ML13331B053
| ML13331B053 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/01/1988 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13331B052 | List: |
| References | |
| NUDOCS 8807140084 | |
| Download: ML13331B053 (9) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON
)
COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY )
for a Class 104(b) License to Acquire,
)
DOCKET NO. 50-206 Possess, and Use a Utilization Facility as
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Part of Unit No. 1 of the San Onofre Nuclear )
Amendment No. 152 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. 152.
This amendment consists of Proposed Change No. 188 to Provisional Operating License No. DPR-13. Proposed Change No. 188 modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A.
Proposed Change No. 188 is a request to revise Appendix A Technical Specification Section 6.5 requirements in the area of Nuclear Safety Group (NSG) review responsibilities.
The revision is an administrative change that will reduce the scope of NSG required reviews in order to allow a focus of NSG resources as required by safety significance.
In the event of conflict, the information in Amendment Application No. 152 supersedes the information previously submitted.
8807140084 880701 PDR ADOCK 05000206 P
-2 Based on the significant hazards analysis provided in the Description and Significant Hazards Consideration Analysis of Proposed Change No. 188, it is concluded that (1) the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.
Pursuant to 10 CFR 170.12, the fee of $150 is herewith remitted.
-3 Subscribed on this.4i1 day of 1988.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:_
Kenneth P. Basrin Vice President Subscribed and sworn toefore me this g'4g?
day of
/fCf 4Not Public in and for the County of Lo Angeles, State of California My Commission Expires: Z,6/'799 OFFICIAL SEAL AGNES CP,ABTREE Notary Public-California Charles R. Kocher LOS ANGELES COUNTY James A. Beol etto My Comm. Exp. Sep. 14, 1990 Attorneys for Southern California Edison Company B y : ' a s
-4 Subscribed on this 27th day of June
, 1988.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY Gary DdCotton Senior Vice President Engineering & Operations Subscribed and sworn to before me this o2_ day of
- 6 HOFFICIAL SEAL STEPHANIE E. HITT NGFARY PUBLIC-CALIFORNIA INCIPAL OFFICE IN SAN DIEGO COUNTY I Commssion Exp. Aug. 30, 1991 Notar Public in and for the County of San Diego, State of California My Commission Expires:
O 3
/
David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:
David R. Pigott
0 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN
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CALIFORNIA EDISON COMPANY
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and SAN DIEGO GAS & ELECTRIC
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Docket No. 50-206 COMPANY (San Onofre Nuclear
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Generating Station Unit No. 1 CERTIFICATE OF SERVICE I hereby certify that a copy of Amendment Application No. 152 was served on the following by deposit in the United States Mail, postage prepaid, on the Fifth day of July, 1988.
Benjamin H. Vogler, Esq.
Staff Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 David R. Pigott, Esq.
Samuel B. Casey, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 L. G. Hinkleman Bechtel Power Corporation P.O. Box 60860, Terminal Annex Los Angeles, California 90060 Michael L. Mellor, Esq.
Thelen, Marrin, Johnson & Bridges Two Embarcadero Center San Francisco, California 94111 Huey Johnson Secretary for Resources State of California 1416 Ninth Street Sacramento, California 95814 Janice E. Kerr, General Counsel California Public Utilities Commission 5066 State Building San Francisco, California 94102
-2 C. J. Craig Manager U. S. Nuclear Projects I ESSD Westinghouse Electric Corporation Post Office Box 355 Pittsburgh, Pennsylvania 15230 A. I. Gaede 23222 Cheswald Drive Laguna Niguel, California 92677 Frederick E. John, Executive Director California Public Utilities Commission 5050 State Building San Francisco, California 94102 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 J m A. Beole fo-
[S.
DESCRIPTION AND SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS OF PROPOSED CHANGE NO. 188 TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATING LICENSE NO. DPR-13 This is a request to revise Section 6.5.3, "NUCLEAR SAFETY GROUP (NSG)" of the Appendix A Technical Specifications for San Onofre Nuclear Generating Station, Unit 1 (SONGS 1).
DESCRIPTION OF CHANGE Technical Specification 6.5.3.4 addresses the review responsibilities for procedure revisions, equipment design changes, tests and experiments and events reported to the Nuclear Regulatory Commission. Proposed Change No. 188 would delete the Nuclear Safety Group review responsibilities outlined in Technical Specification requirements 6.5.3.4.a and 6.5.3.4.g.
EXISTING SPECIFICATION See Attachment 1 PROPOSED SPECIFICATION See Attachment 2 SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS As required by 10 CFR 50.91(a)(1), this analysis is provided to demonstrate that a proposed license amendment to implement a rivision to the Nuclear Safety Group review responsibilities for SONGS 1 represents a no significant hazards consideration. In accordance with the three factor test of 10 CFR 50.92(c), implementation of the proposed license amendment was analyzed using the following standards and found not to: 1) involve a significant increase in the probability or consequences for an accident previously evaluated; or 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.
Analysis The activities described in Sections 6.5.3.4.a and 6.5.3.4.g currently receive extensive technical and managerial review before being sent to the corporate review group for another independent review. Specifically, Technical Specification 6.5.2, "Technical Review and Control," contains detailed requirements for processing changes to plant procedures, equipment and tests and experiments. These requirements include both independent technical review and management approval.
Interdisciplinary reviews which encompass more than five diverse technical organizations, by personel of education and experience levels that meet or exceed *that required for the Nuclear Safety Group staff, as well as the management chain for these organizations, are currently performed for each of these items.
Thus, the review by the Nuclear Safety Group (NSG) is redundant to previous reviews and is not required. The proposed change would, therefore, delete Technical Specification paragraphs 6.5.3.4.a and 6.5.3.4.g.
-2 No change in Nuclear Safety Group staff is involved in the proposed change.
The proposed change will allow SCE the flexibility to focus resources on significant plant events, innovative programs (such as probabilistic risk assessment of key areas of plant performance), conceptual review of plant changes (while the engineering work is in progress), and other appropriate activities. This change is intended to improve the utilization of Nuclear Safety Group personnel by removing the requirement to participate in processes which already receive a high level of review, thereby allowing them to focus their efforts on "significant operating abnormalities," "violations of codes, regulations... having nuclear safety significance," "indications of unanticipated deficiencies," and "changes... which involve an unreviewed safety question" as described in the remaining list of NSG responsibilities in Technical Specification 6.5.3.4.
Conformance of the proposed changes to the standards for a determination of no significant hazard as defined in 10 CFR 50.92 (three factor test) is shown in the following:
- 1. Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?
RESPONSE: NO Technical Specifications currently require the Nuclear Safety Group (NSG) to review, among other things, 1) safety evaluations for a) changes to procedures required by Specification 6.8, equipment or systems, and b) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question and 2) events requiring written notification to the Commission. The proposed change would eliminate the requirement for NSG review of the above items based upon the fact that such items receive interdisciplinary and technically cognizant management reviews prior to receipt by the NSG. Thus, since adequate reviews are being performed, approval of the proposed change will eliminate unnecessary duplication of review efforts and allow SCE to focus NSG efforts on other safety issues.
Therefore, operation of this facility in accordance with this proposed change will not involve a significant increase in the probability or consequences of accidents previously evaluated.
- 2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
RESPONSE: NO For the reasons discussed in response to item 1 above, this change is administrative in nature only and does not affect plant equipment, operating processes, or the accident analysis.
Therefore, the proposed change will not create the possibility of a new or different kind of accident.
S S
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- 3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
RESPONSE: NO For the reasons discussed in response to item 1 above, the revision to Technical Specification 6.4 is responsive to a revised rule and is administrative in nature.
This change is administrative in nature only and does not affect the safety analysis or underlying assumptions.
Therefore, the proposed change will not affect any margin of safety.
SAFETY AND SIGNIFICANT HAZARDS CONSIDERATION 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 10 CFR 50.92 and (2) the health and safety of the public will not be endangered by the proposed change.
LAB:9584F