ML20236A910
| ML20236A910 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1987 |
| From: | Mann B Office of Nuclear Reactor Regulation |
| To: | Butcher E Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8710230228 | |
| Download: ML20236A910 (8) | |
Text
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October 16, 1987 f
MEMORANDUM FOR:
Edward J. Butcher, Chief I
Technical Specifications Branch j
Division of Operational Events Assessment, NRR s
THPU:
David C. Fischer, Section Chief l
4 Special Projects Section Technical Specifications Branch Division of Operational Events Assessment, NRR FROM:
Bernard Mann, Reactor Engineer Special Projects Section i
Technical Specifications Branch Division of Operational Events Assessment, NRR j
SUBJECT:
SUMMARY
OF MEETINGS WITH NUMARC STS COORDINATION WORKING GROUP (STSCWG) i
References:
(a) Draft STSCWG Policy Statement on Plant Specific Impicmentation of Restructured Technical Specifications, 3
August, 1987 (b) Letter from Richard W. Starostecki, NRC, to Robert Gill, B&W Owners Group, " Staff Assessment on B&W Owners Group Technical Specification Improvement Program, Phase I and Phase II (Partial)," September 4, 1987 The NRC staff met with STSCWG members between September 29, and October 1, 1987, in Bethesda, Maryland, to review the STSCWG current activities and future plans.
The following is a summary of the major issues reviewed:
l Standardization of Plant Specific Technical Specifications The STSCWG proposes that licensees choose either their current plant-specific Technical Specifications or adopt the new STS specifications, i
It is the staff's position that plants referencing the improved Standard Technical Specifications (STS) adopt the reovirements of the new STS in their entirety, except to the extent that:
(1) Plant-specific design considerations would justify othentise, or (2) Hardware, structural, or organizational changes from previously approved canditions w ald be required to conform to the new STS.
The cdvantages and disadvantages of imposing standardization as part of the voluntary Technical Specification improvement effort were discussed.
The staff and the STSCWG will work together to identify additional measures cr principles (e.g., plant-specific maintenance practices or A
equipment and system reliability history) as a basis for retaining I.
plant-specific Technical Specifications.
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[ Edward i Butcher. Oc tober. l'6, ' 1987 Generic Prenotice l
The STSCWG asked whether a generic prenotice for each of the four vendor STSs would be acceptable. The position taken-by the STSCWG in reference (a)'and the NRC's reaction to it will be discussed in: greater-detail at the next NRC/NUMARC meeting..
Radiological Effluent Tech Spets (RETS)-
Deletion of the RETS can be' accomplished either by rulemaking'(revision of-10 CFR 50.36a) or by administrative means (i.e., referencing the 3
offsite dose calculation manual'(0DCM) or equivalent in Section 6.0 of.
1 the STS)..-Subsequent to the meeting, the staff decided'to proceed with the latter approach. 'The staff will consult with OGC to establish whether or not'this' approach is feasible.
. Margin of Safety in Bases The staff. believes that the marain of safety for Technical Specification
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requirements should be more clearly addressed in either the: Technical Specification Bases or by some clearly. established methodology as part performing safet Mr. Tom Tipton (y reviews. conducted in accordance with'10 CFR 50.59.~
NUMARC) agreed to coordinate the efforts of the NUMARC
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Working Groups on Technical Specification Improvements and 10 CFR 50.59 to-ensure that margin of safety is adequately. addressed. The extent to which NRC will control changes to the. Technical Specification Bases was discussed. The staff agreed to meet with OGC to discus 5 control of TS Bases before the next NRC/NUMARC meeting.
10 CFR 50.59 Determinations NUMARC is coordinating industry efforts to develop criteria and guidelines for conducting 10 CFR.50.59 reviers. An.NRC 50.59 Working 1
Group is interacting with the NUMARC Working Group and has provided preliminary comments on a draft 'of NSAC/NUMARC criteria 'and guidelines for conducting 50.59 reviews.
Better Definition of Criterion 2 The staff believes that criterion 2 needs to be clarified.to capture not i
only " process variables"'but'also " design features and other operating restrictions." The'STSCWG believes that the criteria should remain as they exist in the Consnission's interim Policy Statement 'on Technical' Specification Improvements. During the~ discussion of ethe industry's draft split of the new STS (W CE, B&W, and GE), several examples occurred where industry found tiia,t a system or component did not meet any of the three TS screening criteria but NRC staff found (f.e.. in the. Wolf Creek -
and Limerick trial, splits). that these same systems. or components had met one of the criteria. Many of these differences would be eliminated if minor adjustments were made to the' wording of criterion 2.
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' Edward J. Butcher'. October-16, 1987' 1
. Technical Specification Cross-Referencing l
-l The.-STSCWG. expressed interest in including a cross-reference-section as J
-part~of the format for each Technical Sp' edification.
The cross-reference section would identify the number and title of other.related Technical' t
? Specifications. The STSCWG said human factors experts and plant operators
-l have.foundlthis type of' cross-referencing to be _particularly helpful.
They are,-however, concerned that any. changes to this section would require TS amendment requests and hence prior NRC approval. The NRC staff agreed to consult with OGC to see if there-is an acceptable method to include _ such a section in TS without requiring prior. staff approval of changes.
Control of Requirements' Removed From Technical Specifications The staff recoramended that the:0wners Groups propose optional licensee host documents which have appro' priate regulatory controls for receiving relocated Technical Specifications. This will be' considered by the owners groups.
I 1 contains a more detailed meeting summary. provides an attendance list and the agenda for the meeting.
The next NRC/NUMARC meeting i
to discuss the development of the new STS is tentatively scheduled for j
October 27-29, 1987.
6,b b Bernard Mann, Reactor Engineer W Special Projects Section i
T Technical Specifications Branch Division of Operational Events Assessment, NRR
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Enclosures:
As stated l
cc w/encls:
R. W. Starostecki q
C. E. Rossi i
Distribution:
TSB R/F.
BNnn DOEA R/F TSB Members
(,PDR w w w une q" GBerlinger CentralAFiles WDLanning CERossi JConran EJButcher-
.DBrinkman DCFischer
.SNewberry (MEMO TO B TCHER FROM MANN),
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TSB:DOEA:NRR C: SB OEA:NRR TSB:
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ENCLOSURE 1 REPORT ON MEETING WITH NUMARC STS CWG SEPTEMBER 29, 1987 1.
PLANT-SPECIFIC IMPLEMENTATION--SPECIFICATION
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The STSCWG proposed groundrules [ contained in reference (a)] for
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plant-specific adoption of the new Standard Technical Specifications are as follows:
3 (1) With respect to individual Technical Specification requirements, the licensee may choose to either retain his current specification or to adopt-the new specification for the plant-specific requirements that can be made identical to the new STS; (2) The licensee may choose to either retain his current specification or "odify the appropriate new specifications for plant-specific retirements that cannot be made identical to-l ti.e new STS because of the specific plant design or accident analysis; and' (3)
If a licensee chooses to retain a current requirement in lieu of adopting the new version of that requirement, the licensee shall modify the current requirement to include,the human factors' improvements that have been approved by the NRC.
1 The staff's position, as presented in reference (b), is that any plant referencing the improved STS should adopt the requirements of the new STS in their entirety except to the extent that:
(1)
Plant-specific design considerations would justify otherwise, or l
(2) Pardware, structural or organizational changes from previously l
approved conditions would be required to conform to the new STS.
The staff sees benefit in Technical Specification standardization both from a safety viewpoint and becat:? of more efficient utilization of'NRC resources.
The advantages and disadvantages of imposing standardization as part of the voluntary Technical Specification improvement effort were discusse.d. The staff and STSCWG will work together to identify additional measures or principles (e.g., plant-specific maint'oance practices or equipment and system reliability history) as a basis for retaining plant-specific Technical Specifications. The staff also'noted that it would, because of limited resources, give priority to the review of plant Technical Sru ifications that adopt the new STS.
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The staff requested the owners; groups toireview the surveillance frequencies to determine: optimum frequency..(i.e., Would less frequent surveillance increase system reliability?)- The. methodology for establishing allowable outage times (A0Ts) should be standardized.
'2.
- APPLICATION OF' 10 CFR 50.91 'AND 50.92 -(SH0LLY).
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' Industry proposesLa. generic prenotice for'each.of the four vendor
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STS,'.to be referenced by individual. licensees. wishing to impleme'nt the new STS. The. staff will investigate this proposal and expects to take' a position on'it by December,1987.
- Industry also proposes that the criteria ' embodied in the Commission's
-Policy _ Statement defining the, Technical. Specification contents should be recognized as an acceptable basis-for no "significant hazards" consideration..The staff indicated that this will probably be unacceptable, but will consult'with OGC.-
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EXEMPTIONS ~FROM THE REGULATIONS This topic dealt primarily with the question of relocation-of the Radiological Effluent Technical Specifications (RETS). Two approaches 1
were' discussed:
i Rulemaking to revise 10 CFR 50.36a to delete the RETS. This is the most ' direct approach, but may take considerable time ~.
In the j
interim, licensees deleting the RETS'may have to request exemptions
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from this regulation.
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Prepare a radioactive effluent plan or equivalent, base'd on the j
Offsite Dose Calculation Manual, (0DCM)'which would be referenced in Section 6.0 of the Technical Specifications:(subsequent to the
'i meeting, the staff decided.to ' proceed with this approach).
4.
CONTROL OF REQUIREMENTS REMOVED FROM TECHNICAL SPECIFICATIONS-The Interim Policy Statement, establishes a specific set of objective criteria for determining which regulatory requirements and operating
.j restrictions should be included in Technical Specifications.~
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-Application of the criteria will result.in the transfer of many j
requirements from the Technical Specifications to the control of-other documents, primarily the Final Safety Analysis Report (FSAR),
plant operating / surveillance procedures, and~ program plans.. Revision of these documents would be performed by.the licensee under 10 CFR 50.59 or some other administrative control. process without prior NRC approval. There is'a question of where the Action Statements:for requirements relocated from Technical Specifications-to procedures would be located. The staff. suggested that a generic relocation mechanism might'be appropriate..The 0wners Groups (0Gs) will give this suggestion further consideration.
B&WOG Position XII (Reference b) recommended that former Technical Specifications be relocated to FSAR chapter 16.
This option will be further considered by the other-0Gs and NRC staff.
The staff expressed some concern that the FSAR alone might not provide appropriate controls for some relocated requirements.
5.
CONTROL OF BASES The OGs propose that plant-specific Bases would be initially developed by the licensees and provided to NRC.
Subsequent changes would be developed by the licensees by means of the licensee's administrative process and copies would be provided to NRC. The staff believes that it should have the same control over Technical Specification Bases changes it has over Technical Specification revisions. The NRC staff will discuss this with OGC.
The staff believes that the margin of safety for Technical Specification requirements should be more clearly addressed in either the Technical Speciifcation Bases or by come clearly established methodology as part of performing safety reviews conducted in accordance with 10 CFR 50.59. Mr. Tom Tipton (NUMARC) agreed to coordinate the efforts of the NUMARC Working Group on l
Technical Specification Improvements and 10 CFR 50.59 to ensure that l
margin of safety is adequently addressed.
SEPTEMBER 30, 1987 TECHNICAL SPECIFICATION SPLIT Each OG will submit a separate topical report containing the Technical Specification split results and rationale for the split. These reports will be submitted between mid October and early November,1987. The staff evaluation of these topical report will be documented in a SER or approval letter.
It was agreed that if PRA is a factor in the OG submittals, the staff would do its best to address this in the NRC evaluation.
The PWR Technical Specification Split Summary was reviewed by the conferees.
Separate columns were provided for B&W, CE and Westinghouse plants. The staff had some questions with regtrd to the split, e.g.:
l Does deletion of all boration Technical Specifications satisfy the criteria?
Does deletion of the fuel pool area criticality monitor Technical l
Specification satisfy the criteria?
Does deletion of the pressure / temperature limits and cold overpressure limit Technical Specifications violate criterion 2?
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Does deletion 'of the atmospheric dump valve (ADV) Technical Specifications may' violate criterion 37 Operation of the'ADVs is required.to mitigate the steam generator tube rupture and smalll 1
break LOCA accidents.-
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i The BWR. Technical: Specification Split Summary was.also reviewed by-I the conferees. :Some of-the staffs cuestions were:
1 should.the mode-switch and manual ~ scram switch : Technical' Specifications be relocated?
Should the source. range monitor Technical Specifications,be a
I relocated?: The staff believes that it should be retained since'this : Technical. Specification appears to meet criterion 2..
The discussions on the Technical Specification split, in staff opinion, evidenced the need for. a~ better definition of criterion 2.
OCTOBER 1, 1987 The industry human factors / writers guide task force efforts were reviewed by the conferees. The staff concluded that the proposed new Technical-Specification format was satisfactory and a great improvement over the
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q existing format. A draft human factors report will be available at the i
end of October,1987. The final report will be available in December,1987.
j In its concluding remarks, the STSCWG stated that its consensus was that i
the screening criteria: contained in the Commission's interim Policy J
Statement should not be~ changed in any way.
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'ENCLOStlRE. 2 LIST OF ATTENDEES NAME ORGANIZATION Tom Tipton' NUMARC Mike Schoppman-Florida Power & Light Co.
Rich Emch NRC/NRR/D0EA/TSB 4
Edward J. Butcher NRC/NRR/D0EA/TSB.
David C. 'Fischer NRC/NRR/DOEA/TSB l
l Sam Bryan.
NRC/NRR/DOEA/TSB 1
l Millard Wohl:
NRC/NRR/DOEA/TSB Tom Dunning.'
NRC/NRR/DOEA/TSB Kulin Desai NRC/NRR/DOEA/TSB-Bernard Mann NRC/NRR/DOEA/TSB Isabelle Schoenfeld'(part time)
NRC/NRR/DLPQ/HFAB l
Yong S. Kim-NUS Corporation John Trotter Grove. Engineering Richard W. Beckwith PSE&G Joe hndry SERI Jim Klapproth GE Donald R. Hoffman Excel Services Corporation /BWROG Biff Bradley BWROG/ Georgia Power i-Rocky Sgarro Pennsylvania Power & Light Co./BWROG l
Ed Lozito Virginia Power Bob Turner Babcock-& Wilcox Co.
Bob Gill Duke Power Larry Phillips (part time)
NRC/NRR/RSB L
September 17, 1987' MEMORANDUM FOR:
Charles E. Rossi, Director Division of Operational Events Assessment, NPR FROM Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment, NRR
SUBJECT:
MEETINGS WITH NUMARC WORKING GPOUP ON TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM OATE & TIME:
(1) Tuesday, September 29, 1987 11:00 a.m. - N00N; 12:45 p.m. - 3:00 p.m.
(2) Wednesday, September 30, 1987 10:00 a.m. - N00N; 12:45 p.m. - 3:00 p.m.
(3) Thursday, October 1,1987 9:00 a.m. - N0ON LOCATION:
AIF Office Ford Bufiding 12th Floor 7101 Wisconsin Avenue Bethesda, Maryland PURPOSE:
To review Industry Technical Specification Improvement efforts and establish plans to complete review.
PARTICIPANTS:
NRC U ~J. Butcher NUMARC i
D. C. Fischer, et. al.
ST5 Coordination Working Group R. L. Emch, et. al.
T. Tipton J. Persensky (Oct. 1 only) Original Signed By:
Isrard J. Butcher Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment, NRR
Enclosure:
Meeting Agenda Distribution:
Murley/5ntezek (MEETINGNOTICEMEMO)
SAVarga BBHayes, OI PDR JStoltz VStello EDO DMCrutchfield MClausen,, OC RWStarostecki LCShao TSB Members JGPartlow JGKeppler, OSP TSB R/F FCongel JLieberman, OE JRoe WGMcDonald 0 ARM TSB S/F - (MEETING NOTICE)
PHPDAS - 4th floor ELJordan, AE00 Regional Administrators SRConnell WBKerr, SDBU/CR BKolostyak, P-433 WCParler,y, 01A PEBird, OP DBrinkman OGC TCox SJChilk, SECY HLThompson, NMSS SNewberry NRC Participants AThadant TSB:DOEA:NRRf)N TS EA:NRR EA:NRR BMann:dlm DCFischer E
her 09//i/87 09//8/87 09/1 /87
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1 MEETING AGENDA l
(I) SEPTEMBER 29, 1987 l
INTRODUCTION AND OBJECTIVES.
OVfRVIEW OF INDUSTRY DELIVERABLES REi!EW ELEMENTS.0F INDUSTRY POLICY PAPER ESTABLISH PLAN TO COMPLETE REVIEW l
l (2) SEPTEMBER 30. 1987' 1
REVIEW RESULTS OF APPLICATION OF SELECTION CRITERIA
.l TO REFERENCE'STS ESTABLISH PLAN T0 COMPLETE REVIEW
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(3) OCTOBER 1, 1987 j
REVIEW INDUSTRY HUMAN FACTORS / WRITERS GUIDE TASK 1
FORCE EFFORTS ESTABLISH PLAN TO COMPLETE REVIEW I
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