ML20196A234

Concludes That Based on Licensee Annual Rept of Facility, Changes,Tests & Experiments & 880608 Site Visit, Changes,Tests & Experiments Meet Criteria in 10CFR50.59. Lists Improvements Recommended to Licensee During Visit

ML20196A234
Person / Time
Site:	Beaver Valley
Issue date:	06/20/1988
From:	Tam P Office of Nuclear Reactor Regulation
To:	Stolz J Office of Nuclear Reactor Regulation
References
TAC-62935, TAC-63996, TAC-64577, TAC-66674, TAC-67922, NUDOCS 8806290493
Download: ML20196A234 (8)

Text

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, jog UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION Q :E WASHINGTON, D C. 20555

\+.../ Juae 20,1988 Docket No. 50-412 I

l MEMORANDUM FOR: John F. Stolz, Director Project Directorate I-4 l

Division of Reactor Projects I/II I

~

FROM: Peter S. Tam, Project Manager Project Directorate I-4 Division of Reactor Projects I/II

SUBJECT:

COMPLETION OF REVIEW 0F THE 1987 BEAVER VALLEY UNIT P, 10 CFR 50.59 REPORT AND INSPECTION OF 10 CFR 50.59 PROCEDURES AT THE SITE (TAC N0. 67922)

By letter dated April 8,1987, the licensee subniitted the Annual Report of Facility Changes, tests and Experiments, in accordance with 10 CFR 50.59. I reviewed that i report following the guidance of Section 3.4.4. of draft Revision 1 of the Project i Manager's Handbcok (memorandum, S. Yarga to D. Crutchfield, et al., dated May 19, 1988). In addition, in order to gain an understar. ding of the licensee's procedure for 10 CFR 50.59 modifications, I obtained additional infomation at the site on June 8, 1988. Enclosure 3 lists the persons I held discussions with during ny visit.

The licensee's Site Adninistrative Procedures (SAP) assure that each facility modification, test or experiment has been reviewed against the requirements of 10 CFR 50.59 by the Onsite Safety Coninittee. Enclosure 2, consisting of three pages extracted from the SAP, provides details and is self-explanatory. All licensee personnel that may have anything to do with plant nodifications are being given a three-hour training course by the licensee on this regulation and its application.

Based on the licensee's report, and the facts I obtained onsite, I conclude that there is reasonable assurance that the changes, tests and experiments meet criteria in 10 CFR 50.59. Further1nore, a number of these changes have been or are still being addressed by licensing actions; details may be obtained by accessing the TAC files listed in Enclosure 1. No new licensing actions need be opened as a result of the licensee's report.

While on site, I suggested to licensee personnel to effect the following improvenents to future 10 CFR 50.59 reports:

8806290493 880620 PDR ADOCK0500g12

(1) Maintain the current level of detail but clearly state what systeni/ component each change pertains te. The current report is rather cryptic on son.e items.

(2) The licensee should encourage i;s personnel to consult with the NRC staff through the project manager, whenever there is the slightest doubt regarding the classification of a change. The licensee should document such consulta-tion, by a letter following the consultation, and in the 10 CFR 50.59 report, giving names of individuals and dates.

(3) When reviewing a proposed ch'ange against commitments made in the FSAR or UFSAR, the licensae should be careful as to which document contains the current licensing basis. Licensing of a plant is a living and ongoing process and therefore, both the original FSAR and UFSAR should be consulted to.deterniine if there is a change in consitrrent.

(4) The report should be nore succinct in describing the reasons for a change.

The current report often uses words that did not convey nessages such as "correction of an error" or "improving the design" even though such were indeed the reascns for the changes.

This conpletes TAC 67922, "Review of 1987 Report of 10 CFR 50.59 Changes for Beaver Valley Unit 2."

/ 4 ch Pe'te'f Tam, roject Manager Project Directorate I-4 Division of Reactor Projects I/II

Enclosures:

As stated L

e (1) MSintain the current icvel of detail but clearly state what system / component each change pertains to. The current report is rather cryptic on sone items.

(2) The licensee should encourage its personnel to consult with the NRC. staff through the project manager, whenever there is the slightest doubt regarding the classification of a change. The licensee'should docurrent such consulta-tion, by a letter following the consultation, and in the 10 CFR 50.59 report, giving narres of individuals and dates.

(3) When reviewing a proposed change against committ..ents made in the FSAR or UFSAR, the licensee should be careful as to which document contains the current licensing basis. Licensing of a plant is a living and ongoing process and therefore, both the original FSAR and UFSAR should be consulted to determine if there is a change in coninitment.

(4) The report should be trore succinct in describing the reasons for a change.

The current report often uses words that did not convey tressages such as "correction of an error" or "improving the design" even though such were indeed the reasons for the changes.

This cortpletes TAC 67922, "Review of 1987 Report of 10 CFR 50.59 Changes for Beaver Valley Unit 2."

original signed by

' Peter S. Tam, Project Manager Project Directorate I-4 Division of Reactor Projects I/?I

Enclosures:

As stated

. DIS _TR_I 8UTION NDocket Filer J. Beal, Sr. Resident Inspector i NRC & Local PORs L. Tripp PDI-4 Rdg. P. Tam l S. Varga S. Norris i B. Boger l

LA:PDI-4 PM:PDI- D:PD 4  !

SNorris PTam:bd 3 JSto I 06/ /88 06/20/8 06/go/88

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.- Enclosure 1 l

Beaver Valle LUnit 2 1987 10 CFR 50.59 Report

'" ' Nb'ss E fe reIIEE 'th'll c e n s i ng_ A c t i o n s Cha,na,e_No. and Description NRC TAC NO. STATUS 25-0, fire damper and CO 62935 Completed, 2

system changes License Condition C(10) 69-1, addition of backdraft , 62935 Completed, dampers License Condition C(10) 170-0, primary process racks /PSMS 64577 Ongoing 177-0, PSMS plasma dispicy console 64577 Ongoing p.59, Offsite Dose Calculation 66674 Ongoing l Manual (0DCM) 63996 l p.61, ODCM 63996 Ongoing p.66, Control rod drop time Complete, measurement test License Condition C(3) 1 l

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i Enclosure 2

. ' Nuclear Group - Site Administrative Procedures Chapter 10 FIGURE 3 l REVIEW PROCESS 6.5.1.6.e 6.5.1.6.d. f.5.6.5.1.6.b.e.s,h T.S.6.5.1.6.a Tech Spec factity Change 1. Test or Esperiments 3. Operetton Pretened Frecedure Change Regnest '

or Ndification 2. T.S. Violations Asst. a) pew t

4. Special b) Revistens with Iteviews latent Changes t) feeperary Changes (T.S.( . 8. 3) 8, Prepare er Plant Neager Preparer ovaluate I'8

[f fect 4.5. or 10 Cyt $0.59

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No OSC COMMITTEE REY! ENS

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' Yes Prepare or evaluate I to OSC Change Frasentation 3 A ny Foru Iselecent No W.59  : ,

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( ($tt) l I App Yes (concur) e No to A))

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t W Flant Nnager Yes / Unreview \ No I Ap9 /Disa pp Dis approval

! Safety Questions Reccesunded or k i Approval /

\ / 8 Disapproval T.S. Change  ;  : cisapp fes \ j ,,

Tabled i ,,

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r Page* 17- of 21 Revision 8

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Nuclsar Group - Site Administrativa Procsduras Chiptar 10 (EXAMPLE)

DA7E: OSC CHANC3 PRESENTATION FORM Attachment . .

. Subject or Procedure No. : . Issue _

, Revision TITLE: *

(

Reason and/or Description of Change (Include references, if applicable)

NOTE: Record OSC meeting if change was previously tabled.

( .

1 Preparer / Reviewer Checklist Circle One

1. Site Facilities are changed temporarily / permanently and evaluated: YES NO

a. Adverse hazards are created outside their qpalification profile. YES NO

b. Radwaste system is involved (refer to IEC 80-18).  ! YES NO

c. Environmental qualifications of equipment or plant are af feched. YES NO

d. System, structure or component performance is changed. '

YES, NO

2. A procedure described in the UFSAR is changed; such as: , YES NO

a. Referenced documents that e- a commitment to an inspection, surveillance or operating reqairement are af fected. YES NO

b. System, structure or component performance is changed. YES , NO

3. Test or experiment not in the UFSAR is involvedi such as: YES NO

a. Outside of Technical Specification surveillance compliance. YES NO

b. Reduces adequacy of UFSAR equipment to prevent accident or i mitigate consequences of an accident. YES NO l

c. System, structure or component performance is changed. YES NO j

4. A change to the Tech. Spec. is required and Licensing notified. YES NO l If any answer to items 1, 2, or 3 is answered "Yes", a safety evaluation is required.

Re f e r t o SAP 10.

The above change (s) meets or exceeds the original intent or design requirement. Both the probability of previously analyzed accidents and the consequences of such accidents are unchanged.

BECAUSE:

Prepared By: Reviewed By:

• • • • • • • • • • • • • • • • • • • • • • • • t.eeee;;eeeae*******************************************************

OSC Comments: ((] Recommended Approval, No Unreviewed Safety Questions Exist

([] Recommended Disapproval ((] Tabled ([} Concurred with Above Statements Requires Review.and Approval by ORC and NRC [] Additional OSC Comments attached

( BV -0SC- -

OSC Chairman .

. Meeting No.

FIGURE 1 Page 15 of 21 Revision 8

i Nuclser Group - Site Administrativa Procsdursa Chtptar 10

. (EXAMPLE) Attachment . .

Nuc1, ear Group - Site Administrative Procedures SAFETY EVALUATION (10 CFR 50.59) FOR CRANGES, TESTS OR EXPERIMENTS

( )

Subject:

1. Will the probability of an accident previously evaluated in the Safety Analysis YES NO Report be increased?

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2. Will the consequences of an accident previously evaluated in the Safety Analysis YES NO Report be increased?

3. Will the probability of 8 malfunction of equipment important to safety be YES 'C N

increased?

4. Will the consequences of a malfunction of equipment important to safety be YES NC increased? __

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5. Will ths.- possibility of an accident of a dif ferent type than any previously YES N(

analyzed in the Safety Analysis report be created? /'

(

6. Will the possibility of a malfunction of a dif ferent type than any previously YES Ni l evaluated in the Safety Analysis Report be created?

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7. Will the margin of safety as defined in the basis for any Technical Specification YES N bs reduced?

If any of the above questions.are answered "YES" an Unreviewed Safety Question is involved and the change may not be made without NRC concurrence.

Prepared By Date Reviewed By Date OSC Concurred: OSC Chairman /Date /BV' -0SC- -

NOTE: If applicable, the specific section of the update FSAR or Tech. Spec down to at' least g one decimal plac'e should be referenced and the criteria or reasons for the decision \

documented.

. . FIGURE 2 Page 16 of 21 Revision 8

. 1 N I 0

Enclosure 3-Persons Contacted Regarding 10 CFR 50.59

~Pr5ci3ures at Beiver Ville[P5EFPlihI ____________

l G. Be6ty A. Lerczak

.K. McMullen

. -R. Roth J. Spiegel I

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