ML20151A390

Temporary Change Notice 1-1 to Rev 1 to Procedure SO123-VI-1.3, Documents - Guidelines for Completing Unreviewed Question & Environ Evaluation

ML20151A390
Person / Time
Site:	San Onofre
Issue date:	12/18/1985
From:	Mcgee B SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20151A165	List: ML20151A162 ML20151A335 ML20151A360 ML20151A364 ML20151A388 ML20151A390 ML20151A404 ML20151A414 ML20151A417 ML20151A427 ML20151A436 ML20151A439 ML20151A651 ML20151A661 ML20151D441 ML20151D513
References
SO123-VI-1.3, NUDOCS 8807190357
Download: ML20151A390 (14)

Text

e HUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 1 0F 12 EFFECTIVE DATE __

f .4)-8I TCN i - l.

DOCUMENTS - GUIDELINES FOR COMPLETING THE UNREVIEWE0 3AFETY QUESTION AND ENVIRONMENTAL EVALUATION TABLE OF CONTENTS PAGE SECTION 2

1.0 OBJECTIVE 2

2.0 REFERENCES

2 .

3.0 PREREQUISITE 2

4.0 PRECAUTION (S) 2 5.0-~ CHECKLIST (S) ,

3 6.0 PROCEDURE 3

6.1 General Information 6.2 Unreviewed Safety Question Evaluation 3 Technical Specification Evaluation. 5 6.3 6

6.4 Environmental Evaluation 6

7.0 RECORDS .

l ATTACHMENTS

_.Unreviewed Safety Question Evaluation Guidelines 7

._ __. _ 1 10 2 Environmental Evaluation Guidelines 1

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NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0:23-VI-1.3 REVISION 1 PAGE 2 0F 12 UNITS 1, 2 AND ,3 TCN l-l DOCUMENTS - GUIDELINES FOR COMPLETING THE UNREVIEWED SAFETY QUESTION AND ENVIRONMENTAL EVALUATION n --..-- _. -_ _ _.

1.0 OBJECTIVE 1.1 To establish guidelines for completing ~the untsviewed safety questions and .tnvironmental evaluation 'as required for new, revised, or cancelled Site documents.

2.0 REFERENCES

2.1 Licensing Commitments 2.1.1 10 CFR 50.59 and 10 CFR 51 2.1.2 Unit 1, Unit 2, and Unit 3 Technical Specifications 2.2 Procedure 2.2.1 S0123-VI-1.0, Documents - Review and Approval Process for Site Orders, Procedures and Instructions 2.3 Other 2.3.1 Unit 1 and Units 2/3 Final Safety Analysis Report (FSAR) 3.0 PREREQUISITE 3.1 Prio- to use of an uncontrolled (pink) copy of this Procedure, it is e s user's responsibility to verify that the revision and any TCNs are current by utilizing one of the following methods:

3.1.1 Check it against a controlled copy and.any TCNs; 3.1.2 Access an SCE Document Configuration System (SDCS) TSO i

Terminal; I

3.1.3 Contact CDM by telephone or through counter inquiry; 3.1.4 Obtain an uncontrolled (pink) copy of the Procedure from ,

CDM; 3.1.5 Reference a current (within one week) Destination Configuration Control Log and associated daily update.

4.0 PRECAUTION (S) 4.1 None __

5.0 CHECKLIST (S) 5.1 None

NUCLEAR GENERATION SITE ADMT.NISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 3 0F 12 TCH l-l 6.0 PROCEDURE 6.1 General Information 6 '.1.1 Preparation, review, and approval of the Environmental Evaluation, PF(123) 109 form and the UnrevieWiid-Safiry-Question Evaluation, 10 CFR 50.59 Review, .pgjg PF(123) 109-1 form is the responsibility of the Cognizant Functional Division Managers (CFDM) or their designees. (Reference 2.2.1)

.1 All interdiscir- .- eviews shall be completed and comments incorpot. so and/or resolved prior to obtaining approvals for sne unreviewed safety question and environmental evaluation.

.2 The CFDM shall designate, in writing, the personnel within his organization authorized to complete anreviewed safety and environmental questions. Copies of such designations shall be kept on file with the originating organizations, and additional copies shall be forwarded to the Site Procedures Group (SPG)'and Corporate Documentation Management (CDM).

6.1.2 Formal training shall be made available by the Nuclear Training Division for all individuals completing the unreviewed safety question ana environmental evaluations.

6.1.3 The process for completing the unreviewed safety question and environmental evaluations for Proposed Facility Changes (PFCs) shall be in accordance with S01-V-3.11 for Unit 1 PFCs. initiated prior to January 14, 1983; and 50123-V-4.14 for Unit 1 PFCs initiated after January 14, 1983, and all Units 2 and 3 PFCs.

6.2 Unreviewed Safety Question Evaluation 6.2.1 Personnel completing the safety questions should familiarize themselves with applicable commitments contained in References 2.1.1, 2.1.2, and 2.3.1.

Compliance may be contacted to assist in identifying any licensing or NRC related commitments.

6.2.2 Guidelines for completing the Unreviewed Safety Question Evaluation are contained in Attachment 1 of this procedure.

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NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 ' REVISION 1 PAGE 4 0F 12 TCN l-l 6.0 PROCEDURE (Continued) j 6.2.3 The unreviewed safety question responses shall be j recorded on the PF(123) 109-1 form. The questions gp contained therein address whether-implementation of the document would pose an unreviewed safety question per 10 CFR 50.59.

.1 A proposed change, test, or experiment shall be deemed to. involve an unreviewed safety question per 10 CFR 50.59 if: ,

• The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety, previously evalua*.ed in the Final Safety Analysis Report, may Tc.tl be increased;

.or -

• Possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report may be created; gg or

• The margin of safety, as defined in the basis for any Technical Specification, is reduced.

6.2.4 If an unreviewed safety question is posed, the CFDM shall not approve the document until that unraviewed safety question is fully resolved. Resolution shall .

include NRC review, approval, and concurrence.

.1 The Nuclear Safety Group (NSG) shall assist in resolving T6N any unreviewed safety questions. The document shall be returned to the SPG for transmittal to the NSG, and to the Manager, Compliance '(for all documents).

O ADMINISTRATIVE PROCEDURE 50123-VI-1.3 NUCLEAR GENERATION SITE PAGE 5 0F 12 UNITS 1, 2 AND 3 REVISION 1 TCN l-l I

[ 6.0 PROCEDURE (Continued) 6.2.5 When an unreviewed safety question is not involved, responses to the safety questions must be accompanied by a justi * ~~* for making such a finding.

cxamples:

• This revision changes the distribution of the canary copy of form SO(123)-XXX, which

i. is administrative in nature and does not j

' affect the safety function of plant equipment.

l

• This procedure addresses the process for filling the Reactor Coolant System and is consistent with FSAR criteria and Technical l Specification requirements.

• This is a generic calibration test for FC l

Meter (s); the method for testing is ,with n acceptable engir.w.-ing criteria and limit .

6.3 Technical Specification Evaluation 6.3.1 Responsibility for addressing whether or not the document in question violates the provisions of any Techrtical Specification, is tha same as stated in Section 6.1 of this procedure.

1 If the provisions of the document under cuasideration violate the terms or requirements of ary Technical Specification, the CFDM shall not apprave the document until a Technical Specification chants which removes the conflict is approved by the Nuclear Tiegulatory Commission (NRC).

.2 The NSG shall assist in r9 solving conflicts. The document shall be returned to the SPG for transmittal to -gN the NSG; the Manager, Compliance (for all documents);

and the Manager, Nuclear Engineering Safety and Licersing.(NES&L).

6.3.2 The Tecnnical Specification number that the document implements and/or complies with may be entered in the Technical Specification (s) question section of the PF(123) 109-1 form. T6N i

I

• s NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE 50123-VI-1.3 REVISION 1 PAGE 6 0F 12 UNITS 1, 2 AND 3 TCN l- l  !

l 6.0 PROCEDURE (Continued) 6.4 Environmental Evaluation 6.4.1 Guidelines for completing the Environmental Evaluation are contained in Attachment 2 of this procedure.

.1 Responses shall be recorded in the appropriate section ,7gg of the PF(123) 109 form.

6.4.2 The originating organization shall determine if '

implementation of the document could directly or indirectly af;ect evolutions involving tne potential release of selids, liquids, or gasses containing flammable, tcaxic, radioactive, or other hazardous substances; and, if so, shall indicate routing of the document t's the Supervisor, Environmental Services.

6.4.3 Personnel completing and approving the Environmental Evaluation shoul.d familiarize themselves with References 2.1.1 and 2.1.2 as applicable, the Final Environmental Statement, and other Federal, State, and local requirements for environmental protection.

.1 If implementation of the document is likely to result in a condition which alters the impact of the station on the environment in a significantly unfavorable manner, the Supervisor, Environmental Services shall provide a written evaluation to the appropriate goverrment regulatory agency and obtain approval befora implementing the document.

7.0 RECORDS 7.1 A copy of each Site Document and its associated review forms shall be filed in CDM.

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ADMINISTRATIVE PROCEDURE S0123-VI-1,3 NUCLEAR GENERATION SITE UNITS 1, 2 AND 3 REVISION 1 PAGE 7 0F 12 l

ATTACHMENT 1 TCN l-l UNREVIEWE0 SAFE, Y QUESTION EVALUATION GUIDELINES 4

The following guidelines and examples are listed to aid the reviewer in determining if a document poses an unreviewed safety question per Reference 2.1.1.

I. Will there be an increase in the probabilicy of occurrence of an

! accident or malfunction of equipment importar.t to plant safety previously evaluated in the safety analysis report (FSAR)?

A. The response to this question shall be the result of considering the overall effects of the implementation of the document on the probability of occurrence of accidents as previously analyzed in the FSAR. This review shall be sufficiently detailed so that it is clear whether those accidents previously analyzed in the FSAR, which are in any way affected by implementing the document, are, cr are not, increasingly probable due to implementing the document under consideration.

B. Any conditions which could lead to an increased probability of an accident or equipment malfunction must be evaluated. Some examples of these would be: ,

1. Changes in equipment or systems which result in less conservative operating conditions,

a. Replacement of a piping section of Schedule 120 pipe with one of Schedule 1B0.

b. Replacement of a seismical?y qualified component with one having a lesser seismic qualification.

c. Changing acceptance criteria to less conservative requirements.

! d. Replacing fuses with fuses of a different rating.

e. Changing the minner in which radioactive waste is .

packaged, solidified, or transported,

f. Moving a safety-related component into a High Energy Line Break Zone of Influence, or a Flooded Volume.

2. Changes in Administrative procedures which could increase an event's probability. 4

a. Decreasing the frequency of surveillance intervals beyond those presently in use.

b. Changing valve lineups which prevent systems from performing as requi *ed.

c. Deleting "As Found" data recording requirements from a surveillance procedure.

N'VN N 9 3 'YN U Lf6# _ L _ _______ _ ___ _

s e NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 8 0F 12 ATTACHMENT 1 TCN- l-I UWREVIEWEC SAFETY QUESTION EVALUATION GUIDELINES I. (continued) = ._ _. -_

C. To assist in determining whether or not the probability of equipment malfunction is increased, compare the document under consideration to the original specifications detailed in the FSAR evaluation for the applicable component or system.

II. Will there be an increase in the consequences of an accident or '

malfunction of equipment important to plant safety previously evaluated in the Final Safety Analysis Report (FSAR)?

A. The response to this question shall be the result of considering those accidents analyzed in the FSAR which may in any way be affected by the document under consideration. This review shall be sufficiently detailed as to the scope of the FSAR analysis to demonstrate clearly whether that analysis bounds any and al'1 conditions created by the document under consideration. Accidents analyzed in the FSAR are presented in Sections 8 and 9 of,the Unit 1 FSAR (and all amendments) and Section 15 of the Units 2/3 FSAR.

B. Each FSAR evaluates certain types of accidents which may affect the plant. The analyses are conducted to cover the "worst case" of a particular accident. To ensure that the document under c.onsideration does not increase the consequences of an accident or equipment malfunction, determine which accidents are involved and if the provisions of the document under consideration fall inside or outside the worst case boundaries. Some examples which fall outside the worst case boundaries would be:

1. Increasing the allowable activity levels in the RCS which could result in increased offsite dose rates following a steam generator tube rupture.

2. Changing the flow rate or balance of flows through redundant injection flow paths. This could result in excessive loss of injection if a break were to occur in that line during an

- accident.

3. Increasing the torque requirements on a valve to reduce leakage. This could affect the stroke time of a valve and its ability to perform its intended function.

l Will there be created the possibility for an accident or malfunction of a l

l III.

l different type than any evaluated previously in the safety analysis report l (FSAR)?

A. The response to this question shall be the result of considering -

accidents not analyzed in the FSAR affected by the document under consideration.

ATTACHMENT 1 PAGE 2 0F 3

. NUCLEAR GENERATION SITE ,

ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 9 0F 12 ATTACHMENT 1 TCN 1-1 l

.UNREVIEWED SAFFTY QUESTION EVALUATION GUIDELINES III. (Continued) .., ,

B. 'If an evsnt has not been previously analyzed, it is gNerally because it has not been recognized as a problem. Past unreviewed items of this nature have usually been discovered after a change has been implemented, either as a result of a transient which results in an unanticipated response, or by an individual who recognizes its implications.

1. Small break LOCAs as evidenced at Three Mile Island. Although the small break LOCA was evaluated in the FSAR, its full '

implications were not recognized. Following THI, several operating changes were made in LOCA response procedures.

2. Steam generator overfill events. The steam generator high level trip was provided as a protective feature for the main

- turbine. It'has now been recognized that an overfill event could seriously affect other safety-related equipment such as

.the Steam Generator Safety Valves and the steam-driven Emergency Feedwater Pump.

3. After resetting the undervoltage starting and load shedding relays for the Emergency Diesel Generators, Millstone Unit II experienced an unreviewed transient the first time the diesel generators started to load following a loss of offsite power.

As each large load started, bus voltage dropped low enough to reinstitute load shedding with the result that the diesel

. generators were running ~at rated output but all Class IE loads

. had been shed. The only electrical loads that had power were those supplied by batteries.

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C. The types cf events outlined above are difficult to recognize. The best advice in this area is not to allow oneself to become confined by previous analyses and to use some imaginative research when this  ;

~

issue is being investigated.

IV. Will there be a reduction in the margin of safety as defined in the basis for any technical specifiution?

A. The bases for all portions of the Appendix A Technical Specifications sEall be considered. These include: Safety Limits and Limiting Safety S3 stem Settings (Safety Standards for Unit 1),

Limiting Conditions for Operation, Surveillance Requirements, Design Features, and Administrative Controls. For Unit 1 only, bases in Appendix B must also be considered.

0049f ATTACKhENT 1 PAGE 3 0F 3

4

. NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 10 0F 12 ATTACHMENT 2 TCN 1-l ENVIRONMENTAL EVALUATION GUIDELINES The following guidelines (both general and specific) are provided to assist the document reviewer in completing an Environmental Evaluation. A written review shall be prepared, if required, by the Site En,1ronmental Services Group.

I. General Guidelines The primary question to ask in conducting an environmental evaluation is:

"Could implementation of the document in review involve an Environmental Question?" .

A. In a practical sense, the reviewer is being asked to consider whether implementation of the document, or the activities, policies, modifications, etc., described in the document could adversely affect the environment.

1. One method which can be used to simplify this task is to employ the "pathway" approach. Virtually all unreviewed Environmental Questions will Impact the environment through one of three pathways:

a. Airborne

b. Waterborne

c. Solid Waste

2. An additional form of environmental impact is related to new construction or land use. The "pathway" approach can uften be successfully applied to this situation as well.

II. Specific Guidelines Specific questions to ask in establishing the existence of an Environmental Question, including examples of such situations, are as follows:

A. Will implementation of the document result in an increase in the probability of occurrence of an accident or malfunction of equipment important to Environmental Protection?

1. Response to this question sho%1d focus upon accident /

malfunction probabilities as they relate to existing Environmental Protection Equipment. Some examples are as follows:

a. Interruption of power sources, circuitry which feeds Environmental Protection Equipment such as Air Samplers, Oil Separators, Sewage Treatment Plant, and Discharge Stream Analyzers.

ATTACHMENT 2 PAGE 1 0F 3

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I NUCLEAR GENERATION SITE ADMINISTRATIVE >ROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISI0d 1 PAGE 11 0F 12 ATTACHMENT 2

TCN 1 -- (

l ENVIRONMENTAL EVALUATION GUIDELINES

1. (Continued)

b. Overload conditions affecting wastewater treatement

systems. Overload can be due to excessive flow volume j or excessive pollutants.

\ c. Installation of administrative loopholes which permit .

the unregulated release of untreated airborne, liquid, or solid waste.

4 B. Will implementation of the document result in an increase in the

' consequences of an accident or malfunction of equipment important to Environmental Protection?

1. Response to this question should focus upon the Environmental consequences of an accident or malfunction affecting equipment important to Environmental Protection. Some examples are as follows: V

a. Interruption of or interference with cutomatic sensors or surveillance equipment which would be used to sense an accidental release or aa out-of-limits condition.

This would typically involve Circulatirg Water Discharge Honitoring systems for temperature, chlorine, or other waste water monitors.

b. Redesign of plant drainage or storm water runoff systems, which could influence types and quantities of pollutants discharged.

c. Any modifications'to existing weste triatment systems such as sumpr, oil separators, and sewage treatment facilities.

C. Will implementation of the document create the possibility for an accident or malfunction not previously evaluated?

1. Response to this question requires the reviewer to apply a broad and profound understanding of the Environmental Impact Pathways as they relate to the Site. The most appropriate advice is to determine if an Environmental Pathway is involved, either directly or indirectly, and, if so, to request an Environmental Evaluatien be conducted by the Site Environmental Engineering Group. Some examples are as follows:

a. Installation and modification of facilities or equipment which generate airborne, liquid, or solid wastes.

b. Use of ch?micals, reagents, agents not previously used on Site.

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NUCLEAR GENERATION SITE ADMINISTRATIVE PROCEDURE S0123-VI-1.3 UNITS 1, 2 AND 3 REVISION 1 PAGE 12 0F 12

' ATTACHMENT 2 TCN 1-1 ,

ENVIRONMENTAL FVALVATION GUIDELINES D. Will implementation of the document result in a reduction of the margin of safety for protection of the environment?

1. Response to this question should be addressed to existing Environmental Protection Equipment and should consider the possibility of reducing the effectiveness of this equipment.

An example is as follows:

a. Adjustment of alarm setpoints on discharge stream mcnitors.

QQ49f ATTACHMENT 2 PAGE 3 0F 3

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$tte Document Title Anhuknvironmentaflines for Evaluation Cot:ipleting the Unreviewed Safety quesE I

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r. 0 Art /ttg OntstnArto: 3. t$$wt h1 $ M Sb ust MT) 4 $1mGLt u$t TCn cancels on (CDM U$t onLf)

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6. Chect aooropriate boat "1 Entire Cocument Attached l'_~,1 Af fected Page(s) Attuned m _(not apolicable

$vperseded/tacorporated 6 (s): Nano Cns) 0 No. (tr none. So state) a sG($$ gt

7. This change cannot wait untti the nest revision of the $tte Document and is required:

A. To isiplement f acility design one9e (PFC, not. TTM etc.) h7 r u m sy desi5 n chan,e identifier i indicat. n c. c . m etc. ideenrier SI7g e

gllE COPY is ie.eniacon of we f acmir deuen aan,e has seen deiereined. rt$

(If e, a TCn cannot be approved untti the f actitty design change has seen isolamenTW:T

g. X Other (e.g.. CAA Licensing Cosattments) Specific tesson: To undate the form references _

to current numbers, and to appropriately address the role of the Nuclear Safety Group (NSG).

tune re.orse side, ir requireel

8. Is the document being TCn'd QA Affectingt Yt$ 1 NO (IfVf$.comeletetheboxesbelow.)(IfNO.see*belou.)

(This 'es indicated on the f able of Contents page of thNite SIusent. If not todicated, treat as QA Af f uting.)

Does thle change arrut FsAR or run. spec comunf tmentsi 7th WY 1 A.

B. Doet this change affect the nonraetological environment of any oTTITie area previously undisturbed no during site preoaration and plant constructiont rt!

no Is the intent of the original du ument altered? Yt1 C.

Is the document to be panged an Ensegency Orerating Instructionf no X l D.

Does this cha*ge pose an unrevtewed saf ety evestion per 30 r74 50.$g i.e.'."Es it increase the I

t. i protability of occurrence or the consequences of an auident; create the possibility of t, different l Mcidants Jr reduce the fee. Spec. margin o' safetyi YtS no V 1 I (Ir TNE hnSetA TO A, 8. C. O or t 15 ffE A TCMS not Actncalzt0.) I

'l Oces this charge affect Itcensing commitment recuiregentst Yd _ n0 _,X, i

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10. Coop forwarded to the uvetear Safety Grovo. Pt1 FORM 3 87: /7./A/ _ Cate:

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(502/3 6 123 QA Affuting TCes only)

11. The entire doceent was reviewed in conjunction wit'. this TCn. N /A attltvt0 Ade AP*tovfA eve _ . , _ , , N /_A CHR or Destgnee este 12,' $IGAATW E$ etCUIRt0!

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• units zu r cete l \)FTaTt nanagement starr . unit y I t l

I could this TCn affut or does it reoresent a pange to a plant could thisperetton a plan TCn af f ut in or does it represent progresst Yt1

• a change MO Ety I operation in o sst $m . N0 t/

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- if a ex-t is .e eA iffnun, o.iain ininai ao.ro.ai f, we Co,nani 5.oervi.or(s) oa to C:.. the. oafne,fected si a n .,e,Unit,(s) (signs on P14pt inanagtsent $taf f lint (s)) and final approv 4,e ,e,,1,ed.

" If CA affecting, approvat shall be by two morters of the Plant Managewat n $taff knowledgeable in the areas (For 7Cn approval.

af futed at least one of w aon holds an $40 Licease on the wait or u its affuted.

the Plant manageg nt $taff are defined as the sweervisor in charge of the satft. or as designated in writing by the Cf 0M. esertising responsibility in the specific area and u fnt(s) addressed ay tne change.)

• If It,,$. the $nift $woerinteadent shall provide the reevired $A0 approval.

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