ML113040026
| ML113040026 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 11/10/2011 |
| From: | Schulten C NRC/NRR/DSS |
| To: | |
| References | |
| Download: ML113040026 (3) | |
Text
Public Call Thursday, October 27, 2011 Discussion of Administrative Controls Technical Specifications Inservice Testing Program SR 3.0 Enforcement Guidance Memorandum Purpose of the Enforcement Guidance Memorandum (EGM) is to establish a proper generic application of SR 3.0.2 and SR 3.0.3 allowances in Standard TSs 5.5 Programs and a uniform basis for continued operation of nuclear power plants consistent with TIA 2010-001 Evaluation of Application of Technical Specification Surveillance Requirement 3.0.3, Surveillance Requirement Applicability at Clinton Power Station.
Regulatory Position Background TIA 2010-001 (April 2010) documents the NRC staff position for Clinton on the applicability of SR 3.0.3 in TS 5.5.6, Inservice Testing Program (ITP) to missed inservice testing performed under 10 CFR 50.55a(f) for excess flow check valves that must function to support operability of Tech. Spec. Suppression Pool Makeup System Instrumentation.
The excess flow check valve 10 CFR 50.55a(f) tests is not a TS required test.
In its review the NRC staff evaluated the licensee position that SR 3.0.3 applies to tests performed under 10 CFR 50.55a(f).
TIA 2010-001 concluded that applying ITP SR 3.0.3 to a test that is not associated with a TS surveillance requirement would be inappropriate for the reasons that there has been no Surveillance that was not performed within its specified Frequency, which is necessary to invoke SR 3.0.3, and that there is no associated requirement from SR 3.0.1 to declare equipment inoperable (SR 3.0.1 requires TS surveillance requirements to be both performed and met for equipment to be operable).
TS cannot override the IST activity requirements for any equipment o 50.55a(f)(5)(ii) states if a revised inservice test program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program.
Standard TS 5.5 Programs Surveillance Requirement Applicability Provisions Group 1 is defined as a TS 5.5 Program to which one or both Surveillance Requirement Applicability provisions apply and the TS 5.5 Program tests are associated with a LCO surveillance requirement. Program testing performed in accordance with a TS 5.5 Program and a TS surveillance requirement would make SR 3.0.2 and SR 3.0.3 available without a license amendment to change TSs.
Inservice Testing Program applies both the provisions of SR 3.0.2 and SR 3.0.3.
Ventilation Filter Testing Program applies both the provisions of SR 3.0.2 and SR 3.0.3.
Diesel Fuel Oil Testing Program applies both the provisions of SR 3.0.2 and SR 3.0.3.
Public Call Thursday, October 27, 2011 Discussion of Administrative Controls Technical Specifications Inservice Testing Program SR 3.0 Enforcement Guidance Memorandum Steam Generator (SG) Tube Surveillance Program (PWRs only) applies only the provisions of SR 3.0.2.
Containment Leakage Rate Testing Program applies only the provisions of SR 3.0.3.
Group 2 is defined as a TS 5.5 Program to which one or both Surveillance Requirement Applicability provisions apply; however, TS 5.5 Programs are not associated with a LCO surveillance requirement. Program tests performed under these programs are not associated with surveillance requirements. The NRC staff intended, as shown by the precedent set forth in improved STS, that SR 3.0.2 and SR 3.0.3 be made available to TS 5.5 programs and consequently to their tests.
Primary Coolant Sources Outside Containment.
Radioactive Effluent Controls Program.
Pre-Stressed Concrete Containment Tendon Surveillance Program.
Explosive Gas and Storage Tank Radioactivity Monitoring Program.
Group 3 is defined as a TS 5.5 Program to which the Surveillance Requirement Applicability provisions do not apply. These programs are unaffected by the TIA 2010-001 NRC staff position, therefore the EGM would not apply.
Offsite Dose Calculation Manual.
Post Accident Sampling.
Component Cyclic or Transient Limit.
Reactor Coolant Pump Flywheel Inspection Program (PWRs only).
Secondary Water Chemistry Program (PWRs only).
Technical Specifications Bases Control Program.
Safety Function Determination Program.
Battery Monitoring and Maintenance Program.
OM Code and OM Code Case Status ASME OM Code Committee is working on a revision to the Code and an OM Code Case to define the testing frequencies and allow for the 25% extension provisions but not the missed test provision.
Component Testing and Performance Branch is working to endorse the revised OM Code and an OM Code Case.
Regulatory Guide 1.192 will be revised to endorse this Code Case and incorporated by reference into 10 CFR 50.55a to define the testing frequencies and allow Frequency extension provisions currently in the Technical Specification. However, the Code Case
Public Call Thursday, October 27, 2011 Discussion of Administrative Controls Technical Specifications Inservice Testing Program SR 3.0 Enforcement Guidance Memorandum wont be incorporated into the ASME OM Code until 2013 a revision to 10 CFR 50.55a isn't likely to occur until 2015, or later.
Component Testing and Performance Branch has prepared Revision 2 to NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants to ensure consistency with the Clinton TIA. The projected date to issue NUREG-1482, Rev. 2 for public comment is Fall 2011 or later.