ML13336A105
| ML13336A105 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/17/1988 |
| From: | Holahan G Office of Nuclear Reactor Regulation |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| TAC-68708, NUDOCS 8808250185 | |
| Download: ML13336A105 (18) | |
Text
.
-August 17, 1988 MEMORANDUM FOR:
Dennis F. Kirsch, Director Division of Reactor Safety and Projects Region V FROM:
Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
REQUEST FOR TECHNICAL ASSISTANCE - SAN ONOFRE UNIT NO. 1 (TAC NO. 68708)
By letter dated July 1, 1988 (enclosed), Southern California Edison requested an amendment to the San Onofre Unit 1 Technical Specifications. The proposed change would delete two review responsibilities from the off-site Nuclear Safety Group.
One of the changes would drop NSG review of 10 CFR 50.59 safety evaluations for changes to procedures and tests or experiments. As you know, we have had at least two occasions when we did not agree with Edison's determination of "no unreviewed safety question", and would note here that this group does not review proposed changes to the facility itself for unreviewed safety questions.
Because of Region V's familiarity with the various review groups associated with San Onofre, we would like to request your assistance in reviewing this proposed change. We request that you provide a written safety evaluation addressing the acceptability of the Edison proposal.
Our goal is to complete actions such as this in about 60 days.
TAC No. 68708 has been assigned to this effort.
original signed by Kenneth Perkins for Gary M. Holahan Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
SCE letter dated 7-1-88
Contact:
Charles M. Trammell (492-3121)
DISTRIBUTION DOCKET FILE NRC & LOCAL PDRs G:S08250185 880817 P
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 August 17, 1988 MEMORANDUM FOR:
Dennis F. Kirsch, Director Division of Reactor Safety and Projects Region V FROM:
Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
REQUEST FOR TECHNICAL ASSISTANCE - SAN ONOFRE UNIT NO. 1 (TAC NO. 68708)
By letter dated July 1, 1988 (enclosed), Southern California Edison requested an amendment to the San Onofre Unit 1 Technical Specifications. The proposed change would delete two review responstbilities from the off-site Nuclear Safety Group.
One of the changes would drop NSG review of 10 CFR 50.59 safety evaluations for changes to procedures and tests or experiments. As you know, we have had at least two occasions when we did not agree with Edison's determination of "no unreviewed safety question", and would note here that this group does not review proposed changes to the facility itself for unreviewed safety questions.
Because of Region V's familiarity with the various review groups associated with San Onofre, we would like to request your assistance in reviewing this proposed change. We request that you provide a written safety evaluation addressing the acceptability of the Edison proposal. Our goal is to complete actions such as this in about 60 days.
TAC No. 68708 has been assigned to this effort.
Gary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
SCE letter dated 7-1-88
Contact:
Charles M. Trammell (492-3121)
Enclosure Southem California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN July 1, 1988 TELEPHONE VICE PRESIDENT 818-302-1401 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Amendment Application No. 152 San Onofre Nuclear Generating Station Unit 1 Enclosed is Amendment Application No. 152 to Provisional Operating License No. DPR-13. Amendment Application No. 152 consists of Proposed Change No. 188 which requests revision of the Appendix A, Technical Specifications.
Proposed Change No. 188 is a request to revise Appendix A Technical Specification regarding the Nuclear Safety Group (NSG) review responsibilities. The revisions consist of a deletion of NSG review of 10 CFR 50.59 evaluations and reportable event reports.
Pursuant to 10 CFR 170.12, the review of Amendment Application No. 152 has been determined to require a fee of $150.00. Accordingly, SCE's check in the amount of $150.00 is enclosed.
Very truly yours, Enclosures cc: J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
- 3. H. Hickman, California Department of Health Services PDR ADOCK 05000206 P
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
)
Part of Unit No. 1 of the San Onofre Nuclear )
Amendment No. 152 Generating Station
)
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.
88071
_O084
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-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 tA&L__ day of
, 1988.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:
Kenneth P. Bas in Vice President Subscribed and sworn efore me this day of
/
Noty Public in and for the County of Lo Angeles, State of California My Commission Expires: Z.62 1'/Fe OFFICIAL SEAL AGNES CPABTREE Notary Public-California Charles R. Kocher LOS ANGELES COUNTY My Comm. Exp. Sep. 14. 1990ms
. elet LOSAGELECOU~Y IJames A. Beoletto Attorneys for Southern California Edison Company By:
3s A. Beo Tttch
-4 Subscribed on this 27th day of June
, 1988.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By:
Gary DJCotton Senior Vice President Engineering & Operations Subscribed and sworn to before me this 97 day of OFFIOAk SEAL EPHANIEE.HITT ND?@PUBIC*CLIFRNIA RINCIPAL OFFICE IN SAOIEGO COUNTY Notar Public in and for the County of San Diego, State of California My Commission Expires: 6 Leol David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By: 04A/
David R. Pigott
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN
)
CALIFORNIA EDISON COMPANY
)
and SAN DIEGO GAS & ELECTRIC
)
Docket No. 50-206 COMPANY (San Onofre Nuclear
)
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 S,tate 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 ESSO 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. B06eole
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 revision 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 standa'rds 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. Spectfically, 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.
-3
- 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 EXISTING TECHNICAL SPECIFICATION QA40086-88070 PDR ADOCK 05000206 p
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6.5.3 NUCLEAR SAFETY GROUP (NS6)
FUNCTION 6.5.3.1 The Nuclear Safety Group shall function to provide independent review and audit of designated activities in the areas of:
- a. nuclear power plant operations
- b. nuclear engineering
- c. chemistry and radiochemistry
- d. metallurgy
- e. instrumentation and control
- f. radiological safety
- g. mechanical and electrical engineering
- h. quality assurance practices COMPOSITION 91 6.5.3.2 The NSG shall consist of a Supervisor and at least three staff 11/14/85 specialists. The Supervisor shall have a Bachelor's Degree in Engineering or Physical Science and a minimum of 6 years of professional level managerial experience in the power field. Each staff specialist shall have a Bachelor's Degree in Engineering or Physical Science and a minimum of 5 years of professional level experience in the field of his specialty.
The NSG shall use specialists from other technical organizations to augment its expertise in the disciplines of 6.5.3.1. Such specialists shall meet the same qualification requirements as the NSG members.
CONSULTANTS 6.5.3.3 Consultants shall be utilized as determined by the NSG Supervisor
,to provide expert advice to the NSG.
RESPONSIBILITIES 6.5.3.4 The NSG shall review:
- a. The safety evaluations for 1) charZes to procedures required by Specification 6.8. equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.
SAN ONOFRE - UNIT 1 6-14 Revised: 11/14/85
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- d. Proposed changes in 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 deviation from normal and expected performance of unit equipment that affect nuclear safety.
- g. All REPORTABLE EVENTS.
- h. All recognized indications of an unanticipated deficiency in 91 some aspect of design or operation of safety related 1/14/85 structures, systems or components that could affect nuclear safety.
- i. Reports and meeting minutes of the Onsite Review Committee.
AUDIT 6.5.3.5 Audits of unitactivities shall be performed under the cognizance of the NSG. These audits shall encompass:
- a. The conformance of unit operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
- b. The performance, training and qualifications of the entire unit staff at least once per 12 months.
- c. The results of all actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety ht least once per 6 months.
- d. The peformance of all activities required by the Quality Assurance Program to meet the criteria of Appendix O8",
10 CFR 50, at least once per 24 months.
- e. Any other area of unit operation considered appropriate by the Nuclear Safety Group or the Vice President and Site Manager, Nuclear Generation Site.
SAN ONOFRE -
UNIT 1 6-15 Revised:
11/14/85 PROPOSED TECHNICAL SPECIFICATION 6.5.3 NUCLEAR SAFETY GROUP (NSG)
FUNCTION 6.5.3.1 The Nuclear Safety Group shall function to provide independent review and audit of designated activities in the areas of:
- a. nuclear power plant operations
- b. nuclear engineering
- c. chemistry and radiochemistry
- d. metallurgy
- e. instrumentation and control
- f. radiological safety
- g. mechanical and electrical engineering
- h. quality assurance practices COMPOSITION 6.5.3.2 The NSG shall consist of a Supervisor and at least three staff specialists. The Supervisor shall have a Bachelor's Degree in Engineering or Physical Science and a minimum of 6 years of professional level managerial experience in the power field. Each staff specialist shall have a Bachelor's Degree in Engineering or Physical Science and a minimum of 5 years of professional level experience in the field of his specialty.
The NSG shall use specialists from other technical organizations to augment its expertise in the disciplines of 6.5.3.1.
Such specialists shall meet the same qualification requirements as the NSG members.
CONSULTANTS 6.5.3.3 Consultants shall be utilized as determined by the NSG Supervisor to provide expert advice to the NSG.
RESPONSIBILITIES 6.5.3.4 The NSG shall review:
- a. Deleted
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
SAN ONOFRE - UNIT 1 6-14
- c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- d. Proposed changes in 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 deviation from normal and expected performance of unit equipment that affect nuclear safety.
- g. Deleted
- h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems or components that could affect nuclear safety.
- i. Reports and meeting minutes of the Onsite Review Committee.
AUDIT 6.5.3.5 Audits of unit activities shall be performed under the cognizance of the NSG. These audits shall encompass:
- a. The conformance of unit operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
- b. The performance, training and qualifications of the entire unit staff at least once per 12 months.
- c. The results of all actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.
- d. The performance of all activities required by the Quality Assurance Program to meet the criteria of Appendix "B",
10 CFR 50, at least once per 24 months.
- e. Any other area of unit operation considered appropriate by the Nuclear Safety Group or the Vice President and Site Manager, Nuclear Generation Site.
SAN ONOFRE - UNIT 1 6-15