General Design Criteria

GDC are design requirements.

Relationship between GDC and TS

from: ML12115A279

As the DPO panel that reviewed this matter noted, the GDC and technical specifications differ 1n that the GDC generally set forth requirements for design of nuclear power reactors; whereas, technical specifications generally relate to requirements for operation of nuclear power reactors. The ability to comply with both sets of requirements, the GDC and technical specifi cations, 1s required for the finding under 10 CFR 50.57 that "(t)he facility will operate 1n conformity with...the regulations of the Commission." Although the design criteria of the GDC and the operation requirements of the technical specifications are related, as discussed below, It 1s not a one-toone correspondence. • ,v ...

The GDC (10 CFR Part 50, Appendix A) "establish the necessary design, -{ fabrication, construction, testing, and performance requirements for , '. structures, systems, and components [SSCs] Important to safety." .'ThusV a broad spectrum of SSCs Important to safety Is covered by the GDC^ Not all the GDC, however, are directly reflected 1n the technical specifications. ]The GDC are reflected 1n the plant design as documented 1n the FSAR. The analyses 1n the FSAR and the staff safety evaluation form the bases from which the . technical specifications are to be derived. Although a variety of features must be Included in the design of a nuclear power reactor, only those aspects of the design and plant conditions that are required to assure adequate protection to the health and safety of the public; need be controlled by the technical specifications required by.lO CFR 50.36. :;• Technical specifications are to be "derived from the analyses and evaluation Included 1n the safety analysis report." They do not cover every aspect of kvthe design but rather, they establish, among other things, limiting conditions for operation which are "the lowest functional capability or performance:^ : levels of equipment required for safe operation of the Yacility."^The^^o' - Commission provided guidance 1n the Policy Statement on Technical ^^^^^v Specification Improvements (52 FR 3788) and the recently approved final }- statement. This provides guidance on Identifying SSCs and plant conditions of controlling Importance to safety which are to be included in technical a ^ specifications. These technical specification requirements recognize, - - however, that even for those design features and plant conditions that require close regulatory control, there are varying degrees of safety importance. Thus, In most cases, whenever a limiting condition for operation is not satisfied, remedial action, rather than a plant shutdown, is usually v: appropriate and specified. The allowed outage times associated with the remedial actions generally vary with safety .importance.-.;^'§sf^:'y'^^ Section 182 of the Atomic Energy Act as Implemented by 10 CFR 50.36 requires* that those design features of the facility which, if altered or modified, would have a significant effect on safety be Included in technical^- - • ' specifications. Pursuant to 10 CFR 50.59 specific aspects of those SSCs that are described in the FSAR may be changed by the licensee without prior NRC approval unless the changes are unreviewed safety questions or a change in the technical specifications.

Changes to the facility at a level of detail below that covered in the FSAR are not restricted by Commission regulations, provided that such changes.do not result in changes to the FSAR and do not also have the effect of resulting in noncompliance with Commission regulations, orders, or license conditions. However, certain such changes are controlled by the design control process of the QA program required by 10 CFR Part 50 Appendix B. Changes to systems, components, or procedures described in the FSAR are * allowed pursuant to 10 CFR 50.59 provided such changes do not introduce * accidents or malfunctions not previously evaluated, do not increase the: probability or consequences of accidents previously evaluated, and do not decrease margins of safety defined 1n the basis of any technical specifi cation. The staff believes that the tests of 10 CFR 50.59 could not be, satisfied 1f compliance with a GDC, as reflected in the FSAR and staff safety evaluation, were violated by a proposed change.