ML20196B572
| ML20196B572 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8806300296 | |
| Download: ML20196B572 (60) | |
Text
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- 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
Title:
BRIEFING ON TECHNICAL SPECIFICATION REVISIONS Location: ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND Date: MONDAY, JUNE 20, 1988 Pages: 1-49 l Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 (202) 293-3950
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l DISCLAIMER This is an unofficial transcript of a meeting 9
of the United States Nuclear Regulatory Commission held 1
on 6-20-88 in the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript i has not been rev'iewed, corrected or edited, and i t may I
contain inaccuracies.
The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, i t is not part of the formal .or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as -the result of, or addressed to, any )
statement or argument contained herein, except as the Commission may authorize.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION
,_ 3 Briefing on Technical Specification Revisions 4 ----
5 PUBLIC MEETING 6 ----
7 -
One White Flint North 8 Bethesda, Maryland 9 Monday, June 20, 1988 10 The Commission met in public session, pursuant to 11 notice, at 2:45 p.m., the Honorable Lando W. Zech, Chairman of 12 the Commission, presiding.
l 13 COMMISSIONERS PRESENT:
14 Lando W. Zech, Chairman 15 Thomas M. Roberts, Commissioner 16 Kenneth C. Rogers, Commissioner 17 Kenneth M. Carr, Commissioner 18 STAFF AND PRESENTERS SEATED AT TABLE:
19 S. Chilk, SECY 20 W. Parler, OGC 21 J. Taylor 22 E. Butcher 23 T. Martin i 24 l
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0 1 PROCEE-DINGS 2 CHAIRMAN ZECH: Good afternoon, ladies and gentleman, f-3 The purpose of today's meeting is for the NRC Staff 4 to brief the Commission on the status of the technical 5 specification improvem'nt e p'rogram. This is an information 6 briefing. The technical specifications set forth the specific 7 characteristics of a nuclear power reactor and the conditions 8 for its operation that are required to provide adequate 9 protection for public health and safety.
10 Over the years there have been problems with both the 11 volume and the usability of the technical specifications. In 12 February 1987 the Commission issued an interim policy statomont 13 on technical specification improvements. This policy was 14 intended to result in improved standard technical l 15 specifications and to encourage voluntary licensee submittals i
16 of revised technical specifications for their plants.
17 For today's meeting, we have asked the NRC Staff to 18 address specific issues. First of all, the progress of the 19 Staff's review of the owners groups split technical 20 specification submittals; second, the decisions of key program 21 implementation issues; and third, whether continued deferrment 22 of a final policy statement is warranted.
23 I understand copies of the slides are available as 24 you enter the room.
25 Do any of my fellow Commissioners have any opening
3 1 comments?
2 If not, Mr. Taylor, you may proceed.
- 3 MR. TAYLOR: Good afternoon, sir.
4 Starting, I think it's important to point out that 5 one of the major goals of the Staff effort on tech spec 6 improvements has been towards improving operational safety.
7 For example, as appropriate, the Staff is trying to 1 8 reduce surveillance tests while the plants are at power, to 1
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9 reduce transients that are sometimes introduced and caused when '
10 doing such surveillances. Efforts to improve equipment 11 reliability by reducing or eliminating surveillances which put i 12 undue strain on equipment such as cold fast starts on diesels, I l
13 and another key thing, making tech specs cover the vital and 14 important safety checks and not trivia or relative trivia to l 15 important safety checks which can sometimes cause operators to 16 have disdain for large and voluminous tech specs.
17 I'd like to underline that desire of the Staff to 1
18 improve operational safety and I will now turn to Tim Martin, 19 who will introduce the presentation.
20 CHAIRMAN ZECH: All right, thank you. You may 21 proceed.
22 MR. MARTIN: Thank you, Mr. Chairman.
23 I'd like to remind you that this effort started back 24 in 1983, research effort, I think it was documented in NUREG 25 1024. Quite frankly, this is one of our success stories.
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4 1 We're not finished yet, but we're well on our way.
2 The purpose is and has always been the enhancement of 3 l
- operational safety. We think we get that from several points: ;
1 4 First, the tects epecs are being upgraded to remove 5 the ambiguity in the tech specs. They are being reduced in i i
6 volume, so that they do not distract the operators to less !
7 significant safety issues. That's a double-edged sword: Not 8 only do you cut down the volume there, and thereby cut down on 9 the distractions; you release industry resources to do a better 10 job on concentrating on other safety-significant issues, and 11 you reduce the NRC Staff involvement in the day-to-day 12 activities so they can better focus on the safety-significant 13 issues. There will be less tech spec amendments as a result of 14 this, and we can then focus on the more safety-significant 15 ones.
lo New issues that have been incorporated into this 17 effort, we are trying to improve the reliability of equipment 18 by reducing the unnecessary testing that is wearing out some of ;
IS tha major pieces of equipment, such as the diesels. And our 20 major effort rigint now is in reducing the transients that are 21 caused by unnecessary technical specification testing. We see
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22 this as a major part in the closure of severe accidents, in 23 that enhancements in operational safety will reduce the risk l
24' from severe accidents.
25 Our briefing today is a follow-up on a meeting that l
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1 we had about nine months ago where we gave you status of the l
2 improvement program, and we talked about the public comments we
,_ 3 had received at that point. The Staff at that point l l
4 recommended dolaying a final policy statement until we l I
5 completed two important milestones. One of those, as you 6 mentioned, is the development of the tech spec split document; l 7 and the second, the resolution of the key implementation i
issues.
8 9 We are here today to provide you an update on the 10 program, to discuss the results of these two important ,
1 11 milestones, and to make recommendations on whether to continue 12 deferral of the issuance of the final policy statement.
13 We will be answering the questions that were asked in 14 the February Staff requirements memo, and also other 15 discussions that we have had with the Commission Staff.
I 16 At this point I'd like to turn it over to Mr. Ed l 1
17 Butcher, who is responsible fur the implementation of this 18 program.
19 CHAIRMAN ZECH: Thank you. You may proceed.
20 MR. BUTCHER: Thank you.
21 I would like to turn to the first slide which 22 reiterates the program goals which you have already heard this 23 morning. We think it's important to focus on these goals a 24 little bit before we continue with the presentation. These 25 goals have been the hallmark and cornerstone for the program
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1 frca the very beginning. All the folks who are involved in 2 this program are both with the industry and with the NRC, keep 3 these goals uppermost in mind when determining which specific i 4 tasks should have priority within the context of this program.
l 5 Improvement of operational safety is clearly number 6 one goal of the program. We think this can be achieved through 7 some very specific activities which are focused on some 8 specific problems that have been identified.
9 You have heard reducing the size and complexity of 10 technical specifications. This program, as it's currently l
11 constructed, should result in a reduction of approximately 40 '
12 to 45 percent the number of limiting conditions for operation ;
i 13 which are retained in the specifications.
l 14 That should represent a significant reduction in both I
15 the size and complexity of the document itself. There are !
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16 changes being proposed which will make the specifications that !
I 17 are retained more understandable for operations personnel.
18 These changes are being accomplished both by changes in the 19 wording of the actual specification and its form and 20 presentation. There has been substantial input from both 21 operations people and human factors specialists to make certain that the formatting changes that we make are the optie m
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23 changes.
24 We are proposing many improvements to the actual )
25 technical requirements within the document itself, so as to l
7 1 remove those things which were not necessarily the optimum 2 response to given plant configurations. -
- 3 Again, one of the principal ways that we hope to 4 improve operational safety is by reducing operational 5 transients, both those that are induced by mistakes, so to 6 speak, that are made while trying to perform surveillances at 7 power, and those which are induced by the specifications 8 themselves in terms of dictating mode changes when perhaps a 9 mode change at that particular time is not the optimum safety 10 action to be taken.
11 The second major goal is to provide a clearer link 12 between the technical specification' requirements and their 13 safety significance. We have discovered that in the past, many 14 of the requirements were not as clearly articulated in the 15 specification itself and in the bases for the specification, so 16 that ope. rations personnel would know the safety significance of 17 that specific requirement.
18 We propose major upgrades to the bases section of the 19 specifications to achieve this objective. In upgrading these 20 bases sections, it should also result in our ability to 21 facilitate improvements in the training of operations 22 personnel.
23 We think these are all -- these are important goals, 24 and again they represent the hallmark and cornerstone of tLa 25 program.
8 1 I would like to turn to the next slide. And what we i I'
2 have tried to do with this slide is to outline the program or
,_ 3 break it down into its three major elements. The program has 1
4 4 focused in two principal areas the development of the new ;
l 5 standard technical specifications to achieve the objectives we j l
6 have just reviewed, and a parallel program of specific )
l 7 technical improvements -- we call them line item improvements l
-- to the technical specifications as they exist today.
9 The distinction between element number one and 10 element number two of the program is that in element number two l 11 of the program, we are making those changes immediately 12 effective today, so that we do not have to wait until the l
13 completion of the new STS to begin to implement those changes, '
l 14 and I will use the same example that was used earlier, things )
i 15 like changes in testing requirements for diesel generators, and 16 I'll go over in detail some more of the specific changes that 17 we are making that are immediately available today to improve 18 operations.
19 The third element of the program is -- if I might 20 call it some housekeeping items that are necessary in order to l
21 fully realize and implement the first two olements of the l I
22 program.
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23 I have a separate slide for each element of the l 24 program where I can provide more specific details on what it is !
25 I we are achieving, i l
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l 9 l 1 For the first element, the development of the new 2 STS, the commission has asked that we provide an update on the
,_ 3 status of some of our activities in this area, and that's what 4 we have on this slide.
5 We have progressed in an orderly process since the 6 publication or since the issuance of the interim policy 7 statement back in early 1987, through a series of specific 8 steps which are designed to make sure that the specifications 9 that we produced, the new standard, is the optimum document 10 that it can be, and that the process that we design for 11 implementing that standard makes the most effective use of both 12 industry and NRC Staff resources.
13 The first step in that process is we wanted to see 14 some model specifications from the industry groups that are 15 working with the Staff to develop the new standards, and we 16 were able to develop those and see those and get some feedback 17 from both the NRC, industry people, our people in the field, 1
18 the resident inspectors, and the utility operations people. We 19 were able to do that in mid-1987, so at that time we have in 20 fact developed the form and format for some of the new 21 specifications, and they were reviewed, and we have settled on
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22 a specific approach that the new specs will be based on.
23 There were a number of implementation issueu, wDat we 24 have been calling the key implementation issues, which are 25 those issues which relate to the specific process that we will
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10 1 use to implement the new standards on the existing plants.
2 It was very important that we come to an
- 3 understanding with the industry on the appropriate milestones 4 and steps that one had to step through in order to convert an 5 existing specification to the new standard. There are many 6 operational questions that are raised by that process; there 7 are many resource allocation questions; there need to be 8 provisions made for public participation in those kinds of 9 licensing actions; and these issues were what we called the key 10 implementation issues. There were five of those issues, and 11 the last time we briefed the commission, we were in the middle l 12 of working on those issues and resolving our general approach.
13 If I may, I will just identify what the issues are l 14 and say briefly how we resolved them.
15 There was the question of plant-specific deviations 16 from the new STS. To what extent would we require a plant 17 converting to the new STS to take those requirements as they 18 exist in the STS at that time, versus what are the existing 19 requirements in the current pl'mt specifications?
20 For the nost part, we don't anticipate adding any new 21 requirements to the new standards at this time over and above
- 9. 2 which are already in the existing standard specifications. But P
23 it is true that some of the plants out there with custom 24 specifications today don't have all of the standards that are 25 in the existing standard specifications -- don't have all the
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1 requirements. l 2- .The Staff has taken the position, and we have 3 discussed this with the industry to make certain that we have 4 all the different points of view, and we have offered for 5 public comment these sorts of issues -- we have taken the 6 position that a plant, in converting to the new r?S, should 7 adopt the new STS to the maximum extent practicable, and that 8 there should be a specific set of ground rules that one should 9 use in deviating from the new STS. There are benefits to be 10 accrued to both the industry and the NRC from having as uniform e.
11 requirements out there as possible.
12 The standards that we propose to use for deviations 13 from the STS include things such as where a plant-specific 14 design consideration dictates a deviation from the standard.
15 Another rule that we propose to use in making this ,udgment is 16 where plant-specific operating experience over the years --
17 many of these plants have been operating for many years, and 18 where the plant-specific operating experience indicates that 19 one can achieve the same level of safety with a requirement in 20 a different form than that which is in the standard, and then 21 that can be borne out by actual operating experience, we would 22 propose to allow that as a justification for a deviation from 23 the standard.
24 We would also propose that where a current 25 specification has been -- where a requirement in the current
. l 12 1 standard specifications has been added to a plant in recent 2 years, and that change has been reviewed and approved by the
, 3 Staff, we would not propose to reopen those issues.
4 In other words, if the Staff has already approved the 5 deviation from the standard and that requirement has not 6 changed from the old standard technical specifications to the I 7 new, we would not propose to reopen those issues. We feel that l 8 an adequate review was done in the past.
9 The fourth basis for a change from the standard is 10 not really a separate thing, it's an amplification of the 11 previous basis for a change from the specification, and that is 12 where a hardware or organizational change would be required in 13 order for a plant to adopt the standard, we would not propose 14 to backfit any hardware changes at this time in order to make a 15 conversion to the new standard. We would not propose to force 16 any organizational changes on sites specifically as a part of 17 this activity for the purpose of the conversion to the 18 standards also.
19 With regard to the key implementation issues, they 30 have all been discussed with the parties involved, and there is 21 general agreement that these rules can in fact represent an 22 adequate framework for proceeding, and that these conversions 23 can be made.
24 The second issue that we wanted to focus on was the 25 Sholly noticing procedural requirements. There was the need to 1
13 l 1 focus on specifically how the Staff would meet the requirements l 2 for noticing, and we have come up with several different
,. 3 options on how that might be achieved. I don't propose to go 4 into it today other than to say that we have worked that out 5 with Staff counsel, and we believe that there are options that -
6 would permit a timely notification without representing an 7 impediment to the speedy implementation of the new standard 8 specifications.
9 We have a little bit more work to do in that area to 10 optimize and select the most effective option, but there are 11 several options out there which represent acceptable solutions 12 to making certain that we don't impede the process 13 unnecessarily. .,
1 14 We discussed the need as the third issue, key l 15 implementation issue, of changes from the regulations --
16 changes and revisions to the regulations for implementing 17 changes to the radiological effluent technical specifications.
18 There are no impediments to that process. The Staff can in 19 fact -- we have in fact defined the regulatory regulation 20 changes that are needed, and we are prepared to go forward with 21 those changes at this time.
22 We are exploring some options to -- which would 23 permit us to make some more immediately effective changes in 24 the area of radiological effluent technical specifications 25 which could be done in advance of or in parallel with the
. j 14 1 rulemaking. So we don't believe that represents an impediment 2 to going forward. -
,_ 3 Controls for relocated requirements. There was a 4 need to determine and to satisfy -- the Staff needed to satisfy 5 itself that there would be adequate control mechanisms 6 available for those things that were former technical 7 specifications and relocated out. I l
8 We have satisfied ourselves that the 50.59 rule 1
9 provides one control mechanism, the administrative control l
10 procedures within the specifications for changes to plant 11 procedures provides another very cubstantial control mechanism, l
12 and then there are controls for programmatic requirements, such ;
13 as the QA program and fire protection program and things like l 14 that which, in case of fire protection program, remain in 15 Section 6 of the specifications.
16 So we have concluded that there are various options !
I 17 depending upon the specific requirement that would be relocated '
18 from technical specifications, which gives the Staff confidence 19 that the controls that are out there are adequate. I 20 We will talk some more about she 50.59 process and 21 the update on how the guidelines that were developed for that
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22 effort are proceeding, further in the presentation. I 23 The final issue, key implemantation issue, was the 24 content and control of bases. One of the reasons why the bases 25 has not been as useful in the past as we would like it to be in 4
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15 1 the future is that the difficulty of processing changes to the 2 bases in the past, the Staff has pretty much taken the position c 3 that the bases could not be changed without prior Staff 1
4 approval, i
5 We believe that there are some aspects of the bases !
i 6 which can in fact, under the regulations, be changed without 7 prior Staff approval, and that in the interest of maintaining i
8 the bases current and making sure that they do achieve our 9 objective of facilitating and understanding of the basis for 10 ';he requirements and making sure that people fully understand 11 the requirement, that it's in the best interest to have some of 12 those changes to be able to be made by the individual utilities 13 without prior Staff approval.
14 There are some areas, such as where the change to the 15 basis might affect the margin of safety, where the Staff 16 believes that prior approval is still necessary; but for the 17 most part we believe that the control of that part of that 18 document can be turned over to individual licensees.
19 CHAIRMAN ZECH: Do we have the staff to support the 20 plant-specific technical specification questions that may come 21 up? Will we be able to review those sufficiently, do you 22 think?
23 KR. BUTCHER: You're referring to when we make the 24 conversions to the new STS?
25 CHAIRMAN ZECH: Right. And say they say, well, we
l 16 1 don't want to do that, we want to use the ones we have, and we 2 like this, it's an older plant, and we've got a lot of
~ 3 experience -- what kind of an interplay do you expect there?
4 And mainly I'm interested in do we have enough, can we support 1
5 those kinds of questions that come up? '
6 MR. BUTCHER: For the most part, we believe that it 7 is most resource-effective for both the utilities and the Staff ,
8 if everyone had the standard technical specifications. ,
l 9 CHAIRMAN ZECH: I understand that.
10 MR. BUTCHER: There are obvious economies of scale.
11 CHAIRMAN ZECH: But I'm thinking about an older plant 12 that has been operating for a long time, and they have what 13 appears to be a good suggestion about retaining some 14 specification or not adapting some part of the new ones. Can l I
15 we cover that? Is that going to be -- do we have staff 16 resources to respond to those kinds of matters?
17 MR. BUTCHER: We currently have to respond to those 18 individual plants. We have that situation that exists today, a 19 distinction between standard and custom plants. It represents 20 a resource burden to the Staff which we have been able to 21 absorb, and I don't think that burden will increase by virtue 22 of what we are doing here, so I would anticipate we would be 23 able to absorb it, too.
24 CHAIRMAN ZECH: Fine.
25 MR. BUTCHER: Again, we are encouraging the maximum I
17 1 amount of voluntary participation that we can get. And we are 2 encouraged by the feedback we get from the industry, that there
,_ 3 is substantial interest and there will be a large amount of 4 participation.
5 CHAIRMAN ZECH: How much have you brought in the 6 operators and the operational people into the tech spec review 7 program in total?
8 MR. BUTCHER: The operations perspective has been 9 brought into the program in several different ways. The 10 original studies which defined that which was needed to be 11 changed in the current specifications included input by 12 operations personnel. Those studies, both done by the old then 13 AIF organization, and the special study group that was set up 14 within NRR, I guess about three years ago. Operations --
15 visits were made to the site, operations personnel were 16 interviewed. The original study, NUREG 1024, which was done 17 back in 1983, had input from operations people. In 18 constructing the format, the new format, we have had input from 19 operations people there.
20 I personally have visited all the regions and met 21 with the resident inspectors at their regular resident 22 gatherings to make certain that what we are doing here from an 23 l operations standpoint makes sense to thoce folks. '
24 We have had -- we actually have introduced a system i 25 of rotational assignments within the branch that's responsible l l
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18 1 for creating these specifications. We have an individual now l 1
2 working in the events assessment branch, and there is an 3 individual from the events assessments branch who, within NRR, 4 are the folks that had the day-to-day contact. They are i 1
5 working on this program also. So we have made a conscious l
6 effort to bring operations in. ,
7 CHAIRMAN ZECH: Have the utility people themselves 8 participated heavily in the program?
9 MR. BUTCHER: The operations side of the house?
10 CHAIRMAN ZECH: Yes.
11 MR. BUTCHER: Yes, sir. It's my understanding that ;
12 they have, in fact, inputted to all the major studies that have 17 been done.
14 I have visited one of the sites for the lead plants 15 that will be the first to convert to the STS and talked with 16 operations people myself, and I have trips scheduled to do all 17 the rest of them also, as part of this program.
18 CHAIRMAN ZECH: Fine.
19 MR. MARTIN: Mr. Chairman, just to amplify; if there 20 is a wholesale request by licensees to pick and choose from the 21 standard tech specs, we will have a backlog problem. We don't 22 anticipate that's going to happen, and we can -- some licensees l
23 will need to do that, we understand that. But if it was a l l
24 wholesale thi.ng, we would have difficulty in entertaining all l 25 the amendments simultaneously.
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19 1 CHAIRMAN ZECH: Okay. Fine. Thank you.
2 MR. BUTCHER: I'd like to say a few words about the 1
,_ 3 tech spec split report. That was a major effort where we felt 4 it was important to define early in the program the specific l
5 LCOs, limiting conditions for operation, that would be '
6 retained, and those that would be relocated, and we entered 7 into a major effort and study to apply the criteria for the 8 contents of the technical specifica* ions that were in the 9 interim policy statement, and that erfort was completed just 10 recently in May.
l 11 COMMISSIONER ROBERTS: Well, the last time you l l
12 briefed us, wasn't that to be completed in early '88?
13 MR. BUTCHER: That may be the case, yes, sir. We ;
14 just completed it here in May.
I 15 Now when I say completed it, we published the report. l 16 We actually received the industry's input on their judgment as 17 to how the criteria ought to be applied, and the Staff did its 18 independent review of how the criteria might be applied. It 19 was in the April timefrare that -- March and April, that we 20 actually had the judgments, we wanted to have some more l
21 meetings. We had several iterations back and forth to make l
~ I 22 sure we got it right.
23 This program has been marked by very deliberate 24 process of stepping through, step by step, and not proceeding 1 1
25 into the next step until we have complete confidence that we 1
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20 1 1 have in fact gotten it right, so.to speak. l 2 The bottom.line on that was it confirmed our earlier !
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,. 3 judgments that a significant portion of the spec could be
-l 4 relocated, and depending upon the specific generation of plant 5 and the specific vendor involv&d, it was something between 30 I 6 and 45 percent of the LCos could be relocated. That was 7 confirmed by this study, both by the industry groups working on 8 it, and the Staff group.
9 The most significant finding of that effort that is 10 also confirmed in an earlier conclusion that the Staff had 11 reached independently, was tha't there is one area oi the 12 criteria that could use some clarification, and that is in the !
l 13 area of specific requirements that.are in the standards to l I
14 preclude unanalyzed events. That was not as clearly 15 articulated in the criteria as it could have been, and that's 16 the one area that we have learned something about the criteria 1
17 that would indicate some clarification is needed. That's i 18 criterion 2.
19 So that pretty much brings you up to date where the ,
l 20 split results are behind us, we understand what the new spec 21 will contain now, the key implementaticn issues are pretty much
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22 behind us. We have a few minor details to work out there, but 23 none of those represent any impediment to proceeding forward 24 with the complete. program.
25 There are a number of ongoing activities. I have
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21 1 already referred to the Staff visits to the lead plants, which 2 we hope to begin moving into that process right now. One of
,. 3 our principal objectives there is to bring an operations --
4 direct feedback from operations personr.el on the specifications 5 as they exist today.
6 In early -- in late '88 to early '89, we expect to 7 see complete submittals from the industry on what the new STS 8 would look like.
9 COMMISSIONER ROBERTS: Is that a slip from the last 10 time you briefed us?
11 MR. BUTCHER: Yes, sir, I bould have to say that's 12 about three to six months slip. It's primarily the result of a 13 pause in the process to work out the key implementation issues 14 in the split. Both the Staff and the industry groups, the 15 owners groups, working with us, concluded that that was a 16 worthwhile thing to do.
17 It's a slip in terms of when the actual deliverables 18 would be completed. The work continued while we were going 19 through these efforts; it just resulted in a slip on when it 20 would be completed.
21 I want to make it clear here that in late '88, we
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22 will begin to see pieces of it. In fact, we have alread/ seen '
23 a few pieces of the new STS, but it will not be until 'fJ9 until 24 we see a complete new set of STS for any one of the vrndors.
s 25 We have made a commitment to develop a very ambitious ~l
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1 review turnaround from the Staff, and our decisions on whether .
2 or not we can accept the new STS in the format as proposed by
- 3 the groups working on it in the industry, and that is a six to 4 nine-month turnaround, which indicates that late '89, early 5 '90, we hope to have the Staff complete its evaluation of the 6 new STS and the lead plant reviews which will be done roughly 7 in parallel, but a bit behind the individual STS. We wa6t to j 8 be getting feedback from the actual conversions to the STS as l l
9 We are finalizing what the new document will look again. l 1
10 Again, to bring an actual experience operations perspective to 11 the procese of the conversions.
12 You can see that we have listed here as October '88 13 for issuance of the final policy statement, and in terms of the l
14 sequence of events, it is a bit out of order. In other words, 15 the current schedule that we have proposed for the final policy 16 statement comes before we have completed the STS, and it comes l l
17 before we have actually seen the application of the new STS to j 18 any given plant.
19 The Commission asked at this briefing that we address l
20 the question of whether or not it makes sense to continue '
21 deferral of the publication of the final policy statement.
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22 Staff is still evaluating that, but I anticipate that we would 23 be coming forth with a proposal that would indicate that it 24 would make more sense to continue the deferral on the interim 25 policy statement until we have at least seen a significant
23 1 portion of the new STS to make certain that the specific 2 problems that the thing we are focusing on now, is the concern
,_ 3 that we have had with criterion 2, and whether or not it 4 articulates as precisely as it can the requirements related to 5 things needed to prevent unanalyzed accidents.
6 The final bottom line on the program is we would 7 expect to see in late '90 complete -- many, many submittals a from the industry. There's no reason at that point why any 9 individual utility should have any hesitance whatsoever about '
10 applying for an amendment to convert to the new STS, and we l 11 would expect to see wholesale license amendments at that time 12 to begin that process, 13 The final date for when we would complete those
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14 reviews is largely dependent upon the availability of resources 15 to allocate to that task.
16 COMMISSIONER CARR: When would the approved STSs be 17 on the street?
l 18 MR. BUTCHER: The approved STS would be on the street 19 in late to early '89 to '90. In early '89, you would see the 20 STS, I would expect pretty much in the form in which it will 21 look. If someone wanted to see what the new STS were going to 22 look like, I think what is available in early '89 will be the 23 picture. And we are not really too far away from that at this 24 point.
25 CHAIRMAN ZECH: All right. Proceed.
)
24 1 MR. BUTCHER: I guess at this point, unless there are 2 any questions --
,_ 3 . CHAIRMAN ZECH: Go ahead. Let's move along.
4 MR. BUTCHER: -- I'd like to proceed to this second 5 element of the program, which is the parallel program for line 1
6 item improvements.
7 Again, I would like to reiterate that these are 8 changes that we are making to the current STS which are 9 available for immediate implementation. There's no need to 10 wait for a conversion to the new STS in order to implement 11 these, i 12 Some of the completed -- and these are significant.
13 Some of the completed activities to date, we have made 14 revisions to the general requirements in the specifications 15 which make it no longer necessary for the individual utilities 16 that file the appropriate license amendments and have them 17 approved and have their specifications changed, it's no longer 18 necessary to declare equipment inoperable merely because it has 19 missed a surveillance requirement.
20 In the past, that has resulted in some mode changes, 21 transients, operation of the plant that really, in our mind, 22 was not justified.
23 We have also made some clarifications with regard to 24 the appropriate use of specification 303 to make it clearer 25 with regard to removing redundant systems from operation at the
25 1 same time. We felt that was an area that was unclear and it 2 ought to be clarified, that the Staff did not intend to see .
. 3 that occur.
4 There are a number of other administrative changes in 5 that section of the specification which are required to 6 preclude unnecessary changes and -- I mean unnecessary mode 7 changes, and to remove unnecessary restrictions on mode 8 changes. .
9 We have recently approved a change for the relocation 10 of organization charts from the specifications under some 11 specific ground rules which have been retained within the 12 specifications. We have found that that is a trerandous 13 resource saver in terms of the needing to process license 14 amendments. Many, many license amendments were being generated 15 by relatively minor changes in the organizational structure.
16 Many of the utilities have implemented this change, 17 and it was implemented immediately, because there were many 18 pending organizational changes that people wanted to have 19 reflected in a regulatcry document.
20 We have approved surveillance interval extensions, 21 and this is a major activity, for GE and Westinghouse plants 22 for the reactor protection system. Before the year is out, we 23 expect to make similar approvals for all of the vendor -- all !
24 the types of reactors out there for both the reactor protection l 25 system and the engineered safety features actuation.
l
26 l 1 This change alone will result in a 57 percent 1
2 reduction in the amount of testing at power that's done for
_ 3 instrumentation of systems in the plant.
4 It would result in something like -- a rough estimate 5 would be 1000 to 1500 separate tests per year that are done at 6 testing per plant that would no longer be needed. That 7 translates into something like 200,000 to a quarter of a 8 million tests that are now done that will no longer have to be .
9 done after the end of this year, once these approvals are 10 accomplished.
11 COMMISSIONER CARR: Well, you say you have completed 12 that?
13 MR. BUTCHER: Say again, sir?
14 COMMISSIONER CARR: That work is done, but then you 15 tell me that when something is approved -- so I don't know what 16 the status of that is.
17 MR. BUTCHER: I should clarify that. The Staff has 18 approved for Westinghouse and General Electric plants those 19 changes. There have been some license amendments, but not a 20 great deal. The principal reason why they have not been 21 implemented and the testing has actually not been reduced, is
~
22 because you need similar changes to the engineered safety 23 features actuation system, because some of the instrumentation 24 appears in both systems.
25 We anticipate by the end of the year having it out --
27 1 having the approvals out on the street for both of them, which 2 would mean amendments could be filed immediately to accomplish
- 3 that objective.
4 Some of those amendment approvals are expected as 5 early as September, but by the end of the year, we should have 6 all of them behind us.
7 We have also been through the process of relocating 8 detailed lists and tables from the specifications which 9 generate a lot of unnecessary license amendments. Things like 10 lists of snubbers in the plant, penetration over current 11 protection devices, containment isolation valves; things that 12 can be controlled very nicely in a design document like the 13 FSAR.
14 Other ongoing activities. Removal, relocation of 15 fire protection system requirements. This is an implementation 16 of an earlier generic letter. We have been trying to do these 17 plant by plant, and it became very resource-intensive. It was 18 taking a lot of time, so we just kind of called a pause till we 19 could get a generic position out there to make that process 20 move a lot smoother. We are taking that to CRGR, I believe, 21 tomorrow, so that should be immediately available.
22 COMMISSIONER ROBERTS: Didn't the Cotamission approve 23 that as part of the Appendix R generic letter that was done in 24 March of '86?
25 KR. BUTCHER: That's correct. The commission
28
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1 directed that those requirements should be relocated -- well, I 2 that those requirements could be relocated from specification,
_ 3 once that license amendment was implemented. What it turned 4 out is that one needed more specific guidance than just you can 5 relocate them in order to accomplish that and to implement the 6 other parts of the generic letter. And that was causing a l
7 plant-by-plant review, which was eating up a lot of resources l 8 and causing delay. We have drawn back from that position and 9 come up with a generic process that can be done so that the 10 amendment can be processed by the project manager, and does not 11 require any special attention by any of the technical 12 specialist branches to implement.
13 That's an interesting change, because it turns out 14 that something like 20 to 25 percent of the LERs that are 15 generated today are generated from fire protection requirements 16 that exist in the specification. And recent studies have been 17 done to show that all of those violations are of low safety ,
18 significance. So it's a major reduction in resource -- or 19 major change in resource allocation from lesser safety-20 significant things to more safety-significant things.
21 Again, I'll mention that there's a --
22 COMMISSIONER ROBERTS: Should that remind me of 23 something Bill Dircks used to tell me, that the Staff didn't 2 /. write the fire protection system, the Commissioners did?
25 No comment?
29 1 ( Laughter. )
2 -
MR, BUTCHER: I have already indicated that by the
_ 3 end of the year, we will have the other topical reports on the 4 RPS and SFAS surveillance changes in.
5 We propose to, hopefully by the en'd of August, to 6 complete a program to relocate cycle specific parameters from 7 the specification. What that will do is eliminate the need for 8 the Staff to make individual reload license amendments, except 9 in those cases when there are substantial changes in the 10 constitution of the core. We process those amendments today, 11 and in many cases, theycanbesubstan$ialresource 12 commitments.
13 We also, by August, hope to remove a restriction on 14 extending surveillance intervals related to surveillances that '
15 are done at refueling outages. Frequently utilities come out l
16 of a refueling outage, and right away, they turn around in 17 having to go into a shutdown to do surveillances which have 18 come due. We propose to remove that restriction, because it 19 -- there is no technical justification for it. And that 20 specific application, the restriction on 25 percent extension j 21 of surveillance intervals over a three-interval period, will be 22 retained for those things which can be done that are not 23 affected at refueling, that are not necessarily being done at 24 refueling.
25 Again, there's a tremendous effort underway to focus l
30 1 on testing at power, and in conjunction with the work that's 2 already being done on the topical reports on instrumentation, 3 we have initiated a short term 90-day program to completely 4 reexamine all the surveillances that are in the specifications 5 now that are done at power, or at any -- in any mode of 6 operation; to identify those which can be changed, based upon 7 engineering judgment, and just plain common sense, and past 8 experience with having done those surveillances, without 9 requiring a rigorous PRA risk sort of calculation.
10 We have passed through the specifications already 11 line by line on the surveillance requirements in connection 12 with this specific initiative that we have, and we have 13 determined that there are many candidates in there for 14 adjustment. And this relates to major mechanical components.
15 So far the emphasis has been other than diesel generators or 16 instrumentation. l
}
17 As part of that program, we will conduct visits to 1 18 each of the sites to confirm our own conclusions with 19 operations personnel on whether these tests are overburdensome 20 and are causing 1: olems.
21 CHAIRMAN ZECH: I think it would be helpful for the I
22 Commission to get a paper on this subject, on reduced testing )
i 23 at power, and reduced surveillance while the plant is operating )
24 at power levels. I think that part of your program that might 25 be useful for us to just elaborate a little bit on a paper to i
as-- -y , ,gw-, ----
p-- - - - - w-- ,- ----,,--,,g- -,- ,--. , .eng-~ - -,., ,y.-,
31 1 send to the Commission and tell us exactly what you're doing in 2 this area. It's a very important area.
3 MR. BUTCHER: Yes, sir. We have such a paper under i
4 preparation, and we had scheduled it to, I believe it was, 5 early in August, when we expected to have it available for the' l
6 Commission. j 7 CHAIRMAN ZECH: Well, get it to us soon.
l 8 MR. SUTCHER: Yes, sir.
9 CHAIRMAN 2ECH: Thank you.
10 COMMISSIONER CARR: What's the date on that 90-day 11 program? When did it start, and when is it going to finish, l 12 and what do you expect to have at the end of it?
13 MR. BUTCHER: Well, we are about two weeks into it 14 right now, and at the end of it, we expect to have two things:
15 We expect to have some requirements identified which ,
l 1
16 we believe can be changed immediately without any further l 17 study.
18 COMMISSIONER CARR: Well, will they have to go 19 through that generic routine, like fire protection, or are we 20 going to get rid of them right away?
21 MR. BUTCHER: We are going to make those immediately 22 available. Now we do have administrative processes, checks and 23 balances, such as the CRGR, that reviews, and things that we 24 will go through. But I wouldn't anticipate that it would be 25 any more than a 60 to 90-days before these things are available e . . - . , - _ _
. 1 1
. 1 32 1 to people. You have to take time to --
l 2 COMMISSIONER CARR: After the 90 days?.
3 MR. BUTCHER: That's correct.
1 l
4 COMMISSIONER CARR: We're talking six months.
5 MR. BUTCHER: That's a fair goal for that.
6 The second thing we would expect to come out of that 7 90 days would be an identification of those things while we 8 cannot, based upon the limited review that we have done in this 9 short period of time, make a final conclusion, we believe that l l
10 there it substantial reason to believe that given a little i
11 bit ,
study, they could be adjusted, and we would highlight l l
12 and identify those and expect to have those implemented prior ;
1 13 to the development of the new -- the completion of the new STS, 14 so those changes can be folded into the new STS. And that 15 longer term effort would be dono in conjunction with a study 16 tha' AEOD is doing right now on the specific surveillances and {
17 want the results of those surveillances would say about the 18 frequency at which they are done, and the effect that those 19 surveillances have on inducing transients. That work has 20 already been done, has already been initiated by AEOD, and 21 they're beginning to get some preliminary results now on the 22 percentage of transients that are induced that come from 23 specifications.
e4 CHAIRMAN ZECH: On this testing and surveillance 25 program, you're trying to cut down on testing of surveillar.co
33 1 at power, T would hope that after you come acrcss something 2 that is clearly doable and makes sense, that we don't have to 3 wait till '89 or '90 or '91 to get it done. I hope we will 4 just be able to factor that into something that we can do l
5 before that time. Because in my experience in looking at these 1
6 plants, there's a lot of room for improvement in that area. We l l
7 do too much testing at power, too much testing when the plant l 8 is operating, too much surveillance, and good people make 9 mistakes, and we challenge the plant.
10 So if you come across something that clearly should 11 be changed, I hope we're not going to wait a great deal of time l l
12 to get everything with a big ribben around it to change I 13 anything.
l 14 MR. BUTCHER: Yes, sir. That's our intent.
15 CHAIRMAN ZECH: Keep that in mind, and get the word 16 up the line to the Staff, that we make -- you know, sensible l 17 changes don't have to take forever.
1 18 MR. BUTCHER: Yes, sir.
19 CHAIRMAN ZECH: Gkay.
20 MR. BUTCHER: At this point, I would like to --
21 unless there are any further questions on this parallel program 22 for the line item improvements, I would like to turn to the 23 housekeeping ' asks that I spoke to earlier, the other 24 miscellaneous tasks that need to be done in order to fully 25 implement the program.
l i
34 l 1 One of the specific things that the Commission has 2 asked for feedback on is the progress that we have made in
- 3 developing guidelines for what we call quality 50.59 reviews.
4 If we are going to be relocating things from technical 5 specifications and putting them in the environment where the 6 individual licensees can make changes without prior Staff 7 approval, we have to have confidence that the process that they 8 will use for making those changes is adequate.
1 We have entered into an effort with the industry to 10 examine the 50.59 process, and to -- for the Staff to define )
11 specific requirements that would constitute things that have to 12 be satisfied in order to have a quality 50.59 review. l 13 The industry has established a working group under 14 NUMARC, NSAC, to develop a set of guidelines and propose them 15 for Staff review. T'he Staff has established a working group to 16 do the sa ae thing, and to interact with the industry, and to 17 develop its ow.4 regulatory guide, hopefully based upon the work )
18 done by both working groups, to assure that the 50.59 reviews l 19 are done correctly.
I 20 We have received a -- one draft has been reviewed of 21 the document. There have been comprehensive comments back from 22 the Staff. The general reaction is very favorable. It was a 23 very comprehensive document, and the guidelines were very 24 sharply defined, and we feel that it is going to represent a 25 significant' improvement in the 50.59 process.
~
35
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1 The next draft we --
2 COMMISSIONER ROGERS: Excuse me. When did you say
_ 3 you'd have that -- you think that's going to be completed? l 4 MR. BUTCHER: The next draft of that is due to be
~
5 completed in September-October of this year. The last draft, 1
6 we formallj provided our comments back to the NUMARC NSAC I l
7 working group on, I think it's May the 12th of this year. l l
8 The effort is on schedule to support the conversions 9 to the new STS, because that's frankly what's driving the 10 process. We have concluded, and it was stated in the interim 11 policy statement, that an individual utility could not adopt 12 the new STS until both the Ccmmission and the Staff and the 13 utilities were satisfied that there was a suitable 50.59 14 process in place. And the schedule that we have for this 15 effort is compatible with that, and there is no problem. ;
1 16 I believe the Staff did recently propose a change in l 17 the track date which called for a regulatory guide to be issued l 18 in September of this year, and clearly it will not be is:ued at 19 that -- on that date, but it will be issued in plenty of time 20 to support the conversion to the new STS. I 21 The rulemaking on radiological effluent technical l
22 specifications, as I indicated earlier, we are pursuing two 23 avenues with that. We believe there are many improvements that 24 can be made in that area of specifications now, without waiting 25 for a rule change, and we would propose to proceed with a rule
36 1 change immediately in parallel with our effort. Sometimes rule 2 changet, can be - can take tine, so we believe that we ought to
- 3 proceed with a line item improvement on those changes that can 4 be made without -- absent the rule change in that area. But we 5 will have also started a rule change action in that area.
6 In the area of risk-based technical specifications, 7 in the policy statem.nt, that's acknowledged as an important 8 area for the current program and for future activities, and we 9 have devoted significant effort to that area.
10 In the case of the extensions on surveillance e.
13 intervals for instrumentation, there have been substantial 12 changes based upon rule changes in that area and -- excuse me, 13 based upon PRA methods in that area.
14 A longer term area that we are looking at is we have 15 a current longer term study to study the feasibility of 16 reducing coremelt frequency by controlling plant configurations 17 which result in high short-term risk. Experience with the 18 existing specifications has shown that sometimes the secondary 19 configuration of the plant, in conjunction with the 20 configuration of the safety systems at any given time, can 21 result in unusually high risk. When those things are averaged 22 out over the life of the plant, or over a year, using the 23 current methods, what we discover is they don't always -- what 24 yoc need is a system that acknowledges the current 25 configurction of the plant, and defines the instantaneous risk,
, - - - ~ , , . . - - . . - - . - - , -
37 l l
1 short term risk, associated with that.
2 In ordor to achieve that objective, we believe that
_ 3 that may require some fairly significant changes in the whole 4 approach that we use for technical specifications, and we are 5 looking in.o that right now, as to what that would look like. l l
6 That would be the next generation of specifications that we 7 would turn to. -
8 COMMISSIONER CARR: That effort is not going to delay l 9 what you are doing now?
10 MR. BUTCHER: Not at all. And ~we set it off as a 11 separate program that is separately funded, so as not to impact 12 this program.
13 I might point out that research in that area is being 14 done in Europe right now, as we speak, and they have made 15 substantial progress in that area, and some of the feedback l
16 that we get indicates that it holds real promise for the 17 future.
18 I guess at this point I would like to just reiterate 19 all the things we have said here today, that so far in our 20 presentation, that the overall program that's designed to have 21 a significant impact on safety and on the resource requirements, to maintain safety in the reactors that exist 22 23 today and in the future, and the program will improve 24 operational safety by letting operators focus more on the most 25 safety-significant aspects of the requirements that are
38 l l
1 necessary, and making technical specifications more l 2 understandable and less ambiguous, and by the specific l 1
._ 3 technical ~ improvements that we intend to make to the specific 4 line items within the specifications.
5 We believe that th'is effort will result in more 6 reliable and efficient plant operation. Needless restrictions 7 on mode changes would be eliminated, and transients and mode 8 changes induced by specifications would be reduced.
9 And finally, the bottom line is that all of this can 1
10 be done and at the same time result in fewer resources J 11 comm,itted to things like unnecessary licenea amendments, 12 interpretation problems, and these resc. .es that are saved can 13 be turned to the more safety-significant aspects of the 14 regulatory requirements.
15 That concludes my prepared remarks. We are prepared 16 to answer any specific questions that the Commission may have.
17 CHAIRMAN ZECH: All right. Thank you very much.
18 Questions from my fellow Commissioners? Commissioner 19 Roberts?
20 COMMISSIONER ROBERTS.' No.
21 CHAIRMAN ZECH: Commissioner Carr?
22 COMMISSIONER CARR: It was a little fuzzy to me on i 1
23 that October '88 final policy statement. I couldn't tell 24 whether you were telling me you weren't going to make, or you 25 were going to make it. !
39 l
\
1 MR. BUTCHER: I guess we were trying to tell you that 2 we could make it, but that we believe tl.fc it would be prudent 3 to see this new STS in its final format, or at least to have it 4 in house before we finalize that policy statement. We have 5 identified one area and that is the area of requirements that 6 are nccessary to preclude unanalyzed accidents that we think j l
7 should be sharpened, and in the coming months, as we develop 8 the new STS would be the right forum in which to sharpen that i
9 language. I 10 COMMISSIONER CARR: If you don't have an October '88 11 date, what date are you having?
12 MR. BUTCHER: Clearly we would have it issued before
)
13 the date that we proposed to have for the new STS approval, 14 which would be late '89, early '90. I think probably mid '89 15 would be plenty of time, because by then we will have the new 16 STS, we will have had a chance to look at it in its entirety 17 and in context. It's difficult to make these judgments line by 18 line. You need to see the document in context.
i 19 So I believe the Staff will come back with a 20 recommendation that we continue to defer issuance of the final 21 policy statement.
22 COMMISSIONER CARR: The other qt.estion I've got is 23 how is the backlog of routine tech specs now coming along, and 24 are you still handling those? And are you at all stopped while 25 this is going on?
l 40 j 1 MR. VJTCHER: We are clearly not at all stopped.
I 2 Tim, I'm not familiar --
i 3 MR. MARTIN: We're not at all stopped, but it is l l
4 slowly increasing. I 5 MR. BUTCHER: One thing that should hopefully begin 6 to turn that around, we won't be processing fire protection ;
l
~
7 tech spec amendments in the near future. We won't be 8 processing organization charts, and we won't be processing 9 emergency tech spec changes associated with some surveillances 10 that come due that really are too frequent.
11 CHAIRMAN ZECH: Commissioner Rogers?
12 COMMISSIONER ROGERS: Well, a couple of questions.
13 Where does the general area of internal 14 communications equipment and anything relating to that, fall?
15 Is that in the tech spec now? l l
16 MR. BUTCHER: You mean internal, within the plant 17 itself, the electronic communications?
18 COMMISSIONER ROGERS: Yes.
19 MR. BUTCHER: I don't believe any of that equipment 20 is controlled by specification.
21 COMMISSIONER ROGERS: Are you addressing that in any 22 way? This is a very important area, and you know, that's 23 something that has been a contri.butor to some of the 24 surveillance testing problems, lack of adequate communications.
25 Maybe reducing some of the surveillance tests will mitigate
41 1 that a little bit, but still the quality and nature of 2 principally, you know, the electronic aspect of it, although we l
- 3 have all seen the use of language is an important thing, how q 4 that's being done is important. It may not have to be in the 5 tech specs, but where is that being addressed, if at all?
6 (Commissioner Roberts left the room at 3:35 p.m.)
7 MR. BUTCHER: In this specific program, we do not 8 have specific focus on that aspect of it.
9 Now I think it is important to point out that one of 10 the objectives of this program is to get the kinds of resource-11 inteasive things out of the specs that are eating us up now, 12 and it's our hope to have that resource available to go back 13 and reexamine questions like this, and that's wh'at we would 14 intend to do with that resource. And we would hope that the 15 utilities -- and we have every reason to expect that they would 16 use that increased resource available for better training of 17 people that are using those kinds of internal communication 18 devicos.
19 The current requirements are quite burdensome in 20 terms of the resource requirements to satisfy them.
21 COMMISSIONER ROGERS: Yes. Right.
22 MR. BUTCHER: There's not a lot of time left over.
23 COMMISSIONER ROGERS: Right.
24 Just what are the lead plants, and how were they 25 chosen?
l
l 42 1 MR. BUTCHER: There's one for each vendor right now, l
2 and we chose them in cooperation with the industry owners l l
3 groups in developing the new STS. There's one for each vendor.
4 North Anna, for Westinghouse; Crystal River for B&W; San Onofre 5 for CE.
6 COMMISSIONER ROGERS: Just roughly, what were the 7 criteria for making a choice there, do you know? I 8 MR. BUTCHER: We tried to mix up a variety of plants 9 with the standard ones with the current standard specs, and 10 ones with custom specs. We wanted to find a design which was 11 pretty much representative of the general class of plants out 12 there, tried to do that.
13 In the case of General Electric, in order to achieve 14 that objective, we ended up with having to have two lead 15 plants, Grand Gulf for the BWR 6s, and Hatch for the later or 16 the earlier model designs.
17 There have been a couplc of plants that have 18 indicated a desire to be parallel lead plants. In the case of 19 Rancho Seco, they have indicated a desire to make an early 20 conversion to the new STS. There's some likelihood we will run 21 them in parallel. We have had -- and this is what encourages 22 me, we have had inquiries from several plants with custom 23 specifications, which would also like to be thoroughly in the 24 implementation process.
25 I'm not convinced that we can have seven or eight or
~
43 1 10 lead plants. That defeats the process and it is not very 2 efficient. So I don't know that we can accommodate everybody
. 3 that would like to get in as the first round of plants; but 4 certainly by adjusting resources, we can get early reviews for 5 these folks.
6 (Commissioner Roberts entered the room at 3:38 p.m.]
7 COMMISSIONER ROGERS: What have been the kinds of 8 sticky issues that have developed so far with industry in this 9 program?
l 10 MR. BUTCHER: Well, I have to be honest. The key 1 11 implementation issues, the question of the amount of deviation 12 that we can stand on an individual plant from the standard that 13 we are proposing has been a major concern to individual 14 utilities. And I can understand why. They have a plant they 15 believe operates safely now; they see the benefits of 1.6 converting to the new STS; but they don't want to run ripples i
17 through their whole organization in making the conversion, but (
1 18 at the same time they want to get the benefit. 1 19 So we believe the ground rules we have established l 20 give them the flexibility they need to do that, and that's the 21 feedback we are getting from them, that it does give them 22 flexibility that they need to do that, and -- but that has been 23 a major sticking point.
24 There is a great deal of concern about the resources 25 required to process the lic:ense amendment and the noticing
44 1 procedures. There's some -- the average plant out there has 2 150 LCOs in it, and if they have to deal with those changes 3 line by line, that becomes a rather significant package to l
4 submit. We have looked at several alternatives to make sure 5 that we satisfy the noticing requirements, but at the same 6 time, we don't use a process that consumes any more resources 7 than we have to.
8 I think we have come up with several alternatives 9 that satisfy the objective, but that's been a major concern.
10 COMMISSIONER ROGERS: Does this open up the door for 11 really new activities to shut a plant down, in going to a new 12 set of tech specs?
13 MR. BUTCHER: Well, clearly any major license 14 amendment offors opportunity for public participation in the 15 process, and this wouldn't be any different. It's a license 16 amendment, and this wouldn't be any different from that.
17 Now the rules provide.for participation before the 18 amendments are issued, and participation after the amendments 19 are issued, depending upon the substance of the change, and 20 that's what we are focusing on now.
21 We believe, all indications we have so far, are that 22 this change can be done in a manner which would provide for the 23 amendment to be issued prior to the completion of any hearing 24 which might be requested on it.
25 COMMISSIONER ROGERS: Just one final one. What is
45 1 the legal status of the relocated specifications, when you take 2 them out of the tech specs and they go some place else in the 3 documentation? What is the legal status of those things then?
4 MR. BUTCHER: They acquire the legal status of the 5 document they get relocated to. In the case of something going 6 to the FSAR, it is governed by the 50.59 regulation. In the ,
)
7 case of something that is relocated to a plant procedure, it's 8 governed by the administrative control requirements on plant 0 procedures which lie in the utility's QA program under the -- I 10 believe it's Appendix B of the regulations, and by the specific 11 requirements for plant procedures and changes to plant 12 procedures which are written into Section 6 of the technical 13 specifications.
14 In the case of some things which are governed by the 15 regulations -- I'm thinking in terms of code requirements, ASME 16 code requirements, they are driven by the regulation which 17 references that code.
18 So these things take on the same regulatory status as 19 the document that they are relocated to.
20 COMMISSIONER ROGERS: Thank you.
21 CHAIRMAN ZECH: Well, I would certainly encourage you 22 to continue to work with individuals with operating experience 23 at the plants, those who will be using the tech specs, and make 24 sure that they get a chance to participate in this very 25 important endeavor.
1 46 1 I would also encourage you to look very carefully as 2' you go through the process at where we can reduce testing and l
- 3 surveillance at power. We have mentioned -- and you are going 4 to give us a paper on that.
5 Many of us, as we visited the plants, almost every 6 time, some discussion of tech specs comes up, and I have heard 7 it, you know, for a number of years now, and so -- and I am 8 encouraged by what you are telling us. I know we are making -
9 progress, but it's such an important program, and it does 10 impact on safety. It certainly could impact on safety. I've 11 seen some of the tech specs that we have in the control room, 12 and they are just voluminous, as we know, and it is 13 discouraging for the operators to have to even try, especially 14 in emergency situations or in time of stress, to use these 15 documents that are so voluminous.
16 So what you are doing is extremely important, and I 17 would just emphasize, I think it's awfully important for the l 18 operational people themselves to participate in this, because 19 they are going to be the b.nefactors in many ways. And also 20 they can make an input that's very real and practical, and so I 21 would encourage you, as you continue in the program, to ensure 22 you get the input from those in the plants themselves.
23 I guess the other thing that you've told me, I know 24 resources are always a problem for us, as well as the 25 utilities, and we must be realistic about it, and I asked you
- .- . -~ -
47 1 earlier about resources, and I think you told me that you 2 thought you had.enough resources t'o cover the program. But the
, 3 benefits of this program, if we are to achieve them in a timely 4 fashion, do require resources, we know that, and perhaps I 5 should ask Mr. Martin or Mr. Taylor if they think that NRC in 6 general, in headquarters and in the field, is applying proper 7 resources to this endeavor?
8 MR. MARTIN: At this point in time, we are. We do 9 not have standard tech specs in front of us to review. We 10 anticipate a major crunch and need of additional resources in
~
11 the fiscal year '90 timeframe. The budget we are working on 12 right now will reflect that, and again, we are going'in with an.
13 operational assumption that the majority of licensees will opt 14 for the standard tech specs. If we are hit with a wholesale 15 request for custom tech specs and pick-and-choose, then we have 16 not budgeted properly.
17 CHAIRMAN ZECH: Well, let's be mindful of that, l 18 because we are involved here in an area of amendments, and it 1
19 does take time and it does take resources, so I certainly agree l i
20 that I would hope that most would opt for the standard tech l 21 specs, but I submit, too, that if they participate in the 22 program, there perhaps may be more of a feeling of ownership.
23 They might be more motivated to do it, if they feel it's going 24 to be in their best interest, and if it's going to be in the 25 interest of reliability and safety.
48 1 So I think the approach you take is important, and 2 that's why I emphasize involvement of those who are going to be
_ 3 the users, and that may help with the resources, too.
4 Well, unless there are any comments from my fellow 5 Commissioners, let me just say --
6 COMMISSIONER CARR: May I make one comment?
7 CHAIRMAN ZECH: Commissioner Carr.
8 COMMISSIONER CARR: You started out on a note of 9 optimism, saying what a successful program this was. I imagine 10 if I asked the guy on the other end who has been waiting since 11 '83 to give you a mark, he might not agree with that, but I 12 encourage you to go ahead, this is very important, and we need 13 to get it done, and we need to get it behind us.
14 CHAIRMAN ZECH: Yes, I agree with that comment, too.
15 It's all relative, I suppose, from where you sit, but those of 16 us who have heard so many complaints about it, and have seen 17 the big thick books that we're talking about, have a certain 18 empathy for the operators. And on the other hand, we don't 19 belittle the task, and those of you who are involveJ: '.n it, I 20 commend you for your efforts, and just hope that resources will 21 be supplied, and I ask Mr. Taylor to take a special look at it 22 to make sure that we are putting our money and our resources 23 where our mouth is, because this is an important area, and it's 24 something I think we can gain in safety particularly in, and so 25 resources are important. But the schedule is important, too,
49 1 and we dol.'t want to see the schedule just keep drifting along.
2 And that's why we recognize that if we need to put more 3 resources, we'll just have to find out how to do that.
4 Mr. Rogers?
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5 COMMISSIONER ROGERS: Just one further though.t, and 6 that is I think that it is important to keep emphasizing and 7 reemphasizing that this is a program which really is going to l 8 improve safety. I think we all believe that. I think we 9 understand it, but I think it's very important that that point 10 be made at every single opportunity. Because it is easily 11 misconstrued, and that this -- that first the safety 12 improvements really are palpable that will come out of this, 13 I'm sure; but I think it's important not to simply say that and 14 then forget it, but to reemphasize it every time at every 15 opportunity. Because it's easy to misread this as something 16 that is being less assiduous or less regulatory in its nature, 17 when in a sense it really is a big step forward in improving 18 plant safety. And I think that is something we have to keep 19 reminding the world about.
20 CHAIRMAN ZECH: And perhaps also remind them that a 21 safe plant is a reliable plant is an economic plant, and they 22 all go together.
23 Any other comments?
24 All right. Thank you very much. We stand adjourned.
25 (Whereupon, at 3:50 p.m., the meeting was adjourned.)
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: Briefing on Technical Specification Revisions PLACE OF MEETING: Washington, D.C.
DATE OF MEETING: Monday, June 20, 1988 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
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Ann Riley & Associates, Ltd.
i
! COMMISSION BRIEFING 4
4 i
I ON THE 1
i TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM i
i i
i 1
i i JUNE 20, 1988 i
f i
i t
4
PROGRAM GOALS I
o IMPROVE OPERATIONAL SAFETY BY l
REDUCING THE SIZE AND COMPLEXITY OF TECH SPECS L .
MAKING TECH SPECS MORE UNDERSTANDABLE TO l OPERATIONS PERSONNEL .
l MAKING IMPROVEMENTS TO SPECIFIC TECHNICAL I REQUIREMENTS l
f REDUCING OPERATIONAL TRANSIENTS i
o PROVIDE A CLEARER LINK BETWEEN TECHNICAL
! REQUIREMENTS AND THEIR SAFETY SIGNIFICANCE ALLOW THE OPERATORS AND PLANT STAFF TO FOCUS l ON THE MORE RISK SIGNIFICANT REQUIREMENTS
) -
ALLOW FOR PROPER UNAMBIGUOUS INTERPRETATIONS OF TECH SPECS j
FACILITATE IMPROVEMENTS IN TRAINING i
IMPLEMENTATION OF THE INTERIM POLICY STATEMENT
! THE FROGRAM WILL IMPLEMENT THE COMMISSION'S POLICY STATEMENT THRU-I i
i 1. DEVELOPMENT OF NEW STS l
A PARALLEL PROGRAM OF SPECIFIC LINE ITEM
- 11.
IMPROVEMENTS TO TECHNICAL SPECIFICATIONS Ill. OTHER ACTIVITIES NECESSARY TO FU LLY IMPLEMENT THE POLICY STATEMENT I
i 1
- l. NEW STS DEVELOPM ENT o COMPLETED ACTIVITIES NRC STAFF REVIEWED MODEL SPECIFICATIONS MID 87 AND SUPPORTING DOCUMENTATION FOR TWO l OWNERS GROUPS -
KEY IMPLEMENTATION ISSUES ADDRESSED JAN 88 1
STS "SPLIT" REPORT ISSUED MAY 88 I
i o ONGOING / PLANNED ACTIVITIES STAFF VISITS LEAD PLANTS LATE 88 l
INDUSTRY COMPLETES REWRITE OF LATE 88-EARLY 89 l STS l -
STAFF COMPLETES REVIEWS OF NEW LATE 89-EARLY 90 I STS AND BEGINS REVIEW OF LEAD l PLANT SUBMITTALS ISSUE FINAL POLICY STATEMENT OCT 88 ADDITIONAL LICENSEE CONVERSIONS LATE 90 TO NEW STS i
4
II. PARALLEL PROGRAM FOR LINE ITEM IMPROVEMENTS o COMPLETED ACTIVITIES 4
REVISION OF THE STS GENERAL REQUIREMENTS 3.0/4.0 -
RELOCATION OF ORGANIZATION CHARTS .
W AND GE PLANTS RPS STI AND AOT EXTENSIONS '
RELOCAT'ON OF DETAILED LISTS AND TABLES o ONGOING / PLANNED ACTIVITIES
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l REMOVAL OF FIRE PROTECTION SYSTEM TS VENDOR OWNERS GROUPS' TOPICAL REPORTS l [ APPROX 7] RPS/ESFAS STI's AND AOT's .
I -
RELOCATION OF CYCLE-SPECIFIC PARAMETER LIMITS i
REMOVAL OF 3.25 LIMIT ON EXTENDING REFUELING l OUTAGE SURVEILLANCES REDUCED TESTING AT POWER PROGRAM I
i _ _ _
. . m j 111. OTHER MISC SUPPORT TASKS 1
i
)
). o GUIDELINES FOR CONDUCTING 10 CFR 50.59
,i I~ REVIEWS
! o RULEMAKING FOR RADIOLOGICAL EFFLUENT
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TECH SPECS _RETS_
o RISK-BASED TECHNICAL SPECIFICATIONS 4
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l._________-_________-__-_____________________-_-_-
OVERALL PROGRAM IMPACT ON SAFETY AND RESOURCE REQUIREMENTS -
I I .
l o IMPROVE OPERATIONAL SAFETY I
o MORE RELIABLE AND EFFICIENT PLANT
- OPERATION
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i b
o RESOURCE SAVINGS TO BOTH NRC AND INDUSTRY .
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