Relocation of Technical Specification Administrative Controls Related to Quality Assurance

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

                               December 12, 1995


NRC ADMINISTRATIVE LETTER 95-06:  RELOCATION OF TECHNICAL SPECIFICATION 
                                  ADMINISTRATIVE CONTROLS RELATED TO QUALITY   
                                  ASSURANCE


Addressees


All holders of operating licenses or construction permits for nuclear power
reactors.


Purpose


The U.S. Nuclear Regulatory Commission (NRC) is issuing this administrative
letter to inform licensees about recent experiences involving the relocation
of technical specification administrative controls related to quality
assurance.  Any license amendment request related to the content of this
Administrative Letter is voluntary.  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


Among U.S. Nuclear Regulatory Commission efforts related to technical
specification improvements are the issuance of a revision to 10 CFR 50.36,
revisions to the Standard Technical Specifications, some generic
communications, and many individual license amendments.  The revision of 
10 CFR 50.36 included specific criteria for determining those design
conditions that warrant inclusion in technical specifications as limiting
conditions for operation.  The staff has reviewed and approved many recent
amendment requests that involved incorporating parts of the improved Standard
Technical Specifications, relocating requirements that do not satisfy the
criteria of 10 CFR 50.36 for inclusion as limiting conditions for operation,
and relocating requirements that are controlled directly by regulations and
related licensee programs.  The relocation of technical specification
requirements has included administrative controls as well as limiting
conditions for operations and related surveillance requirements.


Increasingly, licensees are requesting amendments to technical specifications
that are located in the "administrative controls" section and are related to
quality assurance programs.  Licensees have frequently requested amendments to
these specifications because they contain detailed information that is
affected by organizational and process changes.  Many licensees have revised
their technical specifications to remove excessive detail, thereby gaining
flexibility in making organizational changes without the need for a license
amendment.  Recent amendment requests related to quality assurance have also
followed the trend for other technical specifications and have included

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moving requirements to licensee controlled documents and programs.  The
quality assurance program is a logical candidate for such relocations due to
the controls imposed by such regulations as Appendix B to 10 CFR Part 50, the
existence of U.S. Nuclear Regulatory Commission-approved quality assurance
plans and commitments to industry quality assurance standards, and the
established quality assurance program change control process in 10 CFR
50.54(a).  The relocation of technical specification requirements in cases
where adequate controls are provided by such other methods can reduce the
resources spent by licensees and the U.S. Nuclear Regulatory Commission staff
in preparing and reviewing license amendment requests.   

Discussion

The staff has reviewed the content of typical technical specification
administrative controls related to quality assurance requirements, for those
plants that have not converted to the improved Standard Technical
Specifications, and compared them to established staff positions and recent
amendment requests.  On the basis of this review, the staff offers the
following observations (which do not go beyond established staff positions) in
order to assist those licensees considering amendment requests related to
quality assurance requirements:

Independent Safety Engineering Group
      
The existing technical specification requirements related to an independent
safety engineering group function may be relocated.  The review of any license
amendments related to the relocation of the independent safety engineering
group function can be facilitated by licensee references to an existing
quality assurance plan commitment or the simultaneous submittal of a revision
of the quality assurance plan which incorporates the independent safety
engineering group functions.  As a minimum, the quality assurance plan should
contain a commitment related to the functions of the independent safety
engineering group organization to a level of detail comparable to that
previously contained in the technical specifications.  The review process
becomes simpler if the existing independent safety engineering group
requirements presently in the technical specifications are relocated intact to
the quality assurance plan.  Any subsequent changes to the independent safety
engineering group provisions incorporated into the quality assurance plan
would be controlled in accordance with 10 CFR 50.54(a).  

Reviews and Audits 

The technical specification requirements related to review and audit
requirements may be relocated to the quality assurance plan.  The review of
any license amendments related to the relocation of the review and audit
functions can be facilitated by licensee references to an existing quality
assurance plan commitment or the simultaneous submittal of a revision to the
quality assurance plan including the relocated requirements.  Commitments may
be incorporated into the quality assurance plan by relocating the existing
technical specifications intact or by capturing existing structural and
administrative requirements by a description of the review and audit.                                                            AL 95-06
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organizations and referencing appropriate industry quality assurance standards
such as American National Standards Institute standard N18.7, "Administrative
Controls and Quality Assurance for the Operational Phase of Nuclear Power
Plants," that explicitly duplicate current technical specification provisions. 
Subsequent changes to the relocated requirements would be controlled in
accordance with 10 CFR 50.54(a).

The commitments incorporated into the quality assurance plan may revise
existing technical specification audit frequencies by implementation of a
performance-based schedule (schedule adjusted according to objective
evaluation of plant functional area performance) provided that the maximum
audit interval does not exceed the 2-year interval specified in ANSI N18.7. 
Exceptions to the allowable use of performance-based audit frequencies are:
(1) those audit intervals defined by regulations, such as for emergency and
security plans, and (2) triennial audits of fire protection plans, conducted
by outside qualified fire consultants, which should be maintained in
accordance with current technical specification requirements.  In addition to
changing existing "annual" fire protection audits to a "maximum interval of 
24 months," if justified by performance reviews, ongoing U.S. Nuclear
Regulatory Commission and industry initiatives may lead to additional changes
in the audit practices related to fire protection.  In the interim, however,
triennial audits conducted by outside qualified fire consultants are being
maintained in accordance with the staff positions expressed at various
meetings and in correspondence.  

Procedure Review Process

Existing technical specifications typically contain requirements for the
processes related to the review and approval of procedures and changes to
procedures.  These requirements may be relocated to the quality assurance
plan.  The review of license amendments related to the relocation of the
procedure review processes can be facilitated by licensee references to an
existing quality assurance plan commitment or the simultaneous submittal of a
revision of the quality assurance plan including a commitment related to the
relocated technical specification requirements.  As a minimum, the quality
assurance plan should contain a commitment to process procedures and procedure
changes in accordance with an accepted standard such as ANSI N18.7.  Site-
specific aspects currently in technical specifications, that do not duplicate
ANSI N18.7 provisions, should be relocated to the quality assurance plan. 
Relocation of the technical specification requirements in this manner,
basically relocating them intact to the quality assurance plan, simplifies the
U.S. Nuclear Regulatory Commission license amendment review.  Any subsequent
changes to these provisions would be controlled in accordance with 10 CFR
50.54(a).   

Records and Record Retention

Technical specification administrative controls typically contain record
requirements for particular specifications (such as independent safety
engineering group and review and audit functions), as well as a section on
general requirements for record retention.  These sections may be removed from
the technical specifications and placed in the quality assurance plan.  The
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review of any license amendments related to the relocation of requirements
related to records or record retention can be facilitated by licensee
references to an existing quality assurance plan commitment or by the
simultaneous submittal of a revision of the quality assurance plan that 
incorporates the relocated technical specification requirements.  As mentioned
above, the review process is less complicated if the requirements are moved
intact to the quality assurance plan.  For those current technical
specification requirements that are explicitly duplicated in accepted industry
standards, reference to those standards is sufficient.  Any subsequent changes
to these provisions would be controlled in accordance with 10 CFR 50.54(a).  

Other Changes

The current 10 CFR 50.54(a) change control process requires prior U.S. Nuclear
Regulatory Commission review and approval of reductions in commitments
contained in the quality assurance plan.  In response to a recent petition for
rulemaking, the staff is evaluating the 10 CFR 50.54(a) threshold at which
U.S. Nuclear Regulatory Commission approval of quality assurance plan changes
is required.  In addition to the 50.54(a) petition, licensees and the U.S.
Nuclear Regulatory Commission staff have recently discussed proposed changes
to quality assurance provisions that go beyond those discussed in this
administrative letter.  Although such proposed changes may ultimately be found
to be acceptable, this administrative letter is limited to existing staff
positions and lessons learned related to the relocation of technical
specification requirements.

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 the appropriate Office of Nuclear Reactor Regulation project manager.

                                    /s/'d by DMCrutchfield


                                    Dennis M. Crutchfield, Director
                                    Division of Reactor Program Management
                                    Office of Nuclear Reactor Regulation      

Contact:  William Reckley, NRR
          (301) 415-1314