NRC Generic Letter 1995-10
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555December 15, 1995NRC GENERIC LETTER 95-10: RELOCATION OF SELECTED TECHNICAL SPECIFICATIONSREQUIREMENTS RELATED TO INSTRUMENTATION
Addressees
All holders of operating licenses or construction permits for nuclear powerreactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter toadvise those licensees that have not converted or are not in the process ofconverting to the improved Standard Technical Specifications that they mayrequest a license amendment to relocate selected instrumentation requirementsfrom their Technical Specifications (TSs).
Description of Circumstances
This line-item TS improvement was developed in response to TS amendmentsproposed by licensees and ongoing NRC TS improvement programs. The intent ofthis generic letter is to reduce the resources spent by licensees and the NRCstaff in amending requirements related to the selected instrumentation-relatedTSs. Relocating requirements to licensee-controlled documents or programswill reduce costs for licensees by allowing them to change the requirementswithout necessarily amending their licenses. The NRC staff will save time andreduce costs by using internal guidance to review amendments related to thisgeneric letter and by decreasing the number of plant-specific changes to theaffected TSs.DiscussionSection 182a of the Atomic Energy Act (the Act) requires applicants fornuclear power plant operating licenses to include TSs as part of the license.In Section 50.36 of Title 10 of the Code of Federal Regulations(10 CFR 50.36), the Commission established the regulatory requirements relatedto the content of TSs. That regulation requires that the TSs include items infive specific categories, including (1) safety limits, limiting safety systemsettings, and limiting control settings; (2) limiting conditions foroperation; (3) surveillance requirements; (4) design features; and (5)administrative controls. However, the regulation does not specify theparticular requirements to be included in TSs.The NRC developed criteria, as described in the "Final Policy Statement onTechnical Specifications Improvements for Nuclear Power Reactors"95121203701 t a -PC>& XMO ACK 0So3 1 ftsa ? U GL 95-10December 15, 1995 (58 FR 39132), to determine which of the design conditions and associatedsurveillances should be located in the TSs as limiting conditions foroperation. Four criteria were subsequently incorporated into the regulationsby an amendment to 10 CFR 50.36 (60 FR 36953):1. installed instrumentation that is used to detect, and indicate inthe control room, a significant abnormal degradation of thereactor coolant pressure boundary;2. a process variable, design feature, or operating restriction thatis an initial condition of a Design Basis Accident or Transientanalysis that either assumes the failure of or presents achallenge to the integrity of a fission product barrier;3. a structure, system, or component that is part of the primarysuccess path and which functions or actuates to mitigate a DesignBasis Accident or Transient that either assumes the failure of orpresents a challenge to the integrity of a fission productbarrier;4. a structure, system, or component which operating experience orprobabilistic safety assessment has shown to be significant topublic health and safety.The Commission's Final Policy Statement and documentation related to therevision of 10 CFR 50.36 acknowledged that implementation of these criteriamay cause some requirements presently in TSs to be moved out of existing TSsto documents and programs controlled by licensees. This generic letteraddresses the relocation of selected TS requirements related toinstrumentation as a result of applying the 10 CFR 50.36 criteria. Onreviewing typical TSs for nuclear power reactors, the staff determined that,in accordance with the 10 CFR 50.36 criteria, several specifications did notwarrant inclusion in TSs. The staff also concluded that the instrumentationaddressed by these specifications are not related to dominant contributors toplant risk. The following typical TSs are among the candidates for relocationto licensee-controlled documents:* Incore Detectors (Movable Incore Detectors, Traversing IncoreProbe)* Seismic Monitoring Instrumentation* Meteorological Monitoring Instrumentation* Chlorine Detection System* Loose-Part Detection System* Explosive Gas Monitoring Instrumentation* Turbine Overspeed Protection IGL 95-10December 15, 1995 Requested InformationLicensees that voluntarily choose to use the guidance in this generic letterwill need to submit license amendment requests in order to relocate theaffected technical specifications. These licensees are encouraged to proposeTS changes consistent with the guidance in Attachment I to this genericletter.Licensees that do not wish to amend technical specifications are not expectedto submit any response to this generic letter.Required ResponseLicensees that voluntarily choose to use the guidance in this generic letterare required to submit license amendment requests in order to relocateaffected technical specification requirements.Licensee requests should be submitted to the U.S. Nuclear RegulatoryCommission, ATTN: Document Control Desk, Washington, DC 20555, under theprovisions of 10 CFR 50.90.
Backfit Discussion
This generic letter requests information under the provisions of 10 CFR 50.90only from addressees that voluntarily choose to use the contained guidance toseek an amendment of an operating license. Any action by licensees to proposeTS changes in accordance with the guidance of this generic letter is voluntaryand, therefore, not a backfit under 10 CFR 50.109. Therefore, the staff hasnot performed a backfit analysis.
Federal Register Notification
A notice of opportunity for public comment was published in the FederalRegister (60 FR 33239) on June 27, 1995. Comments were received fromone industry organization. Copies of the staff evaluation of these commentswill be made available in the NRC Public Document Room.
Paperwork Reduction Act Statement
The voluntary information collections contained in this request are covered bythe Office of Management and Budget clearance number 3150-0011, which expireson July 31, 1997. The public reporting burden for this voluntary collectionof information is estimated to average 40 person-hours per response, includingthe time for reviewing instructions, searching existing data sources,gathering and maintaining the data needed, and completing and reviewing thecollection of information. Send comments regarding this burden estimate orany other aspect of this voluntary collection of information, including GL 95-10December 15, 1995 suggestions for reducing this burden, to the Information and RecordsManagement Branch (T-6F33), U.S. Nuclear Regulatory Commission, Washington, DC20555-0001, and the Desk Officer, Office of Information and RegulatoryAffairs, NEOB-3019, (3150-0011), Office of Management and Budget, Washington,DC 20503.Compliance with the following request for information is voluntary. Thefollowing information would assist the NRC in evaluating the cost of complyingwith this generic letter:1. licensee staff time and costs to prepare the amendment request,and2. an estimate of the long-term costs or savings accruing from thisTS change.If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager.Denn sS' .utc# 'e d:irectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contact: William D. Reckley(301) 415-1314Internet:wdr@nrc.gov
Attachments:
1. Guidance for a Proposed LicenseAmendment To Relocate SelectedTechnical Specifications RequirementsRelated to Instrumentation2. List of Recently Issued NRC Generic Lettersdoor GL 95-10December 15, 1995 suggestions for reducing this burden, to the Information and RecordsManagement Branch (T-6F33), U.S. Nuclear Regulatory Commission, Washington, DC20555-0001, and the Desk Officer, Office of Information and RegulatoryAffairs, NEOB-3019, (3150-0011), Office of Management and Budget, Washington,DC 20503.Compliance with the following request for information is voluntary.following information would assist the NRC in evaluating the cost ofwith this generic letter:Thecomplying1. licensee staff time and costs to prepare the amendment request,and2. an estimate of the long-term costs or savings accruing from thisTS change.If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager.original signed byDennis M. Crutchfield, DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contact:William D. Reckley(301) 415-1314Internet:wdr@nrc.gov
Attachments:
1. Guidance for a Proposed LicenseAmendment To Relocate SelectedTechnical Specifications RequirementsRelated to Instrumentation2. List of Recently Issued NRC Generic LettersDOCUMENT NAME: 95-10.GLTech Ed reviewed this document 11/16/95SECY 95-283 DTD 11/29/95To receive a copy of this document, Indicate In the box: 'C' Copy without attachment/enclosure 'E' -Copy with attachment/enclosure OFF -No copyOFFICE TECH
CONTACT
- OGC* /PECBD INAME SHLewis AChaffee DM&M1berirleldDATE 11/16/95 11/21/95 11/22/95 12//S /95OFFICIAL RECORD COPY Attachment 1GL 95-10December 15, 1995 GUIDANCE FOR A PROPOSED LICENSE AMENDMENT TO RELOCATE SELECTEDTECHNICAL SPECIFICATIONS REQUIREMENTS RELATED TO INSTRUMENTATIONIntroductionThe NRC is issuing the following guidance for preparing a proposed licenseamendment to relocate from Technical Specifications (TSs) selectedrequirements related to instrumentation. As discussed in the Final PolicyStatement and documentation related to the revision of 10 CFR 50.36, licenseessubmitting amendment requests should identify the location of and controls forthe relocated requirements. It is expected that most of the TSs addressed bythis generic letter will be relocated to the Updated Final Safety AnalysisReport (UFSAR) and that changes to those provisions will be performed inaccordance with 10 CFR 50.59, "Changes, tests and experiments." Ifrequirements are relocated to other documents (e.g., the emergency plan),controls may be provided by regulatory requirements such as 10 CFR 50.54,"Conditions of licenses." The adequacy of controls for relocated provisionswhich do not fit in the above categories will be reviewed and approved by theNRC staff on a case-by-case basis.License amendment requests should contain a commitment to relocate eachselected requirement to a particular licensee-controlled document or program,(e.g., the UFSAR or the emergency plan). The commitment should also addressthe submittal of the revised documents to the NRC in accordance with theapplicable regulation (e.g., 10 CFR 50.71(e)). In the amendment request, thelicensee should clearly describe the program it will use to control changes torelocated provisions (e.g., 10 CFR 50.59 or 50.54(q)). Control of therelocated provisions in accordance with the applicable regulation ensures thatNRC review and approval will be requested for changes exceeding the statedregulatory threshold (e.g., an unreviewed safety question or a decrease ineffectiveness).Licensees should note that this generic letter supersedes TS-related guidancecontained in several previously issuel NRC documents, such as regulatoryguides and the Standard Review Plan (NUREG-0800). Commitments contained inthe UFSAR or other docketed correspondence may need to be revised to reflectthe deviations from these NRC documents. However, this generic letteraddresses only the need to include requirements related to the affectedsystems in TSs. Staff positions in the regulatory guides or other documentson matters other than TS content are not affected by the issuance of thisgeneric letter.The NRC has approved the relocation of most of these specific instrumentationrequirements in various amendments issued to specific licensees. The improvedstandard TSs also reflect the staff position that these requirements do notmeet the 10 CFR 50.36 criteria for inclusion in TSs. The staff has alsoconcluded that these provisions are not related to dominant contributors to Attachment 1GL 95-10December 15, 1995 plant risk. Additional discussions follow for each of the selected relocatedinstrumentation requirements.Incore DetectorsThe relocation of requirements related to incore neutron detectors affectsthe TS sections entitled "Incore Detectors" or "Movable Incore Detectors," forpressurized water reactors (PWRs), or "Traversing Incore Probe," for boilingwater reactors (BWRs). Incore instrumentation is used periodically tocalculate power peaking factors to verify nuclear design predictions, ensureoperation within established fuel performance limits, and calibrate othernuclear instrumentation. The measurements are used in a confirmatory mannerand do not provide direct input to reactor protection system or engineeredsafety features actuation system functions.These instruments are neither used for, nor capable of, detecting asignificant abnormal degradation of the reactor coolant pressure boundarybefore a design basis accident, nor do they function as a primary success pathto mitigate events which assume a failure of or a challenge to the integrityof fission product barriers. Although the core power distributions (measuredby the incore detectors) constitute an important initial condition to designbasis accidents and therefore need to be addressed by TSs, the detectorsthemselves are not an active design feature needed to preclude analyzedaccidents or transients. The staff has determined, therefore, that the incoredetector requirements do not meet the criteria of 10 CFR 50.36 for inclusionin TSs. Licensees may propose to relocate the incore detector requirements tothe UFSAR and control changes to those provisions in accordance with10 CFR 50.59.Relocation of the incore detector requirements from the TSs to the UFSAR doesnot imply any reduction in their importance in confirming that core powerdistributions are bounded by safety analysis limits. It is expected thatlicensees will continue to maximize the number of available incore detectors.Evaluations related to changes in incore detector requirements are expected toconsider such factors as the need to identify the inadvertent loading of afuel assembly into an improper location, the calibration of protection systemsusing incore measurements, and the allowances for measurement and nucleardesign uncertainties. Should these or other considerations lead to theidentification of a proposed change as an unreviewed safety question, thelicensee should request NRC review and approval in accordance with10 CFR 50.59(c).Seismic Monitoring InstrumentationSection VI(a)(3) of Appendix A to 10 CFR Part 100 requires that seismicmonitoring instrumentation be provided to promptly determine the response ofthose nuclear power plant features important to safety in the event of anearthquake. This capability is required to allow for a comparison of the Attachment 1GL 95-10December 15, 1995 measured response to that used in the design basis for the unit. Comparisonof such data is needed to (1) determine whether the plant can continue to beoperated safely and (2) permit such timely action as may be appropriate.However, seismic instrumentation does not actuate any protective equipment orserve any direct role in the mitigation of an accident.The capability of the plant to withstand a seismic event or other design basisaccident is determined by the initial design and construction of systems,structures, and components. The instrumentation is used to alert operators tothe seismic event and evaluate the plant response. The Final Policy Statementexplained that instrumentation to detect precursors to reactor coolantpressure boundary leakage, such as seismic instrumentation, is not included inthe first criterion. As discussed above, the seismic instrumentation does notserve as a protective design feature or part of a primary success path forevents which challenge fission product barriers. The staff has concluded thatthe seismic monitoring instrumentation does not satisfy the 10 CFR 50.36criteria and need not be included in the TSs. Licensees may propose torelocate the seismic monitoring instrumentation requirements to the UFSAR andcontrol changes to those provisions in accordance with 10 CFR 50.59.Meteorological Monitoring InstrumentationIn 10 CFR 50.47, "Emergency Plans," and 10 CFR Part 50, Appendix E, "EmergencyPlanning and Preparedness for Production and Utilization Facilities," theCommission requires power plant licensees to provide reasonable assurance thatadequate protective measures can and will be taken in the event of aradiological emergency. Timely access to accurate local meteorological datais important for estimating potential radiation doses to the public and fordetermining appropriate protective measures. In 10 CFR 50.36a(a)(2), theCommission requires nuclear power plant licensees to submit annual reportsspecifying the quantity of each of the principal radionuclides released tounrestricted areas in liquid and airborne effluents and such other informationas may be required by the NRC to estimate maximum potential annual radiationdoses to the public. A knowledge of meteorological conditions in the vicinityof the reactor is important in providing a basis for estimating annualradiation doses resulting from radioactive materials released in airborneeffluents. Accordingly, the meteorological monitoring instrumentation servesa useful function in estimating radiation doses to the public from eitherroutine or accidental releases of radioactive materials to the atmosphere.The meteorological monitoring instrumentation does not serve such a primaryprotective function as to warrant inclusion in the TSs in accordance with the10 CFR 50.36 criteria. The instrumentation does not serve to ensure that theplant is operated within the bounds of initial conditions assumed in designbasis accident and transient analyses or that the plant will be operated topreclude transients or accidents. Likewise, the meteorologicalinstrumentation does not serve as part of the primary success path of a safetysequence analysis used to demonstrate that the consequences of these events Attachment 1GL 95-10December 15, 1995 are within the appropriate acceptance criteria. Accordingly, the staff hasconcluded that the meteorological instrumentation does not meet the10 CFR 50.36 criteria and need not be included in TSs. The staff hasdetermined that requirements related to the meteorological monitoringinstrumentation may be moved from the TSs to the UFSAR and that anysubsequent changes to the provisions may be controlled pursuant to10 CFR 50.59. Licensees may alternately choose to relocate the meteorologicalmonitoring instrumentation requirements from the TSs to the facility'semergency plan. In this case, subsequent changes would be made in accordancewith 10 CFR 50.54(q).Chlorine Detection SystemChlorine detection systems ensure that sufficient capability is available topromptly detect and initiate protective action to isolate the control room inthe event of an accidental chlorine release. Some plants may also havesystems to detect other toxic gases that have the potential to hamper plantoperation in the case of their accidental release from onsite or offsitesources. This discussion of the typical chlorine detection systems alsoapplies to the relocation of TSs related to other toxic gas detection systems.Staff positions regarding the relationship of the chlorine detection systemsto the general design criteria (GDC) appear in NUREG-0800, "Standard ReviewPlan" (SRP); Regulatory Guide (RG) 1.78, "Assumptions for Evaluating theHabitability of a Nuclear Power Plant Control Room During a PostulatedHazardous Chemical Release"; and RG 1.95, "Protection of Nuclear Power PlantControl Room Operators Against an Accidental Chlorine Release."As discussed above, chlorine detection systems may serve an important role inprotecting control room personnel from internal or external hazards related totoxic gases. However, the release of chlorine or other hazardous chemicals isnot part of an initial condition of a design basis accident or transientanalysis that assumes a failure of or presents a challenge to the integrity ofa fission product barrier. Since the release of toxic gases is not assumed toinitiate or occur simultaneously with design basis accidents or transientsinvolving challenges to fission product barriers, the chlorine detectionsystem is not part of a success path for the mitigation of those accidents ortransients. The staff has, therefore, concluded that requirements for thissystem do not meet the 10 CFR 50.36 criteria and need not be included in TSs.Licensees may propose to relocate the chlorine detection system requirementsto the UFSAR and control changes to those provisions in accordance with10 CFR 50.59.Loose-Part Detection SystemThe loose-part detection system identifies the existence of possible looseparts in the reactor coolant system. Early detection can give operators timeto take corrective actions and avoid or mitigate damage to or malfunctions ofprimary system components. However, as discussed in the Final Policy Attachment 1GL 95-10December 15, 1995 Statement, the loose-part detection system does not function to detectsignificant abnormal degradation of the reactor coolant pressure boundary.The loose-part detection system does not serve as an active design feature forestablishing initial conditions or mitigation of design basis accidents ortransients. The staff has concluded that requirements for this system do notsatisfy the 10 CFR 50.36 criteria and need not be included in TSs. Licenseesmay propose to relocate the requirements related to the loose-part detectionsystem from the TSs to the UFSAR and control changes to those provisions inaccordance with 10 CFR 50.59.Explosive Gas Monitoring InstrumentationThe relocation of most of the instrumentation related to radioactive gaseouseffluent monitoring was addressed in Generic Letter 89-01, "Implementation ofProgrammatic Controls for Radiological Effluent Technical Specifications[RETS] in the Administrative Controls Section of the Technical Specificationsand the Relocation of Procedural Details of RETS to the Offsite DoseCalculation Manual or the Process Control Program." Relocation of therequirements for explosive gas monitoring instrumentation was not addressed inthe guidance provided by Generic Letter 89-01. Staff positions regarding themonitoring of explosive gases within the radioactive waste management systemsare outlined in SRP Section 11.3 and Branch Technical Position ETSB-11-5,"Postulated Radioactive Releases Due to a Waste Gas System Leak or Failure."The actions required by existing TSs typically require alternate sampling,limited operation of the gaseous waste system, and submittal of a specialreport if the explosive gas monitoring instrumentation does not conform to thelimiting condition for operation. The explosive gas monitoringinstrumentation requirements address detection of possible precursors to thefailure of a waste gas system but do not prevent or mitigate design basisaccidents or transients which assume a failure of or present a challenge to afission product barrier. Acceptable concentrations of explosive gases areactually controlled by other limiting conditions for operation (e.g., GaseousEffluents, Explosive Gas Mixture) or by programs described in the"Administrative Controls" section of TSs. The requirements related toexplosive gas monitoring instrumentation do not conform to the 10 CFR 50.36criteria for inclusion in the TSs. Therefore, licensees may propose torelocate the explosive gas monitoring instrumentation requirements to theUFSAR and control changes to those provisions in accordance with 10 CFR 50.59.Turbine Overspeed ProtectionExisting TSs typically include limiting conditions for operation andsurveillance requirements for the turbine overspeed protection system. Theturbine is equipped with control valves and stop valves which control turbinespeed during normal plant operation and protect it from overspeed duringabnormal conditions. The turbine overspeed protection system consists of
<-I' -Attachment 1GL 95-10December 15, 1995 separate mechanical and electrical sensing mechanisms which are capable ofinitiating fast closure of the control and stop valves. Current TSs mayrequire particular operability and surveillance requirements for these steamcontrol and stop valves to minimize the potential for fragment missilesgenerated by a turbine overspeed event. General Design Criterion 4 ofAppendix A to 10 CFR Part 50 requires that structures, systems, and componentsimportant to safety be appropriately protected from the effects of missilesthat may result from equipment failures. Application of the design criteriato turbine missiles is described in SRP Section 10.2 and in subsequent safetyevaluations related to probabilities of turbine failures, turbineorientations, and surveillance requirements for turbine overspeed protectionsystems. In NUREG-1366, "Improvements to Technical SpecificationsSurveillance Requirements," the staff discusses the benefits, resultant costs,and the safety impact of performing turbine overspeed protectionsurveillances.Although the design basis accidents and transients include a variety of systemfailures and conditions which might result from turbine overspeed events andpotential missiles striking various plant systems and equipment, the systemfailures and plant conditions are much more likely to be caused by eventsother than turbine failures. In view of the low likelihood of turbinemissiles, assumptions related to the turbine overspeed protection system arenot part of an initial condition of a design basis accident or transient thateither assumes the failure of or presents a challenge to the integrity of afission product barrier. The turbine overspeed protection system is notrelied upon in the design basis accident or transient analyses as a primarysuccess path to mitigate such events.Probabilistic safety assessments and operating experience have demonstratedthat proper maintenance of the turbine overspeed control valves is importantto minimize the potential for overspeed events and turbine damage; howeverthat experience has also demonstrated that there is low likelihood ofsignificant risk to public health and safety because of turbine overspeedevents. Further, the potential for and consequences of turbine overspeedevents are diminished by factors such as the orientation of the turbinerelative to plant structures and equipment, licensee inservice testingprograms, which must comply with 10 CFR 50.55(a), and surveillance programsfor the turbine control and stop valves derived from the manufacturer'srecommendations.Accordingly, the staff has concluded that the turbine overspeed protectionsystem does not meet the 10 CFR 50.36 criteria and need not be included inTSs. Licensees may propose to relocate the turbine overspeed protectionrequirements to the UFSAR and control changes to those provisions inaccordance with 10 CFR 50.5 fAxachment 2GL 95-10December 10, 1995 LIST OF RECENTLY ISSUED GENERIC LETTERSGenericI tterDate ofIssuanceSubhictIssued To------95-0995-0888-20,Supp. 595-0795-06MONITORING AND TRAINING OFSHIPPERS AND CARRIERS OFRADIOACTIVE MATERIALS10 CFR 50.54(p) PROCESS FORCHANGES TO SECURITY PLANSWITHOUT PRIOR NRC APPROVALINDIVIDUAL PLANT EXAMINATIONOF EXTERNAL EVENTS FOR SEVEREACCIDENT VULNERABILITIESPRESSURE LOCKING AND THERMALBINDING OF SAFETY-RELATEDPOWER-OPERATED GATE VALVESCHANGES IN THE OPERATORLICENSING PROGRAMVOLTAGE-BASED REPAIR CRITERIAFOR WESTINGHOUSE STEAM GEN-ERATOR TUBES AFFECTED BY OUT-SIDE DIAMETER STRESS CORROSIONCRACKING11/03/9510/31/9509/08/9508/17/9508/15/9508/03/95ALL U.S. NRC LICENSEESALL HOLDERS OF OLs &CPs FOR NPRsALL HOLDERS OF OLs(EXCEPT THOSE LICENSESTHAT HAVE BEEN AMENDEDTO POSSESSION-ONLYSTATUS) OR CPs FOR NPRs.ALL HOLDERS OF OLs(EXCEPT THOSE LICENSESTHAT HAVE BEEN AMENDEDTO POSSESSION-ONLYSTATUS) OR CPs FOR NPRs.ALL HOLDERS OF OLs(EXCEPT THOSE LICENSESTHAT HAVE BEEN AMENDEDTO A POSSESSION ONLYSTATUS) OR CPs FORNPRs.ALL HOLDERS OF OLs ORCPs FOR PRESSURIZEDWATER REACTORS (PWRs).95-05OL -OPERATING LICENSECP = CONSTRUCTION PERMITNPR -NUCLEAR POWER REACTORS