ML070810523
| ML070810523 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 08/31/1996 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NEI 96-06 | |
| Download: ML070810523 (27) | |
Text
NEI 96-06 (ORIGINAL)
IMPROVED TECHNICAL SPECIFICATIONS CONVERSION GUIDANCE AUGUST, 1996
NEI 96-06 (ORIGINAL)
NUCLEAR ENERGY INSTITUTE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION GUIDANCE AUGUST, 1996
NEI 96-06 (Original)
August 1996 ACKNOWLEDGMENTS This document, Improved Technical Specifications Conversion Guidance, NEI-96-06, was developed by EXCEL Services Corporation for the NEI Technical Specifications Task Force to act as a starting point for utility nuclear power plant personnel considering conversion to the Improved Standard Technical Specifications. It incorporates the comments of industry experts and the Nuclear Regulatory Commission. NEI wishes to acknowledge the efforts of the following individuals involved in shaping the final form of this document:
Chris Grimes, U.S. Nuclear Regulatory Commission and the members of the Nuclear Energy Institute Technical Specifications Task Force:
Donald Hoffman, EXCEL Services Corporation Lee Bush, Commonwealth Edison, Westinghouse Owners Group Marilyn Kray, PECO Energy, Boiling Water Reactors Owners Group Drew Maron, Pennsylvania Power & Light, Boiling Water Reactors Owners Group Brian Mann, Baltimore Gas & Electric, Combusting Engineering Owners Group Clint Szabo, Entergy, Babcock & Wilcox Owners Group Jim Eaton, Nuclear Energy Institute NOTICE Neither the Nuclear Energy Institute, nor any of its employees, members, supporting organizations, contractors or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of, or assume any liability for damages resulting from any use of, any information apparatus, method, or process disclosed in this report or that such may not infringe privately owned rights.
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August 1996 TABLE OF CONTENTS Acknowledgments ...........................................................................................................i 1 INTRODUCTION............................................................................................ 1 1.1 Definitions ......................................................................................................... 1 1.2 Conversion Schedule ......................................................................................... 2 2 SUBMITTAL PREPARATION ..................................................................... 2 2.1 The Scope of Changes Included in the ITS Conversion Application............... 3 2.2 The Conversion Application Cover Letter........................................................ 3 2.3 Technical Specification Selection Criteria Report ........................................... 4 2.4 ITS and Bases.................................................................................................... 5 2.5 CTS Comparison Document.............................................................................. 5 2.6 No Significant Hazards Considerations ........................................................... 7 2.7 Deviations from the Applicable ISTS ............................................................... 7 2.8 Submittal Recommendations............................................................................ 8 3 ISTS GENERIC CHANGE PROCESS....................................................... 10 3.1 Identification of Potential Generic Changes .................................................. 10 3.2 Generic Change Threshold ............................................................................. 11 3.3 Generic Change Review Process..................................................................... 11 4 NRC REVIEW PROCESS............................................................................ 12 4.1 Review of the Submittal.................................................................................. 12 4.2 Development of a Draft SE ............................................................................. 13 4.3 Issuance of the Final SE ................................................................................. 13 5 IMPLEMENTATION ACTIVITIES............................................................ 13 5.1 Procedures and Programs ............................................................................... 14 5.2 Training ........................................................................................................... 15 5.3 Development of a Technical Requirements Manual...................................... 15 6 POST-IMPLEMENTATION AUDIT .......................................................... 16 ATTACHMENTS
- 1. NRC Recommended Conversion Application Guidelines ............................ A-1 ii
NEI 96-06 (Original)
August 1996 IMPROVED TECHNICAL SPECIFICATION CONVERSION GUIDANCE 1 INTRODUCTION This document was developed by the NEI Technical Specifications Task Force as a guide to utilities considering conversion to Improved Standard Technical Specifications. The document gives an overview of the conversion process and gives recommended practices and process enhancements that will enable a utility to convert in an efficient and timely manner. They reflect the experience of licensees who have already converted and the NRC staff.
1.1 Definitions Definitions of the key terms used in this document are provided below:
1.1.1 Current Technical Specifications (CTS): The existing Technical Specifications, including the existing plant-specific licensing basis and any approved license amendments which may not yet be effective.
1.1.2 Improved Standard Technical Specifications (ISTS): The applicable Improved Standard Technical Specification NUREG (e.g., NUREG-1430, -1431, -1432, -1433, or -1434).
1.1.3 Improved Technical Specifications (ITS): The proposed plant-specific Technical Specifications developed from the ISTS.
1.1.4 Limiting Condition for Operation (LCO): As defined in 10 CFR 50.36, limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
1.1.5 Plant Specific Design, Analyses, and Licensing Basis: Consists of plant-specific design, safety analyses, and licensing basis. Includes initial conditions, acceptance criteria, setpoints, actions, completion times, surveillance requirements, and surveillance intervals, which were approved by the NRC with the initial license or subsequent license amendments.
1.1.6 Generic Change: Proposed or approved changes to the ISTS NUREGs to correct or improve the documents that are generically applicable to plants for which the ISTS were written.
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August 1996 1.2 Conversion Schedule The projects to convert to the ITS are typically divided into two phases, the Submittal Phase and the Implementation Preparation Phase. The Submittal Phase extends from the start of the project through the submittal to the NRC of a license amendment request for conversion of the plant CTS to the ITS.
The Submittal Phase includes the development of plant-specific ITS. The Submittal Phase typically requires 12 to 14 months to complete. The Implementation Preparation Phase begins with the submittal of the license amendment request to the NRC and ends on the effective date of the ITS.
The NRC schedules 6 months to review the license amendment, however, it is recommended that each licensee establish with the NRC a mutually agreed upon schedule for review of the ITS conversion application. The Implementation Preparation Phase includes resolving any NRC questions concerning the submittal. In parallel with the NRC review, the utility works on the action items required to implement the ITS. These action items are discussed further in Section 5.0 of this guidance. The length of time required to complete the implementation action items will vary from utility to utility, but utilities should strive to implement the ITS soon after NRC approval of the license amendment.
2 SUBMITTAL PREPARATION The objective of the Submittal Phase is to prepare a license amendment request for submittal to the NRC. This license amendment request will address the overall conversion of the plant CTS to the ITS. Various documents will be created in support of this objective. The documents to be included in the license amendment request are:
- Application of Technical Specification Selection Criteria Report,
- ITS and Bases,
- CTS Comparison Document,
- No Significant Hazards Considerations, and
- Deviations from the Applicable ISTS (Technical Specifications and Bases).
These documents are ordered in the application on a chapter or section basis to allow the application to be easily divided by the NRC for review. All documents discussing the conversion of a particular chapter or section should be grouped together.
A discussion of each of these documents is provided below.
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August 1996 2.1 The Scope of Changes Included in the ITS Conversion Application During the conversion of the plant CTS to the ITS, major changes to the current licensing basis (other than those elected to be made to be consistent with the applicable ISTS) should be avoided if possible. Providing the NRC with a license amendment request that is focused on conversion to the ITS without extraneous issues will improve the timeliness of the NRCs review and to minimize the possibility of the NRCs conversion approval being delayed while the other issues are reviewed.
Changes which are in addition to the direct conversion of the CTS to the ITS but which are included within the scope of an ITS conversion application include incorporation of Generic Letter line item improvements (including extending surveillance frequencies to 24 months in accordance with Generic Letter 91-04), incorporation of generically approved topical reports, AOT-STI for BWRs, and generically approved risk based changes.
Changes which are considered beyond the scope of an ITS conversion application, and therefore may result in delays in the review and approval of the application, include plant-specific risk based changes, and power uprate.
In cases where these types of Beyond Scope changes to the current licensing basis are to be pursued, separate submittals for these changes should be made in parallel with the ITS submittal. The separate submittals should be in the ISTS format and be identified for implementation concurrent with the ITS. The ITS conversion submittal should identify all such separate submittals. This will enable separate Federal Register notification, if required, and facilitate planning for separate NRC technical review.
2.2 The Conversion Application Cover Letter To assist the NRC in the review of the ITS conversion application, the cover letter should highlight any unique or unusual characteristics of the application, such as:
- A description of all Beyond Scope changes.
- A description of all changes which are in addition to the direct conversion of the CTS to the ITS but which are included within the scope of an ITS conversion application.
- A description of all changes to Technical Specification values beyond those needed to conform with the ITS.
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August 1996
- All license amendments still under review by the NRC which have been incorporated into the application.
- A description of all Surveillance Requirements which will not be applicable at the time the ITS are implemented, a justification for the delay, and the date at which the Surveillances will be applicable.
In addition, a list of the ISTS generic changes included in the application should be provided as well as the date beyond which no new generic change travelers were incorporated.
The cover letter should describe the ITS implementation schedule and the requested date for approval of the application.
2.3 Technical Specification Selection Criteria Report The Technical Specification Selection Criteria in 10 CFR 50.36 are applied to the CTS LCOs. This review determines which LCOs may be relocated from the CTS to plant controlled documents. These criteria have been generically applied to previous Standard Technical Specifications to obtain the LCOs in the ISTS. The results of this generic application must be confirmed on a plant-specific basis. Plants with custom Technical Specifications (i.e., not based on the previous Standard Technical Specifications) should consider their licensing basis and the previous Standard Technical Specifications used by the NRC in developing the ISTS for their type of plant when applying the selection criteria to their LCOs.
2.3.1 A matrix should be developed that identifies for each of the CTS LCOs which criteria are applicable and the new location of the CTS LCOs in the ITS.
For each CTS LCO to be relocated to plant controlled documents, a justification for the relocation should be provided. The justification should address each of the four Technical Specification criteria using the plant-specific safety analysis and PSA/IPE results, as applicable.
As the selection criteria only apply to LCOs, when considering other portions of the Technical Specifications (i.e., Safety Limits, Design Features, and Administrative Controls) the justification should address the requirements of 10 CFR 50.36.
The matrix, or another document included with the submittal, should describe where the relocated items will be maintained (i.e., FSAR, QA Plan, procedure, etc.) and the corresponding controls (i.e., 10 CFR 50.59, 10 CFR 50.54(a), etc.).
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August 1996 2.4 ITS and Bases Typed ITS should be provided in the submittal and should also be provided in electronic media. The ITS should be based on the currently published version of the applicable ISTS, modified to reflect plant-specific design, analyses, and licensing bases.
Changes to the ISTS approved by the industry and the NRC through the generic change process should also be incorporated in the ITS. Section 3.0 describes the generic change process. The submittal cover letter should identify the cutoff date after which no generic changes were incorporated during submittal development. Approved generic changes incorporated in the ITS should be annotated with the generic change number. If an incorporated generic change is subsequently rejected, it must be removed from the application or a plant-specific justification for the change provided.
The format for the ITS should be consistent, to the extent practical, with that of the applicable NUREG and NUMARC 93-03, Writers Guide for the Restructured Standard Technical Specifications (Writers Guide). The Writers Guide provides specific guidance for the preparation of the ITS. It is used to promote standardization in the preparation and revision of the ITS.
2.5 CTS Comparison Document The CTS should be marked to indicate the changes necessary to become the proposed ITS. All substantive changes should be identified, but changes in formatting do not have to be marked. This markup is needed to facilitate the NRC staff review of the ITS conversion submittal. There should be a discussion of each change or group of common changes. These change discussions should also be provided in electronic media. The markup of the CTS should be annotated to reference the appropriate discussion. The marked CTS should be provided in ITS order. Plants converting from custom Technical Specifications should consider providing the marked CTS in CTS and ITS order to assist the NRC in their review.
If a change is related to an NRC generic action, including line-item improvements, the generic action should be referenced in the justification for the change.
The mark up should also include or identify any outstanding amendment requests that have been submitted to the NRC that are expected to be issued prior to ITS implementation and, therefore, should be included in the ITS submittal. This will enable coordination between the NRC Project Manager 5
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August 1996 and the NRC Technical Specifications Branch ITS conversion reviewer on the disposition of the changes.
2.5.1 To the maximum extent possible, changes should be grouped to simplify the evaluation. Common groupings are:
ADMINISTRATIVE (designated A) changes are purely editorial in nature and are associated with reformatting, restructuring, interpreting, and complex rearranging of requirements, and other changes not revising the technical requirements contained in the existing document.
MORE RESTRICTIVE (designated M) changes result in added restrictions or elimination of flexibility. For these changes, the justification should describe why the more restrictive requirement is appropriate using the rationale in the ISTS Bases, as applicable.
RELOCATED (designated R) requirements are LCOs which do not meet the 10 CFR 50.36 selection criteria and may be relocated to licensee controlled documents.
LESS RESTRICTIVE (designated L) changes are requirements that are relaxed, or those where new flexibility is provided. This category of change does not include Relocated changes. The licensee must consider whether the item is required to be in the Technical Specifications by requirements in 10 CFR 50.36 other than the selection criteria (such as the description of Limiting Safety System Settings, LCOs, Surveillances, Design Features or Administrative Controls) and also justify that the relaxed requirement is not necessary to eliminate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
REMOVED DETAIL (designated LA or LR) changes are a subset of the Less Restrictive category in which certain details and information, from otherwise retained specifications, are removed from the Specifications and placed in the Bases, the UFSAR, or other licensee controlled documents. These changes would include details of system design and function, procedural details or methods of conducting surveillances, or alarm or indication-only instrumentation.
Other groups may be used to simplify the submittal (designated in some submittals as LB, LC, etc). These groupings may be used to 6
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August 1996 designate changes affecting multiple specifications such as 24-month surveillance interval extension, BWR AOT-STI extension, and removal of alarm-only functions.
2.6 No Significant Hazards Considerations For each change or group of changes identified in the CTS Comparison Document, an individual No Significant Hazards Consideration (NSHC) analysis, based on the criteria in 10 CFR 50.92, must be provided. The type of NSHC analysis prepared may depend on the category of the proposed change to the Technical Specifications. Changes in the Administrative, More Restrictive, Relocated, and Removed Detail categories may be described by a single NSHC analysis for each category. However, each change in the Less Restrictive category should have an individual NSHC analysis.
2.7 Deviations from the Applicable ISTS Each ITS will require some degree of customization. Examples of plant-specific changes are:
- Provision of plant-specific information for bracketed information in the ISTS. Bracketed values or requirements are those that are known to change based on plant-specific design, analysis, or licensing basis.
- Unique design basis (for example, a Surveillance Frequency for a particular system that is extended from that in the ISTS due to a system design feature not considered in the ISTS);
- Current licensing basis (CLB) which justifies retaining CTS requirements (for example, not including response time testing requirements, if the CLB does not require response time testing);
- Unique operating practices (supported by technical justification or analysis); and,
- Terminology (for example, the plant-specific name of a system).
2.7.1 Significant discussion and disposition of philosophical and technical issues between the industry and the NRC occurred during the development of the ISTS. Therefore, a high threshold should be satisfied for deviating from the ISTS in the ITS. Language and format preferences, unless justified on a plant-specific basis, should be avoided. This is especially true of Sections 1.0 and 3.0. This high threshold is used to preserve the standardization of the use and meaning of the requirements for the industry and the NRC.
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August 1996 2.7.2 The licensee may decide not to adopt certain ISTS provisions because conformance with the ISTS would constitute an unwarranted backfit to existing license requirements. For these changes, the NRC may consider whether plant-specific provisions affect the completeness of the ISTS, and determine if a backfit evaluation is warranted.
2.7.3 All deviations from the applicable ISTS should be shown on a marked up copy of the currently published version of the applicable ISTS. To the extent possible, deviations should be grouped. Common groupings are: bracketed information, plant specific values, and generic changes.
In addition, justification of each deviation or group of common deviations should be provided.
2.7.4 The ITS Bases will normally require more plant-specific changes than the Technical Specifications due to the increased level of detail. The plant-specific Bases should be modified as necessary to provide a comprehensive description of the requirements to clearly document the origin and intent of the ITS. Plant-specific information and experienced-based interpretations should be incorporated into the Bases to the extent possible to ensure a complete and accurate description of the plant-specific design, analyses, and licensing basis.
Deviations from the ISTS Bases should also be identified and described. In addition, justification of each deviation or group of common deviations should be provided 2.8 Submittal Recommendations The following are some additional suggestions and recommendations that have been used during the submittal phase by utilities who have converted to the ITS. Attachment 1 contains detailed recommended conversion application guidelines developed by the NRC. These recommendations are consistent with the guidance contained in this document, but provide a greater level of detail with respect to the content and format of an ITS submittal. Applying these suggestions and guidelines will assist the NRC in rapidly and efficiently reviewing the submittal.
2.8.1 Provide the NRC with a cross-reference of the CTS requirements to the ITS and vice versa. Also provide a listing of CTS requirements relocated to licensee controlled documents, the proposed location of the relocated item and the controls that will be applied to the relocated items. The matrix may be part of the CTS and ITS markups.
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August 1996 2.8.2 Certify, at submittal, that the ITS conversion submittal is consistent with plant-specific design, analyses, and licensing bases (where the utility has elected to maintain it), in accordance with 10 CFR 50.9.
Any changes made to the ITS during the NRC review period will require the same certification.
2.8.3 For all plant-specific deviations from the ISTS based on current licensing bases, ensure that the current licensing basis requirement remains valid when incorporated into the ITS.
2.8.4 The level of detail in the discussion of changes should be sufficient to support the NRCs development of the Safety Evaluation (SE). For guidance on the level of detail needed, it may be prudent to obtain and review the SE for a previous ITS conversion.
2.8.5 As the NRC has stated that 10 CFR 50.59 only applies to the UFSAR, no reference should be made to documents being controlled in accordance with 10 CFR 50.59 except for the UFSAR and documents incorporated by reference into the UFSAR. Procedures and programs should be described as being revised in accordance with licensee-controlled programs.
2.8.6 Provide the NRC with computer files of all typed ITS conversion submittal information. This assists the NRC in performing electronic comparisons between the ITS and the ISTS and to support development of the Safety Evaluation. The NRC prefers that the files be in WordPerfect 5.1 format.
2.8.7 Limit all other amendment requests during the NRC review process.
Develop with the NRC a date after which no new license amendment requests will be submitted unless necessary to support continued plant operations or other emergencies.
2.8.8 Provide the NRC with a schedule for ITS implementation identifying when a draft and final SE is required from the NRC to support implementation activities.
2.8.9 Identify and discuss in the submittal any requirement that will be implemented after the ITS implementation date (i.e., new surveillances which will be delayed until the next refueling outage, etc.)
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August 1996 2.8.10 Provide training materials to assist the NRC in their review. This would include simple, one-line system schematics and general instrument logic diagrams. Three copies of these materials should be provided (1 copy for the NRCs use and 2 copies for the NRCs contractors). Determine with your NRC Project Manager how those materials should be provided.
2.8.11 The NRC requests that licensees provide nine copies of the license application. This will allow the NRC to provide copies to the Project Manager, Conversion Lead, Technical Specifications Branch, NRC contractors (2), Docket File, Resident Inspector, the Regional Office, and the technical staff. Providing copies eliminates the time and expense of the NRC making copies and allows the licensee to verify the copies are correct, possibly avoiding questions from the NRC.
3 ISTS GENERIC CHANGE PROCESS The industry and the NRC are working together to make the ISTS living documents. There are processes for incorporating improvements identified during plant conversions and new generic issues into the ISTS. This will save resources for the industry when performing ITS conversions and other license amendments and will allow information to be shared between plants more easily. Maintenance of the ISTS and increased standardization between plants saves the NRC resources during the processing of license amendments, during inspections, and when considering generic issues.
To facilitate the maintenance of the ISTS, the industry formed the NEI Technical Specification Task Force (TSTF). The TSTF is composed of six members, one appointed by each Owners Group, a Technical Coordinator, and an NEI member. Each Owners Group representative is responsible for identifying and evaluating changes to their respective ISTS and for acting as a point of contact between the TSTF and the plants represented by their Owners Group. The TSTF works with the NRC to propose, review, and approve changes to the ISTS.
3.1 Identification of Potential Generic Changes Changes may be identified by Owners Groups or NRC staff in the process of resolving technical issues, or by an individual plant performing ITS conversions. Deviations from the ISTS identified by the conversion plant should be considered as potential generic changes to the ISTS. Generic 10
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August 1996 changes may also be initiated by plants that are not converting to the ITS to support license amendment requests.
3.2 Generic Change Threshold The TSTF will act on changes that meet a significance threshold and are potentially generic. The significance threshold was developed by the TSTF and the NRC. It is:
- Technical Specifications - any technical or administrative error that could reasonably lead to a misinterpretation of the technical specification, or technically incorrect information.
- Bases - any significant error that could reasonably lead to misinterpretation of the Technical Specification, or technically incorrect information.
3.3 Generic Change Review Process The review and approval of a proposed generic change to the ISTS is a many-staged process designed to ensure that each ISTS remains internally consistent, to maintain consistency between the ISTS, and to incorporate the knowledge and positions of the industry and the NRC.
3.3.1 The proposed changes should initially be reviewed by the Owners Group which identifies the change to determine if they recommend incorporation into their ISTS. Those changes determined to meet the threshold and that have been accepted by the Owners Group will be transmitted to the TSTF.
3.3.2 The proposed change will be transmitted to each Owners Group representative on the TSTF for review by their respective Owners Group.
3.3.3 The TSTF members, and the represented Owners Group members, will review the proposed change to determine if it is an appropriate change to the various ISTS. Discussions with other members of the TSTF will be held, as appropriate, and modifications to the proposed change may be requested. This review will also confirm that the proposed change meets the threshold.
3.3.4 If the proposed change has been accepted as a potential change to one or more of the ISTS by the TSTF, the TSTF members will create 11
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August 1996 marked up pages from their ISTS reflecting the change. The proposed change will then be sent to the NRC Technical Specifications Branch for review.
3.3.5 The NRC Technical Specifications Branch will review the proposed generic changes for inclusion into the appropriate ISTS. Formal interactions are coordinated through the TSTF, but this does not preclude direct technical exchange between the cognizant NRC and industry staff.
3.3.6 In cases where the industry and the NRC cannot come to agreement, an appeal process exists. Appeals will be made before a group of industry and NRC executives which will make the final decision.
3.3.7 Changes that are approved to be made to the ISTS by the TSTF and the NRC will be incorporated into the word-processing files and placed on the NRCs Technical Specifications Bulletin Board System in accordance with NRC Administrative Letter 94-13, and be made available for distribution. Periodically, the NRC may issue the entire NUREG as a new revision.
4 NRC REVIEW PROCESS Each ITS conversion application has unique features which will influence the review. Conversion from custom technical specifications, significant technical changes being reviewed concurrently with the ITS conversion, or unique plant features will affect the review process.
4.1 Review of the Submittal The details of the NRC review of the ITS conversion license amendment request will vary from plant to plant. However, there are some general areas which the NRC will typically review.
- The NRC will typically assess the application of the Technical Specification Selection Criteria Report to ensure the criteria were appropriately applied and that any plant-specific requirements not addressed in the original application of the criteria by the Owners Groups have been appropriately addressed.
- The NRC will typically review all deviations from the ISTS to determine if the requirements have been appropriately incorporated into the ITS.
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- The NRC will typically review all relocated requirements to ensure the requirements are not required to be maintained in Technical Specifications per 10 CFR 50.36 and are not required to eliminate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
- The NRC will typically review all CTS changes which are consistent with ISTS but require the licensee to revise the plant design or analyses (i.e.; identified as more restrictive or less restrictive in the CTS Comparison Document).
4.2 Development of a Draft SE The NRC will develop a draft SE upon completion of the tasks described above. The draft SE may be issued for utility review to ensure the SE is factually correct. The final ITS pages are then prepared for publication with the amendment.
4.3 Issuance of the Final SE The final SE may be issued in advance of completion of all the requisite programs, procedures and training necessary for implementation. The determination as to when to issue the final SE should be made jointly between the utility and the NRC and should be based on when all the technical and legal issues are resolved, and on the specific requirements and schedules of the utility and the NRC.
5 IMPLEMENTATION ACTIVITIES In the conversion submittal, the licensee should state their planned implementation date. However, the conversion license amendment will typically not include an exact implementation date, but rather an implementation window. When the implementation activities are complete, the licensee will inform the NRC of the exact implementation date.
There are many implementation activities required by conversion to the ITS.
The resources required to implement the ITS will typically far exceed those required to develop the submittal. It is usually necessary to begin implementation activities immediately after submittal of the conversion application to avoid excessive delays between application approval and implementation.
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August 1996 The NRC prefers implementation to occur soon after application approval.
Some delay, in the manner of several months, is acceptable. Historically, delays approaching a year have been discouraged.
While each plant will have unique implementation needs, there are several categories of changes that affect each plant.
5.1 Procedures and Programs Utilities must develop or change programs and procedures that address the requirements in the new ITS.
5.1.1 Utilities must review procedures and determine those that require modification as a result of the conversion. These procedures include but are not limited to:
- Surveillance Test Procedures
- Systems Operations Procedures
- Maintenance Procedures
- Operations Procedures
- Administrative Procedures 5.1.2 It is important to develop a strategy for the identification, revision, and implementation of the affected procedures. Techniques have been developed to avoid implementing hundreds or thousands of revised procedures at the moment of implementation of the ITS. One technique is to incorporate both the CTS and ITS numbers as references in procedures and implementing these procedures prior to ITS implementation with appropriate administrative controls. Some plants have also implemented the procedure reflecting more restrictive changes prior to implementation. An alternative approach is to provide a cross-reference of the CTS and ITS numbers and incorporate the ITS numbers into procedures after ITS implementation. Of course, procedures reflecting requirements which are more restrictive in the ITS must be revised prior to or concurrent with the implementation of the ITS.
5.1.3 Experience has shown that of the procedure changes resulting from conversion to ITS, approximately 75% are reference changes only.
Approximately 15% of procedure changes are minor technical changes (e.g., the frequency is changed from monthly to quarterly), and approximately 10% of procedure changes are more technical in nature 14
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August 1996 (i.e., they are new procedures or they are existing procedures with changes to technical detail).
5.1.4 There are a number of new programs required by the ITS Administrative Controls. These programs must be developed prior to implementation. While many of these programs are very similar to existing technical specifications requirements, some, such as the Safety Function Determination Program, are new and will require substantial resources to develop.
5.2 Training Utilities must provide training to personnel to ensure successful transition to the ITS. Concurrent training of personnel while the ITS submittal is reviewed by the NRC should be performed to minimize the time between issuance of the final SE and implementation of the ITS. Implementation should only occur after training of critical personnel is completed. Personnel to be trained include:
- Shift Technical Advisors
- Non-licensed Operators
- Engineering Support Personnel
- Plant Management
- Licensing Personnel
- Maintenance Personnel
- Chemistry Personnel Because of the pervasive nature of technical specifications on the operation of a nuclear power plant, careful attention should be given to identifying all of the personnel who will require training.
5.3 Development of a Technical Requirements Manual Many utilities have chosen to develop a licensee-controlled manual which contains many of the relocated technical specifications. This manual is typically incorporated by reference into the UFSAR. This manual is typically called a Technical Requirements Manual (TRM), Operations Requirements Manual, or Licensee-Controlled Specifications, and is formatted similar to the ITS. All changes made to the relocated technical specifications placed in the TRM must be evaluated under 10 CFR 50.59. As requirements are moved from the Technical Specifications to the TRM, shutdown requirements, 15
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August 1996 special report submittals, and other unnecessary restrictions may be evaluated under 10 CFR 50.59 and eliminated. It is important to note that all changes to relocated technical specifications must be documented and evaluated under 10 CFR 50.59.
6 POST-IMPLEMENTATION AUDIT The NRC has stated that they will perform a post-implementation audit to assess the effectiveness of the ITS implementation and to determine if relocated items have appropriate licensee control. The audit will typically occur approximately 12 to 18 months after implementation. See NRC Inspection Manual Temporary Instruction 2515/130, Improved Technical Specification Implementation Audits, September 12, 1995.
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August 1996 ATTACHMENT 1 NRC RECOMMENDED CONVERSION APPLICATION GUIDELINES The following guidelines describe the optimum license amendment application for conversion to the improved standard technical specifications.
The cover letter that forwards and explains the license amendment submittal should summarize and emphasize the following specific changes included in the application, for early planning and coordination:
- potential "beyond scope" or licensing basis changes that are both different than the CTS and different from the ISTS; changes in plant-specific (bracketed) parameters from those in the CTS should also be noted, unless the change in the value is specifically associated with conforming to the usage in the ISTS.
- existing pending license amendment applications incorporated in the ITS, and any future amendment applications expected to be incorporated into the ITS.
- pending ISTS change travelers incorporated in the application.
- proposed new ISTS changes that are being submitted as travellers, and the expected submittal date to the Technical Specifications Task Force (TSTF).
The cover letter should also discuss the implementation schedule for the ITS, and projected date when the amendment is needed.
Application Attachments The attachments to a conversion application present the information needed to evaluate the changes from the CTS requirements, complete the Safety Evaluation supporting issuance of an amendment, and understand the comparability and differences from the ISTS.
A-1
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August 1996 The material should be organized for each Chapter 1.0 chapter and section of the ISTS/ITS, as listed Chapter 2.0 to the right, as follows: Section 3.0 Section 3.1
- Clean copy of the ITS Section 3.2
- CTS markup Section 3.3
- Discuss of Changes (DOCs) from the Section 3.4 CTS requirements Section 3.5
- ISTS and Bases markup Section 3.6
- Justification for Differences (JDs) from Section 3.7 the ISTS Section 3.8
- NSHC findings Section 3.9 Section 3.10 (if applicable)
Chapter 4.0 Chapter 5.0 Clean Copy of the ITS Each chapter and section of the ITS should be printed as it is intended to appear in the final version of the technical specifications.
Markup of Current Technical Specifications (CTS)
Each change from the CTS requirements should be numbered for identification and traceability; the preferred method is sequential numbering by the following types in each ISTS/ITS chapter, section, or specification:
R - relocated specification moved entirely to licensee-controlled document in accordance with the criteria in §50.36(c)(2).
A - administrative change associated with format, presentation, or reorganization of existing requirements without changes to the license restrictions.
L - less restrictive requirement, including reduction in a Frequency, the Applicability, or an OPERABILITY requirement (or variable limit), increase in a Completion Time, or deletion of a requirement, to conform to the ISTS.
LR - [optional category, sometimes labeled LA] less restrictive removal of certain details and information, from otherwise retained specifications, which is specified in the bases, FSAR or licensee procedures, as appropriate.
A-2
NEI 96-06 (Original)
August 1996 M - more restrictive requirement, including the addition of a new LCO or other requirement; increase in a Frequency, the Applicability, or an OPERABILITY requirement (or variable limit); or a decrease in a Completion Time to conform to the ISTS.
Each numbered change should have a corresponding discussion of change (DOC) which provides that information that is both necessary and sufficient to justify the change from the current restrictions.
The CTS pages (and any insert pages) corresponding to each proposed specification should be paginated by hand in the "Page # of #" format. This will facilitate referencing replacement pages when updating the CTS markup (improved TS order) with changes in the application.
A change to CTS that is reflected in multiple improved TS specifications may be discussed once to avoid unnecessary duplication. It is not necessary to repeat the discussion as a separately numbered DOC each time the same change occurs in the CTS, provided that references are clearly identified and completely appropriate to the change. Such general changes may be numbered separately for the entire submittal and be provided with a prefix corresponding to the category of change (for example, the prefixes AG-, LG-, LRG-, and MG- could be used). However, any particular change that warrants additional unique justification, to ensure that the basis for the change is clear, should not be designated as a general change. A change occurring several times in the CTS, but which is reflected in just one specification in the improved TS, also ought not be designated as a general change.
Each change to each requirement on the page should be clearly delineated by drawing a border which surrounds all of the affected text, and annotated with the corresponding change number.
For a page with requirements being moved to two or more separate improved TS specifications, two or more versions of the page, each corresponding to its new location, should be prepared with cross reference to the other specification(s).
When deleting large sections or entire lines, surround them with a border and mark through the text with sparse diagonal lines. For individual word deletions, line straight through the word. The information marked out must still be able to be read. All marked out requirements should be annotated with a corresponding DOC number.
Replacement text or new text may be handwritten if not too long. Use typed inserts for more extensive changes to text (with the insert(s) on the page(s) immediately following the affected page).
A-3
NEI 96-06 (Original)
August 1996 Print handwritten information in the markup and make sure the information is legible - avoid using cursive handwriting.
Insofar as possible, each retained requirement should be annotated with the improved TS requirement number (e.g., LCO 3.3.2, SR 3.4.5.2, Applicability of 3.2.3, ACTION A of 3.2.3, Note 1 to ACTION B of 3.8.1, etc.).
A cross-reference table that lists all current requirements in CTS order, and their disposition in the ITS is a very useful tool to facilitate the review, and is usually prepared by the licensee for use by plant personnel that prepare procedure changes to implement the improved TS. The more detailed the table, the more useful it will be for the reviewer. As a minimum, the licensee should provide a summary table for relocated or removed requirements from the CTS which clearly identifies the new location of the requirement and what control applies to relocated requirements and less restrictive details removed from the CTS to conform to the ISTS content (details subsequently specified in the Bases or FSAR).
Discussion of Changes (DOCs)
For each annotated change to the CTS, the DOC contains the detailed justification for the change. Each DOC, regardless of the type of change, should contain the following:
- A full description of the proposed change to the CTS requirement.
- If the change is not consistent with the ISTS, state that it is not and reference the JD that describes the difference from the ISTS.
Each change, deletion or addition to the CTS requirements must be justified on a plant-specific basis; conformance to the ISTS is not sufficient justification. The justification for relocating requirements from the LCOs in accordance with the criteria in §50.36(c)(2), should include an appropriate description of the "split" evaluation which was used to develop the ISTS, as it relates to the plant-specific design and licensing basis. Use of references, rather than complete explanations, in the DOCs is undesirable, because that adds to the review time and the DOC information is used to develop the Safety Evaluation.
Markup of the ISTS and ISTS Bases A-4
NEI 96-06 (Original)
August 1996 Sequentially number the differences for each division of the ISTS markup, using the same divisions used for the CTS markup (improved TS order). Clearly indicate each ISTS requirement for which the corresponding improved TS requirement differs.
Consideration should be given to adding the following prefixes to the difference numbers to indicate the general reason for each difference:
CLB - retention of existing requirement (current licensing basis)
PA - plant-specific wording preference or minor editorial improvement DB - plant-specific difference in the design or the design basis TA - difference based on an approved traveler TP - difference based on a submitted, but pending traveler X - difference for any reason other than the above Bracketed numbers or requirements need not be addressed by a difference discussion provided that the existing requirement is being retained. Otherwise, the relevant DOC should be referenced. Modifying difference number prefixes with a "G" may be appropriate for differences affecting multiple specifications in the improved TS.
Bases differences should be annotated with the difference number in the markup of the corresponding ISTS specification. Bases differences without such a correspondence should be numbered in the same way, sequentially following the last number used for the section.
Each difference from an ISTS requirement on the page should be clearly numbered and delineated by drawing a border which surrounds the affected difference.
When deleting large sections or entire lines, surround them with a border and mark through the text with sparse diagonal lines. For individual word deletions, line straight through the word. The information marked out must still be able to be read. All marked out requirements should be annotated with a corresponding JD number.
Replacement text or new text may be handwritten if not too long. Use typed inserts for more extensive changes to text (with the insert(s) on the page(s) immediately following the affected page).
A-5
NEI 96-06 (Original)
August 1996 Print handwritten information in the markup and make sure the information is legible - avoid using cursive handwriting.
Justification for Differences (JD)
For each departure from the ISTS, the JD contains the explanation for the difference. The correspondence of each difference from the ISTS to technical changes to the CTS (R, L, LR, or M) should be referenced in the corresponding difference discussion, as appropriate.
No Significant Hazards Consideration (NSHC)
For each appropriate group of changes from the CTS, the NSHC justification contains evaluation required under §50.91. General evaluations may be used as appropriate for changes of types R, A and AG, LR and LRG, and M and MG.
Specific evaluations should be provided for changes of type L.
Electronic Files Diskettes should be provided with the initial application which contain the DOC and JD information, the cross-reference table (the table format can be negotiated if the information is readily available to the licensee in a database) and the files of the proposed ITS and associated Bases, in WordPerfect 5.1 format.
Application Updates and Revisions During the course of the review process, the application may need revising to reflect resolution of issues arising from the review, issuance of other TS change amendments, and approval or rejection of ISTS change proposals. All affected pages of the markups, DOC and JD documents, and proposed TS and Bases should be revised and submitted with a cover letter outlining the general reasons for the changes. In addition, the revision should also include a diskette with updated electronic files of the affected difference and change discussions. It is suggested that changes resulting from specific staff comments be annotated with the associated comment number to facilitate verification that comment resolution commitments have been met.
Application updates should be timely enough to preclude delaying the review.
Substantial changes to the application should be addressed affirmatively by the licensee with regard to whether the change warrants a revised Sholly notice.
Final Certified ITS A-6
NEI 96-06 (Original)
August 1996 Upon the completion of the staff's review, a draft Safety Evaluation (SE) will be sent to the licensee to confirm that the details of the conversion have been appropriately reflected. After any licensee or staff comments on the draft SE have been resolved, the licensee will submit the final version of the ITS to be issued with the license amendment. The licensee should also submit the final ITS in electronic format, WordPerfect 5.1 format, to establish the benchmark files for use by the Project Directorate staff.
A-7