The licensee procedure Nuclear System Directive (NSD): 209
10 CFR 50.59 Process, committed to using
Nuclear Energy Institute (NEI) 96-07, Guidelines for
10 CFR 50.59 Implementation.The guidance in
Nuclear Energy Institute (NEI) 96-07 Section 4.3.2, specified that if a change in likelihood of occurrence of a malfunction increases by more than a factor of two would need NRC approval, because certain changes that satisfy the factor of two limit exceed the minimal increase standard for accident/transient frequency under criterion
10 CFR 50.59(c)(2)(i). The guidance in
NEI 96-07 Section 4.3.8, specified that the use of new or different methods of evaluation that are not approved by NRC for the intended application, such as the methods identified in the memo to File, ME Patrick (PJ North), dated 1/12/92, Single Failure Timing Licensing Basis, no file number given. (Note: Memo was actually written 1/12/93), would need NRC approval, because it was considered a departure from a method of evaluation described in the
UFSAR. Based on this guidance, the team determined that the modifications associated with engineering changes (ECs),
EC91880, Keowee Emergency Start Cable, revision 24 and
EC91875, Keowee
AC Power Supply Tie-Ins, revision 15, and
EC91874, 13.8 KV Feed To PSW System from 100 KV
APS, revision 7 would require NRC approval in accordance with
10 CFR 50.59(c)(2)Corrective Actions: TBDCorrective Action References:
TBD