ML17296A974
| ML17296A974 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/22/1980 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 8009160178 | |
| Download: ML17296A974 (10) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1990 N. CALIFORNIABOULEVARD SUITE 202, WALNUTCREEK PLAZA WALNUTCREEK, CALIFORNIA94596 August, 22, 1980 Docket Nos. 50-528, 50-529, 50-530 Arizona Public Service Company P. 0.
Box 21666 Phoenix, Arizona 85036 Attention:
Nr. E. E. Van Brunt, Jr.
Vice President, Nuclear Projects Gentlemen:
The enclosed IE Circular No. 80-18, provides information on the details of' safety evaluation that is necessary to adequately support changes to radwaste systems.
No written response is required.
Should you have any questions related to the enclosed information, please contact this office.
Sincerely, R.
H. Engelken Director
Enclosures:
1.
IE Circular No. 80-18 2.
Recently Issued IE Circulars cc w/enclosures:
F.
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 August 22, 1980 SSINS No.: 6830 Accession No.:
8006190038 IEC 80-18 IE Circular No. 80-18:
10 CFR 50.59 SAFETY EVALUATIONS FOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS Discri tion of Circumstances:
Recent inspection efforts at operating power reactors have revealed numerous instances in which licensees have failed to perform adequate safety evaluations to support changes made to the design and/or operation of facility radioactive waste treatment systems.
These safety evaluations are required by the 'regula-tions of 10 CFR 50.59 whenever changes are made in the facility as described in the Safety Analysis Report (SAR).
The inadequacies of the evaluations have caused radiological safety hazards to occur unidentified and therefore to remain unevaluated and uncorrected.
In two particular cases, the inadequately evaluated system changes resulted in system failures that caused an uncontrolled release of radioactivity to the environment.
In each of these situations, a proper 10 CFR 50.59 safety evalua-tion should have identified and corrected deficiencies in the system modifica-tion and/or operation and would have prevented the inadvertent release of radioactivity.
NRC followup examination of the situation indicates that the inconsistency and/or inadequacy of licensee safety evaluations may be widespread.
A wide range of opinions seems to exist among licensees as to what constitutes an appropriate 10 CFR 50.59 safety evaluation, particularly for radwaste systems.
Therefore, the following discussion and/or guidance is provided for licensee use in preparing future 10 CFR 50.59 safety evaluations to support changes. in the design and/or operation of the radioactive waste treatment systems of licensed facilities.
Although the contents of this guidance are specifically directed to the radioactive waste systems, the general principles and philosophy of the 10 CFR 50.59 safety evaluation guidance are also applicable to the facility design and operation as a whole; thus, the application of 10 CFR 50.59 should reflect a consistent approach.
Discussion:
The requirements of 10 CFR 50.59 are composed of three essential parts.
First, paragraph (a)(l) is permissive in that it allows the licensee to make changes to the facility and its operation as described in the Safety Analysis Report without prior approval, provided that a change in Technical Specifica-tions is not involved or an "unreviewed safety question" does not exist.
Criteria for determining whether an "unreviewed safety question" exists are defined in paragraph (a)(2).
- Second, paragraph (b) requires that records of changes made under the authority of paragraph (a)(1) be maintained.
These records are required to include a written safety evaluation that provides the
l
IEC 80-18 August 22, 1980 Page 2 of 3 basis for determining whether an "unreviewed safety question" exists.
Paragraph (b) also requires a report (at least annually) of such changes to the NRC.
Third, paragraph (c) requires that proposed changes in Techn'ical Specifications be submitted to the NRC as an application for license amendment.
Likewise, proposed changes to the facility or procedures and the proposed conduct of tests that involve an "unreviewed safety question" are required to be submitted to the NRC as an application for license amendment.
Any proposed change to a system or procedures described in the SAR, either by text or drawings, should be reviewed by the licensee to determine whether it involves an "unreviewed safety question."
Maintenance activities that do not result in a change to a system (permanent or temporary),
or that replace components with replacement parts procured with the same (or equivalent) purchase specification, do not require a written safety evaluation to meet 10 CFR 50.59 requirements.
- However, a safety evaluation is required to meet the provisions of 10 CFR 50.59 and any change must be reported to the NRC as required by 10 CFR 50.59(b) if the following circumstances occur:
(1) com-ponents described in the SAR are removed; (2) component functions are altered; (3) substitute components are utilized; or (4) changes
'remain following comple-tion of a maintenance activity.
Notice to Licensees:
For all cases requiring a written safety evaluation, the safety evaluation must set forth the bases and criteria used to determine that the proposed change does or does not involve an "unreviewed safety question."
A simple statement of conclusion in itself is not sufficient.
However, depending upon the significance of the change, the safety evaluation may be brief.
The scope of the evaluation must be commensurate with the potential safety significance of the proposed change or test.
The depth of the evaluation must be sufficient to determine whether or not an "unr eviewed safety question" is involved.
These evaluations and analyses should be reviewed and approved by an appro-priate level of management before the proposed change is made.
An important part of the "unreviewed safety question" determination is the evaluation and analysis of the proposed change by the licensee to assure that (1) potential safety hazards are identified, and (2) corrective actions are
.taken to eliminate, mitigate, or control the hazards to an acceptable level.
All realistic failure modes and/or malfunctions must be considered and protec-tion provided commensurate with the potential consequences.
All applicable regulatory requirements, including Technical Specifications, must be complied with so that the proposed change shall not represent an "unreviewed safety question."
Also, the margin of safety as defined in the bases of the Technical Specifications shall not be reduced by the proposed change.
For radioactive waste
- systems, the appropriate por tions of 10 CFR 20, 30, 50, 71, and 100, the facility Technical Specifications, and 40 CFR 190 (Environ-mental Oose Standard) are applicable.
Additional specific criteria that should be reviewed prior to the modification of radioactive waste systems are presented below:
(1)
System modifications should be evaluated against the seismic, quality group and quality assurance criteria in Regulatory Guide
- 1. 143.
Oesign
I
IEC 80-18 August 22, 1980 Page 3 of 3 provisions for controlling releases of radioactive liquids, as presented in Regulatory Guide 1. 143, should also be evaluated.
(2)
Radiological controls should be evaluated against the criteria in Regulatory Guide 1.21 and Standard Review Plan Section 11.5, "Process and Effluent Radiological Monitoring and Sampling Systems."
(3)
Systems involving potentially explosive mixtures should be evaluated against the criteria in Standard Review Plan Section 11.3, "Gaseous llaste Management System," subsection II, item 6.
(4)
System design and operation should be evaluated to assure that the radiological consequences of unexpected and uncontrolled releases of radioactivity that is stored or transferred in a waste system are a small fraction of the 10 CFR 100 guidelines; i.e., less than 0.5 rem whole body
- dose, 1.5 rem thyroid from gaseous
- releases, and less than the radionuclide concentrations of 10 CFR 20, Appendix 8, Table II, Column 2 from liquid releases at the nearest water supplies.
(See Standard Review Plan Sections 15.7. 1, 15'.2, and 15.7.3 for more details.)
The evaluation must include an analysis encompassing the above criteria to the extent that the criteria are applicable to the proposed changes; i.e., if the modifications involve a change addressed by the above regulations and criteria, then the modifications must be evaluated in terms of these regulations and criteria.
In conclusion, for any change in a facility radioactive waste system as described in the
- SAR, a safety evaluation is required in accordance with 10 CFR 50.59.
In this safety evaluation and the "unreviewed safety question" determination, the evaluation criteria in Items 1-4 above should be used.
If the proposed modification (design, operation, or test) represents a departure from this evaluation criteria, one of the following actions sh'ould be taken:
(1)
The proposal should be modified to meet the intent of the criteria; (2)
The evaluation/determination must present sufficient analyses to demonstrate the acceptability of the departure; or, (3)
Commission approval must be received prior to implementing the modification (i.e.,
an unreviewed safety issue may be involved).
No written response to this circular is required.
If additional information regarding this subject is required, contact the Director of this office.
RECENTLY ISSUED IE CIRCULARS IEC 80-18 August 22, 1980 Circular No.
80-17 Subject Fuel Pin Damage Due to Water Jet from Baffle Plate Corner Date of Issue 7/23/80 Issued to All holders of PWR OLs and PWR CPs 80-16 Operational Deficiencies In Rosemount Model 510DU Trip Units And Model 1152 Pressure Transmitters 6/27/80 'll power reactor facilities with an OL or a CP 80-15 80-14 80-13 80-12 80-11 80-10 Loss of Reactor Coolant Pump Cooling and Natural Circula-tion Cooldown Radioactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel Grid Strap Damage in Westinghouse Fuel Assemblies Valve-Shaft-To-Actuator Key May Fall Out of Place When Mounted Below Horizontal Axis Emergency Diesel Generator Lube Oil Cooler Failures Failure to Maintain Environmental gualification of Equipment 6/20/80 6/24/80 5/18/80 5/14/80 5/13/80 4/29/80 All power reactor facilities with an OL or CP All holders of power and research reactor licenses (operating and construction permits),
and fuel cycle licensees All holders of reactor OLs and CPs All holders of reactor OLs and CPs All holders of a power reactor OL or CP All.holders of reactor OLs and CPs 80-09 Problems With Plant Internal 4/28/80 Communications Systems All holders of a power reactor OL or CP 80-08 80-07 BWR Technical Specification Inconsistency RPS
Response
Time Problems with HPCI Turbine Oil System 4/18/80 4/3/80 All General Electric BWRs holding a power reactor OL All holders of a power reactor OL or CP
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