ML19316A524
| ML19316A524 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/14/1975 |
| From: | Sniezek J Office of Nuclear Reactor Regulation |
| To: | Purple R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7912300066 | |
| Download: ML19316A524 (2) | |
Text
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i JAN 14 B7S l
i R. A. Purple, Chief, Operating Reactors Branch 1, DL DUKE POWER COMPAfW - OCONEE UNITS 1, 2 & 3 - DOCKET NOS.
50-269/270/287 q
We have reviewed the subject licensee's letter to Mr. A.~
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Giambusso dated December 26, 1974, relating to the Oconee i
Technical Specifications (TS), and do not agree with the licensee's position. Our specific comments are concerned I
with the examples of procedure revisions that Duke states
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do not require review by the Station Review Connittee (SRC).
Example 1 '- The SRC review of changes to facility TS does l
not relieve the SRC of the responsibility to l
review procedures resulting from such changes.
The fact that the AEC approves TS changes does not mean approval of related procedures.
i Example 2 - As described in TS 6.1.2.1.d.5, the SRC is
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responsible for reviewing safety-related changes to the station design.
The performance i
of this function does not relieve the SRC of
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the responsibility to review procedure l
revisions resulting from such changes.
Example 3 - Procedure revisions resulting from corrective actions necessitated by station incidents in many cases relate to safety-related structures, systems or components.
In our view, the licensee is not complying with TS I
requirements if such procedure revisions are not reviewed by the SRC.
Example 4 - This example a; pears to be an excerpt from 10 CFR 50.59. The use of this terminology, however, does not relieve the SRC of responsibility.
to review procedure revisions associated with changes, tests or experiments covered by
,J 10 CFR 50.59.
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This mtter has been discussed by Frank fiolan, RO with L. McDonough of your staff.
If you wish to discuss this l
matter further or require additional information, please contact Frank or me (Ext. 7451).
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l Mi.wu J. H. Sniezek, Chief Facility Inspection Branch j
Directorate of Regulatory l
Operations cc:
RLewis, RO:II LMcDonough, DL j
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1 Decetber 26, 1974 7
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lir. Angelo Cincbusso Deputy Director for Reactor Projects
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j Directorate of Licensing Office of Regulation U. S. Atomic Energy Comission Washington, D. C.
20545 Re: Oconee Euclear Station I)acket Eos. 50-269, -270, -287 Dear 1tr. Cinchussoi Oconee Euclear Station Technical Specification 6.1.2. requires that, in natters of nucicar safety and radiation exposure, revicw and audit of station operation, raintenance and technical ratters be provided by tuo con:;:ittecs,- the Station Review Co=ittcc (SRC) cnd the Euclear Safety Revie9 Co=mittee (liSRC). With regard to the on-site co:.nittee, the SRC, Technical Specification 6.1.2.1.d requires that
' the comittee have the~' responsibility to " review all new procedures or changes to existing procedures detercined by the station 1!anager or his designate to affect operational safety."
In order to adequately icplement this Technical Specification, the Duke Pow'er Company, Stean Production Departcent, " Administrative-Policy )!anual,for Nuclear Stations" establishes a detailed progran for the review and approval of station procedures and revisions thereto.
Conecrning procedure revisions, the progran specifies that ' prior to final approval of a procedure revision the Technical Services Superin-te.aient., the Operating Superintendent or the l'.aintenance Superintendent revicu the revision for its safety significance. Such an individual r.sy approve the revision or tay trans it it to the station P.anager for further review. Upon review by the station l'.anager, the revision e.ay be approved, or depending on the station llanager's deterrination of
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the safety significance of the revision, the revision cay be transmitted to th= SRC for rqview. In this manner, full co:pliance' vith the Technical Specification requirenent is achieved in that those procedure revisions which are deternined by the station llanager, or his designate
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(i.e., the group Superintendents),,to affect operational safety are reviewed by the SRC prior to final approval for use.
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.. Er. Angelo Cla Susro Page 2
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Deccc.ser 26. 1h 4 a
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u With rec.ard to irple entation of the Technical Specification requitecent, exceples of procedure revisions which would not require SI:C review are
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as follows:
Revisions reculting from cha:y;es to the Technical Specifications.
1.
(Such changes are reviewed by the SRC prior to submittal to the EC and are revicued, approved and issued by the EC.)
Revisions resulting fro: a properly reviewed and approved station 2.
rodification. (Prior SRC review of codifications to safety-related structures, systess and components is perforced.)
Revisions resulting from corrective actions necessitated by station 3.
incidents.
4.
Procedure revisions which the station Hanager, or his designate, deternine (a) do not increase the probability of occurrence or the consequences of an accident or calfunction of equipment important to safety previously evaluated in the safety analysis report, (b) do not create a possibility for an accident or calfunction of a dif ferent type than any evaluated previously in the safety analysis report, and (c) do not reduce the nargin of safety as defined in the basis for any Technical Specification.
It is Duke Power Company's position S*.t tb[above-described program fully complies with Oconee Ymehar statio. Technical Specification 6.1. 2.1. d.1.
The purpose of this letter is to describe our program
,for nceting the requirements of Technical Specification 6.1.2.1.d.l.
If it is your detercination that the prostan does not fully comply with the requirements of the cited Technical Specification, please advise.
Very truly yours, G
A. C. Tnics ACT:ve cc: Mr.1;ornan C. Moseley g
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STATION EDDIF CATI
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, DOES M PROPOSED MODITICATION:
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Affect the integrity of the reactor. coolant Pressure boundary (excluding lines one inch or less in duneter).
YES _ NO,V i
1.
2.
Affect the capability to shu: deva the reactor and
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maintain'i.t in a safely shutdcun condition.
YES_ NO V
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Affect the capability to prevent or citigate
,t consequences of accidents which eculd result in
- I offsite exposures cc: parable to the gui.leline
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- exposures expressed in Title 10. Code of Federal YES' N01\\
Regulations, Part 100 i
Not affect the reactor or its primary suppo'rt
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systenss but which, in the event of malfunction, i
could result in significant exposure to people under the guidelines of 10CFR20 or 10CTR1GO, ubichever is YES applicabic.
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If the ansvers to 1 through 4 above are all & the modification is not safety-related and further anslysis is not required.
o If the ansver(s') to any of the questicos 1 through 4 above is TES, the modification is safety-related and a Safety Evaluation aust be conducted documenting
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that the modification does not involve an unreviewed s
V safety question.
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