ML20214T810

Rev 2 to NRC Tech Specs Improvement Program Plan

ML20214T810
Person / Time
Issue date:	06/30/1987
From:	Office of Nuclear Reactor Regulation
To:
References
PROC-870630, NUDOCS 8706100431
Download: ML20214T810 (25)

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NRC TECHNICAL SPECIFICATIONS _ l IMPROVEMENT PROGRAM PLAN j l

i REV. 2 i 1

i JUNE, 1987

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Prepared by: l 1

Technical Specifications Branch I 1

Office of Nuclear Reactor Regulation J

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TABLE OF CONTENTS TECHNICAL SPECIFICATIONS IMPROVEMENT PP.0 GRAM PLAN ,

PAGE i 1.0. INTRODUCTION................................................. I  !

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2.0 DEVELOPMENT OF NEW STS............................,,......... 2 2.1 Trial Use of AIF a nd TSIP Cri teria. . . . . . . . . . . . . . . . . . . . . . 2 l 2.2 Devel op Commi ssion Policy Statement. . . . . . . . . . . . . . . . . . . . . 2 )

2.3 Improvements to TS Text and Bases Sections.............t. 3 2.4 Improvements to Sections 5.0 and 6. 0 of STS. . . . . . . . .< . . . 3 l 2.5 Industry Preparation / Submittal of New STS............... 4 ,

2.6 Plant Specific Implementation of New STS................ 8 '

3.0 SFECIFIC LINE ITEM IMPROVEMENTS TO TECHNICAL SPECIFICATION.. 9 3.1 Improvements ir.itiated by the NRC....................... 11 3.2 Improvements initisted by the Industry.................. 11 4.0 IMPROVEMENTS NECESSARY TO FULLY IMPLEMENT THE POLICY STATEMENT................................................... 13 4.1 Rule Changes............................................ 13 ,

4.2 PRA Methods for STS Improvements........................ 14 '

4.3 Controls for Requirements Trensferred from the Control of the TS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 APPENDIX A - Historical Background of the Improvement Program.....Al-A2 APPENDIX B - Purpose of Technical Specifications and Screening Criteria as Specified in the Interim Policy Statement.......................................... 391-B2 i APPENDIX C - Short Term Technical Specification Improvements Using the Lea d Pl a n Approach. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . C1-C3 i

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l TECHNICAL SPECIFICATIONS IMPROVEMENT l

PP0 GRAM PLAN l I. INTRODUCTIO_N j

The NRC Technical Specification Iniprovement Program Plan was originally issued on May 1, 1986. A brief summary of the historical background of l the Improvement Program is provided in Appendix A. l This revision of the Program Plan is being issued in response to the  !

Commission's recently promulgated interim Policy Statement on Technical Specification Improvements. The Program Plan now emphasizes the details of j how to implement (as opposed to develop) the Commission's Policy Statement on Technical Specification Improvements under the new organization.

The interim Policy Statement presents the policy of the Nuclear Regulatory Commission (NRC) with respect to the scope and purpose of Technical Specifications for nuclear power plants as required by 10 CFR 50.36. It establishes a specific set of objective criteria for determining which regulatory requirements and ooerating restrictions shculd be included in Technical Specifications (see Appendix B). It encourages licensees to implement a voluntary program to update their Technical Specifications (TS) to be consistent with revised vendor-specific Standard Technical Specifications (STS) to be developed by the industry based on these criteria and subject to NRC Staff approval,. The new STS will contain improved Technical Specifications, including upgraded Bases sections, significant human factors improvements. and greater use of risk and Probabilistic Risk Assessments insights. The Policy Statement also identifies mechanisms to be used by the NRC and industry to control changes to those items removed from Technical Specifications.

The purpose of the Technical Specification Improvement Program Plan is to identify activities that need to be completed to meet program objectives.

The first program objective is to make substantial general improvements to the format and content of Technical Specifications (see Section 2 below).

This objective will be achieved through the development of new Stanuard Technical Specifications (STS). A second, but no less important, program objective is to make specific line item improvements to the requirements in Technical Specifications (see Section 3). These two objectives are consistent with the two major recommendations of the Technical Specification Improvement Project (TSIP) and AIF discussed in Appendix A.

Another purpose of this revision to the Pregram Plan is to highlight completed improvement activities and outline the status of ongoing activities. This will provide the user with the background information necessary to understand why specific future activities are included in the Plan.

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l 2.0 DEVELOPMENT OF NEW STS The. objective of the activities described in this section is to make substantial general improvemcnts to the format and content of STS. The s plan for achieving this program objective is for the Staff to work with the four major U.S. NSSS vendor owners groups to develop new STS that are based on the Commission's interim. Policy Statement. The new STS will .

then be used as guides in preparing new Technical Specifications for i operating reactors and for future license applications.

2.1 Trial Use of AIF and TSIP Criteria (COMPLETED)

Before the staff recommended that the Commission issue a Policy Statement based on the AIF and TSIP criteria (for determining which regulatory requirements and operating restrictions should be retained in TS), these criteria were validated (i.e., shown to be technically sound and practical toimplement). The validation process was by a. trial use of the criteria on operating reactor TS for both a PWR and BWR plant. The plants chosen were Wolf Creek (Westinghouse) and Limerick (General Electric). These plants were chosen because they represented recently licensed plants and their TS included a full range of current requirements. The results of the trial use study were factored into the interim criteria recommended to the Commission. Additional practical experience with the criteria is being gained in the ongoing early phases of the owners groups program to develop the new STS. The risk significance of relocating requirements from current Technical Specifications to other licensee controlled documents, as allowed by the interim Policy Statement, was also evaluated and shown to be negligible.

2.2 Develop Final Commission Policy Statement (ONGOINGACTIVITIES)

The second step in the process of developing the new STS was to issue a Commission Policy Statement which defines the scope, purpose, and content for Technical Specifications. The core of this Policy Statement is the TS selection criteria validated by the process outlined in Section 2.1 above. This Policy Statement provides. guidance and direction for the remcining NRC and Industry activities necessary to develop the new STS.

Completed Activities and Status The first draft of a Commission Paper forwarding a proposed Policy Statement was circulated for review and comments to each NRC Program Office on May 8, 1986. A second-draft was forwarded to the ACRS on June 30, 1986. Presentations were made to the ACRS on July I'and 11, 1986.

By le+ter dated July 15, 1986 the ACRS endorsed issuing ~the proposed Policy Statement on Technical Specification Improvements for public comment.

CRGR reviewed the Commission Paper on August 22 and October 8, 1986. It was forwarded to the Commission on October 21,1986(SECY-86-310). By

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Staff Requirements Memorandum dated January 9,1987 the Connission approved a slightly modified Policy Statement for interim use and public  ;

comment. The interim Policy Statement was published in the Federal  !

Register on February 6, 1987. The public comment period expired on l March 23, 1987.

l Future Activities and Schedule Goals

1. Public comments reviewed and addressed Start-03/22/87 in a second Commission Paper on the Finish-06/26/87 interim Policy Statement. Commission Paper Issued.

2. Commission deliberation and action on Start-06/26/87-the Connission Paper. Finish-08/31/87 2.3 Development of New Standard Format for STS (ONG0INGACTIVITIES)

In addition to relocating less important requirements from the existing l STS by application of the selection criteria, implementing the interim l Policy Statement will also, through the application of human factors i principles, add clarity to the STS. An important activity in this regard is the development of a new standard format for the STS including the Bases sections. This work will be completed and available for use in .

preparing the new STS discussed in Section 2.5. l Completed Activi, ties and Status On July 28, 1986, the NRC received a draft revision to ANSI /ANS 58.4,

" Criteria for Technical Specifications for Nuclear Power Stations", ,

that included a TS Writers Guide. Lawrence Livermore National Laboratory  ;

issued its final report on " Standard Format and Content Guide for TS Bases" on July 22, 1986. This report was forwarded to the standards committee 1 for use in preparing the revision to ANS 58.4. A revised draft of the i proposed ANS Standard was forwarded to the NRC on February 12, 1987 along '

with a recuest for endorsement. The staff found the draft ANS Standard to be "an acceptable basis upon which the individual owners groups can continue the development of the restructured STS" (1tr. from E. Rossi to S. Webster dated May 26,1987). Now that general agreement has been ,

reached on the structural format, the NRC and industry will focus on )

standardizing the language and technical requirements within the body of j the new STS. As described in Section 2.S.3, the NRC will work with the '

owners groups to resolve these later concerns.

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2.4 Improvements to Sections S.0 and 6.0 STS (ONGOINGACTIVITIES)  ;

I The Policy Statement establishes LC0 selection criteria but does not  ;

provide specific. guidance for incorporating improvements to the STS sections on Design Features (5.0) and Administrative Controls (6.0).

Improvements to these sections of the STS will be developed by the Technical Specifications Branch and incorporated into the new STS. ,

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-4 Completed Activities and Status Discussions have been held between NRC and industry to identify improvements that can be made to Sections 5.0 and 6.0 and alternatives for making these improvements. On August 6, 1986 NRC received a draft proposal for a major revision to Sections 5 and 6 of the STS. As a result of this draft proposal a meeting between NRR, IE, 0GC, and AIF was held to clarify legal requirements. A revised draft proposal was submitted by AIF on December 3, 1986. The Staff requested that AIF clarify its proposa~l and formclly submit it to NRC for review. On February 2, 1987 AIF 1 provided suggested changes to Sections 5.0 and 6.0 of the STS along with a general discussion and justification for those changes.

Future Activities and Schedule Goals l

1. The Staff will review AIF's suggested Start-05/87 changes to Sections 5.0 and 6.0 and Finish-07/87 j

p(rovide Proposedwritten feedbackwill rule changes to industry.

be initiated if needed.)

2. Discussions will be held with Industry Start-05/09/86 to identify additional improvements Finish-09/87 that can be made to Sections 5.0 and l 6.0. I i

3. The Staff will issue guidance on Start-09/87 additicnal improvements that can be Finish-01/88 I

made to Sections 5.0 and 6.0 l

2.5 Industry Preparation / Submittal of New STS '(ONGOINGACTIVITIES)

The Industry is taking the lead in developing new STS (based on the interim Conmission Policy Statement) and w!11 submit them via a Topical l Report from each owners group for NRC staff review. When a section of, or the complete, new STS is submitted to the NRC, it will be accompanied i by a companien document which identifies how each requirement relocated from control by the T5 would be controlled under the new system (e.g.,

Procedures, QA Program, etc.) i Completed Activities and Status The individual owners groups have initiated programs for developing the new STS and submitting them for NRC staff review and approval. Each of l the owners groups has selected an operating plant to be the lead plant for implementing the new STS.

Owners Group Lead Plant B&WOG Crystal River l WOG North Anna EE0G San Onofre 2/3 BWROG Hatch 2 i

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Comoleted Activities and Status (con't)

This will. provide the opportunity to review the application of the new STS to an actual plant and thereby facilitate Staff review of the new STS.

Prior to the. submittal of the complete new STS, model specifications of selected parts of the new STS wi}l be prepared by each of the owners groups and submitted to the NRC (currently CE does not plan to submit a model of its new STS) for staff review. Model specifications have been received from the Westinghouse and Babcock & Wilcox Owners Group. Based on the staff review of the model STS, additional interaction with the AIF and Owners Groups will take place to assure a consistent style and format for the new STS. I The NRC staff and the Industry will continue discussions on the process 3 to be used to develop and review the new STS. Specific milestones and i schedule goals will be established for each owners group. For planning  ;

purposes B&W has established a schedule goal of September 1987 to submit .i the new B&W STS. '

Future Activities and Schedule Goals

1. The Staff will review (Phat,e I) a model of the new STS to be submitted by each owners group and docun;ent this review in an Assessment Report.

a. -WOG Start-03/87  !

Finish-05/87 l Completed, Assessment '

P,eport Issued on 05/05/87.

b. B&WOG Start-02/87 Finish-06/87

c. CE0G Start-TBD Finish-

d. BWROG Start-TBD Finish-

2. Develop review plan / milestones .for the Start-03/06/87 staff's new STS review. Finish-07/87

3. Staff interaction with AIF and Owners Start-11/06/85 Groups to reach agreement on the Finish-08/87 reouired level of standardization of style and format between individual vendor STS (see Section 2.3).

Future Activities and Schedules Goals (con't)

4. Determine what documentation will be Start-06/87 needed to support CRGR review of Owners Finish-08/87 Group prepared new STS. l

5. Determine whether 10 CFR 50.91 and Start-04/87 50.92 (Sholly) can be dealt with on Finish-08/87 a generic basis by the Owners Groups and if so how (The following organizational elements will be involved in this determination: TSB,PD-II-2,and0GC).

6. Review result of Owners Group l application of TS screening criteria to existing STS.

a. -WOG Start-08/87 Finish-11/87 l

b. B&WOG Start-06/87 Finish-08/87

c. CE0G Start-TBD Finish-

d. BWROG Start-TBD Finish- 1 i

7. Develop staff reviewer guidelines for Start-03/87 review of new STS. These guide ~1ines Finish-09/87 will, among other things, address:

a. requirements for Bases sections,

b. the question of " margin of safety" (10 CFR 50.59) and whether it is adequately addressed in the Bases, and

c. the uss of risk evaluations as an appropriate tool for defining requirements that should be retained in the STS.

Future Activities and Schedule Goals (con't)

8. Prepare a standard format for the SER Start-04/87 which will document the staff's review Finish-09/87 of new STS topical reports. Ensure that SER contains the items required by NRR Office Letter 39, the CRGR charter, the Commission's Policy Statement, etc.

9. Staff interaction with AIF and Owners Start-05/22/86 Groups on the need for additional Finish-10/30/87 i guidance for control of relocated TS requirements. (See Section 4.3).

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10. Review industry identified generic Start-04/27/87 )

issues related to new STS (and Finish-12/87 l individual plant TS) development I and their proposed resolution.

Respond to industry positions re:

a. Chapter Organization and Table Start-06/87 of Contents. Finish-09/83 l I

b. STS reference to other documents. Start-06/87 {

Finish-09/87 '

c. Requirements in regulations Start-TBD being duplicated in Technical Finish-12/87 Specification (see section 4.1). i I

d. Removal of Lists and Tables Sta rt-06/87 Finish-09/87

e. The definition of operable and the Start-06/87 statement of LCOs in terms of Finish-09/87 operability.

11. Owners Group submittals of new STS.

a. WOG Finish-05/88

b. B&WOG Finish-09/87

c. CEOG Finish-TBD

d. BWROG Finish-TBD

Future Activities and Schedule Goals (con't)

12. Staff review (Phase II) of new STS.

This includes a review of new STS for consistency with the Policy Statement, previous interpretations of specific Technical Specifications, and previous generic studies concerning TSs (e.g., j ContainmentStudy),

a. WOG

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b. B&WOG Start-09/87 Finish-06/88

c. CE0G Start-TBD Finish-

d. BWROG Start-TBD Finish-2.6 Plant Specific Implementation of New STS (PLANNEDACTIVITIES)

The Technical Specifications Branch will, in conjunction with Industry, l develop guidelines for the contents of the individual licensee amendment submittals necessary to convert to the new STS. A requirement for the i submittal package will be some document or method to identify how each l requirement removed from the TS would be controlled after the license is amended. The effective date of the amendment would be specified to allow time for any required changes in.the licensee's procedure and administrative cont ols as well as to allow for an appropriate period of operator training on the new TS. Review guidelines will be prepared for use by the NRC staff in evaluating the plant specific amendments converting to the new STS.

Future Activities and Schedule Goals

1. Develop a staff position on-individual' Start-09/87 licensee proposals for alternative Finish-03/88 1 approaches to TS improvement that are different than the new STS approach. If the staff will consider such alternative approaches, how will they be handled, on what schedule and what will be the  ;

acceptance criteria?

2. Establish standard milestones and Start-10/87 timetable for review of individual Finish-12/87 license amendment reauests for conversion to the new STS.  !

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3. Develop staff review guidelines for Start-09/87 individual license amendment requests Finish-03/88 that are based on the Policy Statement.

Among other things, these guidelines should specifically address:

a. What the licensee's proposed Technical Specification should be reviewed against (i.e., Will licensees be required to accept the new STS in their entirety, including requirements that do not exist in their current plant TS?).

b. Can licensee's select A0T's and TI's from either the new STS or their current TS. Or must they comply with the new STS requirements unless a plant unique design feature dictates otherwise.

3.0 SPECIFIC LINE ITEM IMPROVEMENTS TO TECHNICAL SPECIFICATION NRC and Industry agree that many specific line item improvements in the current TS should be made in parallel with the plan to develop new STS as discussed in Section 2.0. These specific line item improvements deal with adjustments to surveillance intervals, allowed outage times, etc. and are needed to resolve recurring problems with certain technical and administrative requirements in TS. Specific line item improvements which are reviewed and approved by the NRC staff prior to approval of the new STS will be incorporated into the new STS. (The owners groups' submittals of the new STS should not be used as a primary mechanism for initiating action on these types of improvements).

Specific line item improvements to TS may be proposed by either the NRC or Industry. The process through which these improvements are reviewed, approved, and ultimately incorporated into plant TS will depend on who initiates action on the inprovements, when the improvement is approved, and on the mechanism chosen to initiate the improvement (see figure 1).

Basicall Letter (y, thethe with NRC can initiate revision to theaexisting change STS by either preparing atttched) or byapreparing Generic a revision to the new STS topical report SER. The decision on which mechanism the NRC will use depends on whether or not the new STS has been approved by the Staff yet.

Industry can initiate specific'line item improvements to the STS by either submitting to the NRC 1) an Owners Group endorsed lead plant license

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amendment request, 2) a topical report, or 3) a revision to the new STS topical report (after the new STS has been reviewed and approved by the Staff).

9 FIGURE 1 TO BE INSERTED l

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1 3.1 Specific Line Item Technical Saecification (ONGOINGACTIVITIES) l Improvements Initiated by the iRC The NRC has initiated several improvements to TS which are applicable to all plants without regard to vendor design, e.g., a generic letter and associated revision to the STS has been prepared on modification of the general requirements of Section 3/4.0. While these types of changes can be initiated and developed by the Staff without significant input from the Industry, resource constraints preclude the staff from initiating further specific line item improvements at this time. Rather, the staff will utilize available resources to consider industry initiated improvements in  !

these areas (e.g., submitted by industry based on either the topical i report or lead plant approach). I 3.2 Specific Line Item Technical Specification (ONGOINGACTIVITIES)

]5provementsInitiatedbyIndustry Industry is initiating numerous improvements to TS which are a a selected group of plants (e.g., a given reactor vendor type)pplicable to Regardless of which approach used to initiate these changes they usually require specific and often detailed submittals from Industry which must be reviewed by a technical specialist branch within the NRC. They frequently involve relaxation of Allowed Outage Times (A0Ts) and Surveillance Intervals (SI's) associated with STS requirements.

Topical Reports The staff review of the Topical Reports which have already been submitted or are planned for the near future are listed as specific activities below. The schedule for future Topical Report reviews is based on past experience and the assumptions that it will take six months for the technical review (typically by a contractor); two months for the preparation of the SER (by the appropriate technical review branch); three months to develop a Generic Letter with the revised STS attached (by Technical Specifications Branch) and to secure interoffice concurrence; and two months for CRGR review [13 month total].  !

Topical Report Peviews Schedule Goals

1. Review B&W Topical Report BAv'-10167 Start-03/87 on RPS SI extension. Finish-03/88

2. Review CE Topical Report CEN-327 on Start-06/86 RPS and ESFAS SI and A0T extension. Finish-02/88

3. Review GE Topical Peport HEDC-30844, Start-01/85 Response to NRC ATWS GL 83-28, Finish-07/31/87 item 4.5.3.

4. Review GE Topical Report NEDC-30851P, Start-05/85 on RPS. Finish-07/31/87

l Topical Report Reviews Schedule Goals (con't)

5. Review GE Topical Report NEDC-30851P, Start-06/86 1 Suppl. 1 on Rod Block Instrumentation. Finish-5 months after 1 issuance of Staff's SER.

(est.SER03/88)

6. Review GE Topical Report NEDC-30851P, Start-TBD Suppl. 2 on Isolation Instrumentation Finish-Unscheduled common to RPS/ECCS. )

7. Review GE Topical Report NEDC-30936P, Start-11/85 j Part 1 on ECCS Actuation Instrumentation. Finish-5 months after i issuance of Staff's SER. )

(est. SER 11/87) l

8. Review GE Topical Peport NEDC-30936P, Start-TBD {

Part 2 on ECCS Actuation Instrumentation. Finish-Unscheduled  !

9. Review W Topical Report WCAP-10271, Start-TBD Suppl. 'l on ESFAS SI and A0T extension. Finish-5 months after l issuance of Staff's SER. '

(est. SER 10/87)  ;

i Lead Plant Items The second approach which Industry can use to initiate an improvement to the STS is a plant specific licerse amendment which has been endorsed by-the Industry (e.g., an Owners Group) as a candidate for consideration l under the Technical Specification Improvement Program. This approach is  !

referred to as the Lead Plant Approach. A procedure for handling l proposals under the lead plant approach was provided in a letter to AIF {

from the Director of NRR on May 5,1986 (see Appendix C). The schedule f for future Lead Plant reviews is based on past experience and the assumptions that it will take two months for the preparation of the SER (by the appropriate technical review branch); three months to develop a Generic Letter with the revised STS attached (by Technical Specifications Branch)[and review 7 months to secure total). interoffice concurrence; and two months for CRGR Lead Plant Reviews and Schedule Goals

10. Crystal River (B&W) request on Reactor Start-C8/14/86 Vessel Vent Valve -(RVVV) Surveillance Finish-Seven months Interval. after staff SER is '

completed.

11.Oconee(B&W)requesttomodifySpecs Start-05/87 related to cycle specific variables Finish-12/87 j (e.g. rod insertion limits). Changes '

will eliminate the need for a license amendment for each fuel cycle.

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14.McGuire(W)requesttoirbemoyfresctor Start-05/87L vessel pressure temperaturiWsviind Finish-12/87 capsule removal schedule. " " * {

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. 3 There are a number of tasks which the 'Inte$m Policy Statement includes ;

as things td be accomplished in conjunctics with the development of the ~ i new STS 'These planned activities suppoYt the developmept of.new STS and d the overall Technical Spec Mication Improvement Program but are not-critical in terms of devuopin'y the new STS.

3 N 4)1 Rule Chang (PLANNEDACTIVJTIES) ,

A nuScer of rules which rekt to Technica1[ Specifications may need td be  !

revised to implement some> aspects program of TS improvements considered l desirable by the Staff,..and Industry. For example 10 CFR 50.36a on I i'

Radiological. Effibent Technical Specifications would have to be amended j before radiologidal effluent controls can be transferred from the TS i to another document. The Staff will initiate in parallel with issuance of the Policy Statement the rule changes necessary to ful}y implement the i\

Policy Statement as well as to reduce the number of redundant requirements in the regulations. In the interim, the staff will corgsidxr exemptjon requests that are consistent with the interim Policy Stute}xent and thy -

"y s .i overall Technical Specification Improvement Program. A rul'echange to ' '

codify the criteria vill not be initiated until experience using the-criteria under a Policy ^ Statement has been)$ained. ,

Future; Activities and Schedule Goalc

.x 1. Develop an NRit Research "U.sers Start-07/87 Need Request" to initiate rulemaking- Finish-08/87 to remove RETS from TSL included on the '

s q Reguh. tory Agenda '

rulemakingpackage.)(Researchtodevelop

2. DiscuskwithIndustry$hichTS Start-05/87 requirements are redtadant to NRC 1 Finish-09/87 regulations and decide which are the 'l J most advantageous to pursue (e.g.,

delete section 6.4 of TS because it ([

is redundant to the revised Part 55, f Operators' Licenses, affective 1

'l hay 26,1987). " '

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1 4.2 PRA fiethods for STS Improvements (PLANNEDACTIVITIES) l The Commission Policy Statement on Technical Specification Improvements states that, as a part of the Comission's ongoing program of improving Technical Specifications, it will continue research in methods to make better use of risk and reliability considerations for defining future generic Technical. Specification requirements. The following activities are designed to implement this aspect of the Policy Statement.

Future Activities and Schedule Goals

1. A survey of the state-of-the-art Start-02/87 alternative approaches, especially Finish-10/87 risk-based approaches, for optimizing the effectiveness of TS as a rick- l controlled mechanism, will be performed. 1 This will include methodologies and J techniques developed both in the United i States and foreign countries. A detailed '

work plan has been developed for:

(a) identifying practical approaches for optimizing the effectiveness of TS as i a risk-control mechanism, as mentioned above, (b)evaluatingthealternativeapproaches identified, and L

(c)demonstratingthepreferredapproach(es) I through a pilot program. 1

2. Several vendor topical report reviews Start-04/87 are inchtded in Section 3.2 of this Finish-09/87 Program Plan; the reports are on such subjects as RPS SI extension; RPS and ESFAS SI and A0T extension, Rod Block Instrumentation, Isolation Instrumentation common to RPS/ECCS, and ECCS Actuation Instrumentation. For purposes of facilitating reviews of these and/or other topical reports, work has been initiated at BNL, under contract to the NRC, to:

(a)evaluatetheeffectivenessof staggered testing for selected systems, and (b) evaluate the significance of PRA uncertainties in risk-based modifications to TS.

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Future Activities and Schedule Goals (con't)

3. The NRC Office of Research has an Start-01/87 Ongoing effort to develop Procedures for Finish-02/88 Evaluation Technical Specifications (PETS) which addresses PRA methods to evaluate the risk impacts of changes to A0Ts and l STIs. Guidance on these subjects is needed to facilitate licensees' preparation l of A0T/STI changes based on risk assessments. l The Technical Specifications Branch will interface with RES on the results of the l PETS program which will be used to provide '

guidance to industry and the staff on PRA methods for evaluating changes to Technical l Specifications. In addition to the l guidelines for NRC review of licensee l submittals for A0T and STI changes re p(a)sently Allowedunder development, Cumulative reports Outage Time on (ACOT),

(b) Numerical Safety Goals-Related Criteria, and (c) Diesel Generator STIs are being developed.

4.3 Controir,for Requirements Transferred (PLANNEDACTIVITY) from TS Various mechanisms exist which can be used to control requirements I which will be removed from the STS when the selection criteria approved by the Policy Statement are applied. There is a need to establish guidance for determining which controls are appropriate for particular requirements.

I Future Activities and Schedule Goals i i

1. Develop guidance on the appropriate S tart-05/22/86 )

control L.echanisms for requirements Finish-10/31/87 removed from Technical Specifications (e.g., FSAR amendment, procedures, or other licensee controlled document).  :

This guidance will be issued for Industry's  :

use in preparing submittals proposing the '

new STS and for NRR's review in plant specific 4 applications.  ;

2. The staff will work with industry and Start-TBD monitor their development of Guidelines Finish-Six months i for Conducting 50.59 Reviews. Staff after receipt of will give the industry prepared  !

industry guidelines j Guidelines regulatory status (e.g., for conducting 50.59 {

separate policy statement, regulatory reviews.

guide, or generic letter).

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Future Activities and Schedule Goals

3. Develop separate (for issuance by ILRB) Start-Four months after ,

internal NRC procedures for auditing receipt of industry licensee performance of 50.59 reviews. guidelines for conducting 50.59 reviews.

Finish-Six months after receipt of industry guidelines for conducting 50.59 reviews.

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APPENDIX A I

MSTORICALBACKGROUNDOFTHEIMPROVEMENTPROGRAM 10 CFR 50.36, " Technical Specifications," which implements Section 182a. of  !

the Atomic Energy Act, was promulgated by the Commission in 1969. Thic rule delineates requirements for determining the contents of Technical- .

Specifications. Technical Specifications set forth the' specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public. Specifically. 10 CFR 50.36 requires that:

"Each license authorizing operation of a production or utilization facility of a type described in 950.21 or 650.22 will include Technical  ;

Specifications. The Technical Specifications will be derived from the i analysis and evaluation included in the safety analysis report, and-amendments thereto, submitted pursuant to 550.34. The Commission may include such additional Technical Specifications as the Commission finds appropriate."

Technical Specifications cannot be changed by licensees without prior NPC l approval. However, since 1969, there has been a trend towards including in Technical Specifications not only those requirements derived from the i analyses and evaluation included in the safety analysis report but also essentially all other Commission requirements governing the operation of nuclear power reactors. This extensive use of Technical Spe::ifications is due in part to a lack of well defined criteria (in either the body of the rule or in some other regulatory document) for what should be included in Technical Specifications. This has contributed to the volume of Technical Specifications and to the several fold increase, since 1969, in the number of license amendment applications to effect changes to the Technical Specifications. It has diverted both staff and licensee attention from the more important requirements in these documents and has resulted in an adverse but unquantifiable impact on safety.

In August 1983, the Executive Director for Operations established a Task Group on Technical Specifications to identify the scope and nature of problems with surveillance testing in current Technical Specifications and to develop alternative approaches that will provide better assurance that surveillance testing does not adversely impact safety. The product of this Task Group was NUREG-1024, " Technical Specifications - Enhancing the Safety Impact."

On December 31, 1984, the Director of NRR established a Technical Specification Improvement Project (TSIP) to reconsider the entire subject of-Technical Specifications and provide recommendations for improvement. There was close coordination between this project and a similar industry effort-sponsored by AIF.

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SECY-86-10 forwarded to the Commission the recommendations of TSIP and AIF and identified planned Staff actions in response to their recommendations. i The Staff and AIF briefed the Commission on these recommendations on  ;

January 21, 1986 and February 11, 1986, respectively. Both TSIP and AIF made two major recommendations which can be summarized as follows:

1) The NRC should adopt the criteria for defining the scope of TS proposed in the AIF and TSIP reports. Those criteria should then be used by the NRC and each of the Industry Owners Groups to completely rewrite / streamline the existing Standard Technical Specifications (STS). This process would result in many requirements being transferred from control by Technical Specifications to control by other mechanisms (e.g., the FSAR and 10 CFR 50.59, Operating l Procedures, the QA Plan, or Fire Protection Plan) which might not I require a license amendment or prior NRC approval when changes are i needed. The new STS would include greater emphasis on human factors "

principles to add clarity and understanding to the overall text.

The new STS would also include improvements to the Bases Section for Technical Specifications.

2) A parallel program of specific line item improvements in both the scope and substance of the existing TS should be initiated in addition to l developing a new set of STS as identified in 1) above. l On October 21, 1986 the staff forwarded a proposed Policy Statement on Technical Specification Improvement, which included Technical Specification screening criteria, to the Commission. By Staff Requirements Memorandum dated l January 9, 1987 the Commission approved a slightly modified Policy Statement '

for interim use and public comment. The modified Policy Statement was

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published Tn the Federal Register on February 6,1987. The public comment period expired on March 23, 1987. Industry has begun preparation of new STS q based on the Commission's interim Policy Statement and the staff has been '

working with the various Owners Groups to provide guidance and early feedback on the new STS development efforts.

Both the staff and industry have initiated specific line item improvements which will be incorporated into the new STS topical reports.

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APPENDIX D PURPOSE OF TECHNICAL SPECIFICATIONS AND SCREENING CRITERIA AS SPECIFIED IN THE INTERIM POLICY STATEMENT l

The : purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public s health and safety by establishing those conditions of operation which canrot l be changed without prior Commission approval and by identifying those j features which are of controlling importance to safety. l The following criteria delineate those constraints on design and operation of l nuclear power plants that are derived from the plant safety analysis report 1 and belong in Technical Specifications in accord w'th 10 CFR 50.36 and the l purpose of Technical Specifications stated above.

Criterion 1: Installed instrunentation that is used to detect, and indicate '

in the control room, a significan', abnormal degradation of the reactor coolant pressure boundary:

Discussion of Criterion 1: A basic concept in the edequate protection of the public health end safety is the prevention of accidents.

Instrumentation is installed to detect significant abnormal degradation of the reactor coolant pressure boundary so as to allow operator actions l to either correct the condition or to shutdown the plant safely, thus reducing the likelihood of a loss of coolant accident.

This criterion is intended to ensure that Technical Specifications control those in;truments specifically installed to detect excessive reactor coolant system leakage.

Criterion 2: A process variable that is an initial condition of a Design Basis Accident (DBA) or Transient Analyses that either assumes the failure of or presents a challenge to the integrity of a fission pFoduct barrier:

Discussion of Criterion 2: Another basic concept in the adequate

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protection of the public health and safety is that the plant shall be operated within the bounds of the initial conditions assumed in the existing Design Basis Accident and Transient Analyses. These analyses consist of postulated events, analyzed in the Final Safety Analysis Report (FSAR),forwhichastructure, system,orcomponentmustmeet specified functional goals. These analyses are contaired in Chapters 6 and 15 of the FSAR (or equivalent chapters) and are identified as Condition II, III, or IV events (ANSI N 18.2) (or equivalent) that either assume the failure of or present a challenge to the integrity of a fission product barrier.

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As .used in Criterion 2, process variables are on13 ' hose parameters for which specific values or ranges of values have been chosen as reference ,

bounds in the Design Basis Accident or Transient Analyses and which are lionitored and controlled during power operation _such that process values remain within the analysis bounds.

The purpose of this criterion is to capture those process variables that brye initial values assumed in the Design Basis Accident and Transient Analyses, and which are monitored and controlled during power operation.

So long as these variables are maintained within the established values, risk to the public safety is presumed to be acceptably low.

Criterion 3: A structure, system, or component that is part of the primary

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Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier:

Discussion of Criterion 3: A third concept in the adequate protection of the public health and safety is that in the event that a postulated Design Basis Accident or Transient should occur, structures, systems, and components are available to function or to actuate in order to mitigate the consequence of the Design Basis Accident or Transient.

Safety sequence analysis or equivalent have been performed in recent years and provide a method of presenting the plant response to an accident. These car be used to define the primary success paths.

1 A safety sequence analysis _is a systematic examination of the actions required to mitigate the consequences of events considered in the plant's Design Basis Accident and Transient Analyses, as presented in Chapters 6 and 15 of the plant's Final Safety Analysis Report (or equivalentchapters). Such a safety seauence analysis considert. all applicable events, whether explicitly or implicitly presented. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operats (including consideration of the single failure criteria), so that the plant response to Design Basis Accidents and Transients limits the consequences of these events to within the appropriate acceptance criteria. ,

It is the intent of this criterion to capture into Technical Specifications only those structures systems, and components that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and acturtion systems that are necessary for items in the primary success path to successfully function.

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APPENDIX C

} SHORT TERM TECHNICAL SPECIFICATION IMPROVEMENTS USING THE LEAD PLANT CONCEPT *

Background

As a result of recent Industry and NRC studies aimed at finding ways to improve Technical Specifications (TS), each of the Owners Groups have proposed i or are considering many worthwhile changes to TS. These changes will be l proposed as short term improvements to existing TS to be implemented in '

parallel with NRC and Industry longer term efforts to conpletely rewrite / streamline the Standard Technical Specifications (STS). The short  ;

term improvements to TS will be implemented as part of the NRC program for TS I improvements.

These improvements are needed to resolve recurring problems with certain technical requirements in operating plant TS. The issues involved are generally of minor safety significance, but their resolution requires a considerable amount of NRC staff and Industry resources. The general approach for implementing short term TS improvements will be to update these requirements in the existing STS, issue a t]eneric Letter advising the licensees of the updated STS, and then process individual operating reactor license amendment requests based on the Generic letter. The updated STS will provide guidance to all licensees on the types of changes which the staff would find acceptable for plants that have TS in either the standard or custom format.

To assure the anost expeditious implementation of short term improvements, NRC has proposed that the short term improvements be processed using a lead plant concept. The benefits of the lead plant concept are the following:

The lead plant concept results in the optimum utilintion of NRC and Industry resources for developing and processing the approval and implementation of generic short term TS improvements.

The process will facilitate the tracking of short term TS improvements under the lead plant concept and the prioritization of resources to be focused on their review and approval.

The types of short term improvements that would be processed under the leed plant concept are vendor specific and generally require a technical specialists review. The lead plant concept assures this type of review.

Industry wide implementation of TS changes developed under the lead plant concept will minimize the impact on NRC resources required for issuance of liMnse amendments.

• Slightly modified version of the Lead Plant Concept as described in Enclosure I to letter from DEisenhut to APasswater dated May 5, 1986.

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l Procedure 3

The fc!10 wing outlines the proposed procedure to be used by each Owners Group for implementing short term TS improvements using the lead plant concept: )

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1. The Owners Groups would forward a letter for each short term improvement I to the Director of the appropriate Project Directorate with a copy to the  !

Technical Specifications Branch (TSB). The letter would include the {

following information.

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1 A description of the conceptual approach for the proposed TS change.

The lead plant and the licensee that would submit the proposed change.

The proposed schedule for submittal of the lead plant TS change.

2. The Project Directorate, in consultation with TSB, would confirm by letter to the Owners Group that the proposed change is appropriate for review under the program plan for TS improvements and that resources would be assigned for the review of the lead plant submittal on a priority basis.

3. The licensee for the lead plant would submit a license amendment application to change the TS for the lead plant. The licensee would note that the specific of the proposed change have been endorsed by the Owners Group for incorporation into the STS as part of the TS improvement program. The lead plant would be responsible, with support from the Owners Group, for respoliding to any questions raised by the staff in its review of the proposed change.

4 The NRC Project Manager would provide the proposed TS change to TSB, which would have progrNn management responsibility for processing the change. TSB would reassign the proposed TS change to the appropriate technical review branch (es) for review. The review would consider the acceptability of the proposed change for the lead plant and for updating the STS. The review would note whether the change is applicable only to the STS for that NSSS or to more than one of the NSSS STS, to ensure consistency among the STS. Following the review of the proposed change, the TSB would issue a safety evaluation report cddressing the TS change for the lead plant and the STS.

5. The NRC Project Manager would process a license amendment to incorporate the change to the TS for the lead plant.

6. TSB would incorporate the change into the STS, in accordance with NRC procedures based on the approval of the TS change by the Licensing Division. The updated STS would be distributed to all licensees by a Generic Letter indicating that changes to the TS for their plants may be requested based on the guidance provided in the updated STS.

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7. Subsequent requests to incorporate the changes into the TS for a plant would be submitted by individual licensees, on a voluntary bases, in accordance with the requirements of 10 CFR 50.91(a). These changes generally will not require further review by the technical review branches, i

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