Information Notice 1997-80, Licensee Technical Specifications Interpretations

Licensee Technical Specifications Interpretations

ML031050052
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date:	11/21/1997
From:	Roe J Office of Nuclear Reactor Regulation
To:
References
IN-97-080, NUDOCS 9711180029
Download: ML031050052 (8)

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001

November 21, 1997

NRC INFORMATION NOTICE 97-80: LICENSEE TECHNICAL SPECIFICATIONS

Addressees

All holders of operating licenses for nuclear power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is Issuing this information notice to alert

addressees to problems identified with licensee technical specifications (TS) interpretations.

For the purpose of this information notice, a licensee TS interpretation" is written guidance

developed by a licensee for use by the licensee's staff. NRC does not review or concur in

licensee TS interpretations. It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances

Many licensees have established TS interpretations to help their plant staff understand and

correctly implement TS requirements. Recent NRC reviews found that approximately

80 percent of reactor power plant licensees have TS interpretations. However, these reviews

identified questionable interpretations of TS requirements and statements that implied NRC

concurrences in the interpretation.

The following examples of inappropriate licensee TS interpretation were noted:

1.

A TS interpretation allowed the plant to operate at full power when only one 345-kilovolt

transmission line was capable of supplying offsite power to the plant. This conflicted

with the TS basis, which discussed reducing power to 50 percent when only one 345- kilovolt line was available.

2.

A TS interpretation for a pressurizer power-operated relief valve (PORV) did not require

the PORV to be declared inoperable If the control switch in the control room was placed

in the closed position. This was contrary to the TS and the NRC safety evaluation for a

TS amendment implementing the licensee's response to Generic Letter 90-06,

"Resolution of Generic Issue 70, 'Power-Operated Relief Valve and Block Valve

9711`189

08 -n llt

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IN 97-80

November21, 1997 Reliability,' and Generic Issue 94, 'Additional Low-Temperature Overpressure Protection

for Light-Water Reactors,' Pursuant to Section 50.54(f) to Part 50 of Title 10 of the Cod

of Federal Regulations [10 CFR 50.54(f)]."

3.

A TS interpretation related to annual auto-start testing of the emergency diesel

generator (EDG) specified that only the breakers for the equipment loads need to

operate in the correct sequence and at the correct time. Consequently some of the

larger EDG loads were not started and sequenced onto the bus during the annual test

and the EDG's ability to handle in-rush currents and the acceleration times of large

motors was not demonstrated.

4.

A TS interpretation allowed the EDG fuel oil transfer system to be out of service for a

predetermined time period without requiring the EDG to be declared inoperable. This

was contrary to the TS operability definition for auxiliary equipment and related support

functions.

5.

Numerous examples were found of TS interpretations referencing discussions between

the licensee and an NRC inspector or project manager. In one instance, an NRC

inspector's signature was on a TS interpretation, giving the appearance that the NRC

had approved the interpretation.

Discussion

Licensee TS interpretations can enhance the safe operation of the plant by helping the plant

staff understand and correctly implement TS requirements. However, licensees must exercise

caution to ensure TS interpretations do not change the wording, the meaning, or the intent of

TS requirements. Since the NRC does not endorse or approve particular TS interpretations, there should be no reference to NRC involvement in the TS interpretation. An exception is

referencing official NRC correspondence in the TS interpretation. This is an acceptable

practice.

Licensees should be aware that there are several NRC recognized methods for resolving TS

questions or clarifying TS requirements. Licensees are encouraged to pursue one of these

methods when they have a question concerning TS compliance and want the NRC to formally

recognize their position. The methods include (1) amending the license to change the TS

wording; (2) revising the TS bases via 10 CFR 50.59 or 50.90 (when an unreviewed safety

question is identified) to clarify the TS requirement; or (3) formally requesting a written

interpretation from the Office of Nuclear Reactor Regulation (NRR) regarding the intent of the

TS requirement (for clarity these are referred to as "NRC-approved TS interpretations)."

NRC inspectors routinely review applicable TS interpretations when verifying that plant

operations are in compliance with TS requirements. The inspection staff has been given

guidance to never concur or become involved in the approval process for licensee TS

interpretations. Licensees should not infer from an inspector having reviewed and not

questioned a TS interpretation that the inspector has approved the interpretation.

IN 97-80

November 21, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contact listed below

or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

.

ai k W. Roe, Acting Director

bision of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Ronald Frahm, Jr., NRR

301-415-2986 E-mail: rkf~nrc.gov

Attachment: List of Recently Issued NRC Information Notices

'\\Attachment

IN 97-80

November 21, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information

Date of

Notice No.

Subject

Issuance

Issued to

97-79

97-78

97-77

Potential Inconsistency

in the Assessment of

the Radiological Conse- quences of a Main Steam

Line Break Associated

with the Implementation

of Steam Generator Tube

Voltage-Based Repair

Criteria

Crediting of Operator

Actions in Place of

Automatic Actions and

Modifications of Operator

Actions, Including Response

Times

Exemptions from the

Requirements of

Section 70.24 of

Title 10 of the C

of Federal Regulations

11/20/97

10/23/97

10/10/97

All holders of OLs for

pressurized-water reactors

implementing a steam

generator tube voltage- based repair criteria in

accordance with the

guidance presented in

Generic Letter 95-05,

'Voltage-Based Repair

Criteria for Westinghouse

Steam Generator Tubes

Affected by Outside

Diameter Stress Corrosion

Cracking," issued August 3,

1995

All holders of OLs for

nuclear power reactors

except those who have

permanently ceased

operations and have

certified that fuel has

been permanently removed

from the reactor vessel

All holders of OLs for

nuclear power reactors

OL = Operating License

CP = Construction Permit

K;>S

IN 97-80

November21, 1997 This information notice requires no specific action or written response. If you have any

questions about the information In this notice, please contact the technical contact listed below

or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

original signed by

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Ronald Frahm, Jr., NRR

301-415-2986 E-mail: rkf@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

• See previous concurrence

DlOCUMFNT NAME: 97-80.IN

.

OFC

TECH EDITOR

PECB:DRPM

PIPB:DISP

SUPIPB:DISP

NAME

P. Kleene*

T. Greene*

R. Haag*

C. Holden*

DATE

08/02/97

11/05/97

08/22/97

11/05/97 OFC

C/PIPB:DISP

C/TSB:ADPR

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SUPECB:DRPM

NAME

R. Borchardt*

W. Beckner*

F. Gillespie*

R. Dennlg*

DATE

10/21/97

08/28/97

08/25/97

11/10/97 OFC

C/PECB:DRPM

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S. Richards*

J.RI

DATE

11/13/97 II/It - / 97

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[OFFICIAL RECUKU CUC)YJ

IN 97-XX

November XX, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contact listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Ronald Frahm, Jr., NRR

301-415-2986 E-mail: rkfenrc.gov

Attachment: List of Recently Issued NRC Information Notices

• See previous concurrence

DOCUMENT NAME: G:\\TAG:INTECSP

OFC

TECH EDITOR

PECB:DRPM

PIPB:DISP

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NAME

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T. Greene*

R. Haag*

C. Holden*

DATE

08/02/97

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08/22/97

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DATE

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November XX, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contact listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Ronald Frahm, Jr., NRR

(301) 415-2986 E-mail: rkflnrc.gov

Attachment: List of Recently Issued NRC Information Notices

• See previous concurrence

DOCUMENT NAME: G:%TAG:INTECSP

OFC

TECH EDITOR

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PIPB:DISP

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NAME

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T. Greene*

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September XX, 1997

Page 4 of X

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact the technical contact listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Robert C. Haag, NRR

(301) 415-1245 E-mail: rch@ nrc.gov

Attachment: List of Recently Issued NRC Information Notices

OFC

TECH EDITOR

PECB:DRPM

PIPB:DISP

SUPIPB:DISP

NAME

P. Kleene*

T. Greene&>

R. Haag

Cx. Holden

DATE

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[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:ITAG:INTECSP