ML20212R423

Proposed Tech Specs Changing Responsibility for Review & Audit of App B Tech Specs Due to TVA Reorganization. Description & Justification for Changes & NSHC Determination Encl

ML20212R423
Person / Time
Site:	Sequoyah
Issue date:	04/17/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212R393	List: ML20212R392 ML20212R423
References
NUDOCS 8704270169
Download: ML20212R423 (7)

Text

I ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANCE SEQUOYAH NUCLEAR PLANT DOCKET NOS. 50-327, -328 (TVA SQN TS 87-05)

PROPOSED _ RESPONSIBILITY CHANGES TO SECTION 5.0, ADMINISTRATIVE CONTROLS, OF APPENDIX B LIST OF EFFECTED PAGES S-1 5-2 5-3 l

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5-1 5.0 Adninistrative Controls 5.1 Responsibility

% 4. t h er- 3 The :t:0!;. ;g:rir.ter. der.t hr.s responsibility for operating the plant in compliance with these environmental technical specifications.

5.2 Review and Audit 5.2.1 Review LICEAfSEE The T7f 1,_' _;.., ZuTT is responsible for the review of procedures for meeting these environmental technical specifications.

The above nentioned review shall be conducted on the following:

A. Proposed changes to the Environmental Technical Specifications and evaluated impact of the change. , ,

, B. Proposed changes to station operating procedures, which affect the i

environmental effects of the station. .

l C. Proposed changes or nodifications to station or unit equipment, or systems which might have an environmental impact, in order to detemine the environmental impact of the change.

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5-2 D. All routine reports prior to their submittal to NRC (described in Subsection 5.4.1).

E. All nonroutine reporte prior to submittal of the written report (described in Subsections 5.4.2.a. b, and cl.

F. Investigations of all reported instances of noncompliance with Environ-mental Technica? Specifications, associated corrective actions, and measures taken to prevent recurrence.

5.2.2 Audit (LICEN.SEE)

The T,'.'A Of fi m .T tr belitj Anr== ;..d Audit St;ff shall conduct an Avtur opts /f' f,

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/NMf/AloENTLofYthe environmental monitoring 4 20 0l's prog??$P0tVS/84E fet: t.

of 'r/F /Nbt VfDV4L cR. lY/lf0A/MIA/(p T//f .S/fCIfIC AcTivi ry. l'ESut 5.3 Changes Ts & THf in Station AvoirorAcOoeration Design ri.n r/Fs .sydli (;f />toisrAwr4 ps:b MbiSV4ILAalF hlISWicried Changes in station design or operation may 6e made subject to the following conditions:

A.

The licensee may (1) make changes in the station design and operation, and (2) conduct tests and experiments not described in this document without prior Commission approval.,unless the proposed change, test or experirent involves a change in the objectives of the ETS and/or an unreviewed environmental question of significant impact.

B. A proposed change, test or experinent shall be deemed to involve an unreviewed enviromental question'if it concerns (1) a matter which may result in a significant increase in a,ny, adverse environmental impact

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previously evaluated in the final environmental impact statement as modified by testimony to the Atomic Safety and Licensing Board, sur pienents thereto, environmentai impact appraisals, or in initial or

'inal adjudicatory decisions; cr (2; a ;ign'fi r.t d. , ' Offla;;t; G 2 .

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;;tiu 01.;G;G; ef 10 CT 01; or S 7 a matter not previously reviewed and evaluated in the documents specified in (1) of this section which may have a significant adverse environmental impact.

C. The licensee shall maintain records of changes in facility.desian or operation made pursuant to this subsection. The licensee shall also maintain records of tests and experiments carried out pursuant to O

tg' paragarph "A" of this subsection. These records shall include a written evaluation which provides the bases for the detemination that the change, test, or experiment does not involve an unreviewed environmental question of substantive impact or constitute a change jn the objectives  !

of these ETS. The licensee shall furnish to the Comission, annually or at

. l such shorter intervals as may be specified in the license, a report contain-ing descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

D. Changes in the special studies, if required in Section 4.2, which affect. -

sampling frequency, location, gear, or replication shall be reported to the NRC within 30 days after their implementation, unless otherwise reported in accordance with Subsection 5.4.2. These reports shall describe the

E ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION FOR RESPONSIBILITY CHANGES TO SECTION 5.0, ADMINISTRATIVE CONTROLS, OF APPENDIX B (TVA SQN TS 87-05)

Description of Change This change will revise parts of section 5.0, Administrative controls, of the Appendix B environmental technical specifications. The proposed changes will reflect the new title for the station superintendent and assign the.

responsibility for review and audit to the licensee, instead of a snecific licensee organization. The change will also extend the audit time interval from annual to once per 18 months and delete reference to a defunct section of the Code of Federal Regulations (CFR).

Reason for Change The changes to responsibility for review and audit and the correct title for the station superintendent are necessary to reflect correct titles as a result of the TVA reorganization. Relaxation of. the required time interval for environmental compliance auditing will relieve TVA of additional manpower requirements and the unnecessary burden that is required by the annual audit.

Section 5.3 of the Administrative Controls gives conditions which must be met when making changes to the station design or operation. One of the conditions precludes significant changes in effluents or power level in accordance with requirements in section 51.5(b)(2) of 10 CFR 51. These specific requirements have been deleted from the CFR and no longer need to be referenced in the technical specifications.

Justification for Change The proposed change is necessary due to a TVA reorganization that eliminated the TVA Regulatory Staff. This change will assign the responsibility for review of procedures to meet the environmental technical specifications to the licensee. Holding the licensee responsible for this review, instead of a specific TVA organization, will eliminate the need for future technical specifications changes as a result of further TVA organizational changes.

Additional changes in the TVA reorganization will give the Environmental Quality Staff (EQS) responsibility for nonradiological environmental compliance auditing at TVA's nuclear power plant sites. This responsibility is being shif ted from the Power Quality Assurance and Audit Staff. The Division of Quality Assurance will work closely with EQS to ensure a smooth transfer of responsibilities. As with the change in responsibility for review, this proposed change will assign the responsibility for audit to the licensee, apposed to a specific TVA organization. .,

INGen a a C The proposed change also requests an increase in the audit period from annual to once per 18 months. This request is based on EQS's audit experience at Sequoyah, Watts Bar, and Browns Ferry Nuclear Plants and over ')ur years of conducting environmental compliance audits at TVA's coal-fired steam plants, the hydro plants, the National Fertilizer Development Center, and many other facilities. EQS believes that environmental requirements at nuclear plants with respect to air, water, and solid and hazardous wastes are not appreciably different from those at other facilities, and that audits on an 18-month basis will provide manar,ement with the necessary information relative to the status of environmental compliance at the plant.

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General requirements for environmental impact statements, negative declarations, and impact appraisals have been deleted from the CFR due to a turnover of these responsibilities to the Environmental Protection Agency (EPA). In consideration of the provisions of tnw Clean Water Act (33 USC, Section 1251, et seq.) and in the interest of avoiding duplication of effort, the conditions and monitoring requirements related to water quality and aquatic biota are specified in the National Pollution Discharge Elimination System (NPDES) Permit No. TN 026450 issued by the United States EPA to TVA.

This permit authorizes TVA to discharge controlled waste water from Sequoyah units 1 and 2 into the Tennessee River.

, NRC will be relying on the NPDES permit for protection of the aquatic environment from nonradiological effluents. This is referenced in sections 3.0 and 4.0 of the Appendix B technical specifications.

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ENCLOSURE 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS FOR RESPONSIBILITY CHANGES TO SECTION 5.0, ADMINISTRATIVE CONTROLS,.0F APPENDIX B (TVA SQN TS 87-05)

1. Is the probability of an occurrence or the consequences of an accident previously evaluated in the safety analysis report significantly increased?

No, the changes in responsibilities for review and audits in the environmental technical specifications will not prevent these jobs from being performed. This job function will still be performed by the licensee in a satisfactory manner in order to meet the requirements.

Extending the audit time interval to 18 months will still provide the necessary information relative to the status of environmental compliance.

2. Is the possibility for an accident of a new or different type than evaluated previously in the safety analysis report created?

No, the proposed changes to the environmental technical specifications do not present new or different safety concerns. These changes will ensure that the licensee is responsible for compliance of these specifications.

3. Is the margin of safety significantly reduced?

No, safety is not effected by the changes to the environmental technical specifications. These changes effect responsibility for review and audits and thus the margin of safety is unchanged.

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