ML20195J351
| ML20195J351 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19313B231 | List: |
| References | |
| NUDOCS 8801270301 | |
| Download: ML20195J351 (14) | |
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ENCLOSURE
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NRC STAFF RESPONSE
- TO NUMARC TECHNICAL SPECIFICATIONS WORKING GROUP KEY IMPLEMENTATION ISSUES i
FOR i RESTRUCTURED TECHNICAL SPECIFICATIONS JANUARY 1988 4
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( CONTENTS STAFF RESPONSE TO INDUSTRY'S POSITIONS ON KEY IMPLEMENTATION ISSUES PAGE
- 1. INTRODUCTION 1
- 2. PLANT-SPECIFIC RESTRUCTURED TECHNICAL SPECIFICATIONS 1
- 3. APPLICATION OF 10 CFR 50.91 AND 10 CFR 50.92 (SHOLLY) 4
- 4. REQUIRED EXEMPTIONS FROM THE REGULATIONS 6
. 5. CONTROL OF REQUIREMENTS REMOVED FROM TECHNICAL SPECIFICATIONS 8 i
- 6. CONTENT AND CONTROL OF IMPROVED BASES 10 l 1' I
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( 1. INTRODUCTION This enclosure provides NRC's response to NUMARC's November 10, 1987 letter to Dr. Thomas E. Murley titled "NUMARC Technical Specifications Working Group Key Implementation Issues for Restructured Technical Specifications." In that letter the NUMARC Technical Specifications Working Group described several issues that are the key to implementing the Technical Specification Improvement Program. The NUMARC working group requested NRC review and approval of the positions taken jointly by the four Nuclear Steam Supply System (NSSS) vendor owners groups on these issues.
The following sections document NRC's review of the industry's position on each key implementation issue. The common focus of the industry's positions and the NRC staff's responses is on how to structure the process of converting to the new Standard Technical Specifications (STS) so as to conserve both industry and staff resources and thereby ensure that the safety and operational benefits to be derived from the conversion to the new SlS will not be outweighed j by the implementation costs.
- 2. PLANT-SPECIFIC RESTRUCTURED TECHNICAL SPECIFICATIONS l
l The staff previc W ,v addressed this topic in a letter from R. W. Starostecki, NRC, to R. L. Gill, B&W Owners Group, "Staff Assessment Report on B&W Owners l Group Technical Specification Improvement Program," dated September 4,1987.
In that letter the staff indicated that the general principles currently used for developing near-term operating license technical specifications (TS) based on vendor STS should serve as the model for plants referencing the vendor owners group's revised STS that reflect the Commission's interim Policy Statement on Technical Specification Improvements, February 6, 1987, published in the Federal Register (52 FR 3788). Specifically, the staff indicated that any plant referencing the improved STS should adopt the requirements of the new STS in their entirety except to the extent that:
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Plant-specific design considerations would justify otherwise, or Hardware, structural, or organizational changes from previously approved conditions would be required to conform to the new STS.
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! The staff took this position in order to promote the benefits of standardization, thereby conserving both industry and staff resources while still providing adequate flexibility for plant-specific considerations as they relate to overall safe plant operation.
Industry Position The NUMARC working group agrees that it is in the nuclear industry's interest l to achieve, to the extent practicable, standardization of TS. The area of principal focus is the degree to which standardization should be required. The following very general ground rules were proposed by the group:
Witn respect to individual technical specification requirements, the licensee may choose to either retain his current specification in its entirety or to adopt the new specification in its entirety for the plant '
specific requirements that can be made identical to the new STS; .
For plant specific requirements that cannot be made identical to the new STS because of the specific plant design or accident analysis, the licensee may choose to either retain his current specification or modify the appropriate new specification.
If a licensee chooses to retain a current requirement in lieu of adopting the new version of that requirement, the licensee shall modify the curreat requirement to include the human factor improvements that have been
( approved by the NRC.
The working group also offered the following examples of how these ground rules would be applied by stating that a licensee may elect not to adopt the requirements of the new STS in their entirety when:
(1) Plant-specific design considerations would justify otherwise, or (2) Hardware, structural, or organization changes from previously approved conditions would be required to conform to the new STS, or (3) Based on past operating experience, the plant-specific requirement would remain; or (4) Based on a previously approved plant-specific amendment, this provides a sufficient basis for retaining the existing or using another requirement.
It is not clear whether the working group proposed these examples as specific criteria for implementing its more, general ground rules or merely as examples with the final decision to be a subjective determination by individual licensees.
t Staff Response In evaluating the conversion to the revised STS, the staff will look not only at which Limiting Conditions for Operations should stay in the TS but also at the substance of specific technical requirements. The staff believes that the industry standard should be adopted unless a compelling technical justification exists for deviating from it. Experience has shown that unnecessary plant-specific deviations from the standard generic TS have resulted in a needless waste of both industry and NRC resources without a commensurate improvement in safety.
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The staff believes that allowing licensees, as a general rule, to arbitrarily choose between their current TS requirement or adopting a similar requirement in the new STS would not be the most resource efficient way to implement the If a plant-specific alternative to an STS requirement can be new STS.
adequately justified on a technical basis then it can be used and the Bases for the requirement should clearly state why it is appropriate. Absent adequate technical justification, licensees should adopt the requirements in the new STS and its Bases.
The staff has developed the following criteria which provide guidance to licensees on what the staff will accept as adequate justification for deviations from the new STS. These criteria are similar to the examples cited by the industry. Specifically, any plant referencing the new STS should adopt the requirements of the new STS in their entirety except to the extent that:
Plant-specific design or safety analysis considerations would justify
- otherwise, or Hardware, structural, or organizational changes from previously approved conditions would be required to conform to the new STS, or On the basis of past operating experience, the existing plant-specific requirement can be shown to provide an equivalent degree of protection to that provided by the new STS, or A plant that currently uses STS has been granted a plant-specific arrendment (based on one of the criteria above) that approved a deviation from a requirement in the new STS.
- 3. APPLICATION OF 10 CFR 50.91 AND 10 CFR 50.92 (SHOLLY NOTICES)
Implementation of the Commission's interim Policy Statement on Technical Specification Improvements will involve significant changes to TS that will be subject to the amendment process. Because 10 CFR 50.91 requires that a brief
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description of license amendments be prenoticed and because implementing the new STS will involve many changes, the prenotice process could impose a significant administrative burden on both the NRC staff and licensees.
Industry Position The industry proposed the following approach to cddress the prenoticing requirements for individual license amendments as they apply to the conversion to the new STS:
' The criteria embodied in the Commission's policy defining the content of .
Technical Specifications should be recognized by the Staff as an acceptable basis for no significant hazards considerations determination.
A generic no significant hazards determination for each of the four vendor STS should be permitted to be used by individual licensees wishing to implement the new STS. Only changes to the plant TS that are different
. than the requirements in the new STS would need to be discussed.
Only broad overview descriptions of changes conforming to the owners groups specifications need to be included in the amendment submittal by the licensees for their specifications and evaluated in accordance with !
the regulations. <
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Licensees wishing to implement changes not present in the new STS shall describe those changes separately in accordance with the regulations.
Staff Response 1
The staff agrees that a generic Sholly finding would minimize the expenditure l
of resources on the part of the NRC and individual licensees and still ensure that the requirements of the Sholly notification process are satisfied. The ]
staff also agrees that a generic Sholly finding can be made and is pursuing 1
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f this approach with the NRC's Office of the General Counsel to define an acceptable basis for the generic finding. Following are some general conclusions resulting from the staff's work to date:
' It is doubtful that the Commission Policy Statement defining the content of TS could serve as the sole basis for a finding of no significant hazards consideration.
It is possible to have a topical report (e.g., STS topical report) prenoticed along with the staff's generic finding of no significant hazards determination so that individual licensees could reference it for identical changes. However, each amendment request from participating licensees must be prenoticed.
Similar TS changes can be grouped and a single justification for that group of changes can be written (an example is a recent Northern States
. Power amendment request for Prairie Island containing several related change requests.)
Changes made by licensees that are not addressed in the new STS would have to be addressed separately in the prenotice.
- 4. REQUIRED EXEMPTIONS FROM THE REGULATIONS l
10 CFR 50.36a requires that each license authorizing operation of a nuclear power teactor will include TS that, in addition to requiring compliance with i applicable provisions of 10 CFR 20.106, require operating procedures for the control of effluents and semi-annual reports on the release of effluents.
The rule also requires that licensees maintain effluent releases as low as is
! reasonably achievable.
t The Commission's interim Policy Statement states:
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The Commission recognizes that certain amendments to the regulations may be necessary before the content of Technical Specifications can be limited entirely to the purpose defined above as embodied in the associated criteria (e.g., $50.36a on Radiological Environmental Technical Specifications (RETS) would have to be amended before radiological effluent controls can be transferred from the Technical Specifications to other documents). The Staff will initiate in parallel with issuance of this Policy Statement the rule changes necessary to fully implement this Policy Statement.
Industry Position Because rulemaking has not been effected that would allow licensees to relocate radiological effluent control requirements from the TS, the NUMARC letter provided a rationale that industry believed would justify granting individual .
license exemptions from the requirements of 10 CFR 50.36a.
Staff Response The staff does not believe that processing the large number of individual license exemptions called for in the industry's position is the most resource-effective way to achieve the Commission's objective of eliminating unnecessary detalici requirements from the TS. The staff recognizes that a rulemaking action can be very time consuming and may not be completed before the new STS are r<ailable for implementation. Therefore, the staff is pursuing as an alternative approach, including more general programmatic requirements in Section 6.0 of the TS and leaving the more detailed requirements, currently in the Limiting conditions for Operation section of TS, to be controlled and documented in the Offsite Dose Calculation Manual. Such an approach is consistent with 10 CFR 50.36a and could be implemented immediately without waiting for the new STS to be completed. The staff believes that this approach could be implemented in parallel with, or as an alternative to, a 10 CFR 50.36a rulemaking action.
- 5. CONTROL OF REQUIREMENTS REMOVED FROM TECHNICAL SPECIFICATIONS The Commission's interim Policy Statement provides a set of objective criteria for determining which regulatory requirements and operating restrictions should be included in the TS. Implementation of the Policy Statement will result in the transfer of many requirements from the TS to other documents such as the Final Safety Analysis Report (FSAR), plant operating / surveillance procedures, or program plans. Positions implemented through these documt.nts typically do not require a license amendment or NRC approval before changes are made.
The Commission's interim Policy Statement states:
When licensee's submit amendment requests based on the Policy Statement, they are to identify the location of, and controls for, the technical and administrative requirements relocated from the TS.
Industry Position The NUMARC working group has developed guidance on the control of requirements to be removed from the TS and iden'Lified several possible locations for relocated requirements (similar to those identified in the Commission's interim Policy Statement). Although alternative locations were identified, no specific
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guidelines or criteria were offered for choosing any of the alternatives.
Rather, the NUMARC working group merely stated that licensees will need to identify (a) which document will include the relocated requirements and (b) the control mechanisms used to process changes to those documents. It indicated that new documents need not be developed for the sole purpose of addressing requirements relocated from the TS. The group did identify several considerations which licensees should take into account to ensure that all requirements contained in Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) are addressed.
The NUMARC working group stated that "to the extent that plant programs are
( described in the FSAR, changes to those programs can be made in accordance with the requirements of 10 CFR 50.59 unless another regulation is controlling." In
f addition, it noted that the STS place administrative controls (e.g., requirements for onsite and offsite reviews) on changes made pursuant to 10 CFR 50.59 and on certain changes to procedures and programs.
Finally, the NUMARC working group noted that such preimplementation and postimplementation review / audits should be reviewed for completeness and adequacy and, where necessary, strengthened to ensure that relocated requirements are adequately controlled. <
Staff Response The guidelines which the NUMARC working group identified for controlling l requirements to be relocated from TS are generally acceptabla but should be supplemented as follows:
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In deciding where to relocate specific requirements, licensees should consider both the type of requirement and the controls that would govern changes to the relocated requirement. Licensees should generally locate similar requirements together (e.g., in a programmatic document, procedures, or FSAR section).
If related requirements are documented in a program plan, a license condition may be necessary to ensure that the plan is implemented and maintained.
Requirements to be relocated out of the TS that involve operator action generally should be incorporated into procedures.
Requirements to be relocated out of the TS should be put into the FSAR if any change to the requirement (including deletion) could involve an unreviewed safety question.
The staff is reviewing industry developed guidelines for conducting safety reviews in accordance with 10 CFR 50.59. Individual licensees must have
( adequate procedures for conducting these reviews before the NRC will approve the relocation of TS requirements.
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- 6. CONTENT AND CONTROL OF IMPROVED BASES 10 CFR 50.36(a) requires:
A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application [for a license), but shall not become part of the technical specifications.
The Commission's interim Policy 5tatement states:
Each LCO, Action Statement, and Surveillance Requirement should have supporting bases. The Bases should at a minimum address the following questions and cite references to appropriate licensing documentation (e.g. , FSAR, Topical Report) to support the Bases.
The Policy Statement also specifies minimum requirements for documenting the application of the criteria and for the bases for LCOs, Action Statements, Limiting Safety System Settings, and Surveillance Requirements.
Industry Position The NUMARC working group provided sample topics to be discussed in the Bases of i the requirements that remain in TS. The working group took the position that new analytical efforts need not be undertaken to substantiate the present TS (or to address all the sample topics). Although generic Bases will be developed by the NSSS owners groups, the NUMARC working group indicated that, to a large extent, plant-specific bases will be developed by individual licensees (based on plant-specific licensing and design bases). The working group proposed that licensees establish an adminictrative process to maintain and control changes to the plant-specific Bases. It also proposed that the upgraded Bases be provided to the NRC for information only. Subsequent changes would be '
developed by the licensee and implemented without prior NRC approv41; however, NRC would be provided with copies of the changes at the time they were implemented.
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f Staff Response A similar outline of topics to be discussed in the Bases for requirements remaining in the TS was generally endorsed by the staff in its letter from Thomas E. Murley, NRR, to Roger Newton, Westinghouse Owners Group, dated May 5, 1987 on Phase I of the Westinghouse Owners Group's Methodically Engineered, Restructured and Improved Technical Specifications (MERITS)
Program. The staff has reviewed this slightly modified outline and remains in general agreement except for the following:
The definition / description of the system (Outline Item la.) should be in functional terms as well as in hardware terms. This will facilitate proper determination of the operability status of systems and components.
The bases for each LCO requirement should discuss why the requirement is necessary and sufficient to ensure that the lowest functior.a1 performance level required for safe operation is met.
To the extent practicable, TS Bases should address the margin of safety.
This will facilitate the determination of whether or not an u reviewed safety question is involved when a licensee makes a change to its facility, procedures, tests, or experiments under the provisions of 10 CFR 50.59.
The use of the phrase "credible events" (Outline Item 4a) should be clarified.
Improved Bases for action statements should, to the extent practicable, provide the rationale for allowed outage times (A0Ts), rather than simply provide justification for the number. For example, the staff prefers to see calculations that show that a 6-hour A0T is justified on the basis of risk, but, to be conservative (or because of uncertainties), the licensee chooses a 4-hour A0T. This is preferable to seeing calculations that show that the 4-hour A0T is acceptable.
When references are provided in the improved Bases, it should be made clear which references provide general information and which references provide detailed justification for specific requirements in the specification.
The staff recognizes that some aspects of the new improved bases must be developed by individual licensees on the basis of a plant-specific licensing and design basis. However, the staff also believes that the most resource-effective way to implement the Bases upgrade is for the owners groups to prepare comprehensive generic Bases for the new STS to the maximum extent practicable. Plant-unique bases can only be justified by plant-unique circumstances, not purely as a matter of individual licensee or NRC staff preference.
In addition to the proper content of Bases discussed above, there is also the question of whether the Bases, once accepted by the staff, can be changed without prior staff approval.
TS Bases will provide information to facilitate the proper interpretation and application of TS requirements. Bases are also used for determining the purpose of existing requirements when changes to the TS are being considered.
In short, Bases provide the technical underpinning for To requirements. Any change to this technical underpinning that would influence the way the requirement might be interpreted or applied should be subject to prior staff approval because it would,'in effect, be a TS change. However, changes that do not erode this technical underpinning should not require prior staff approval.
i The staff believes that it may be possible to structure an administrative control process for Bases changes that could be included in Section 6.0 of TS to ensure that TS requirements are applied and interpreted correctly. For such a process to work, careful consideration would need to be given to the additional detail that might have to be included in the body of the TS (that would otherwise be in the Bases) and the resulting human factors considerations.
The staff is prepared to work with the industry to attempt to structure the new l STS and Bases so that such a process can be effectively implemented.
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