ML20205G987

Proposed Tech Specs,Consisting of Changes to Parts of Section 6.0, Administrative Controls. Justification for Changes,Independent Qualified Review for Safety,Review of Facility Procedures & NSHC Encl

ML20205G987
Person / Time
Site:	Sequoyah
Issue date:	03/24/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20205G935	List: ML20205G929 ML20205G987
References
NUDOCS 8703310595
Download: ML20205G987 (41)

Text

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ISEGl wucifui e DIRECTOR Muctm g mas lPt.ANNINo at SCHEDUUNCl mm DMsm

, g,N SE ES ON t,c[NSINO MANAGER , MANAGER MANAGER. MANAGER MANAGER l PORS l l;NDUSTRfAL SAFETY *l

, PROJECT ENGINEER I

NPP RADIOLOGICAL wuNTENANCE SUPERINTENDENT CONTROL SUPERINTENDDR I

I I I I OPERATIONS SITE TECHNICAL ORoUP MANAoER CHEMISTRY SECURITY SUPPORT

• SRO SERVICES Assrsvar MT-asious-ano SHIFT '

SUPERVISOR SRo

• Responsibility for Fire Protection Program

. SHIFT SRO - Senior Reactor Operator License TE l o RO - Reactor Operator License Ear sureusosi seio UNIT OPERATOR ,

RO FIGURE 6.2-2 FACILIT( ORGANIZATION - SEQUOYAH NUCLEAR PLANT l

F11a:Pt. TORO?

. m ADMINISTRATIVE CONTROLS 6.4 TRAINING gusieor7ewef?lant(NPP)g

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6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the -t; :; .;..t M ara C.r.. .r.

...s. and shall N18.1-1971 meet or exceed the requirements and recommendations of Section 5.5 of l ANSI and Appendix "A" of 10 CFR Part 55 and the supplemental recuire-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. id:nti'id by C.i :C G. l 6.5 REVIEW AND AUDIT '

NUCLE. A P 6.5.0 The Manager of3Power i.

power plants. s responsible for the safe operation of all TVAll Figure 6.2-1. The functional organi:ation for Review and Audit is shown on 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The PORC shall function to advise the Plant E;mannGER.  ;;r' ncr. :nt on all matters related to nuclear safety. ll COMPOSITION G<ent h a sec 6.5.1.2 The PORC shall be composed of the:

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-- ADMINISTRATIVE CONTRO*.5 ALTERNATES 6.5.1.3 All alternate neebe-s shall be appointed in writing by the POR Chaiman to serve on a teepara y basis; however, no r. ore than two alternates shall participate as vo:ing nervers in POR: ac*ivities at any one -ine.

MEETING FREOUENCY E.5.1.4 The PORC shall meet at least once per calencar month and as convened by the PORC Chairman or his cesigna*ed al*ernate.

000RLH E. 5.1. 5 The minimum aucrum of the POR: necessary f er .he perfomance of the PORC responsibility and authority provisions of these *echnical specifications shall consist of the Chairman or his designated alternate and four members including alternates. ~

4 %443 p., e eversi 3ht- rev;ew ef sekcM saf ety evaluations f or: (1) procedures, (2) changr Ito procedures. equipment, systems or facilities, and (3) tests or RESPONSIBILITIES . experiments completed under the provision of 10 CFR 50.59 to l ' verify that such actions did not constitute an unreviewed safety C.S.1.6..The PORC, shall be responsible for. . M a%

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8, # Review of unit coerations to oetect potential nuclear safety hazards. ,

. -,n SEQUDYAH - UNIT 1 6-8 - - * - * " .

Revice of proposed pro:edures and changes to proceduffsMSN ' '

couipmer.1, systems or f acilities which aa--involve an,unrevi, ewe -

saf ety ouestion as cefined in 10 CFR 50.59. ' -

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Performan:e of spe:Tal reviews, investications or analyses and

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reports inereon as reouested by the Plant : .. ' .e d:n or the Nu: lear Safety Review Board. l

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g, ad Review of every unplanned onsite release of radioactive materiel to the environs including the preparation and forwarding of reports covering evaluation, recommendations and disposition of the corrective a: tion to prevent recurrence to tnl7) ire: tor, ;:'::- 5: - D' 'r#:-

l and to the Nuclear Safety Review Board.

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. AUTHORITY 5.5.1.7 The PORC shall:

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di r:;p :-:1 :' it;:.: ::r:'d: ed und - E.I. ' . ::: tr :::! ld th : rt. .

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?_ determination / in writing with regard to whether or not.44sk .

item :.:..id. d ;-d:s 5.5.1.E'-: :'r:c;r ': above constitutes an unreviewed safety cuestion. la. -

b,h SRt .

Provide written notifi:Etion within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the, Dire: tor, ': C n- -

Te .. !! ::i:r and the Nu: lear Safety Review Board of disacreement ~

between the PORC and the Plant ~;;fYIEEd:nt; .however, th Plant

a;; '-::nd:-t shall have responsibility for resolution of such

/msce]disagreemen~s pursuant .o E.i.i above.

RE00RDS

5. 5.1. 8 The PORC shall maintain written minutes of 'each PORC meeting that, at

-a minimu=, do:ument the resul s of all PORC attivities performed under the responsibility and authority provisions of these technical specifications.

Copies shall be previoed to the. Director, S .~.... ' s.: :' ::::n- and the.

cf;gg. Hu: lear Safety Review Boari L- Sike l

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6. 5. 2 NU LEAR SAFETY REVIEW EDARD (NSRE) ,

~ FUN ~ TION s

5.5.2.1 The HSP.B shall fun: tion tr provide independent review and audit 'of designated a:tivities in the areas of:

SEQUDYAH - UNIT 1 E-9

, INSERT: Sicticn 6.5.1A 6.5.1A TECHNICAL REVIEW AND CONTROL ACTIVITIES 6.5.lA.I. 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 j responsible manager as designated in writing by the Plant Manager or l Site Director as appropriate. The Site Director, Plant Manager, Superintendent NPP, 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 /gtoup 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, Superintendent NPP, 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 I by the Plant Manager, Superintendent NPP, or Maintenance l Superintendent.

d. Proposed changes to the Appendix A Technical Specifications shall be l prepared by a qualified individual / organization. The preparation of each proposed Technical Specification change shall be reviewed by an l

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.

e. Individuals responsible for reviews performed in accordance with Specifications 6.5.1A.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 e shall include determination of whether or not an unreviewed safety question is involved pursuant to Section 10 CFR 50.59.

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, . 'ADMINX5TRATfVE CONTROLS REVIEV Ce$nhAN E y ,, . . . . L t - "

-Q 6.5.2.7 The NSRS shall3review [0F:

a. The safety evaluations for 1) changes to procedures, equipment or systeris 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. Prcposed changes to procedures, equipmen*. or syttems 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, 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.

1E%2TABLG EVENT.S.

g. All 3 '" -  ;;:-1:  :: ; : ' :- - - - -' - '- '--

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.

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i. Reports and meetings minutes of the PORC and the RARC.

3 AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cogni:ance of'...

the NSRB. These audits shall encompass:

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a. The conformance of unit operation to provisions contained within the \.

Technical Specifications and applicable license conditions at least once per 12 months. 'i

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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 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 '

a-Assurance Program to meet the criteria of Appendix "B",10 CFR 50,

, at least once per 24 months. .

SEQUDYAH - UNIT 1 6-11 b

W.INISTRATIVE CONTROLS

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. A Safety Limit Violation Report shall be prepared. The report shall  !

. be reviewed by the PORC. This report shall oescribe (1) applicable  !

tircumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective  ;

action taken to prevent recurrence. l

d. The Safety Limit Violation Report shall be submitted to the Comission, i the HSRB and the Director, 6 .1 a. Te-cr Oi . i:icn within 14 days of the violation. b ae.S 6.8 PROCEDURES & PROGRAu.5  ;

l 6.8.1 Written procedures shall be established, implemented ar.d maintained covering the activities referenced below: *

a. The applicable procedures recommended in Appendix "A" of Regulatory

- Guide 1.33, Revision 2, February 1978. .

b. Ref~ueling.rperations. ,

. Su veillanbe and test a:tivities of safety-related ecuipment.

d. Plant Physical Security Plan implementation.

e. ~ Site Radiologi:a1 Emergency Plan implementation.

f. Fire Prote: tion Program implementation. .

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g. PRD ESS CONTROL PROGRAM implementation.

h. Quality Assuran:e Prog a= for effluent sonitoring, using t' he guitance contained in Regulatory Guide 4.15, De: ember 1577, or Regulato y Guion 1.21, Rev.1,1974 and Regulatory Guide ,4.1, Rev.1,1575.

6.8.2 Each procedure of 5.8.1 above, and changes thereto,- shall be reviewed l i; th: N ~ and approved b; th: " :t 5.;;rint;.ndent prior to implementation ' l

-:nf rc.i act ;;M:di .I'y as set forth in cd..iri t :t' /: p ::: u ::. '

apl .f eb ,es f 4. 4 s, c,4u4% c.r.sA abwe '

E. 8. 3 Temporary e procedure /g $ 6.E.1 above may be made provided:

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d,/ - The change is approved by two members of the. plant management staff, at least one of whom holds a Senior Rea: tor Operator's License on

. the unit affe:ted. A. mee4-se.reguirements af %ddW M.lA d*

h, / The change -is _ ... ., 7 . i:- . ; .... . . .; :.nd approved b; t" -

P. e.. . p;ri.. nd;n@ thin 14 days of implementation.

in c.uordue.c. wh 5 Pr$;*cd-ion I.S.14 ca>we.

. E. 8. 4 Written procedures shall be established, ic:alemented and maintained by l 2ha-Radiological Msi n Ir .r.:P covering the a:tivities below: ,  ;

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a. OFFSITE DOSE CALCULATIONAL MANUAL is

plementation.. . .,,,

SEQUDYAH - UNIT 1 -

5-15 . - -

A .. ... S..  ;.

ADMINXSTRATIVE CONTROLS

b. Quality Assurance Program for environmental monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977. I

c. Surveillance requirements and environmental monitoring requirements shown in Table 6.1-1.

6.8.5 The dndfollowing programs c.%es Bed shall be established,SecA'on I A occorciance we% 6. fold : implemented,E+*d mainta

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 practic51 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 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. Secondary Water Chemistry 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, .

(ii) Identification of the procedures used to" measure.the values of the critical variables, (iii) Identification of process sampling points, t

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SEQUOYAH - UNIT 1 6-15a i. . ~ . m..~ . . . um. 12 l

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AD"?M25TRATIVE CONTROLS )

l a cetermination that the change did not reduce the overall con- l b.

femance of the solidified waste product to existing criteria i

I for solid wastes; and

c. documentation of the fact that the change has been reviewed and found acceptable i., th: P0"I. 14 decendanu. wWA see{im 4.s.14.

2.- Shall become effective upon review and .x; pts;i b,7 thi PO*'I.

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6.14 DFFSITE DOSE CALCULATION MANUAL (ODCM) wi e Se W i m t..r.tA. .-

6.14.1 The CDCH shall be approved by the Commission prior to implementation.

6.14.2 Liecnsee initiated changes to the DDCM: .

' Shall be submitted to the Comnission in the next Semi-Annual Radio- - M active Effluent Release Report pursuant to Specification 6.9.1.9.

This submittal shall contain: ,

a. sufficiently detailed information to totally support the rat'ionale for the change without benefit of additional or supplemental information. Infomation submitted should consistent of a pa:kage of those pages of the DDOM to be changes with each page .

,nu=bered and provioed with an approval and date box, together with appropriate analyses or evaluations justifying the change (s);

b. a detemination that the change will not reduce the accura:f or reliability of dose calculations or setpoint ceteminations; -

,a,nd --: . . . . .

c. documentation of the fa:t that the change has been reviewed and '

fouEd accePable by tnrRARC. ,

. 2. Shall become effective upon review and acceptance by the RARO.

6.15 MAJOR CHANGES TO RADIDACTIVE WASTE TREATMENT SYST9'.5 (Liquid, Gaseous ,

anc Sohc) 6.15.1 Licensee initiated major changes to the radica:tive waste systems (liouid, gaseous and solid):" -

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1. Shall be reported to the Com:ission in the Semi-Annual Radion:tive 9~4g Effluent Release Report for the period in which the evaluation was reviewd ty 3 th: P:PI. The discussion of each change shall contain: ' ~

m oce.edene.e. whk .5eek 6.5".14.

a. A summary of the evaluatien that led to the determination that the chance could be made in accordance with 10 CFR 5D.59[

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" Submittal of infomation required by this section may be made as part of the- R' ,

annual FSAR updata. -

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SEQUDYAH - UNIT 1 ,

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b. sufficient detailed information to totally support the reason for t' 1 change without benefit of additional or supplemental inft sation; >

c. a detailed description of the equipment, components and proces-ses involved and the interfaces with other plant systems; .

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d. an evaluation ofradioactive%thechangewhichshowsthepredictedreleases materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments 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 application and amendments thereto; i f. a comparison of the predicted releases of radioactive materials, i

in liquid and gaseous effluents and in solid waste, to the

. actual. releases for the period prior to when the changes are to be made;

g. an estimate of the exposure to plant operating personnel as a '

result of the change; and ~

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h. documentation of the fact that the change was reviewed and

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, PROJECT ENGINEER NPP RADIOLOGICAL MAINTENANCE SUPERINTENDENT CONTROL SUPERINTENDENT I I I I oPERAMONS TECHNICAL GROUP MANAGER CHEMISTRY SITE SUPPORT SRO SECURITY SERVICES e tee onou,. -

sno SHIFT SUPERVISOR SRO SHIFT

• Responsibility for Fire Protection Program TE I L SRO - Senior Reactor Operator License g RO - Reactor Operator License Te"r ano UNIT OPERATOR ,

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RO-4 FIGURE 6.2-2 FACILITY ORGANIZATION - SEQUOYAH NUCLEAR PLANT File:Pt TORO 7

ADMINISTRATIVE CONTROLS E.: RAINING guclearDe(7/anf-(N?P) 6.4.1 A retraining and replacement train h :.o.;-at for the unit staff shall da maintained unoer the dire:: ion of the T.r. : ~: - Superintencentland l shall mee or exceed the recuirements and reccomentations of Se:-ion 5.5 of ANSI N18.1-lS71 and Appendix "A" of 10 CFR Part 55 and the suoplemental recuirements specified in Section A and C of Enciosure 1 of the Mar:n 28,19E0 NRC letter to all licensees, and shall include familiarization with relevan-in=ustry cperational experience.n...C .. .. .... ::::.

E. 5 REVIEW AND AUDIT NUCLERP

6. 5. 0 The Manacer 3of Power is., responsible for the safe cperatien of all TVA ll power plants. The functional organi:;ation for Review and Audit is shown on Figure E.2-1. '

E.5.1 PLANT 0 ERATIONS OEVIEW COMMIN EE (:0RC)

FUNCTION .- ,,

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6.5.1.1 The PORC shall fun: tion to acvise the Plant :.;;"-tu.:.r. on all . ll catters related to nuclear safety.

COMPOSITION G y pa aaer E.5.1.2 The PORC shall be ::mposed of the:

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SEQUOYAH - UNIT 2 6-10 r - . . _ , . , , , , , _ _ . c - ---..__,,..+7-.,

gg ;,,, , m<s'.3 b (s.' to 4 *W safety evaluations for: (1) protecures, (2) cnange procedures, equipment, systems or facilities, and (3) tests or.

A experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety cuestion. '

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m s ADMINISTRAiTVE CONTRDL5

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ALTERNATES

• 6.5.1.3 All alternate memoers shall be a:: pointed in writing by the 20RC l Chairman o se ve on a tempora y basis; however, no more than two alternates I sna11 pa-ticipate as voting mermers in PORC activities at any one time.

HEE ING FREQUENCY l 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by tae PORO Chair:an or his designated alternate.

000 RUM 6.5.1.5 The minimum cuoru= of the POR necessa y for the perfor=ance of the PORO responsibility and authority provisions of these Technical Specifications j shall consist of the Chairr.an or his cesignated alternate and four me=ce s l including alternates. ,

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RESPONSIBILITIES l

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g. 5.1.6 The FOR: shall be responsible for:

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ADMINISTRATIVE CONTROLS p p. Performance of special reviews, investigations or analyses ana l T. reports thereon as requested by the Plant y Er : ' ':-d:-t o' the l Nuclear Safety Review Board. Agu3er-

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@, g. Review of every unplanned onsite release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation, recommendatiog and disposition of the corrective action to prevent recurrence to the3 irector, M_;':_ *: :- C' ':':-

f and to the Nuclear Safety Review Board.

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l AUTHORITY 6.5.1.7 The PORC shall: [

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d. g h-% -- A d ete-minationf in writing with regard to whether or not each item considered under 6.5.1.6':.' t' :r;" ( ) above constitutes an unreviewed safety question. b .c.

Sk 6.g. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the3 Director,'.;.l a

' ' -' "' and the Nuclear Safety between the PORC and the Plant :_;; ' g:._ _gt; Board however, of disagreement the Plant

_;; '-t -f- ' shall have responsibility for resolution of such A p :isagreements d pursuant to e.l.1 above.

RECORDS 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. - '

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W5 #Nuclear cpies shall Safetybe provided Review Board. to they 0irector sae.

1. • 6.5.2 NUCLEAR' SAFETY REVIEW BOARD (NSRB)

. 5'. IA FUNCTION ,,

f 6.5.2.1 The NSRB shall function to provide independent review and a,udit of s designated activities in the areas of:

SEQUOYAH - UNIT 2 6-12 1

INSERT: S:ction 6.5.lA i

6.5.lA TECHNICAL REVIEW AND CONTROL ACTIVITIES 6.5.lA.l. Activities which affect nuclear safety shall be conducted as follows:

I a. Procedures required by Specification 6.8.1 and other procedures which

affect plant nuclear safety, and changes thereto, shall be prepared, i reviewed and approved. Each such procedure or procedure change shall j 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, Superintendent NPP, 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 i shall be approved prior to implementation by the Plant Manager, Superintendent NPP, 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 i 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, Superintendent NPP, or Maintenance Superintendent.

d. Proposed changes to the Appendix A Technical Specifications shall be o 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 I

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,

e. Individuals responsible for reviews performed in accordance with Specifications 6.5.1A.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.

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, ADMINISTRATIVE CONTROLS I

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REVIEW copiaan4 of i be C = ^ d b k 9:2$he  !

6.5.2.7 The NSRB shall n revieJj of:

a. The safety evaluations for 1) changes to procecures, equipment or systems and 2) tests or experiments ce=aleted under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety ouestion.

b. Proposed changes to procedures ~, ecuipment or systems which involve ar, unreviewed safety question as defined in Section 50.59, 10 CFR.

c. Preposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.

c. Proposed changes to Technical Specifications or this Operating License.

e. Violatidns.cf codes, regulations, crcers, Technical Specifications, license recuirements, or of internal precedures or instructions having nuclear safety significance.

f. Significant cperating abnormalities or deviations from normal and expected performance of unit equipment inat affect nuclear safety.

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h. All recogni:ed indications of an unanticipated deficiency in scoe aspect of design er operation of structures, systems, or ccmponents that ceuld affect nuclear safety.

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i. Repcrts and meetings minutes of the PORC and tht.g ARC.

E AUDITS 6.5.2.8 Audits of unit activities shall be performed uncer the cegni:ance of the NSRB. These audits shall enecmpass:

a. The conformance of unit cperation to previsions contained within the Technical Specifications and applicable license conditions at least once per 12 months.

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b. The performance, training and cualifications of the entire unit -

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staff at least once per 12 months. .

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c. The results of actions taken to correct deficiencies ot:urring in

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unit equipment, structures, systems or method of cperation that-affect nuclear safety at least once per 6 months.

d. The performance of activities recuired by the Operational Quality ,

Assurance Program to meet the criteria of Appendix "B",10 CFR 50, l at least once per 24 months. l

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SEQUOYAH - UNIT 2 6-N

. ADF.INISTRATIVE CON 7R01.5 O

c. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the PORC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation '

upon facility components, systems or structures, and (3) corrective action taken to prevent recurrence.

d. The Safety Limit Violation Report shall be submitted to the Commission, the NSRB and theyDirector, 1 .L.. ' . c ':': within 14 days of the violation. .me.

6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained.

covering the activities referenced below:,

. a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978. _ .

, b. Refueling operations. , ,,

c. Surveillance and test activities of safety related equipment. .

d. Plant Physical Security Plan implementation.

e. Site Radiological Emergency Plan implementation. .

f.

Fire Protection Program, implementation.

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g. PROCESS CONTROL PROGRAM implementation. .

h. Quality Assurance Program for effluent monito' ring, using the guidance contained in Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, Rev.1, IS75. R34 6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be revie' wed Q ^.. m .'07,0 and approved t t'.; "rt %: '-t - '- ' prior to implementation m.s ....:....s .. se._,,..

Tem & \ ,9 as set forth iny:1 '-i:cr: tic: spat.gca% e- ' 6.S.l A a%pr: x f xx.

. 6. 8. 3 porary :hr;x i:

3 procedurefy+ 6.8.1 above may be made provided:

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• t/ The ch'nge a is approved by two members 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 p pgg 4,cA,g .

' h / '"The change.is M- r r'-f, : ' cf % th: **'? rf approved t ":

n. '.tuf xtyWthin 14 days of implementation. ._.  ;

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Q.3 SEQUOYAH - UNIT 2 6-18 .' ;xin nt t. ? '

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ADMINISTRATIVE CONTROLS 6.8.4 Written procedures shall be established, implemented and maintained by ee- Radiologica@4rdp Con r 2n d covering the activities below:

a. OFFSITE Dd3E CALCULATIONAL MANUAL implementation.

b. Quality Assurance Program and environmental monitoring, using the guidance contained in Regulatory Guide 4.15, December 1977.

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c. Surveillance requirements and environmental monitoring requirements shown in Table 6.1-1.

6.8.5. The following programs shall be established,, implemented, and.maintainedf and c% %.se4. in accordance w% Seche t 4.s.sA :

a. Primarv 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 injection 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 maintenanc.e and periodic visual inspection requirements, and O

V (ii) Integrated leak test requirements for each system at refueling cycle intervals or less.

b. In-Plant Radiation Monitoring 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 personn I, (ii) Procedures for monitoring, and (iii) Provisions for maintenance of sampling and analysis equipment.

c. Secondary Water Chemistry 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, i (ii). Identification of the procedures used to measure the values of  !

I the critical variables, O-s (iii) Identification of process sampling points, l

I SEQUOYAH - UNIT 2 -

6-19 '

. . . ~ , J.. ~ . J. . ~ . 2 '-

l ADMINISTRATIVE CONTROLS m

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 i such areas and the keys shall be maintained under the acministrative control I of the Shift Engineer on duty and/or the Health Physicist.

6.13 PROCESS C0hTROL PROGRAM (PCP) 6.13.1 Licensee initiated changes to the PCP: R3 1.

Shall be submitted to the Comission in the semi-annual Radioactive Effluent Release Report for the period in which the change (s) was made. Thip submittal shall contain:

a. sufficiently detailed information to totally support the fationale for the change without benefit of additional or supplemental information,

b. a determination that the change did not reduce the overall

- confomance of the solidified" waste product to existing criteria for solid wastes; and ,

c. documentation of the fact that the change has been reviewed and fcund acceptable b; N "***. in accordec.e. w% SeeN 6.5.M.

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Shall become effective uponagrwo review andg\ce.(dant ha

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• 6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by the Commission prior to implementation. "

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6.14.2 Licensee initiated changes to the'0DCM9. # ~ -

1.

Shall.'be submitted to the Commission in the next Semi-Annual Radioactive Effluent Release Report pursuant to Specification R3I 6.9.1.9. -This submittal shall contain:

a. sufficiently detailed infor=ation to totally support the rationale for the change without benefit of additional or supplemental information. Information submitted should consistent of a package of those pages of the ODCM to be changes with each page nu=bered and provided with an approval and date box, together with appropriate analyses or evaluations justifying the change (s);

b. a determination that the change will not reduce the" accuracy or-reliability of dose calculations or setpoint determinations; and . . -

c. documentation of the fact that the change has been reviewed and.

1ound acceptable by the-RARC. .

f.Y SEQUDYAH - UNIT 2 6-30 l. . . _.m . . _ . ' ' -

- _ _ . , - - - - , - - y . - - , ,

I ADMINISTRATIVE CONTROLS m

j 2. Shall become effective upon review and acceptance by the RARC.

I 6.15. MAJOR CHANGES TO RADIDACTIVE WASTE TREATMENT SYSTEMS (Liquid, Gaseous  ;

and Sohd) 1 6.15.1 Licensee initiated major changes to the radioactive waste systems  :

(liquid, gaseous and solid):" 1

1. Shall be reported to the Corr. mission in the Semi-Annual Radioactive Effluent Report for the period in which the evaluation was reviewed t, i "'TfyThe di,scussion of each change shall contain:

in accadade vMk Se:h b5;lA.

a. A summary of the evaluation that led to the detemination that the change could be made in accordance with 10 CFR 50.50; ,

b. sufficient detailed info'mation to totally support the reason for the change without benefit of additional or supplemental information; ,

c. a detai-led description of the, equipment, components and proces-ses involved and the interfaces with other plant systems;

d. an evaluation for the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the li. cense application and amendments 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 i in the license application and amencments thereto; i

f.

a comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the' changes are to be made;

g. an estimate of the exposure to plant operating personnel as a .,

result of the change; and

h. decumentation of the fact,that the change was reviewed and found acceptable y 5 M: '?'?.

enwaic_ dith Siech 4 - 14.

2.

Shall become effective upon review and acceptancQ3 tk '~r.

'm acewdance wh Secti" #'I A*

Submittal of information required by this section may b'e made as part of the annual FSAR update. 73 4 7

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SEQUOYAH - UNIT 2 .

E-31 n 5m._2.. . [ . "

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l 4

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND'2 (TVA SQN TS 87-08)

JUSTIFICATION FOR CHANGES TO PORC. RESPONSIBILITIES Description of Change This change will extensively revise parts of Section 6.0, " Administrative Controls," affecting the Plant Operations Review Committee (PORC). The revision will delete several items from PORC responsibility and place them under the new " technical review and control" 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.

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.

Some of the marked-up pages of the technical specifications contain changes which were submitted by a May 27, 1986 letter from R. L. Gridley to B. J. Youngblood. NRC is currently in the process of approving this change.

Those changes which were previously submitted will be indicated by double revision bars.

Some position titles have changcd since the May 27, 1986 submittal. The,se changes have been reflected on the marked-up pages of figure 6.2-2 and the PORC composition (page 6-7a, unit 1, and page 6-10, unit 2). Also, section 6.5.2.7 will be revised to hold the Nuclear Safety Review Board (NSRB) responsible for cognizance of identified review items.

Reason for Change A very large administrative burden to PORC has resulted from the current 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 l verifying that operating activities are conducted safely and in accordance with administrative controls.

Justification for Change 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 and other procedures which affect plant nuclear safety and changes thereto will be controlled under Section 6.5.1A, " Technical Review and Control."

A new administrative instruction, AI-43 (Independent Qualified Review), will establish requirements for " Technical Review and Control." AI-43 will establish qualifications and training requirements necessary for qualified reviewers. Specific guidelines are given for performing the independent qualified review, and the appropriate level of management to approve the change will be designated. A copy of AI-43 is provided in attachment 1. This 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 review process. TVA will inform NRC of any significant changes which may occur to this procedure.

AI-4, " Preparation, Review, Approval, and Use of Plant Instructions,"

will require review and approval in accordance with 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. QA will be given the option to review all changes. Items which are not applicable to QA review will be marked accordingly.

2) Review of all programs required by specification 6.8.5 and changes thereto will be controlled under new section 6.5.lA. Specification 6.8.5 is being revised to include this review.

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.lA. The review cycle will consist of the qualified reviewer's approval and the responsible section supervisor's approval. The Plant Manager, Superintendent NPP, or Maintenance Superintendent must provide final approval, J

, 7

c) Review of all proposed changes to appendix "A" of the technical specifications will be controlled under section 6.5.lA. 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 l before being sent to NRC.

d) Review of all proposed changes or n.odifications to unit systems or equipment that affect nuclear safety will be controlled under section 6.5.lA. Additionally, Quality Engineering and Control will review all workplans before initial approval. The Plant Manager, Superintendent NPP, or Maintenance Superintendent must provide final approval of the change.

1 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 dono in accordance with section 6,5.lA. Also, an audit under the cognizance of NSRB will be performed at least once per 12 months of the Plant Physical Security Plan, the Safeguard Contingency Plan, the Site Radiological Emergency Plan, and implementing procedures.

1) Review of changes to the radwaste treatment systems is also covered by specification 6.15. Review and approval of these changes will be done in accordance with section 6.5.lA. Additionally, Quality Engineering and Control will review all changos beflee being approved. The Plant Manager, Superintendent NPP, 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 responsibilities 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 TS violations. It is not practical for PORC to perform investigaticn of L

the violatloa. Investigation and preparation

, -The following PORC responsibilities 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 prevent recurrence is performed by the appropriate line organization. PORC will provide oversight to ensure the evaluations and recommendations are sufficient and complete.

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 TS 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 (NUREG-0452).

The following PORC responsibilities will be added to section 6.5.1.6:

a) PORC will provide an oversight review of selected safety evaluations 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 be reported to PORC at scheduled monthly meetings. This report will become a part of PORC meeting minutes, along with any actions to be taken from the report. Individuals performing oversight review shall meet the qualifications specified in AI-43.

b) PORC will provide a 100-percent review of proposed procedures and changes to procedures, equipment, syctems, or facilities which involve an unreviewed safety question as defined in 10 CFR 50.59.

Specification 6.5.2.7 is being revised to avoid confusion in interpreting the way NSRB review is required to be conducted. NSRB delegates the review through use of appointed subcommittees. The newly restructured NSRB does not '

believe the revised wording would allow this delegation. The proposed change clearly. states NSRB's responsibility to be cognizant of the identified review items.

i Specification 6.8.3 will delete temporary changes. Temporary approval of procedure changes will be permitted if the appropriate manager is not available to allow for the normal review process. Temporary approval shall l consist of two qualified reviewers (per AI-43) of the plant management staff, j at least one of whom holds a Senior Reactor Operator License on the unit 4 affected. Upon temporary approval, the change may be implemented. Final I approval must be given within 14 days of the temporary approval.

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If an instruction change is given temporary approval and then rejected prior to final approval, a new instruction change request must be initiated by the 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.

The requested amendment requires that decisions affecting safety be made at l the proper level of responsibility with the necessary technical advice and review. The detailed technical reviews can be accomplished by qualified individuals not encumbered with other managerial duties but possessing the technical expertise to provide a thorough review. The current technical specification requirement for review of changes is actually satisfied by individuals of a similar responsibility level; however, considerable management time is consumed in assigning these personnel to review each 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 I 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.

2 For the reasons stated above, TVA has concluded that the proposed technical specification changes will significantly enhance management control and nuclear safety.

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SQN AI-43 Page 1 DRAFT (RO)

INDEPENDENT QUALIFIED REVIEW TABLE OF CONTENTS Page 1.0 PURPOSE 2 2.0 SCOPE 2 3.0 SOURCE DOCUMENTS AND REFERENCES 2 4.0 DEFINITIONS 3 5.0 QUALIFIED REVIEW 3 t 6.0 QUALIFICATIONS OF REVIEWERS 6

. APPENDIX 1 - 8

, ATTACHMENT 1 - QUALIFIED REVIEW GUIDELINES 9 1

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SQN AI-43 Page 2 DRAFT (RO) 1.0 PURPOSE This Administrative Instruction (AI) establishes the requirements for Independent Qualified Review (IQR) for activities which affect nuclear safety at Sequoyah Nuclear Plant (SQN).

2.0 SCOPE The IQR program establishes technical review of procedures and safety evaluations for the following:

• Precedures 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 53.59.

3.0 SOURCE DOCUMENTS AND REFERENCES 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 References j 3.2.1 AI-4, " Preparation, Review, Approval and Use of Plant Instructions" 3.2.2 AI-19, Part IV,J" Plant Modifications

After Licensing" 3.2.3 STI-1, "Special Test Instructions" i

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.SQN AI-43 Page 3 DRAFT (RO)

3.2 References (Continued) 3.2.4 SQA-21, " Plant Operation Review Committee Charter" 3.2.5 SQA-30, " Responsibility for Technical Specification Changes" 3.2.6 SQA-119, "Unreviewed Safety Question Determination" 4.0 DEFINITIONS 4.1 Cross - Disciplinary Review - Technical review by disciplines  ;

l other than those responsible for the procedure / document preparation. This review is performed by Qualified Reviewers i (QR) and includes technical aspects of the procedure / document-

! organizational interfaces, and edequacy of safety evaluations, i 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 i proposed changes or , modifications to plant nuclear safety -

related structures, systems, and components, proposed changes to j Appendix A Technical Specifications, or 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.

4.3 Qualified Reviewer (QR) - An individual responsible for technical review of activities which affect nuclear safety and is designated by his group /section head to perform IQR. This 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 individual / organization per SQA-30. -

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SQN AI-43 Page i DRAFT (RO) 5.0 QUALIFIED REVIEW (Continued) 5.2. Review Requirements 5.2.1 Procedures required by Sequbynh Nuc; ear 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 SQA-119, another QR qualified per SQA-119 must perform evaluation of the USQD.

5.2.2 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 shall 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 determination of whether or not an unreviewed safety question is involved, i

5.2.4 Proposed changes to the Appendix A Technical Specifications shall be reviewed by a qualified i reviewer / group other than the reviewar/ group which i

pretared the proposed change. This review may be done by 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.

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SQN AI-43 Page 5 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 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).

5.4 Approvals Approvals shall be obtained in accordance with the appropriate reference.

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SQN AI-43 Page 6 DRAFT (RO) 6.0 QUALIFICATION OF REVIEWERS 6.1 Training Requirements Qualified Reviewers chall only perform reviews within their respectiva crea 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 i 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 i education requirements:

• Academic and related technical training l

• 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)

• Certification of academic ability and knowledge, by 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, s

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SQN AI-43 Page 8 DRAFT (RO)

APPENDIX 1 EXAMPLE (All required disciplines will be listed)

OPERATIONS:

9 Submitted

• Responsible Manager Approved by Plant Manager l l

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SQN AI-43 Page 9 DRAFT (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.

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SQN AI-43 Page 10 DRAFT (RO)

ATTACHMENT 1 Page 2 of 5 .

4.0 PROCEDURE REVIEW GUIDELINES To meet these objectives, the following guidelines have been developed 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. Current 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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SQN AI-43 Page 11 DRAFT (RO)

ATTACHMENT 1 Page 3 of 5 .

4.0 PROCEDURE REVIEW GUIDELINES (Continued) 4.3 (Continued) f) Precautions are provided to alert individuals to 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 specific _

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steps, shall be included as appropriate and clearly identified.

g) Procedure is written clearly with 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.

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l h) Precautions are specified, where appropriate, to alert individual who is performing procedure _s of those 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 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 i will be altered, and notification by other station procedures is not assured.

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o SQN AI-43 Page 12 DRAFT (RO)

ATTACHMENT 1 Page 4 of 5 4.0 PROCEDURE REVIEW GUIDELINES (Continued) 4.6 (Continued) 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: 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 fulfilled 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 current and complete.

4.9 Verify that information contained within the procedure 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 procedure, 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.

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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SQN AI-43 Page 13 DRAFT (RO)

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.

4.13 Verify that any ambiguous and vague wording or implied actions are eliminated.

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

. perform the procedure are listed.

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, ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 (TVA SQN TS 87-08)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS FOR PROPOSED CHANGES TO PORC RESPONSIBILITIES

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

No. The Plant Operations Review Committee (PORC) serves in an advisory capacity to the Plant Manager in matters related to safety in plant operation. The proposed change will significantly reduce the number of items that must be reviewed by PORC thus allowing the PORC members to focus their attention on the more important safety-related issues. Those items being removed from PORC review will still receive a detailed technical review by qualified individuals.

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

No. PORC will still exist to advise the Plant Manager. No operability or surveillance requirements for systems, structures, or components used to terminate or mitigate accidents are being reduced and no equipment changes are involved.

3. Is the margin of safety significantly reduced?

No. The proposed changes are administrative in nature and conform to NRC guidance in recently issued technical specification amendments. Nuclear safety should be significantly enhanced.

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