ML20245D820

Proposed Tech Specs Changes to Reflect Current Restructuring of Plant Organization

ML20245D820
Person / Time
Site:	Sequoyah
Issue date:	04/17/1989
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20245D811	List: ML20245D808 ML20245D820
References
NUDOCS 8905010181
Download: ML20245D820 (8)

Text

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l ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-89-16)

LIST OF AFFECTED PAGES Unit 1 3/4 6-5 Unit 2 3/4 6-5 1

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ADMINISTRATIVE CONTR0t.S 6.2.3 INDEPENDENT SAFETY ENGINEERING 9999-(ISEd)

FUNCTION l

6.2.3.1 TheISEdshallfunctiontoexamineplantoperatingcharacteristics, %2 NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety. l

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COMPOSITION _ a s nice vry 6.2.3.2 TheISEfshallbecomposedofatleast3 ka ll-time engineers R62 located onsite. Theseengineerswillbesupplementedebygfull-timeengineers shared among all TVA nuclear sitess 4 achse/e. a sh(R g af f oi3,acces.

RESPONSIBILITY'ES 6.2.3.3 The ISEs shall be responsible for maintaining surveillance of plant j 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 TheISEIshallmakedetailedrecommendationsforrevisedprocedures, equipment modifications, or other means of improving plant safety to the

'"~' Directcr cf "uciccr Licencing cnd *.cguictcry ^ffcirc.

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6.2.4 SHIFT TECHNICAL ADVISOR (STA)

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6.2.4.1 The STA shall serve in an advisory capacity to the shif t supervisor R16 on matters pertaining to the engineering aspects of assuring safe operation of the unit. ,

6.3 FACILITY STAFF QUALIFICATIONS R78 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifi-cations of ANSI N18.1-1971 for comporable positions and the supplemental requirements specified in Section A at:d C of Enclusure 1 of the March 28,'1980 NRC letter to all licensees, except for the Site Radiological Control Super- R62

- intencent who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

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'Not responsible for sign-off function.

SEQUOYAH - UNIT 1 6-5 Age,n,dmgtopg,gg H, M 1

ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING 4ROUP (ISEd)

FUNCTION 6.2.3.1 The ISE/ shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources R50 which may indicate areas for improving plant safety.

COMPOSITION ,,g nicas 6.2.3.2 The ISEf shall be composed of at least 3 dedicated full-time engineers - R50 located onsite. These engineers will be supplemented *by 2 full.-time engineers -

I shared among all TVA nuclear sitess to ac.kle A a. s+a4&3 of ' F engtniers.

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RESPONSIBILITIES -

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6.2.3.3 TheISEpshallberesponsibleformaintainingsurveillanceofplant 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_TheISEpshallmakedetailedrecommendationsforrevisedprocedures, equipment modifications, or other means of improving plant safety to the Circctcr cf Nucicer Liccasing and Regulatory Aff airs - . - - -

% Ma,,#8er e[A!dee Ilha0ers br.:

6.2.4 SHIFT TECHNICAL ADVISOR (STA) - _- -s 6.2.4.1 The STA shall serve in an advisory capacity to the shift supervisor on matters pertaining to the engineering aspects of assuring safe operation of the unit.

6.3 FACILITY STAFF QUALIFICATIONS .

R66 6.3.1 Each member of the facility staff shall meet or exceed the* minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of Enclosure 1 of March 28, 1980 fin.C letter to all licensees, except for the Site Red $cingical Contrel Supe.-i v.an..w. h~,

who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

" Nut responsible for sign-off function.

R66 SEQUOYAH - UNIT 2 6-5 Amendment No. 40 66 June 30, 1988

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ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE l

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-89-16)

DESCRIPTION AND JUSTIFICATION FOR PROPOSED CHANGE TO SPECIFICATIONS 6.2.3.2 AND 6.2.3.4 i

ENCLOSURE 2 Description of Change Tennessee Valley Authority (TVA) proposes to modify the Sequoyah Nuclear Plant (SQN) units 1 and 2 technical specifications (TS) to revise specifications 6.2.3.2 and 6.2.3.4 to reflect the current restructuring of TVA's nuclear power organization. The proposed administrative change specifically addresses the Independent Safety Engineering Group (ISEG) with regard to site and corporate staffing and the corporate official to whom ISEG makes recommendations. In addition, TVA is proposing to rename ISEG to Independent Safety Engineering (ISE).

Reason for Change The organizational changes within the management structure of TVA's nuclear power organization have been made to consolidate independent oversight and assessment functions. This organizational realignment would place ISE within the Nuclear Manager's Aeview Group under the newly formed Nuclear Assurance and Services organization. TS 6.2.3.4 currently requires that ISEG make their recommendations to the Director of Nuclear Licensing and Regulatory Affairs.

TVA's stated reorganization would, therefore, require that specification 6.2.3.4 be revised to indicate the new corporate official to whom ISE would make recommendations. This corporate official would be entitled Manager of the Nuclear Manager's Review Group.

An additional proposed change has been made to the composition of ISE with regard to staffing of full-time engineers among TVA's nuclear sites. This change to specification 6.2.3.2 clarifles staffing requirements if more than 3 engineers are assigned full-time at both SQN and Browns Ferry Nuclear Plant sites. The manager of ISE would be located at TVA's corporate office and would serve a generic function to support both TVA sites. The combined manpower would continue to provide a total of five dedicated full-time employees within ISE.

Justification for Change The proposed change to specification 6.2.3.4 reflects current restructuring of TVA's nuclear power organization. The reorganization will continue to provide the appropriate level of independence with regard to ISE's review and auditing functions within TVA's nuclear power program. ISE will continue to perform onsite independent reviews of plant operations under the Nuclear Manager's Review Group within the Nuclear Assurance and Services organization. This change maintains compliance with NUREG-0737 requirements and the standard NRC TSs to ensure that ISE reports to a high-level corporate official in a technically oriented position who is not in the management chain for power production.

The proposed change to specification 6.2.3.2 provides a total of five dedicated full-time engineers within ISE. This proposed ISE composition provides the required level of technical expertise at TVA's nuclear sites to independently assess day-to-day plant activities.

i The assignment of four full-time engineers at each TVA nuclear site will optimize the independent safety assessment functions to comply with NUREG-0737 requirements. The ISE manager (located within TVA's corporate office) would allow effective assessment of generic safety issues between TVA's nuclear sites.

In conclusion, the proposed changes to specifications 6.2.3.2 and 6.2.3.4 ensure that the independent assessment of plant activities by ISE meets or exceeds the requirements of NUREG-0737.

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i I ENCLOSURE 3  ;

j PROPOSED TECHNICAL SPECIFICATION CHANGE l SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-89-16)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS u

j ENCLOSURE 3 Significant Hazards Evaluation TVA has evaluated the proposed 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 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 changes to the ISEG staffing requirements and the title of the corporate official to whom ISEG makes recommendations has not affected the safe operation of SQN. These changes are administrative in nature and serve to reflect recent organizational changes within TVA's nuclear power program.

Since the proposed amendment has not resulted in any changes to hardware, procedures,.or the safety a.ialysis report, the probability or consequences of an accident previously evaluated have not been increased.

(2) Create the possibility of a new or different kind of accident from any previously analyzed. The proposed change to specification

'6.2.3.2 revises ISEG onsite and corporate staffing requirements.

These staffing changes continue to provide a total of five dedicated full-time engineers within ISEG. The proposed change to specification 6.2.3.4 provides a change in the corporate official to whom ISEG makes recommendations. These changes are administrative changes that reflect realignment of the management structure within TVA's nuclear power organization. The proposed amendment does not involve a physical change to the facility; therefore, no new or different kind of accident is created.

(3) Involve a significant reduction in a margin of safety. The proposed revision to administrative specifications 6.2.3.2 and 6.2.3.4 reflects current restructuring of,TVA's nuclear power organization.

These changes in no way affect the physical facility design or safe operation of SQN. The function of ISEG continues to conform with l NUREG-0737 requirements for performing independent review of plant activities. Because compliance with the regulatory requirements has not been compromised and because these changes did not alter the facility or its design, there is no reduction in the margin of safety.

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