ML17177A452

Summary of 920421 & 22 Meeting W/Util Representative to Discuss Various Licensing Issues.List of Attendees,Agenda, Organization Chart,Generic License Issues Affecting Aging Plants & Operability & Degraded Equipment Presentation Encl

ML17177A452
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle
Issue date:	05/18/1992
From:	Pulsifer R Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9206040262
Download: ML17177A452 (45)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 Docket Nos. STN 50-456, STN 50-457; STN 50~454, STN 50-455; May 18, 1992 50~231, 50~249; 50~373, 50~374; 50~254, 50:265; and 50~295, 50~304 LICENSEE:

Commonwealth Edison Company FACILITY:

Braidwood Station, Units 1 and 2 Byron Station, Units 1 and 2 Dresden Station, Units 2 and 3 LaSalle Station, Units 1 and 2 Quad Cities Station, Units 1 and 2 Zion Station, Units 1 and.2

SUMMARY

OF MEETING ON APRIL 21 AND 22, 1992, WITH COMMONWEALTH EDISON REPRESENTATIVES TO DISCUSS VARIOUS LICENSING ISSUES On April 21 and 22, 1992, NRC staff met with representatives of the Commonwealth Edison Company {CECo} to discuss licensing issues of mutual interest. The meeting participants are listed in Enclosure 1.

An agenda was developed by the NRC staff and CECo as a guide for the discussions {Enclosure 2).

The discussions were to foster open communication between the organizations on various subjects so that there would be a better understanding of the issues by both organizations.

The last two subject areas, SA/QV, SALP and General Topics, were not addressed because of time constraints.

• is an organization chart of the CECo Nuclear Licensing Department.

How generic licensing issues affected aging plants was discussed with CECo

{Enclosure 4).

CECo presented how these issues would be addressed and the communication that would be necessary as an issue evolves. It was noted a,

healthy, working discussion of the issues is needed for a mutual understanding of respective positions. was provided during a CECo presentation on their interpretation of operability and degraded equipment. A frank and open discussion ensued with the staff emphasizing that the determination of safety significance should be the first step when addressing operability {Enclosure 6). The disposition of the operability or degraded equipment concern must be commensurate with the safety significance in a timely manner.

OFC NAME DATE Commonwealth Edison Company May 18, 1'992 Commonwealth Edison Company provided Enclosure 7 which was issued in a discussion of CECo's approach to the technical specification amendment process and the staff followed with Enclosure 8 to discuss the contents needed for a license amendment request.

CECo and the staff talked over the attributes of a good amendment to assure an efficient and timely process.

An interpretation of 10 CFR 50.59 (Enclosure 9) was presented by CECo reviewing the use of 10 CFR 50.59 and how margin is determined.

10 CFR 50.59 states that a proposed change, test, or experiment shall be deemed to involve an unreviewed safety question if the margin of safety is reduced. This discussion helped CECo and the staff better understand their respective position on this issue.

• At the conclusion of the meeting the licensee and the staff stated, through

. this frank and open discussion, these counterparts meetings between CECo and the NRC licensing staff should continue in the future.

Enclosures:

1.

List of attendees

2.

Agenda

3. Organization Chart

4.

Generic Licensing Issues Affecting Aging Plants

5.

Interpretation of operability and degraded equipment

6.

Focus on Safety

7.

CECo's Approach to the Amendment Process

8. Content For License Amendment Requests Original 5igned tly:

.Robert M. Pulsifer, Project Manager Project Directorate III-2 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation DISTRIBUTION:

. B~e*t~r~=l:e:s>

NRC & Local PDRs PDIII-2 r/f TMurley/FMiraglia JPartlow BBoger JZwolinski BSiegel RPulsifer GGrant, 17G21 OS keen BCl ayton, RII I LOlshan RElliott MD Lynch CPatel OGC.

ACRS (10)

CMoore RBarrett EJordan

9.

10 CFR 50.59; Margin and Methods cc w/enclosures:

See next page

-2

PM: POii I-2

RPULSIF

5 liy/92

Commonwealth Edison C~any cc:

Mr. William P. Poirier Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo, Esquire Hopkins and Sutter 888 16th Street, N.W., Suite 700 Washington, D.C.

20006 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935*

Mr. Edward R. Crass Nuclear Safeguards and Licensing Division Sargent & Lundy Engineers 55 East Monroe Street Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens, Director Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706 Robert Neumann Office of Public Counsel State of Illinois Center 100 W. Randolph, Suite 11-300 Chicago, Illinois 60601 EIS Review Coordinator Environmental Protection Agency Region V 230 S. Dearborn Street Chicago, Illinois 60604 Attorney General 500 South 2nd Street Springfield, Illinois 62701 U. S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Douglass Cassel, Esquire 17 East Monroe Street, Suite 212 Chicago, Illinois 60603 U. S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 George L. Edgar Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C.

20036 Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 Illinois Dept. of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Mayor of Zion Zion, Illinois 60099

Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. C. Schroeder Plant Manager Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U. S. Nuclear Regulatory Commission Resident Inspectors Office Dresden Stat ion Rural Route #1 Morris, Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street Suite 12 Chicago, Illinois 60601 Resident Inspector/LaSalle, NPS U. S. Nuclear Regulatory Commission Rural Route No. 1 P.

O~ Box 224 Marseilles, 11 l i noi s 61341 Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street Chicago, Illinois 60601 Mr. G. Diederich LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois, 61341 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. 0. Box 4350 Davenport, Iowa 52808 Mr. Richard Bax Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 Resident Inspector U. S. Nuclear Regulatory Commission 22712 206th Avenue North Cordova, Illinois 61242 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, Illinois 61201 Mr. Thomas J. Kovach Nuclear Licensing Manager Commonwealth Edi son Company-Suite 300 OPUS West Ill 1400 OPUS Place Downers Grove, Illinois 60515

Robert Pulsifer Al Harger T. W. Si mp k i n David Chrzanowski Rita Radtke Byron Siegel JoAnn Shields Michael A. Mikolanis David Skeen Alex Misak L. N. 01 shan Rob Elliott Gerald L. Swihart Terence Schuster Peter L. Pi et Marcia A. Jackson M. David Lynch Jeannie Reinhart Christy Moore Steve Stimac Ron Chrzanowski Chandu Patel Joe *Langan Rich Barrett Thomas Kovach John Schrage Jim Partlow John Zwolinski NRC/CECo COUNTERPARTS MEETING April 21 AND 22, 1992 ORGANIZATION NRR/PDII 1-2 CECo/Braidwood CECo/NLD CECo/NLD CECo/Dresden NRR/PDill-2 CECo/NLD Bechtel/Licensing NRR/DOEA CECo/Quad Cities NRR/PDIII-2 NRR/PDII 1-2 CECo/NLD CECo/NLD CECo/NLD CECo/NLD NRR/POIII-2 NRR/PDIII-2 NRR/POIII-2 CECo/NLD CEOo/Zion NRR/PDIII-2 CECo/Byron NRR/POIII-2 CECo/NLD CECo/NLD NRR NRR/ADRIII ENCLOSURE 1

Tuesday, Aprll 21, 1992 8:30-8:45 8:45 -10:15 10:15 -10:30 10:30 -11 :00 11 :00 - 11 :45 11 :4~ -1 :00 1 :00 - 2:30 2:30 - 2:45 2:45 - 4:00

.. 4:00 AGENDA NRR/CECo COUNTERPARTS MEETING MID-YEAR LICENSING SEMINAR Welcoming Remarks; A. Barrett Goals and Expectations, NRA and CECo; A. Barrett and T. Kovach, Presentation and Group Discussion Break Keynote Address and Discussion: Senior Management Meeting, Associate Director role in Licensing, and the Perception of CECo; J. Partlow Generic Licensing Issues Affecting Aging Plants: Proactive versus Reactive; CECo Presentation (J. Schrage} and Group Discussion Lunch Operability and Degraded Equipment: Dealing with Friday Afternoons; CECo Presentation (T. Schuster), Group Discussion; John Zwolinski Break Attributes of a Good Submittal: NRA and CECo (T.

Simpkin} Presentations and Group Discussion Dismiss Wednesday, April 22, 1992 8:30 -10:00 10:00-10:15 10:15-11:15 11 :15 -12:00 12:00 50:59 and Margin; CECo (D. Chrzanowski) and NRA (Harbuck) Presentations and Group Discussion Break SA/Q, and SALP; NRA (Siegel) Presentation and Group Discussion General Topics

- 50.59 Inspection (Pulsifer)

- Six Plant Administrative TS change (Simpkin)

Lunch and Dismiss

NUCLEAR LICENSING DEPARTMENT IUclur Licensing

~r T. J. ICOVKll Secretary IMdy Lara I

I I

I Issues Management law Management State Liem.Ing Parlor.nee Review Engineer Acbinf atrator Acbiniatrator Project Manager G. A. Denenberg R. J. Lezon M. M. Vincent I * ". Johnson I

Cclllplfm Licensing luperviaor

. IUpervi aor P. L. lames T. IC. ldnater Cclllpl lance Engineer Lfcenaing Adliniatrator Licensing Adliniatrator D. M. S.C:commldo Byron Statton Dresden Statton D. J. OlrunoMalcf.

P. L. Plat Cclllplfance Engineer Licensing Adliniatrator Licensing Adlrinfatrator J. M. W.taon Zion Statton i"-

Q&md Cltf* Statton S. F. Stfmc:

"* L. ldlrage Lfcenatng lnformtlan LIC9naing Adlfnfatrator Llc:enafng Adlriniatrator Acbfnf atrator lraiclwood Statton US.lle Statton

• o. I. Blaclcloclc T. W. SflllPlcfn

"* II. lhfelda Generic 1.....

Lf ans f ng Engl neer Adliniatrator 1.c. ~

M. A..laclcaon

• fl 1D, 1992

I Generic Licensing Issues Affecting Aging Plants*

Proactive versus Reactive

Purpose:

• Promote a healthy, working discussion in order to establish a mutual understanding of the framework necessary to address this type of issue..

• Mutual interest and importance.

• Evolution of issue.

• Understanding the framework {healthy discussion).

Mutual Interest and Importance AEOD l&CBranch~

Electrical Branch Plant Systems Reactor Systems NRR PM CE Co NLD

~Engineering

~Nuclear Op~

BWR/PWR Projects

UFSAR Rebaseline DBD Reconstitution CLB Compilation IPE Development Inspections Licensee Initiatives NRC Initiatives Rock I Worm Effect Evolution of Issue Original Design Discrepancies Calculation Discrepancies Assumption Discrepancies Mistakes (UFSAR I SER)

Communications t

50.59 Evaluations I Margin Operability Evaluations License Submittals (TWOC, etc.)

Generic Letter 91-18 Issued "For Information Only" to licensees Contains Two New Inspection Manual Sections Shorter first section entitled:

"Resolution of Degraded and Non-Conforming Conditions"-(DNCC)

Second section entitled:

"Operable/Operability: Ensuring the Functional Capability of a System or Component"-(Operability)

Purpose of GL: Assure consistent application during NRC Staff Inspection Activities Stated inspectors had been briefed on the guidance Noted that use of sections may raise backfitting issues for specific plants ZNLD/1673/6

DNCC Section Defines the conditions of concern, as those affecting SSCs which are relied upon in the Current Licensing Basis (CLB).

CLB defined to include:

UFSAR Tech Specs License Conditions Written Commitments LE Rs NRC SERs New Rule Compliance Commitments Notes 1 OCFR50 App. B, Criterion XVI requires licensee to promptly identify and correct conditions

• adverse to quality Primary objective of process is to ensure public health and safety Secondary objective is to restore SSCs consistent with the CLB ZNLD/1673/7

DNCC Section cont'd States both design and operations must be consistent with CLB States timeliness of corrective actions to resolve a concern should be commensurate with the safety.

significance of the issue Acknowledges use of 50.59 provision is an option of reconciliation Refers to Waiver process and defines "JCO" a_s a licensee's technical basis for requesting a waiver of a**

Tech Spec or license condition CECo has no major concern with the guidance provided in the DNCC section CECo practice regarding resolution of DNCC reflects substantial agreement with the NRC's guidance ZNLD/1673/8

• Operability Section Subsections 1-5 provided purpose, scope, definition of terms, and general background relating to process of determining operability Subsection 6 contained 16 subparts, each treating separate types-of operability issues Ex: 1) Consequences of missed Tech Spec Surveillance ZNLD/1673/9

2) Limitations placed on use of manual operator actions in place of automatic actions to maintain operability

Operability General Comments Generally well thought out Some sections exhibited great insight regarding the operability decision making process Concerns Referenced same body of documentation as identified earlier in the DNCC section as the CLB.

Term "OPERABLE", and all derivatives of it, appear to be used loosely in the guidance, perhaps as a result of the broad body of documentation referenced for consideration ZNLD/1673/10

Operability Explanation CLB is that body of documentation to which DNCC must be reconciled and the licensee should be held accountable for. This is supported by 1 OCFR50-App B.

The condition of operability is assessed relative to a smaller body of documentation which is a subset of the CLB.

The definition of "OPERABILITY" resides in Technical Specifications. Equipment/systems identified in Tech Specs must be OPERABLE.

For equipment to have the quality of OPERABILITY it mu.st be capable of performing its specified safety functions. The equipment's safety functions, or uses in preventing or mitigating accidents, may be found described in the Tech Specs, UFSAR or other.

documents. Analyses and assumptions may also be

. found in these documents, which support operability of equipment.

ZNLD/1673/11.

Operability Specifications were created to protect certain critical safety functions and analyses assumptions.

Descriptive entries exist in the UFSAR and other documents describing non-critical functions of equipment which should not be linked to operability.

Functions for equipment, added to the CLB, should not be assumed to broaden the operability requirements for the equipment unless specifically committed to do so.

Must be careful not to make tangelo scenarios out of tangerines and grapefruit.

ZNLD/1673/12.

.e Operability ADDITIONAL CONCERNS Support System Operability, sometimes referred to as Cascading Tech Specs issue.

Major concern is complete loss of safety function CECo strongly agrees operation should not be allowed in such a condition, unless specifically allowed by Tech Specs.

Concern resolved by imposing a requirement to cascade Tech Spec requirements from inoperable support systems to.previously operable supported systems.

Drawbacks:

Unnecessary expenditure of plant resources

\\

Unnecessary documentation of applicable LCO's ZNLD/1673/13 Conservative application could lead to unnecessary plant shutdown

• Operability Threshold at which a SSC must be declared inoperable as a result of an evolving issue is of concern.

Plethora of qualitative words define threshold CECo Operability Philosophy:

ZNLD/1673/14 Assume the component remains operable, after a concern is raised, until there is no longer "reasonable assurance" that the component will perform its design function, based on current available information.

Operability System or component operability during surveillan' testing Policy statement appears to have been written without regard for:

1) Design of older plants

2) Technical Specifications of older plants

3) Consideration of a possible combination of one and two.

Policy as written implies that older plant design is inadequate and/or certain Tech Spec action requirements were specified without recognition of

• the plant conditions required by the action statement Policy, if enforced as written, could result in significant resource expenditure by a licensee without requisite rulemaking or cost/benefit analysis. Policy could also cause changes in legal documents such as Tech Specs, under threat of plant shutdown.

ZNLD/1673/15

I

'(,

'-,\\._, l.

l_A.,.!i, '"-'*I <i_

FOCUS ON SAFETY

• Determine safety significance.

• Will system, structure or component perform its intended function

• Disposition the above commensurate with its safety significance in a timely manner _

.

• Follow Gl 91-18 o~ degraded and non-conforming. conditions

• Is the system, structure or component operable or not

., z

CECO'S APPROACH TO.THE AMENDMENT PROCESS ZNLD/1744/1

-e SOURCES OF AMENDMENTS

+

PLANT MODIFICATIONS

+

TOPICAL REPORTS

+

INDUSTRY/NRC INITIATIVES

+

OPERATIONAL EXPERIENCE ZllLD/1744/2

CONTENT OF AMENDMENT REQUEST

+

DESCRIPTION OF CURRENT REQUIREMENT

+

BASIS FOR CURRENT REQUIREMENT

+

NEED FOR CHANGE

+

DESCRIPTION OF REVISED REQUIREMENT

+

BASIS FOR REVISED REQUIREMENTS

+

NSHC

+

ENVIRONMENTAL ASSESSMENT

+

MARKUPS ZNU>/17U/3

PREPARATION PROCESS

+

IDENTIFICATION OF NEED/DESIRE FOR CHANGE

+

BACKGROUND RESEARCH

- NORMALLY DONE BY STATION STAFF

- ESTABLISHES BASIS FOR CURRENT REQUIREMENT

- COMPARE PROPOSED CHANGE TO:

SRP CURRENT STS SIMI.LAR PLANTS

+

ASSEMBLE DRAFT PACKAGE

- ENGINEERING INPUT REVIEW

- NFS INPUT <ANALYSIS IMPACT>

- NSSS/AE INPUT.

+

ONSITE REVIEW

+

OFFSITE REVIEW ZNU>/1144/*

+

LICENSING DEPARTMENT REVIEW, PREPARATION

+

INDEPENDENT REVIEW

- NON-CECO

- ASSURES CONSISTENCY

+

NRC SUBMITTAL

+

FOLLOWUP

- PHONE CALLS

- RAI 'S

- MEETINGS ZNL0/1H4/5

CONTENT FOR LICENSE AMENDMENT REQUESTS EACH AMENDMENT REQUEST SHOULD INCLUDE THE. FOLLOWING INFORMATION:

/ A DESCRIPTION OF THE CONTENT OF THE CURRENT LICENSE CONDITION FOR TECHNICAL SPECIFICATIONS, INCLUDING SPECIFIC IDENTIFICATION OF THE CONDITION OR SPECIFICATION.

(E.G. 1 PARAGRAPH 2.C(S) 1

• EMERGENCY PREPAREDNESS, a OR TECHNICAL SPECIFICATION 3/4.2.4, *DNBR MARGIN*).

L{ A DESCRIPTION OF THE PROPOSED CHANGE 1 A DISCUSSION OF THE PURPOSE OR FUNCTION OF THE SUBJECT AREA FOR WHICH A CHANGE IS BEING REQUESTED (E.G., IF A TECHNICAL SPECIFICATION IS INVOLVED, THE PURPOSE OF THE SPECIFICATION)

) A DISCUSSION OF WHY THE CHANGE JS BEING REQUESTED

) A SAFETY EVALUATION DEMONSTRATING THE ADEQUACY OF THE LEVEL OF SAFETY PROVIDED IN SUPPORT OF THE REQUESTED CHANGE

~ A DISCUSSION OF WHETHER A NO SIGNIFICANT HAZARDS CONSIDERATION IS INVOLVED AND THE BASIS FOR THE DETERMINATION, USING THE STANDARDS IN 10 CFR 50.92(c) 1 AN ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION (SEE 10 CFR 51.21 AND 10 CFR 51.22) f HARKED-UP PAGES REFLECTING THE REQUESTED CHANGE

CONTENT OF SAFETY EVALUATIONS FOR LICENSE AMENDMENT REQUESTS THE SAFETY EVALUATIONS PROVIDED FOR STAFF REVIEW AND APPROVAL SHOULD INCLUDE THE FOLLOWING INFORMATION:

A DESCRIPTION OF THE AREAS BEING EVALUATED A DISCUSSION OF THE ANALYTICAL METHODS USED, INCLUDING THE INPUT PARAMETERS, JN SUPPORT OF THE PROPOSED CHANGES. THE DISCUSSION SHOULD ALSO STATE WHETHER THE METHODS ARE DIFFERENT THAN THOSE PREVIOUSLY USED AND WHETHER THE METHODS HAVE BEEN PREVIOUSLY REVIEWED AND APPROVED BY THE STAFF.

AN EVALUATION SHOULD ALSO BE PROVIDED FOR ADMINISTRATIVE CHANGES TO DETERMINE WHETHER THE CHANGES HAVE AN ADVERSE SAFETY IMPACT.

THE RESULTS OF THE EVALUATION WHICH DEMONSTRATE THE ADEQUACY OF THE LEVEL OF SAFETY PROVIDED BY THE PROPOSED CHANGE.

THE LEVEL OF DETAIL PROVIDED BY THE SAFETY EVALUATION SHOULD BE SUCH THAT THE STAFF CAN MAKE AN INDEPENDENT ASSESSMENT OF THE EVALUATION BASED ON THE INFORMATION PROVIDED BY THE LICENSEE.

ADDRESSING THE STANDARDS IN 10 CFR 50.92 JN.ADDRESSING THE STANDARDS FOR DETERMINING WHETHER A NO SIGNIFICANT HAZARDS CONSIDERATION EXISTS, THE DISCUSSIONS SHOULD INCLUDE THE FOLLOWING INFORMATION AND SHOULD HAVE SUFFICIENT DETAIL FOR THE STAFF TO DRAW THE SAME CONCLUSIONS AS THE LICENSEE, BASED ON THE INFORMATION PRESENTED STANDARD 1 - INVOLVING A SIGNIFICANT INCREASE JN THE PROBABILITY OR CONSEQUENCES OF AN ACCIDENT PREVIOUSLY EVALUATED THE DISCUSSION SHOULD IDENTIFY WHAT ACCIDENTS WERE PREVIOUSLY EVALUATED (I.E., THOSE THAT HAD BEEN SUBMITTED ON THE DOCKET AND EVALUATED BY THE STAFF) *THAT INVOLVE THE AREAS OF PROPOSED CHANGE.

THE DISCUSSION SHOULD ALSO FOCUS ON HOW THESE ACCIDENTS ARE AFFECTED BY THE PROPOSED CHANGES AND WHETHER THE CHANGES INVOLVE A SI.GNIFICANT INCREASE IN PROBABILITY.OR CONSEQUENCES OF THOSE PREVIOUSLY EVALUATED ACCIDENTS.

IF THE PROPOSED CHANGES DO NOT AFFECT ANY P.REVIOUSLY EVALUATED ACCIDENTS, THE REASONS FOR THIS CONCLUSION SHOULD BE STATED.

STANDARD 2 - CREATE THE POSSIBILITY OF A NEW OR DIFFERENT KIND OF ACCIDENT FROM ANY ACCIDENT PREVIOUSLY' EVALUATED THE INFORMATION PROVIDED IN THE DISCUSSION OF THIS STANDARD SHOULD MAKE IT CLEAR WHETHER A NEW OR A DIFFERENT ACCIDENT IS INVOLVED.

AMENDMENT REQUESTS INVOLVING CHANGES JN EQUIPMENT, PLANT OPERATIONS, ETC. MIGHT CREATE THE POSSIBILITY OF A DIFFERENT KIND OF ACCIDENT.

THE EVALUATION OF AN ACCIDENT WHICH HAS NOT BEEN SUBMITTED ON THE DOCKET 'AND REVIEWED BY THE STAFF IS CONSIDERED NEW OR DIFFERENT. THERE SHOULD BE A CAREFUL FOCUS ON THIS ISSUE, ESPECIALLY IF THE DISCUSSION OF THE FIRST STANDARD ASSERTS THAT THE CHANGES DO NOT INVOLVE ANY PREVIOUSLY EVALUATED ACCIDENTS.

STANDARD 3 ~ INVOLVE A SIGNIFICANT REDUCTION IN A MARGIN OF SAFETY THE DISCUSSION OF THIS STANDARD SHOULD CONSIDER WHETHER ANY MARGIN OF SAFETY, BASED ON THE ANALYSES OF RECORD AND/OR THE EXISTING LIMITS OF THE TECHNICAL SPECIFICATIONS, WILL BE SIGNIFICANTLY REDUCED.

SUCH A CONSIDERATION SHOULD BE BASED UPON THE MARGIN OF SAFETY ESTABLISHED IN THE FSAR, SRP, SER AND SER SUPPLEMENTS, AND TECHNICAL SPECIFICATIONS BASES OF RECORD.

A SIGNIFICANT REDUCTION JN MARGIN CAN BE INVOLVED EVEN IF THE RESULTS OF REVISED ANALYSES ARE WITHIN ACCEPTANCE CRITERIA.

JN ADDITION, THE LICENSEE SHOULD PROVIDE ENOUGH DETAIL FOR THE READER TO UNDERSTAND THE PROPOSED CHANGE WITHOUT REFERRING TO THE SUBMITTAL. THIS ALLOWS THE NSHC ANALYSIS TO STAND ALONE AND MAKES JI EASIER FOR THE PM TO REFERENCE IT IN A FEDERAL REGISTER NOTICE.

JUSTIFICATION REQUIRED FOR ESTABLISHING AN EXIGENT OR EMERGENCY CLASSIFICATION FOR A LICENSE AMENDMENT REQUEST THE COMMISSION EXPECTS LICENSEES TO APPLY FOR LICENSE AMENDMENTS ON A TIMELY BASIS.

ALTHOUGH THE COMMISSION RECOGNIZES THAT EMERGENCY SITUATIONS MAY ARISE, LICENSEES ARE NOT TO CREATE AN EMERGENCY TO TAKE ADVANTAGE OF THE EMERGENCY PROVISIONS.

WHEN A REQUEST IS MADE FOR EMERGENCY ACTION ON A LICENSE AMENDMENT SUBMITTAL, OTHER INFORMATION IS REQUIRED IN ADDITION TO THAT IDENTIFIED PREVIOUSLY.

THE REQUIRED ADDITIONAL INFORMATION FOR JUSTIFYING AN EMERGENCY CLASSIFICATION, WHICH JS IDENTIFIED BELOW, SHOULD BE SUBMITTED IN A TIMELY HANNER AND IN SUFFICIENT DETAIL FOR THE STAFF TO DRAW THE SAHE CONCLUSIONS AS THE LICENSEE, BASED ON THE INFORMATION PRESENTED.

(l)

ESTAeLISH THAT IMMEDIATE ACTION JS REQUIRED TO PREVENT DERATING OR SHUTTING DOWN OF THE PLANT, OR TO PREVENT RESUMPTION OF OPERATION OR AN INCREASE IN POWER OUTPUT (2)

ESTABLISH THAT THE NEED FOR THE REQUESTED ACTION COULD NOT REASONABLY HAVE BEEN IDENTIFIED SOONER (3)

ESTABLISH THAT THERE IS NO OTHER ALTERNATIVE AVAILABLE (4)

DESCRIBE INTERIM COMPENSATORY MEASURES TO BE IMPOSED (5)

IF TEMPORARY RELIEF IS BEING REQUESTED, STATE THE SCHEDULED DATE FOR WHEN THE RELIEF PERIOD WOULD END, E.G., THE SCHEDULED DATE FOR RETURNING INOPERABLE COMPONENTS OR SYSTEMS TO AN OPERABLE CONDITION, OR THE SCHEDULED DATE FOR ACCOMPLISHING REQUIRED SURVEILLANCES (6)

ADVISE THE APPROPRIATE STATE PERSONNEL WHEN A REQUEST JS MADE FOR EXIGENT ACTION ON' A LICENSE AMENDMENT SUBMITTAL, THE ADDITION INFORMATION SHOULD INCLUDE ITEMS (2) AND (6) ABOVE AS WELL AS THE FOLLOWING INFORMATION:

ESTABLISH THAT QUICK ACTION IS DESIRABLE (1) TO AVOID THE LOSS OF A NET SAFETY BENEFIT OR (2) TO PROVIDE A NET INCREASE IN SAFETY OR RELIABILITY, OR A SIGNIFICANT ENVIRONMENTAL BENEFIT

l)

2)

3)

4)

TECHNICAL SPECIFICATIONS CHANGES AND AMENDMENTS THAT SHOULD NOT HAVE BEEN SUBMITTED TOGETHER AN ADMINISTRATIVE AMENDMENT TO THE DEFINITIONS SECTION THAT ADDED THE WORD

• MANUAL* TO DESCRIBE THE VALVES THAT ARE REQUIRED TO BE CLOSED FOR PENETRATIONS NOT CAPABLE OF BEING CLOSED BY OPERABLE CONTAINMENT AUTOMATIC ISOLATION VALVES, AND ADDED *cLOSED* TO DESCRIBE THE POSITION THEY ARE SECURED JN DURING ACCIDENT CONDITIONS.

EXEMPTION. TO AN APPENDIX J REQUIREMENT TO STOP A TYPE A TEST (CILRT) IF EXCESSIVE LEAKAGE IS DETERMINED.

THE EXEMPTION WOULD ALLOW THE SATISFACTORY COMPLETION OF THE TYPE A TEST IF THE LEAKAGE CAN BE ISOLATED AND APPROPRIATELY FACTORED INTO THE RESULTS.

EXEMPTION AND TS AMENDMENT DEALING WITH APPENDIX J ACCEPTANCE CRITERIA FOR TYPE A TESTS (CILRT). THE EXEMPTION REQUESTS THAT THE ACCEPTANCE CRITERIA FOR AS FOUND TYPE A TESTS BE SET AT THE SAHE VALUES AS THE MAXIMUM ALLOWABLE LEAKAGE RATE, La.

EXEMPTION AND TS AMENDMENT DEALING WITH APPENDIX J REQUIREMENT TO PERFORM THE THIRD TYPE A TEST (CILRT) DURING EACH 10-YEAR SERVICE PERIOD WHEN THE PLANT IS SHUTDOWN FOR THE 10-YEAR PLANT INSERVICE INSPECTIONS.

APPENDIX

. J GIVES PERMISSIBLE PERIODS FOR TESTING AS PERIODS WHEN THE PLANT FACILITY IS NONOPERATIONAL AND SECURED IN THE SHUTDOWN CONDITION UNDER THE ADMINISTRATIVE CONTROL AND IN ACCORDANCE WITH THE SAFETY PROCEDURES DEFINED IN THE LICENSE. THESE PERMISSIBLE PERIODS FOR TESTING WOULD NORMALLY OCCUR DURING A REFUELING SHUTDOWN.

TS AMENDMENT DELETES A SURVEILLANCE REQUIREMENT TO PERFORM THE THIRD TEST OF EACH SET DURING THE SHUTDOWN FOR THE 10-YEAR PLANT INSERVICE INSPECTION.

5)

TS AMENDMENT CHANGES THE EXISTING ACTION STATEMENT INTO THREE ACTION STATEMENTS IN LIEU OF ONE TO BE MORE COMPATIBLE WITH THE LCO AND CLARIFY THE SURVEILLANCE REQUIREMENTS TO BE MORE CONSISTENT WITH THE INTENDED REQUIREMENTS OF APPENDIX J. EXPANSION OF THE ACTION STATEMENT INTO THREE ACTION STATEMENTS PROVIDES MORE DIRECTION ON WHAT TO DO WHEN THE LCOs FOR CONTAINMENT LEAKAGE RATES ARE NOT BEING MET.

AN EXAMPLE OF A 600D TS AMENDMENT SUBMITTAL

. SECTION TITLED *sYSTEM DESCRIPTION* CONTAINING TWO SIMPLIFIED DRAWINGS AND PROVIDED A COMPLETE, ONE PAGE DESCRJPTJON OF SYSTEM OPERATION.

IT CLEARLY EXPLAINED HOW THE SYSTEM COMPONENTS INVOLVED JN THE AMENDMENT FUNCTIONED, AND THEN TIED EVERYTHING TOGETHER, EXPLAINING HOW THE AMENDMENT WOULD AFFECT THE SYSTEM OPERATION.

JUSTIFICATION SECTION THOROUGHLY DISCUSSED THE DESIGN BASIS AND INTENT OF THE TS AND EXPLAINED WHY THE CHANGE WAS NEEDED, THEREBY HELPING THE PM TO ESTABLISH A PRIORITY.

THE LICENSEE ALSO CITED AN LER THAT SHOWED WHY THE EXISTING SPECIFICATION WAS INADEQUATE FOR CERTAIN SITUATIONS.

BETWEEN THE SYSTEM DESCRIPTION AND JUSTIFICATION SECTIONS, THE PH WAS ABLE TO UNDERSTAND SYSTEM OPERATION, THE DESIGN BASIS, THE AFFECTED TS, AND THE NECESSITY FOR THE CHANGE. A 600D METHOD OF ACHIEVING THIS GOAL MIGHT BE TO HAVE A CRITICAL REVIEWER WHO DID NOT WRITE THE AMENDMENT SEE IF HE CAN UNDERSTAND THE AMENDMENT REQUEST WITHOUT HAVING TO REFER TO OTHER DOCUMENTS.

RESPONDING TO GENERIC COMMUNJCAJIONS GENERIC COMMUNICATIONS (E.G., GENERJC LETTERS AND NRC BULLETINS) WILL USUALLY HAVE A SECTION ENTITLED *RESPONSE REQUIRED.*

IN THIS SECTION, EACH REQUIRED RESPONSE WILL BE ENUMERATED.

THE RESPONSE SHOULD QUOTE THE REQUIRED RESPONSE, AND IMMEDIATELY BELOW IT, GIVE THE INFORMATION BEING SUBMimED.

DO NOT MAK! THE PM HUNT THROUGH THE SUBMITTAL TO FIND THE INFORMATION THAT WAS REQUIRED TO BE SUBMITTED.

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NRC Concerns Related to Dresden Control Room Habitability

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Safety Margin

• Analyses Old vs. *New.

• Implicit Margin

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Use of Standard Review Plan (SRP)

Use of Safety Evaluation Reports (SERs)

Changing NRC Commitments Resolution of USQ

- **-License Amendment Letter of Approval ZNLD/1691 /4

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• Margins or safety factors are assigned to assure barrier integrity or to provide dose control.

They are, typically, dependent variables derived from the interaction of many independent or process variables. These process variables are adjusted or fixed in such a way as to insure that the Licensed Acceptance Limit (LAL) is maintained. The relationship between the LAL and the barrier integrity limit provides the margin, if any.

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. Barrier Integrity or Release Limit Licensed Acceptance Limit Analysis Results Normal Operating Region ZNLD/1691/11.

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difference between the LAL and barrier integrity or dose limit is always preserved. What may be varied

. is the difference between operating values and the LAL. The amount of flexibility is case specific, but in general the results of the analysis dictate how much parameters can be varied.

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Guidance on Changing Analyses Theguidan~e is ~s diff;:~~t'~~th~ specific 50.59. It requires an understanding of the change, the impact of the change on SSC an~ on LALs referenced in design basis documents. Also, SRPs, Reg Guides, and Industry Codes can be useful to determine the extent of permissible variation of inputs. Therefore, there are really two limits to monitor in 50.59s; the end results must be within

- bounds, and-the various input parameters must be within a~hievable, realistic and regulated limits.

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• Implicit Margins

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1 mplicit margins, are those instances when an analysis result is dependent on the mechanism used to determine the result. Example; specific computer codes involved in Reload Analyses, ASME code, conformance with material or equipment specifications.. In these cases it should be clear that the "margin" to be preserved/maintained is the.

• calculation method itself or the specification, along with the end result. However implicit means understood, not hidden or unapparent to the reviewer. If an implicit "margin" is an issue it should be identified as such.

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II Implicit Margins Certain analyses techniques are in fact intended to maintained (implicit margins). For example LOCA codes are in themselves preserved parameters, others are not technique dependent.

Analysis tools such as piping computer codes, heat load computer calcs, etc. are "black boxes" that provide the end results. These programs are controlled and verified through the QA program but not submitted for review and acceptance. In these cases the analysis mechanism does not constitute an implicit margin.

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Use of SAP Criteria For older plants this is not typically done. For newer plants this is obviously the evaluation criteria with exceptions as stated in the SERs. However, without any guidance to the contrary, the SRP and industry guides provide a method to determine if parameters are shifted in the appropriate direction and in the appropriate amount. Note that the SRP would not be used to determine the LAL but rather would be used to provide a reasonable measure of parameter variance. Since it is agreed that parameters or independent variables can be adjusted, SRPs provide an excellent guideline.

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Credit for Dose Reduction Byron SER "The applicant has indicated in the FSAR that flow from the main condenser air ejectors can be diverted to a filter system consisting of a demister, electrical heater, prefilter, HEPA, charcoal adsorber, and a HEPA prior to release via the vent stack. However, the applicant did not indicate, based upon the noble gas release, at what corresponding 1-131 release rate flow would be diverted to the filtration system. It is the staff's position that no credit may be given for such a filtration system that is not used on a continuous basis unless the applicant agrees to use the system at a given release rate. Therefore, the fraction of iodine activity which was assumed to be released from the main condenser air ejectors

• was 1.0 rather than 0.10, the value it would have been if credit were given."

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Examples of Margins Margin established for Main Steam Line Isolation Valve Closing Time Quad Cities SER dated August 25, 1971 "The applicant has shown that even if the isolation valves required as long as 10.5 seconds to close the core would not be uncovered and fuel rod cladding perforations would be avoided. These analyses appear reasonable and we conclude that the 5 second Technical Specification limit on valve closure time provides a satisfactory margin~~

Margin to 1 OCFR 100 limits Byron Tech Spec Bases 3/4.4.8 SPECIFIC ACTIVITY "The limitations on the specific activity of the reactor coolant ensure that the resulting 2-hour dose at the SITE BOUNDARY will not exceed an appropriately small fraction of 10 CFR Part 100 dose guideline va~s following a steam generator tube rupture. accident... "

~Byron SER

".*. a small fraction (less than 10 percent) of the exposure limits set fourth in 10 CFR 100.11,"

Required time margins for Inadvertent Dilution Transient NUREG 0800 Rev. 1 - July 1981 "If operator action is required to terminate the transient, the following minimum time intervals must be available between the time when an-alarm announces an unplanned moderator dilution and the time of loss of shutdown margin:

a. During refueling: 30 minutes

b. During startup, cold shutdown, hot standby, and power operation: 15 minutes"

Change to NRC Commitments NRC commitments should not, in general, be changed by-the 50.59 process alone. Any change to a commitment made in response to a violation, generic communication or other similar mechanism should first be approved by the originating NRC office. After approval for commitment modification has been received, a change under 50.59 can be initiated.

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