ML20235N146

Summary of 870626 Meeting W/Aif Working Group Re AIF Suggested Improvements to Sections 5 & 6 of STS Dealing W/ Design Features & Administrative Controls & Plans/Proposals to Reduce Number of Cyclic Specific Variables

ML20235N146
Person / Time
Issue date:	07/10/1987
From:	Bryan S Office of Nuclear Reactor Regulation
To:	Butcher E Office of Nuclear Reactor Regulation
References
NUDOCS 8707170452
Download: ML20235N146 (5)

Text

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July 10,1987 MEMORANDUM FOR: Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment, NRR FROM:

Samuel E. Bryan, Sr. Reactcr Engineer i

Special Projects Section Technical Specifications Branch Division of Operational Events Assessment, NRR l

David Langford, Reactor Engineer Review and Assessment Section l

Technical Specifications Branch Division of Operational Events Assessment, NRR l

SUBJECT:

JUNE 26, 1987 MEETING WITH AIF REGARDING STS 5 & 6 AND CYCLE SPECIFIC VARIABLES On June 26, 1987 we met with the AIF Working Group on Technical Specification t

Coordination. Our purpose was to discuss AIF's suggested improvements to Sections 5 and 6 of the Standard Technical Specification (STS 5 8 6) dealing with Design Features and Administrative Controls, and to discuss AIF plans / proposals to reduce the number of cycle-specific variables that must be included in Technical Specifications (TS) changes in reload applications.

We brought with us Tom Dorian and Joe Scinto of the Office of General Counsel; tney discussed legal requirements for STS changes.

The AIF will redo its submittals on STS 5 & 6 and will probably seek changes via the lead plant approach.

No AIF schedule has been set for this.

The AIF approach on cycle specific variables appears consistent with that in TS recently issued to Vogtle. Sam Bryan will tell AIF whether we will try to resolve this issue by writing a generic letter.

l Some details of the meeting and an agenda and attendance list ar enclosed.

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Q Samuel E. Bryan, Sr. Reactor Engineer David Langford, c or Engineer Special Projects Section Review and Assessment Section Technical Specifications Branch Technical Specifications Branch Division of Operational Events Division of Operational Events Assessment, NRR Assessment, NRR

Enclosures:

Distribution:

(MEM0 TO BUTCHER FROM SB/DL)

As stated ISB R/F SEBryan DBrinkman PDR 0

j ' [hh' TSB Subject File (MEETING MINUTES) JLieberman 1

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DETAILS OF JUNE 26, 1987 MEETING OGC representatives Tom Dorien and Joe Scinto said-l NRC regulations (10 CFR 50.36) and the underlying statute require that TS

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exist and that they be part of a plant license; the history of custom TS and STS gives existing TS the aura of meeting l

statutory requirements so a defensible rationale is needed to delete items now in STS 5 t, 6 j

Also, changing ID CFR 50.36 will not eliminate the need for a' defensible I

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rationale for such deletion because 50.36 is presumably a valid interpretation of the underlying statute and that statute is not being changed.

Philosophical discussions included the following points:

u TS's are not defined in the statute or the regulations but 10 CFR 50.36 gives NRC prior approval rights on TS changes, while 10 CFR 50.59 gives NRC hindsight review on other (non-TS) matters.

AIF proposes to use TS as tools for operators but the statute does not imply that TS are intended to be used to govern daily operations: the statute implies that TS should be taken from the staff SER which is based on a design review for a 40 year license.

For this reason, some NRC -

staff say TS should go to the licensee's lawyers rather than to the.

operators.] [0ther NRC staff want to use TS for very tight controls on operators.

The NRC Commissioners stress the importance of licensee management but the licensee wants to downplay STS Section 6 on Administrative Controls.

Items may/can be shifted from control by 10 CFR 50.36 if also controlled by other regulations,1f the shift is supported.by a good argument.

Sam Bryan is leading the NRC effort on whether Organizational Charts can be deleted from STS Section 6.

l We pointed out that the docunented AIF efforts to shrink STS 5 & 6 have contained " suggestions" rather than proposals, and that AIF has told us what they want to delete but they have not told us how AIF will meet the specific requirements of 10 CFR 50.36 or the statute. We suggested that future documents'show explicitly how licensees will meet NRC requirements and/or make explicit requests for waivers.

The AIF said it asked the various owners groups (OGs) for proposals on STS 5 and 6.

The AIF will redo STS 5 & 6 and seek changes via the lead plant approach (if a licensee willing to lead can be found).

The AIF discussed its plans / proposals to reduce the number of cycle-specific l.

variables that must be included in reload applications.

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i The AIF approach is to seek approval of the methodology used to calculate the values of cycle-specific variables, en approach iri harmony with current NRC thinking as exemplified by TS recently issued to Yogtle.

l Tom Dunning and Sam Bryan will determine whether NRC can vrite a generic letter on this without need for further AIF work.

Sam will advise AIF within a week or so.

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AIF/NRC MEETIl$ JUNE ?6, 1987 l

AGENDA I.

i;RC ITEMS l

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Statute 1

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Regulations 3.

Policy II. AIF Items ", '

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Cycle Specific Variables 2.

Section 6 - Adm. Controls a.

Process by which it can be maintair.cd.

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Contents 3.

Section 5 - Design Features III. Details of AIF Options l

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p, AIF/NRC TS IMPROVEMENT't1EET.!NG 5.0/6.0 AND CYCLE SPECITIE~IXFlAELES JUNE 26, 1987

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ORGANIZATION Gregg A. Sinders Carolina Power & Light /WOG l

1 Ed Lozito Virginia Power /WOG j

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Stu Webster CE/ANS-58.4/CE0G,_

Sam Bryan NRC/0TSB

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David Fischer

((RC/0TSB Robert Gill n ke Power /BWOG u

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Lynn Connor 3

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David Langford NRC/0TSB s

Dan Green li, Florida Power Coperatice l

Biff Bradley Georgia Power /BWROG

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NRC/0TSB Tom Dunning Tom Tipten AIF A

Joe Scinto NRC/0GC I'

Tom Dorian NRC/0GC i

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