ML20080P650

Proposed Tech Specs Change Request 225 Re Change to Page 6-4 of Tech Spec Section 6.5.1.12.Change Consistent w/NUREG-1433,STSs General Electric Plants,BWR/4,Rev 0,dtd 920928

ML20080P650
Person / Time
Site:	Oyster Creek
Issue date:	02/28/1995
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20080P601	List: ML20080P599 ML20080P650
References
RTR-NUREG-1433 NUDOCS 9503080075
Download: ML20080P650 (3)

Text

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0YSTER CREEK NUCLEAR GENERATING STATION OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 225 L

y Applicant hereby requests the Commission to change Facility Operating License No. DPR-16 as discussed below, and pursuant to 10 CFR 50.91, an analysis concerning the determination of no significant hazards consideration is also presented:

!- 1.0 SECTION TO BE CHANGED Technical Specification Section 6.5.1.12.

2.0 EXTENT OF CHANGE Technical Specification Section 6.5.1.12 is revised to delete the requirement to render determinations in writing with regard to whether or not activities listed in Technical Specification Sections 6.5.1.2 and 6.5.1.5 constitute an unreviewed safety question. These activities are proposed changes to the Appendix A Technical Specifications (6.5.1.2) and investigations of all violations of the Technical Specifications (6.5.1.5).

3.0 CHANGES RE0 VESTED The requested change is shown on the attached Technical Specification page 6-4.

4.0 DISCUSSION This Technical Specification Change removes the requirement to render determinations in writing with regard to whether or not proposed changes to the Technical Specifications and investigations of violations of the Technical Specifications constitute an unreviewed safety question. Both of these activities involve submittals to the NRC. Proposed changes to the Technical Specifications cannot be implemented until approved by the NRC. Investigations of violations of Technical Specifications require a docketed response to the identified violation and are subject to NRC review and acceptance. Therefore, the requirement to determine whether or not either of these activities constitute i an unreviewed safety question, in terms of 10 CFR 50.59 criteria, I is not relevant to the activity. The existing OCNGS Technical Specification Section 6.5.1 and 6.5.2 requirements to perform Technical Reviews and Independent Safety Reviews of these activities are not affected by this change. Therefore, the level of assurance that these activities do not adversely affect nuclear safety or safe plant operations is maintained.

i This change is also consistent with the Revised Standard Technical Specifications (NUREG 1433) Administrative Controls for Review and Audit (STS 5.5.1.1.c).

ADO h o k PDR

5.0 DETERMINATION  ;

GPU Nuclear has determined that this Technical Specification-Change Request involves no significant hazards consideration as defined by NRC in 10 CFR 50.92.

1. Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or the consequences of an accident previously evaluated. The proposed change removes the requirement to render determinations in writing with regard ,

to whether or not proposed changes to the Technical Specifications and investigations of violations of Technical Specifications constitute an unreviewed safety question.

This change is considered an administrative change to remove a requirement which is not relevant to these activities and which is also consistent with the BWR Revised Standard Technical Specifications (NUREG 1433). Existing requirements to perform Technical and Independent Safety Reviews of these activities are not affected. Therefore, ,

the proposed amendment does not significantly increase the  !

probability of occurrence or the consequences of an accident previously evaluated. -

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change is considered administrative since it removes a requirement which is not relevant to the affected activities, and which is also consistent with the BWR Revised Standard Technical Specifications Administrative Controls for Review and Audit. Existing requirements to perform Technical and Independent Safety Reviews for the affected activities are not changed. Therefore, this change has no effect on the possibility of creating a new or different kind of accident from any accident previously evaluated.

3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety. The proposed change removes a requirement which is not relevant to the affected activities. Existing Technical Specification requirements to perform Technical and Independent Safety Reviews for the affected activities are not changed and therefore, will continue to ensure that such activities properly address nuclear safety and safe plant operation. Therefore, it is concluded that operation of the facility in accordance with the proposed amendment does not involve a reduction in a margin of safety.

6.0 IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance.

a *. ,

6.5.1.2 Proposed changes to the Appendix "A" Technical Specifications shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group who prepared the change.

6.5.1.3 Proposed modifications, that affect nuclear safety, to facility structures, systems and components shall be designed by an individual / organization knowledgeable in the areas affected by the proposed modification. . Tach such modification shall be reviewed by an individual / group other than the Lndividual/ group which designed the modification but may be from the same division as the individual who designed the modification.

6.5.1.4 Proposed tests and experiments that affect nuclear safety shall be reviewed by a knowledgeable individual (s)/ group other than the preparer but who may be from the same division as the individual who prepared the tests and experiments.

6.5.1.5 Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence, shall be reviewed by a knowledgeable individual (s)/ group other than the individual / group which performed the investigation.

6.5.1.6 Events requiring 24-hour written notification to the Commission shall be reviewed by an individual / group other than the individual / group which prepared the report.

6.5.1.7 Special reviews, investigations or analyses and reports thereon as requested by the Vice President & Director Oyster Creek shall be performed by a knowledgeable individual (s)/ group.

6.5.1.8 The Security Plan and implementing procedures shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group which prepared them.

6.5.1.9 The Emergency Plan and implementing procedures shall be reviewed by a  ;

knowledgeable individual (s)/ group other than the individual (s)/ group which l prepared them.

6.5.1.10 Review of every unplanned onsite release of radioactive material to i the environs including the preparation and forwarding of reports covering  !

evaluation shall be performed by a knowledgeable individual (s)/ group.  ;

Recommendations and disposition of the corrective action to prevent recurrence l shall be sent to the Vice President & Director Oyster Creek. j 1

l 6.5.1.11 Major changes to radwaste systems shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group which prepared them.

6.5.1.12 Individuals responsible for reviews performed in accordance with 6.5.1.1 through 6.5.1.4 Lhall include a determination of whether or not l additional cross-disciplinary review is necessary. If deemed necessary, such i review shall be performed by the appropriate personnel. Individuals responsible )

for reviews considered under 6.5.1.1 , 6.5.1.3, and 6.5.1.4 shall render i determinations in writing with regard to whether or not 6.5.1.1, 6.5.1.3, and '

6.5.1.4 constitute an unreviewed safety question.

OYSTER CREEK 6-4 Amendment No.: p4, 1/h , /4