ML19332A483

Forwards IE Circular 80-18, 10CFR50.59 Safety Evaluations for Changes to Radwaste Treatment Sys. No Written Response Required

ML19332A483
Person / Time
Site:	Perkins, Cherokee
Issue date:	08/22/1980
From:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Dail L DUKE POWER CO.
References
NUDOCS 8009160133
Download: ML19332A483 (1)

Text

[

p na.-

'o UNITED STATES 8"

~,1, NUCLEAR REGULATORY COMMISSIGN e-e a REGION 11

'h

~8

%g f

101 MARIETTA ST N.W., SUITE 3100 o

ATLANTA, GEORGIA 30303 AUG 2 21980 In Reply Refer To:

RII:JPO c30:4Y

/ 11 50-489, 50-490 /

Duke Power Comparq ATTN:

L. C. Dail, Vice President Design Engineerirg P. O. Box 33189 Charlotte, NC 28242 Gentlemen:

The enclosed IE Circular No. 80-18, provides information on the details of a 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, C~ C N M [

N p s~9r James P. O'Reilly Director

Enclosures:

1.

IE Circular No. 80-18 2.

Recently Issued IE Circulars i

cc w/ encl:

J. T. Moore, Project Manager i

l l

l l

I e

l 8009160 ] M J j

O e

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.

20555 August 22, 1980 IE Circular No. 80-18: 10 CFR 50.59 SAFETY EVALUATIONS FOR CHANGES TO RADI0 ACTIVE WASTE TREATMENT SYSTEMS Discription 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 uncontrclled 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)(1) 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 D 'TF an. a0 %

. !a"

> eu p H./1n 3 r

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 Technical 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 determice 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 cet 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 l

of the proposed change or test. The depth of the evaluation must be sufficient l

to determine whether or not an "unreviewed 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 cafety hazards are identified, and (2) corrective actions are taken to eliminate, mitigate, or control the hazards to an acceptable level.

l 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 l

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.

l For radioactive waste systems, the appropriate portions of 10 CFR 20, 30, 50, 71, and 100, the facility Technical Specifications, and 40 CFR 190 (Environ-mental Dose Standard) are applicable.

Additional specific criteria that should be reviewed prior tb the modification of radioactive waste systems are presented below:

(1) System modifications should be evaluated against the seismic, quality group and quality assurance critetia in Regulatory Guide 1.143.

Design

)

1 1

l 1

L-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 c

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 he evaluated against the criteria in Standard Review Plan Section 11.3, " Gaseous Waste 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 or radioactivity that is stored or transferred in a waste system are a amall fraction of the 10 CFR 100 guidelines; i.e., less than 0.5 rem whole body l

dose, 1.5 rem thyroid from gaseous releases, and less than the radionuclide concentrations of 10 CFR 20, Appendix B, Table II, Column 2 from liquid releases at the nearest water supplies.

(See Standard Review Plan Sections 15.7.1, 15.7.2, and 15.7.3 for more details.)

l The evaluation must include an analysis encompassing the above criteria to the l-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 l

from this evaluation criteria, one of the following actions should 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 or the departure; or, (3) Commission approval must be received prior to implementing the modification (i.e., an unreviewed safety issue may be involved).

I No written response to this circular is required.

If additional information i

regarding this subject is required, contact the Director of this office.

L l

a IEC 80-18 j

August 22, 1980 RECENTLY ISSUED IE CIRCULARS Circular Date of No.

Subject Issue Issued to 80-18 10 CFR 50.59 Safety 8/22/80 All power reactor Evaluations for Changes to facilities with an Radioactive Waste Treatment OL or CP Systems 80-17 Fuel Pin Damage Due to Water 7/23/80 All holders of PWR Jet from Baffle Plate Corner OLs and PWR cps 80-16 Operational Deficiencies In 6/27/80 All power reactor Rosemount Model 510DU Trip facilities with an Units And Model 1152 Pressure OL or a CP Transmitters 80-15 Loss of Reactor Coolant Pump 6/20/80 All power reactor Cooling and Natural Circula-facilities with an tion Cooldown OL or CP 80-14 Radioactive Contamination of 6/24/80 All holders of power Plant Demineralized Water and research reactor System and Resultant Internal licenses (operating Contamination of Personnel and construction l

permits), and fuel cycle licensees 80-13 Grid Strap Damage in 5/18/80 All holders of reactor Westinghouse Fuel Assemblies OLs and cps 80-12 Valve-Shaft-To-Actuator Key 5/14/80 All holders of reactor May Fall Out of Place When OLs and cps Mounted Below Horizontal Axis l

80-11 Emergency Diesel Generator 5/13/80 All holders of a power Lube Oil Cooler Failures reactor OL or CP 80-10 Failure to Maintain 4/29/80 All holders of reactor Environmental Qualification OLs and cps of Equipment 80-09 Problems With Plant Internal 4/28/80 All holders of a power Communications Systems reactor OL or CP 80-08 BWR Technical Specification 4/18/80 All General Electric Inconsistency - RPS Response BWRs holding a power Time reactor OL