[Federal Register Volume 60, Number 123 (Tuesday, June 27, 1995)]
[Notices]
[Pages 33239-33243]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-15677]



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NUCLEAR REGULATORY COMMISSION


Proposed Generic Communication; Relocation of Selected Technical 
Specifications Requirements Related to Instrumentation

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of opportunity for public comment.

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SUMMARY: The Nuclear Regulatory Commission (NRC) is proposing to issue 
a generic letter regarding the relocation of selected technical 
specifications requirements related to instrumentation. The NRC is 
seeking comment from interested parties regarding both the technical 
and regulatory aspects of the proposed generic letter presented under 
the Supplementary Information heading. This proposed generic letter and 
supporting documentation were endorsed for publication in the Federal 
Register by the Committee to Review Generic Requirements (CRGR) on June 
15, 1995. The relevant information that was sent to the CRGR to support 
their review of the proposed generic letter is available in the NRC 
Public Document Room under accession number 9506160308. The NRC will 
consider comments received from interested parties in the final 
evaluation of the proposed generic letter. The NRC's final evaluation 
will include a review of the technical position and, when appropriate, 
an analysis of the value/impact on licensees. Should this generic 
letter be issued by the NRC, it will become available for public 
inspection in the NRC Public Document Room.

DATES: Comment period expires July 27, 1995. Comments submitted after 
this date will be considered if it is practical to do so, but assurance 
of consideration cannot be given except for comments received on or 
before this date.

ADDRESSES: Submit written comments to Chief, Rules Review and 
Directives Branch, U.S. Nuclear Regulatory Commission, Washington, DC 
20555. Written comments may also be delivered to 11545 Rockville Pike, 
Rockville, Maryland, from 7:30 am to 4:15 pm, Federal workdays. Copies 
of written comments received may be examined at the NRC Public Document 
Room, 2120 L Street, NW. (Lower Level), Washington, DC.

FOR FURTHER INFORMATION CONTACT: William D. Reckley, (301) 415-1314. 
[[Page 33240]] 

SUPPLEMENTARY INFORMATION:

NRC Generic Letter 95-XX: Relocation of Selected Technical 
Specifications Requirements Related to Instrumentation

Addressees

    All holders of operating licenses or construction permits for 
nuclear power reactors except Crystal River, Grand Gulf, Clinton, and 
Hatch, Units 1 and 2.

Purpose

    The U.S. Nuclear Regulatory Commission (NRC) is issuing this 
generic letter to advise those licensees that have not converted or are 
not in the process of converting to the improved Standard Technical 
Specifications that they may request a license amendment to relocate 
selected instrumentation requirements from their Technical 
Specifications (TS).

Description of Circumstances

    This line-item TS improvement was developed in response to TS 
amendments proposed by licensees and ongoing NRC TS improvement 
programs. The intent of this generic letter is to reduce the time and 
costs spent by licensees and the NRC staff in amending requirements 
related to the selected instrumentation-related TS. Licensees will 
reduce cost by relocating requirements to a licensee-controlled 
document or program so that future changes to those requirements would 
not necessarily involve a license amendment. The time and cost of NRC 
staff review is reduced by the use of internal guidance for the review 
of generic letter-related amendments and the reduction in the number of 
plant-specific changes to the affected TS.

Discussion

    Section 182a of the Atomic Energy Act (the Act) requires applicants 
for nuclear power plant operating licenses to include TS 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 related to the content of TS. That regulation requires 
that the TS include items in five specific categories, including (1) 
safety limits, limiting safety system settings and limiting control 
settings; (2) limiting conditions for operation; (3) surveillance 
requirements; (4) design features; and (5) administrative controls. 
However, the regulation does not specify the particular requirements to 
be included in TS.
    The NRC developed criteria, as described in the ``Final Policy 
Statement on Technical Specifications Improvements for Nuclear Power 
Reactors'' (58 FR 39132), to determine which of the design conditions 
and associated surveillances should be located in the TS as limiting 
conditions for operation. The four criteria provided in the Final 
Policy Statement are:
    (1) Installed instrumentation that is used to detect, and indicate 
in the control room, a significant abnormal degradation of the reactor 
coolant pressure boundary;
    (2) a process variable, design feature, or operating restriction 
that is an initial condition of a Design Basis Accident or Transient 
analysis that either assumes the failure of or presents a challenge to 
the integrity of a fission product barrier;
    (3) a structure, system, or component that is part of the primary 
success path and which functions or actuates to mitigate a Design Basis 
Accident or Transient that either assumes the failure of or presents a 
challenge to the integrity of a fission product barrier;
    (4) a structure, system, or component which operating experience or 
probabilistic safety assessment has shown to be significant to public 
health and safety.
    The Commission recently promulgated a proposed change to 10 CFR 
50.36 pursuant to which the rule would be amended to codify and 
incorporate these criteria (see Proposed Rule, ``Technical 
Specifications,'' 59 FR 48180 (September 20, 1994)).
    The Commission's Final Policy Statement acknowledged that its 
implementation may cause some requirements presently in TS to be moved 
out of existing TS to documents and programs controlled by licensees. 
This generic letter addresses the relocation of selected TS 
requirements related to instrumentation as a result of the 
consideration of the final policy statement criteria. Upon review of 
typical TS for nuclear power reactors, the staff determined that, in 
accordance with the policy statement criteria, several specifications 
did not warrant inclusion in TS. The staff also concluded that the 
instrumentation addressed by these specifications are not related to 
dominant contributors to plant risk. The following typical TS are among 
the candidates for relocation to licensee-controlled documents:
     Incore Detectors (Movable Incore Detectors, Transversing 
Incore Probe).
     Seismic Monitoring Instrumentation.
     Meteorological Monitoring Instrumentation.
     Chlorine Detection System.
     Loose-Part Detection System.
     Explosive Gas Monitoring Instrumentation.
     Turbine Overspeed Protection.

Requested Information

    Licensees who voluntarily choose to use the guidance in this 
generic letter will need to submit license amendment requests in order 
to relocate the affected technical specifications. These licensees are 
encouraged to propose TS changes consistent with the guidance in 
Attachment 1 to this generic letter.
    Licensees who do not wish to amend technical specifications are not 
expected to submit any response to this generic letter.

Required Response

    Licensees who voluntarily choose to use the guidance in this 
generic letter are required to submit license amendment requests in 
order to relocate affected technical specification requirements.
    Licensee requests should be submitted to the U.S. Nuclear 
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 
20555, under the provisions of 10 CFR 50.90.

Backfit Discussion

    This generic letter only requests information under the provisions 
of 10 CFR 50.90 from addressees who voluntarily choose to use the 
contained guidance to seek an amendment of an operating license. Any 
action by licensees to propose TS changes in accordance with the 
guidance of this generic letter is voluntary and, therefore, not a 
backfit under 10 CFR 50.109. Therefore, the staff has not performed a 
backfit analysis.

Attachment 1--Guidance for a Proposed License Amendment to Relocate 
Selected Technical Specifications Requirements Related to 
Instrumentation

Introduction

    The NRC is issuing the following guidance for preparing a proposed 
license amendment to relocate from Technical Specifications (TS) 
selected requirements related to instrumentation. As discussed in the 
Final Policy Statement, licensees submitting amendment requests should 
identify the location of and controls for the relocated requirements. 
It is expected that most of the TS addressed by this generic letter 
will be relocated to the Updated Final Safety Analysis Report (UFSAR) 
and changes to those provisions will be performed in accordance with 10 
CFR 50.59, ``Changes, tests and experiments.'' If requirements are 
relocated to other documents (e.g., the emergency plan), controls may 
be [[Page 33241]] provided by regulatory requirements such as 10 CFR 
50.54, ``Conditions of licenses.'' The adequacy of controls for 
relocated provisions which do not fit in the above categories will be 
reviewed and approved by the NRC staff on a case-by-case basis.
    License amendment requests should contain a commitment to relocate 
each selected requirement to a particular licensee-controlled document 
or program, (e.g., the UFSAR or the emergency plan). The commitment 
should also address the submittal of the revised documents to the NRC 
in accordance with the applicable regulation (e.g., 10 CFR 50.71(e)). 
In the amendment request, the licensee should clearly describe the 
program it will use to control changes to relocated provisions (e.g., 
10 CFR 50.59 or 50.54(q)). Control of the relocated provisions in 
accordance with the applicable regulation ensures that NRC review and 
approval will be requested for changes exceeding the stated regulatory 
threshold (e.g., unreviewed safety question or decrease in 
effectiveness).
    Licensees should note that this generic letter supersedes TS-
related guidance contained in several previously issued NRC documents, 
such as regulatory guides and the Standard Review Plan (NUREG-0800). 
Commitments contained in the UFSAR or other docketed correspondence may 
need to be revised to reflect the deviations from these NRC documents. 
However, this generic letter addresses only the need to include 
requirements related to the affected systems in TS. Staff positions on 
matters other than TS content that are contained in the regulatory 
guides or other documents are not affected by the issuance of this 
generic letter.
    The NRC has approved the relocation of most of these specific 
instrumentation requirements in various amendments issued to specific 
licensees. The improved standard TS also reflect the staff position 
that these requirements do not satisfy the final policy statement 
criteria for inclusion in TS. The staff has also concluded that these 
provisions are not related to dominant contributors to plant risk. 
Additional discussions follow for each of the selected relocated 
instrumentation requirements.

Incore Detectors

    The relocation of requirements related to incore neutron detectors 
affects the TS sections entitled ``Incore Detectors'' or ``Movable 
Incore Detectors,'' for pressurized water reactors (PWRs), or 
``Transversing Incore Probe,'' for boiling water reactors (BWRs). 
Incore instrumentation is used periodically to calculate power peaking 
factors in order to verify nuclear design predictions, ensure operation 
within established fuel performance limits, and to calibrate other 
nuclear instrumentation. The measurements are used in a confirmatory 
manner and do not provide direct input to reactor protection system or 
engineered safety features actuation system functions.
    These instruments are neither used for, nor capable of, detecting a 
significant abnormal degradation of the reactor coolant pressure 
boundary prior to a design basis accident nor do they function as a 
primary success path to mitigate events which assume the failure of or 
challenge the integrity of fission product barriers. Although the core 
power distributions (measured by the incore detectors) constitute an 
important initial condition to design basis accidents and therefore 
need to be addressed by TS, the detectors themselves are not an active 
design feature needed to preclude analyzed accidents or transients. The 
staff has determined therefore, that the incore detector requirements 
do not satisfy the criteria of the Final Policy Statement for inclusion 
in TS. Licensees may propose to relocate the incore detector 
requirements to the UFSAR and control changes to those provisions in 
accordance with 10 CFR 50.59.
    Relocation of the incore detector requirements from the TS to the 
UFSAR does not imply any reduction in their importance in confirming 
that core power distributions are bounded by safety analysis limits. It 
is expected that licensees will continue to maximize the number of 
available incore detectors. Evaluations related to changes in incore 
detector requirements are expected to consider such factors as the need 
to identify the inadvertent loading of a fuel assembly into an improper 
location, the calibration of protection systems using incore 
measurements, and the allowances for measurement and nuclear design 
uncertainties. Should these or other considerations lead to the 
identification of a proposed change as an unreviewed safety question, 
the licensee should request NRC review and approval in accordance with 
10 CFR 50.59(c).

Seismic Monitoring Instrumentation

    Section VI(a)(3) of Appendix A to 10 CFR Part 100 requires that 
seismic monitoring instrumentation be provided to promptly determine 
the response of those nuclear power plant features important to safety 
in the event of an earthquake. This capability is required to allow for 
a comparison of the measured response to that used in the design basis 
for the unit. Comparison of such data is needed to (1) determine 
whether the plant can continue to be operated safely, and (2) permit 
such timely action as may be appropriate. However, seismic 
instrumentation does not actuate any protective equipment or serve any 
direct role in the mitigation of an accident.
    The capability of the plant to withstand a seismic event or other 
design-basis accident is determined by the initial design and 
construction of systems, structures, and components. The 
instrumentation is used to alert operators to the seismic event and 
evaluate the plant response. The Final Policy Statement explained that 
instrumentation to detect precursors to reactor coolant pressure 
boundary leakage, such as seismic instrumentation, is not included in 
the first criterion. As discussed above, the seismic instrumentation 
does not serve as a protective design feature or part of a primary 
success path for events which challenge fission product barriers. The 
staff has concluded that the seismic monitoring instrumentation does 
not satisfy the final policy statement criteria and need not be 
included in the TS. Licensees may propose to relocate the seismic 
monitoring instrumentation requirements to the UFSAR and control 
changes to those provisions in accordance with 10 CFR 50.59.

Meteorological Monitoring Instrumentation

    In 10 CFR 50.47, ``Emergency Plans,'' and 10 CFR Part 50, Appendix 
E, ``Emergency Planning and Preparedness for Production and Utilization 
Facilities,'' the Commission requires power plant licensees to provide 
reasonable assurance that adequate protective measures can and will be 
taken in the event of a radiological emergency. Timely access to 
accurate local meteorological data is important for estimating 
potential radiation doses to the public and for determining appropriate 
protective measures. In 10 CFR 50.36a(a)(2), the Commission requires 
nuclear power plant licensees to submit annual reports specifying the 
quantity of each of the principal radionuclides released to 
unrestricted areas in liquid and airborne effluents and such other 
information as may be required by the NRC to estimate maximum potential 
annual radiation doses to the public. A knowledge of meteorological 
conditions in the vicinity of the reactor is important in providing a 
basis for estimating annual radiation doses resulting from 
[[Page 33242]] radioactive materials released in airborne effluents. 
Accordingly, the meteorological monitoring instrumentation serves a 
useful function in estimating radiation doses to the public from either 
routine or accidental releases of radioactive materials to the 
atmosphere.
    The meteorological monitoring instrumentation does not serve such a 
primary protective function as to warrant inclusion in the TS in 
accordance with the criteria of the final policy statement. The 
instrumentation does not serve to ensure that the plant is operated 
within the bounds of initial conditions assumed in design basis 
accident and transient analyses or that the plant will be operated to 
preclude transients or accidents. Likewise, the meteorological 
instrumentation does not serve as part of the primary success path of a 
safety sequence analysis used to demonstrate that the consequences of 
these events are within the appropriate acceptance criteria. 
Accordingly, the staff has concluded that the meteorological 
instrumentation does not satisfy the final policy statement criteria 
and need not be included in TS. The staff has determined that 
requirements related to the meteorological monitoring instrumentation 
can be moved from the TS to the UFSAR, and that any subsequent changes 
to the provisions would be controlled pursuant to 10 CFR 50.59. 
Licensees may alternately choose to relocate the meteorological 
monitoring instrumentation requirements from the TS to the facility's 
emergency plan. In this case, subsequent changes would be made in 
accordance with 10 CFR 50.54(q).

Chlorine Detection System

    Chlorine detection systems ensure that sufficient capability is 
available to promptly detect and initiate protective action to isolate 
the control room in the event of an accidental chlorine release. Some 
plants may also have systems to detect other toxic gases which have the 
potential to hamper plant operation in the case of their accidental 
release from onsite or offsite sources. The relocation of TS related to 
other toxic gas detection systems is included in this discussion for 
the typical chlorine detection systems. Staff positions regarding the 
relationship of the chlorine detection systems to the general design 
criteria (GDC) appear in NUREG-0800, ``Standard Review Plan'' (SRP); 
Regulatory Guide (RG) 1.78, ``Assumptions for Evaluating the 
Habitability of a Nuclear Power Plant Control Room During a Postulated 
Hazardous Chemical Release''; and RG 1.95, ``Protection of Nuclear 
Power Plant Control Room Operators Against an Accidental Chlorine 
Release.''
    As discussed above, chlorine detection systems may serve an 
important role in the protection of control room personnel from 
internal or external hazards related to toxic gases. However, the 
release of chlorine or other hazardous chemicals is not part of an 
initial condition of a design basis accident or transient analysis that 
assumes a failure of or presents a challenge to the integrity of a 
fission product barrier. Since the release of toxic gases is not 
assumed to initiate or occur simultaneously with design basis accidents 
or transients involving challenges to fission product barriers, the 
chlorine detection system is not part of a success path for the 
mitigation of those accidents or transients. The staff has, therefore, 
concluded that requirements for this system do not satisfy the final 
policy statement criteria and need not be included in TS. Licensees may 
propose to relocate the chlorine detection system requirements to the 
UFSAR and control changes to those provisions in accordance with 10 CFR 
50.59.

Loose-Part Detection System

    The loose-part detection system identifies the existence of 
possible loose parts in the reactor coolant system. Early detection can 
provide operators time to take corrective actions and avoid or mitigate 
damage to or malfunctions of primary system components. However, as 
discussed in the final policy statement, the loose-part detection 
system does not function to detect significant abnormal degradation of 
the reactor coolant pressure boundary. The loose-part detection system 
does not serve as an active design feature for establishing initial 
conditions or mitigation of design basis accidents or transients. The 
staff has concluded that requirements for this system do not satisfy 
the final policy statement criteria and need not be included in TS.
    Licensees may propose to relocate the requirements related to the 
loose-part detection system from the TS to the UFSAR and control 
changes to those provisions in accordance with 10 CFR 50.59.

Explosive Gas Monitoring Instrumentation

    The relocation of most of the instrumentation related to 
radioactive gaseous effluent monitoring was addressed in Generic Letter 
89-01, ``Implementation of Programmatic Controls for Radiological 
Effluent Technical Specifications [RETS] in the Administrative Controls 
Section of the Technical Specifications and the Relocation of 
Procedural Details of RETS to the Offsite Dose Calculation Manual or 
the Process Control Program.'' Relocation of the requirements for 
explosive gas monitoring instrumentation was not addressed in the 
guidance provided by Generic Letter 89-01. Staff positions regarding 
the monitoring of explosive gases within the radioactive waste 
management systems are 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 TS typically require alternate 
sampling, limited operation of the gaseous waste system, and submittal 
of a special report if the explosive gas monitoring instrumentation 
does not conform to the limiting condition for operation. The explosive 
gas monitoring instrumentation requirements address detection of 
possible precursors to the failure of a waste gas system but do not 
prevent or mitigate design basis accidents or transients which assume a 
failure of or present a challenge to a fission product barrier. 
Acceptable concentrations of explosive gases are actually controlled by 
other limiting conditions for operation (e.g., Gaseous Effluents, 
Explosive Gas Mixture) or by programs described in the ``Administrative 
Controls'' section of TS. The requirements related to explosive gas 
monitoring instrumentation do not conform to the final policy statement 
criteria for inclusion in the TS. Therefore, licensees may propose to 
relocate the explosive gas monitoring instrumentation requirements to 
the UFSAR and control changes to those provisions in accordance with 10 
CFR 50.59.

Turbine Overspeed Protection

    Existing TS typically include limiting conditions for operation and 
surveillance requirements for the turbine overspeed protection system. 
The turbine is equipped with control valves and stop valves which 
control turbine speed during normal plant operation and protect it from 
overspeed during abnormal conditions. The turbine overspeed protection 
system consists of separate mechanical and electrical sensing 
mechanisms which are capable of initiating fast closure of the control 
and stop valves. Current TS may require particular operability and 
surveillance requirements for these steam control and stop valves to 
minimize the potential for fragment missiles that might be generated as 
the result of a turbine overspeed event. [[Page 33243]] General Design 
Criterion 4 of Appendix A to 10 CFR Part 50 requires that structures, 
systems, and components important to safety be appropriately protected 
from the effects of missiles that may result from equipment failures. 
Application of the design criteria to turbine missiles is described in 
SRP Section 10.2 and in subsequent safety evaluations related to 
probabilities of turbine failures, turbine orientations, and 
surveillance requirements for turbine overspeed protection systems. In 
NUREG-1366, ``Improvements to Technical Specifications Surveillance 
Requirements,'' the staff discusses the benefits, resultant costs, and 
the safety impact of performing turbine overspeed protection 
surveillances.
    Although the design basis accidents and transients include a 
variety of system failures and conditions which might result from 
turbine overspeed events and potential missiles striking various plant 
systems and equipment, the system failures and plant conditions are 
much more likely to be caused by events other than turbine failures. In 
view of the low likelihood of turbine missiles, assumptions related to 
the turbine overspeed protection system are not part of an initial 
condition of a design basis accident or transient that either assumes 
the failure of or presents a challenge to the integrity of a fission 
product barrier. The turbine overspeed protection system is not relied 
upon in the design basis accident or transient analyses as a primary 
success path which functions or actuates to mitigate such events.
    Probabilistic safety assessments and operating experience have 
demonstrated that proper maintenance of the turbine overspeed control 
valves is important to minimize the potential for overspeed events and 
turbine damage; however that experience has also demonstrated that 
there is low likelihood of significant risk to public health and safety 
because of turbine overspeed events. Further, the potential for and 
consequences of turbine overspeed events are diminished by factors such 
as the orientation of the turbine relative to plant structures and 
equipment, licensee inservice testing programs, which must comply with 
10 CFR 50.55(a), and surveillance programs for the turbine control and 
stop valves derived from the manufacturer's recommendations.
    Accordingly, the staff has concluded that the turbine overspeed 
protection system does not satisfy the final policy statement criteria 
and need not be included in TS. Licensees may propose to relocate the 
turbine overspeed protection requirements to the UFSAF requirements to 
the UFSAR and control changes to those provisions in accordance with 10 
CFR 50.59.

    Dated at Rockville, Maryland, this 20th day of June 1995.

Brian K. Grimes,
Director, Division of Project Support, Office of Nuclear Reactor 
Regulation.
[FR Doc. 95-15677 Filed 6-26-95; 8:45 am]
BILLING CODE 7590-01-P