Applications for License Amendments (Generic Letter No. 86-03)

                               UNITED STATES 
                          WASHINGTON, D. C. 20555 

                             February 10, 1986




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 

As stated



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. 


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 

     (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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