ML090640443
| ML090640443 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/01/2005 |
| From: | - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| Marrero, Abe, NRR/DIRS, 415-8531 | |
| Shared Package | |
| ML090690151 | List: |
| References | |
| Download: ML090640443 (9) | |
Text
Enclosure 9 Case Study 5: Palisades use of LCO 3.0.4 Meeting Summary of the January 27 & 28 Meeting with NRC/TSTF Dated March 9, 2009
Case Study 5: Palisades use of LCO 3.0.4 In the letter "Response to NRC Memorandum, Task Interface Agreement (TIA) 2008-002,
'Evaluation of Implementation of Limiting Condition For Operation (LCO) 3.0.4.a, 'MODE Change Limitations,' at Palisades Nuclear Plant," dated May 9, 2008 (ADAMS Accession Number ML081300096), the NRC issued a response to a Task Interface Agreement (TIA) request documenting the -Staff position regarding the application of Technical Specification LCO 3.0.4. This TIA was issued as a result of inspection activities conducted at Palisades Nuclear Plant during the first quarter of 2008. The inspection report included a non-cited violation of Technical Specification (TS) 5.4.1 for the failure to have adequate procedure guidance for the general operating procedures for Mode transition to power operations. The NRC stated that the general plant operating procedure for Mode transition did not have adequate guidance to ensure the actions required by TS LCO 3.0.4 were complete prior to Mode transition.
This NRC Staff guidance was issued due to an incident which occurred at Palisades Nuclear Plant when a radiation instrument was inoperable and the related TS ACTIONS allowed the instrument to be inoperable indefinitely provided the instrument was placed in the tripped condition within 7 days. It is noted that adequate protection is afforded by placing this instrument channel in trip within 7 days for an inoperability occurring at 100% rated thermal power, which is the limiting case for the transients and accidents (LOCA and rod ejection) that are mitigated by these radiation detectors (the mitigation actions include transitioning to the Control Room HVAC Emergency Mode, Containment Isolation Valve closure, and blocking automatic starts of the ECCS pump room sump pumps). Therefore, adequate protection would also be maintained following a Mode transition into this LCO's Applicability with an action to trip the instrument channel within 7 days after entering the LCO Applicability.
The NRC's stated position in the response to TIA 2008-002, was "...LCO 3.0.4a prohibits a Mode transition while not in compliance with the Required Action," and "...the associated action which allows operations for an unlimited time (in this case tripping a bi-stable) must be completed prior to mode ascension in order to apply TS 3.0.4a." This position is incorrect because it is in direct conflict with LCO 3.0.1 and LCO 3.0.2 which both state that Technical Specification LCOs and related Required Actions are not required until the Technical Specification is Applicable. TS LCO 3.0.4 does not govern the performance of Technical Specification ACTIONS but rather provides guidance on when a plant transition can be made when an LCO is not met. LCO 3.0.4 is not an exception to LCO 3.0.1 or LCO 3.0.2.
Performance of Required Actions is governed by LCO 3.0.2 and proper application of Completion Times is governed by Technical Specification Section 1.3, "Completion Times."
The LCO and Surveillance Use and Application rules in Section 3.0 of the Technical Specifications provide the foundation of all requirements in the ISTS. Stated simply:
- 1.
LCO 3.0.1 states that LCOs must be met when in the Applicability of the Specification.
- 2.
LCO 3.0.2 states that when an LCO is not met, complete the Required Actions within the stated Completion Time or until the LCO is met or the Applicability is exited.
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- 3.
LCO 3.0.4 states that in order to enter the Applicability when the LCO is not met, certain conditions must be met. The LCO 3.0.4.a condition is that the Actions to be entered must allow operation in the Applicability for an unlimited period of time.
- 4.
When LCO 3.0.4.a is used, the plant enters the Applicability, declares the LCO not met, and must complete the applicable Required Actions within the stated Completion Time.
Contrary to these fundamental rules of usage, the stated staff position is that when using LCO 3.0.4.a, the LCO must be declared not met and the Required Actions must be completed.
before entering the Applicability without regard for the Completion Times. This position contradicts LCO 3.0.1, LCO 3.0.2, and LCO 3.0.4. It is also contrary to statements in LCO 3.0.3 (i.e., the plant must shutdown until the Applicability of the LCO is not met), the Section 1.1 definition of "ACTIONS", and Section 1.3, "Completion Times." This position undermines the entire foundation of the ISTS.
The sole basis for the NRC Staff guidance in TIA 2008-002 is the use of the word "when" in the LCO 3.0.4.a statement:
"When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;" (emphasis added)
The TIA acknowledges that the phrase "to be entered" supports the industry's position, but chooses to ignore this plain interpretation and instead justifies their position by joining separated sentences out of context from the ISTS Bases. The TIA quotes, "Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation...
Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions." These Bases statements are ambiguous regarding whether the Actions must be taken before or after entering the Applicability. However, if the omitted sentence is added, the Bases clearly support the LCO 3.0.4 statement that Actions are entered after entering the Applicability. The entire Bases states, "Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions."
(Emphasis added). The TIA response ignores the plain meaning of LCO 3.0.4 and omits Bases statements that do not support the staffs proposed interpretation.
In addition, the TIA does not address the inconsistency of the staff guidance with the remainder of the ISTS usage rules. It does not address the conflicts created with LCO 3.0.1, LCO 3.0.2, 16
LCO 3.0.3, or Section 1.3 even though the licensee had provided documentation that brought these conflicts to the NRC's attention.
The correct intent is described in the Bases of LCO 3.0.4 and is consistent with other regulatory documents, such as Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of the Limiting Conditions for Operation and Surveillance Requirements," dated June 4, 1987. The Generic Letter stated that Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable level of safety for continued operation. GL 87-09 replaced the common note, "The provisions of Specification 3.0.4 are not applicable," with a global exemption (LCO 3.0.4.a) for actions that allowed operation in the TS Applicability for an unlimited period of time. The NRC's stated position in the response to TIA 2008-002 was never previously required by the NRC. This position is not based on any wording or implied statements in the Technical Specifications, the Bases, or in any other regulatory document.
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LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
- a.
MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,
- b.
[MODE 4 within 13] hours, and
- c.
MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a.
When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;
- b.
After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or
- c.
When an allowance is stated in the individual value, parameter, or other Specification.
CEOG STS 3.0-1 Rev. 3.1, 12/01/05
LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 (continued)
This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.
LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
LCO 3.0.7 Special test exception (STE) LCOs [in each applicable LCO section] allow specified Technical Specifications (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with STE LCOs is optional. When an STE LCO is desired to be met but is not met, the ACTIONS of the STE LCO shall be met. When an STE LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.
LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:
CEOG STS 3.0-2 Rev. 3.1, 12/01/05
LCO Applicability B 3.0 BASES LCO 3.0.3 (continued)
MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reached in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reaching MODE 4 is the next 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, because the total time for reaching MODE 4 is not reduced from the allowable limit of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to reach a lower MODE of operation in less than the total time allowed.
In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.16, "Fuel Storage Pool Water Level." LCO 3.7.16 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.16 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.16 of "Suspend movement of irradiated fuel assemblies in fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.
[The requirement to be in MODE 4 in 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> is plant specific and depends on the ability to cool the pressurizer and degas.]
LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.
CEOG STS B 3.0-4 Rev. 3.1, 12/01/05 CEOG STS B 3.0-4 Rev. 3.1, 12/01/05
LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.
Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.
LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.
The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.
CEOG STS B 3.0-*5 Rev. 3.1, 12/01/05
LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
LCO 3.0.4.b may be used with single, or multiple systems and components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.
The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4.b risk assessments do not have to be documented.
The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.
LCO 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications. which describe values and parameters (e.g., [Containment Air Temperature, Containment Pressure, MCPR, Moderator Temperature Coefficient]), and may be applied to other Specifications based on NRC plant specific approval.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
CEOG STS B 3.0-6 Rev. 3.1,12/01/05 CEOG STS B 3.0-6 Rev. 3.1, 12/01/05
LCO Applicability B 3.0 BASES LCO 3.0.4 (continued)
The provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown. In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.
Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.
Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by SR 3.0.1. Therefore, utilizing LCO 3.0.4 is not a violation of SR 3.0.1 or SR 3.0.4 for any Surveillances that have not been performed on inoperable equipment. However, SRs must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.
LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of required testing to demonstrate either:
- a.
The OPERABILITY of the equipment being returned to service or
- b.
The OPERABILITY of other equipment.
The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to perform any other preventive or corrective maintenance.
CEOG STS B 3.0-7 Rev. 3.1,12/01/05 CEOG STS B 3.0-7 Rev. 3.1, 12/01/05