ML20044B590
| ML20044B590 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1992 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20044B591 | List: |
| References | |
| NUDOCS 9212150291 | |
| Download: ML20044B590 (6) | |
Text
.
i guccu Q
L O
3 UNITED STATES
[ ' l.. oE NUCLEAR REGULATORY COMMISSION 3
zj f
WAsHWGToN, D.C. 20$55
....+
December 7, 1992 MEMORANDUM FOR: Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM:
Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
RELOCATION OF TECHNICAL SPECIFICATION TABLES ON INSTRUMENT i
RESPONSE TIME LIMITS The staff is proposing a generic letter for a line-item improvement to technical specifications (TS) that is based on TS issued for the last group of plants that received operating licenses. The proposed generic letter,
- Relocation of Technical Specification Tables on Instrument Response Time Limits," attached to the enclosed CRGR review package, is submitted for review as a Category 2 item.
The TS change relocates the tables with instrument response time limits to the updated final safety analysis report (FSAR). The staff has implemented a similar TS modification in the improved standard technical specifications for each nuclear steam supply system (NSSS) vendor. The generic letter includes guidance to help licensees and project managers process license amendments to implement the changes.
Brian K. Grimes, Director, Division of Operating Reactor Support is sponsoring this work.
Please schedule a meeting at the earliest opportunity for the CRGR to review this proposal.
Frank @ Hirag ia, Deputy Directer Office of Nuclear Reactor Regulation
Enclosure:
As stated CONTACT: Tom Dunning, 504-1139
'hi 215o 29l yk j
Enc 1csura QSR REVIEW PACKAGE Proposed Action: Issue a generic letter to give licensees guidance for implementing a line-item technical specification (TS) improvement. The change relocates the tables of response time limits for the reactor trip system (RTS) and the engineered safety features actuation system (ESFAS)'
instruments from the TS to the updated final safety analysis report (FSAR).
CATEGORY 2 RESPONSE TO RE0VIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW (i)
The proposed generic requirements or staff position as it is proposed to be sent out to licensees. Where the objective or intended result of a proposed generic requirement or staff position can be achieved by setting a readily quantifiable standard that has an unambiguous relationship to a readily measurable quantity and is enforceable, the proposed requirements should merely specify the objective or result to be attained, rather than prescribing to the licensee how the objective or result is to be attained.
e See proposed generic letter, " Relocation cf Technical Specification Tables on Instrument Response Time Limits."
(Attachment) i (ii)
Draft staff papers or other underlying staff documents supporting the requirements or staff positions.
o The staff permitted applicants to relocate the tables of response time limits to the FSAR when the TS were proposed for the operating license i
for recent plants.
Inspection reports do not indicate that this action or that response time limits in general have been a problem.
The staff is proposing this generic letter to give licensees guidance on implementing this line-item TS improvement.
(iii)
Each proposed requirement or staff position shall contain the sponsor-ing office's position as to whether the proposal would increase requirements or staff positions, would implement existing requirements or staff positions, or would relax or reduce existing requirements or staff positions, e
The change allows the licensee to propose relocating the tables of the RTS and ESFAS instrument response time limits from the TS to the updated FSAR. This change does not alter the existing TS surveillance requirements to verify that the response times of the RTS and ESFAS instruments are within their limits. The licensee would be required to commit to placing the response time limits in the next update of the FSAR. Tabulated response time limits may envelope the results of a series of sequential or overlapping tests; i.e., the bounoing limit for a series of individual response times. Response time limits are assumed values in accident analyses and range from about 0.5~ seconds to 4 seconds for the RTS and from about 2 seconds to 6.5 minutes for
t the ESFAS. Because these limits will be placed in the FSAR, any changes to them will then be subject to the same requirements of Section 50.59 of Title 10 of the Code of Federal Regulations (10 CFR I
50.59) that apply to other aspects of the safety analysis described in the FSAR. This regulation states that the licensee may make changes without the prior approval by the Commission only if the change does I
not result in an unreviewed safety question.
This is a relaxation of the present requirements wherein changes to these limits in the TS can only be made through the license amendment process.
Licensees would also have to confirm that the plant procedures that implement the TS surveillance requirements for response time testing include requirements that reflect these response time limits. Thus, the TS administrative controls on changes to plant procedures are another control for changes to these limits.
(iv)
The proposed method of implementation along with the concurrence (and any comments) of the Office of the General Counsel (OGC) on the method proposed. The concurrence of affected program offices or an explanation of any nonconcurrences.
Licensees would voluntarily propose TS changes consistent with the generic letter. Project managers would review proposed changes, prepare the safety evaluation report (SER), and process the license l
amendment to implement the TS changes. OGC has reviewed the proposed generic letter and had no comment or objections. This TS improvement does not directly affect other offices.
(v)
Regulatory analyses generally conforming to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.
A regulatory analysis is not required because action taken by licensees in response to the generic letter would be voluntary.
(vi)
Identification of the category of reactor plants to which the generic requirement or staff position is to apply.
This guidance applies to all power reactor plants.
e (vii)
For backfits other than compliance or adequate protection backfits, a i
backfit analysis as defined in 10 CFR 50.109.
The backfit analysis shall include, for each category of reactor plants, an evaluation which demonstrates how action should be prioritized and scheduled in light of other ongoing regulatory activities. The backfit analysis shall document for consideration information available concerning any of the following factors as may be deemed appropriate and any other information relevant and material to the proposed action:
(a) Statement of the specific objectives that the proposed action is designed to achieve; (b) General description of the activity that would be required by the licensee or applicant in order to complete the action; 2
o.
(c) Potentia age in risk to the public from the accidental offsite release of radioactive material-1 i
(d) Potential impact on radiological exposure of facility employees and other onsite workers; (e)
Installation and continuing costs associated with the action, including the cost of facility downtime or the cost of construction delay; (f) The potential safety impact of changes in plant or opera-tional complexity, including the relationship to proposed
+
and existing regulatory requirements and staff positions; (g) The estimated resource burden on NRC associated with the proposed action and the availability of such resources; t
(h) The potential impact of differences in facility type, design, or age on the relevancy and practicality of the proposed action; (1) Whether the proposed action is interim or final, and
interim, the justification for imposing the proposed ution i
on an interim basis; (j) How the action should be prioritized and scheduled in light of other ongoing regulatory ectivities. The following information may be appropriate in this regard:
1.
The proposed priority or schedule, 2.
A summary of the current backlog of existing requirements awaiting implementation, 3.
An assessment of whether implementation of existing requirements should be deferred as a result, and 4.
Any other information that may be considered appropriate with regard to priority, schedule, or cumulative impact.
For example, could implementation be delayed pending public comment?
Backfit considerations do not apply because a licensee's response to e
this generic letter would be voluntary.
(viii) for each backfit analyzed pursuant to 10 CFR 50.109(a)(2) (i.e., not adequate protection backfits and not compliance backfits) the proposing office director's determination, together with the rationale for the determination based on the considerations of paragraphs (i) through (vii) above, that (a) there is a substantial increase in the overall protection of public health and safety or the common defense and security to be derived from the proposal; and t
0.,
(b) the direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
j (ix)
For adequate protection or compliance backfits evaluated pursuant to i
(a) a documented evaluation consisting of:
(1) the objectives of the modification, (2) the reasons for the modification, and (3) the basis for invoking the compliance or adequate i
protection exemption.
(b)
In addition, for actions that were immediately effective, the evaluation shall document the safety significance and appropriateness of the action taken and consideration of how costs contributed to selecting the solution among various acceptable alternatives.
Backfit considerations do not apply because a licensee's response to this generic letter would be voluntary.
(x)
For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office director's determination, together with the rationale for the l
determination based on the considerations of paragraphs (i) through (vii) above, that (a) the public health and safety and the common defense and security would be adequately protected if the proposed reduction in requirements or positions were implemented, and The TS change will not adversely affect the public health and safety. The TS surveillance requirements include provisions to t
verify that the response times of the RTS and ESFAS instruments are within their limits, and the design control process can adequately maintain the values of the response times, consistent with the design basis accident analyses.
(b) the cost savings attributed to the action would be substantial enough to justify taking the action.
This guidance should help to reduce the costs for preparing license amendments by enabling licensees to make changes to response time limits without the need to process a license amendment when the changes do not result in an unresolved safety question. The intent of this generic letter is to reduce a licensee's costs to prepare a related license amendment request and to reduce the staff's cost to review that request._
+
4 l
l
~
(xi)
For each request for information under 10 CFR 50.54(f) (which is not subject to exception as discussed in~III.A) an evaluation that includes at -least the following elements:
l (a) A problem statement that describes the need for the information in terms of potential safety benefit.
(b) The licensee actions required and the cost to develop a, response to the information request.
(c)- An anticipated schedule for NRC use of the information.
(d) A statement. affirming that the request does not impose new-requirements on the licensee,- other than for the requested information.
i e
The generic. letter would not request information under 10 CFR 50.54(f). However, it would request the licensee to voluntarily submit information on its time and cost to prepare the license amendment request and an estimate of long-term savings to be realized from the proposed TS change.
o i
(xii)
An assessment of how the proposed action relates to the Commission'sL Safety Goal Policy Statement.
The proposed action is not related to the policy statement on safety i
goals.
f 1
f v
i P
f 1
i
=
5 l
d
-