ML20147D110

Package Consisting of Draft 10CFR50.59, Changes to Facilities,Procedures & Tests (or Experiments)

ML20147D110
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Issue date:	06/01/1976
From:	NRC
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ML20147D088	List: ML20147D083 ML20147D110
References
FOIA-87-768 NUDOCS 8801200059
Download: ML20147D110 (7)

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, 50.59 Issue Date: 6/1/76 10 CFK 50.59 - CHANCES TO FACILITIES, PROCEDURES AND TESTS (OR EXPERIMEIUS)

PURPOSE The purpose of this guidance is to clarify the specific 10 CFR 50.59 language relating to the type of proposed ' changes, tests or experiments that require a record of the safety evaluation specified in 10 CFR 50.59 (b). It is not intended that this guidance delineate specific licensee review criteria which may be used to identify proposed changes, tests or experiments which require a safety evaluation as specified by 10 CFR 50.59 (b) .

DIS':USSION 10 CFR 50.59 is 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 a change in Technical 8pecifications 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 the licensee maintain records of changes made under the authority of paragraph (a)(1).

Rese records are required to include a written safety evaluation which provides the basis for determining whether an "unreviewed safety question" exists. Paragtaph (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 proce-dures and the proposed conduct of tests which involve an "unreviewed safety question" are required to be subnitted to the NRC as an application for license amendment.

It should be noted that the safety evaluation required by 10 CFR 50.59 is only one of the several evaluations and reviews required by the NRC.

Most Technical Specifications require that onsite review groups review

/ proposed procedures and codifications or changes to plant equipment or t

components affecting safety. Rese review requirements are applicable 1

8801200059 880114 PDR FOIA LAMDERS87-7A8 PDR

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Y 50.59 Issue Date: 6/1/76 whether or not the equipment or component is described in the Safety Ana?ysis Report (SAR). As a result of the TS required reviews, the need for a safety evaluation to meet 10 CFR 50.59 requirements may be identified. Figure 1 delineates a typical overall review scheme at a facility.

The guidance contained herein pertains primarily to that portion between steps C.1 and C.2. .

This guidance is to be applied during inspections of facilities holding an operating license under 10 CFR 50 and is primarily directed towards:

(1) changes made to those systems' and procedures described in the SAR, and (2) performance of tests not described in the SAR.

Within the context of this guidance, any proposed change to a system or procedure as described in the SAR eithe.r by text'or drawings should be reviewed by the licensee to determine whether it involves an unreviewed safety question. Changes may involve an unreviewed safety question even though they are "beyond the second isolation valves," or they do not serve a normal safety-related function, since alteration may introduce an unreviewed safety question.

Maintenance activities which do not result in a change to a system (permanent or temporary), or whi-h replace components with replace =ent parts procured to the same (or equivalent) purchase specification, do not require a tiritten safety evaluation to meet 10 CFR 50.59 requirecents.

However, if components described in the SAR are re:rved, or their function is altered; or if substitute components are utilized; or if changes recnin following co=pletion of a maintenance activty, a safety evaluation is required to meet the provisions of 10 CFR 50.59 and the change cust be reported to the NRC as required by 10 CFR 50.59 (b).

In all cases requiring a written safety evaluation, the safety evaluation cust provide the basis for deter =ination that the proposed change does or does not involve an "unrevie.ted safety question." A simple statement of conclusion in itself is not sufficient; however, depending upon the significance of the change, the safety evaluation cay be quite brief. -

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l 50.59 Issue Date: 6/1/76

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Listed below are examples of various changes to facilities, systems, piecedures and tests which typify those requiring a 10 CFR 50.59 safety evaluation and those which do not reqaire a safety evaluation

-under the requirements of 10 CFR 50.59.

1. Changes in the Facility as Described in the Safety Analysis Report This pertain:: to any changes in the facility which alter the design, function or method of performing the function of a component, system or

, structure described in the SAR, This would apply to components, systems and structures described either in the written portion of the SAR or in the drawings contained therein. Contrasting examoles of each case are:

a) Components - Replacement of a thermocouple in the diesel high-betring temperature automatic shutdown circuitry (if such a [

component were described in the SAR) with one made by the same manufacturer, but encompassing different response characteristics, would require a safety evaluation to meet the requirements of 10 CFR 50.59.

On the other hand, replacement of a thermocouple in the diesel high-bearing temperature automatic shutdown circuitry (if such a component were described in the SAR) with one encompassing equivalent response characteristises, but made by a different manufacturer, would not require a safety evaluation under the requirements of 10 CFR 50.59.

b) Systems - Modification of the diesel shutdown circuitry (described in the SAR) to provide an automatic diesel shutdown on high-bearing tec:perature (shutdown feature not described in application) would require a safety evaluation to meet the require-eents of 10 CFR 50.59. On the other hand, if the methods of initiating autoracic diesel shutdown are not described in the SAR, specific automatic shutdown features may be rendered inoperable without the cond.mt of a safety evaluation under the

. requirements of 10 CFR 50.59.

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1. 50.59 -

Issue Date: 6/1/76 .

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.v. Structures - The erection of a concrete block shield wall iwithin the containment building (shield wall is not described in the SAR) would require a safety evaluation to meet the requirements of 10 CFR 50.59. On the other hand, deletion of a shield wall within the containment building (shield wall not described in the SAR) would not, require a safety evaluation under the requirements of,10 CFR' 50.59.

2. Changes in procedures as Described in the SAR This pertains not only to procedur'es discussed in the Initial Operations and Organizational Chapters of the SAR, but also to other proecedural-type commitments such as the emergency plan and modes and sequences of plant operation described in the SAR. Contrasting examples of each case are: '

a) If in the description of the radioactive waste system in the SAR, the licensee states that the Shif t Supervisor will authorize all radioactive liquid releases, a safety evaluation to meet the requiremen,ts of 10 CFR 50.59 would be required prior to assigning this function to another individual. On the'other hand, if the SAR merely states that radioactive liquid releases will be authorized as detailed by plant procedures, the licensee's redesignation of the authorization function would not require a safety evaluation under the requirements of 10 CFR 50.59.

b) If the reactor startup procedure, as described in the SAR, contains eight fundamental sequences, the licensee's decision to eliminate one of the sequences would require a safety evaluation to meet the 10 CFR 50.59 requirements. On the other hand, if the licensee consolidated the eight fundamental sequences into six sequences but did not alter the basic functions performed, it would not be necessary to conduct a safety evaluation under the i

require:ents of 10 CFR 50.59.

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-N 50.59 Issue Date: 6/1/76 34 conduct Tests and Experit)ents Not Described in the SAR This pertains to the performance of an operation not described in the SAR which could have an adversa effect on safety-related systems.

Contrasting examples of such tests or experiments are:

a) Some plants in the startup testing program have performed a deboration to critical with all rods' inserted. Since this test is performed without deference to the "one stuck rod criterion,"

a safety evaluation to meet the requirem ets of 10 CFR 50.59 would be required if the tdst is not delineated in the SAR.

Since this test may decrease the margin of safety defined in the TS basis, it should in most instances be classified as an unreviewed safety question. On the other hand, a test to demonstrate the calibration of the nuclear instrumentation system by performance of a secondary plant heat balance would not require a safety evaluation under the requirements of 10 CFR 50.59, even if such a test was not delineated in the SAR, since the test does not involve an abnormal mode of operation.

l b) A test to determine if the boric acid evaporator may also be used l for concentration of the steam generator blowdown effluent (function I

not described in the SAR) would require a safety evaluation to meet the requirements of 10 CFR 50.59, since secondary system .

l chemicals could possibly have a deleterious effect on some conponents l vithin the reactor coolant pressurt boundary. On the other hand, an experiment to determine the decontamination factor of the liquid waste concentrator with influent activities of 10 -2 ue/mi and 10 -5 ue/mi would not require a safety evaluation under the requirements l of 10 CFR 50.59 since such an experiment would not represent departure 1

from normal operational modes.

l 4. General Guidance i

l It should be noted that SARs for a number of older facilities contain floor plans of onsite buildings that may include trivial detail such as the locating of dividing walls between various offices. From a l 5 l

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50.59

w' Issue Date: _6/1/76 C

rigid reading:of 10 CFR 50.59, it is possible to infer that the removal e of a dividing wall between two offices constitutes a change from the facility described in the SAR, and therefore requires a safety evaluation.

However, the intent of 10 CFR 50.59 is to limit the requirement for written safety evaluations to facility changes, tests and experiments which could impact the safety of operations.

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50.59 Figure 1 Issue Date: 6/1/76 CHANGE I A. PR0POSAL

• sent to

• 1 Review Authority er es:

B. designated by Plant 1. Is safety affect

2. Are SAR and TS affected?

NO . NOT SURE l

v Not V Approved Approved i

Referral may Onsite review authority ** "***

be required C. designated by Plant Procedures 1. Is 50 S safety by some TS

,y, g, (or in some cases the TS required?

NO YES 2.a. Does unrevieve safety questie exist?

b. Is TS change required?

NO YES Disappro v v q Proposa D' ) Onsite review authority Submit to NRC for Determinos designated in TS license amendment Varies according (Some TS require l to TS prior review by a I

designated review e q authority)

Approve Disapprove Proposal Proposal l -

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