Applications for License Amendments (Generic Letter No. 86-03)
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
February 10, 1986
TO ALL LICENSEES OF OPERATING REACTORS AND APPLICANTS FOR AN OPERATING
LICENSE
Gentlemen:
SUBJECT: APPLICATIONS FOR LICENSE AMENDMENTS (Generic Letter 86-03)
During the past year, I have evaluated the difficulties in providing timely
notices in the Federal Register regarding license amendments proposed for
issuance. One of the reasons for these difficulties is that too often the
information called for by 10 CFR 50.91(a)(1) regarding an analysis of no
significant hazards consideration using the standards of 10 CFR 50.92 is not
provided with the amendment request.
The enclosed discussion is for your information and guidance. Its purpose is
to reduce delays in processing Federal Notices regarding license amendment
requests. Included with the discussion is an example of a submittal which
the staff found to contain an adequate analysis of the no significant
hazards consideration.
You are requested to ensure that all future amendment requests contain
sufficient documentation to specifically address each factor under 10 CFR
50.92(d). An adequate submittal would include a detailed basis sufficiently
comprehensive on the issue of no significant hazards consideration to permit
the staff to file a timely Federal Register Notice. The staff's objective is
to have most routine Federal Register Notices published within 20 working
days of receipt of a license amendment request.
In the event that the staff is unable to find that an adequate basis to
support a finding regarding no significant hazards consideration has been
provided, I have directed the Project Director to return the application so
that the necessary information can be included. This will also highlight to
utility management any significant problem the staff is experiencing with
your amendment requests. Any such determination will be made by the staff
within six working days of receipt. Your Project Manager will promptly
notify you and return the amendment request accordingly.
No specific response to this letter is required. Please contact your Project
Manager if you have any questions.
Harold R. Denton, Director
Office of Nuclear Reactor Regulation
Enclosure:
As stated
ENCLOSURE
RECENT PROBLEMS WITH LICENSE AMENDMENT REQUESTS
10 CFR 50.91(a)(1) requires that licensees requesting an amendment provide
an analysis "using the standards in 50.92" (the 3 factor test) about the
issue of no significant hazards considerations (NSHC). Staff final
determinations must also use the 3 factor test of 50.92. Proposed staff
determinations may use the examples of actions which are "likely" or "not
likely" to involve significant hazards considerations. These examples were
provided in Enclosure 1 to Generic Letter 83-19.
The basic problem with many recent license amendment requests is that the
licensee does not provide an analysis using the 3 factor test. Often, all
the licensee provides is a simple line assertion, copying the 3 factors, but
offering no analysis. In many cases the safety assessment is brief or
lacking in content such that the reader cannot conclude that the basis for
the NSHC determination is in fact adequately provided in the description or
in the safety assessment section. In other cases the safety assessment is
written so that the reader cannot determine which part of the assessment
applies to which of the three factors. A simple assertion that references an
entire, fairly complex safety assessment as justification for satisfying the
three factor test is not considered satisfactory. To expedite processing of
your application, each of the three factors should be addressed separately
for each part of the license amendment request. An assertion without
appropriate analysis does not satisfy 10 CFR 50.91(a)(1).
While a licensee may offer an opinion to be helpful to the staff on which
example is appropriate, that is not sufficient to satisfy 50.91(a)(1) -- a
licensee is not merely to suggest that it is "likely" or "unlikely" that a
proposed amendment involves a significant hazards consideration -- the
licensee is required to give an analysis in terms of the 3 factors. The
licensee should not need examples of what is "likely" or "unlikely"; the
licensee must complete a safety evaluation before submitting the proposed
amendment. Thus, the licensee should know on the basis of the completed
technical evaluation whether the proposed amendment increases the
probability or consequences of an accident previously evaluated, creates the
possibility of a new accident or reduces a safety margin. On this basis, the
licensee should be able to articulate clearly the specific reasons as to
whether the change is significant.
Attached is an example of a submittal which the staff found to meet the
above criteria.
ATTACHMENT 1
Description of amendment request:
The proposed amendment would modify Technical Specification 2.2.2, "Core
Protection Calculator Addressable Constants"; Table 2.2-2, which provides a
listing of the Type I and Type II Addressable Constants; and the associated
Bases. The proposed amendment would also revise the appropriate page of the
Index, delete the reference to Table 2.2-2 from Notation (9) and delete
Notation (10) of Table 4.3-1, and delete the note in Administrative Control
6.8.1 (g).
The addressable constants of the Core Protection Calculators (CPC) provide a
mechanism to incorporate reload dependent parameters and calibration
constants to the CPC software so that the CPC core model is maintained
current with changing core configurations and operating characteristics. As
a method to avoid gross errors upon operator entry of an addressable
constant, a reasonability check requirement was imposed by the original NRC
CPC Review Task Force. The CPC software has been designed with automatic
acceptable input checks against limits that are specified by the CPC
functional design specifications. Therefore, inclusion of the addressable
constants and the software limit values in the Technical Specifications
(2.2.2 and Table 2.2-2) is redundant, and serves only to enforce prior
approval of changes to these limits. Proper administrative control
procedures are available to assure that appropriate values of addressable
constants are entered by the operator. Any CPC software changes involving
addressable constants or software limit values are made and tested under NRC
approved software change procedures and are available for NRC review.
BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION:
The proposed change does not involve a significant hazards consideration
because operation of Arkansas Nuclear One Unit 2 in accordance with this
change would not:
(1) involve a significant increase in the probability or consequences
an accident previously evaluated. This change merely eliminates
redundant administrative requirements concerning the CPC
addressable constants. The function of these requirements is
already implemented by the allowable value checks in the CPC
software. Changes to the addressable constants are accomplished
through strict administrative procedures. Therefore, this change
cannot increase the probability or consequences of an accident.
(2) create the possibility of a new or different kind of accident from
any previously analyzed. It has been determined that a new or
different kind of accident will not be possible due to this
change. This elimination of redundant administrative requirements
does not create the possibility of a new or different kind of
accident.
(3) involve a significant reduction in a margin of safety.
Administrative procedures involving the CPC addressable constants
ensure that the CPC core model is calibrated to current plant
conditions and therefore preserve the margin of safety.
Elimination of redundant administrative requirements will not
reduce the margin of safety.
.
The Commission has provided guidance concerning the application of the
standards for determining whether a significant hazards consideration exists
by providing certain examples (48 FR 14870) of amendments that are
considered not likely to involve significant hazards consideration. Example
(i) relates to a purely administrative change to Technical Specifications:
for example, a change to achieve consistency throughout the Technical
Specifications, correction of an error, or a change in nomenclature. Example
(iv) relates to a relief granted upon demonstration of acceptable operation
from an operating restriction that was imposed because acceptable operation
was not yet demonstrated. This assumes that the operating restriction and
the criteria to be applied to a request for relief have been established in
a prior review and that it is justified in a satisfactory way that the
criteria have been met.
In this case, the proposed change described above is similar to both Example
(i) and Example (iv) in that deletion of Technical Specification 2.2.2,
Table 2.2-2 and modifications to the related pages are purely administrative
changes, and are also relief granted upon demonstration of acceptable
operation from an operating restriction that was imposed because acceptable
operation was not yet demonstrated.
Conceptually, the addressable constants reasonability checks are the
equivalent of the limits of an adjustable potentiometer in the conventional
analog hard-wired type protection system. The limits of these potentiometers
are not specified in the Technical Specifications, as this would be
unrealistic and would make no contribution to plant safety. The addressable
constants are basically calibration constants which are used to assure that
the CPC calculations of core parameters accurately reflect actual plant
conditions. The proposed change may therefore be considered to achieve
consistency throughout the Technical Specifications in that it removes a
listing of calibration constants which is redundant in purpose and is not
provided for any other system.
Removal of the listing of the addressable constants (and the allowable
ranges of the Type I constants) may be considered a relief from an operating
restriction that was imposed by the NRC CPC Review Task Force because
acceptable operation was not yet demonstrated. ANO-2 was the first CE plant
equipped with the CPC system; the addressable constants Technical
Specification was imposed because this system was the first application of a
digital computer based portion of a reactor protection system. Subsequent
operational experience with the CPC system, both at ANO-2 and the other CPC
equipped plants, has demonstrated acceptable operation. Relief from this
administrative restriction has been allowed after several meetings between
the utilities with CPC equipped plants and the NRC Core Performance Branch,
which included members of the CPC Review Task Force. The criteria applied to
the relief from this operating restriction have been established and there
is satisfactory justification that they have been met. The NRC Core
Performance Branch have issued a draft Safety Evaluation Report (concerning
the removal of the addressable constants Technical Specification) which
provides this justification.
Therefore, based on the above considerations, AP&L has determined that this
change does not involve a significant hazards consideration.
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