ML19322C661
| ML19322C661 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/18/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| TASK-TF, TASK-TMR SECY-79-395, NUDOCS 8001180286 | |
| Download: ML19322C661 (7) | |
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U N 47 *..C ST ATES "CY-7e 15' June 18,1979 Nuct. EAR R EGULATORY CCMMissiCN
\\b IT4 FORMATION REPORT For:
The Commissioners
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Thru:
Executive Director for Operations /
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From:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation
Subject:
OPERATIONAL SURVEILLANCE PROGRAM (OSP)
Purpose:
To notify the Commission of the staff's plans to modify the Standard Technical Specifications (STS) for nuclear power plants to provide for an OSP.
Discussion:
The Division of Operating Reactors has an ever increasing workload, a large portion of which entails the processing of changes to licensee's technical specifications.
Some of these changes are of relatively minor safety significance.
The number of technical specification changes requested by licensees that must be processed is increasing at a rate
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disproportionate to the number of facilities with operating licenses.
To process each of these items, the staff is required to perfom a review, write a safety evaluation, prepare a Federal Register notice, and assemble a license amendment package. We believe this " paper work" burden is causing an unnecessary amount of staff ma.: hours to be spent on the processing of actions having minor safety significance.
Many of the technical specification changes we process are more significant from a public health or safety standpoint and certainly warrant the " full treatment" associated with license amendments.
However, in some cases, the nature of the change is considerably less significant frcxn a safety standpoint and thus should be processed in a more streamlined fashion.
This is especially true with regard to changes to Surveillance Requi rements.
3 CONTACT:
Brian K. Grimes Ext. 27415 q
P00R DRE1Ns, 8001180 M
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l The Coromissioners ;
Consequently, we have developed th5 concept of the t
" Operational Surveillance Program" (OSP).
Simply stated, the STS, as they are known today, will be divided into two groups. The first group will consist of those speci-fications that delineate requirements directly related to safe operation of the reactor, i.e., Safety Limits, Limiting Safety System Settings, Limiting Condi*
ns for Operation (LCOs), Design Features and Administr, ave Controls.
Under current regulations, these requirements would continue to be technical specifications and any proposed changes will be subject to the same regulatory and procedural requirements as today's technical specifications, e.g., staff review, written safety evaluation and notice in the Federal Register.
The second group will contain the required surveillance activities that are necessary to assure the performance capability of the LCOs. This group will be essentially comprised of the Surveillance Requirements in the existing STS.
This second group of requirements will be called the
" Operational Surveillance Program" (OSP).
It will be referenced in the Technical Specifications, but will not be part of them.
The Administative Controls Section of the Technical Speci-fications will contain provisions that will allow changes to be made to the OSP upon request from the licensee, without an amendment to the license, provided certain criteria are met.
These criteria include:
1.
A determination that the change will not materially
\\\\g reduce the overall level of facility safety.
2.
Documentation of the fact that the change has been reviewed and found acceptable by both the Fac11itv-Review Group and the Company Nuclear Review and Audit Group.
3.
Documentation that the change does not decrease the effectiveness of the OSP.
Suf ficiently detaile_d l
information must be submitted to suoDort the rationale
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- iv i une cnange wunout benefit of additional or suppbm a i i nforma tion.
Information submitted may cnnsist of analyses or refinement of analytical techniques.
l 200R BRIGINL
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The Commissioners,
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Lice.sce proposed changes to the OSP will become effective f
i ro-in u f the proposed, wtcmatically 15 days af tnr statt Licensee proposed changes may bectme effective f n change.
less than 15 days after receipt, if approved by the staff.
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Within the 15 day time period, however, the staff may notify the licensee that the proposed change is, in the staff's opinion, unacceptable for the OSP and requires a license amendment because it would be a violation of the admini-strative controls portion of the technical specifications (see paragraphs 1-3 quoted on previous page).
If necessary, appropriate actions are available to the staff to prohibit
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or negate impicmentation of a proposed change considered unacceptable by the staff via an Order to Show Cause pursuant to 10 CFR 52.202.
If the OSP were retained as part of the technical specifications, the licensee would have the burden of proving that a licensee-initiated OSP change was safe.
The proposed new OSP concept has a disadvantaae in that, if a licenseo insisted in going forward with a change over staff objections (which the licensee would have the right _
to do. since no staff annrnvai w n i ri ho reouired). then the 5taff would have the bur' den of showina that the licensee's change violated the administrative controls portion and thus required prior staff annenval
,However, it is expected
%'that only in unusual cases will licensees proceed in the face of staff objection.
Furthermore, the staff is prepared, in any such unusual cases, to proceed with prompt enforcement action.
We plan to revise the STS to incorporate the OSP concept l
by September 1979, and plan to implement it in a systematic fashion on subsequent operating license issuances. We also l
plan to utilize the OSP concept for plants already licensed with Standard Technical Specifications on a voluntary basis.
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'We believe the effective implementation of this program will, over the long term, materially improve the licensing process and belo reduce the future backlog of Technical Specification change requests.
j We estimate a yearly manpower savings of 0.24 man-years per c
- y. ear for each STS facility with OSP based on elimination of at least two STS amendments per year. This manpower savings would be initially offset in part by the 0.05 man-years required to convert STS facilities to the OSP concept.
P00R DER
Tt; Commissioners.
For non-STS facilities, we estimate a yearly manpower savings of 1.08 man-years per year for each non-STS facility converted to STS and OSP partly as a result of the reduction in number of amendments afforded by conversion to STS.
Again, this manpower savings would be initially offset in part by the 0.4 man-years required to convert the facility to the STS and OSP concept. We do not plan to convert non-STS plants to the OSP concept unless they are also converted to the STS fonnat. There are now 19 units with STS and 51 units with custom speci-fications. This will change, within about a year, to'about 34 units with STS and 46 units with custom specifications as a result of voluntary conversions and new OL issuances.
We plan to announce our intent to implement the OSP concept by sending the enclosed letter to all power plant licensees and OL applicants. We will have copies of the OSP and the r ev i s e dJIkava t4M e:for~ r e f e r = c eJy tember 1979.
Coo i
fice of the Executive Legal Dire legaN objection.
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4 Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
Sample Letter to All Power Plant Licensees and OL Applicants DISTRIBUTIOf(
Commissioners Commission Staff Offices Exec Dir for Operations ACRS Secretariat l
P00R ORIGINAL O
W O
/" *4 unirco ciarcs NUCLEAR REGULATORY CCt.'.t.ussl0N y
g WASHINGTON, D. C. ::005 g
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%,.... + f All Power Reactor Licensees Gentlemen:
This letter is to notify you of our plans to modify the format of the Coranission's Standard Technical Specifications (STS).
As you know, there are four sets of STS (one for each NSSS vendor type plant) that are used by applicants and the staff to develop plant specific Technical Specifications for each new plant that is licensed to operate.
The current STS, as well as customized Technical Specifications for filants that pre-date the STS, contai_n
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+hn fin 4+4nn Surveillance Requirements for damnnstratinn tCanditions for Operation (LCOs) are being satisfied for the various modes of plant operation._ Over the years, nuese surveiiiauw Requirements have become more extensive and detailed. We believe that the level of assurance that LCOs are being met has been significantly increased by the performance of these surveillance activities.
However, because of the way current Technical tnn survnillance Specificatinne fnr all 'olants are structurno..
intoneal cart of them; and thus, like the 3 equ4re ents we an T.ghnical 9acifications, are also an accendagn to the coeratinq
,lic,ef.s e.
Consequently, any change to the Surveillance Recuirements q
must _be crocessnd as a liennso mancment.
Generally, this involves '
the application for a license amendment from the licensee, a staff review, a documented safety evaluation, and the publication of a notice in the Federal Register.
This process is followed regardless of the nature of the change.
Some of these changes
.-h have proven to be significant frnm the standpoint of public health and safety while the majority have not.
Nevertheless, the volume of documentation needed to support each change, whatever its significance, is approximately the same.
This " paperwork
( burden" has caused considerable delayjn-thrprocess' these
{/ changes, by the NRC, wi e resultant backlog %e do ot W
feel this backlog is in he best interest of the publie', or licensees.
j y[Ii l
JF' f
4-O
All Power Reactor Licensees :
To help alleviate this problem, we have developed the concept of an Operational Surveillance Program (OSP).
Simply stated, the STS Ine as they are known today will be divided into two groups.
hrst group will consist of those specifications that delineate requirements directly related to the safe operation of the reactor, i.e., Safety Limits, Limiting Safety System Settings, LCOs, Design Features and Administrative Controls.
These requirements will continue to be Technical Specifications and any proposed changes will be subjected to the same regulatory and procedural requirements as today's Technical Specifications, i.e., staff review, written safety evaluation and notice in the Federal Register. The s_econd_
group will contain the surveillance related activities that are Ini3 Recessary to assure the perfomance capability of the LCOs.
(econd group of requirements will be called the Operationai he referenced in the Technical C O.
Surveill ant p Prngram (ntD) and will Soecifications, but will not be part of them.
g The Administrative Controls Section of the Technical Specifications /
will include provisions that will allow changes to be made to the /
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OSP without a license amencmenTprovided certain criteria are M
satisfied.
5 These criteria.
de:
A detemination that the change will not materially reduce the overall level of facility safety.
- Oh Documentation of the fact that the change has been reviewed 2.
and found acceptable by both the Facility Review Group and the Company Nuclear Review and Audit Group.
Documentation that the change does not decrease the effectiveness Sufficiently detailed information must be submitted of the OSP.
to support the rationale for the change without benefit of Information submitted additional or supplemental information.
l may consist of analyses or refinement of analytical techniques.
censee proposed changes to the OSP will become effective automatically Licensee proposed 15 days after staff receipt of the proposed change.
changes may become effective in less than 15 days after receipt if approved by the staff:
Documentation ~ of the staff agreement with changes will be in the form of revised pages of the OSP subsequently transmitted by letter.
Within 15 days, the staff may notify the licensee that the proposed change is, in the staff's opinion, unacceptable for the OSp and requires a license amendment review.
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All Power' Reactor Licensees Implementation of a proposed change which is unacceptable would, in the staff's opinion, be a violatina ef the administrative controls portion of the techr.ical specifications and the staff
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N pp.uld take prompt enforcement action to prevent or abate any such v1olation.
We plan to revise the STS to incorporate the OSP concept by September 1979, and plan to implement it in a system ticJashic n subsequent operating license issuances.
We also an tTutil N ncept
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for plants already licensed with STSs o lu1Ltary basis.
We believe the effective implementation of this program will3er-t ong term, materially improve the license process and reduce the future backlog of Technical Specification change requests.
We plan to have copies of the revised STS available for your reference by September 1979.
If you have any questions or desire any more information on the program, please contact us.
Sincerely, Darrell G. Eisenhut, Acting Director Division of Operating Reactors Office of Nuclear Reactor Regulation l
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