ML20005E520
| ML20005E520 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/28/1989 |
| From: | Hayes J Office of Nuclear Reactor Regulation |
| To: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| GL-86-03, TAC-69066, TAC-74577, TAC-74821, TAC-74823, TAC-74824, TAC-74825, TAC-74826, TAC-74839, TAC-75049, NUDOCS 9001080063 | |
| Download: ML20005E520 (5) | |
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December 28, 1989 Docket 50-395 Mr. 0.- S. Bradham Vice President, Nuclear Operations South Carolina Electric & Gas Conany P.O. Box 88 f
Jenkinsv111e, South Carolina 29065 i
Dear Mr. Bradham:
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SUBJECT:
AMENDMENT r.EOUESTS FOR THE V. C. SUMMER NUCLEAR STATION, UNIT NO 1 (SUMMER) (TAC NOS. 69066, 74577, 74821, 74823-74826, 74839, AND 75049)
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The NRC staff's review of your amentent request involving the feedwater i
isolttion valves (TAC 72893) determined that your submittal was missing a Safety Analysis' (SA). : As a-result of this finding, the staff reviewed other recent aner.dment requests and found that some of these submittals were also missing a SA or the SA was in a format which was. inconsistent with that expected for licensing amendments.
A review of these submittals also revealed some instances where the no significant hazards consideration (NSHC) was deficient in content and'forr.at.
The deficiencies which were identified can i
best be sumarized as taking the form of one of the following:
1)
The NSHC included no description of the amendment request and/or no safety assessment.-
2)
The proposed amendment regnest.does not.contain a reparate and distinct SA document which stands alone and contains a description of the plant specific request end the basis for its acceptebility.
This occurs frequently % hen the anendment request involves a generic a > plication of an item to Sumer and topical reports are utilized in tie submittal.
While I was at your plant during the week of August 7,1989 and again on Noveder 17, 1989, I discussed the content and the format of your amendment requests with meubers of your staff.
During the time between these two meet-ings, numerous telephone conversations were held to discuss your submittals.
- As a result of these conversations, on December 11,19E9 you submitted refer-matted sybmittals for all of the recent amendrent reg (TACs 69066 and 74823, ests noted in Enclosure 1 cxcept L and the diesel generator fuel oil sampling respectively).
Your resubmittals addressed the deficiencies noted in Enclosure 1.
As a result of these submittals those requests which have not been noticed in th9 Federa1, Register can now be noticed.
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December 28, 1989 Mr. O. S. Bradham 2
To assist your staff we are providing a. copy of Generic Letter 80 03 which addresses the necessary inforation to be included in a NSHC.
This is included as Enclosure 2.
We are also providing a copy of a letter which was transmitted to Arizona Nuclear Power Project w11ch provides additional details on the informatJon which should be included in amenchnent request.
'This-letter'is included as Enclosure 3.
1 The inforation presented in this letter has been discussed with your staff.
Sincerely,
Original Signed By:
t' John J. Hayes, Jr. Project Manager Project Directorate 11 1 Division of Reactor Projects Office Of Nuclear Rector Regulation
Enclosures:
- 1. Status of Recent.
- anendment requests i
- 2. Generic Letter 86 03'
- 3. Letter to Arizona Nuclear Power Project cc w/encls:
See next page DISTRIBUTION See attach page t
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Document Name:
RESUBMITTALS
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i South Carolina. Electric & Gas Company Virgil C. Sumer Nuclear Station j
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Mr. William A. Williams, Jr.
Technical Assistant - huclear Operations Santee Cooper P. O. Box 764.(Mail Code 153) i Columbia, South Carolina 29218 J. B. Knotts Jr., Esq.
Bishop, Cook, Purcell j
and Reynolds.
-1400 L Street, N.W.
Washington, D. C.
20005-3502 Resident Inspector / Summer hPS c/o U.S. Nuclear Regulatory Comission Route 1 Box 64 i
~Jenkinsville, South Carolina 29065 t
Regional Administrator, Region II U.S. Nuclear Regulatory Comission, 101 Marietta Street, N.W., Suite 2900 t
Atlanta, Georgia 30323 Chairman, Fairfield County Council P. O. Box 293 Winnsboro, South Carolina 29180 Mr. Heyward. G. Shealy, Chief l
Bureau of-Radiological Health South Carolina Department of Health and Environmental Control l
2600 Bull Street Colunbia, South Carolina 29201 South Carolina Electric & Gas Company Mr. A. R. Koon, Jr., Manager Nuclear Licensing Virgil C. Sumer Nuclear Station P. O. Box 88 Jenkinsville, South Carolina 29065 i
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ENCLOSURE 1 STATUS OF.RECENT AMENDMENT REQUESTS FOR V. C. SUMER HUCLEAR STATION L
. TAC AMENDMENT REQUEST STATUS OF NSHC STATUS CF SA 69066
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3 (8/1/88 & 6/12/89) g
.74577 F Extension 1
(7/24/09)'
r 74821 Renumberin 1
2
-(8/10/89) g TS 3/4.7.11 74823 DG Fuel Oil Sanpling 2
(7/27/89 & 9/21/89)
'74824' RHR Autoclosure 3
(7/21/89) '
74825 DC Fuel Oil Storage Vol.
2 (7/21/89 & 9/21/89) 74826 RTD Bypass 14nifold 3
(7/21/89) 74839 B & W SG Sleeves 1
L (9/19/89) 74549 Deletion of Cycle Specific 4
2 Pa rameters (9/19/89)
I flSHC is missing description of the amendment request and/or missing saf ety ' assessment.
l 2
Submittal does not contain a distinct and separate SA document which l
contains the plant specific SA covering the request and the basis for its a cceptabili ty.
4 3
Submittal includes a WCAP but no plant specific SA covering the request and the basis' for the acceptability of the request.
1.
a Example of a good NSHC.
i Requests which have not been noticed.
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etnas 14-H-3 IAdensam 14-B-20 l; Anderson 14-B-20 M Hayos 14-B-20 EC (For inform. Only) 15-B-18 g-: Jordan MfiBB-3302
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ip ENCLOSURE 1 STATUS OF RECEt:T AMENDMENT FIQUESTS FOR V. C. SUMMER NUCLEAR STATION 1
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TAC AMENDMENT REQUEST STATUS OF f;SHC STATUS OF SA 69066 L
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(8/1/88 & 6/12/89) 74S 77 F Extension 1
(7/24/89)'
74821 Renumbering TS 3/4.7.11 1
2 (8/10/89) 74823 DG Fuel Oil Sarpling 2
i (7/27/89 & 9/21/89) 74824 P.HR Autoclosure 3
(7/?1/89) 74825 '
00 Fuel Oil Storage Vol.
2 (7/21/89 & 9/21/89) 74826 RTD Bypass l'anifold 3
L (7/21/89)
(9/19/89) 74549 '
. Deletion of Cycle Specific 4
2 Parameters (9/19/89) l' ilSilC is missing 'descriptien of the amendment request and/or missing safety assessment.
2-
-Submittal does not contain a distinct and separate SA document which contains the plant specific SA covering the request and the basis for its l
a cceptabili ty.
3 Submittal includes a WCAP but no plant specific SA covering the request and the basis for the acceptubility of the request.
4 Example of a good iGilC.
i' Requests which have not been noticed.
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Lnclosure 2 unutt3stATas NUCLEAR REGULATORY COMMISSION
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wasamoton. o. c. nus gk February 10, 1986 TO ALL LICENSEES OF OPERATING REACTORS AND APPLICANTS FOR AN OPERATING LICENSE Gentlemen:
SUBJECT:
APPLICATIONS FOR LICENSE AMEN 0MENTS (Generic Letter 86-03)
)
During the past year, I have evaluated the difficulties in providing timely i
notices in the Federal Register regarding license amendments proposed for issuance. One of the reasons for these difficulties is that too often the infomation called for by 10 CFR 50.91(a)(1) regarding an analysis of no significant hazards consideratier, using the standards of 10 CFR 50.92 is not provided with the amendment request.
i The enclosed discussion is for your information and guidance.
Its purpose is to reduce delays in processing Federal Recister Notices regarding license amendment requests.
Included with the discussion is an example of a submittal which the staff found to contain an adequate analysis of the no significant hazards consideration.
L You are requested to ensure that all future amendment requests contain sufficient documentation to specifically address each factor under 10 CFR 50.92(c). An t
adequate submittal would include a detailed basis sufficiently comprehensive on the issue of no significant hazards consideration to pemit the staff to file a timely Federal Recister Notice. The staff's objective is to have most routine Federal Register Notices published within 20 working days of receipt of a license amenhent request.
In the event that the staff is unable to find that an adequate basis to support a finding regarding no significant hazards consideration has been provided, I have' directed the Project Director to return the application so that the necessary information can be included. This will also highlight to utility management any significant problem the staff is experiencing with your amenhent requests.
Any such detemination will be made by the staff within six working days of receipt. Your Project Manager will promptly notify you and return the amenhent request accordingly.
No specific response to this letter is required.
Please contact your Project Manager if you have any questions.
l Harold R. Denton, Director Office of Nuclear Reactor Regulation h
Enclosure:
As stated 4MH803F4' kP
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ENCLOSURE RECENT PROBLEMS WITH LICENSE AMENDMENT REQUESTS 10 CFR 50.91(a)(1) requires that licensees requesting an amendment provide en analysiu "using the standards in 50.92" ((the 3 factor test) about the issu of no s gnificant hazards considerations NSHC). $taff final deteminations must also use the 3 factor test of 50.92. Pro use the examples of actions which are "likely" posed staff deteminations may or "not likely" to involve significant hazards considerations. These examples were provided in Enclo-sure 1 to Generic Letter 83-19.
The basic problem with many recent license amendnent requests is that the licensee does not provide an analysis using the 3 factor test. Often, all the licensee provides is a simple bot 3om line assertion, copying the 3 factors, but offering no analysis.
In many cases the safety assessment is brief or lacking in content such that the reader cannot conclude that the basis for the NSHC detemination is in fact adeouately provided in the description or in the safety assessment section.
In other cases the safety assessment is written so that the reader cannot detemine which part of the assessment-l applies to which of the three factors. A simple assertion that references en entire, fairly complex safety assessment as justification for satisfying the three factor test is not considered satisfactory. To expedite processing of your application, each of the three factors should be addressed separately for each part of the license amendnent request. An assertion without appro-priate analysis does not satisfy 10 CFR 50.91(a)(1).
L While a licensee may offer an opinion to be M1pful to the staff on which example is appropriate, that is not sufficip t to satisfy"unlikely" tha 50.91(a)(1)--a licensee is not merely to suggest that it 4 "likely" or i
proposed amendment involves a 31gnificant h4zards consideration -- the Ifeensee is required to give an analysis in tems of the 3 factors. The licensee should not need examples of what is "likely" or "unlikely"; the licensee must complete a safety evaluation before submitting the proposed amenenent.
Thus, the licensee should know on the basis of the completed technical evaluation whether the proposed amendment increases the prot; ability or consequences of an accident previously evaluated, creates the possibility of a new accident or reduces a safety margin. On this basis the licensee should be able to articulate clearly the specific reasons as,to whether the change is significant.
Attached is an example of a submittal which the staff found to meet the above criteria.
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ATTAC MENT 1 g
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Description of amendment request:
The proposed amendment would modify Technical Specification 2.2.2, "Cere Protection Calculator Addressable Constants"; Table 2.2-2, which provides a listing of the Type I and Type !! Addressable Constants; and the associated Sases.
The proposed amendment would also revise the appropriate pape of the i
Index, delete the reference to Table 2.2-2 from Notation (9) and de ete Notation (10) of Table 4.3-1, and delete the note in Aministrative Control 6.8.1 (g).
The addressable constants of the Core Protection Calculators (CPC) provide a mechanise to incorporate reload dependent parameters and calibration constants to the CPC software so that the CPC core model is maintained current with changing core configurations and operating characteristics.
r As a method to avoid gross errors upon operator entry of an addressable constant, a reasonability check requirement was imposed by the original NRC CPC Review Task Force.
The CPC software has been designed with automatic acceptable input checks against limits that are specified by the CPC functional design specifications.
Therefore, inclusion of the addressable constants and the software lief t values in the Technical Specifications (2.2.2 and Table 2.2-2) is redundant, and serves only to enforce prior approval of changes to these limits.
Proper administrative control procedures are available to assure that appropriate values of addressable constants are entered by the operator. Any CPC software changes involving addressable constants or software limit values are made and tested under NRC approved sof tware change procedures and are available for NRC review.
BASIS FOR N0 $1GNIFICANT HAZAR85 DETERMINATION:
The proposed change does not involve a significant hazards consideration i
because operation of Arkansas Nuclear One Unit 2 in accordance with this change would not:
(1) involve a significant increase in the probability or consequences an accident previously evaluated.
This change merely eliefnetes redundant administrative requirements concernin11 the CPC adoressable constants.
The function of these requirements 's already faplemented by the allowable value checks in the CPC software.
Changes to the addressable constants are accomplished through strict seinistrative procedures.
Therefore, this change cannot increase the probability or consequen.tas of an accident.
(2) create the possibility of a new or different kind of accident from any previously analyzed.
It has been determined that a new or different kind of accident will not be possible due to this change.
This elimination of redundant administrative requirements does not create the possibility of a new or different kind of accident.
(3) involve a significant reduction in a margin of safety. Aetnistrative l
procedures involving the CPC addressable constants ensure that the CPC core model is calibrated to current plant conditions and therefore preserve the margin of safety.
Elimination of redundant administrative requirements will not reduce the margin of safety.
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The Commission has provided guidance concerning the appitcation of the standards for determining whether a significant hazards consideration amists by providing certain examples (48 FR 14470) of amendments that are considered not likely to involve significant hazards consideration.
Example (1) relates t: a purely administrative change to Technical Specifications:
i for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature.
Example (iv) relates to a relief granted upon demonstration of acceptable j
operation free an operating restriction that was imposed because acceptable operation was not yet demonstrated.
This assumes that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way i
that the criteria have been est.
1 In this case, the proposed change described above is similar to both Example (1) and Example (iv) in that deletion of Technical Specification 2.2,2, i
Table 2.2-2 and modifications to the related pages are purely administrative changes, and are also relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable 3
operation was not yet demonstrated.
Conceptually, the addressable constants reasonability checks are the equivalent of the limits of an adjustable potentiometer in the conventional analog hard-wired type protection system.
The lietts of these potentiometers are not specified in the Technical specifications, as this would be unrealistic and would make no contribution to plant safety.
The addressable constants are basically calibration constants which are used to assure that the CPC calculations of core parameters accurately reflect actual plant conditions.
The proposed change may therefore be considered to achieve consistency throughout the Technical Specifications in that it removes a listing of calibration constants which is redundant in purpose and is not provided for any other system.
r Removal of the listing of the addressable constants (and the allowable ranges of the Type I constants) say be considered a relief from an operating L
restriction tnat was imposed by the NRC CPC Review Task Force because acceptable operation was not yet demonstrated. ANO-2 was the first CE plant equipped with the CPC systee; the addressable constants Technical Specification was imposed because this system was the first application of a digital computer based portion of a reactor protection systes.
Subsequent operational experience with the CPC systee, both at AND 2 and the other CPC equipped plants, has demonstrated acceptable operation.
Relief from this administrative restriction has been allowed after several meetings between the utilities with CPC equipped plants and the NRC Core Performance Branch, which included members of the CPC Review Task Force. The criteria appited to the relief from this operating restriction have been established and there is satisfactory justification that they have been met. The NRC Core
- Performance Branch have issued a draft Safety Evaluation Report (concerning the removal of the addressable constants Technical Specification) which provides this justification.
Therefore, based on the above considerations. AP&L has determined that this change does not involve a significant hazards consideration.
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Docket Nos.:
50-528, 50-529 DISTRIBUTION and 50-530 Docket File NRC & Local PDRs t
Mr. E. E. van Brunt, Jr.
GMHolahan Executive Vice President JLee Ari2cna Nuclear Power Project EAlicitra/MJDavis Post Office Box 52034 OGC-Bethesca Phoenix, Arizona 85072-2034 EJordan/JPartlow ACRS (10)
Dear Mr. Van Brunt:
PDV Plant File
SUBJECT:
GUIDANCE ON FILING LICENSE AMENDMENT REQUESTS FOR PALO VERDE The purpose of this letter is to summarize the guidance we have been providing to your staff over the past 19 months concerning the filing of license f
amendment requests.
Initial guidance was provided in a January 1986 meeting held in Phoenix, Arizona, and was followed by the guidance in Generic letter 86-03, dated February 10, 1986.
Additional guidar.co has been provided verbally on several occasions since then during the processing of a number of license amendment requests on Palo Verde.
We note that th content of your recent submittals on amendment requests shows an improving trind when compared to earlier submittals.
In order that this trend may continue, we are repeating the guidance given so that it could be available to all ANPP personnel involved in processing license amendment requests.
The regulations applicable to filing the technical portion of a license amend-ment request are 10 CFR 50.90, 50.91 and 50.92, where 10 CFR 50.92 provides the standards for determining whether a proposed amendment involves a no significant hazards consideration.
Examples of amendments that are considered likely, or not likely, to involve a significant hazards consideration are provided in 51 FR 7750 and 51 FR 7751, respectively.
Specific guidance on the preparation of license amendment requests is contained in four enclosures to this letter. Summarizes what the content should be for amendment requests; Enclosure 2 discusses the information that should be included in the safety evaluation; Enclosure 3 provides more detail on how to address the standards for determining whether a no significant l
hazards consideration exists; and Enclosure 4 summarizes what additional infor-mation is required for an amendment involving exigent or emergency circumstances.
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J If you have any questions regarding this letter please let me know, i
Sincerely.
C ;-!r.r! signed bp E. A. Ucitra M i
E. A. Licitra, Senior Project Manager Project Directorate Y Division of Reactor Projects - !!!.
!Y, Y and Special Projects
Enclosures:
As stated I
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CONTENT FOR LICENSE AMENDMENT REQUESTS Each amendment request should include the following information:
A description of the content of the current license condition or technical specification, including specific identification of the condition or specification (e.g., Paragraph 2.C(8), " Emergency Preparedness," or Technical Specification 3/4.2.4, "DNBR Margin").
A description of the proposed change.
t 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 is being requested.
i A safety evaluation demonstrating the adequacy of the level of safety provided in support of the requested change (see Enclosure 2 for more detail).
A discussion of whether a no significant hazards consideration is involved and the basis for the determination, using the standards p
in 10 CFR 50.92 (see Enclosure 3 for more detail).
l-t An environmental impact consideration determination (see 10 CFR 51.21 and 10 CFR 51.22).
a Marked-up pages reflecting the requested change.
Application fee (see 10 CER 170).
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l' CONTENT OF SAFETY EVALUA110NS FOR LICENSE AMENDMENT REQUESTS The safety evaluations provided for staff review and approval should include j-the following information:
A description of the areas being evaluated, i
A discussion of the analytical methods used, including the input parameters, in 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 6
changes to determine whether the changes have en adverse safety impact.
The results cf the evaluation which demonstrate the ' adequacy of the level of safety provided by the propcsed changes.
The level of detail provided by the safety evaluation should be such j
that the staff can make an independent assessment of the evaluation based on the information provided by the licensee.
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e ADDRESSING THE STANDARDS IN 10 CFR 50.92 In addressing the standards for determining whether a no significant hazards consideration exists, the discussions should include the following infermation and should have sufficient detail for the staff to draw the same conclusions as the licensee, based on the information presented.
Standard 1 - Involve a Sionificant Increase in 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 significant increase in probability or consequences of those previously evaluated accidents.
If the proposed changes do not t
affect any previously evaluated accidents, the reasons for this conclusion l
should be stated, i
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 different accident is involved.
Amendment requests invciving changes in 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, i
a Standard 3 - Involve a Sionificant Reduction in a Marcin of Safety The discussion of this standard should consider whether any margin of Safety, based on tne 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 Specification Bases of record.
A signifi-cant reduction in margin can be involved even if the results of revised analyses are within acceptance criteria,
f JUSTIFICATION REQUIRED FOR ESTABLISHING AN EXIGENT OR EMERGENCY i
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 in order 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 in Enclosures 1, 2, and 3.
The required additional information for i
justifying an emergency classification, which is identified below, should be submit!*d in a timely manner and in sufficient detail for the staff to draw the same conclusions as the licensee, based on the information presented.
(1) Establish that immediate action is 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.
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When a request is made for exigent action on a license amendment submittal, the additional 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 relia-bility, or a significant environmental benefit.
. _ _