Efficient Adoption of Improved Standard Technical Specifications

                                 UNITED STATES
                         NUCLEAR REGULATORY COMMISSION
                     OFFICE OF NUCLEAR REACTOR REGULATION
                         WASHINGTON, D.C.  20555-0001

                                October 9, 1996


NRC ADMINISTRATIVE LETTER 96-04:  EFFICIENT ADOPTION OF IMPROVED              
                          STANDARD TECHNICAL SPECIFICATIONS


Addressees

All holders of operating licenses for nuclear power reactors who have not converted to the
improved standard technical specifications (STS).

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this administrative letter to
inform addressees of (1) efficient means to adopt the improved STS and (2) staff practices
for the review of applications for license amendments to convert to the improved STS. 
This administrative letter does not transmit or imply any new or changed requirements or
staff positions.  No specific action or written response is required.

Background

In 1992, the NRC issued the improved STS to more clearly define the content and form of
requirements necessary to ensure safe operation of nuclear power plants in accordance
with Title 10, Code of Federal Regulations (10 CFR) Section 50.36.  In its Final Policy
Statement on Technical Specifications Improvements for Nuclear Power Reactors, issued
on July 22, 1993 (58 FR 39132), the Commission placed the highest priority on license
amendment applications to convert the technical specifications to the improved STS.  For
the reasons described in the policy statement, the NRC continues to believe that total
adoption of the improved STS will substantially improve the efficiency of the regulatory
process, and ensure that licensee and NRC resources are applied to significant safety
matters.

Discussion

The major objective of converting from plant-specific technical specifications to the
improved STS is to achieve as much consistency in the license requirements as possible,
to the extent that the plant-specific design basis can conform with the related typical plant
design reflected in the improved STS.  To ensure efficient and timely staff review of
conversions to the improved STS, the associated license amendment applications must
clearly identify in the forwarding letter those changes to the technical specifications that
are not directly related to the conversion amendment.  These "beyond scope" issues,
which are generally characterized as changes that differ from both the existing technical
specifications and the improved STS, tend to unnecessarily complicate and delay the
conversion review process.  


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                                                            October 9, 1996
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Although it may be more efficient to incorporate pending or planned changes to the design
basis in the conversion application, subsequent delays in the technical review for those
parts can interfere with the timely and efficient review of the conversion.  Consequently,
applications for conversion to the improved STS should include proposed technical
specifications with and without the changes to the design basis so that "beyond scope"
changes may be separated if the completion of the review for those changes would affect
timely completion of the conversion amendment.

In a related matter, the conversion reviews have occasionally been hampered by questions
concerning the applicability of appropriate controls for requirements moved from the
technical specifications to licensee-controlled documents.  Although parts of the existing
technical specifications can be moved to the Quality Assurance Program, or to similar
licensee-controlled documents for which there is an applicable regulatory process for
future changes, most of the relocated requirements are placed in the final safety analysis
report (FSAR) so that future changes can be made in accordance with 10 CFR 50.59. 
Some licensees have attempted to incorporate those requirements into plant procedures,
rather than into the FSAR, by committing to apply .50.59 to future changes.  The staff
believes that for consistency and clarity, licensees should incorporate the details of the
relocated technical specification requirements for which .50.59 is needed to control future
changes, directly in the FSAR or in the Bases for the improved standard technical
specifications.

An acceptable approach that several licensees have used is to incorporate the details of
the relocated technical specification requirements into a manual, and then reference the
manual in the FSAR.  On the basis of industry experience, the Nuclear Energy Institute
(NEI) recently issued NEI 96-06, "Improved Technical Specifications Conversion
Guidance."  This guide was prepared by the NEI Technical Specifications Task Force; it
contains useful information that may improve the efficiency of the license amendment
process for improved STS conversions and describes the role of the task force in managing
generic changes to the improved STS.

These practices will ensure efficient and timely completion of applications to convert to
the improved STS, and more effective use of NRC and licensee resources.

.                                                            AL 96-04
                                                            October 9, 1996
                                                            Page 3 of 3


This administrative letter requires no specific action or written response.  If you have any
questions about this letter, please contact the person listed below or your appropriate NRR
project manager.


                                          signed by A.E. Chaffee

                                    Thomas T. Martin, Director
                                    Division of Reactor Program Management
                                    Office of Nuclear Reactor Regulation

Contact:  C. I. Grimes, NRR
          (301) 415-1161
          E-mail:  cig@nrc.gov