ML20137M624
| ML20137M624 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8601280313 | |
| Download: ML20137M624 (98) | |
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of COMMISSION MEE" JING Briefing on Status of Task Force on Technical Specifications (Public Meeting)
Docket No.
Location Washington, D. C.
Date: Tuesday, January 21, 1986 Pages 1 - 78 ANN RILEY & ASSOCIATES Court Reportors 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 0601200313 060121 (202) 293-3950 PYb. 7 PDR
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5 6 This 6s an unofficial transcript of a meeting of the l
7 Un6ted States Nuclear Regulatory Commission held on i a 1/21/86 in the Commission's office at 1717 H Street, 1
9 N . LJ . , tJa sh i ng t on , D.C. The meeting was open to public 10 attendance and observation. This transcript has not been -
11 reviewed, corrected, or edited, and it may contain I
12 6naccueac6es.
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I 13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the I 16 matters discussed. Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beI6efs. No l
18 pleading or other paper may be filed with the Commission in i
I 19 any proceeding as the result of or addressed to any stafement '
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i' j 20 or argument contained herein, except as the Commission may
- 21 authorire.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR HEGULATORY COMMISSION 3 - - -
4 UNIEFING CN STATUS OF TASK FOHCE ON 5 TECHNICAL SPECIFICATIONS 6 - - -
7 Public Meeting 8
9 Tuesday, January 21, 1986 10 Hoom 1130
, 11 1717 H Street, N.W.
12 Washington, D.C.
13 14 The Commission met in open session, pursuant to 15 notice, at 2:00 p.m., the HONOHAULE NUr4ZIO J. PALLADINO, 10 Chairman of the Commission, presiding.
11 18 COMM I S S I Or4EH S P R ES Ei4T .
19 F4 UllZ I O J. FALLADINO, Ch a i rcia n of the Coninai s s i o n 20 JAMES X. A S S E L ST l ilE , Member 21 FREDEMICK M. HEHNTHAL, Member J2 THOMAS M. HOUERTS, Member 23 LANDO W. ZECH, JR., Member 24 1
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1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 S. Chilk M. Matsch 3 H. Denton V. Stello 4 E. Butcher F. Baranowsky 3 S. Bryan 6 AUDIENCE SFEAKENS:
't M. Vollmer 8
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16 19 20 21 22 23 ,
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. 3 1 P ROC E E D I NO 8 CHA1HMAN PALLADINO: Good a t t ev r n o o n , nadies and I J gentlemen. This attornoon we are meeting with members of the 4 statt to discuss their recommendations for improving technical 5 specittoations. P l .a n t technical specifications have evolved 6 over many years, and at this time there is general statt and
? industry agreement that improvements should be considered.
8 In 1982, the NHC proposed a change to 10 CFR $U.30, 9 and in August 1983, the EDO established the Task Group on 10 Technical Specittoations. More recently, in December 1994 a 11 Technical Specification Improvement Project, TSIF, was 12 estabitshed to reconsider the entire subject of technical 13 specittoations and to provide recommendations for 1:ap r ov eme n t .
14 On January 13, 1986, the acting EDO terwarded SEGY 15 80-10, Neoommendations for Improving Technical to Spoottications. This is the result of a TSIP ettort as well 17 as the signittoant contributions made by the Atomic Industrial 18 Forum. I understand that copies of this policy paper are 19 available on the table in the back of the room.
20 Among other things, SECY 80-10 recommends that the 21 statt proceed now with the development of a Commission policy 22 paper on technical specifications, and to proceed with 23 rulemaking at a later date. However, as I unde rs t and' the 24 situation. AIF would preter that rulemaking be undertaken now.
l 25 A discussion of the pros and cons at each approach
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1 would be useful I believe that a main objective of today's 2 meeting is to obtain enough intormation for the Commission to
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' t 3 decide whether the stati should now proceed with a proposed l t
4 4 policy or with rulemaking or some other option, it any member I
i 5 has an option to suggest.
6 Do any ci my tellow Commissioners have any 7 additional opening remarks at this time?
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b LNo response.J i
j 9 CHAIRMAN PALLADINO: All right Then let me turn l 10 the meeting over to Mr. Stello. ,
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1 11 MM. STELLO: Thank you, Mr. Chairman. The issue of l
l 12 improving the process by which we issue tech specs and the 1 *J whole issue of tech specs has been with us to quite some 4 14 time, and it's been recognised as an area where we clearly-4 I
15 want to do better, and I think recognise the need to do j 16 better. Part of what you'll hear today will include the !
i l 17 background and summary of how we get to the point, and 4
j 18 Mr. Denton will get into that in a ninute. -
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! 19 I wanted to make sure that it's clear that this is l L l 20 only one aspect of our going back and looking into the
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21 regulatory process and trying,to aecide areas such.as this one i
22 where we can do better, and indeed we're c ommi t t,o d to do that I 23 nherever we can.
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24 This particular activity is one tar whteh there 4
l 25 obviously was a need to got industry involvement, _and as s r i t I
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- 5 1 you*ve correctly pointed out, the Atomic Industrial Forum has t '
i 2 spent considerable ettort in this program. I understand that
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3 they have asked the Commission to come forward and have some 4 views that they would like to otter, and perhaps that could be i
5 arranged for the future.
I 6 I think it's interesting that usually, the industry 7 has a view that we ought not to issue a rule but rather, to l
I 8 issue a policy statement. In this case it is reversed, and 9 they probably have some good reason. I think it*s important, 4
' 10 though, to recognize they are not opposing issuing the policy 11 statement, and Mr. Denton will get into that a little bit more l 12 in a minute.
13 Our plans are to go torward in the near future and i
14 discuss this program with the ACHS, and we plan on doing that, j 15 and I don *t believe a date has been set yet but we expect to
$ 16 be able to do it in the next couple of months, I would assume.
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17 With that, let me turn the meeting over to l t
18 Mr. Denton to give you some of the background of how we got i
19 where we are today.
20 MR. DENTON: We have at the table today Ed Butcher f
- 21 on my lett who is Chief of the Tech Spoo Branch and will be i
i 22 making a lot of the presentation. Pat Haranowsky from i
23 Research to Vic's right, and Sam Bryan who will be 1
i 1 24 participating in the presentation also, i
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25 Going back to the early days of regulation, we used I
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. 6 1 to hold the licensee to the entire submittal, and he couldn't 2 change anything in the plant that had been put in the 3 application without amending the license. It was recognized 4 about 20 years ago that that became extremely burdensome, and 5 that's when we adopted the present approach to tech specs.
6 There*s been a lot of accretion of adding things to
? tech specs in the decades that are past, and we'll be getting 8 into those details. But I formed this task force on tech 9 specs about a year ago probably because of three main 10 reasons. One was the Sho11y legislation. That made it 11 increasingly ditticult to correct unintentional impact. of the 12 tech specs easily. With Sholly, everything is much more m
13 formal and rigorous and you have to notice it. Before that, s
14 we had a little 11exibility to make changes.
15 Another thing we've come to realize is that tech to specs were no longer oriented as much as we felt they should 17 be towards human. tactor aspects. Originally, the idea was 18 tech specs would be on process variables; those things under 19 the direct control of the operator and things in which you s 20 would not want the plant maki.ng changes without Commission 21 approual Plus, we were beginning to see trom the FRAs and 22 other technical work that was being done that we hadn*t 23 necessarily selected the proper surveillance intervals and 24 limiting conditions for operation and these sorts of things.
25 So we formed a committee to work full time. They
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7 1 delivered their product on time in September, and we'll give 2 you some of the results of that. We also formed an advisory 3 committee to follow that and to advise them, and that 4 committee included people like Glenn Heed from the ACRS who 5 has extensive operating experience. So I've been very pleased 6 with the results of this ettort. Industry has been heavily 7 involved.
8 This effort is a little bit different than the 9 eftert to improve tech specs in general You remember after 10 Grand Gulf and some of those debacles we have gone to a 11 process of improving the quality of the tech specs per se. In l
I 12 that area, we do now require the utility to certify tech 13 specs, we have regional inspections of the as-built plant, we 14 have a contractor in many cases review the application versus 15 the tech spec, and we get focused management attention on tech 16 spec.
17 We're not going to talk about those aspects today; 18 we're going to talk about more what should be the boundary in 19 the tech specs; where should that boundary be between the 20 things that a licensee is permitted to change without coming 21 to the agency for amendment, and those which he should change 22 only after our review and approval.
23 So with that introduction, Ed, why don't you 24 proceed. We have about 14 slides to cover today.
25 MR. GiTCHER: I'll start- oli and till in a little
- 8 1 bit more detail on the' history of the development of technical 2 specifications and where they came from.
3 L S l i d e . 'J 4 The tech specs actually find their genesis 19%t in 5 the Act itself. The Act established spe4\fic requirements for e which information within the applic[;<4 *
- c.u l d be considered 7 technical specifications, and I'll quote directly from the B Act. The Act states that, " Technical specifications shall 9 include the amount, kind and source of special nuclear 10 material required; the place of use; the specific 11 characteristics of the facility and such other information as 12 the Commission by rule or regulation deems necessary."
13 In 1956, the Commission published its early 14 regulations on technical specifications, and the effect of 15 $0.36 was merely to codify the requirements of the Act. There 16 was very little additional information published, or 17 additional detail on the content of technical specifications.
18 In 1962, it became aware -- the period between 1966 i 19 .and 62 -- that it was necessary to.be more specific about 20 which specific parts of the application should be considered 21 technical specifications. And at that time, the Commission 22 amended 50.36 and published Appendix A, which provided details 23 on the specific requirements to be considered technical 24 specifications; the specific elements of the plant design.
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25 This Appendix A I_ guess could be considered a l
- 9 1 forerunner of today's Appendix A, the General Design Criteria.
2 The Commission still did not, in 1962, require that 3 technical specifications be incorporated in a separate 4 document. At that time, the entire Hasards Analysis Report 5 was still considered the technical specifications, 6 The first point at which it was determined that 7 technical specifications ought to have a separate status of 8 their own from the application was in 1968 when 50.3e was 9 again amended to make the technical specifications a separate 10 document. As Harold mentioned, up until this point, virtually 11 any change to the plant design could be-interpreted as 12 requiring a technical specification or license amendment, 13 The specific -- $U.36 sets torth specific elements 14 which must be included in the technical specifications, and 15 you can see them listed there on the slide.
16 The next major action in the development of 17 technical specifications occurred in 1974.
18 [ Slide.)
19 It became clear after the amendment to 50.36 in 1968 20 that an awful lot, a large amount of staff resource was going 21 in to developing this separate document which was called 22 Technical Specifications, and it was determined that in order 23 to simplify this process and gain some uniformity in the 24 industry, standard technical specifications for a given 25 reactor design would be developed. And they were developed
. 10 1 in 1974. In large measure, the industry developed those 2 proposals and they were submitted to the staff and the stati 3 reviewed them and changes were made accordingly, and we 4 finally published and issued standard technical specifications 5 for each of the reactor designs, 6 The significant features of those documents, those 7 standard documents, were that the meat of the specification 8 and those parts of the document which we are interested in 9 tocusing our attention on now for making improvements lies in 10 tour areas.
11 The limiting conditions for operation -- the 12 limiting conditions for operation are . hose specific 13 conditio'ns which are placed upon plant operation in terms of 14 the minimal number of systems which must be operable, minimal 15 numbers of trains that must be operable. It defines the 16 complement of equipment which must be operable in the plant in 17 order to continue its operation.
18 The action statements define what one must do when 19 he cannot meet the limiting conditions for operation. Many
.20 times that involves a reduction in power or shutting the 21 reactor down.
22 The surveillance requirements are simply the 23 testings which must be done on a periodic basis to verity that 24 the equipment is, in fact, operable.
25 And of course, the bases ties the whole thing
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- 11 1 together, provides the technical rationale that goes into 2 establishing the specific limiting conditions for operation, 3 action statements and surveillance' requirements.
4 In 1979, there was I guess what could be 5 charseterized today as a major policy statement on the intent 6 and purpose of technical specifications. 1*m not so sure that 7 it was recognised at the time that the board decision was 8 made, but upon careful reflection it has turned out to be a 9 fairly protound statement of the intent and purpose of 10 technical specifications.
11 You can see the ruling on the slide. It was -- this 12 ruling was made in connection with a specific license l '3 amendment on the Trojan plant in connection with the spent 14 fuel pool expansion, but it has universal applicability. I 15 will read it; it's quite a significant statement.
16 "The technical specifications are to be reserved for 17 those matters as to which imposition of rigid conditions and 18 limitations upon reactor operation is deemed necessary to 19 obviate the possibility of an abnormal situation or event 20 giving rise to an immediate threat to the public health and 21 safety." The key words there are " rigid conditions and 22 limitations upon reactor operation" and "immediate threat."
23 with this statement, the concept of the technical 24 specifications being, in effect, a contract between the 25 utility and the NRC on how the plant will be operated was l
. 12 1 brought forth.
2 Having gone through the history of how we got from 3 the beginning to where we are in tech specs now, it's.
4 appropriate to focus on what the not ettect of this 5 development process has been.
6 COMMISSIONEM ASSELSTINE: Before you leave this one, 7 let me ask you, is that really the end point in your view?
8 Was there any change after TMI in terms of the emphasis of 9 what should be in tech specs, expanding the number of items 10 that ought to be included in tech specs? And 11 so, what was 11 the basis for that?
12 MR. BUTCHER: I think this slide will give some 13 indication of the effect.
14 COMMISSIONER ASSELSTINE: I agree with you, the 15 slide talks about the effect. I guess what I'm interested in 16 is the cause and the rationale.
17 MR. BUTCHER: There were many of the action items in 18 the -- I guess you could characterize them as -- new staff i
19 requirements which came out of the information that was 20 learned from the TMI accident that found their way into 21 technical specifications. And that, in combination with the 22 changes for the fire protection program, we would have to say 23 represented a major increase in the number of technical 24 specifications.
25 COMMISSIONER BERNTHAL: Well nevertheless, if you
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- 13 a look at your number,there, it would appear that the major 2 change pre-dated TMI, both on LCO's and surveillance tests.
3 MR. BUTCHER: That's correct, there was a major 4 change. You can see that there was another substantial change 5 between 1977 and 80 which is the timeirame of TMI 6 COMMISSIONEH BERNTHAL: But there you're talking 7 about maybe a 25 to 30 percent, 36, whatever it is, change; 8 whereas before, you're looking at a change that's 20 or 30 9 times between 1972 and 1977.
10 MR. BUTCHER: I guess you would have to say there 11 were probably two major events;-the advent of standard 12 technical specifications and the TMI accident, which were 13 principal contributors.
14 [ Slide.3 15 These statistics here are pretty impressive in terms 16 of particularly the surveillance burden that has grown over 17 the years and as we have progressed through the development 01 18 technical specifications. There are other examples which 19 people have done -- informal surveils of various older plant 20 designs with tech specs versus the new onesf-- and they all 21 bear out these sorts of increases in the requirements.
22 CHAIRMAN PALLADINO: Coming back to Commissioner 23 Bernthal's question, what caused the. tremendous increase 24 between 1972 and 77 as opposed to a more modest increase 25 between 1977 and 80.
t l _ _ _ - --
. 14 1 MR. DENTON: Let me try to answer that. One reason 2 is the plant has gotten more complex. The early plants like 3 Hig Rock Point and Dresden were fairly simple, and I think the 4 statt interpreted the need for control to sort of be a minimum 5 set. And so we tended to concentrate on don *t exceed a 6 certain pressure in the pressure vessel design pressure, the
? ASME sort of requirements, and did not have a lot of detailed 8 requirements for many systems.
9 1 think the regulatory statt grew during this period 10 and there were conflicts developing between how do you -- what 11 was the real meaning of a tech spec. So in some cases, the 12 industry wanted to make a more exact board cititation, and in 13 some cases the statt wanted to make them more exact to pin the 14 licensee down. I don *t think there is any single cause, and 15 that's why I used the word " accretion."
16 I think every set tended to get a little more 17 complex than the last one with all sides trying to carry out 18 their best judgment on what was required. And so they kind of 19 crept from 30 pages to 40 pages to 60 pages, and everyone now 20 realizes, looking back, that many of the fundamental safety 21 parameters we were trying to control may be obscured by 1iving 22 attention to some of the lesser important issues.
23 CHAIRMAN PALLADINO: Was there a basic change in 24 philosophy? Because I thought when the tech spec got started 25 that the intent was just to keep to maintaining, as you said,
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. 15 1 a minimum number of parameters as being specified in the tech 2 specs. Whereas, a s' the years went by, apparently others 3 thought more should be in it.
4 MR. DENTON: I don't think it ever really came to 5 the Ccmmission as a Comrai s s i on level of attention. I think it 6 was gust sort of plant by plant that as everybody got smarter 7 and some of the systems changed to a solid state where you got 8 test them more often, maybe the requirement went in to test 9 . things once a week instead of once a month. And everybody 10 said that sounds find.
11 Many of the decisions were made not because we had 12 PRA's or knew exactly what the right decisions were, but 13 because on engineering judgment it sounded like a good test 14 area.
15 COMMISSIONEM ASSELSTINE: Harold, is it fair to look 16 at both sides of the coin?- When I look at that chart it seems 17 to me it*s a fair question to ask: are the numbers of LCO's 18 and surveillance tests for some of the new plants excessive?
19 The 15,000 cr 14,000? But it also strikes me as a fair 20 question to ask whether 390 surveillances is adequate for a 21 plant like Surry. Surry is a far cry from Big Rock Point or 22 Dresden 1 You know, I wonder whether both sides of the coin 23 have to be looked at; that is, whether for the older plants, 24 the pre-standard tech spec plants, whether we really have 25 enough in there to give us the assurance that tne plant is l
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- 1G 1 being maintained and operated in a safe manner.
2 MR. DENTON: It has been pointed out that some of 3 the best-running plants have the skimplest tech specs, you 4 know, which is another side to that argument that they could
$ devote'more time. But it is a question. Just because it is 6 in tech specs or not doesn*t really.say what t .s e safety of the 7 plant is. If the licensee is conscientious about making 8 changes and doing $0.59 reviews and only making changes that 9 add to safety, then it doesn't matter -- I think what we're 10 talking about here is the degree of regulatory control 11 And for example, Westinghouse came in probably a 12 year or two ago with a' topical report saying our intervals had 13 been set far too snort based on modern reliability data and 14 theory, and we ended up agreeing with them. And I think we 15 have changed from weekly to quarterly or weekly to monthly.
16 And sometimes that makes a big change in the numbers, but it 17 might be in systems who are not in those dominant sequences.
18 And I think one of the things I wanted the group to 19 look at here -- two of the things I wanted them to look at --
20 is look at these from the human factors side. They were 21 originally developed more from a design side, not from an 22 input from operational data what-was really failing and what 23 was important, and in fact, around these FRA*s which showed 24 dominant sequences.
25 And it may well turn out that there are some things
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' 17 1 that we ought to be covering more tightly, such as t
2 containment, for example, and there might be things that we 3 are over-regulating. But clearly, most people think that we 4 should not have put in there snubber inspections. Snubbers 5 are important, but do we really have to have inspecting every 6 snubber in a plant in the tech specs. Can*t that be lett to 7 some other program that the utility has.
8 So I don't think we meant this to be all-inclusive; 9 they were just samples that just illustrate the growth in tech 10 specs. And I don't think at the Commission level it was ever 11 a conscious policy decision to add more or less; it just kind 12 of grew. And sometimes you rec.11 boards added requirements 13 that had to be tech specs. So there were many different 14 causes.
15 But looking back at it, now they are quite fat and 16 they're much larger than I've seen anywhere else in the world 17 and since regulatory control And I think what we're going to 18 do about it comes a little later in the presentation.
19 COMMISSIONER ASSELSTINE: Okay.
20 MR. BUTCHER: In an analog sense, I can give you an 21 indication. This is the original tech spec that was issued 22 for San Onofre, and I think it was 1967, and you can get a 23 sense of'the~ size of that. And this is the one for Wolf Creek i
24 today. This one I think is printed on both sides, and this 25 one on a single side; it*s the difference between 39 pages and l
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1 some.600 pages. And I'm not sure that there's any evidence 2 that would indicate that San Onofre is operated any less safe 3 than a plant with a $UU-page tech spec.
4 COMMISSIONER ASSELSTINE: I think Harold is right.
5 The question is the degree of regulatory control and which 6 aspects you want to maintain that degree of regulatory 7 control.
B You are right, Harold; if you have a licensee that 9 is very conscientious about its activities 5 .d maintaining the 10 FSAR commitments and those kinds of things, then you aren't 11 going to have a problem one way or the other whichever place 12 it's In.
13 The question is: if you rely more heavily on the I 14 FSAR commitments and alternative approaches to tech specs, 15 what are you giving up in terms of control, what alternatives 16 do we have to assure ourselves that that approach is going to 17 provide the same high level of compliance that we have with 18 tech specs?
19 MR. STELLO: I would like to make sure that we make 20 the point that there is a genuine safety concern, though.
21 Hemember, I think it was Jim Keppler and I can't remember the 22 name of the plant where he mentioned that they had an occasion 23 where they were simultaneously trying to pay attention to 14 l 24 time clocks that were ticked off by limiting conditions of 25 operation.
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- 19 1 COMMISSIONER'ASSELSTINE: I think it was LaSalle.
2 They have had a lot of those.
3 MR. STELLO: It may have been, okay. Now, you have 4 to ask yourself, when the. operating staff of the plant, d knowing that should you run into a clock issue you have to 6 take action with the plant, ge'ts preoccupied with worrying
? about those kinds of activities and distracted from really ,
8 managing the plant. Where 11 it weren*t because it were in l
9 the tech specs they could have done what they needed to do l 'J with those particular pieces of equipment in an orderly 11 fashion. But once it*s in the license, they no longer have an 12 option, and they*ve got to adhere to it.
13 So there*s a real question as to whether adding that 14 much in terms of requirement is really distracting. The point 16 that Harold has made. People in the control room will have to 16 really worry about operating the plant. So there is 1 think a 17 genuine ocncern over making sure that we have used the right 18 tools to accomplish the right purposes. And that*s really the 19 bottom line.
20 MR. DENTON: We appointed as the original director 21 of this group Don Beckham. You recall he came out of being 22 Chief of the Operator Licensing Branch, and vs wanted a heavy 23 . operational flavor since the toch specs really had been design 24 documents, to some extent, and this was our effort to bring. in 25 that operational feel for what were they really doing and what l
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. 20 1 were they adding to safety or not adding to safety, in real 2 practice.
3 COMMISS10NEM ASSELSTINE: To what extent, Harold --
4 you mentioned the ditterence in complexity, and you just 5 showed the difference between San Oncire 1 and Wolf Creek.
6 There's a lot of difference in the complexity of those two 7 plants, both size and complexity of the units. And LaSalle 8 has been having the problem with lots of time clocks running 9 at the same time.
10 I get the sense from talking with the licensee that l'1 a lot of that is due to the particular design -- the logic 12 that's built into those systems. How much of this is design 13 dependent and complexity dependent; that is, as the plants 14 have grown and become more complex. How much of c contributor 15 has that been?
16 MR. STELLO: I don't think we've tried to determine 17 that. Certainly, in ettect, there's increased numbers of 18- systems and complexity and instruments, but I don't we could 19 quantity that. You know it's more.
I 20 HR. DENTON: And we sent this group ott without any 21 instructions as to what to come back with. We said go study 22 the problem, go talk to everybody that knows anything about 23 it, and we really didn't have a preconceived notion except we 24 were kind of uneasy about the growth. So I think what you're 25- getting here is people with their objective view on what to do l
. 21 1 with the situation.
2 LSlide.]
3 MR. BUTCHER: I'd like to give a little outline for 4 the rest of the presentation, where we're going to go from 5 here. Having been through the hi' story and aome summary of 6 what the problem is that's before us, we can consider our
'l overall Technical Specification Improvement Program as a e two-phased approach. The first phase, to identity the problem 9 and come up with-some recommendations; and the second phase, 10 to begin to implement some solutions to these recommendations.
11 Sam Bryan, who is the Assistant Director for the 12 Technical Specification Improvement Project, which was Phase 13 1, is here with us and he will discuss the actual results of 14 their work and what their recommendations were. I'll follow i
15 Sam's presentation with some discussion of Phase 2 and our 16 implementation and our proposals to move forward from here to I 'l correct some of the things that we_believe could be focused on 18 and improvements made.
19 Pat Haranowsky from the Office of Research is also t 20 here, and he will speak briefly about some of the research 21 work which is very closely aligned with what we're doing and l
22 becomes -- the tools and methods and models they're' developing 23 become key ingredients in allowing us to work in such a'r e a s as 24 extending surveillance intervals and allowed outage times so 25 that we can do some of this testing at power that*s going on.
22 1- MR. STELLO: Let me put a plug in for the -- which I 2 don *t think we do enough of -- talking to the Commission on 3 issues such as the one of the kind of work that goes on in 4 research. It really puts an awful lot of scientific 5 understanding of how to go about coming up with solutions to 6 some of the problems we have, and I think I want you to keep 7 in mind that a lot of the judgments that were made in tech 8 specs were just engineering judgments without the basis of 9 what*s the impact of setting a surveillance time of four hours 10 or six days or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or whatever, and what does that mean 11 in terms of safety.
12 And we*re starting now to develop the tools and 13 understanding to put a real scientific basis behind helping us 14 to make some of those -- and they*re still going to be 15 judgments, but now we can start to understand the impact of 16 that. And I think it*s very important to start to see the
, 17 role that research plays in developing those kinds of tools.
18 COMMISSIONER BERNTHAL: Let me ask a broad question 19 on that general subject. I am certainly sympathetic with -- I 20 think it works out to 30 or 40 surveillance tests per day, 365 21 days a year that some of these new plants require. There can 22 be a tendency to forget to worry about whether the cookbook 23 included the baking time in the recipe when there are 100 24 directions in the recipe instead of a half a dozen.
25 On the other hand, I wonder -- and this is the
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r 33 1 question now -- I wonder how ditticult it would be to' perform i
2 all of those surveillance tests with a modest amount of 3 automation. And, Harold, we have talked about this before and 4 by making it possible to gather with modern techniques and 5 computers obviously, microprocessors, large amounts of 6 information quickly and perform these tests quickly and i 7 automatically. Have we ever looked at that very carefully?
8 The other side of the coin here is'that it may be 9 that performing these tests repeatedly and quickly and t
10 efficiently is well within technical possibility today and wo 11 Just haven't pushed it.
12 MR. DENTON: I think you're quite right, One of the 13 things we have been stressing to EPHI in their new design was 14 that they should consider tech specs right from the 15 beginning. When they design an important safety system, what to are its limiting conditions for operation, how often.should it 17 be tested -- design in a way to test it without causing 18 unnecessary scrams and trips and other problems. And I think 19 it is being done in that framework.
20 You also see it in some plants outside the U.S. that 21 have newer plants coming online. The control rooms do seem to 22 be designed for more automatic testing of systems. I think 23 the plants in this country that are being finished don't tend 24 to look that much different than plants that we licensed a 25 couple years ago.
i
.- .-- - - _ _ - -. . - , - , . ,-. ,. ,, , - - - . - - . .-, ,.--,.--.,n_ , , . - ~ . .
. 24 1 CHAIRMAN PALLADINO: Let me ask a follow-up question 2 on that. It seems to me that a number of the tests are 3 required by ASME or IEE8 standards, so what 11 you did reduce 4 the amount of testing called for in the tech specs? Would you 5 really have a significant reduction -- or could you estimate 6 what reduction there really would be in the testing as a 7 result of that?
8 MR. DENTON: That might be a good question for 9 industry. I don't know the numbers, but I think you are 10 right. I think the utilities would still do some testing that 11 they are interested in even 11 we didn't require it.
i 12 CHAIEMAN PALLADINO: But there are also these other 13 tests that I gather are required because of the applicability 14 of these codes.
15 MR. DENTON: Yes.
16 CHAIRMAN PALLADINO: I just wonder whether we really 17 would be -- or how much we would be impacting on the total 1
18 test program by a reduction in tech. specs.
19 MM. BUTCHER: I don't believe we focused on that.
20 CHAIRMAN PALLADINO: I'm not saying we shouldn*t do 21 it; maybe there's something you could get for us.
22 COMMISSIONER ZECH: I*d like to support Mr. Ste11o's 23 statement on involving Research in the tech spec review. I 24 think that*s very important and I think it would enhance the i
25 professionalism of our own review of tech specs.
O
- 25 1 I think the research people can play a very 2 important role to our doing a really much better job in this 3 area. As we discipline the process, why certainly, research 4 judgments can be very helpful. I think it*s a very important 5 point.
6 COMMISSIONER ASSELSTINE: I think that is useful, 7 too, and I wanted to follow up on the research aspect from one 8 standpoint. It strikes me that by improving the technical 1
9 base, the result may well be that there is a technical 1 10 justification for relaxing some of this burden in terms of the 11 trequency of number of surveillance tests that are needed.
. 12 How much of that research work is industry paying 13 for$ Because it strikes me that there is a real tangible 14 benefit from that work to the industry, and I would be
, 15 interested in hearing how much they are paying for that work, 16 it anything.
17 MR. iTELLO: I think the answer is none.
18 MR. BARANOWSKY: Well, the research that industry 1
19 does, at course, is to allow them to come forward with 20 analyses that justify in their opinion modifications to 21 technical specifications. The work that we do allows the NRC 22 to perform its independent evaluation and have the capability 23 of making judgments as to whether or not the proposals by 24 industry are warranted or not. It*s a fairly complex area, i 25 and it would be pretty ditticult on a cese-by-case basis to do
- 26 1 a detailed asaessment of the technology time and time again.
2 And so one of the things that Research does is
~
3 provides tools, capabilities, procedures to make the whole 4 regulatory process more eiticient by beforehand, having worked 5 this stuti out.
6 COMMISSIONER ASSELSTINE: So it's really oriented 7 just towards the tools that are needed to evaluate the 8 industry research results.
9 MR. BARANOWSKY: Yes. A lot of the analytical 10 methods have been developed over the last several years, and 11 what*s happening now is the industry and the NRC are retining 12 these tools to meet their own needs. The industry to meet 13 their needs in terms of performing analyses so they can come 14 in here and hopefully make a change in the technical I 15 specifications, and the NRC converts tools that exist to meet 16 our needs in terms of evaluating the proposed modifications 17 that industry is trying to get.
l 18 COMMISSIONER BERNTHAL: It becomes a matter of 19 philosophy, though, whether the industry should also support 20 our ability to verity their results as well as provide the 21 support to obtain the results to begin with.
22 I wasHgoing to make the comment after you made your 23 comment, Commissioner Zech, and I fully agree with you, that 24 it's going to be interesting to see how we get the money to do 25 all this stuff with these massive budget cuts we're facing, l
I
. 27 1 and with the predominant burden of those cuts once again 2 talling on research in this agency.
3 MR. STELLO: I would suggest that we ought to have 4 that in a more systematic way in terms ot discussing how to 5 proceed with that. But without belaboring it, it the agency 6 didn't have this kind of capability, we sould be in very, very 7 ditticult shape to make many, many regulatory decisions.
8 And the one that stands out in my mind where I don't 9 know how we would have ever gotten out of the issue is back in l 10 1971 when we were in.the middle of the emergency core cooling 11 hearings. It we didn*t have our own code capability to do 12 checks on the models that were being developed by the 13 industry, I don't know how we would have been able to make an 14 assessment, a judgment, that those collection of codes were, 15 in iact, okay.
J 16 It-you had -- just using the industry code and 17 reviewing it and not having that independent capability, I t
18 think you would have been hard pressed to know you were all 19 right. But that*s just --
20 COMMISSIONER BERNTHAL: That doesn't answer the 21 policy question, though, of who ought to pay for it.
I 22 COMMISSIONER ASSELSTINE: That's right.
23 MR. STELLO: I was suggesting that sounds to me like 24 a very philosophical question. Who ought to pay our 25 salaries? Either the industry or the taxpayer, it seems to
_ . , _ , - _ __m., - - . , . .
. 20 1 me; it's going to be one or the other. But that's a ;
2 tundamental, philosophical question that maybe we ought to 3 have it in a more structured way.
4 CHAIRMAN PALLADINO: But I think it is a question S we're going to have to address, perhaps --
6 COMMISSIONER ASSELSTINE: Soon.
7 CHAIRMAN PALLADINO: -- as part of our budget 8 deliberation. But it's something we shouldn't forget 9 MR. STELLO: I was trying to make a very important 10 point, though, Mr. Chairman. I don't seen any distinction 11 between who should pay Harold Denton and his reviewers, or who 12 should pay research people. I don't see that t h e r e '. s 13 necessarily any difference between the two. We*re one and the 14 same --
15 COMMISSIONER ASSELSTINE: I*m not sure I see a 16 difference either, and I would say that when we're talking 17 about reviews of applications, the industry pays for Harold's 18 time and the time of his reviewers.
19 COMMISSIONER BERNTHAL: The philosophical question 20 was resolved long ago in the Nuclear Waste Policy Act for that 21 component of federal activities. The industry is not only 22 paying for the repositories; they are paying for the 23 , Department of Energy's activity and they apparently are going i 24 to pay, 11 perhaps indirectly, for the NRC's monitoring of
(
26 DOE's efforts.
l
39 1 'CHAIMMAN PALLADINO: And furthermore, there have 2 been statements made about other segments of our activity and 3 getting greater industry participation.
4 COMMISSIONEN 2ECH; I'd suggest we move along, 5 Mr. Chairman, 6 CHAIRMAN PALLADINO: Yes. That*s exactly where I
'I was goinD to. That's what I was trying to suggest, too.
8 Let*s do it.
9 COMMISSIONER ASSELSTINE: I had one other question 10 on the surveillance testing part, and that is, how does that 11 relate to,'and what assumptions are made in terms of, 12 maintenance programs? And isn*t that a part of this that you 13 need to consider as well? If you're looking at ettorts to cut 14 back on the frequency at doing these surveillance tests, don *t 15 you have to make some assumptions about the quality in which 16 the equipment is maintained, and have some basis for assurance 17 that those expectations are being met?
18 MR. DENTON: We've not coupled surveillance test 19 intervals with the quality of maintenance programs in the i 20 past; we*ve tended to have standardized tech specs for the 21 same systems and we require everybody to test it. But
.22 obviously 'in real life, someone who has a well-maintained, 23 reliable system needs to test it a lot less than someone who 24 as a poorly-maintained system.
25 COMMISSIONER ASSELSTINE; Yes.
t 30 1 MR. DENTON: I don't know, Sam, whether your group 2 looked at that or not I should mention that Sam and his 3 group got advice from Research and I&E and regional 4 inspectors, so we had a broad-based advisory group looking 5 over what Sam was finding. I guess, Sam, maybe you'd want to 6 summarize your findings and maybe answer some of the questions 7 that we've gotten.
B [ Slide.J 9 MR. BRYAN: Okay. What established the need for 10 TSIP? We had heard complaints about too many specifications, 11 less important ones distracting from the important- ones.
12 There were complaints about the size and complexity of tech 13 specs; presently, the document comprises about 500 pages.
14 Just finding where you need to be or want to be'is difficult.
15 The industry availability record is low when 16 contrasted with that of some foreign reactors having fewer 17 tech specs. Their impact on this availability was 18 questioned. We'd had complaints that tech specs are not I 19 operator oriented; they're written by engineers for engineers 20 to solve licensing problems, and they're placed in the control 21 room for operators to follow but they were not written with l 22 this in mind.
1 23 Then the findings published in NUMEG-1024, the 24 technical specification. Enhancing the safety impact. Some 25 test intervals are too short, some action statements were f
l I
s
4
. 31 1 punitive and unrelated to risk; equipment allowed outage times 2 are not optimum; some specifications may place the plant in a 3 less safe mode; some tests are unnecessary, causing 4 unnecessary personnel. exposure, and some unnecessary 5 requirements in technical specifications.
6 COMMISSIONER ASSELSTINE: On that non operator 7 oriented, there's no reason why they have to be non operator 8 oriented, is there? I get the sense from some plants that 9 they make a very strong ettort to involve their operators in 10 the drafting and design of the tech specs to make sure that 11 they are at least as compatible as possible with operational 12 needs. Others, 1 get the sense just as you described it; i
13 we've got a bunch of engineers _that write the tech specs, the 14 -operators aren't involved very heavily, they're given a 15 package of stuti and said, here's what you've got to run the 16 plant with. And with remarkably different results in terms of 17 the ability to operate the plant and run it reliably.
18 MR. BRYAN: Often you see in control rooms documents 19 that says, " interpretation," " tech spec interpretations,"
20 where they*ve taken the literal words of the tech specs and 21 sort of put it in a language that the operator can understand.
22 But there is no reason why they can't be operator l 23 oriented. We feel like this is one of our tasks; to help them 24 make it more readable and useable and clearer to operators.
25 COMMISSIONER ZECH: Good. I agree. The operators l
l l
l
. 32 I
1, in every utility should review those tech specs and should 2 understand them fully and be able to use them. And 11 they're 3 not in that language, then I think it's up to the utility to 4 do something about it. 1 usually ask on my plant visits about 5 this very thing, and ordinarily I get a pretty good answer, 6 that the operators do, indeed, pay special attention to those 7 procedures, and where they have questions they make efforts to 8 resolve them.
9 So I think it's important that they be operator 10 oriented, but as far as my experience to date, I think 11 . generally they are. You could well be right in the initial 12 ones written by engineers that have not been reviewed by 13 operators. But I submit it's the operator's responsibility to 14 reiew them, and I agree with Commissioner Asselst'ne i to that 15 extent; that-it should be done, and we should insist that it 16 be done.
17 COMMISSIONER ASSELSTINE: Yes. In fact, a lot of it 18 is the initiative of the utility itself, I remember talking 19 with the Florida Power & Light folks about Saint Lucie, and I 20 had the sense that in that case in particular, the utility 21 made a special effort to make sure that their tech ~ specs gave j 22 them what they needed to be able to operate the plant reliably 23 and effectively. And in fact, spent a good deal of time and I
24 ettort working on the tech specs before the plant went into 25 operation to assure themselves that they'd have something that
. 33 i i
i 1 they could work with and not something that was going to 2 create a lot of unnecessary problems.
3 MR. BRYAN: I guess I would say that there is a 4 spectrum of the quality of tech specs out there. We, in 5 talking with several operators, we'tound that their response
$ was that they need improvement in this-area. '
? COMMISSIONER ZECH: 11 they need improvement, it*s d my submission that the operator should initiate the 9 improvement. It they can*t understand the tech specs. .they 10 should do something about it. That*s utility responsibility, 11 in my view.
12 MR. BRYAN: I understand. But it means a change --
13 COMMISSIONER ZECH: 'I understand that, too. But 14 they shouldn*t just whine about it; they should do something 15 about it.
16 MR. DENTON: Sam, you might mention some of the 17 tacilities you did -- your task torce did visit, because they 18 didn*t do it from sitting in Bethesda; they went out and 19 talked to people.
20 MR. BRYAN: Yes, I'm going to cover that. So we 21 were chartered to reconsider the entire area of tech specs, 22 including philosophy, scope, content, depth, how to l
23 incorporate into licenses, how implemented by licensees,"and I
[ 24 how enforced by NRC.
25 tSlide.]
- - - , . . . . ~ ,
. 34 1 This slide covers the TSIP highlights. We were 1 1
2 formed December 31st, 1984; we established an advisory group 3 January 31st, 1985; Mr. Eisenhut was named Chairman; the 4 director appointed senior management from diverse NRC offices 5 to be members. They were named from IE, the regions, AEOD, 6 Research, ELD,'NRR, and we had an ACES member a' s Harold 7 mentioned, Mr. Glenn Reed.
8 And we met with the advisory group several times and 9 received valuable information from them. They were not asked 18 to concur in our report.
11 Throughout this ettort, we had a close working 12 interface with industry. Both our goals were to improve tech 13 specs, and we cooperated fully toward that end. It began with 14 a March 1st, 1985 meeting with industry reps and TSIP and 15 Mr. Denton present. Mr. Howell Tucker of the Duke Power 16 Company made an appeal for NRC not to go it alone. He cited 17 past experience whhre cooperative efforts had led to much 18 better solutions to problems. He said, in making this appeal,
'19 that he was backed by AIF, the owners' groups, EPHI and ANS.
20 Members of these groups were present at that 21 meeting. The Direct"C +1 NER agreed with the need to 22 cooperate and a c i e .> t g ( g ie i r otter. They organized their 23 activities under the AIF Committee on Reactor Licensing. They 24 created a Subcommittee for Tech Spec Improvement, and Mr. Alan s
25 Passwater of the Union Electric Company was named Chairman.
4
35 1 Each owners' group was represented in that i
2 subcommittee, and they established tour working groups to do 3 the ground work.
4 TSIP named a point of contact for each of these
$ working groups, and we met frequently with the tull 6 subcommittee and more often with the individual workers.
7 Our program plan, as every project has one, was 8 approved March 19th, 1985. This is the same slide, fourth 9 item. The program plan had tour objectives; to determine the 10 problems, develop alternatives to fix the problem; select the 11 best approach; and identity short-term fixes.
12 Our interim report on' problem. identification was 13 issued July 1st, 1985, and TSIP and AIF final reports were 14 issued containing conclusions and recommendations about 15 September 30, 1985. We held a joint TSIP/AIF meeting with the 16 Director of NHM, and presented recommendations on October 17 1st, 18 We had a trial application of the criteria using 19 Wolf Creek tech specs, and we began that. October 7th, 1985.
l 20 LSlide.]
21 This slide deals with our problem identification and 22 possible solutions. We identified problems by interviews, 23 document reviews, contractor assistance. And interviews, we 24 visited 13 plants, we talked to tive utility vendor ottices.
25 The people in those ottices were engineers and operators in
- 3Q 1 the plants. We talked to regional inspectors, resident 2 inspectors, AIF subcommittee members, public interest groups, 3 both GAP and UCS, and NRR reviewers.
4 And we sent questionnaires to NHR project managers 5 and I&E headquarters personnel to see it they had any problems 6 with tech specs, lWe paid special attention to the operators 7 and resident inspectors, the primary users of tech specs.
8 We found the operators responsive, and not all telt 9 that changes were needed, particularly at the older plants 10 which had custom tech specs. They*d lived with them for years 11 and knew what to expect, and they have' tar fewer tech specs in 12 them. And they really don *t trust NRC when they hear, "We*re 13 here to help you."
4 14 ELaughter,3 15 COMMISSIONER ASSELSTINE: Was that same-view shared 16 by the residents, by the way, at the older plants? You said 17 you talked to both residents as well-as the operators.
18 MM. BRYAN: Yes.
19 COMMISSIONER ASSELSTINE: They felt comfortable that 20 the tech specs for some of the older plants covered 21 everything?
22 MM. BRYAN: No. I think they felt that there were 23 improvements needed, t 24 COMMISSIONER ASSELSTINE: That*s what some have told l
l 25 me.
. 37 1 MM. BHYAN: We found t'hom supportive of taking some 2 things out of tech specs and cleaning up, and making wording 3 improvements, that sort of thing.
4 CHAIEMAN PALLADINO: How prevalent was this feeling 5 that pernaps you should just keep the old tech specs because 6 everybody*s familiar wi.i them, they set requirements clearly 7 and everybody knows what to do with them?
I 8 MR. BRYAN: I don't think that's a prevalent 9 feeling. I think that is a minority in the very older plants.
10 CHAIRMAN PALLADINO: Only in the older plants.
11 MM. BRYAN: The older plants. You xnow, the sixties 12 and early seventies plants perhaps.
13 COMMISSIONER ASSELSTINE: People with custom tech 14 specs don't want to go to standard tech specs.
15 MR. BRYAN: No, that's correct.
I '6 CHAIRMAN PALLADINO: They don't want' -- ?
17 COMMISSIONEM ASSELSTINE: Don't want to go to 18 standard tech specs.
19 MR. BRYAN: Typically they d'o n
- t .
20 CHAIRMAN PALLADINO: But the utilities didn't feel 21 that they should stay with the standard tech specs at the 22 present time, or some segment of it did not, or some 23 significant segment did not?
24 MR. BRYAN: I would say that the tech speos that are 25 out there now, most of them felt that a change was needed.
l
. 38 1 The resident. admonished us that 11 you wanted to 2 make sure that things that come out of tech specs get done, 3 you ought to find a way to enforce them; otherwise, they may 4 not get done.
5 As for document reviews, we looked at NUMEO-1024, 6 the old George rule, which proposed a split of tech specs. It
? came before the Commission back in the early eighties. We 8 found those very useful in problem discussion. And we also 9 looked at regulations, at some of the work of the Marvin Mann 10 task force which was the father of present-day tech specs, and 11 some of the older tech specs and some of the newer tech specs.
12 Contractor assistance. We obtained for tour 13 specific areas where we had open questions in mind. The 14 impact of the tech specs on operation, containment system, 15 bases evaluation, impact of new information on tech specs such 16 as source -term, leak before break principle, and screening of 17 tech specs for risk importance.
18 Within the scope of our review and as indicated in 19 our report, we found no safety problems that were compelling 20 enough for us to say, proceed immediately to fix it. We found 21 some problems that would improve safety 11 tixed, but in our 22 judgment were not significant enough to require 'ixing.
23 We did identify three problem a rea s . One would be a 24 lack of well-defined criteria for toch specs. There are no 25 clearcut criteria. We have guidance in an NRR office-letter
, . 39 I t ha t' 's ay s 11 the commitment is of such importance that no 2 change should be made without prior staff approval, it should 3 be reflected in the tech specs. This leaves it to the 4 judgment of each reviewer, and each reviewer will thinks his 5 own area is very important natura11'y, and they find their way 6 into tech specs. So they become a catch-all, 7 A second problem area was the human factors and 8 technical weaknesses. For example, inadequate bases, lack of 9 clarity, inadequate requirements, inappropriate action 10 statements and' problems with the definition of operability.
11 The third problem area was reluctance of the NRC 12 Stati to use tools other than tech specs. Requirements can be 13 imposed and regulations, tech specs, FSAR, license or through 14 documents such as the QA program tied to the license. The 15 staff *s choice has been to use_ tech specs for most 16 requirements, and'again, they become a catch-all covering a 17 spectrum of safety importance.
18 COMMISSIONER ZECH: But as I read the report, the 19 report suggests that perhaps we should be using other 20 regulatory tools'other than just the tech specs. So you've 21 got a difference between the report and the stait view, as I 22 understand it. How -- could you comment on that and perhaps 23 talk about enforcement and the flexibility and practicallty of 24 using other than the tech specs?
I 25 And how do you see the difference between the report
. 40 1 and the Stati position?
2 MR. BRYAN: The Stati position has always been that 3' they don't trust the 50.59 process, or they are unfamiliar 4 with it and don't use it.
5 COMMISSIONER ZECH: Do you agree with that? What*s 6 the rationale?
? MM. BRYAN: No, I don't agree with that. Things B that are in the Final Safety Analysis Heport are requirements, 9 and in order to change those, they must do a 50.59 review.
10 COMMISSIONER ZECH: Then what is the problem? Why 11 do you think that the Stait position has been to, you know, 12 turn them all into tech specs? This is something that was of 13 concern to me as I read the report.
14 MR. DENTON: Let me give a view on it. I have i
15 talked to people about it. I think when the tech specs were 16 so encompassing, we Just di dn' t -pay much attention to 50.59, 17 because it it were important, it got into the tech specs and, 18 therefore, so little was left to the Licensee --
19 COMMISSIONER ZECH: Well, that is part of the 20 problem, that's why the tech specs have grown so much.
21 MR. DENTON: Yes. So what was left to the 22 Licensee's discretion was odds and ends, and the whole focus 23 on the system was on the tech specs. And I think it we shift 24 back and reduce the amount that is in the tech spect, then we 25 should appropriately start looking more at 50.59, and I think
l
, 41 1 the fear, as I sensed it, Sam, among our inspection statt, was 2 that $0.59 reviews were a low priority typically in the 1
3 inspection modules and this sort of thing, and there was l 4 concern that as more and more significant stuft moved in 5 there, they should be accompanied by'looking.
6 So I think it's a philosophical sort of thing.
7 COMMISSIONER ZECH: But as least as far as you are 8 concerned, though, the report recommendation for using other 9 than tech specs is an appropriate one, and you think it is 10 workable as far as NRR is concerned, anyway?
11 MR. DENTON: Yes.
12 COMMISSIONER ZECH: Well, how about I&E? Can you 13 talk for I&E, too?
14 MR. DENTON: Well, I have talked to Jim Taylor about 15 it. I think he is concerned about the need to alter the 16 inspection scheme, that 50.59 would loom larger than it did 17 before. And so I think with appropriate management attention, 18 though, to how much inspection we give 50.59, it would work.
19 COMMISSIONER ZECH: I would hope so.
20 MR. BRYAN: Well, I have some more words to say on 21 that.
22 COMMISSIONER ZECH: I'm sorry. Go right ahead.
23 COMMISSIONER ASSELSTINE: And when you do, I hope 24 you can describe a little bit how the 50.59 process will work 25 in this particular case.
l 1
. 42 1 MR. BRYAN: All right. )
2 MR. BUTCHER: Sam, excuse me. If I might say 3 something about this. I have talked to several people about 4 trying to get a better feeling myself as to what the concerns 5 are, and I think that the concern tends to be on a conceptual 6 level When I talked to these same individuals who had
? expressed concern with Eniorcement using the other tools, when 8 I point out to them the specific things that we are talking I
9 about removing from the tech specs, it's always, "Well, that 10 doesn*t give me concern." I say, "We're going to take the 11 snubbers out." "Well, okay, 50.59 is fine for snubbers."
12 "I'm going to take fire detectors out." "Well, it's fine for 13 those."
14 When people deal with this on a conceptual level, 15 they say, well -- they have in their mind that what you are 16 going to do is rely on 50.59 or some other similar tool to 17 control the testing of the reactor protection system, and that 18 is not so.
19 You have to look at this issue on a substantive 20 basis, in context. You cannot deal with it on a conceptual 21 level so much, because you find that people don't communicate 22 well on a conceptual level on something like that.
23 COMMISSIONER ASSELSTINE: I do remember, however, 24 though, when we were looking at -- I think it was one of the 25 Grand Guli enforcement cases on the training cases, that there i
1
, 43 )
l I were some questions at the time about enforceability and the .!
2 basis for taking enforcement actions. Based upon some of 3 those PSAR-commitments or derivative commitments, the qual 4 card business - -my recollection is a little fuzzy on that, 5 but I seem to recall that there was a lot of discussion about 6 what we could do to enforce on some of those things,- and that 7 there were some gaps in our enforcement authority.
8 I think one of the things I want to make sure we 9 understand is what the bases for enforcement are and w h a 't the 10 differences are from having the things in tech spec to going 11 back and relying on some other ones of these alternatives. I 12 think it~might be useful to have OGC take a look at that as 13 well 14 COMMISSIONER ZECH: IL seems to me it ought to be 15 resolved, because it is my understanding that we have the to authority for enforcement, and certainly the flexibility for 17 enforcing our rules, other than that are in the tech specs, 18 COMMISSIONER ASSELSTINE: Certainly, ii it's in a 19 regulation, it is enforceable, i
20 MM. STELLO: Well, unless my memory is wrong, wasn*t 21 the qual card issue the issue that we took the enforcement 22 action on?
i 23 COMMISSIONEM ASSELSTINE: I think we did.
I I
24 MR. STELLO: And it was only an FSAM commitment.
25 COMMISSIONER ZECH: Well,-it seems to me that is
- 44 1 appropriate 2 MR. STELLO: Well, as I recall, . we made a major 3 issue out of an issue that was strictly an issue that was a 4 commitment in the FSAM, and our expectation is that those 5 things that are committed to in the FSAR, they will follow 6 them or they will use a 50.59 procedure as they modify them.
? And we rely on that.
8 I think now it is a matter of degree as to how much 9 more reliance, to what extent we should put things that are in 10 the tech specs into -- let's not just say 50.59. There are a 11 lot of other mechanisms available. If you have an ASME code 12 setting forth in surveillance requirements, we are already 13 embody use of the ASME code as a part of the license. Do we 14 need to then reiterate all those things in the tech specs? I 15 don't think that you need to do some of that.
i 16 We have talked about -- that is1 se of fire 17 protection, which is before you now, that you are considering, 18 the ability to put those kinds of things in the PSAM, rather 19 than make those a very long laundry list of, again, tech 20 specs, are they appropriate? Should they be? The Statt 21 judgment now is they ought not to be.
4 22 There are different mechanisms and vehicles that you 23 can use. 50.59 is one of them. There are others. You could 24 find a variety of ways in which to deal with the issue. I 25 don't think you want to stay with just one particular i
i 45 l 1 mechanism.
2 MM. VOLLMEM: I think on the subject of the 3 enforcement of the FSAM commitment, I think the view that we 4 have -- and I think it is supported by ELD -- is that they are 5 not directly enforceable. That is, the FSAM commitments, 11 6 somebody doesn't meet those commitments, that is not a 7 directly enforceable item. It a 50.59 change is made to that, 8 and it doesn't follow the appropriate 50.59 process, then one 9 could go back and find that that process was not used, and one 10 could enforce on that basis. But that requires, first of all, a
11 that we find out that the 50.59 process was not used 12 correctly, and since that occurs after the fact, much time 13 might elapse between the time one finds the problem and it 14 actually occurs.
15 And, in tact, I think it was indicated. earlier there 16 isn't a lot of attention given or regulatory time and 17 attention given to the 50.59 process. I think that is one of 18 the reasons i n the package we sent down to you on tire 19 protection that Vic just mentioned, we suggested putting into 20 the FSAR those things that are currently in tech specs, but we 21 included with that a license condition, that those things had 22 to be met by the Licensee, and that gave us our enforcement 23 vehicle. And without that, we really wouldn't have one. .
24 COMMISSIONER ASSELSTINE: Dick, why is it that the 25 FSAR commitment in and of itself is not directly enforceable?
i
,_ ... - , . _ . _ _ _ _ _ - . m-_ , - _ - - _ . . _
. 40 l
1 MR. VOLLMER: Well, you would have to get some --
l 4
l 2 you would have to discuss it with Guy Cunningham or the 3 Enforcement people, Leiberman and so on, and that*s the view i
4 they have.
5 MR. MALSCH: Yes, I think there are two reasons for 6 the concern about enforceability of 30.59. The first one is
? .just the way it*s worded. It's worded in terms of permission, 8 rather than restriction. It says the Licensee may make i
9 certain changes, may do such-and-such.
j 10 The other problem is the term " change." Now i
11 literally it says Licensee may make, let*s say, changes in the i
12 plant as described in the FSAM, unless that change involves a 13 tech spec change or a safety question. And that always 4
14 presents two questions for the Enforcement people:
15 First of all, is there a basis for enforcement when 16 the Licensee is not proposing to make any changes? As, for l
17 example, 11 a provision in the FSAM is in there, has always I ,
4
- 18 been in there, but an. inspector suddenly discovers that the 1
19 plant isn*t in accordance with the original FSAR. The 20 question then arises, do you construe the regulation narrowly 21 or in an enforcement sense broadly, so that unless he -- there 22 could be a violation, even it he isn*t proposing any change, J
23 merely because the plant is at variance with the FSAR.
i 1
24 I think in the enforcement case, the view may have 25 been taken that even though the Licensee isn*t proposing a ,
i
47 1 change, 11 the plant is not in fact in conformity with the 2 FSAR, t'h a t in itselfL is enough to invoke the due process
- 3 called by 50.59.
4 The next problem is in the review process, and that 5 is simply that it gives the Licensee a measure of judgment and 6 expert discretion as to whether 50.59 allows the action or 7 prohibits it, with us being given an inspection or audit 8 function over his process. And I think the problem is 11 you 9 approach tech specs from the perspective that everything that 10 you want the Licensee to come to you first for. approval before
! 11 doing it has to be in the tech specs, then you end up with a 12 gigantic tech spec document, because 50.59 doesn't quite get 13 you that tar.
I 14 If you are willing to say the Licensee ought to be 1
! 15 given a better manner of judgment as to what is important and 16 not important in the operation of his plant, then 50.59 might 17 suffice.
18 CHAIRMAN PALLADINO: Well, do you foresee that as we 19 change tech specs, we are strengthening our enforceability 20 from other areas, such as FSAH?
21 MR. STELLO: I think the point that Harold made is 22 that we certainly will be looking at the way in which we have 1
23 been r e tr i ewi n g 50.59 changes, in our awareness of the 50.59 24 changes. We almost have every plant in the country with two 1
25 residents, and I cannot believe that any change of
~ , - _ _ , ,,.,_.,,.,--,-___.,---,y_..-- . _c,_
r, , . _ . - - . - . - - , . -_ ~,--
. 48 ;
I i
i significance that is going to be made in the plant that is a 2 regulatory concern, that we have any significant lag time in 3 being informed of it, even before the change is made.
4 CHAIMMAN PALLADINO: But Marty makes the point that 5 there are some things that may be out of compliance based on 6 the FSAM that we don't have any enforceability on. Now if you
? put more of them in the FSAM, will we lose enforceability?
8 MR. STELLO: I have never heard an inspector tell me 9 that there is something in the plant that they think they need J
10 to have major compliance with the FSAM, that there has been 11 any real difficulty in getting the Licensees to do the things 12 that they have in the FSAM.
l i
13 CHAIMMAN PALLADINO: Well, that may be true.
14 MR. STELLO: Well, that is the real problem of what 15 goes on every day, and maybe there is some --
16 CHAIMMAN.FALLADINO: But it may change 11 more 17 things are put in the FSAM, rather than the tech specs.
. 18 MM. STELLO: Well, clearly we will want to pay more 19 attention .to the-50.59 process for sure. But I don *t foresee 20 that there is any real major problem in terms of our going in 1
l 21 and inspecting any particular utility and finding i
j 22 nonconformance with an application and making it an issue.
l l
And I think where we took the enforcement action at Grand Guli 23 24 is at excellent example of that. I assume that we'did that r 25 legally.
- 40 1 CHAIRMAN PALLADINO: I~think the point here is to 2 make sure that that*s covered.
3 MR. MALSCH: Yes, 1 think -- maybe the difficulty is 4 as long as there develops a common, firm understanding as to 5 what 50.59 requires.
6 COMMISSIONER ASSELSTINE: Hight.
7 MR. MALSCH: And then once you understand what it 8 requires -- and that's a uniform understanding -- then you can 9 decide -- then you can fit your program into what you 10 understand it to require. And.you can use 50.59 in the right i 11 circumstances, and as long as you understand what those
) 12 circumstances are and what the basis for enforcement is, and 13 with that in mind, you take some things out of tech specs and 1
I 14 put them into the FSAM, that's perfectly oka- as long as you 15 understand what you're doing.
16 CHAIRMAN PALLADINO: Well, let's move on to other 17 aspects of this tech spoo program. I think we have identified 18 an area that deserves attention. I gather it's an area that l
19 is going to get attention. I don't want to lose our time 20 completely because I am interested in coming back to the basic 21 question that I opened up with, and that is do we go 22 rulemaking, do we do policy statement? But I-don *t want to 23 interrupt the flow of your presentation.
, 24 MR. DENTON: I thini we had better skip Slide 8 and
- 25 maybe 12.
' 50 1 MR. BRYAN: How about going to Recommendation?
2 Slide'9.
3 MR. DENTON: We have used about two-thirds of our 4 time.
1
, 5 MR. ERYAN: I will try to move through this rather 6 quickly.
7 Slide 9, Technical Specifications. These were j 8 lifted verbatim out of our TSIF report. We recommend that 9 Commission policy statement should be-issued which defines the 10 scope and purpose of the tech specs, and encourages Licensees l
11 to implement a program to upgrade their tech specs. This is a 12 solution to one of our defined problems.
13 Defining the scope and pu* pose for new plants. Tech 14 specs will be smaller for the new plants, . r. d for the older 15 plants, 11 they elect to change, it will mean a split of tech l 16 specs, and they, too, will be smaller.
17 Tech specs that remain require all existing
! 18 procedures to change, including noticing in the Federal 19 Register, opportunity for public participation, and approv11 20 by NRC before the change is made.
21 For toch specs removed, there are still requirements 22 that must be complied with. However, changes can be made by 23 the Licensee under 10 CFM 50.59.
24 But first, a review and safety determination must be 25 made as to whether or not it involves an unreviewed safety
. - - _ _ _ . _ = _
51 1 question. It it doos, prior NHC approval is roquired, and tho 2 opportunity for public participation is required. It it does 3 not, the Licensee may make the change without prior NHC 4 involvement.
l 5 TSIP proposes no change to-this NHC review process.
6 We elected to recommend a policy statement instead of a rule
? change, to publish the Commission's scope, purpose and 1
8 criteria for what qualities as a tech spec, because we want to 9 gain experience with that criteria before we. codify it, j 10 COMMISSIONER ASSELSTINE: Does that mean, then, that 11 11 a Licensee 'as a large number of surveillance tests in 12 their tech specs now, that they believe should not be in there 13 under the criteria for tech spec content that you are 14 proposing, that they would then have to come in with a 15 proposed license amendment to ~ take all those things out?
16 Hight?
17 MH. BHYAN: That*s right.
18 COMMISSIONER ASSELSTINE: So it would be handled on 19 a case-by-case basis. All the policy statement would do would j 20 be to say the Commission is prepared to entertain requests for i
21 individual license amendments 11 they fit the following 22 standard?
3 23 P1 dHYAN: Exactly. .
24 CHAIMMAN PALLADINO: But one of the advantages, I am 25 told, of a policy statement is it can be implemented l
. 52 l l
l l' promptly. But 11 you, in each case, are going to have to havo 2 a hearing, will you really be implementing it more rapidly 3 than some other system?
l 4 MR. DENTON: I guess it*s not obvious we'd have to 4
1 5 have it in every case. We have approved --
6 CHAIRMAN PALLADINO: Well, I could see it an i
I
? invitation for our people to take positions 11 they feel that 8 we are. degrading the procedures for protecting public health 9 and safety.
10 MR. DENTON: I guess one example I remember was this 11 Westinghouse topical that proposed a major change in the 12 trequency of testing the reactor protection system that was J
l ,
13 solid state, and we had a technical review and had 14 consultants, and I think we offered an opportunity for 15 participation. I don't believe there was ever any interest to shown in that, is my memory on that.
17 MR. MALSCH: 1 think on a statistical basis, 18 something like one half of 1 percent of operating license j
i 19 amendments involve hearing requests.
t l 20 MR. DENTON: I think I have made that point in 21 Sholly before, that it*s very small.
i 22 CHAIRMAN PALLADINO: Well, it depends on how broadly 23 you change something that people have relied on for assuring i'
24 public health and safety, I
i 25 MR. DENTON: 1 think we are not opposed at all to l
l
. . 53 l
1 the rule. It was just the case that we need a little 2 experience. What has happened since September and-today is 3 that when Sam and his staff developed the criteria, there was
, 4 a question about, well, what*s really going to happen when you 5 apply these criteria? So since September they have applied it 6 at Wolf Creek. They took the Wolf Creek license, applied the 7 critoria, and they have a new set, and industry is doing the B same thing, So we wanted to be sure we saw what the impact of 9 applying this criteria was, and I think' after we understand I
10 that, t 'roposed rule and final rule would be the way to go, i 11 It* Just that in the way it getting Commission 12 endorsement of the idea, I think that*s what industry really 1
13 wants to know. Do you know at this table want to proceed with a
14 this project or not? And they*ve put a lot of ettort into 14 getting this far and we thought a policy statement is just 16 one way of showing that you support the general idea, and the
- 17 rule could follow as appropriate, i
18 So I don *t think we had any philosophical debate l
19 between the two; it*s just that we weren*t quite at a the rule 20 stage. We thought -- you might want to cite the statistics, i 21 Sam, for what happened when you applied the criteria to the 22 Wolf Creek tech spec.
23 MR. BRYAN: Ed, did you want to do that?
i 24 MR. BUTCHER: Yes, I have some numbers here. We 25 were going to talk about it in one of the follow-up slides, l
l l _ _ _ , _ , _ _ _ _ _ , _
e
, 54 1 but I can talk about it right now. I can just state the most ,
~
2 striking thing is that about 40 percent of the LCO*s that are l
3 in the tech specs now would no longer quality in these 4 criteria.
5 Of those tech specs that came out, it*s particularly 6 interesting when you look at them in terms of whether they 7 would have resulted in a plant shutdown under the existing 8 technical specifications. About 81 percent of the current 9 technical specifications which require a power limitation or 10 shutdown when you're outside the bounds of it would remain 11 nder these criteria. So it tends to verity at least that the 12 judgments weren*t necessarily made in a rigorous way, but 81 13 percent of them meet these particular criteria. So it 14 confirms the kind of judgment calls that have been made in the 15 past.
16 CHAIRMAN PALLADINO: I thought you said 40 percent 17 wouldn*t be --
18 COMMISSIONEH ASSELSTINE: Of the LCO's.
19 MR. BUTCHER: Forty percent of the LCO's.
20 CHAIMMAN PALLADINO: Now, what"s the 81 percent?
21 MR. BUTCHER: di the LCO*s that remain,.81 percent
- 22 of them previously would have required power reduction, so l
l 23 it*s a measure of the importance of the ones that remain. Of 24 the ones that did not require a power limitation, 64 percent 25 of those went out So the majority of things that were in the l
l l
I
o o $$
j 1 technical specifications which didn*t require you to change
] 2 the power level or shut the reactor down in fact would leave 3 the technical specifications, presumably because they are of l
4 lesser importance.
5 CHAIRMAN PALLADINO: Now, these LCO's that are 6 eliminated, don *t they appear anywhere? Or were they
! 7 eliminated because they*re unnecessary, or did they appear in 8 some c her document?
9 MH. BUTCHER: They're eliminated as LCO's, but you 10 have to keep in mind that everything that*s in the technical l
11 specifications, its genesis comes from the safety analysis, so j 12 it it*s in the technical specifications now, at least on a 13 conceptual level it exists in the safety analysis.
14 Now also, everything that*s in the technical 15 specifications tends to be written in detail into plant 16 procedures. So when you take it out of the technical 17 specifications it would remain in the FSAM and would remain in 18 the plant procedures and then be subject to the normal 19 controls for changing those documents before it would be 20 dropped altogether as a requirement.
21 CHAIRMAN PALLADINO: How thick is this FSARP
- 22 MR. BUTCHER
- Oh, it could be as many as 20 volumes t'
23 these days.
24 CHAIHMAN PALLADINO: Okay. Now, ii the LCO's are j 25 buried in that 20 volumes, are they going to -- is.anybody
SC 1 going to know about it unloss thoro's a student --
2 MR. BRYAN: Yes, we're going to know about it.
3 We're going to require that they tell us where they are going 4 in the FSAR and identity the location.
5 CHAIRMAN PALLADINO: You may have good intentions, 6 but the practicality of everybody knowing at every point that 7 this is an LCO I find ditticult to even imagine. Maybe I'm 8 less capable than.others.
! 9 MR. DENTON: I think it*s a question of degree in 1
i 10 that some of these original applications we had had many 11 volumes also. And it's only a question of what do we choose 12 to control through the amendment process. So there's always 13 been a lot of commitments the licensee made here and beyond 14 that either -- that we didn't focus on or didn't inspect that 15 much to.
16 I think we've had -- most of our enforcement issues, 17 not to pick that area back up, the most important issue in our 18 tech specs is probably safety limits. And I doubt it we*ve l 19 had very many safety limit violations at all, Vic, you might 20 know better than I do the history of this program, i
21 MR. STELLO: I think probably I would say TMI had 22 violated two limits.
! 23 MR. DENTON: .Well, yes. But moving beyond that 24 case, most of the things that we pick up are surveillance l
25 requirements, or was it surveilled at the right time. And I
o o 57 1
1 think back when the tech spec rule was written, things like 1
2 snubber -- we had a case where a plant was shut down because a 3 seismic snubber on a pump was found to be potentially 4 non-qualliied. So the pump is declared inoperable and then 5 the plant can't run with an inoperable safety system pump.
6 Well, some of those things were ones where we would 7 have granted relief in the old days for a day or a week until 8 somebody could do an analysis and look at it. With today's 9 more formal system, it's declared inoperable and the plant 10 shuts down or else they're operating in violation of the toch 11 spec, 11 that pump support is in the tech spec. It's a j
1 12 question of the extent of degree, I think.
13 CHAIEMAN FALLADINO: Well, all I was trying to 14 examine is what is the impact of moving it from one place to j 15 another. And incidentally, I'm not against simplification of i
4 16 tech specs, believe me. As a matter of fact, I remember in t
17 the early days when Marvin Mann came down to talk to the ACMS 18 about how toch specs should focus on only the important 19 things. ,
/
,7 " What I'm trying to-determine now is get a little bit 21 of feel for how important some of these things are that we're 22 taking out.
l 23 MR. DENTON: Maybe you ought to identify the kind of I
24 things that do move out, just so you.have a' teel for them.
25 MR. BHYAN: Let me say this, Harold. We considered l
i .
. $8 1 an intermediate set of specifications like tech specs and 2 something in between --
3 COMMISSIONER ASSELSTINE: Administrative controls or j 4 something else?
5 MR. BRYAN: They were supplemental specs, I think we 6 called them. We considered that and we concluded that that 4 'I was not the way to go. It's another whole new set of B criteria. The distinction as to where it goes and all those 9 considerations just made it very unwieldy and really it didn't 10 make a lot of sense, in our view.
11 So we felt that putting those things in the FSAR was 12 the best of the alternatives available to us.
13 COMMISSIONER ASSELSTINE: It would be useful either
- 14. now or maybe just a written summary of a comparison of what 4
15 you found on Wolf Creek. The kinds of things that would be in 16 under the standard tech specs, and then the kinds of things
.I 17 that would be moved over to the FSAR. Maybe you could do that l
18 in writing.
4 19 MR. DENTON: Well, where'we were going in this whole
- 20 project was a trial use of these criteria. Industry is 21 applying a trial, we're applying a trial. Once we straighten i
22 out what the differences were, 11 any, in how the criteria f
f 23 apply, then come back to you sometime with a total evaluation 24 including the Wolf Creek comparisons. And that's.why we sort l
l 25 of tilted toward a policy statement, is until we get these f
,. , - _ _ - _ . . _ - --- --e. , , _,,yr._.-,,.___y- _ . _ . . _ , . _, - , , - , _ _ . _ . , , , , , , - , .
_ , _ . , . _ _ - _ _ m. , - . . . . _ -
. 59 1 comparisons done and differences understood it was a big 2 premature.
u 3 We did want to get a chance to get the research 4 component in, and maybe since we're down to live minutes to go 5 maybe we.should at least make the point that they did develop 6 this approach and the approach is being done on a trial basis
? b3 both ourselves and industry. And we will report back to 8 you the results of that when it's completed, 9 CHAIRMAN PALLADINO: Just one more question on the 10 pros and cons of policy. Is it your intent, after so many
, 11 months, after_so many years, to come back and propose a rule?
1 12 MR. DENTON: I guess we'd propose a rule it we can 13 Justify it.
l 14 CHAIRMAN PALLADINO: And do you see any idea when 14 that might be? After a year's experience?
16 MR. BUTCHER: I wouldn*t think it would take that 17 long. I think we would do it in terms of the numbers of 18 plants. It we did a couple of these plants, or actually went 19 fully through the process we could propose to do it.
20 I don't see any reason why we couldn*t do it also in 21 parallel. There's no reason why we couldn*t start with a j 22 policy statement and then begin a rulemaking in parallel.
I i 23 It's just a question of whether we want to put our resources l
24 in the rulemaking or do we want to put it in actually applying 25 the new process. There's that issue also.
__ .. . . , _ _ . . . . - - _ _ _ - - _ _ _ . . . , _ _ _ , . _ ._ _ _ _ - - ~ _ - _ _ . _ _ _ _ _ , _ . . . _ _ _ _ - . . ._
. = _ -
. 00 1 MR. BHYAN: Yes. I would say, too, that we would 2 like to .e satisfied that we do have good workable criteria.
3 We can already see some places where a slight modification 4 might improve it. And once we*re satisfied that the criteria 5 really do stand up to the test, then I think we would be happy 6 to go ahead with the rule.
\ -
7 COMMISSIONEM BEHNTHAL: I see general counsel is at 8 the end of the table here, and I move to inquire how the 9 Commission would go about complying with the requirements it 10 imposed on itselt under the backtit rule. It we were, for-11 example, to amend our regulations in an attempt, in this case 12 apparently, to relax some of our requirements, what would t
13 prevent one of the so-called public interest groups from
) 14 coming in and arguing in court that we have not demonstrated 15 adequately that we've done a cost-benefit analysis to justify 16 that in terms of public health and safety?
17 MR. MALSCH: Well, it would depend on how the rule le was worded. It it was worded in terms of not requiring 19 licensees to do anything in addition but in a sense permitting 20 them to do things which they are not permitted to do now, then 21 you might conclude that it doesn*t require a backilt analysis 22 because it's not a backlit. It depends on what's done. How 23 the rule is drafted.
24 COMMISSIONEH BEHNTHAb: It is a change in the rules, 25 though.
l l
o 01 1 MR. MALSCH: It would be a change in the rules, a 2 change in the requirements. But if it doesn't impose any 3 additional requirements but merely allows a licensee to do j
4 some things now which he would not before have been permitted j $ to do, 11 you can read the backlit rule as saying that's not.a 6 b a c k i i t '.
l 7 COMMISSIONER'BEMNTHAL: But I assume that the 8 cost-benefit argument cuts both ways, and in fact, the 9 definition of a backiit in the backfit rule, as I recall the 10 words run something like any change in the operating or 11 -- what*s the other word -- a very, very broad definition of 12 backiit.
i 13 MR. MALSCH: That's right.
14 COMMISSIONER BERNTHAL: So why would we be able to 15 escape the requirement of cost-benefit, And I think once 16 we're into cost-benefit on this, then we*re in deep trouble.
- 17 MR. MALSCH
- Well, you first have to reach the j 18 question of whether the backiit rule applies to rules which 19 are designed to either maintain or relax requirements. If you 1
20 conclude that it does apply to that, then obviously it would
< 21 apply to this kind of a rule.
22 We've looked at it and concluded it only applies to 23 the imposition of additional requirements. And if that's the 24 case and you word the regulation so that it permits people to 25 do things which they're not now permitted to do but doesn't i
. G2 1 impose any additional burdens, you then conclude it's not a 2 backlit.
3 COMMISSIONER BERNTHAL lt doesn't sound like you't3 4 imbued with a surioit of confidence in the way you're 5 appraising this. But --
6 MR. MALSCH: No, actually I'm quite comfortable with 7 that interpretation; otherwise, the backilt rule makes no 8 conse, because the commission then would have disabled itself 9 trem ever making any safety relaxations or improvements, other 10 than the other direction.
11 MR. STELLO: I think in fairness tu Marty the -
12 question is perhaps you*ve got to take the next. step. After 13 having written a rule which perhaps you wouldn't have to do 14 all the backtit analysis because it becomes an elective rule, 15 one where a utility then could apply those criteria, when he f 16 comes back in and.the utility now asks to relax the tech specs 17 pursuant to taking that option, then do you really accomplish i
18 anything, because is it not going to be individual cases which 19 can then be contested, because won't it still be a licens-20 change, amenable to the amendmen't process and the Sholly 21 procedures.
s 22 COMMISSIONER BERNTHAL: Well, all I can say is that 23 this is go'ing to be a good test case and that it would be the 24 supreme irony 11 the Commission in its backiit rule succeeded 25 in preventi6gsitself from even relaxing regulations and
~
f
. 63 1 regulatory requirements.
2 MR. STELLO: Let me go on. 11 we wanted to write 3 the rule that would deal with both issues; that is, be able to 1
4 write a. rule phrased with the right language which would d ettectively mandate removing or taking out certain portions of 6 the tech specs so that we wouldn*t have to go through the 7 case-by-case analysis, then I think -- and let me ask Marty --
8 in that case I believe we would have to do a back11t analysis.
9 MR. MALSCH: 1 agree with that.
10 MM. STELLO: We would be required to do that, and wo 11 would. It we did it so it was mandated, we*d do a backtit 12 analysis. And we'd do one. You do them generically.
13 MR. MALSCH: The other question is: to what extent, 14 by rulemaking, you could realistically expect to eliminate the 15 need for contested hearings on contested issues. Rulemaking 16 is designed to resolve issues generically. I suspect a lot of 17 these tech specs involve plant-specific safety questions, and
'18 as a practical matter there probably is not a.whole lot you 19 can do by way of rulemkaing to eliminate those. It may go 20 some way in that direction.
21 MR. STELLO: And I think that's part of what we want 22 to understand before we finally come forward with a rule, 23 because you really-have two issues you're trying to resolve.
24 One is how to assure yourseli you have the right criteria, and 25 then 11 you*re. going to issue a rule, how could you_ issue the l
l s l
l
. 04 1 rule to save the burden both on us and the licensees and do 2 it generically, since that*s the real purpose. And that 3 requires I think a bit more thought before we're prepared to 4 make sure that the rule we come forward with accomplishes both 5 purposes. I don *t think we're ready to do that.
6 CHAINMAN PALLADINO: What did AIP think in terms of 7 rule instead of --
8 MR. STELLO: I think that they're looking down the 9 road. To the best of my knowledge, -- and I asked them just 10 before the meeting -- they aren't objecting to policy 11 statement as the right first step to take. At least that's my 12 understanding.
13 CHAIRMAN PALLADINO: Well, I think you've given us 14 some pretty cogent points on policy statement.
15 MR. STELLO: Yor. I would like to -- because I 16 think the real issue b e r. i n d all of this is how now, when we go 17 about making these changes, do -- that we have some tools that 18 we didn't have before that c a u r. e d us I think to make some of 19 thre judgments we made about what issues ought to be in tech 20 specs and what do they mean, And now we can start getting 21 some of the insights.
22 It we could have Wesearch at least go through some 23 of the' kinds of activities that we've been into in the last 24 tew years.
25 MR. MALSCH: Before I go, I just wanted to mention
65 l 1 that Commissioner Asselstine has asked us for a logal ~ opinion 2 on p r e c i s'e l y the question that Commissioner Bernthat asked 3 me. Does the backiit rule apply to --
4 CHAIMMAN PALLADINO: We asked you for the rationale 5 for an earlier decision that you gave.
6 MM. MALSCH: That's right, 7 COMMISSIONER ASSELSTINE: They gave the conclusion.
8 Waat I asked for was the rationale for it 9 CHAIRMAN PALLADINO: I know, but I'm interested in 10 what comes out, also.
11 Okay, let's go ahead.
12 MR. BAMANOWSKY: What we've heard discussed are some 13 of the administrative and technical issues associated with 14 technical specifications. And what I'd like to do is identity 15 the role that Research has had and is planning on having in 16 the technical specification improvement work.
17 The NRC and the nuclear industry over the last few 18 years have recognized that certain aspects of technical 19 specifications, such as allowed outage times and surveillance 20 test intervals, could be related to reliability of plant 21 systems and hence to risk at nuclear power plants.
22 The NRC took a look at technical specifications in 23 NUREG-1024 and concluded that the use of reliability and risk 24 analysis would be a worthwhile endeavor in terms of bringing 25 the proper tools to bear on evaluating technical i
- - - - - . -. - ---,--y , - , - - - _ . . - , , , , - - , ,,_.,..,_-y y.. _ - , , _ , , _ - 3%.-y-... _ . - -_ _e----
. 66 1 specifications.
2 Following publication of that document, Hesearch 3 planned a program called " Procedures for Evaluating Technical 4 Specifications," which is given the initials PETS, and that's 5 being carried out by the Division of Risk Analysis in 6 Operations and Research. That program has as its overall 7 objectives to develop methods and procedures which are based 8 on reliability and risk assessment techniques for evaluation 9 of techniques and-to provide tools that are associated with 10 that development which enhance the e t l i c i o n e.y , the 11 consistency, and the technical adequacy of the regulatory 12 review process, as people try to evaluate changes in technical l
13 specifications that are related to reliability and risk.
14 COMMISSIONER ASSELSTINE: You might want to go to 7
15 Slide 11, lo [ Slide.'J 17 MR. BARANOWSKY: I have just covered the overall 18 objectives of the program.
19 Specifically, the research program is directed at 20 the items in the second major bullet that I have identified.
21 We are developing and refining reliability analysis computer 22 codes, and one code that has been quite useful, which has been 23 developed and refined over the last few years, is FRANTIC. We 24 have used that for some plant-specific and generic' analyses, 25 and in particular, we used-the computer code during the Salem
, - - - - - . , . , . n ..- .--- n. , , _ , . _ _ _ . - - ,. .,.--.,,.,,.n .,,n-
G7 1 ATWS deliberations, and someone brought up an issue earlier 2 about maintenance and its relationship to surveillance 3 intervals, and I specifically recall looking at the impact of 4 the reactor trip breaker reliability, given proper maintenance 5 and improper maintenance and how that might atiect the 6 proposed surveillance intervals, and we found that, given i
1 7 proper maintenance, the surveillance trip breakers,-at least 8 in our generic analysis, could at least be maintained at the 9 current surveillance interval, and probably the interval could 10 be extended.
11 Since then, I believe analyses have been done and 12 reviewed by Westinghouse, in which that conclusion has been 13 confirmed.
14 COMMISSIONER ASSEbSTINE: But that sounds like, 15 then, it becomes terribly important to ensure that everybody lo has an adequate and an ettective maintenance program.in place 17 at all times, 11 that's what you're going to use as the basis 18 for setting those intervals.
19 MR. BARANOWSKY: For equipment that are particularly 20 important and that one can show the importance of the reactor 21 trip breakers, the maintenance and surveillance on that' 22 component is important. In fact, that*s one of the strengths 23 of this analysis, is that it can show you what*s important, 24 maintenance and surveillance on the type of equipment that one
.I 25 should be paying most careful attention to.
. 68 1 MR. STELLO: Let me make a point, though, to 2 emphasize something that is very, very important.
3 Most equipment, like trip breakers, to perform the 4 maintenance, one has to remove that breaker from service.
5 When you take a component out of service that was performing a 6 safety function, you change the vulnerability of that system, 7 so that it becomes more sensitive to tailures, which can 8 increase substantially the risk.
9 So just doing maintenance and doing it well is 10 clearly important, Put how often you do it and how much of a 11 risk you take by doing'it, since you clearly change the way 12 the system can oporate -- 11 I take a pump out of service or a 13 diesel generator to perform maintenance which requires me to 14 take.it apart, then I don't have that component available, 15 The more often I do that, the more frequent I do it, then 16 clearly I can create a decrease in safety by doing it more 17 trequently rather than less frequently.
18 So one has to look carefully at how to -- how often 19 to do those kinds of things in a plant.
20 MR. BARANOWSKY: We looked at that explicitly here, 1
21 and that's some.of the tradeoit types of things that we looked 4
22 at in the analysis, for instance. As one does more and more 23 surveillance and maintenance, the. opportunity for problems 24 grows, as well as the downtime associated with taking the 25 equipment out, and thus one has to trade oli those
. 69 1 considerations against the safety enhancement associated with 2- performing the surveillance.
3 COMMISSIONER ASSELSTINE: But that . takes you to the 4 next step, which is, do we need a much more ambitious
$ preventive and predictive maintenance program that focuses on 6 doing a lot of that work, much heavier work, during outages, 7 so that you're not taking equipment out of service during the 8 operational program?
9 MR. STELLO: That is a very good question that we 10 need to come to grips with, because we require a great deal of 11 surveillance and maintenance throughout the operating cycle of 12 the plant.
13 Question: Is that the right way to do i t'?
14 COMMISSIONER ASSELSTINE: Hight. Make sure it*s 15 overhauled during the outages, and then you don *t have to fool 16 with it while the plant is running.
17 MR. STELLO: and that*s the kind of insight you get 18 out of looking and using these tools.
19 COMMISSIONER ZECH: I think I've asked you to look 20 into that fairly recently, and I hope you*re doing that. I*ve 21 been most impressed by the number of surveillances we do and 22 the actual testing we do when the plant is operating, and it 2 '3 does seem to me a very important issue to look into.
j 24 MR. STELLO: That*s really one of the fundamental 25 issues that's being faced here.
t
+ 70 1 COMMISSIONER ZECH: Good.
2 MR. STELLO: Because the requirement for the 3 frequency of those surveillances are set in the tech spec 4 documents, and one has to ask the question whether we have, in
$ fact, decreased safety.
6 COMMISSIONER.ZECH: And as far as I'm' concerned, 7 this very issue has a very direct bearing on safety. Safety 8 of operations is involved here when we require various 9 testing and surveillances when the plant is running at a high 10 power level, up to full power. And we do that, of course, an 11 awful lot, and I'm glad that you are looking'into it. I think 12 it's very important.
13 COMMISSIONER ASSELSTINE: But the quid pro quo for l
14 decreasing some of those frequencies may well be doing much 15 more, doing more along the lines of what some of the European 16 countries and Japan do in terms of more aggressive outage 1
j 17 maintenance programs.
18 MR. STELLO: They are clearly doing it better.
19 COMMISSIONER ASSELSTINE: That's right.
20 MR. STELLO: Surely.
i 21 COMMISSIONER ASSELSTINE: And it almost looks like I
l 22 that has to be factored in.
23 COMMISSIONER ZECH: It has to be factored in, the 24 whole consideration.
25 CHAIRMAN PALLADINO. Well, I gather they are. I l
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71 !
I think it's a very important point and one not to be lost.
s 2 MR. BARANOWSKY: Let me point out that the research 3 activities here are directly related to the technical aspects 4 of the tech specs that were identified earlier.as nee' ding some 5 work, and I have identified the four of them, and I can say a 6 few words on each of them.
7 For instance, the limiting conditions for operations 8 or the LCOs. We have planned research to use FRA techniques 9 and models to provide a supplement to the deterministic 10 criteria, which is based primarily on single-failure criteria, 11 for determining what should be the content of the technical 12 specifications that should have LCOs.
13 Here, we*re concerned not only with completeness --
14 Is everything covered? -- but with overzealousness in perhaps 15 looking at the risk relevance of the things that are included 16 in there to see it we're either overregulating or perhaps 17 underregulating.
18 Another element of the tech specs that the research 19 program has focused on are the action statements, and here i
20 we're talking about the allowed outage times or the ACTS, a n d-21 the specific actions that Licensees take.when they. exceed the 22 allowed outage times, an important item because sometimes you 23 have a plant mode change, which is not always necessarily 24 advisable considering the type of equipment that might be out.
l 25 We've done a fair amount of work in developing the l
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72 1 methodology for looking at what are the appropriate allowed 2 , outage times and how to evaluate allowed outage time 3 submittals, and we are in the process at finalizing 4 recommended procedures for doing that.
5 The look at the risk implications of the action 6 requirements themselves is planned for Fiscal Year '86.
7 Surveillance requirements are another aspect of tosh B specs that the research program has been investigating. Here, i
9 we have developed the methodology which is typical of FRANTIC 10 -- other methodologies exist -- to look at surveillance test 11 intervals.
12 It's important to look at various competing 13 considerations and surveillance test intervals. We think we 14 have the methodology well in hand, and by doing some ' final 15 demonstration tests, we can develop procedures within the near 16 future which can be used, I think, to fairly quickly evaluate 17 surveillance test interval requirement proposals from industry 18 or NRC's own investigations.
19 COMMISSIONER BERNTHAL: Can't we find a better name 20 tor that program than FRANTIC?
21 CHAIRMAN PALLADINO: Yes. I was going to say, it i 22 joins a list of names like SCRAM, Turkey Point, Diablo Canyon.
23 MM. BARANOWSKY: Well, you know, in the old days, I 24 guess, people had a desire to come up with crazy n.a m e s , and it 25 stuck
l 73 1 We do have another research program which I'm just l
2 going to mention here for one second. That is the Operational 3 Safety Reliability Research Program, which looks at the 4 potential for blind spots existing in the current surveillance 5 or testing requirements.
6 The tech spec program, PETS, looks at the risks 7 associated with performing surveillances at different j
8 intervals. Our other reliability program looks at whether or 9 not the testing is sufficient or necessary and perhaps 10 addresses the issue that Vic raised earlier of, maybe we can 11 do some things at different times in the year, rather than 12- during plant operation.
13 It's related. I wanted to mention it. We can go 14 on with or without it. But it would be more otticient, of 15 course, to have that type of information.
16 Lastly, I think one of the important things that 17 we're doing in our research is providing the connection 18 between safety and the tech spec requirements through 19 reliability and risk censiderations. And I think that*s an 20 important point, because the question we're asking is: Why do 21 we have these requirements, and what are the requirements 22 based on; what are the acceptance criteria, so that Licensees 23 and people who carry out the requirements of the tech specs 24 have a clear understanding of where they're going with this, 25 and we have a clear understanding of why we have the i
. 74 !
l 1 requirement,_what its relationship to safety and risk is.
2 In summary, I would just like to point out that we 3 have activities ongoing, planned, to evaluate the quantity 4 _ aspects of tech spec requirements and evaluate the risk 5 relevance of technical specifications scope and content, and 4
6 that work should take place over the next 18 to 24 months.
? It*s ongoing.
8 COMMISSIONER ASSELSTINE: You mentioned on the 9 Operational Safety Reliability Research Program that we could 10 go on without it. Is this one of the ones that"s -- one of
' 11 the programs that is targeted for outs?
12 MR. BARANOWSKY: 1 don *t know, to be honest with 13 you, everything that*s being targeted for cuts. I'm just 14 saying that I would go on in-this program, even it we had no 1
15 requirement to do that. It would be more etticient to include 16 that type of activity.
17 COMMISSIONER ASSELSTINE: I was just wondering 11 18 that"s what the problem was.
19 MR. STELLO: The answer is no.
20 Let me try to summarize where we are. I have had a 21 role in tech specs, I guess it must be nore than ten years 22 now, Marty, since you and I chatted about the need to move.
23 While this may not be the perfect answer, an1' 24 certainly isn*t, I think it*s time to at least take a first 25 step.
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o 75 1 LCommissioner Bernthal leaves the hearing room.]
2 MR. STELLO: This policy statement i s a first step.
3 We have a lot to learn. I think that our real. legitimate 4 safety issues of how to get plants to be safer, both by making 5 sure. that where we need to add more, we've added more, and 6 where we have too much and we're detracting from safety, we 7 also take that action.
8 And I would urge that the Commission agree to move 9 forward with the policy statement, so that we can start to 10 make some measurable progress and changes. We.have just been 11 dealing with this issue too long, and we have to move it off 12 dead center, 13 I would not object to the Commission scheduling 14 something quickly to hear AIF and make sure that you hear 15 firsthand the industry views. I think 11 they have an issue 16 that they need to bring to your attention and you need to hear 17 how they view what we are doing and what their views are, I
- 18 would urge you to do that quickly, so that we can move on and 19 get it behind us.
20 We're finished.
21 CHAIRMAN PALLADINO: I think you make a good point.
22 I think AIF had asked to be heard, but we wanted to hear the 23 Stati first.
- l 24 I suggest we do follow your recommendation, have AIF 25 in as soon as we possibly can, and then encourage m y. ~
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. 70 1 Commissioners to address the paper as promptly as they 2 possibly can.
3 I think you*ve answered a number of questions 4 that were bothering me, especially with regard to the 5 relationship of a policy statement to rulemaking. I think I 6 understand that better than I did before and.am more prepared 7 to adopt it 8 COMMISSIONER '4 E C H : I agree. I think we ought.to 9 get on with it. We*ve talked about it long enough, and I 10 certainly thing it appropriate to hear from AIF, but I also 11 agree that we ought to put out the policy statement that the 12 Statt has recommended and move out.
13 COMMISSIONER ASSELSTINE: Well, I gather from the 14 schedule in the paper, the Stati is talking about, it would 15 take until about this summer to put the policy statement 16 together.
17 I certainly don *t have a problem with bringing AIF i
18 in. I still have a few other questions that I think I*11 just 19 send to the Stati in writing, and I would like to get a sense, 20 even it it's a crude sense, of what the Stati's current 21 understanding is that the difference would be in terms of tech 22 specs, depending upon what you've done so far in the Woli 23 Creek --
24 MM. STELLO: We*11 be happy to provide you with what i
25 we have on Wolf Creek next week.
l L
1 l
l _ _ _ __
. ?? l 1 COMMISSIONEN ASSELSTINE: That would be fine.
2 MR. STELLO: We*11 give you what we have. I don *t 3 see any reason why we have to have a finished product, as long 4 as you understand it*s not finished, that it*s preliminary.
/
5 COMMISSIONER ASSELSTINE: That*s fine.
6 MR. STELLO: What I would really like to do is to 7 start getting on with it and find out where we have our 8 weaknesses and our strengths and take advantage of our 9 strengths and start getting rid of the weaknesses.
10 COMMISSIONER ASSELSTINE: Okay. And I would like, I 11 think, to give you a few examples and have you trace through 12 the differences between -- on the enforceability side, how the 13 50.59 process would work, going through a few examples, so I 14 get a sense for what the difference would be, both in terms of 15 the inspection burden and the enforcement.
16 MM. STELLO: Now that, we can't answer, because 17 we*re g o i ,3 g to have to develop a new way in which we*re going 18 to go forward it we make this change.
19 We are committed to improving our 50.59 process as 20 part of it, but that will take time, too, as to how to do it, 21 because it is resource-intensive, and you don *t want to start 22 getting tied up with doing a lot more than we need to, and 23 especially involving Hesidents in the inspection process.
24 So we want to approach it with some caution. We 25 won *t have a complete answer.
i
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1 CERTIFICATE OF OFFICIAL REPORTER 1 l
l 2
3 4
5 This is to certify that the attached proceedings 6 before the United States NucIear Regu I a t ory Ccenmi ss i on in the 7 matter of. COMMISSION' MEETING e
9 Name of Proceeding: Briefing on Status of Task Force on Technical Specifications (Public Meeting) 10 11 Docket No.
12 Place: Washington, D. C.
13 cate: Tuesday, January 21, 1986 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
la g
(Signature)- /f g ,, , ,
Q ,,
(Typed Name of Reporter) Su$ anne B.' Young 20 21 22.
23 Ann Riley & Associa'tes. Ltd.
24 25
NRR TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM i
COMMISSION BRIEFING l
JANUARY 21, 1986 i i
1
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4 4
I i
_ . . . . ~ - _ _ _ _ _ _ _ _ _ _ _ _ , _ . _ , _ . . . . _ _ , - _ _ _ _ _
1 HISTORY OF TECHNICAL SPECIFICATION DEVELOPMENT ATOMIC ENERGY ACT OF 1954 1956 10 CFR 50.36 ISSUED
- 1962 10 CFR 50.36 AMENDED, APPENDIX A ADDED 196810 CFR 50.36 AMENDED TO MAKE TS A SEPARATE DOCUMENT SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS LIMITING CONDITIONS FOR OPERATION (LCOs)
SURVEILLANCE REQUIREMENTS DESIGN FEATURES ADMINISTRATIVE CONTROLS i .. .-
1 HISTORY OF TECHNICAL SPECIFICATION DEVELOPMENT (CONTINUED) 1974 STANDARD TECHNICAL SPECIFICATIONS (STS)
LIMITING CONDITIONS FOR'0PERATION (LCOs)
ACTION STATEMENTS SURVEILLANCE REQUIREMENTS (TESTING)
BASES 1979 ALAB 531
" TECHNICAL SPECIFICATIONS ARE TO BE RESERVED
~
l FOR THOSE MATTERS AS T0 WHICH IMPOSITION OF RIGID CONDITIONS OR LIMITATIONS UPON REACTOR OPERATION IS DEEMED NECESSARY TO OBVIATE THE POSSIBILITY OF AN ABNORMAL SITUATION OR EVENT GIVING RISE TO AN IMMEDIATE THREAT TO THE PUBLIC HEALTH AND SAFETY " (ALAB-531) l l
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3 1
GROWTH IN TECHNICAL' SPECIFICATION REQUIREMENTS TOTAL SURVEILLANCE TESTS
- PLANT (LICENSE DATE) N0, 0F LCO'S REQUIRED PER YEAR SURRY 1 (1972) 19 SYSTEMS 390 MULTIPLE LCO'S COOK 2 (1977) 119 9,700 SEQUOYAH 1 (1980) 136 15,000 CALLAWAY 1 (1984) 110 14,000
- BASED ON A SAMPLING OF SIX SYSTEMS: RPS, ACCIDENT MONITORING INSTRUMENTATION, FIRE DETECTION INSTRUMENTATION,- LIQUID RADWASTE MONITORING INSTRUMENTATION,. PRESSURIZER AND PORV, AND LIQUID EFFLUENTS.
8
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NRR TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM PHASE I PROBLEM IDENTIFICATION AND RECOMMENDATIONS, TSIP REPORT PHASE II IMPLEMENTATION, TSCB f
. 5 l
NEED FOR TSIP T00 MANY SPECS - LESS IMPORTANT ONES THUS DETRACTING FROM IMPORTANT ONES SIZE AND COMPLEXITY OF TS INDUSTRY AVAILABILITY RECORD NOT OPERATOR ORIENTED FINDINGS OF NUREG-1024 " TECHNICAL SPECIFICATIONS-ENHANCING THE SAFETY IMPACT" l
1 l
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6 1
TSIP HIGHLIGHTS FORMED DECEMBER 31, 1984 ADVISORY GROUP ESTABLISHED JANUARY 31, 1985 INDUSTRY MEETING WITH MARCH 1, 1985 TSIP/ DIRECTOR NRR PROGRAM PLAN APPROVED MARCH 19, 1985 INTERIM REPORT ON PROBLEM JULY 1, 1985 IDENTIFICATION ISSUED TSIP AND AIF FINAL REPORTS SEPTEMBER 30, 1985 ISSUED JOINT TSIP/AIF MEETING WITH OCTOBER 1, 1985 DIRECTOR, NRR, TO PRESENT RECOMMENDATIONS TRIAL APPLICATION OF CRITERIA OCTOBER 7, 1985 INITIATED - WOLF CREEK TS i
4 PROBLEM IDENTIFICATION AND POSSIBLE SOLUTIONS
- IDENTIFIED PROBLEMS BY INTERVIEWS, DOCUMENT REVIEWS, AND CONTRACTOR ASSISTANCE FOUND NO. SAFETY PROBLEMS REQUIRING IMMEDIATE ACTION 3
IDENTIFIED THREE PROBLEM AREAS
~
i LACK OF WELL-DEFINED CRITERIA FOR TS HUMAN FACTORS AND TECHNICAL WEAKNESSES RELUCTANCE OF THE NRC STAFF TO USE TOOLS OTHER THAN TS CONSIDERED A WIDE RANGE OF POSSIBLE SOLUTIONS ,
DEVELOPED EVAL 0ATION MATRIX TO GAIN INSIGHTS J -
DREW CONCLUSIONS AND RECOMMENDATIONS
__ . _ ..m_ , , _ , _ . . _ , _ _ _ _ _ _ _ _ _ . _ _ _ _ . . , _ ._-,..,________._______.._m. , _ ~ . , __,, . . . - , _ ,. - . . . _ _ _ . , . , _ _ _ .
. b TECHNICAL SPECIFICATION IMPROVEMENT PROJECT CONCLUSIONS
"(1) THERE ARE NO ACUTE SAFETY CONCERNS OR RESOURCE BURDENS WHICH WOULD SUPPORT IMPOSING A MANDATORY PROGRAM OF CHANGES TO THE TECHNICAL SPECIFICATIONS OF OPERATING REACTORS.
(2) IMPROVEMENTS IN BOTH SAFETY AND RESOURCE REQUIREMENTS CAN BE REALIZED THROUGH A FOCUSED EFFORT TO CORRECT HUMAN FACTORS AND OTHER TECHNICAL WEAKNESSES IN THE TECHNICAL SPECIFICATIONS.
(3) DEFINITION OF THE SCOPE AND PURPOSE OF TECHNICAL SPECIFICATIONS WOULD PROVIDE USEFUL GUIDANCE TO THE NRC AND SHOULD LEAD TO SUBSTANTIAL NRC RESOURCE SAVINGS.
(4) MAXIMUM SAFETY ENHANCEMENT WILL REQUIRE PARTICIPATION OF LICENSEES AND OTHER INTERESTED GROUPS.
(5) DEFINITION OF THE SCOPE AND PURPOSE-OF TECHNICAL SPECIFICATIONS IS AN IMPORTANT INCENTIVE FOR INDUSTRY PARTICIPATION IN A PROGRAM TO IMPROVE TECHNICAL SPECIFICATIONS."
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TECHNICAL SPECIFICATION IMPROVEMENT PROJECT RECOMMENDATIONS
"(1) A COMMISSION POLICY STATEMENT SHOULD BE ISSUED WHICH DEFINES THE SCOPE AND PURPOSE OF TECHNICAL SPECIFICATIONS AND ENCOURAGES LICENSEES TO IMPLEMENT A PROGRAM TO UPGRADE THEIR TECHNICAL SPECIFICATIONS."
CRITERIA FOR TS CONTENT AN INSTALLED SYSTEM THAT IS USED TO DETECT, BY MONITORS IN THE CONTROL ROOM, A SIGNIFICANT ABNORMAL DEGRADATION OF THE REACTOR COOLANT PRESSURE BOUNDARY.
A PROCESS VARIABLE.THAT IS AN INITIAL CONDITION OF A DBA ANALYSIS, A STRUCTURE, SYSTEM, OR COMPONENT THAT IS PART OF THE PRIMARY SUCCESS PATH OF A SAFETY SEQUENCE ANALYSIS AND FUNCTIONS OR ACTUATES TO MITIGATE A DESIGN BASIS ACCIDENT.
- 10
)
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l TECHNICAL SPECIFICATION IMPROVEMENT PROJECT RECOMMENDATIONS (CONTINUED)
"(2) THE NRC SHOULD GIVE INCREASED ATTENTION TO CHANGES MADE BY LICENSEES USING THE 10 CFR 50.59 PROCESS.
(3) THE NRC SHOULD REVIEW AND REVISE THE STANDARD TECHNICAL SPECIFICATIONS TO CORRECT HUMAN FACTORS AND OTHER TECHNICAL WEAKNESSES THROUGH A PROGRAM OF TECHNICAL ASSISTANCE AND DEDICATED IN-HOUSE TECHNICAL RESOURCES.
(4) THE NRC SHOULD ENCOURAGE THE CONTINUED DEVELOPMENT AND APPLICATION OF PROBABILISTIC RISK ASSESSMENT METHODS TO ADDRESS TECHNICAL SPECIFICATIONS REQUIREMENTS."
~
. 11 i
RESEARCH IN SUPPORT OF TECH SPEC PROGRAM s
PETS RESEARCH PROGRAM
, DEVELOP METHODS AND PROCEDURES BASED ON RELIABILITY AND RISK TECHNIQUES TO EVALUATE TECH SPEC REQUIREMENTS PROVIDE TOOLS WHICH ENHANCE EFFICIENCY, CONSISTENCY, AND TECHNICAL i.DEQUACY FOR REGULATORY REVIEW PROCESS SPECIFIC RESEARCH TO SUPPORT TECH SPEC PROGRAM
' DEVELOPMENT, REFINEMENT OF RELIABILITY ANALYSIS' COMPUTER CODES (E.G. FRANTIC)
LCOs - SUPPLEMENT DETERMINISTIC CRITERIA FOR TECH. SPEC CONTENT:CCMPLETENESS AND RISK RELEVANCE ACTION STATEMENTS METHODOLOGY TO EVALUATE A0T AND RISK IMPLICATIONS OF ACTION REQUIREMENTS SURVEILLANCE REQUIREMENTS - METHODOLOGY TO EVALUATE SURVEILLANCE TEST INTERVALS: OSRR EVALUATING POTENTIAL " BLIND SPOTS" IN SURVEILLANCE TESTING BASES - RELATING TECHNICAL SPECIFICATION REQUIREMEllTS l TO RELIABILITY ~AND ULTIMATELY TO RISK 4 e.i e - ..m . ~- ,-,-m--
12 TECHNICALSPECIFICATIONC0ORDINATIONBRANCH (TSCB)
FUNCTIONS EVALUATION AND TRIAL PRACTICAL APPLICATION OF TSIP RECOMMENDATIONS COORDINATION AND OVERSIGHT OF ALL NRR TECHNICAL SPECIFICATION ACTIVITIES TSCB ORGANIZATION PROJECT TEAMS (BY VENDOR)
PROVIDES POINT CONTACT AND FOCAL POINT FOR-OWNERS GROUPS ON TECHNICAL SPECIFICATION ISSUES PARALLELS NRR ORGANIZATION TO FACILITATE C0 ORDINATION AND OVERSIGHT i
L
e ONG0ING ACTIVITIES TRIAL USE OF TSIP CRITERIA
-MEETINGS WITH INDUSTRY OWNERS GROUPS AND AIF SHORT TERM IMPROVEMENTS TO EXISTING STS FIRE PROTECTION TECHNICAL SPECIFICATION ACTION STATEMENTS FOR MISSED SURVEILLANCE TESTS BWR RPS SURVEILLANCE INTERVALS AND A0Ts (NEDC-30851P)
BWR ECCS INSTRUMENTATION SURVEILLANCE INTERVALS AND A0Ts (NEDC-30936P).
EVALUATION OF COMMENTS ON TSIP REPORT
14 FUTURE ACTIVITIES DETAILED IMPLEMENTATION PROGRAM PLAN - 03/01/86 PROPOSED COMMISSION POLICY STATEMENT - 06/01/86 ULTIMATE LONG TERM OBJECTIVE "A COMPLETE REWRITE / STREAMLINING" 0F THE EXISTING STS BASED ON THE RECOMMENDATIONS OF THE TSIP REPORT
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