ML20214F415
| ML20214F415 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/18/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214F407 | List: |
| References | |
| TAC-R00143, TAC-R00144, TAC-R143, TAC-R144, NUDOCS 8705260071 | |
| Download: ML20214F415 (74) | |
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l . ENCLOSURE 1 .. PEOPOSED TECHNICAL SPECIFICATION CHANCE , l SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET Nos. 50-327 AND 50-328 (TVA-SQN-TS-87-34) LIST OF AFFECTED PAGES Unit 1 Unit 2 6-1 6-1 6-la 6-2 6-2 6-3 6-3 6-4 6-4 6-5 6-5 6-6 6-7 6-9 6-7a 6-10 6-8 6-11 6-9 6-12 6-10 6-13 6-11 6-14 6-12 6-15 6-13 6-16 6-14 6-17 6-15 6-18 6-15a 6-19 6-23 6-28 6-24 6-29
- 6-25 6-30 l 6-26 6-31 1
6 P PDR l
{ _ . f, 6. 0 ADMINISTRATIVE CONTROLS sE 6.1 RESPONSIBILITY
/ lane . 6.1.1 The Plant "~-- 'it*t' "--' shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his p ga ,,a s e e e t 9 a d io9h :ce l C . J ro l 6.1. 2 The " ' " "'-' ;'-" ". :' - "--- ' , shall be responsible for imple-menting the radiological environmental program and dose calculations and projections
______.co:st.<_. as described
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in..__,_______ the Offsite Dose Calculation Manual
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(ODCM). JEhee. 7 _: '. : .: -: . 6.1. 3 The Shift Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command function. A management directive to this effect, signed by the 4dAE-EE Sitat '
- -! ':':- Director, shall be reissued to all station personnel on an annual basis.
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- 6. 2 ORGANIZATION OFFSITE 6.2.1.1 The offsite organization for unit management and technical support shall be as shown in Figure 6.2-1.
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m ,r : ~ ' ~ UNIT STAFF 6.2.2 The Unit organization shall be as shown in Figure 6.2-0 and: a. Each on-duty 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 Control 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.
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SEQUOYAH - UNIT 1 6-1 '
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ADMINISTRATIVE CONTROLS
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- c. A '02'*" 7 "p ' r: technician, shall be onsite when fuel is in the l
,, reactor. l
- d. All CCRE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation,
- e. A Fire Brigade of at least 5 members shall be maintained onsite at all times. The Fire Brigade shall not include Amembers of the FP minimum shift crew necessary for safe shutdown of tne unit or any i personnel required for other essential functions during a fire emergency.
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ft $iff Superussor wel 2 o$er M c Q u l Co davl.
# Ine :C r p .:::: technician and fire brigade ccmcosition may be less than the minimum requirements for a period of time not to exceed 2 hours in orcer to accommodate unexpected absence provided immediate action is taken to fill
- the required positions.
SEQUOYAH - UNIT 1 6-la CEI
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General
. Manager ** " (. '
1 huclear Saf Review ff Manager of Power g . N ear Safety eview Board Manager of Power Operations
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' Nuclear Power Division j
- Safety Staff
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I Ass't. Director Maintenance & Ass't. Director Engineering Services Nuclear Operations l Nuclear Maintenance Nuclear Operations Branch Coordinator Controls and Nuclear Operations Test Branen Stati Reactor E neering Preoperational *
- B cn Test Staff A
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tage Manacement clear Training Branen Branen .
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Nuclear curity Brank
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Suoerentencant Seouovan
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- Responsible for Fire Protection.
Figure 6.2-1. Offsite Organization for Facility Management and Techniest Sucport. SEQUOYAH - UNIT 1 6-2
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Z . - g mRECTORS C nENCHAL MANAGER Z 5 . s
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l MANAGER 14 iv. , OF
, NUCLE AR POWER DEPUf f MANAGER NSRD L
NUCLE AR Sitt pHECTOR unLCIOR NnECTOR DenEC TOR OIRECTOR OlRECTOR an[CTORS Ala0 OF OF OF- OF OF OF NUCLE AR PHOJECT NUCLEAR ggucggan Nt?CLE AR NUCLEAR NUCLEAR " #9-MANAGERS cot 4S T H UC TION 04 ENGINEEnlNO SERVIC ES TRAINtNG ' S AIETV & LICENS8NG Figure 6.2-1 Offslie Organization for Facility Management and Technical Support 6 J
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.s PLANT SUPERINTENDENT SAFETY l SUP SOR ENGINEERING * -
TAFF
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HYGIENE ASSISTANT PLANT
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BRANCH % SUPE RINTENDENT OA ENGINEERS i N ~~. . .. ... . ..
- HEALTH .. SULTS OPERA 7hNS MAINTENANCE PHYSICS S VISOR SUPE $1SOR SUPERVISOR
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^ HEALTH PHYSICS TECHNICA AS$1STANT ASSISTANT TECHNICI ANS ENGINEERS
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SUPERVISOR SRO SUPERVISORS TECHNICI ANS. / _ SHIFT FOREMEN AND FOREMEN ANW ENGINEER SRO INSTRUMEN/ MECHAN
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'Responsibilary for Fire Protectio #' rogram A'Sd>6 TANT SHIFT'L%INEER
\\ SR3 SRO - Sen or Reactor Opera,wfLicense RO - Reactor Operator Lernse UNIT OPERATO\R\
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Figure 6.2-2. Facility Organization - Sequoyah - Unit 1 Fisuu 'N
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b LAHes Ho ac scHEout.iHo! j -- op g3 A sEn IbEs l PLANT M O Dif*1C ATION LIC SING ' PROJECT MAHACER MANAGER l M AN AG E'R MANAGER uaHAotR ENGINEER l (* ORS l ----IttJDUSTRI AL SArETY *l i l I HUCLEA POWER ftADIOLOGICAL MAlHTENANCE m SUPERIHTENDENT CONTHOL SUPERINTENDENT e s u l 1 l l l l l SIT E TECilNICAL ELECTRICAL IN M 4T - MECHANICAL NN'lSN CHEMISTRY l SUPPORT SUPERVISOR Sno l SECURITY S u P E RviS o R SUPERVISOR ASST OPS SPECIAL M AtHT EN ANC E SUPERVISOR PROJECTS PLAN NIN G SRO S U P E RVis OR .. SUPERVISOR SHIFT SUPERVISOR SRO '
- Responsibility for Fire Protection Pro g ra m SpirT SRO - Senior Recolor Operator Lloense
, Tg>H,1 CAL RO,- Recolor Operator: Lloense ASST SiliFT LEGEND SUPERVtpOR SRo ADMINISTRATIVE AND . TECHNICAL REPORTit4G FUNCTIONAL REPORTING ' UNIT OPEl%ATOR RO , FIGURE 6.2-2 .-* ' FACILITY ORGANIZATION - SEQUOYAli NUCLEAR PLANT-t 'l 0 H. 4 t =s l e s . e
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, I NIS b6 022. LS 36Le~7ED General
- Manager f
Occupa al fice of Power Health _. . , . Safety j N
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Division of Nuclerr ?ower
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Radiological Plant Hygiene Superintendant Branch L Radiolo ' Results Assessrnent Section Sectidn
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Figure 6.2-3. Offsite Organization ~ for Monitoring Program and Dose Calculations.
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i- SEQUOYAH - UtiIT 1 6-4 1
~. - ', TABLE 6.1-1 ;' '
- VEILLANCE REOUIREMEN PERFORMED BY
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RADIOLOGICAL HYGIENE BRANCH
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4.11.1.2 4.11.1.3.1 s '4.11.2.1.1 (partial) 4.11.2.1.2 (partial) 4.11.2.2 . 4.11.2.3
- 4.11.2.4 4.11.4 4.12.1 4.12.2-4.12,3 4
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4 . q., .' , ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) , FUNCTION 6.2.3.1 The ISEG shall function to examine NRC. issuances, industry advisories, Licens @*Event plantReports operating' andcharacteristics, other sources which may indicate areas for improving plant safety. l COMPOSITION 6.2.3.2 The ISEG shall be composedRT liAST 3 of at icu fisc dedicated full-time engineers located onsite. These GN4WCCRS U)W. be SUff einenied d by A. EUSE* T#m0 engsne.sr3 ShMed among All Tyn smTc.leM . Sites. RESPONSIBILITIES ~ 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant 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 ISEG shall make detailed recommendations for revised procedures, equipment s .:-+--. n.modifications, ora--other means of improving plant safety to the
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5.~b[g5c.SU(Idu5.e5ENN$elsdd Y EIEEN$1No. ~ ~ ' '" ~ ~ ~'~ v 6.2.4 SHIFT TECHNICAL ADVISOR (STA) 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 h the unit. 4 () 6.3 UNIT STAFF OUALIFICATIONS 6.3.1 Each member of the unit 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 28, 1980 g NRC letter to all licensees, except for the Mc.:tt ".t si; bt who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. l Site. %diolo_9 c.nl i Coa +noL SwcrM end eat "Not responsible for sign off function. U AD n c vM mnaov 6.~- SEQUOYAH - UNIT 1 6-7 *
=d:;nt No. M
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ADMINISTRATIVE CONTROLS $ 6.4 TRAINING .
/Ju cle M 70 W O f 1
6.4.1 A retraining and replacement train program for the un'it staf f shall be maintained under the direction of the , .: '_.
; c_ :____ __ __. and shall meet or exceed the requirements and recommendations of Section 5.5 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 - letter to all licensees, and shall include familiarization with relevant industry operational experience, . ..... . 4
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- 6. 5 REVIEW AND AUDIT har ,
6.5.0 The Manager of4 Power is responsible for the safe operation of all TVA power plants. The functional organization for Review and Audit is shown on
. Figure 6.2-1.
6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)
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FUNCTION 6.5.1.1 .jaosager The PORC shall function to advise the Plant C r- ....__.. on all matters related to nuclear safety. - /g . I ;.
- COMPOSITION 6.5.1.2 The PORC shall be cc= posed of the:
Chairman: P1 ant [.# E _.._ Member: - Member: h Member: "; M _ ;;.;; : _7 ; - '::- Mecser: . _ _ _ _. . c_ - _ : _ : _c ; c ' _ ; . 2 . ,1 Me:ber: ',c';';:
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, s n e % :ol.3N1 c.,61 foreriMe+ l Ata:e%~e Cose Maager , (1), (e) or (n) j 1elacal futf.it.cus:as G<.g Man 3er Gal lly Fag lneerisy ad Cm%l pgger SEQUOYAH - UNIT 1 6-7a --
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-- ADMINISTRATIVE C0f!IRO'5 ALTERNATES l 6.5.1.3 All alternate necoers shall te a::pcinted in writing by the PORC i
Cnairman to serve on a tecpora y t, asis; ho-ever, no ccre than two alternates. j shall.participa*e as votine needers in DDR a:tivities at any one tine. ; 1 PEETING FREDUENCY E.5.1.4 The PDRC shall meet at least once per calencar month and as convened by the PDRC Chaiman or his cesignated alternate. OUORLH E.5.1.5 The minimum ouerum cf the PORC necessary fer .he perfc =an:e of the PORC responsibility and authority provisions of these *echnical spe:ifications shall consis: of the Chairman or his designated alternate and four mer.oers including alternates.' - > 4 %q F.c 4e eversi W- 3 rev;ewof sekM saf ety evaluations f or: (1) procedures, (2) change ; 1to procedures, eauipment, systems or facilities, and (3) tests or RESP 0H5IEILITIEs ,. experiments completed under the provision of 10 CFR 50.59 to r ' verify that such actions did not constitute an unreviewed safety M*%
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- 5.1.6..The PORC,shall be responsible for.
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l Q 'WhtTA5!E EV!XC- . l d, / Review,allp ':._ _. l 8,.eT Review of unit coerations, to cetect ;:ctential nuclear safety ha: arcs.
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, SEQUOYAH - UNIT 1 -
E-S * * - * -* * * " " a .. Revice of pre::cset crc:ecures and changes ic pro:edures.pr*SN5 e:vi::mer.;, sysic:.s er f a:ilities wt.i:h einvolve an.unrevi, ewe.j , i saf ety cuestien as cefined in 10 CFR 50.5e, ; i l
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p* y. Perfc r.an:e of special reviews, investigations or analyses and repe- s inereon as recuested by .ne Plan : . . . - ' ; . ' d u . cr ine. Nu: lear Safety Review Board. -ht e." ' 2,
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. . . . .. . ...s gx Review cf every unplanned ensite release of radioactive caterial ic the environs in:luding the preparation and forwarding cf reports covering evaluation, reco=mendations and disposition of the c=rre:*ive anion o prevent recurren:e to ini irener, " :':: : "' ' 'd and to the Nu: lear Safety Review Bo@ard.
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. 5.5.1.7 The PDP.C shall: ,
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- h. :' P ovide v-inen n:. ifica-ion witnin 2' h:urs *.o the,Diren:r, ':..' r.:
is_. between :I ::i::the and PSP.; .he and Nu:the lear'Plant Safe:v Review Esa-d =f disa:reement
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/-ater isa; eemen s pursuan .e 5.1.1responsitility E:ove. fer esolutica of su:n
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E.5.1. B The PDR: shall =aintain wrinen minutes Of 'ea:h POR meeting that, at
-a mini ===, d::= ment .he resul .s cf all DDR a::ivities perf: red unoer the
' resconsibility and authority p ovisiens of these ternnical roe:ifi:ations. -
C: pies shall be proviced .o .he,.Diren:r, ....'.__. T. .. :' :. :: - and -he. i
- n.. Nu: lear Safety Review Ecarc L 5p- - - -
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4 asfert. Al E.E.2.1 Tne H5EE shall fun: icn : provide ndependent review and audit 'cf ' designnzed anivi:ies in the areas ef: O . A SEQUDYAH - UNIT 1 E-9 l m m- -- - - - , , , , - - ~ , - - - , - - -- --, . , , - , , , , . , - , , . . , , , - - . , - , - . -
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INSERT: .Section 6.5.1A
.l 6.5.1A TECHNICAL REVIEW A'ND CONTROL
{ ACTIVITIES - j
. 6.5.lA.l. : Activities which affect nuclear safety shall be conducted as ^
-follows:
I
- a. -Proce'dures' required b'y Specification 6.8.1 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 c organization as.the individual who prepared the procedure or-procedure change. Procedures shall be approved by the appropriate j responsible manager as; designated,in writing by the Plant Manager or Site-Director as appropriate. The Site Director, Plant Manager,' NPP Superintendent, or Maintenance. Superintendent shall approve designated Administrative Procedures.
- b. Workplans used to implenent proposed changes or modifications to plant nuclear safety-related structures systems, and components 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 as the. individual / group which designed the modifications. Proposed modifications to plant nuclear safety-related structures, systems, and components and the implementing workplans shall be approved' prior to implementation by the Plant Manager, NPP Superintendent, or Maintenance Superintendent. i
- c. Procedures for. proposed tests and experiments which= affect plant nuclear safety and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed,-'and approved. Each such test or experiment shall be reviewed by a .
qualified individual other than the individual who prepared the procedures.for the proposed test or experiment. Procedures for proposed test and experiments shall be approved before implementation
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by the Plant Manager, NPP Superintendent, or Maintenance
- Superintendent.
1
- d. Proposed changes to the~ Appendix A Technical Specifications shall be prepared by a qualified individual / organization. The preparation of each proposed Technical Specification change shall be reviewed by an
~ individual / group other than the individual / group which prepared the. proposed change, but who may be-from the same organization as the individual / group which prepared the proposed change. Proposed changes i to the Technical Specifications shall be approved-by the Plant Manager. j e. Individuals responsible for reviews performed in accordance with Specifications 6.5.lA.la, -b, -c, and -d shall be designated by approved written procedures. Each such review shall be performed by qualified personnel ~of'the appropriate discipline and'shall include a determination of.whether or not additional, cross-disciplinary review ' is necessary. . Each review in items a, b,'and c shall include determination of whether or not an unreviewed safety question is involved pursuant to Section 10 CFR 50.59. 4 1
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f J ' -ADMINISTRATIVE CONTROLS I a. nuclear power plant operations ^
- b. nuclear engineering
'., c. chemistry and radiochemistry
- d. metallurgy
- e. instrumentation and control 6
- f. radiological safety s
- g. mechanical and electrical engineering
- h. quality assurance practices
; COMPOSITION .
6.5.2.2 The N5RB shall be composed of at least five' members, including the Chairman. Members of the NSRB may be from the Office of Power, or other TVA organization or external to TVA. l.
-4 OUALIFICATIONS Nuclear 6.5.2.3 The Chairman, members, and alternate members of the NSRB shall be appointed in writing by the Manager)ofs Power and shall have an academic degree.
in engineering or a physical science field, or the equivalent; and in additien, O shall have a miniraum of five years ' technical experience in one or more areas j given in 6.5.2.1. No more.than two alternates shall participate as voting . members in NSRB activities at any one time. CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the NSRB Chairman 'to provide expert advice to the NSRB. - 4 MEETING FREOUENCY 6.5.2.5 The NSRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per-2 six months thereafter. 4-t OUORUM i
. 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the NSRB review and audit functions of these technical specifications shall consist of more than half the NSRB membership or at least 5 members, whichever is greater.
This quorum shall include the Chairman or his appointed alternate and the N5RB members, including appointed alternate members, meeting the requirements of r Specification 6.5.2.3. No more than a m.inority of the quorum shall have line responsibility for operation of the unit. j .
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SEQUOYAH - UNIT 1 6-10 i I 4 l sw ,-- - - - - ~ * ' r en' '- ,w-*---m~-mw - -~,-tm~#-< -- --- -'--- - - >--v --mr- omv w we - -- *-- r~ ww ^'n"
ADMINISTRATIVE CONTROLS 9 ' REVIEW r 6.5.2.7 TheNSRBshallreviewg be co3niaa.d of
- a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- c. Proposed tests or experiments which involve an unreviewed saft.ty question as defined in Section 50.59, 10 CFR.
- d. Proposed changes to Technical Specifications or~this Operating License.
- e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f. Significant operating abnormalities or deviations from normal and .
expected performance of unit equipment that affect nuclear safety. T
- g. All I *E1bitTABLE.
- - EvfArrd.
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- :;M' ;; 2' ':r n:t::t':: 1: th: ::- .::':-
- h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
SON
- i. Reports and meetings minutes of the PORC and the RARC.
g AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass:
- a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
- b. The performance, training and qualifications of the entire unit staff at least once per 12 months.
- c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that rffect nuclear safety at least once per 6 months.
- d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50,
- at least once per 24 months.
SEQUOYAH - UNIT 1 6-11
' ~
.- .f.. ADMINISTRATIVE CONTROLS -
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- e. The Site Radiological Emergency-Plan and implementing procedures .at' '
- least once per 12 months. ~ ~
s t f.
-The Plant Physical Security, Plan, the Safeguards Contingency Plan,
!, and implementing procedures.at least once per 12 months. . gi Any other area of unit operation con ~sidered appropriate by the NSRB
-or the Manager of yPower.
, Nuc.ItAR.
- i. h .' The Facility Fire Protection Program and implementing procedures at least once per 24 months.
i i. An independent fire protection'and loss prevention program inspection j and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection-firm.~
;_ j. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
- k. The radiological environmental monitoring program and the results L
thereof at least once per 12 months. 4
- 1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at
- 1. east once per 24 months.
- m. The PROCESS CONTROL PROGRAM and implementing procedures for
- SOLIDIFICATION of radioactive wastes at least once per 24 months.
4 1 n. The' performance of activities required by the Quality Assurance t Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974_and Regulatory Guide 4.1, Rev. 1, 1975, at least-once per 12 months. p y
- j. AUTHORITY i NucLCA k n 6.5.2.9 The NSRB shall report to and advise the Manager o areas of responsibility specified in Sections 6.5.2.7 and [f Power .5.2.8.on those l t RECORDS 3
6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed-as indicated below: i .;
- a. Minutes of each NSRB meeting shall be prepared, approved and forwarded i
to the Manager ofyPower within 14 days following each meeting. :' NUCLERR. i b. Reports of reviews encompassed by Section 6.5.2.7 above, shall be i prepared, approved and forwarded to the Manager ofq Power within 14 days following completion of the review. , NudLERR. 1 ' .* sner SEQUOYAH - UNIT 1 6-12
^= nt:nt ":. '2~
.I ADMINISTRATIVE CONTROLS NUtt.E A R. -
~
- c. Audit reports enco. passed by Section 6..E 2.8 above, shall be forwarded l to the Manager of Power and to the roan,- .: ment positions responsible l for the areas audited within 30 days aster completion of the audit.
6.5.3 RADIOLOGICAL ASSESSMENT REVIEW COMMITTEE (RARC) Function SW Maunu.A of Control., 6.5.3.1 The RARC shall function to advise the Chic', Radiological d'er _ = E :=n, on a#Il matters related to radiological assessments involving dose calculations and projections and environmental monitoring. asJ-MeComoosition Plaf .wam9er. Syl 6.5.3.2 The3 RARC shall be composed of the: TLt.MNSCA1. RSSISTRNCE. Chairman: Da*c'ccic=' ^reeer e-t Section Supervisor Member: Health Physicist, Gaseous, Radiological "rf e"e D-"c6 CONTRDL Member: Health Physgist, Liquid, Radiological Wyf- P2 c' CcNfROL Member: Meteorologi-_: 2;;hccr, Air Quality Branch Member: Chemical Engineer twubLt.' Alternates genyh psysjeisr,Q, RsNyg halts Section, 9 "T$ .2ndiological. 00& 6.5.3.3 All alternate members shall be appointed in writing by the RARC .SSN 3 Chairman to serve on a temporary basis owever, no more than two alternates shall participate as voting memcers in RC activities at any one time. Meetino Frecuencv 6.5.3.4 TheSGhl OR. n narc shall meet at least once per six monte.s r; as ?E.qutSTLD
- c. . n _ cy the yRARC Chairman.+c.,his designated alternate OR3 A p14NT 'REF8 LSCA /7471vE..
494 Ouorum
.Sohl 6.5.3.5 The minimum quorum of the3RARC necessary for the performance of the S$M RARC responsibility and authority provisions of these technical specifications aiternates) 92 Long As cuc is A plRNT REPRE SENTATivE.shall consist of t Resoonsibilities 6.5.3.6 SW #
Then NARC shall be responsible for:
- a. Review of changes to the OFFSITE DOSE CALCULATION mar,UAL.
b. Review of procecures requ' ired by Specification 6.8.4 and changes thereto.
. FOR INFoRinRThost 'PURPOSLS PLvoLWS* og, CyaLUAT/oNS *
- c. Review 3 cf tne results of any avaits,3o7 the Quality Assurance Procram for ef fluent ana environmental monitoring / Arvo 7tnolotegicnL /73345sincurs lNVC]ViNg dCSE f VAlunT/ CMS RuD 'PRoj&c.Tious.
SEQUOYAH - UNIT 1 6-13
ADMINISTRATIVE CONTROLS
- d. Review of proposed changes to the Technical Specifications related to radiological assessments involving dose calculations and projections and environmental monitoring.
RA0iolog scRL Authority 6.5.3.7 ThehRCshall: Maungen of Coa +eoL and h %.RNT
- a. Recommend in writing to the C"icf, Radiological Hygiere Ermcb n)gungs.A, approval or disapproval of 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.
ppygggg. dNUC.L6AR. NL '
- c. Provide written notification within 24 hours to the Di ec & ""c'"-
ome r n4uiginn and the N g g gfgg Rg g g gypg ere
.cg'c2!
f disagreement 0-ench; however, betweenJh the % e~, =_._.yn. g g tg g M @ barch shall have responsibility for resolution of such disagreement pursuant to 6.1.2 above. Records SSM .SSM 6.5.3.8 The3 RARC shall maintain writtpgminutes of eachaRARC meeting that at aminimum,documenttheresultsofallfRARCactivitiesperformedunderthe responsibility and authority provisions of these technical specifications. Copies shall be provided to the Di ectcr, "uc'ccr Y.sc "# i io the Nuclear Safety Review Board. mnungcR of Nuc14MR 'Four;a.n, PORC, and 6.6 REPORTABLE EVENT ACTION 7 ( 6.6.1 The following actions shall be taken for REPORTABLE EVENTS: ) (
)
- a. The Commission shall be notified and a report submitted pursuant to the requirements of Section 50.73 to 10 CFP, Part 50, and
(._ (
)
- b. Each REPORTABLE EVENT shall be reviewed by the PORC and the results l
/
of this review shall be submitted to the NSRB and the C"ccrcr,Sitt 'DlMc7c4 "c' 2 - E c- Di'#:icr T 6.7 SAFETY LIMIT VIOLATION 1 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 STANDSY within one hour.
- b. The NRC Operations Center shall be notified by telephone as soon as ;
possible and in all cases within one hour. The Dir^ct:- "o c ' c c r SITE. l
@RtcTo R. "n:cr Ci i:ica and the NSRB shall be notified 4 24 hours.
w'.th*ws 5 c.n i . ::, '0N _ SEQUOYAH - UNIT 1 6-14
- nc,,= :nt '!c. "
ADu.INISTRATIVE CONTROL $ \
~
I
- c. A Safety Limit Violation Repo-t shall be prepared. The report shall be reviewed by the PDRC. Tnis repor. shall oes: ribe (1) appli:able circu=stan:es preceding the violation (2) effects of the violation upon fa ility co=ponents, systems or structures, and (3) Corrective action taken to prevent re:urren:e.
- d. The Safety Limit Violation RepoF. shall be submitted to the Co:=-ission,
-c; 'i .: kn within 14 cays of the HSRB and the; Director,- L ; L ?
the violation. ~+ SW:. 5.8 PRD Edt!RES & DRDGRA".5 5.E.1 Written procedures shall be established, icpiemented and maintained covering the activities referenced below: -
- a. The applicable procedures recommended in Appendix "A" of Regulato y Guide 1.23, Revision 2, February 1578. -
. b. Ref'ueling.. operations.
- e
- c. Survei11anze and test a:tivities of safety-related ecuipment.
Plant Physical Security Plan implementation. d.
, e. ' Site Radiological Emergency Plan implementation.
a
,. f. Fire Protection Prog a= implement-tion. .
- g. PP.3 EES CDNTRDL PRD3 Rte, i=ple=entation.
- h. Quality Assuran:e Pro; a= for effluent zionitoring, using the guidan:e contained in Regulato y Guide 4.15, De:e=cer 1577, or Regulato y Guion 1.21, Rev.1,1574 and Regulato y Guide ,4.1, Rev.1,1575.
5.E.2 Ez::h procedure o5 E.E.1 above, and changes T.he eto, shall be reviewed i, th: 'C'.: and a:p oved b. t'.: ~~ --- :
' : * . .:nd:n; p-ior to icole=entation
-:nd :~/ ;. .f ;: ':f ? ::.7 s as s et f orth i n .d. .' - i r : : ; ::::r-.:. '
arnwd 4 ebys 4. L 5,=M.n t..r.ui Gbve E.E.3 Tecoora g y eneasee w p o:edurefg E.E.1 above may be made provided: 1 ':, ' ' :-t :' ": r ';i ; m i n i: n:t :---f_
, ;' 4 - , d,/I The change is a:,p oved by two me=be s of the plant canagement staff, at least. one of wno: holds a Senior Rea: tor Doerat.or's License on the unit af.fe: ed. A. meek.%e. noulremeni;s of t S 'cM^ M'lh*cl*
. u .
- b. /? - "The change is du _nt:.d, n i:s:d i th:
~~~
' approved b; ":
. ... ; ,_. ...... :..yvi:nin 24 cays of i=clementation.
"- in c.::onAnr c. wit'% .5f eC :J.im I..r.//! G-c..
E. E. 4 Written ; o:ed: es shall be ' established, icolemented and maintained by
- .ha Radiological .j;k.;; :n:h- covering the a:tivities below: .
.; . ~
% C nrol . .. .
~ - .
.- c a. , DFF5.'TE DOSE 0.ALOULATIONAL MANUAL implementation..
SEQUDYAH - UNIT 1 . - E-15 . -
- r. ...-.....',.. C
~
4
, ADMINISTRATXVE' CONTROLS'
-b. Quality Assurance Program for environmental monitoring,' using the guioance contained in Regulatory Guide 4.15, December.1977.- j 3_
- . c. Surveillance requirements and environmental monitoring-requirements j shown in Table 6.1- g l 6.8.5 rograms i The shalloccon:
be established,Se<h 4.s.id :mplemented, ead-maintaine{ ond followingc.%es - p%=414 lance wiW
- a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. -The systems include the charging system, safety. injection system, residual heat removal system, chemical and volume control system, containment spray system,- iodine cleanup system, and hydrogen recombiner system.
+ - The program shall include the following: *
, (i) Preventive maintenance and periodic visual inspection requirements, and .
[ (ii) Integrated leak test requirements for each system at refueling
- cycle intervals or less.
- b. In-Plant Radiation Monitoring 1 '
A program which will ensure the capability to accurately determine the airborne iodine concentrations in vital areas under accident conditions. This program shall include the following: (i) Training of personnel, (ii) Procedures for monitoring, and ! (iii) Provisions for maintenance of sampling and analysis e'quipment.-
- c. Seconda-v Water Chemistry A program for monitoring of secondary water chemistry to inhibit steam 1
generator tube degradation. This program shall include: (i) Identification of a sampling schedule for the critical variables and control points for these variables, - ,. (ii) Identification of the procedures used to" measure the values of , J the critical variables, - (iii) Identification of process sampling points,
;_., ., ~:
^
SEQUDYAH - UNIT 1 6-15a ......-~..o. 1
sADMINISTRATIVE' CONTROLS
. e .
-6.10.2 Thefollowingrecords.shallberetainedforthedurationo'ftheUnit Operating License:
- a. Records and drawing changes reflecting unit design modifications-
[- made to systems and equipment described in the Final Safety Analysis i . Report. .
- b. Records of new and irradiated fuel inventory, fuel. transfers and assembly burnup histories.
!' c. Records of radiation' exposure for all individuals entering radiation
; control areas.
- d. Records of gaseous'and' liquid radioactive material released to the environs.
e.. Records of transient or operational cycles'for those unit components
~
identified in Table 5.7-1.
. f. Records of reactor tests and experiments. -
. g. Records of training and qualification for current members of the unit staff.
- h. Records of in-service inspections performed pursuant to these
~
2 Technical Specifications. - i.
,$ ' NUCLLAR.
Records of Quality Assurance activities required, he Ope eti r a!
, Qual,ity Assurance Manual. '
1 t
- j. Records of reviews performed for changes made to procedures or equipment'or reviews of tests and experiments pursuant to 10 CFR 50.59.
- k. Records of meetings of the PORC, RC, and the NSRB.
- 1. Records of analyses required by the radiological environmental monitoring program. -
m. Records of secondary water sampling and water quality.- j n. j Records of the service life monitoring of allt safety related hydraulic and mechanical snubbers, required by.T/S 3.79, including ! I the maintenance performed to renew the service life. o. Records for Environmental Qualification which are covered under the
-provisions of Paragraph 2.c.(12)(b) of License No. DPR-77.
M 6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared' consistent-i with the requirements of 10 CFR Part 20 and shall'be approved, maintained and adhered to for all operations involving personnel radiation exposure. 1 i l l
. i SEQUOYAH - UNIT 1 6-23 l ;t-' t ':
4 . ,
, . _ ;__.-_ _ _ . , _ . a _. _ _ _ . . _ . _ _ _ __ _- _ _ _ __ . _ _._ .i_i
' - ADAINISTRATIVE CONTROLS 6.12 HIGH RADIATION AREA - *.
6.12.1 In lieu of the " control device" cu " 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 i
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 activities within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance at the
' frequency rpecified by the facility 9::lth "hysicitt in the Soecial l (Radiation) Work Permit. .
3874-PACdoLCS'C8L C887 DOL l,
.9UPER. m%Lenk 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 control of the Shift E~;i e r on duty and/or the .9c:lth "hy fcist.Sita Pao /o.LogicML 00 ovPE.RVISoR. c Su PE.R.Lnkndet& 6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 Licensee initiated changes to the PCP: R4E 1. Shall be submitted to the Commission in the semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made. This submittal shall contain:
- a. sufficiently detailed information to totally support the rationale !
for the change without benefit of additional or supplemental information, ! BAdioloa senL GoumoL , 2nwaoaaL Goivreob "M:2!!h onyric: personnel or personnel escorted by 90:lth Thy;ica personnel in l accordance with approved emergency procedures, shall be exempt from the SWP issuance requirement during the per.formance of their assigned radiation lll protection duties, provided they comply with approved radiation protection ~ i procedures for entry into high radiation areas.
- =====- T', 1??E SEQUOYAH - UNIT 1 6-24 ^ end::nt '! .^' l
} .,
.' iparINISTRATIVE CDNTRDL5 i
- b. a determination that the enange did not recu:e the overall con- . l
. forzance of the solidified waste procurt te existing. riteria for solid wastes; and
, . c. do:umentation of the fa:t that the change has been reviewe'd and
. found a=eptable i, th. T:'".16 dWodact w% secOe4 &.S.14.
4 2.- Shall become effective upon review and n; gin is th, r;T.~. t f.rgre. sal in as=aralaat. E.24 0FFSITE DDSE CALOULATIDN MANUAL (DD;M) wWn 5e414 t. .r. s A. . - j-E.24.1 The DDOM shall be approved by the Comission prior to implementation. 4 E.14.2 Licensee initiated changes to the DDr?.:
. 1. Sha'll be submitted to the Comission in the next Semi-Annual Radio- -
anive Effluent Release Report pursuant to Spe:ifi:ation E.9.1.2. %- This sue =ittal shall contain: . ..
~.
- z. sufficiently detailed infomation to totally support the rationale for the change without benefit of additional or supplemental l
. information. Information submitted should consistent of a "
j package of those pages of the DDr.M to be changes with each page .
.nu=bered and proviced with an approval and date box, together j . .
with appropriate analyses or evaluations justifying the change (s); I t
- b. .a deter =ination that the chan5e will not reduce the a=ura:7 or l
) _. .. reliability of cose calculations or setpoint ceter=inations; -
. a.nd -----. _ . . . .
- c. . documentztion of the fact that the change has been reviewed and ~
ft:F.d a=ejitable by ::n-P.ARO. .
. 2. Shall be:ome effe:tive ucon review and a::eptanze by the RAR .
E.25 MAJDR CHANGES TD RADIDA.idE VASTE TREATMENT 5% d.5 (Licuid, Gaseous an: .5oh :) E.23.1 Licensee -initiated major changes to the radisa=ive was e syste=s (licuid, gaseous and solid):" -
- 1. Shall be re o-ted to the 0.ozission in the Se=i-Annual Radion=ive -
^'
i
. Effluent Release Re c .1=- the period in which the evaluation was
-' reviewd yb;, th; 'C'.:. The discussion of each change shall contain:'
m occ.tewe. wh _<ech L.f.14. . .
- a. A su=a y of the evaluation that led to the dete=ination that !
. . .he change could be made in a=ordan:e with ID CFR 50.5t;
. . . . v* l
" Sue:ittal of infc=ation recuired by this section may be made as pa-t of ne -
annual FSAR unta,e. -
, ., . - ._n. .. . . . .. -
- - SEQUDyAH - Um 1 6-25 7'
9 l 1 I l
- .- - . - .- . . . -_ . -_- --.-.-------i
App!N!sTRt.TIVE CONTROLS
- b. sufficient detailed information to totally support the reason 1or t i change witnout benefit of additional or supplemenni inft sation;
-a
- c. a detailed description of the eouipment, cocconents and proces-ses involved and the interfaces with other plant systems;-
Se
- d. an evaluation y6 the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or-ouantity of solid waste that differ from those previously I
predicted in the license application and amenoments thereto;
- e. an evaluation of the change which shows the expected maximum exposures to individual in the unrestricted area and to the
' general population that. differ from those previously estimated in the license applicat. ion and amenoments thereto; f.
a comsarison of the predicted releases of radioactive materials,
- in licuid and gaseous effluents and in solid waste, to the actual releases for the period" prior to when the changes are to 1
be made; . .
- g. an estimate of the exposure to plant operating personnel as a ~
- result of the change; and *
. : . ;' .i,.s .,:
- h. documentation of the fact that the change Va's' reviewed and found acceptabley . . ~~~:. g i
.:. *f
;, d a qA sguL.5~.lA.[14- %
. 2.
Shall become effective upon review and acceptance /. 9: " ' . , 4 in atterQ d5k Se:M L CIA.
. . ~ .
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- - ,, SEQUDYdH - UNIT 1 - . . .;.y 4. .; .
6-26 . m.f h .'J:.. -
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.q .p1. s. . - -
- s. - . . . .
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- 6. O ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant ' Aidnap^ef-^
- shall be responsible for overall unit cperation
~-'- -' l l
and shall delegate in writing the succession to this responsibility during his absence. . goagee of %iplog#---cal"----' enk/ 6.1. 2 The ' '"# '
- --' "; ; shall be responsible for implementing the radiological environmental program and dose calculations and projections
__ ___.eme, as
.4 described
, _-3..s.
in the Offsite Dose Calculation Manual (ODCM). 4ee ___<_______ 1,- . 7, __ _ _ N 6.1. 3 The Shift Supervisor (or during his absence from the Control Room, a designated individual) shall be responsible for the Control Room command func-tion. A management directive to this effect, signed by the U : ^* ' E -- S h Director, shall be reissued to all station personnel on an annual basis. } 44 6.2 ORGANIZATION OFFSITE- .. A 6.2.1.1 The offsite organi$ation for unit management and technical support
._, shall be as shown on Figure 6.2-1.
e --- m ,,;, - _ 7,__,_g , - , ___,.__r_; e - s LJ .. .. - .$- '.-...... ....$' . ....-, $. ~3 UNIT STAFF ' 6.2.2 The-Unit organization shall be as shown sn Figure 6.2-2 and:
- a. Each on duty shift shall be composed of at least the minim *:m shift .
crew composition shown in Table 6.2-1.'
- b. At least one licensed Recctor Operator shall be in the Control 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.
[1 [ SEQUOYAH - UNIT 2 6-1 C.-
- ~.
- . .y
~
~
ADMINISTRATIVE CONTROLS
' %OIOlogICAL. OcutRob g
- c. A W e #yci:: technician shall be onsite when fuel is in the reactor. '
- d. All CORE ALTERATIONS shall be observed and directly supervised by . .
l either a licensed Senior Reactor Operator. or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities
'during this operation. ,
- e. AFireBrjgadeofatleast5membersshallbemaintainedonsiteat all times . -The Fire Brigade shall not: include the Shift Supervisor and the 2 other members of the minimum shift crew necessary for safe shutcown of the unit or any personnel required for other essential functions during a fire emergency.
i 4 F t i hoicLccienL c.cniR.ok
- Ine 1::. = ;ny:::: technician and fire brigade coccosition may be less than the minimum reouirements for a period of time not to exceed 2 hours in orcer
- to acccmmodate unexoected absence provided immeciate action is taken to fill .e the required positions. -
1 a i r SEQUOYAH - UNIT 2 6-2 i
%;ggo By- ATTRe.HED FiguRC ,
f, . t Ge,eral
- Manager
, . , Nuclear Sefety Review Staff Mac w of j Power QA Nuclear Safe Staff Review B N Manager of Power Operations I Nuclear Power
' Division
' Safety Staff \\
l \\ l j Ass't. Director % Ass't. Director Maintenance & Nuciur Opratim
]
Engmeenno Services t I Nuctear Maintenance Nuclear Coerations Branch Coorcinator ] ! Controis ano Nuclear 0:erations Test Branen Staff i
\
j Reactor Engineenng Preocerationas Branen _ Test S:aff Outage Managementj"
/ Nue: ear Training Branen Eranen l //
Nuc.ur Secunty Braccn s\ Su%cetintencant ' Se$movan
~\
! *Resocessoie for Fire l'rotection. \, ,
\
Figure 6.2-1. Offsite Organization for Facility Management and Technical Succort.'\
' \ '
l ~ i. ' N, i ! \ l ! SEQUOYAH - UNIT 2 6-3' 4
.- +.- .. ._. c .. . _. - -. . . . ,
s
'+. ,
e l l e
* =
l l .. 03 fTt O i C l O ! uOAsiO
> OF l I E/ REC TOitS I C gel 4EHAL M AN AGER l z 4
9J Og MANAGER 1 W OF I4t#C1E Aft POWER DLPUIV M AN AGER H5Hil NUCR E AR OllE Dit[C IOtt Des [C f 0f t fatt[C TOR OIRECTOR . OIRECTOR DRECTOR gionLCTORS AND OF OF OF OF OF OF NUCLE AR PROJECT Nucl[AR nisca E Arg NUCLEAR NUCLEAR NUCLEAR NUCLEAR
.MANAGENS CON SIH UC IK)td 4A E NGIN( E mt4G $ERWC ES TR AtNfNG S AFETY 8 tICENSING Figure 6.2-1 Offsite Organization for Facility Management and Technical Support e
0 r. l
?evisad Bv $7YAGH2O FIGURL a
e ASST DI TOR MAINTENA NO OFFSITE PLANT SUPERINTENDEM [/ INCEPENDENT \\ SAFETY ENGINEERING % GROUP SAFETY - SUPERVISOR ENGINEERING
- CA STAFF OlO LO '
yc,ENE ISTANT PLANT BRANCH SUPE RINTENDE NT CA ENGINEERS i N /
\\ #
HEALTH ESULTS. OPE R ATlONS MAINTENANCE PHYSICS RV1 SUPERVISOR SUPERVISOR
// SRO l
AS$15 TANT AS$1STANT HEALTH PHYstCS 'HNt OPE R ATIONS MAINTENANCE TECHNICIANS GINEERk SUPERVISOR 1RO SUPE R VISORS
/
TECHNICIANS, SHIFT FOREMEN AND FOREMEN AND ENGINEER ~7 CRAFTSMEN SRO I INSTR UMENT MECHANICS I._ ,
% $1STANT SHIFT TECHNICAL
*Resoonnoiirty for FW P*ect'** PW8'"
SRO/ISemor Reactor Ooerstot Lusana RG - Reactor Operator Lwease \\ g' UNIT OPER A , R Figure 6.2 2. Facility Orpnizauon .- . l
\ l l
/
SEQUOYAH - UNIT 2 6-4
t. m M
.o -
a
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-I >
- r e
c
- 3 FA n
N i T"42,'. " eITe .PJ."4fJ.*3, i ocJI. .. pinecron .. ,vagt,.., '""'a',w."JcD1'I'*"
=t ,7.,;,~.a aas.c, *= Js,T. ;.**
E .. . let ANnmo a scHEouuNo l s to ).-
-------- ------.aw- - - - - - - . -
i I E PLANT MODIFICATION PROJECT syA SERYtbEs UC! SlHO : MANAGER MANAoER MANAGEn MANAGER MANacER ENGlHEER ! l PORS l -- ~ 4t N D UST RI A L SAFETY 'l I, 1 I I NUCLEAR PowEn RADIOLOGICAL M AINTEN ANC E e . e suPEns i NoENT CONTROL suPEnlNTENDENT V I I I I I I l SIT E TECliNICAL ELECTRICAL INS Ru T MECHANICAL k $RVI sno CHEMISTRY - SECURITY SUPPORT SUPERVISOR suPEnvison SUPERVISOR i ASST OPS SPECIAL MAtHTENANCE suPERvlSOR PROJECTS PLANHlHo sno suPEnvison suPEnvison s SHIFT SUPERVISOR sno
- Responsibility f or Fire Protection Program shirt SRO - Senior floaotor Operator Lloense TgtgigL RO - Reactor Operator Lloense ,
Assi sHirY LEGEND-SuPERvlSOR sno ADMlHISTRATIVE AND TECHNICAL REPOR FING FUNCTIONAL REPORTING ' UNIT OPERATOR FIGURE 8.2-2 FACILITY ORGANIZATION - SEQUOYAH NUCLEAR PLANT h$. e'$ $% $
Tb/S . . fqure 1.s defGfe/ _
^
General Manager
/
Occup nal Office of Power Health Safety Division of Nuclear Power E Radiological Hygiene Plant Superintendant Branch
^
Radiologi,lt Assessmej Results see:jon Sectron
/ \ e igure 6.2-3. Offsite Organintion for Monitoring Prograrn and Dose Calculati N .
\
\
/ SEQUOYAH - UNIT 2 6-5'
^
I l TABLE 6.1-1
^U' SURVEIL NCE REOUIREMENTS
' RFORMED BY RAD RLOGICAL HYGIFR BRANCH
-t
.N hlc.
"O 4.11.1.2 4.11.1.3.1
. _4.11.2.1.1 (partial)-
4.11.2.1.2 (partial) -
~
4.11.2.2 4.11.2.3 4.11.2.4-4.11.4 4.12.1-4.12.2
-4.12.3 s, s
\ Ths fable is. AMd/
rk 5f
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t
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Y SEQUOYAH - UNIT 2 _ 6-6
-1 1
N _ _ . . -
'b-.
-ADMINISTRATIVE CONTROLS l 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)
FUNCTION 6.2.3.1 The ISEG shall function to examineg lant operating characteristics, l NRC issuances, industry advisories, Licensaap Event Reports and other sources which may indicate areas for improving plant safety. l COMPOSITION
- S 6.2.3.2 The ISEG shall be composed of at leasth dedicated full-time E:
g$Ine.e.RS .ShRRLO Amolug RII TT/R Atyg,LeAg 8itg5,ineers located onsit RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of plant 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 ISEG shall make detailed recommendations for revised procedures, equipment a s -., .
modifications, or other means of improving plant safety to the at.... . <. u . .,___ ,a r__4-__:__ .,..n4, 4 , 4 ,. . , , , u.._4_-. Y $
- v 6.2.4 SHIFT TECHNICAL ADVISOR (STA) 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 cperation of the' unit. -
6.3 UNIT STAFF OUALIFICATIONS 6.3.1 Each memoer of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for ccmparable positions and the suoplemental requirements specified in Section A and C of Enclosure 1 of March 28, 1980 NRC letter to all licensees, except for the " :'th "y i:f .t who shall meet or exceed the qualifications of Regulatory Guide 1.8, Se emner 1975. Sife.9adicic9 anL i CouTRol _ A eer m % t. o "Not responsicie for sign-off function. SEQUOYAH - UNIT 2 6-9 l
ADMINISTRATIVE CONTROLS
,9 64 TRAINING "
b' ga Lee N (arr) .sgpec;.4.+4-6.4.1 A retraining and replacement train be maintained under the direction of the %: program for the unit staff shall
... n n M..a :-- ' a :;.t and shall meet or exceed tne requirements and recommendations of Section 5.5 of l 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 l i'ndustry operational experience. . ... : ':.. _, .... :::^. l 6.5 REVIEW AND AUDIT ar 6.5.0 The Manager ofAPower is responsible for the safe operation of all TVA power plants. The functional organi:ation for Review and Audit is shown on Figure 6.2-1. 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC) FUNCTION . 6.5.1.1 Ata WP The PORC shall function to advise the Plant : r_. c ..__... ;a all matters related to nuclear safety. COMPOSITION O O 6.5.1.2 The PORC shall be composed of the:
/tla4ajer-Chaiman: Plant h Mecoer: :
Member: h,. . _ . . . . : _ _ _ .__ Me:cer: "; n 7;_ ;_;r ::- Membe'r: _ _ . _ . . . . -_i:___, n__; Memoer: ._J r - ;r;r:1 Memoer* .i _ y . , _[ ;,, ',,
- _,_ _,__7,,,-
S u per' w @ ( N ?p ec /M a', d en.adee Opm%ss Gremg snassw or MisM operdoM $<=4 N^*Y Sk Tad.do$ed i Conkl Gpriwbeted plaide%ce,Org ik.mSee,(.r), (c) ec (m) rs-t s4pc4 wees c,r. p s~aact hi'.ty Spneeri$ ad Cetwt />bajer l 1 63, ; kJ ! SEQUOYAH - UNIT 2 6-10 l
. u-.~ 4 =C't2 safety evaluations for: (1) prc:ecures, (2) crange g.jh* s , m<i.@
to procedures, ecuipment, systems or f acilities, and (3) tests or. ;
, experiments completed under the provision of 10 CFR 50.59 to )
verify that such actions did not constitute an unreviewed safety I c_u.e s ti on. n ADulN! W ~7VE CUN7EUL5
. t.
A'_ TERN!755 - 6.5.1.3 All alternate memoers shall be a:poin ed in w-iting by the PORC Chair =:an .c se ve on a temocra y basis; however, no more : nan two alterna .es sna11 pa-ti:ipate as voting mensers in PORC a :ivities at any one time. HEE ~TNG =REDU=N:Y E.5.1.4 The PCR0 shall meet at 1 east' ence per calendar conth and as c:nvened by One PDR Chair an er his designated alterna_e.
~ OUORUM 6.5.1.5 The minie== cueru= ef the PORC necessa y for the perf -=ance of the POR: responsibili.,y and authority previsiens of these Technical Specificati ns snail censis: of the Chairman er his cesigna .ed alte nate and four me=ce s in:Juding alternates.
.~ '
F._S P O N_CT_ _ :T. ' '.TT. :5 , s- - 3 5.1.5 The POR: shall be responsible f: : . aa -
.c.>- a. . . . - - ~
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as as - u> s Oe* V . uo - f.. ._.3_....- .s. -_=. = . _,..___m. _ 2 _ __.
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=f ne T*==nical _, _____.. .. ..._:.. . ..
Soe:ificati:ns. w , _ _ ___?__ :.r.. 3 .,= o ..o o, ,u ._ y ,. . . - -, - . . . = , . . . . . .. . . .w **
-_. - i, - - - -
a - . ,s. ,,,c,,, k l5 ~ g , g w E sys,e5.' o--- d.: ./'. . Review,a11 A -'u . z. -- - -- -' =- - - " - - - , - -'
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Review cf uni: eper :icns- := ce:e : pe:en ial nuclear safe:y ht: ares. . OC c='- . .
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- ,- . _ _ , - - _ _ . . ,-_,_,,,y., . . _ . _ - .-y._ _ - _ . - , _ _ _
1 ADMINISTRATIVE CONTROLS p jr. Fertormance of special reviews, investiga lons or anaiyses ano ' T. reports thereon as requested by the Planty E _:: ' : ::-t or the Nuclear Safety Review Board. %er-
- -_ _ __ .m. -~__. -u ..r... - __ _. . -.__ _ _ _ . . _ _ . _ _ _ _ . . _ _ ______ ___
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qg )d Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports , coveringevaluation,recommendatiog/,sanddispositionofthecorrective action to prevent recurrence to the Director, "_:'._ - -- and to the Nuclear Safety Review Board.
.1 ,. .. . _ .. _- _- _ _ _ . . . _ . . - - . , - - - .
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AUTHORITY .
- 6. 5.1. 7 The PORC shall: [
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- - :-e :- '; :: r.-_.2 :.,. 2..__.. .,,...a.
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Q. g. %g;ce. a2 Acete-=inationf o. in writing with regard to wnether or not each item considered under 6.5.1.6::.' -- : _;- ::' above constitutes an unreviewed safety question. lv .c 53e ' 6, jf. Provide written notification within 24 hours to the3 Director, __ __
~- -' ' '- and the Nuclear Safety betweenthePORCandthePlant_~..:~g&ggigyBoardofdisagreement _: :: , however, tne Plant jg "
.er ,' : ; ' ' : "- - shall have resconsicility for resolu-ion of sucn disagreements pursuant to 6.1.1 acove.
RECORDS i
- 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 provisions of these technical specifications. .
~
~~
Copies shall be provided to the yDirec cr '
- -:- _ and the '
, 5d5kNuclearSafetyReviewBoard. Sne. I ((6.5.2 NUCLEAR' SAFETY REVIEW BOARD (NSRB FUNCTION -
.p assett adyacl ,
6.5.2.1 The NSRS shall function to provideAi ndependent review and auditA of u
, designated activities in the areas of: . l 1
SEQUDYAH - UNIT 2 E '.h 1
i l INSERT: ~Section 6.5.lA ' 6.5.lA TECHNICAL REVIEW AND CONTROL ACTIVITIES - 6.5.1A.1. Activities which affect nuclear safety shall be conducted as follows: . a. Procedures required by Specification 6.8.1 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 organization as the individual who prepared the procedure or procedure change. Procedures shall be approved by the appropriate responsible manager as designated in writing by the Plant Manager or Site Director as appropriate. The Site Director, Plant. Manager, NPP Superintendent, or Maintenance Superintendent shall approve designated Administrative Procedures.
- b. Workplans used to implement proposed changes or modifications to plant nuclear safety-related structures, systems, and components 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 as the individual / group which designed the modifications. Proposed modifications to plant nuclear safety-related structures, systems, and components and the implementing workplans shall be approved prior to implementation by the Plant Manager, NPP Superintendent, or Maintenance Superintendent,
- c. Procedures for proposed tests and experiments which affect plant nuclear safety and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Each such test or experiment shall be reviewed by a qualified individual other than the individual who prepared the procedures for the proposed test or experiment. Procedures for proposed test and experiments shall be approved before implementation by the Plant Manager, NPP Superintendent, or Maintenance Superintendent.
- d. Proposed changes to the Appendix A Technical Specifications shall be prepared by a qualified individual / organization. The preparation of each proposed Technical Specification change shall be reviewed by an individual / group other than the individual / group which prepared:the proposed change, but who may be from the same organization as the individual / group which prepared the proposed change. Proposed changes to the Technical Specifications shall be approved by the Plant Manager.
l
- e. Individuals responsible for reviews performed in accordance with Specifications 6.5.lA.la, -b, -c, and -d shall be designated by approved written procedures. Each such review shall be performed by qualified personnel of the appropriate discipline and shall include a determination of whether or not additional, cross-disciplinary review is necessary. Each review in items a, b, and c shall include determination of whether or not an unreviewed safety question is involved pursuant to Section 10 CFR 50.59.
I I
..,--.1, l '.
ADMINISTRATIVE CONTROLS (_ _
- a. nuclear power plant operations Lc b. nuclear engineering .
1-
- c. chemistry and radiochemistry- -
- d. metallurgy
- e. instrumentation and control ,
. f. radiological safety
- g. mechanical and electrical-engineering 7
i h. -quality assurance practices COMPOSITION 1 6.5.2.2 The NSRB shall'be comcosed of at least five members, including the Chairman. Members of the NSRB may be from the Office of Power, or other TVA
; organization or external to TVA. 4 Nuclear
} OUALIFICATIONS
- i. Aclear j- 6.5.2.3 The Chairman, members,-and al ernate members of the NSRB shall be-1 appointed in writing by the Manager of Power an'd shall have an acacemic degree-a in engineering or a physical science field, 'or the equivalent; and in addition, I shall have a minimum of five years technical-exoerience in one or more areas 1- given in 6.5.2.1. No more than two alternates shall participate as voting memoers in NSRB ntivities at any one time.
CONSULTANTS
- 6.5.2.4 Consultants shall be utilized as determined by the NSR3 Chairman to provide expert advice to the NSRS.
1 i MEETING FREOUENCY 4 6.5.2.5. The NSRB shall meet at least once per calendar ' quarter during the j initial year of unit operation following fuel loading and at least once per six months thereafter.
> OUORUM
.e 6.5.2.6 The minimum quorum of the NSRB necessary for the performance of the NSRB review and aucit functions of these tecnnical specifications shall consist of more than nalf the NSRB memoership or at least 5 memoers, whichever is greater.
This quorum snall incluce the Chairman or his apoointec alternate and the NSRB-members, including appointed alternite members, meeting the requirements of . Specification 6.5.2.3. No more than a minority of the quorum shall have line i responsibility for operation of the unit. c SEQUOYAH - UNIT 2 6-l3 1
- -- =. _ _. - . . . _ , . _ ._ . _ - _ - .- _ , - . . . _ . _ _ . _ . . _ . . ,. _ _ _ _
ADMINISTRATIVE CONTROLS REVIEW be c.snild of 6.5.2.7 The NSRB shall revie g g
- a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.
- b. Proposed changes to procedures', equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- d. Proposed changes to Technical Specifications or this Operating License.
- e. Violations of codes, regulations, orifers, Technical Specifications, license requirements, or of internal procedures or instructions -
having nuclear safety significance.
- f. Significant operating abnormalities or deviations from normal and expected cerformance of unit equipment that affect nuclear safety.
Tc?dRT,45LE EVENT 5 g.. All . . . . . . _ , . . . . _ _, . ~ , :" t__ 4 .c.... nt; :_ * [-
^
^y
- h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or cc:.conents that could affect nuclear safety.
SY
- i. Reports and meetings minutes of the PORC and the RARC.
4 AUDITS 6.5.2.8 Audits of unit activities shall be perfomed uncer the cognizance of the NSRB. These audits shall encompass:
- a. The conformance of unit operation to provisions contained within the Technical' Specifications and applicable license conditions at least once per 12 months.
. b. The performance, training and oualifications of the entire unit staff at least once per 12 months.
- c. The results of actions taken to correct deficiencies occurring in unit eouipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.
- d. The performance of activities reouired by the Operational Quality Assurance Program to meet the criteria of Aependix "B",10 CFR 50, ,
at least once per 24 months. '
. =-
l SEQUOYAH - UNIT 2 6-N
~
~
". (ADMINISTRATIVECONTROLS' '
i e. 'The. Site' Radiological Emergency Plan and implementing procedures at
,least once per 12 months. i ~.
r ,
- f. The~PlantLPhysical Security Plan, the Safeguards-Contingency ~ Plan, e
- and; implementing procedures at least'once per 12 months.
! g. Any other area of unit operation considered appropriate by the NSRB or the~ Manager ofyPower. NucLTA1t. h h. The Facility Fire Protection Program and-implementing procedures at' least once per 24 months. 4 i
- i. An independent fire protection and loss prevention program inspection i
' * -and audit shall be performed annually utilizing either qualified
.offsite' licensee personnel or an_outside fire protection firm.
- j. ~
An inspection and audit of the fire protection and loss preven' tion program shall be performed by an outside qualified fire consultant j at intervals no greater than 3 years. ' i i k. The radiological environmental monitoring program and the results thereof at least once per 12. months. ' i 1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at
- least once per 24 months. ;
, m. The PROCESS CONTROL PROGRAM and implementing procedures for ( SOLIDIFICATION of ' radioactive wastes at least once per 24 months. i :
- n. Th.e performance of activities required by the Quality Assurance
' Program to meet the criteria of Regulatory Guide 4.15, December 1977 i or Regulatory Guide 1.21, Rev. 1, 1974 and Regulatory Guide 4.1, e Rev.1,1975, at least once per 12 months. RU 4 AUTHORITY {' Nuc.LLA S 6.5.2.9 The NSRB shall report to and advise the Manager of nPower on those l ' i areas of responsibility specified in Sections 6.5.2.7 and'6.5.2.8.' [ i-L RECORDS ! 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed
, as indicated below:
i a.- Minutes of each NSRB meeting shall be prepared, approved and forwarded
- to.the Manager ofqPower within 14 days =following each meeting.
NUCLEAR.
- b. Reports of reviews encompassed by Section 6.5.2.7:above, shall be i j
prepared, approved and forwarded to the Manager ofy Power within - 14 days following completion of the review. noctang, ) h
, _ . .m SEQUOYAH - UNIT 2 6-15 A--a m a+ * " l l
t I
ADMINISTRATIVE CONTROLS
- c. Audit reports encomga gs d by Section 6.5.2.8 above, shall be forwarded g to the Manager ofpc'w rand to the management positions responsible for the areas audited within 30 days after completion of the audit. l 6.5.3 RADIOLOGICAL ASSESSMENT REVIEW COMMITTEE (RARC)
Function S00 innwaata. of GordnoLAND & 6.5.3.1 The 3RARC shall function to advi'se the CM e'7 Radiological Hygi:n: 'InNTl71A// age *3r r9. on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring. Comoosition 6.5.3.2 The RC shall be composed of the: Chairman:TeckvienI 1 ::::gic:.Aps;stauct
.::::: ent Section Suoervisor Member: Health Physicist, Gaseous, Radiological t #: ? 2nch coutROL Member: HealthPhysgist, Liquid,RadiologicalPyg':n: 3 ranch GouTR.oL Member: Meteorologi. ? Engineer, Air Quality Branch Member: Chemical Engineer, 20: ult: Section,- W L V N Aiter e WTAL fcRwg,Tndiolc9lcnL GouteoL
.SOM 6.5.3.3 All alternate members shall be appointed in writing by the RARC n Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting memoers in RARC activities at any one time.
Meetine Frecuency M 6.5.3.4 TheSV De 4 xARC shall meet at least once per six months-ete as
'RESuasTED
..;..u cy the3RARC Chairman,e. his desicnated alternate,og. A PLANT RepRc5 vfatiVd .
Sqnt Ouorum SGW 6.5.3.5 The minimum cuorum of theoRARC necessary for the performance of the SGM RARC responsibility and authority provisions of these technical specific:.tions shallconsistoftheChairmanorhisoesignatedalternateandgmemoers(including alternates)a.,o LONg ns ONL, IS A PLANT REPREStu1Ativt, . Resconsibilities H ! 6.5.3.6 Th ARC shall be responsible for:
- a. Review of changes to the OFFSITE 00SE CALCULATION MANUAL.
- b. Review of procecures required by Specification 6.3.4 and changes thereto ,ng,w fvRpascS
{ u,g og EvnluAfioNS l
- c. Review o of the results of any audits,4of the Quality Assurance Program for effluent, and environmental monitoring JNuohhug dass SvaluRTooNS AND pRoj/ ANO radiologic 46 Assa ec 7Ycgs.
l SEQUOYAH - UNIT 2 6-16 1
y . ADMINISTRATIVE CONTROLS
- d. Review of proposed changes to the Technical Specifications related to ~i radiological assessments involving dose calculations and projections and environmental monitoring.
Authority l'AdioloaiceL a 6.5.3.7 ThefRACshall: mnun
- a. Recommend in writing to the Chic'gte o4%diolog,icaLQon1Rol
, " dic!cgicc! Mygier.c Br:.05 and &pinwr maungeA., approval or disapproval of 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 ar unreviewed safety question.
- c. mnunaca &NxLene Provide written notification within 24 hours to the Direc"'cr, 'N:! car i
Qou)E.Retw"cuer Di"ic ^ and the Nuggfgygv,i;g,ggofgsagreement y the,gngp y -x ; g cm , ms3.muu m unwn, however, _. . . , nc_.e: agge,p;q;g' y c2. a .; ..g,M,..ch shall have responsibility for resolution of such disagreement pursuant to 6.1.2 above. , Records SGA SGAl 6.5.3.8 The 3RARC shall maintain writte minutes of each RARC 3 meeting that at a minimum, document the results of all RC activities performed under the r sponsibility and authority provisions of these technical specifications. Copies shall be provided to the n4-er+-- m_g y omm- 04 4 the Nuclear Safety Review Board, rvmunoctt et Nuo.tenR. Tcw:!cm., eta.PORC, and
- 6. 6 REPORTABLE EVENT ACTION 6.6.1 (
3 f4 The following actions shall be taken for REPORTABLE EVENTS: [
- 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. EachREPORTABLEEVENTshallbereviewedbythePORCandtg;esults ) l 94Lc.TbR.-p;;;rof this review i i:$ emshall be submitted to the NSRB and the Dira - "uc! car y() , [ 6.7 SAFETY LIMIT VIOLATION 2
6.7.1 violated
The following actions shall be taken in the event a Safety Limit is a. The unit shall be placed in at least HOT STANDBY within one hour. b. The NRC Operations Center shall be notified by telephone as soon as l possible and in all cases within one hour. The Cirecter,.b.iesc SiTd Os.n e c.fCA?. " c u e r D ! " ' and
' 4 ^ -the NSRB shall be notified a*** 24 hours, b4Wm s.y. ,- s ,, ,. 4 , e SEQUOYAH - UNIT 2 6-17 ^~and-an+ "a
AD6 NISTRATIVE CONTROLS
- c. A Safety Limit Violation Report shall be prepared. The report sh'all be reviewed by the PORC. This report shall des: ribe (1) applicable circu= stances pre:eding the violation, (2) effects of the violation * ,
j
* . upon facility ec=ponents, systems or stru:tures, and (3) corrective action taken to prevent recurrence. j i
d. The Safety Limit Violation Report shall be submitted to the Co::.ission, the NSRB and theyDirector, t..'...
.;-I' * '
- : within 14 days of 1
the violation. .l5Ge.
. l
- 6. B PROCEDURES AND PROGRAF.S 6.8.1 Written procedures shall be established, implemented and maintained.
covering the activities referenced below: .
- a. The applicable procedures reco:rnended in Appendix "A of Regulatory Guide 1.33, Revision 2, February 1S78. ,, .
. .- b. Refueling operations.
. c. Surveillan:e and test activities of safety related equipment. . .
- d. Plant Physical Security Plan implementation.. ,
- e. Site Radiological Emergency Plan implementation.
*1
, f. Fire Protection Program,icplementation.
- g. PRDOESS CONTROL PROGRAM icplementation. .
h. Quality Assurance Progra= for effluent monidring, using the guidan:e contained in Regulatory Guide 4.15, Dece=ber 1577 or Regulate y
. Guice 1.21. Rev.1,1574 and Regulatory Guide 4.1, Rev.1,1575. 7.34
- 6. 8. 2 Each procedure of 6.8.1 above, and changes thereto, shall be revie'wed
.; .... T. ~
.., ...,. ..,.. and a,:pr,oved b 9: : :h prior o i=clementation
.., ... as set fo-:h in y -. ' ' n n',: : n n u.
i
. .' E. E. 3 Te=wat g sgMm L.5.1 A avove. -
pora y :S ;x i: pro:eduretye+ 6.E.1 above =ay be made provided:
- 2. N '-t:-t " c 6 3e3 f.
' 'J : ;F.C p:;nd_n i: .:t C t:- ;f.
* ',/ "Q The change is approved by two me=ters of the' plant management staf",
at least one of whom holds a Senior Reactor Operator's License on the unit affected. 4 g g
~
yg g g;g.4 4,3 gg , i
' h , / "".The change.is '- : ' > n ': ::'5 9: "?' rd approved t - %
% . . . ~ . ,. . ud:- ywithin.14 days of implementation. , , , , ,
.. k acceeda<t w%k S ee:.;[ksh*a (. 5". IA .-
..t ,. .,. .
(c.; SEQU3YAH - UNIT 2 E-1B '- - - - ^ ^ "' j
, , . , - . . . , _ _ , - - ,y-, . . - , _ . - - , - , - - . , ,
_ _ - , , , , - - . , , , - - . , _ . , _ . __ - , - - _ _ _ , , _ , . - . - , , , ,--,---...,-.m, -
ADMINISTRATIVE CONTROLS O U 6.8.4 Written procedures " shall be established, implemented and main'tained by ee-Radiologica(b;;p:n Cn a :-M covering the activities below: , 1
, a. OFFSITE DGSE CALCULATIONAL MANUAL implementation.
b. Quality Assurance Program and environmental monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977.
, lR c.
Surveillance requirements and environmental monitoring requirements ! shown in TablepRD 6.1-1.'6 - 6.8.5.Thefollowingprogradsshallbeestablished imple and c.4 % 4/;. occ.rdaue vak seclim c,.s.sA :mented, end maintained >'
- a. Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The
- systems include the safety infection system, residual heat removal system, chemical and volume control system, containment spray system, and RCS sampling system. The program shall include the following:
(i) Preventive and maintenanc,e and periodic visual inspection requirements, (ii) Integrated leak test requirements for each system at refueling i cycle intervals or less. - b. In-Plant Radiation Monitorino
' A program which will ensure the capability to accurately determine the airborne iodine concentrations in vital areas under accident conditions.
This program shall include the following: (i) Training of personnel, 3 (ii) Procedures for monitoring, and j (iii) Provisions for maintenance of sa=pling and analysis equipment. c. i _Secondarv Vater Chemistrv
- A program for monitoring of secondary water chemistry to inhibit steam generator tube degradation. This program shall include:
(i) Identification of a sampling schedule for the critical variables and control points for these variables, . 1. (ii). Identification of the procedures used to measure the values of the critical variables, g (iii) Identification of process sampling points, SEQUOYAH - UNIT 2 - 6-19 1 i
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ADMINISTRATIVE CONTR3LS "' O.i - -
.,;., 6.10.2 The following recoras shall be retained for the duration of the Unit y .)ll, Operating License:
a. Records and drawing changes reflecting unit design modifications made'to systems and equipment cescribed in the Final Safety Analysis Report.
~
b. Records of new and irradiated fuel inventory, fuel transfers and assemsly burnup histories. c.
, Records of radiation exposure for all individuals entering radiation
. control areas.
d. Records of gaseous and liquid radioactive material released to the environs. e. Records of transient or operational cycles for those unit components identified in Table 5.7-1. f. Records of reactor tests and experiments. g. Records of training and qualification for current members of the unit staff. h. Records of in-service inspections performed pursuant to these Technical Specifications. m
,,) 1. .f.eth M (* W ** da%.c
;; Records of Quality Assurance activities required Quality Assurance Manual. 3 by the Opri .J ,
s' j. Records of reviews performed fcr changes cade to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59. ,
- k. 5 488 Records cf meetings of the PORC,4RARC, and the HSRB.
1. Records cf analyses recuired by the radiological environmental l monitcring program. .
~
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' y SEQUOYAH - UNIT 2 6-28 " ~.
l l ADMINISTRATIVE CONTROLS l 1 1 6.10.2 (Continued)
- m. Records of secondary water sampling and water quality.
- n. Records of the service life monitoring of all safety related hy-draulic and mechanical snubbers, required by T/S 3.7.9, including the maintenance performed to renew the service life.
- o. Records for environmental qualification which are covered under the provisions of paragraph 2.C.(10)(b) of license No. DPR-79.
R34 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 controlled by requiring issuance of a Special (Radiation)
Work Permit".' Any individual or group of individuals permitted to enter such g 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 activities within the area and shall perform control over the activities within the area and shall perform periodic radiation surveillance at the ;
' frequency specified by the facility "T? 1 ':':t in the Special j (Radiation) Work Permit. SWe.hdesie\ C0+.1 N ednle.stw+ f w .. w c. + .i u.i.u co .i !
*neegen-i==eoes personnel or personnel escorted by 'i2 ". :'+:: personnel in accordance with approved emergency procedures, shall be exempt frem the SWP l 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.
}}
SEQUOYAH - UNIT 2 6-29 " . . ~ . . - . . ~. l l l 1
. o
- ADMINISTRATIVE CONTROLS 6.12.2 The requirements of 6.12.1, above, shall also apply to each high.
radiation area in which the intensity of radiatinn is greater than'1000 mrem /hr. In addition, locked doors shall be provided to prevent unauthorized entry into su:n areas and the keys shall be maintained under the acministrative control
. of the Shift Engineer on duty and/or the '-:; .lth ".1,;i:i;t.
su % .\egea\ 5.13 PROCESS C0hTROL PROGRAM (PCP) Ce44 cog Qgestu4 , S.13.1 Licensee initiated changes to the POP: 1
- 1. Shall be sub=itted to the Commission in the semi-annual Radioactive Effluent Release Report for the period in which the enange(s) was made. Thip submittal shall contain:
- a. sufficiently detailed information to totally support the iationale for the change without benefit of additional or supplemental infomation,
- b. a deter =ination that the change did not reduce the overall -
conformance of the solidified waste product to existing criteria for solid wastes; and "
- c. documentation of the fact that the change has been reviewed and-found ac:eptable t W "'r, in accordece. w% secH.4 6.s.u.
- 2. Shaii become effective upon review and p -- '--- '; s'. ~~~~;
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GWNal K ne:.rdane. . m b.W. , 6.14 00:5ITE DOSE CALCULATION MANUAL (DD;M) t 6.14.1 The ODS. shall be approved by the Co==ission p-ior :.o i=plementation.
..e -:
E.14. 2 Licensee initiated changes to the'0D7. +~ ~ ~
~
- 1. Shall.'be sub=itted to the Co==ission in the next Se=i-Annual Radioactive Eff.luent Release Report pursuant to Spe:ification :
E.S.1.S. This sub=ittal shall con.ain:
- a. sufficiently detailed infor=ation to t: tally support the rationale for the change without benefit of additional or supple = ental infor=ation. Info =ation sub=itted should consistent of a package of those pages of the ODOM to be changes with each page nu=bered and provided with an amproval and cate box, together
. with a:propriate analyses or evaluations justifying the change (s);
- b. a deter =ination that the change will not reduce the~ at:i: racy or . ;
reliability of dose calculations or setpoint deter =inations;
. and .
- c. documentation of the fa:t that the change has been reviewed and
! ,. found acceptable by the RAP.O. .
SEQUDYAH - UNIT 2 6-30 !..,..........
.s -
ADMINISTRATIVE CONTROLS
) 2. Shall become effective upon review and acceptance by the RARC, -
6.15 MA.10R CHAN ES TO RADI0 ACTIVE VASTE TREATMENT SYSTEMS (Liquid, Gaseous anc Sohc) E.15.1 Licensee initiated major changes to the radioactive waste syste=s (liquid, gaseous and solid):" '
- 1. Shall be reported to the Commission in the Semi-Annual Radioactive Effluent Report for the period in which the evaluation was reviewed MyThe discussion of each change shall contain:
ss accmdesce J.% See% L.s.1 A.
- a. A su::r..ary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59; . -
. b. sufficient detailed infoh::ation to totally support the reason for the change without benefit of additional or supplemental information; ,
- c. .a detai-led description of the, equipment, corponents and pro:es-ses involved and the interfaces with other plant systems;
- d. an evaluation for the change which shows the predicted releases of radioactive caterials in liouid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments therete;
- e. . an evaluation of the change which shows the expected maxime:n exposures to individual in t'he unrestricted area and to the -
, general population that differ fro = those previously esticated !
in the license appli:ation and amen:ments thereto; - t
- f. a co=parison of the predicted releases of radica:tive =aterials, in licuid and gaseous effluents and in solid wast.e, to the
, actual releases for the period prior o when tne changes are to be made; ,
- g. an esticate of the exposu e to plant cperating personnel as a
., result of the change; and .
- h. cc:umentation of the fact, that. the change was reviewed and ;
b 'M"". - found a=eptabley tsaca d.u.4.n %% 4.f.I4. , l
- 2. Shall become effective upon review and a=eptance :-.
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'm oe:wdance J,W! Inch E f*lA.
Sub=ittal of infor=ation recuired by this section may be cade as pa-t of m the annual FSAR upcate. 8 1 L.$ . - - - SEQUDYAH - UNIT 2 6-21 n.a.. .U... .... "
E' ENCLOSURE 2
- PROPOSED TECHNICAL SPECIFICATION CHANGE-
, SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2
- DOCKET NOS. 50-327 AND 50-328
~(TVA-SQN-TS-87-34)
- l DESCRIPTION AND JUSTIFICATION FOR CHANCES TO SECTION 6. " ADMINISTRATIVE CONTROLS" l
( l i '4 4 4 i a
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ENCLOSURE 2
!The proposed change to ' technical specifications will extensively revise
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Section 6, " Administrative controls," of'the sequoyah Nuclear Plant technical specifications. : For clarity, the change will'be divided into five items as
, , follows:
Iten Title i
- - A' Office of Nuclear Power (ONP) Reorganization
- 5 Plant Operations Review Committee (PORC) 1 C Independent safety Evaluation Group (ISEG)
! D Radiological = Assessment-Review Committee (RARC) i E Fire Brigade Members 4 A separate section of this package will be dedicated to each item which will , ! address the description, reason, and justification for each of these changes.
; Further, an overall determination of significant hazards' consideration,
. addressing all five items in accordance with 10 CFR 50.91 and 92, will be included as enclosure 3.
1 ' Item A - Office of Nuclear Power (ONP) Reormanization
, Description'of Chanze i
1 This administrative change is being made to change the title of Plant i Superintendent to' Plant Manager, t 4 The Plant Manager will report directly to the Site Director. The title of } Assistant Director of Nuclear Power '(Operations) is being changed to Site Director. The chief officer of the ONP is now titled Manager of Nuclear Power. Any -
, references to the-Manager of Power are changed to read Manager of Nuclear Power.
4 The Health Physicist is now titled Site Radiological Control Superintendent. j The. reference to'the offsite organization for radiological. environmental i monitoring program ~and dose calculations (item 6.2.1.2), table 6.1-1, and figure 6.2-3 is being removed. ' ' The site organization includes the new Plant Operation Review Staff (PORS). l PORS is a staff reporting to the~ Assistant-Plant Manager. I l The proposed changes are consistent with Volume 2 of the Sequoyah, Nuclear. Performance' Plan, Revision 1, which was submitted to NRC April 1. 1987. t ! i l 1 i 'l l 4
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-Reason for Chanae
.The above changes are proposed in order to make the technical specifications!
- Lconsistent with the present organization for the ONP. Several positions
. currently infthe technical specifications no longer exist after the recent-reorganization.
3 This change'will identify the positions currently responsible for those functions.
^ Removing 'the offsite organization for radiological environmental monitoring
~
program and dose calculations will eliminate unnecessary, redundant-information from the technical specifications and avoid potential future
-amendment proposals because of realignment of referenced organizations.
The responsibilities of PORS include, but are not limited to, preparing LERs, investigation of potential reportable occurrences, and technical specification special reports,-as assigned. Justification for Chanae The~ changes proposed are being made to improve the responsiveness of the organizations in ONP. -The new organization is intended to improve performance in every area of plant operation by clearly defining the lines of responsibility and accountability. The information on the offsite organization for radiological environmental i monitoring program and dose calculations is discussed in section 6.3.2 under the Radiological Assessment Review Committee. Item 6.2.1.2,' figure 6.2.3, and table 6.1-1 provide unnecessary detailed information. This information is subject to change due to organizational realignments ~ resulting in- the need for unnecessary and avoidable technical specification amendment proposals. This information is omitted in revision 5 of the Standard Technical specifications (NUREG-0452), which indicates that the evaluation of this information as being superfluous ic correct. No function previously identified as important to safety has been deleted. Only a realignment of functions into positions of realigned responsibilities has taken place. Item B - Plant Operations Review Committee (PORC) Description of Channe i The proposed changes affecting PORC will delete several items from PORC { responsibility and place them under the new " technical review and control" l process. The process will establish required ~" independent qualified review" and cross-disciplinary review and approval to support changes currently under PORC review responsibility. PORC will'now be responsible for providing an oversight review of selected safety evaluations reviewed under'the new
. process. This change will also clarify PORC responsibilities for review of violations of the technical specifications and reportable events. Changes to sections 6.5.1.7, 6.5.2. 7, 6.8.1, 6.8 !2, 6.8.5,- 6.13, and 6.15 are made to reflect consistency with the changes to PORC responsibility. Also, chanses to accurately reflect the titles of the regular PORC members are being made.
4 -.
. .section 6.8.3 will. delete the use of temporary changes to procedures. ,
Temporary approval may be provided under unusual circumstances, provided final approval is implemented within 14 days in accordance with section 6.5.1A. A typographical error is corrected in specification 6.15.1.1.a. Reason for Channe.
- A very large administrative burden to PORC has resulted from the currentL
' interpretation of review requirements for administrative procedures and
, procedural changes. Proposed technical specification changes and the large number of modifications also add to this burden. The proposed change will '
allow the use of individual qualified reviewers to reduce this burden. The current requirements have reduced the time available for PORC to review and focus on significant safety issues.and limits supervisory time available for verifying that operating activities are conducted safely and in accordance i with administrative controls. The proposed title changes are consistent with i revision 2 of the Nuclear Performance Plan. Justification for Channe The following responsibilities will be removed from PORC in section 6.5.1.6: { . a) 1) Review and approval of procedures required by specification 6.8.1 i and other procedures whir $ affect plant nuclear safety and changes theroto will be controlled under section 6.5.1A, " Technical Review and Control." j A new administrative instruction, AI-43 (Independent Qualified {- Review), will establish requirements for " Technical Review and
! Control." AI-43 will establish qualifications and training l-requirements necessary for qualified reviewers. Specific guidelines are given for performing the independent qualified review, and the -
t 2Ppropriate level of management to approve the change will be designated. A copy of AI-43 is provided in attachment 1. This i, procedure is in draf t form and minor changes are expected to occur to reach a final product. However, the key elements noted above represent the main considerations necessary to implement the new j review process. TVA will inform NRC of any significant changes which may occur to this procedure. i i AI-4, " Preparation, Review Approval, and Use of Plant '
; Instructions," will require review and approval in accordance with i AI-43. Additionally, AI-4 will require a larger review and higher level of management approval for designated administrative instructions and procedures affecting safety-related functions.
- . Appropriate managers responsible for approval of different groups of procedures will be designated within their field of responsibility. l QA will be given the option to review all changes. Items which are not applicable to QA review* will be marked accordingly.
1 i i. l 1
. - _ . - . - , - . - _ , - - . _ _ _ ~ , - . _ .. _ _ ,,_ _ _,_.,_~-~ - ._ - , , . _ . - . . , . - . _ - , , . . - - - . _ , .
o . I
- 2) Review of all programs required by specification 6.8.5 and changes ,
thereto will be controlled under new section 6.5.1A. Specification 6.8.5 is being revised to include this review, i 3) ' Review of any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety will be deleted. However, specification 6.5.1.6.h (will be relabeled as f) gives the' Plant Manager the authority to escalate any item to be reviewed by PORC. Additionally, AI-43 will contain a clause which allows the qualified reviewer or the responsible manager approving the procedure or procedure change the right to request PORC review, b) Review of all proposed tests and experiments that affect nuclear safety will be controlled under section 6.5.1A. The review cycle will consist of the qualified reviewer's approval and the responsible section supervisor's approval. The Plant Manager, NPP Superintendent, or Maintenance Superintendent must provide final approval, i c) Review of all proposed changes to appendix "A" of the technical specifications will be controlled under section 6.5.1A. The review process will be done in accordance with AI-43, and the proposed change must be approved by the Plant Manager. Additionally, the proposed technical specification change must receive NSRB approval before being sent to NRC. d) Review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety will be controlled under section 6.5.1A. Additionally.. Quality Engineering and Control will review all workplans before initial approval. The Plant Manager, NPP Superintendent, or Maintenance Superintendent must provide final approval of the change. . i and j) Review of the Plant Physical Security Plan, the Site Radiological Emergency Plan, and implementing procedures is also covered by specification 6.8.1. Review and approval of changes to these procedures will be done in accordance with section 6.5.1A. Also, an audit under the cognizance of NSRB will be performed at least once every 12 months of the Plant Physical Security Plan, the Safeguard Contingency Plan, the Site Radiological Emergency Plan, and implementing procedures. i l
o_ .
- 1) Review of changes to the radweste treatment' systems is also covered _
by specification 6.15. Review and approval of these changes will be done in accordance with section 6.5.1A. Additionally, Quality = Rngineering and control will review all changes before being ., approved. The Plant Manager, NPP Superintendent, or Maintenance Superintendent must provide final approval of the change. -
.m) Review of meeting minutes of the Radiological Assessment. Review Committee (RARC) is no longer needed under the new organization.
Technical.and' administrative review used to be split between two separate TVA organizations, one nonnuclear. PORC review was necessary to oversee the technical review done by RARC. The new organization has brought the technical expertise under the nuclear organization that PORC is under, thus deleting the need for PORC review. .PORC and RARC are equal-level committees subject to the same governing upper-tier nuclear procedures.. Reports and meeting minutes of both committees are reviewed under cognizance of NSRB. Specification 6.5.3.1 sets forth the functional requirements for SQN RARC.- The committee shall advise the Radiological Control Manager and the Plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring. The Plant Manager has the authority to request PORC review of any significant items. The following PORC responsibilitiet- will be revised in section 6.5.1.6 e) Item "e" will be relabeled as item "c." The proposed change more. accurately reflects the PORC function intended for review of technical specification violations. It is not practical for PORC to perform investigation of the violation. Investigation and preparation of reports covering evaluations and recommendations to i prevent recurrence are performed by the appropriate line i organization. PORC will provide oversight to ensure the evaluations i and recommendations are sufficient and complete. l f) Item "f" will be relabeled as item "d." The proposed change requires PORC review of all reportable events. Reportable event is defined by the technical specifications as those conditions specified by section 50.73 to 10 CFR Part 50. The change will be consistent with-Specification 6.6, " Reportable Event Action," and is consistent with the Westinghouse Standard Technical Specification (NUREC-0452).
3' i
;
- 4 .
j l i i i The following PORC responsibilities will be added to section'6.5.1.6 - 1 a)' ,PORC will provide an oversight review of selected safety evaluations i which are reviewed per section 6.5.1A to determine the adequacy of
;.. the qualified review process and ensure that a quality level review is being accomplished. .The review will be performed on a monthly
{ . basis and shall screen a minimum of 10 percent-of the applicable
! safety evaluations. A list of activities reviewed and the results
- of the review, including deficiencies or problems noted, will im i reported to PORC at scheduled monthly meetings. This report will i become a part of PORC meeting minutes, along with any actions to be L taken from the report.. Individuals performing oversight review j shall meet the qualifications specified in AI-43.
+
i , l
- b) PORC will provide a 100-percent review of proposed procedures and i changes to procedures, equipment, systems, or facilities which involve an uncoviewed safety question as defined in 10 CFR 50.59. .
i t specification 6.5.2 is being revised to avoid confusion in interpreting the 1 way N8kB review is required to be conducted. NSRB delegates the review through use of appointed subcosmittees. The newly restructured NSRB does not l believe the revised wording would' allow this delegation. The proposed change clearly states NSRB's responsibility to be cognizant of the identified review items. , a ! Specification 6.8.3 will delete temporary changes. Temporary approval of j procedure changes will. be permitted if the appropriate manager is not i available to allow for the normal review process. Temporary approval shall I consist of two qualified reviewers (per AI-43) of the plant management staff, i at least one of whom holds a Senior Reactor Operator License on the unit l affected. Upon temporary approval, the change may be implemented. Final l
! approval must be given within 14 days of the temporary approval. - ) If an instruction change is given temporary approval and then rejected before j finsi approval, a new instruction change request must be initiated by the !
I responsible section to supersede the rejected instruction change. Any work performed with the rejected instruction change shall be evaluated by the , responsible section to determine necessary corrective action. l
? , ! The requested amendment requires that decisions affecting safety be made at l l the proper level of responsibility with the necessary technical advice and i review. The detailed technical reviews can be accomplished by qualified i individuals not encumbered with other managerial duties but possessing the j technical expertise to provide a thorough review. The current technical I specification' requirement for review of changes is actually satisfied by } individuals of a similar responsibility level; however, considerable i i management time is consumed in assigning these personnel to review each 1
I I I f I
- i
l
. . 1 I
item, collecting results from these reviews, and finally attending a formal , meeting to recommend a disposition. The method requested by this amendment. eliminates much of the unnecessary effort and at the same time provides a more consistent review and approval process. The process will focus responsibility
, and accountability to the technical reviewers and provide a better review.
Cross-disciplinary review will also be improved from current methods because reviewers will be able to concentrate on their particular areas of expertise. The most important safety consideration is that this amendment permits PORC members to focus their attention on the safety significance of the issues essential to the safe operation of the plant, thereby improving PORC's effectiveness. This aspect is increasingly important because of the growing complexity of nuclear plant operation. For the reasons stated above, TVA has concluded that the proposed technical specification changes affecting PORC will significantly enhance management control and nuclear safety. Item C - Independent Safety Evaluation Group (ISEG) Description of Change The composition of ISEG for SQN has been changed from five dedicated full-time onsite engineers to three dedicated full-time onsite engineers supplemented by two full-time engineers located in corporate headquarters and shared by all TVA nuclear facilities. ISEG will now report to the Director of Nuclear Safety and Licensing Division. Reason for change This change will allow TVA to better utilize the expertise available for all its nucicar sites. This will also allow ISEG organization to better maintain cognizance of issues which are potentially generic to TVA's nuclear sites. Justification for Change This change will make all of TVA's nuclear sites consistent. By utilizing the three onsite full-time dedicated engir.cers supplomented by two offsite full-time engineers it will be possible to botter communicato information on issues of generic applicability and, at the same time, fulfill the function of ISEG fully with the available personnel. In case of an immediate need for offsite support this support will be easily accessible. The administrative move of ISEG to report to the Director of Nuclear Safety and Licensing Division is consistent with the intent of ISEG and the proposed alignment in standard technical specifications (revision 5) which proposes that ISEC report to a high level corporate official in a technically oriented position outside the management chain for power tiroduction. This change is also consistent with revision 2 of the Nuclear Performance plan.
-3 Item D - Radiolonical Assessment Review Committee (*ABC) ..
Description of Channe
, The administrative change is to change the titles of the members of RARC to be consistent with the positions responsible for those functions under the new organization.
RARC provides reports to the Manager of Radiological Control (formerly the Chief Radiological' Hygiene Branch) and the Plant Manager. Any reference to the Chief, Radiological Hygiene Branch should now read Manager of Radiological Control, and any reference to the Radiological Hygiene Branch should read. , Radiological Control. ' Reason for Channe The positions identified in the current revision of technical specifications no longer exist because of the recent reorganization. This change is intended to identify equivalent positions and is consistent with revision 2 of the Nuclear Performance Plan. Justification for Channe The purpose of RARC is to advise the Manager of Radiological . Control and the Plant Manager on all matters related to radiological assessments involving dose calculations and projections and environmental monitoring. This change serves to identify the positions which serve to provide this expertise and provide the functions necessary to perform and document this role. The changes in 6.5.3.4, meeting frequency, as an alternative allows credit to be taken for any meeting requested and subsequently convened by the RARC Chairman or a plant representative to satisfy the requirement to meet at least every six months. The changes in 6.5.3.5, quorum, ' ensure that a plant - representative is in attendance at each meeting in order to satisfy plant
~
manager responsibilities. The changes in 6.5.3.6, Responsibilities, clarify our understanding of the defined responsibilities. Item E - Fire Brigade Members Description of Channe For unit 1 technical specifications, change 6.2.2.e to specify the shift supervisor as one of the three excluded personnel from membership in the fire brigade. R,eason for Chanze This change will make unit 1 technical specifications consistent with unit 2 technical specifications, j 1 t 6
( s s g Justification for Channe . The shift supervisor is responsible for the overall safe operation of the plant. For this reason it is imperative that he remain in the main control
- room as much as possible without the distraction of intimate involvement in fire fighting efforts.
- This change is more restrictive (i.e., more conservative) than currently configured in unit 1 technical specifications.
I Unit 2 technical specifications currently are configured this way. The fire , brigade is shared between the two units, as is the shift supervisor, and this rule, being the more restrictive of the two, is already being followed. This change will, for clarification purposes, bring unit 1 technical specifications into agreement with the comparable specification for unit 2. This change will also make SQN's technical specifications consistent with j revision 5 of the standard technical specifications.
! t f
f e l, n 5
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l I
l,* - '. ; !!_hk & ll l SQN AI ' Page'l _ , , DRAFT ~ (RO) ~' ., INDEPENDENT QUALIFIED REVIEW
; ' TABLE OF CONTENTS Page l'. 0 PURPOSE '2 2.0~ . SCOPE '2'
, . 3.0 SOURCE DOCUMENTS AND REFERENCES 2 4.0 ' DEFINITIONS 3 5.0 ' QUALIFIED REVIEW 3
- 6.0 QUALIFICATIONS OF REVIEWERS 6
. APPENDIX 1^- 8
, ATTACHMENT 1 - QUALIFIED REVIEW GUIDELINES-' 9 i
s t l s i . i i f 0710A/rtj 4 ~ t
.i-
, . . ~ , . - - _ . - , , . . ,4-- . . . . . . . . . ._
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SQN AI-43 Page 2 ,
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DRAFT (RO) 1.0 PURPOSE This Admivistrative Instruction (AI) establishes the requirements for Independenc Qualified Review (IQR) for activities Shich affect nuclear safety at Sequoyab Nuclear Plant (SQN). 2.0 SCOPE The IQR program establishes technical review of procedures and safety evaluations for the following:
- Procedures required by SQN Technical Specification 6.8.1 and other procedures which affect plant nuclear safety and changes to these procedures.
- Proposed changes or modifications to plant nuclear safety -
related structures, systems, and components.
.
- Proposed changes to the SQN Appendix A Technical Specifications.
(A safety. evaluation is not performed for changes to Technical
, Specifications; instead a significant hazards evaluation per.
SQA-30 is performed as required by 10 CFR 50.91 and .92.)
- Proposed tests and experiments in accordance with 10 CFR 50.59.
3.0 SOURCE DOCUMEhTS AND REFERDICES 3.1 Source Documents 3.1.1 10 CFR 50.59 3.1.2 NQAM, Part II, Section 1.5, "Onsite Independent Review" 3.1.3 SQN Technical Specifications, Sections 6.5.1.6, 5.5.1.A.1, and 6.8.2 3.2 Refecences 3.2.1 AI-4, " Preparation, Review, Approval and Use of Plant Instructions" 3.2.2 AI-19. Part IV,." Plant Modifications: After Licensing" 3.2.3 STI-1, "Special Test Instructions" 0710A/etj
- ,-D c.-
SQN :; AI-434 i
~Page 3 _
DRAFT (R0);. . -] . 3.2 References!(Continued) - 3.2 4 SQA-21, " Plant Operation Review Committee Charter" l 3.2.5~ SQA-30, " Responsibility for Technical SpecificationL
. Changes" 3.2.6- SQA-119,;"Unr4 viewed Safety. Question' Determination"
.4.0 DEFINITIONS.
4.1 Cross - Disciplinary Review - Technical review by disciplines other than those responsible for the procedure / document preparation. This review is performed by Qualified Reviewers (QR) and includes technical aspects of _ the procedure / document ' organizational interfaces, and adequacy of safety evaluations, and whether or not an unreviewed safety question is involved.' 4.2 ' Independent-Qualified Review-(IQR). '. Technical review by-qualified reviewers of procedures and other documents for proposed changes or , modifications to plant nuclear safety - related structures, tystems, and components,: proposed changes to Appendix A Technical Specifications,sor proposed tests and experiments not addressed in the Final Safety Analysis Report (FSAR) or Technical Specifications. =This review'shall-include a determination of whether or not an unreviewed safety-question is involved for all reviews conducted;except proposed changes to Appendix A Technical Specifications. l 4.3 Qualified Reviewer (QR) - An ind'ividual responsible'for technical review of activities which affect nuclear safety and is designated by.his group /section head to perform IQR. .This
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individual is qualified to -review the discipline ~ addressed by . the activity-within his field.of. expertise. 5.0 QUALIFIED REVIEW 5.1 Preparation Requirements 5.1.1' Proposed changes to the Appendix A-Technical Specifications shall be prepared by a qualified i individual / organization per SQA-30. i i !~ l . 0710A/rtj _ ___a
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'5.0=. QUALIFIED REVIEW (Continued).
5.2.- Review Requirements 5.2.1 . Procedures required by SequoyahLNuclear Plant'(SQN) Technical. Specifications and other' procedures which affect plant nuclear safety including changes .to these procedures shall be reviewed by a qualified reviewer. _ This review shall include determination of whether or not an unreviewed safety question is. involved as_ defined in 10 CFR 50.59.. This individual shall be other than the preparer of the procedure or procedure change, but may be'from the same organization ~as the preparer. .If' .] the QR does not meet qualification. requirements per
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I SQA-119, another. QR qualified per SQA-119 must perform evaluation of the USQD.
- 5. 2. ?. Procedures for proposed tests and experiments which affect' plant nuclear safety and are not addressed in the.
Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Such tests or experiments lshall be reviewed by a qualified individual other.than the individual who prepared the procedures for the proposed test or experiment. 5.2.3 Proposed changes or modifications to plant nuclear safety - related structures, systems,.and components ! shall.be reviewed by a qualified reviewer / group other than the reviewer / group which designed the modifications. This review may be done by the same organization as the reviewer / group which designed the modifications. This review'shall include'deteomination of whether or not an'udreviewed safety question is involved. 5.2.4 Proposed changes to the Appendix A. Technical Specifications shall be reviewed by a' qualified reviewer / group other than the reviewer / group which prepared the proposed change. LThis review may be done. tar the same organization as the~ individual / group which prepared the proposed change. 5.3. Revision Performance. 5.3.1 Discipline Review Review by.a qualified reviewer using the guidelines established in Attachment 1 of this instruction. 0710A/rtj L._-_
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SQN , AI-43. l Page 5 I DRAFT (RO) _, 5.0 QUALIFIED REVIEW (Continued)
~5.3.1 Discipline Review (Continued)
The QR shall be responsible for determining whether-additional cross-disciplinary review is necessary up to and including PORC. Review items which cannot be resolved by the. preparer and QR will'be submitted to the group /section supervisor for resolution. Items needing further resolution will
~be presented to PORC for. final determination.
5.3.2 Cross-Disciplinary Review This review can be requested any time the QR feels the
-need for cross-disciplinary review. :This review shall be performed when the new procedure or procedure revision affects the. conduct of operation of other plant groups. Cross-disciplinary review shall verify that'the procedure does not adversely affect the equipment, systems, or manpower of the respective organization. QA will be given the option to review all~ changes. Items not applicable to QA review will be marked accordingly.
All reviews shall be performed using the guidelines in Attachment 1 of this instruction. Recommendations and comments resulting from cross-disciplinary reviews shall be submitted to the section/ group l responsible for . , preparing the procedure for resolution. Additional reviews may be requested by the QR performing the cross-disciplinary review. Unresolved comments will be referred to the responsible managers and/or PORC for~ resolution. Reviews shall be documented by the qualified reviewer's signature on AI-4, Appendix C or other appropriate document under review (e.g., work plans). i 5.4 Approvals Approvals shall be obtained in accordance with the appropriate reference. 0710A/rtj
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.SQN AI-43
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Page 6 , DRAFT (RO) 6.0 QUALIFICATION OF REVIEWERS 6.1 Training Requirements Qualified Reviewers shall only perform reviews within their respective area of responsibility or expertise. Prior to an individual being designated as a Qualified Reviewer, that individual shall be trained in the duties of a Qualified Reviewer. Requalification Training is required every 12 months to maintain the Qualified Reviewer Designation. 6.1.1 SQN shall maintain a list of names of those individuals that are qualified reviewers. 6.1.2 QRs shall be designated by their responsible supervisor-on Appendix 1 of this instruction and shall be approved by the Plant Manager. The Appendix 1 list can be updated as necessary without requiring procedure
. revision.
6.2. Experience Requirements 6.2.1 To qualify as reviewers, individuals shall meet the following experience requirements: An individual shall possess an academic degree in engineering or related field or equivalent and three years related experience or currently hold a NRC license (Reactor Operator or Senior Reactor Operator license). Individuals who do not possess the formal education or license specified in this section shall not be automatically eliminated where other factors provide sufficient demonstration of their abilities. These other factors shall be evaluated on a case-by-case basis and approved and documented by the Plant Manager. The positive factors listed as follows may be considered in making the evaluation of an acceptable alternative to the education requirements:
- Academic and related technical training
- Four years of additional experience in this area of responsibility.
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SQN. AI-43' _ Page-.7 . DRAFT (RO) ., 6.0'- QUALIFICATION OF REVIEWERS (Continued) - 6.2.1 (Continued)
*J Certification-of academic ability and.
knowledge,iby corporate management.
- Successful completion of'the Engineer-in-training examination Professional Engineer. License;
- Associate Degree in Engineering or.related~
science 6.3- .It is the group /section supervisor's responsibility to' ensure that each individual'in his/her organization that is' qualified. to perform IQR has a thorough' knowledge of the IQR process. Each group /section having Qualified Reviewers'should conduct specific training, as required, and provide specific guidelines on the specific requirements of a Qualified Reviewer for that
. group /section. This training:is meant to supplement the general training and requalification training mentioned above.
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SQN. AI Page 8- ^~ DRAFT (RO)., - APPENDIX l' ,
^4 e EXAMPLE (All required disciplines will be' listed).
OPERATIONS: Submitted Responsible Manager Approved by Plant Manager:- l
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SQN. AI " Page 9 . DRAFI (RO)~. ~ ._, - ATTACHMENT 1~ -
- Page 1 of 5 .
QUALIFIED REVIEW GUIDELINES , 1.0 PURPOSE The purpose of these guidelines is to ensure that the review of SQN procedures are performed uniformly and that the review is sufficiently detailed to detect erroneous information or omissions of important . . information from both new and existing procedures. 2.0 -SCOPE These guidelines.are applicable to all Nuclear Safety related procedures and should be followed prior to implementation of a new procedure or during the periodic review of existing procedures. Additionally, these guidelines should be used during a major procedure change if the change is reviewed with the intent of using the change as a basis for satisfying the periodic review requirements for two year review. 3.0 PROCEDURE REVIEW OBJECTIVES 3.1 To verify that the procedure is free of typographical errors, easily understandable and meets current general guidelines for procedures as defined in Administrative Instruction (AI) 4.0,
" Preparation, Review, Approval and Use of Plant Instructions."
3.2 To verify that Technical Specifications, AIs and all other applicable requirements are identified and. incorporated. 3.3 .To verify that information contained within the procedure is accurate and complete and that the intent of the procedure is fulfilled. 3.4 To verify that procedures do not contain steps which could potentially lead to Technical Specification violations or expose personnel to hazardous conditions. 3.5 To ensure smooth interaction between plant groups / sections. 4 0710A/rtj
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. ATTACHMENT 1
. .; :Page 2 of 5 .; t 4.0 . PROCEDURE REVIEW GUIDELINES To meet these objectives, the following guidelines-ha've been developed
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.to aid the reviewer.in performing a. qualified review.
; 4.1- Prior to performing the review,' verify that all applicable approved changes to the procedure are considered in the~ copy.
under, review. For new procedures verify that the final draft'of
'the procedure'is;being reviewed. ECurrent' reference material should be reviewed as necessary.(e.g.,' vendor. manuals, drawings).
4.2 ' Verify that the procedure meets-current Technical Specifications and be alert for omissions of additional Technical Specification. requirements from the procedure. Where practical, Technical ~ Specification requirements or limits should be identified'to' . personnel performing the procedures. . 4.3 . Verify'that the procedure meets requirements including but not limited to the following: a) Procedure is in current AI-4 format, and free of typographical errors. b) Requirements of FSAR or other licensing requirements are met (e.g., commitments), c) Title of procedure provides clear description of activity to be performed. d) The purpose for which the procedure is intended is clearly stated. e) Limits.on parameters being controlled and corrective measures necessary to return a parameter to its normal control band are specified where appropriate, i.e. . .~ a procedure should say: " Manually adjust control valve to maintain water level between 9.5 and 10.5. feet," not simply,
" Manually adjust' valve to maintain water level."
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~3 ATTACHMENT 1- -
'< Page 3 of 5~ . 4.0; PROCEDURE REVIEW GUIDET,INES (Continue'd) .
-4.3 .l(Continued) f) .Precautiona are provided to alert individuals tx) potentially health-threatening or equipment-damaging steps of a Procedure. Procedures should be' written'-to minimize risk as
- much as possible.' .. Cautionary notes applicable to specifici steps,Eshall be. included as: appropriate and clearly identified.
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g) Procedure is written clearlyLwith. sufficient data to perform-the procedure with minimal use of' extraneous information. Verify that correct engineering. units are-included ~on all-appropriate data and clearly identified.' h) Precautions are specified, where appropriate, to' alert
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individual.who is performing procedure,s of.thos'e situations. for which immediate corrective action may become :necessary.- i) Adequate documentation is provided by procedure'_to ensure that the purpose of the procedure has been fulfilled. 4 .'4 Verify that independent verification is included in'all procedures that require its use.. a) Verify double sign-offs are provided for all; steps. requiring . independent verification. 4.5 Verify that the Unreviewed Safety Question Determination form in SQA-119 "Unreviewed Safety Question Determination" has been-
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_ properly evaluated or ensures:-that qualified personnel review-the USQD.- 4.6 Verify that Cross-Disciplinary reviews are performed whenever' any of the following conditions apply, a) Response of a system under direct control of another group will be altered, and notification by other station procedures is not assured. I i I i i i 0710A/rtj
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,1 ATTACHMENT 1
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4.0 -: PROCEDURE REVIEW GUIDELINES (Continued) l 1 4 ~. 6 (Continued) 'l
)b) Steps in a ' procedure may affect equipment under another -
group's control.
.c) Whenever another group will be required to perform physical action to' allow the performance of the procedure.
(Example: 1 Isolation of a system.by the Operations Group prior to calibration of equipment by Maintenance.) Note: This step may not be required if the intent is ful'illed by. other station procedures. d) In cases where specific disciplines or. training is needed. _other than;that of the primary reviewer to assure'a complete technical review of the procedure. 4.7 Verify that the procedure meets ALARA criteria. 4.8 Verify that the references specified in'_the procedure 'are I current and complete. 4.9 Verify that information contained within the proce' dure-is accurate and complete. Information which is suspect should be-verified. . 4.10 Verify that any applicable. limits,' precautions,'or unique requirements specified in a . referenced operating pr~ocedure, I design documents, or vendor information literature are included' in the procedure or identified with source-document clearly ; referenced. 4.11 Verify that a minimum amount of interfacing between groups / sections is required to perform the procedure, a) Verify that notification.of appropriate groups are specified in the procedure for all phases of work..
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b) Verify that ' step (s) of the procedure which must be performed ? by another group are clearly' labeled and.the responsible
. group to perform the step (s) is clearly. defined.
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ATTACHMENT 1-
. Page 5 of 5 4;0- PROCEDURE REVIEW GUIDELINES (Continued) . ,
4.12- Verify that the nomenclature used within the procedure agrees ' with that'shown on the'affected components. i 4.13- Verify that any ambiguous and' vague wording or implied actions are eliminated. I 4.14 _ Verify that personnel performing the procedures are instructed '- on what response to expect from their actions and where necessary, what corrective actions to take., 4.15 Verify that appropriate procedure writer's guidelines are used.
-41.6 Verify that special tools, test equipment, etc... necessary to I . perform the procedure are listed.
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ENCLOSURE 3
" PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-87-34)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS FOR CHANGES TO SECTION 6, ADMINISTRATIVE CONTROLS I i I 4 - - - - i
ENCLOSURE 3-i- SIGNIFICANT HAZARDS CONSIDERATIONS Is.theprobabilityof.anoccurrence.ortheconsequences.ofanaccidentl_"[
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1; I F 'proviously evaluated in the safety analysis report significantly. ! .increasedt - No. This change is intended to accurately reflect the changes'to.the
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' Administrative controls Section (section 6) of the technical ;
}' specifications due to the realignment of the ONP. The functions. specified in section-6 important to the safe operation-of SQN have not ' been altered or deleted. The changes to this section merely; reflect.the ~
'new positions that hold the expertise to perforanthese functions. The i ! ' roles of PORC .RARC. NSRB,~and the ISEG are advisory roles to provide
- j. technical assistance to those individuals charged with the responsibility aof safe operation of this facility. This change better-identifies those-positions occupied by individuals qualified to provide this technical
; assistance. There are no hardware, procedure, personnel, or analysis changes represented byLthis amendment proposal which adversely affect the j probability.of-occurrence or the consequences of an accident previously.
evaluated'in the safety analysis report. The' proposed changes to PORC responsibilities will significantly reduce . the number of items that must be reviewed by PORC, thus allowing the PORC l members ~to focus their attention on the more~important safety-related
- 1. issues. Those items being removed from PORC review will still receive a i . detailed technical review by qualified individuals.
The revision to unit one fire brigade membership serves only to make the-
- technical specifications for both units consistent. This change, in'
! excluding the shift supervisor from membership in the brigade, ensures I that the -individual specified in 6.1.3 as being responsible for the control room command function is not distracted by this peripheral
! responsibility. This change does not adversely affect the safety-
-analysis.
- 2. Is the possibility for an accident of a new or different type than evaluated previously in the safety analysis report-created?~ l l
i No. This change represents only a change in the administrative process in that new' positions and responsibilities are identified for review functions of organizations such as PORC, RARC, NSRB, and ISEG. This 4 review function will continue to be performed by those individuals who- are technically competent to perform these review or advisory roles; therefore, the potential for the increase of a possibility of an accident I or' a new or different type accident from an inadequate review is-reduced rather than increased due to having the appropriate personnel designated-
! for these functions.
l 3. Is the margin of safety significantly reduced? 4 No. The changes in this amendment proposal serve only to clarify those. , positions -responsible for key safety functions specified in section 6 of I technical specifications. No function has been impaired or deleted by this change. On the contrary, these functions are enhanced by additional l clarity afforded by the reorganization. i I ! I
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