ML20207D932
| ML20207D932 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/10/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207D928 | List: |
| References | |
| NUDOCS 8808160225 | |
| Download: ML20207D932 (3) | |
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,/ 4 SAFETY EVAL _U_ATIO_N_,BY THE OFFICE OF NUCLEAR REACT _0R REGULATION
_RELATED TO ANENDMENT NO.125 TO PROVISIO_NA_L OPERA _T_ING LICENSE N0. DPR-16 GPU NUCLEAR CORPORATION AND JERSEN7RADMR & LIGliTMPANY OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50d p 1.0 INTRUDUCTION By letter dated May 26, 1988, GPU Nuclear Corporation (GPUN) requested a revision to the Technical Specifications (TSs) for Oyster Creek Nuclear Generating Station.
The TS change would revise various areas in Section 6 (Administrative Controls) forclarityandconsistencywithGEStandardTechnicalSpecifications(NUREG-0173 Revision 3) insofar as the safety review process for new and revised procedures, modifications to unit structures, systems and components and for proposed test and experirents is concerned.
The change would also add a definition to Section 1 of the TSs for substantive changes to these activities.
2.0 EVALUATION Licensees are allowed by 10 CFR 50.59 to make changes in their facility (structures, systems and components) and procedures as described in the safety analysis report and to conduct tests and experiments not described in the safety analysis report without prior Conwission approval as long as the change, test or experirrent does not involve a TS change or an unreviewed safety question.
This regulation also provides criteria for judging whether or not an unreviewed safety question might be involved in a proposed change, test or experiment.
In order to assure appropriate provisions for compliance with 10 CFR 50.59 Section 6.5 of the TSs for most nuclear power plants lists specific requirenwnts for technical review and audit of certain procedures and procedure changes (including those pertaining to tests and experiments) and of facility modifi-cations. GPUN procedure 1000-ADM-1291.01 implements the safety review require-ments of section 6.5 of the Oyster Creek TSs. On September 1,1986, CPUN imple-mented a significant revision of this procedure which established a two-step process for review of procedure changes, facility modifications, tests and experiments. The first step of the process is to determine applicability of 10 CFR 50.59 to the contemplated action.
Step two of the process is to provide a written safety eva'uation of why the contemplated action does or does not involve a change to Oe TSs or an unreviewed safety question.
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. The existence of the words "important to safety" in the current TSs for Oyster Creek have caused some confusion with respect to review of procedure changes and modifications. This confusion apparently stems in part from the industry wide issue with the NPC's use and definition of the terms "important to safety" and "safety related" as discussed in detail in NRC Generic Letter No. 84-01 dated Janua ry 5,1984. To eliminate this confusion and to upgrade the Oyster Creek TSs terminology to be consistent with NUREG 0123 "Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/s) Rev. ?,"
GPUN has proposed the tenn "affecting nuclear safety" as a substitute for "important to safety" in several places throughout Section 6.5.
Furthermore, GPUN has requested placing a definition for the word "substantive" in the TS (Section 1.40) and adding the word to Sections 6.5.1,1 and 6.8.2 to make it clear that minor changes not affecting the function, meaning, or intent of a document need not undergo the formal review process intended for sustantive changes. GPUN's concern is that if the fonnal review process is literally applied to all changes, including corrections of typgraphical errors and editforf al improvenents, the number of such reviews will become overwhelming and the substantive changes may not get the proper level of detail in their review.
Philosophically the staff agrees with this distinction as long as the individuals exercising these judgements are adequately trained and objective.
The staff met with GPUN on April 15, 1988 to discuss, in detail, implementation of the safety review process and GPUN Procedure 1000-ADM-1291.01 at Oyster Creek and TMI-1. The staff concluded that with a minor modification to the procedure, the method used by GPUN will provide acceptable results.
The specific TS changes addressed by this Safety Evaluation are as follows:
l 1.40 Provides addition of a definition of substantive changes to docunents.
6.5.1.1 Replaces "important to safety" with "which affect nuclear safety" as applied to which procedures require preparation and review by a designated individual or group. Replaces "important to safety" with "substantive" in specifying to which procedures changes this section applies.
6.5.1.3 Replaces "important to safety" with "that affect nuclear safety" in conjunction with modifications to unit structures, systems and components and clarifies that those words apply to the proposed modification and not to the structures, system or component themselves.
6.5.1.4 Peplaces "important to safety" with "that affect nuclear safety" in conjunction with tests and experiments.
6.8.2 Replaces "important to safety" with "substantive" in conjunction with review of procedures required by Section 6.8.1.
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3.0 ENVIRONMENTAL CONSIDERATION
This amendment changes administrative procedures and requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environter.tal assessment need be prepared in connection with the issuance of this amendnent.
4.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's 1
regulations, and the issuance of the amendment will not be inimical to the common defense and security nor to the health and safety of the public.
Dated: August 10, 1988 Principal Contributor:
Alexander W. Dromerick l
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