ML20210G702

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Summary of CRGR Meeting 94 on 860822 Re Final Draft of NRR Proposed Commission Policy Paper on Tech Specs.List of Attendees & Handouts Encl
ML20210G702
Person / Time
Issue date: 09/09/1986
From: Sniezek J
Committee To Review Generic Requirements
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20210G670 List:
References
NUDOCS 8609250454
Download: ML20210G702 (15)
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4 SEP9 1986 MEMORANDUM FOR: Victor Stello, Jr.

Executive Director for Operations FROM: James H. Sniezek, Chairman Committee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 94 The Committee to Review Generic Requirements (CRGR) met on Friday, August 22, 1986, from 10:00 a.m. to 12N. A list of attendees for this meeting is enclosed (Enclosure 1).

W. Russell, E. Butcher, and D. Fischer (NRR) presented for CRGR review a final draft of an NRR proposed Commission Policy Paper on Technical Specifications (final draft). Enclosure 2 summarizes this matter (Category 2 item).

Enclosure 2 contains predecisional information and, therefore, will not be released to the Public Document Room until the NRC has considered (in a public forum) or decided the matter addressed by the information.

In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," the item above requires written response from the cognizant office to report agreement or disagreement with CRGR recommendations in these minutes. The response, which is required within 5 working days after receipt of these meeting minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decision-making.

.' Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

J.E. Zerbe for James H. Sniezek, Chairman Comittee to Review Generic Requirements

Enclosures:

Distribution:

As Stated JHSniezek JRoe JZerbe PRabideau cc: Commission (5) JClifford FHebdon SECY GZwetzig WLittle Office Directors RErickson EFox Regional Administrators ROGR Staff JPhilips CRGR Members Central File W. Parler PDR (NRG/CRGR)

  • W. Russell E. Butcher D. Fischer 0FC :ROGR :ROGR/D g :DEDROGR  :  :  :  :

_____:. __________ ___ / , .____________:____________:___________

NAME :TCox% ::JEZ r ebI______:b

,zek  :  :  :  :

DATE :9/9/86 :9/j /E 6 :9/'7/86  :  :  :  :

8609250454 860919 PDR REVGP NRCCRGR MEETINGO94 PDR

Enclosure 1 LIST OF ATTENDEES CRGR MEETING NO. 94 August 22, 1986 CRGRMEMBERb J.H. Sniezek R. Bernero E. Jordan J. Scinto J. Heltemes R. Cunningham D. Ross

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OTHERS J. Zerbe T. Cox W. Schwink ,

R. Starostecki W.T. Russell J.C. Glynn S. Bryan J.H. Austin T. Dorian -

I. Recarte

- P. McKee K.D. Desai -

S. Newberry E.G.Igne ,

D.F. Humenansky e

. G l .

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D Enclosure 2 to the Minutes of CRGR Meeting No. 94 Review of a Proposed NRC Policy Statement on Technical Specification Improvement W. Russell, E. Butcher and D. Fischer presented a final draft of an NRR Proposed Commission Policy Paper on Technical Specifications (final draft).

The paper forwards a proposed Commission Policy Statement on Technical Specification Improvements as requested by the Commission in a Staff Requirements Memorandum dated February 21, 1986. NRR recommended that the policy statement should be approved for release for public comment.

The complete set of materials presented for CRGR review was as follows:

1. Memo, W. Russell to H. Denton dated 7/22/86. _
2. Draft Commission paper, undated, titled " Technical Specifications Policy Statement," (enclosed in 7/22/86 memo, item 1 above).
3. Copy of presentation vugraphs titled, " Proposed Commission Policy Statement on Technical Specifications," dated 8/22/86. ,
4. Federal Register Notice, Vol. 47, No. 61, 3/30/82.
5. List of Plant Systems Evaluated Against Proposed Criteria (Attachment 1).
6. Resource Estimates (Attachment 1).

D. Fischer began the presentation using the vugraphs, item 3 above. He noted the background activities leading to the current proposal, emphasizing that since the publication of NUREG-1094, a Technical Specification Improvement Program (TSIP) has been designed and that the current proposal is a high priority element of that program. The NRR presenters stated that the proposed policy statement is a first step in the practical implementation of changes to tech specs. The primary elements of the policy statement as presented were:

1. An invitation to licensees to propose that portions of their existing tech specs be relocated, not eliminated, to documents other than the tech specs, including the FSAR. Subsequent changes to the relocated tech specs l could then be made by the licensee without prior NRC. review and approval, and without processing a formal license amendment.
2. Strong encouragement to nuclear steam supply system vendor owners groups to undertake the development of revised periodic Standard Technical Specification (STS) based on the policy statement.
3. Three criteria intended to define which installed instrumentation, process variables, and systems, structures or components should be controlled by technical specifications in accord with 10 CFR 50.36.

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4. Identification of four nuclear plant systems for which operating parameters and surveillance requirements must be retained in tech specs j .regardless of the application of the three new criteria.

i 1 5. A Commission finding that risk evaluations using probabilistic techniques are an appropriate tool for defining requirements that should be retained in tech specs. ,

6. A statement that the NRC staff will also use risk insights and PRAs in evaluating the (proposed) revised STS, and in evaluating plant-specific submittals.
7. A list of five questions to be addressed in developing improved supporting bases Safety Settings for the Limiting) Conditions (LSSSs , Action of Operation Statements, (LCOs), Limiting and Surveillance System Requirements which would be retained in the technical specifications.
8. Commission recognition that certain amendments to the regulations may be necessary before the contents of tech specs can be limited to that
governed by the criteria presented in the policy statement.
9. Commission recognition that control processes for relocated tech specs must be carefully designed, and specifically 10 CFR 50.59 reviews must be improved. ,
10. A statement that current enforcement policy will apply to compliance with tech specs and with connitments contained in other licensee-controlled documents. Changes to licensee tech specs to apply the policy statement's i criteria would require a license amendment.

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NRR matntained that the policy statenent overall would neither improve nor '

degrade safety to any significant degree. The basis given for this was that the staff would assure risk control by review and approval of each. licensee l request for a license amendment to relccate tech specs. In addition, some' equipment is explicitly identified in the policy statement as being important enough to control by tech spec notwithstanding any application of new criteria.

Finally, some further controls are, or will be, embedded in license conditions.

NRR also presented some cost estimates in a separate handout (enclosed) that l indicated net savings to the regulated industry.

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l The CRGR had some difficulty following the financial analysis, due to some confusion about which costs or savings were summed over multiple plants and which were on a per-plant basis. CRGR members also expressed their opinion that the utility costs to implement revised STS, develop a writer's guide, and develop plant-specific tech specs seemed low. It was also observed that NRC savings might be illusory--that a sharper focus on significant safety matters could result in more license amendments having "significant hazards considerations" which could significantly increase NRC costs.

CRGR members also questioned the NRR assertion that the policy would or should be risk neutral--a consensus CRGR observation was that the policy, by assuring

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a better operator focus on fewer tech specs that_are carefully selected and clearly technically supported, should achieve a substantial risk reduction.

The CRGR Chairman noted during the meeting that if NRR identified worthwhile safety improvements in the process of pursuing the TSIP, then such improvements should be backfitted within the context of 10 CFR 50.109, even if this would tend to increase the number of tech specs for some plants.

NRR representatives noted, in response to a question about why the policy statem.ent didn't go further than relocations from existing tech specs, that the policy was not intended to result in any additions to the tech specs--but was expected to result in a decrease in the number of tech specs, and the retained tech specs should be more operator-oriented and have improved bases.

. One member observed that offering licensees the option of plant-specific efforts to change tech. specs one at a time while encouraging owners' group efforts to undertake the development of revised STS based on the policy statement was not the kind of definitive direction needed in a policy statement.

A CRGR concern was raised'about the paragraph at the bottom of page 9 of the draft policy statement stating that "...both the NRC and industry will give increased attention to changes made pursuant to 10 CFR 50.59...". The propriety of NRC appearing to direct industry effort through an NRC policy statement was questioned.

The concluding CRGR consensus was that for a number of reasons the policy statement was not adequate to receive a CRGR recommendation to issue for public coment. Several specific recommendations to NRR were agreed on before the meeting adjourned. These were:

1. The CRGR should review a revised proposal at a subsequent meeting.
2. Appropriate NRC headquarters' offices should concur in the proposed policy

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statement prior to the next CRGR review.

3. The policy statement is currently narrowly focused to the relocation of tech specs that do not meet any of the proposed criteria. The statement should recognize the broader objectives of the TSIP, and describe the relationship of the policy statement objectives to the overall TSIP.
4. The policy statement should state that the NUREG-1024 Section 4.1 recomendations must be met by proposals to revise STS.
5. The bases for tech specs to be relocated should also be examined and improved.
6. The basis for measuring the effect on plant risk of relocating / revising tech specs should be the risk level associated with the current plant design and operation. Changes in tech specs should not be examined incrementally for a potentially large number of relatively small changes.

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7. The policy statement should clearly describe the NRC staff review methods and acceptance criteria to be used to review licensee submittals proposing relocations.
8. 10 CFR 50.36 rulemaking should be continued, and policy proposal should be consistent with existing 50.36.

At the meeting, it was agreed that individual CRGR members could sLbmit additional comments in writing subsequent to the meeting. Several comments were written. Specific recommendations for changes have been compiled, and.those that are in addition to those covered in the above CRGR consensus. comments are included in Attachment 2. The CRGR recommends that the policy statement should be modified to address Committee concerns prior to further Committee review.

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Attachment 1 HANDOUT 2

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LIMERICK - SAFETY SYSTEMS WHICH MEET CRITERIA Captured by Criterion LC0 3.1 Reactivity Control Systems LC0 3.1.1 Shutdown Margin 2 LC0 3.1.2 Reactivity Anomalies 2 LCO 3.1.3 Control Rods 2,3 LCO 3.1.4 Control Rod Program Controls 2 LC0 3.2 Power Distribution Limits 2 LC0 3.3 Instrumentation LC0 3.3.1 - Reactor Frotection System Instru. 3 LC0 3.3.2 -

Isolation Actuation Instrumentation 3 LCO 3.3.3 - Emergency Core Cooling System 3 Actuation Instrumentation LCO 3.3.4 Recirculation Pump Trip Actuation Instru.

LCO 3.3.4.2 -

End of cycle Recirculation Pump Trip 3 System Instrumentation LCO 3.3.6 Control Rod Block Instrumentation 2 LC0 3.3.7 Monitoring Instrumentation LC0 3.3.7.1 - Radiation Monitoring Instrumentation 1,3 LCO 3.3.7.5 - Accident Monitoring Instrumentation 3 LCO 3.3.7.6 -

Source Range Monitors 2 LC0 3.4 Reactor Coolant System LCO 3.4.1 Recirc.lation System 2 LCO 3.4.2 Safety / Relief Valves 3 LCO 3.4.3 Reactor Coolant System Leakage 1,2 LC0 3.4.5 Specific Activity 2 LCO 3.4.6 Pressure /TemperatureLimits(RCS) 2 LCO 3.4.7 Main Steam Line Isolation Valves 3 LCO 3.4.8 Structural Integrity 3

.' LCO 3.5 Emergency Core Cooling Systems 3' LC0 3.6 Containment Systems 3

. LC0 3.6.1 Primary Containment 2 LCO 3.6.2 Depressurization Systems 3 LCO 3.6.3 Primary Containment Isolation Valves 3 LC0 3.6.4 ~ Vacuum Relief 2 l LCO 3.6.5 Secondary Containment 2 LCO 3.7 Plant Systems LCO 3.7.1 - Service Water Systems

_ LCO 3.7.1.1 - RHR Service 3 LCO 3.7.1.2 - Emergency Service Water System 3 LC0 3.7.1.3 - Ultimate Heat Sink 3 LCO 3.7.2 Control Room Emergency Fresh Air Supply System 3 LCO 3.8 Electrical Power Systems 3 LC0 3.8.4.3 Reactor Protection System Electrical Power 3 l Monitoring LC0 3.9 Refueling Operations j LC0 3.9.1 -

Reactor Mode Switch (Mode 5) 2

-LCO 3.9.4 - Decay Time 2 l

LCO 3.9.6 - Refueling Platform 2 LCO 3.9.7 - Crane Travel 2 LCO 3.9.8- -

Reactor Vessel Water Level 2 LC0 3.9.9 - Spent Fuel Storage Pool - Water Level 2 LCO 3.10 Special Test Exceptions 2 -

'LCO 3.11.1.4 Liquid Holdup' Tanks 2 LCO 3.11.2.6 Main Condenser 2

- m mu ms,s

. HAND 0UT 3 WOLF CREEK - SYSTEMS WHICH DON'T MEET CRITERIA 3.3 Instrumentation 3.3.3.1 Radiation Monitoring for Plant Operation

- Fuel Building -

Criticality Control Room Air Intake

  • 3.3.3.2 Moveable Incore Detectors 3.3.3.3 Seismic Instrumentation 3.3.3.4 Meteorological Instrumentation 3.3.3.5 Remote Shutdown Instrumentation
  • 3.3.3.7 Chlorine Detection Systems 3.3.3.8 Fire Detection Instrumentation 3.3.3.9 Loose-Part Detection System 3.3.3.10 Radioactive Liquid Effluent Monitoring Inst.

3.'3.3.11 Radioactive Gaseous Effluent Monitoring Inst.

3.3.4 Turbine Overspeed Protection 3.4.2.1 Safety Valves (Modes 4 and 5) 3.4.7 Chemistry (Primary)

  • 3.4.9.2 Pressurizer Temperature / Pressure limits
  • 3.4.9.3 OverpressureProtectionSystem(Modes 3,4,5,6 RCS 368 F) 3.4.11 RCS Vents
  • 3.5.4 ECCS Subsystems - TAVG 200'F 3.6.4.1 Hydrogen Analyzers
  • 3.7.1.3 Condensate Storage Tank (Plant specific)
  • 3.7.9 Sealed Source Leakage ,

3.7.10 Fire Suppression Systems

. 3.7.11 Fire Barriers 3.8.4.1 Electrical Equipment Protective Devices

  • 3.9 Refueling Operations 3.9.1 -

Boron Concentration 3.9.2 -

Instrumentation - Source Range Monitors 3.9.5 - Communications 3.9.6 - Refueling Machine 3.9.8 -

RHR and Coolant Circulation 3.9.12 - Spent Fuel Assembly Storage 3.11.1.1/2 Liquid Effluents l 3.11.1.3 Liquid Rad Waste Treatment System

' 3.11.2.1/2/3 Gaseous Effluents 3.11.2.4 Gaseous Rad Waste Treatment System 3.11.2.5 Explosive Gas Mixture 3.11.3 Solid Rad Waste

, 3.11.4 Total Dose l, 3.12 Radiological Environmental Monitoring l

3.12.1 - Monitoring Program 3.12.2 - Land Use Census l 3.12.3 - Interlab Comparison

  • Action Statement Limits Reactor Power l

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, HANDOUT 4 LIMERICK - SYSTEMS THAT DON'T MEET CRITERIA ,

3.1.5 Standby Liquid Control System **

3.3.4.1 ATWS Recirculation Pump Trip System **

Instrumentation 3.3.5 RCIC System Actuation Instrumentation **

3.3.7.2 Seismic Monitoring Instrumentation 3.3.7.3 Meteorological Monitoring Instrumentation .

3.3.7.4 Remote Shutdown System Instrumentation and Control

  • 3.3.7.7 Traversing In-Core Probe System 3.3.7.8 Chlorine / Toxic Gas Detection System 3.3.7.9 Fire Detection System 3.3.7.10 Loose Part Detection System 3.3.7.11 Radioactive Liquid Effluent Monitoring Instru.

3.3.7.12 Radioactive Gaseous Effluent Monitoring Instru.

3.3.8 Turbine Overspeed Protection System 3.3.9 Feedwater/ Main Turbine Trip System Actuation

3.6.1.2 Primary Containment Leakage 3.6.1.5 Primary Containment Structural Integrity

  • 3.6.2.2 Suppression Pool Spray
  • 3.6.6.1 -

Recombiner System 3.6.6.2 -

Drywell Hydrogen Mixing System 3.6.6.3 -

Drywell and Suppression Chamber Oxygen Concentration 3.7.3 Reactor Core Isolation System **

3.7.4 Snubbers

  • 3.7.5 Sealed Source Contamination 3.7.6 Fire Suppression Systems 3.7.7 Fire Related Assemblies 3.8.4.1 Electrical Equipment Protective Devices

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3.8.4.2 Motor-Operated Valve Thermal Overload Protection 3.9 Refueling Operations 3.9.2 -

Instrumentation (2 source range monitors) 3.9.3 -

Control Rod Position 3.9.5 -

Comunications 3.9.10 -

Control Rod Removal 3.9.11 -

RHR and Coolant Circulation HI/ LOW Water Level 3.10.5 0xygen Concentration Special Test

  • 3.11.1.1/2/3 Liquid Effluents 3.11.2.1/2/3 Gaseous Effluents

/4/5 3.11.3 Solid Radwaste Treatment 3.11.4 Total Dose 3.12 Radiological Environmental Monitoring 3.12.1 -

Monitoring Program 3.12.2 -

Land Use Census 3.12.3 -

Interlaboratory Comparison

  • Action Statement Limits Reactor Power
    • Retained as a Technical Specification Based on Operating Experience and Risk Insights.

. Attachment 1

HANDOUT 1 WOLF CREEK - SAFETY SYSTEMS WHICH MEET CRITERIA Captured by Criterion

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3.1.1 Reactivity Control Systems 2 3.1.2 Boration Systems 3 3.1.3 Moveable Control Assemblies 2 3.2 Power Distribution Limits 2 3.3 Instrumentation 3.3.1 -

Reactor Trip System 3 3.3.2 -

Engineered Safety Features -

3 3.3.3 -

Radiation Monitoring for Plant Ops. 1,3 3.3.3.6 - Accident Monitoring 3 3.4 Reactor Coolant System 3.4.1 Reactor Coolant Loops and Coolant Circulation 2,3 3.4.2.2 Safety Valves (Modes 1, 2, and 3) 3 3.4.3 Pressurizer B/U Heaters and Water Level 2,3 3.4.4 Relief Valves (All PORVs and Block Valves) 3 3.4.5 Steam Generators (Modes 1 through 4) 3

, 3.4.6 Reactor Coolant System Leakage 1,2 3.4.8 Specific Activity 2 3.4.9 Pressure / Temperature Limits (RCS) 2 3.4.10 Structural Integrity 3 3.5 Emergency Core Cooling Systems 3,2 3.6.1 Containment Systems - Primary Containment 2,3 3.6.2 Depressurization and Cooling Systems 3 3

3.6.3 Containment Isolation Valves 3

.. 3.7.1.1 Safety Valves . 3

3.7.1.2 Auxiliary Feedwater System 3 l . 3.7.1.4 Specific Activity 2 3.7.1.5 Main Steam Line Isolation Valves 3 3.7.3 Component Cooling Water System 3 3.7.4 Essential Service Water System 3 3.7.5 Ultimate Heat Sink 3 3.7.6 Control Room Emergency Ventilation System 3 3.7.7 Emergency Exhaust Systems 3 3.7.12 Area Temperature Monitoring 2 3.8 Electrical Power Systems 3 3.9 Refueling Operations 3.9.3 - Decay Time 2 3.9.4 - Containment Building Penetrations 2,3 3.9.7 -

Crane Travel 3 3.9.9 - Containment Ventilation System 2,3 3.9.10 -

Reactor Vessel and Storage Pool -

Water Level 2 3.9.13 - Emergency Exhaust System 3.10 Special Test Exceptions 2 3.11.1.4 Liquid Holdup Tanks 2 3.11.2.6 Gas Storage Tanks 2 O

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Attachment 1 NRC RESOURCE ESTIMATE Approx.

I. Implementation Cost: _ Amount

1. Review of the revised STS ,,($600M)

(2 PSY) (4 Owners Groups) ($72,000/PSY)

2. Reviewing writers guide . ($100K)
3. Develop guidance for reviewing ($100K) individual license amendments
4. Review of lant specific license amendments ($3.5M)

(0.5 PSY (50)($140,000/PSY)

5. Training ($140K) 2 PSY TOTAL ($4.4M)*

II. Post Implementation Resource Estimate:

A. Cost (per year)

1. Additional review and follow-up on annual 50.59' ($30K) s/ reports and audits (NRR) (10-17 staff-hours)

(50 plants) ($40/ staff-hour)

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2. Additional Review of annual 50.59 reports and ($100K)

'- audits (IE) (30-50 staff-hours) (50 plants)

,, ($40/ staff-hour)

3. Compliance inspection for relocated requirements ($140K)
(IE) 2 PSY
4. Incremental staff increase for escalated ($40K) enforcement (IE) 0.5 PSY .

TOTAL (310K)

Annually B. SAVINGS (per year)

$1.4M 1.Reducedprocessing)oflicenseamendments(0.40 (1 PSY) (50 plants reduction) ($72,000/PSY)

. C. NET ANNUAL SAVINGS TO NRC $1.1M

  • ($2.7M) if in-house personnel are used for reviewing the plant specific license amendment requests. The majority of either amount will be directly chargeable to licensees and the owners groups.

Attachm7nt 1 .

2-UTILITY RESOURCE ESTIMATE (f\ \F )

~ Approx.

I. Implementation Costs , Amount 3

1. Develop Revised STS* ($1.5M)
2. Develop Writers Guide ($0.5M) -
3. Develop Plant Specific TS ($7.5M)

TOTAL ($9.5M)

II. Post Implementation Resource Estimate *

1. Effects of splitting TS $100M (1-3/ unit / year)(50 plants) -
2. Lengthening Surveillance Intervals and $12.5M Equipment Out of Service Time

($250K/affected unit / year) (50 plants)

TOTAL $112.5M ANNUALLY ASSUMPTIONS:

1. $72,000/PSY for in-house NRC employees.
2. $140,000/PSY for contractor employees.
3. 50 licensees will file license amendments consistent with the Policy Statement.
4. It will take about as much effort (0.5 PSY) to review each individual license amendment that conform to the revised STS as it does to review the TSs for an NTOL plant.
5. It will take about four times as much effort to review the revised STS as it does to review the TSs for an NTOL plant.
6. A 40% reduction in TS would result in a 40% reduction in license amendments due to TS.

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  • Based on Industry Estimates.

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Attachment 2 to Enclosure 2 Compilation of CRGR Member Recommendations for Changes to Proposed Policy Statement

1. There are serious legal issues. 0GC must review and approve.
2. The proposal should contain a discussion of why staff concludes that tech specs as established by new criteria would satisfy the current statutory standards.
3. The proposed program to improve tech spec language and basis should be recognized as risk beneficial, not risk neutral.

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Staff paper should better support the proposed need for any NRC staff review and approval of plant or procedure changes.

4. Objectives (targets) of policy statement both long- and short-term should be more clearly and separately identified. NRC justification should be more explicit on the problems and safety benefits of tech spec reform.

Should better treat the selection of this approach among alternatives.

5. The proposition that paper processing is substantially reduced is flawed.

If 50.59 reviews are improved as intended by TSIP, difference in current versus future paper work is minimal.. The paper generally attempts to claim great value in the wrong areas. Should correct this.

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6. The paper does not adequately treat the 50.59 problem. A Regulatory Guide or similar guidance document will not alone compensate for basic flaws in the current 50.59 regulation. Believes that revision to 50.59 is necessary. -
7. Policy statement grammar and diction are weak and ambiguous. Paper should

. be improved by OGC's review, i

8. If program is voluntary, the plant owners who most need it are the least

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likely participants. This should be clearly presented to the Commission.

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9. Proposed policy statement should more clearly state that the staff'would strongly pursue long-range tech spec improvements as well as the l short-term relocations of tech specs.
10. The five recommendations of NUREG-1024 should each be addressed explicitly in the proposal. To the extent that the policy statement falls short of I the five recommendations of NUREG-1024, the policy statement is not responsive to the SECY-86-10 commitment.
11. Commenter believes that CRGR should endorse a policy statement to Commission for public comment, with certain caveats:
a. CRGR should monitor implementation of policy statement to determine whether plants known to have problems related to tech specs are participating in the program.

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b. NRR should assure that each of five recomendations in NUREG-1024 is implemented by owners' groups proposed tech spec revisions. .
c. Comission should receive periodic progress reports in which the need for further regulatory remedies is evaluated.

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