ML16223A408

Policy Statement on Technical Specifications Improvements for Nuclear Power Plants

ML16223A408
Person / Time
Issue date:	06/18/1993
From:	Wilkins J Advisory Committee on Reactor Safeguards
To:	Selin I NRC/Chairman
References
D930618
Download: ML16223A408 (2)

Text

D930618 The Honorable Ivan Selin Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

POLICY STATEMENT ON TECHNICAL SPECIFICATIONS IMPROVEMENTS FOR NUCLEAR POWER PLANTS During the 398th meeting of the Advisory Committee on Reactor Safeguards, June 10-11, 1993, we reviewed the NRC staff's draft Final Policy Statement on Technical Specifications Improvements for Nuclear Power Plants, as originally presented in SECY-93-067. We also reviewed a revised draft of this Policy Statement which is responsive to the Commission's comments included in the Staff Requirements Memorandum dated May 25, 1993. During our meeting, we had the benefit of discussions with representatives of the NRC staff. We also had the benefit of the documents referenced.

In SECY-93-067, the staff recommended that the draft Final Policy Statement be published for a 90-day public comment period.

However, the Commission approved publication of the Policy Statement in final form, subject to the following comments:

1. The Commission directed the staff to prepare a rulemaking package that would codify the four criteria contained in SECY-93-067, delineating those aspects of nuclear power plant design and operation that should be included in Technical Specifications. (We note that the staff has proposed the use of these same criteria for establishing plant systems and components requiring an "effective program" under the license renewal rule.) The Commission also directed the staff, in developing the proposed rule, to ensure that the voluntary nature of the improved Standard Technical Specification program be preserved and that the Federal Register notice indicate that public comments on the proposed rule will be welcomed, considered, and addressed during preparation of the final rule. The staff was also directed to prepare any regulatory guides needed to implement this rule.

We agree with the above actions by the Commission and believe that the staff has appropriately modified the Policy Statement in response to the Commission's comments. The staff, of course, needs to proceed with the other matters covered by these comments.

2. The Commission also directed the staff to modify the Policy Statement to clarify how it intends to utilize probabilistic risk assessments (PRAs) in its review of Technical Specifica-tion change requests involving Criterion 4 ý "A structure, system, or component which operating experience or probabilis-tic safety assessment [PRA] has shown to be significant to public health and safety." The Commission apparently has no

problem with this criterion, but believes that if the results of a PRA indicate that Technical Specifications can be relaxed or removed, a deterministic review should be performed. If the results of the deterministic review also support relaxing or removing the Technical Specifications, the staff should not preclude such action.

We agree with the view expressed by the Commission on this issue. The staff believes that it has responded to the Commission's comment in the modified Policy Statement by clarifying how it intends to utilize PRA in its review of Technical Specification change requests. We believe that the staff needs to provide more detailed guidance on the defini-tion of "significant to public health and safety." This additional guidance should probably appear in the implementing regulatory guide(s).

This problem with Criterion 4 also exists in a number of recent staff initiatives (obvious examples are structures, systems, and components to be covered by the Maintenance Rule and the staff's reluctance to define "vulnerabilities" with respect to the Individual Plant Examination program).

Many problems related to the use of PRA by the NRC staff were described in our May 20, 1993 letter concerning the "Draft Report of the PRA Working Group." The issue raised in the present report is in the same class.

Sincerely, J. Ernest Wilkins, Jr.

Chairman

References:

1. SECY-93-067 dated March 17, 1993, for the Commissioners from James M. Taylor, Executive Director for Operations, NRC,

Subject:

Final Policy Statement on Technical Specifications Improvements

2. Memorandum dated June 3, 1993, from Brian K. Grimes, Office of Nuclear Reactor Regulation, for John T. Larkins, ACRS,

Subject:

Request for ACRS Review of Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors

3. Staff Requirements Memorandum dated May 25, 1993, from Samuel J. Chilk, Secretary, for James M. Taylor, Executive Director for Operations, NRC,

Subject:

SECY-93-067 - Final Policy Statement on Technical Specifications Improvements