ML13326A962

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Application for Amend 214 to License DPR-13,consisting of PCN-265,requesting to Delete Physical Protection Program Reporting Requirement from License Condition 2.D
ML13326A962
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 12/22/1995
From: Rosenblum R
Southern California Edison Co
To:
Shared Package
ML13326A961 List:
References
NUDOCS 9512270289
Download: ML13326A962 (5)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORvY COMMISSION Application of SOUTHERN CALIFORNIA Docket No. 50-206 EDISON COMPANY and SAN DIEGO GAS & ELECTRIC

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COMPANY, for a Class 104(b) License to

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Acquire, Possess, and Use a Utilization Amendment Application Facility as Part of Unit No. 1 of the San

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No. 214 Onofre Nuclear Generating Station

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SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 214.

This amendment application consists of Proposed Change Number 265 to Facility Operating License No. DPR-13.

Proposed Change No. 265 is a request to revise the San Onofre Unit 1 License Condition 2.D. License Condition 2.D is requested to be modified to delete License Condition 2.C(4) from the reporting requirements delineated in 2.D.

Subscribed on this f2g' day of 1995 Respectfully submitted, SOUTHERN CALIFORNIA EDISON MPANY No Ptbic - Colibo.

San Diego County By:

MC omm.

Expires Oct 16.19W cha99rdM. osenblum

-w c

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osenbhlum Vice President State of California County of San Diego On?6efr me, personally appeared

',personally known to me to be the person whose name is subscribe to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

WITNESS my hand an fials Signatur 9512270289 951222 PDR ADOCK 05000206 P

PDR

DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NUMBER 265 Proposed Change Number 265 is a request to revise License Condition 2.D of Facility Operating License DPR-13 for the San Onofre Nuclear Generating Station (SONGS) Unit 1.

EXISTING LICENSE CONDITIONS 2.D See Attachment 1 PROPOSED LICENSE CONDITIONS See Attachment 2 DESCRIPTION OF CHANGE This proposed change requests the reference to License Condition 2.C(4) be deleted from License Condition 2.D to eliminate the redundant reporting requirement for violations of the physical protection program plans. The reporting requirements and criteria for the physical protection program are specified in 10CFR73.71 and 10CFR73 Appendix G. Therefore, reporting physical protection events under License Condition 2.D is redundant and not necessary.

DISCUSSION This proposed change, which is a request to revise License Condition 2.0, is considered an administrative change. The physical protection program at SONGS will not be changed or modified as a result of PCN-265. The physical protection program will continue to be implemented and maintained in accordance with the NRC approved physical security, security force training and qualification, and safeguards contingency plans.

Included in License Condition 2.D is the requirement to report violations of the requirements contained in License Condition 2.C(4), the license condition for the physical protection program. The physical protection program has specific reporting requirements located in 10CFR73.71 and 10CFR73 Appendix G.

The reporting under License Condition 2.D is duplicative, not specific to the physical protection program, and consequently, unnecessary. This proposed change removes License Condition 2.C(4), physical protection, from License Condition 2.D, reporting requirements.

SAFETY ANALYSIS

1. Will operation of the facility according to this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated.

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Response: No This proposed change is considered an administrative change. It has no impact on the probability or consequences of any of the accidents previously evaluated. This change revises License Condition 2.D to remove the burden of duplicate reporting requirements. This change does not affect the physical protection program as previously approved by the Nuclear Regulatory Commission (NRC).

A reporting requirement in License Condition 2.D is being revised to remove the reference to License Condition 2.C(4) for the physical protection program. The reporting requirements for the physical protection program are located in the regulations, 10CFR73.71 and 10CFR73 Appendix G.

Therefore, the probability and consequences of an accident previously evaluated are not affected by these proposed changes.

2. Will operation of the facility according to this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No This proposed change is considered an administrative change. It has no impact on equipment, systems, or structures such that a new or different kind of accident is created. This change revises License Condition 2.D to remove duplicate and unnecessary reporting requirements for the physical protection program. There is no change associated with the implementation and maintenance of the physical protection program as previously approved by the NRC.

Therefore, the possibility of a new or different kind of accident from an accident previously evaluated is not created.

3. Will operation of the facility according to this proposed change involve a significant reduction in a margin of safety?

Response: No This proposed change is considered an administrative change only. It has no impact on the margin of safety associated with the physical protection program. This change revises License Condition 2.D to remove duplicative and unnecessary reporting requirements for the physical protection program. The maintenance and implementation of the physical protection program is not affected by this change.

Therefore, there will not be a significant reduction in a margin of safety.

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SAFETY AND SIGNIFICANT HAZARDS DETERMINATION Based on the above Safety Analysis, it is concluded that:

(1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92 and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.

Moreover, because this action does not involve a significant hazards consideration, it will also not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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ATTACHMENT 1 EXISTING LICENSE CONDITION UNIT 1