ML20085G226

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Requests Reconsideration of Denial of Portion of TS Change 90-22,submitted Via Util Re Section 6.0 Covering Administrative Controls.Proposed Wording for Organizational Topical Rept Contained on Encl
ML20085G226
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/15/1991
From: Joshua Wilson
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-79301, NUDOCS 9110240196
Download: ML20085G226 (5)


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Jr*i W c t . .. o 1 ,, , o: 4 Detober 15, 199!

TVA-SQN-TS-90-22 10 CFR 50.90 U.S. Naclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAP, Pl. ANT (SQN) - RECONSIDERATION OF DENIAL OF TEr" ICAL SPECIFICATION (TS) CHANGE 90-22 (TAC NOS. 79301 AND 79302)

References:

1, 1TA letter to NRC sated December 14, 1590, "Sequoyah Nuclear Plant (SQN) - Technical Specification (IS)

Change 90-22"

2. KRC letter to TVA dated August 22, 1991, " Issuance of Amendments (TAC NOS. 79301 and 79302) (TS 90-22)"

The purpose cf this letter is to request reconsideration of the denial of a portion of TS Change 90-22.

TVA requested changes to Section 6.0 of the TS for the administrative controls for SQN Units 1 and 2 by Reference 1. These :hanges included the incorporation of overtime limit guidance, position title changes, approval authority changes 'ar procedures and modifications, modification of the Plant Operations Review Connit tee compasition, ar.d reporting requirement changes for Offsite Dose Calculation Manual revisions. By Reference 2, NRC approved all requested changes with the exetption of a title change for the person on the Operations department staff holding a senior reactor operator (SRO) license from the Operations >bnager to the Operations Superintendent. IVA was requested to confirm that the persan executing the duties and responsibilities described in ANS: N18.;-L971 associated with Operations' me :agement has the appropriate qualifications as required by the current TS3, and to describe TVA's plans to resolve

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2 U.S. Nuclear Regulatory Comuisslor.

October 15, 1991 As described by Section 13.1.4.6.6 of the _'pdated Final Safety Analysis Report (UFSAR), the Operations Superintendent ext 'es the duties and responsibilities described in ANSI N18.1-1 as requiring an SRO license.

TVA does not consider the duties and respc ibilities of the Operations Manager to also require an SRO license. E:vever, TVA recognizes that the f unctions described for the Operations Manager in TVA's Organizational Topical Report and the Sequovah UFSAR could imply that the Operations Manager should also hold an SRO license. To resolve this issue. TVA will revise its Organizational Topical Report in a manner similar to that proposed in Enclosure 1 by April 1S, 1992, the date of the next annual update for that document. Please note that a similar change is not being proposed for the UFSAR as the UFSAR is being revised to reterence the Organization Topical Report.

Accordingly, TVA requests that NRC reconsider its denial of the proposed change to Section 6.2.2.f of the TS to change the title of Operations Manager to Operations Superintendent as the position on the Operations department staf' that is required to hold an SRO license.

Enclosure 2 contains a summary of commitments contained in this letter.

Please direct questions concerning this matter to J. D, Smith at (615) 843-6672.

Sincerely,

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L. Wilson Enclosures ec: See page 3

3 U.S. Nuclear Regulatory Commission October 15, 1991 cc (Enclosures):

Mr. D. E. laBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

e ENCLOSURE 1 Proposed Wording for the Organizational Topical Report Operations Mana m The Operations Manager has responsibility for planning, organizing, setting policy,'and motivation relating to the Operations, Chemistry, and Work Control Group personnel.- These activities include operati(nal strategies for seneration, chemistry control, water and waste usage, approved authority for system enhancements, and prioritization of maintenance activities. To meet these objectives, functions related to Operations, Work Control, and Chemistry are grouped under one manager responsible for

facility generation (i.e., Operations Manager).

-The Operations Manager has three principal reports:

Operations Superintendent Work Control Superintendent '

Chemistry Superintendent Operations Superintendent The Operations Superintendent is responsible for all plant operations. The

-superintendent, through the shif t operations supervisors, nanages the day-to-day operation of the facility, refueliag operations, start-up, operational testing, water and waste processing, and plant operations. The superintendent in responsible for coordinating and scheduling the training program for all Operations personnel as well as'providing the nucleus for emergency response teams.

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, ,. ENCLOSURE 2 2

  • Commitment Revise description of the Sequoyah Nuclear Plant Operations Manager and Operations Superintendent position in the Organizational Topical Report

- similar to the method presented in En::losure 1 of this letter by April 18, 1992.

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