ML14192A273
| ML14192A273 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/18/1981 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8112030250 | |
| Download: ML14192A273 (5) | |
Text
DISTRIBUTION Docket NOV 1 'notNRC PDR L PDR TERA NSIC ORB#1 Rdg DEisenhut OELD Docket No. 50-61-3 S,
ACRS-10 SVarga 0
tW\\2O 98 WRoss Mr. J. A. Jones V0 8rs Senior Vice President 141ome CParrish Carolina Power and Light Co"pany Gray File 336 Fayettevilde Street Raleigh, North Carolina 27602
Dear Mr. Jones:
By letter dated April 10, 1980 from Darrell G.,Eisenhut all licensees of operating nuclear plants were requested to revise their technical specifi cations to ensure that adequate actions are taken when the single failure criterion for safety'related systems is jeopardized by loss of redundancy of OPERABLE systems.
Model (standard) technical specifications were encosed with Mr. Eisenhut's letter to provide an acceptable definition of OPERABLE and to described the action required upon-loss of redundancy of OPERABLE systems.
In your response, dated May 9, 1980, you ppoposed to meet the intent of the staff's request by adding the definition of OPERABLE to the Technical Specifications of Robinson-2. However, you did not propose to include any adoiltional action statements to complement those currently required to meet the Limitidg Conditions of Operation for this plant.
This matter has been discussed with members of your staff on several occasions. It is our position that without appropriate action statements as included in our Model Technical Specifications, under 10 EFR 50.36(c)(2) you are required to initiate prompt reactor shutdown without any reaction time when redundant systems become inoperable. Several technical specifica tions, especially in Section 3.3, relating to safety related equipment either do not provide for action to be taken if a component or system (pump, heat exchanger, flow path) becomes inoperable or do not require additional action if a system becomes inoperable while its redundant system is alre'ady inoperable
- because of failure or permissible temporary outage.
I request that within 45 days of receipt of this letter you (1) submit proposed changes to 3o'9technical specifications that incorporate the requirements of the Model Technical Specifications enclosed with our letter of April.10, 1980, and (2) implement the procedures described in that letter within 30 days thereafter.
8112030250 811118 PDR ADOCK 05000261 P
PDR OFFICE SURNAME DATEfr..................
NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO. 1981-335-960
Mr. J. A. Jones0
- 2 Please contact us if you have any questions related to these requests.
OMB clearance is not required for this request since it is being transmitted to nine or fewer licensees.
Sincerely, DRIGINAL SIGNED Steven A. VargalChief Operating Reactors Branch #1 Division of Licensing cc:
See next page B#1:DL ORB#1:DL ORB#TDL OFFIC SURNAM
..,00Ss.:.ds.....
04 SMOiner AL R C
D CO.......
NRC FORM 318 (10-80) NRCM O240 OFFICIAL RE CO RD CO PY.,
USGPO: 1981-335-960
DISTRIBUTION Docket File NRC PDR Local PDR NSIC TERA ORB 1 File Docket 50-261 D. Eisenhut OELD OI&E (3)
S. Varga Mr. J. A. ones W. Ross Senior Vice esident C. Parrish Carolina Powe and Light Company ACRS (10) 336 Fayettevil Street Raleigh, North rolina 27602
Dear Mr. Jones:
By letter dated April 10, 1980 from Darrell G. Eisenhut all licensees of operating nuclear plan were requested to revise their technical specifi cations to ensure that a equate actions are taken when the single failure criterion for safety rela ed systems is jeopardized by loss of redundancy of OPERABLE systems.
Model (standard) technical sp ifications were enclosed with Mr. Eisenhut's letter to provide an acceptable efinition of OPERABLE and to describe the action required upon loss of redu dancy of OPERABLE systems.
In your response, dated May 9, 1980, ou proposed to meet the intent of the staff's request by adding the defi ition of OPERABLE to the Technical Specifications of Robinson-2. However, ou did not propose to include any additionril action statements to compl ent those currently required to meet the Limiting Conditions of Operati for this plant.
This matter has been discussed with members o our staff on several occasions. It is our position that your propos clarification of the term OPERABLE in Section 1.0 (Definitions) of the Robinson Technical Specifications without appropriate action statemen as included in our Model Technical Specifications will, under 10 CFR 5 36(c)(2), require prompt reactor shutdown without any reaction time whe redundant systems become inoperable. Several technical specifications, e ecially in Section 3.3, relating to safety related equipment either do not p ovide for action to be taken if a component or system (pump, heat exchanger, flow path) becomes inoperable or do not require additional action if a stem becomes inoperable while its redundant system is already inoperable b ause of failure or permissible temporary outage.
I request that within 45 days of receipt of this letter you (1) su it proposed changes to your technical specifications that incorporate te requirements of the Model Technical Specifications enclosed with our OFFICE......
SURNAME...
DATE j.........
NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
Mr. J. A. Jones
- 2 letter of April 10, 1980, and (2) implement the procedures described in that letter within 30 days thereafter.
In onclusion, a determination has been made that the staff's review of this subject should be classified as Class III.
You are, therefore, reque ed to submit an additional fee of $2800 to supplement the $1200 check en osed with your May 9, 1980 letter.
Please contac us if you have any questions related to these requests.
OMB clearance is at required for this request since it is being transmitted to nine or fewer 11 ensees.
Sincerely, Steven A. Varga, Chief Operating Reactors Branch #1 ivision of Licensing cc: See next page Distribution:
Docket File NRC PDR Local PDR ORB#l Rdg D. Eisenhut OELD OI&E (3)
S. Varga W. Ross C. Parrish.
OFFICEO..D.L.0}QB 1..
DL:.B #
DL:ORB#l SURNAME I WRoss:4hs.
SMiner!
SAVarga DAT L...
/.8 NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
Mr. J. A. Jones Carolina Power and Light Company cc: G. F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C. 20036 Hartsville Memorial Library Home and Fifth Avenues Hartsville, South Carolina 29550 U. S. Nuclear Regulatory Commission Resident Inspector's Office H. B. Robinson Steam Electric Plant Route 5, Box 266-1A Hartsville, South Carolina 29550 Michael C. Farrar, Chairman Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Richard S. Salzman Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. W. Reed Johnson Atomic Safety and Licensing Appeal-Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555