ML17158A765
| ML17158A765 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/11/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17158A764 | List: |
| References | |
| NUDOCS 9507180322 | |
| Download: ML17158A765 (6) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-N01 RELAT D TO AM NDMENT NO. 148TO FACILITY OPERAT NG LICENS NO.
NPF-1 AM NDMENT NO. 118 TO FACIL TY OPERAT NG L
C NS NO.
NPF-2 PENNSYLVANIA POW R
8I LIGH COMPANY I
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>>p*p+" SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ALLEGHENY ELECTR C
SUS UEHANNA STEAM ELECTRIC STAT 0 UN DOCKET NOS.
50-387 AND 388 ND 2
- 1. 0 INTRODUCTION By letter dated April 10, 1995, the Pennsylvania Power and Light Company (the licensee) submitted a request for changes to the Susquehanna Steam Electric Station, Units 1
and 2, Technical Specifications (TS).
The requested changes would remove from the Susquahanna Steam Electric Station, Units 1 and 2
Technical Specifications, the response time limit Tables 3.3. 1-2, 3.3.2-3, and 3.3.3-3, for the reactor protection system (RPS),
the isolation system instrumentation, and the emergency core cooling system (ECCS).
The information in the tables is being added to the Final Safety Analysis Report (FSAR) in accordance with the guidance in Generic Letter (GL) 93-08, "Relocation of Technical Specification Tables of Instrument
Response
Time Limits," dated December 29, 1993.
The NRC provided guidance on the proposed TS changes in GL 93-08 to all holders of operating licenses or construction permits for nuclear power reactors.
The next revision to update the FSAR will include these tables.
2.0 BACKGROUND
The NRC staff undertook efforts in the early 1980's to address problems related to the content of nuclear power plant technical specifications.
These projects have resulted in the issuance of various reports, proposed rulemakings, and Commission policy statements.
Line item improvements
- became, a mechanism for technical specification improvement as part of the implementation of the Commission's interim policy statement on technical specification+mpmvements published on February 6, 1987 (52 FR 3788).
The final Commission policy statement on technical specification improvements was published July 22, 1993 (58 FR 39132).
The final policy statement provided criteria which can be used to establish, more clearly, the framework for technical specifications.
The staff has maintained the line item improvement
- process, through the issuance of generic letters, in order to improve the content and consistency of technical specifications and to reduce the licensee and staff resources required to process amendments related to those specifications being relocated from the TS to other licensee documents as a
result of the implementation of the Commission's final policy statement.
9507i80322 9507ii PDR ADOCK 05000387 P
Section 50.36 of Title 10 of the Code of Federal Regulations establishes the regulatory requirements for licensees to include technical specifications as part of applications for operating licenses.
The rule requires that technical specifications include items in five specified categories:
(I) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
In addition, the Cowoission s final policy statement on technical specification improvements and other Commission documents provide guidance regarding the required content of technical specifications.
The fundamental purpose of the technical specifications, as described in the Commission's final policy statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by, identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.
The Commission's final policy statement recognized, as had previous statements related to the staff's technical specification improvement program, that implementation of the policy would result in the relocation of existing technical specification requirements to licensee controlled documents such as the Final Safety Analysis Report.
Those items relocated to the FSAR would in turn be controlled in accordance with the requirements of 10 CFR 50.59, "Changes, tests and experiments."
Section 50.59 of Title 10 of the Code of Federal Regulations provides criteria to determine when facility or operating changes planned by a licensee require prior Commission approval in the form of a license amendment in order to address any unreviewed safety questions.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to FSAR commitments and to take any remedial action that may be appropriate.
2.0
~EVALUAT ON The above noted Susquehanna Steam Electric Station (SSES)
TS tables contain the values of the response time limits for the RPS, isolation system instrumentation, and the ECCS.
The limiting conditions of operation of these systems and instrumentation specify that these systems shall be operable with response times as specified in these tables.
These limits are the acceptance criteria for the response time testing performed to satisfy the surveillance requirements -of TS. 3.3. 1, 3.3.2, and 3.3.3 for each applicable
These surveillances ensure that the response times of the
- RPS, isolation system, and ECCS instruments are consistent with the assumptions of the safety analyses performed for design basis accidents and transients.
Currently, the license amendment process is the only way that TS changes for the RPS isolation system, and ECCS instrumentation response time limits may be implemented.
In contrast, the licensee may make changes to other conditions assumed in the safety analysis as described in the FSAR under the provisions of Section 50.59 of Title 10 of the Code of Federal Regulations (10 CFR 50.59).
The licensee may make changes to the FSAR without NRC approval when the changes do not result in an unreviewed safety question.
The staff has concluded that the provisions of 10 CFR 50.59 provide an acceptable means to control changes to response time limits in lieu of a license amendment and that this can be accomplished by relocating the tables listed above from the TS to the FSAR.
This is a change only in administrative requirements because it does not alter the TS requirements to perform response time tests or to ensure that the response times of the instruments are within their limits.
The licensee has proposed changes to specifications 3.3. 1, 3.3.2, and 3.3.3 by removing the references to Tables 3.3.1-2, 3.3.2-3, and 3.3.3-3 and by removing these tables from the TS.
The licensee has proposed to relocate the tables on response time limits to the FSAR by including them in the next periodic update to the FSAR.
These actions are consistent with the guidance provided in GL 93-08.
The staff has reviewed this matter and finds that the proposed changes to the TS for Susquehanna Steam Electric Station, Units 1 and 2 are acceptable.
The staff's determination is based on the fact that the removal of the specific response time tables does not eliminate the requirements for the licensee to ensure that the protection instrumentation is capable of performing its safety function.
Although the tables containing the specific response time requirements are relocated from the technical specifications to the FSAR, the licensee must continue to evaluate any changes to response time requirements in accordance'ith 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
The staff's review concluded that 10 CFR 50.36 does not require the response time tables to be retained in technical specifications.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure response times for RPS,
- ECCS, and isolation system instrumentation, are retained due to those systems'mportance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of specific response time requirements for the various instrumentation channels and components addressed by Generic Letter 93-08 was not required.
The response times are considered to be an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected instrument or component response
- times, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
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- Further, the response time requirements do not constitute a condition or limitation on operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and
- safety, in that the ability of the instrumentation systems to perform their safety functions are not adversely impacted by the relocation of the response time tables from the TS to the FSAR.
3.0
~ET T CO EIILTATIGN In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 N
IRONMENTAL CONSIDERATION The amendments change a requirement with respect to installation or use,of a
facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types,
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of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative'ccupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 29887).
Accordingly, the amendments meet eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0
~CONC USIOM The Commission has concluded, based on the considerations discussed
- above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
C. Poslusny Date:
July 1% LES
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