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NEI Comments on Draft IMC-0326, Operability Determinations
	ML19247B792
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Site:	Nuclear Energy Institute
Issue date:	08/19/2019
From:	; Nuclear Energy Institute
To:	; Division of Licensing Projects
	Otto N, NRR/DLP, 415-6695
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NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation The section repeats information better described in other sections and is Delete information after the first sentence in incorrect or misleading in some cases. the last paragraph of the operable-

1. Wording: When a condition is discovered that calls into question the TS operability definition.

required SSCs ability to perform the specified safety function, an OD should be made to determine if the SSCs specified safety function can be performed.

Basis: Recommend the sentence be deleted. It is inconsistent with other portions of the document, such as Section 06.02, "The presumption of operability is only lost when it is apparent that a condition has been identified that causes a substantive functional impact or would be expected to have a substantive functional impact during an event requiring the SSC to perform its specified safety function."

2. Wording: In addition, TS operability considerations require that an SSC meet all surveillance requirements (SRs) (as specified in SR Applicability 4.09, Operable-1 SR 3.0.1). An SSC that does not meet a SR must be declared inoperable Operability because the LCO operability requirement(s) are not met.

Basis: This is incorrect and should be deleted. SR 3.0.1 states that when an SR is not met or performed within the specified frequency, the LCO is not met. It does not state the system is inoperable. It is best to not mix TS usage rules with operability.

3. Wording: A system is expected to be tested and maintained to perform as designed.

Basis: This statement is not related to the definition of operability and should be deleted.

4. Wording: When an SSC capability is degraded to a point where it cannot If kept, should be; degraded to a point perform with reasonable assurance, the SSC should be judged where it cannot perform the specified safety inoperable. function with reasonable assurance Basis: This is discussed more thoroughly under 06.02, "Presumption of Operability," and 04.10 "Reasonable Assurance." Recommend it be 1

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation deleted.

1. Wording: The specified function/specified safety function of an SSC is Update Specified Function/Specified Safety that specified safety function(s) in the CLB for the facility." Function, definition to eliminate incorrect, Basis: This sentence implies that all of the SSC functions described in inconsistent, or duplicative information.

the CLB are specified safety functions required for operability. That position is inconsistent of other portions of the IMC as described below Also, consider the wording and bases used in and should be revised or deleted. NEI 18-03 definition and appendix B.

Section 03.01, "Scope of SSCs for Operability Determinations," states: Eliminate portions that add no additional value ;

SSCs may also have design functions that do not perform a necessary and related support function for TS SSCs. These expected to perform as designed, tested design functions are not within the scope of an OD. and maintained For example, (1) Nuclear Service Water supplied to components that do not have a TS specified safety function or a necessary when system capability is degraded 04.11, "Specified and related support function and, (2) station battery 2 Function/Specified nonconformance with the Station Blackout Rule, 10 CFR 50.63, Safety Function" Loss of all alternating current power, would not necessarily render operating or shutdown DC Source Limiting Condition for Operation (LCO) requirements not met and therefore inoperable.

(NEI agrees with this section. It points out that not all functions in the CLB are specified safety functions.)

Section 08.01, "Relationship between the General Design Criteria (GDC) and the Technical Specifications," states:

The GDC and the TS differ from each other in that the GDC specify requirements for the design of nuclear power reactors, whereas the TS specifies requirements for the operation of nuclear power reactors. As such, the GDC cover a broad 2

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation category of SSCs that are important to safety, including those SSCs that are covered by TS. Failure to meet GDC, as described in the licensing basis (e.g., nonconformance with the CLB for protection against flooding, seismic events, tornadoes) should be treated as a condition and evaluated to determine if the condition calls into question the ability of SSCs to perform their specified safety function(s) or necessary and related support function(s) and perform an OD if necessary.

(NEI agrees that the plant design, described in the CLB, is separate from the TS requirements on plant operation, which is circumscribed by the specified safety functions.)

2. Wording: In addition to providing its specified safety function(s), an SSC is expected to perform as designed, tested and maintained."

Basis: This sentence is inconsistent with the TS and other portions of the IMC described below and should be deleted.

The TS definition of operability states, "A [SSC] shall be OPERABLE

... when it is capable of performing its specified safety function(s),

and when all necessary attendant [support systems] are also capable of performing their related support function(s)." There is no regulatory basis for the IMC to add additional requirements.

3. Wording: an SSC is expected to perform as designed.

Basis: The phrase, under the definition of specified safety function, strongly implies that any degradation from the design condition renders a component incapable of performing its specified safety function. That is inconsistent with the following statement in the IMC:

Section 06.02, "Presumption of Operability," states:

It should be noted, that once a condition is identified that may impact the function of an SSC, the presumption of operability is not necessarily lost. The presumption of operability is only lost 3

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation when it is apparent that a condition has been identified that causes a substantive functional impact or would be expected to have a substantive functional impact during an event requiring the SSC to perform its specified safety function.

Section 6.05, "Timing of Operability Determinations," states:

Conditions that do not result in a substantive functional impact can be reviewed under the corrective action program.

(NEI agrees that a deviation from the design condition that does not have a substantive functional impact does not result in failure to perform the specified safety function.)

Section 08.01. "Relationship between the General Design Criteria (GDC) and the Technical Specifications," states:

[T]he GDC covers a broad category of SSCs that are important to safety, including those SSCs that are covered by TS. The safety analysis report describes the design capability of the facility to meet the GDC (or a plant-specific equivalent). The staff safety evaluation report documents the acceptability of safety analysis report analyses. The analyses and evaluation included in the safety analysis serve as the basis for TS issued with the operating license.

The TS limiting conditions for operation, according to 10 CFR 50.36(c)(2)(i), are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Section 182 of the Atomic Energy Act of 1954, as amended and as implemented by 10 CFR 50.36, requires that those design features of the facility that, if altered or modified, would have a significant effect on safety, be included in the TS.

Thus, TS are intended to ensure that the most safety significant design features of a plant, as determined by the safety analysis, maintain their capability to perform their safety functions, i.e.,

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NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation that SSCs are capable of performing their specified safety functions or necessary and related support functions.

This section clearly illustrates the difference between the design described in the CLB and the specified safety functions required to be met by the TS. The specified safety functions of an SSC are a subset of the functions described in the CLB.

4. Wording: an SSC is expected to perform as ... tested and maintained.

Basis: The phrase adds no value to the definition of specified safety function and should be deleted. SSCs are tested by the TS SRs, as described by SR 3.0.1 and SR 3.0.2. These usage rules do not use the term "operable" or "operability." It is best to not mix TS usage rules with operability. The TS do not describe the performance of maintenance. The phrase adds no value and is confusing.

5. Wording: When system capability is degraded to a point where it cannot perform with reasonable expectation or reliability, the SSC should be judged inoperable."

Basis: The sentence is duplicative of other sections of the IMC, is not related to the definition of specified safety function, and should be deleted. The topic is discussed more thoroughly under 06.02, "Presumption of Operability," and 04.10 "Reasonable Assurance."

The following portion of the first paragraph should be deleted: Delete the portion of the first paragraph that

1. Wording: Position 8 in Attachment 1 to Generic Letter 89-04, references outdated information.

Guidance on Developing Acceptable Inservice Testing Programs, 08.09, "Technical defines the starting point for the completion time in TS actions for As discussed at the public meeting, the Specification ASME pump and valve testing. When performance data fall outside guidance provided should reference the 3

Operability vs. ASME the required action range, regardless of whether the limit is equal to specific Code language. Specifically, the OM Code Criteria" the TS limit or more restrictive, the pump or valve must be declared statement that the LCO must be declared inoperable immediately (the word inoperative is used in the text not met is not contained within the code of the ASME Code, i.e., the pump or valve is both inoperative and requirements.

inoperable) and the LCO must be declared not met and the 5

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation applicable conditions must be entered. Therefore. when a pump or The NRC does not accept durations specified by the ASME OM Code valve is determined to be for analyzing test results as a reason for postponing entry into a TS 'inoperable' or "inoperative" as dictated by action statement. As soon as data are recognized as being within code language, the guidance should be the required action range for pumps or as exceeding the limiting- changed to evaluate for system operability value full-stroke time for valves, the associated component must be for the involved TS LCO, as applicable.

declared inoperable, and if subject to the TS, the completion time specified in the action statement must be started at the time the component was declared inoperable. For inoperable pumps and valves that are part of an ASME IST program but not subject to TS, the actions required by the applicable sections of the ASME code are applicable.

Basis: These paragraphs are both taken from Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, Attachment 1, "Potential Generic Deficiencies Related to IST Programs and Procedures," Position 8, "Starting Point for Time Period in TS ACTION Statements." The GL position is based on ASME Section XI IWP-3220, IWP-3230, and IWP-3100-2.

The ASME Section XI requirements discussed in Generic Letter 89-04 have been replaced with the O&M Code. Therefore, the discussion in Generic Letter 89-04 is no longer valid.

The intent of Position 9 is to state that the time allowed by the ASME Code for analyzing data does not apply when the operability of TS equipment is called into question.

NEI agrees this is correct, but it is not needed to be stated in this section. Note that the Generic Letter was published in 1989 and the concept of "operability evaluations" was not introduced until 1991.

2. Wording: When performance data fall outside the required action range, regardless of whether the limit is equal to the TS limit or more restrictive, the pump or valve must be declared inoperable 6

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation immediately Basis: NEI does not agree that a pump or valve in the required action range must be assumed to be inoperable. However, we agree that in such a condition the operability of the component is called into question and must be evaluated.

Wording: "Operability is assessed continuously and upon identification of a Change SHALL to SHOULD or change condition, the licensee shall assess the presumption of operability of the SSC wording to provide guidance to the 06.06, Timing of immediately and without unnecessary delay." inspector. It looks like the IMC is providing 4 Operability Basis: It would be more appropriate to state "should" or change wording to licensee actions.

Determinations state what the inspector is expected to see as it looks like the IMC is directing licensee actions.

Wording: 'If an SMA is used, the seismic demand shall be the recently Change SHALL to SHOULD or change developed Ground Motion Response Spectra (GMRS) for the Fukushima 2.1 wording to provide guidance to the seismic evaluation, and its application shall be consistent with EPRI NP-6041- inspector. It looks like the IMC is providing 08.07, Use of Seismic SL." licensee actions.

5 Margin Assessment in Basis: It would be more appropriate to state "should" or "the NRC staff Operability Decisions recognizes the " or change wording to state what the inspector is expected to see as it looks like the IMC is directing licensee actions.

Wording: It is acceptable for an inspector to ask the licensee for the basis for Consider adding wording that makes it clear the functional impact decision if it is not clear. that this may not be documented 06.01 Continuous Basis: Similar to the practices, there is no separate documentation that information.

Assessment of 6 supports the presence or absence of a degraded and/or non-conforming Operability condition. Could be implied that the basis for answering the three required entry criteria is documented.

Wording:

06.04 Reasonable Assurance has replaced Expectation Retain the existing definition of Reasonable Assurance of Basis: Expectation of Operability.

7 Operability

The meaning of Expectation is distinct from Assurance and has been in consistent and widespread use since it is inception in Generic Letter 91-18. Each sites procedure currently utilizes expectation and 7

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation any alteration would induce confusion.

Expectation was clarified in RIS 2005-20 in order to support the timely declaration of Operability via the Immediate Operability Determination.

That is, the use of Expectation at that stage allows the operating staff to make a timely declaration while supporting a continuing investigation, if needed.

The term Reasonable Assurance is used elsewhere within the regulations and there is no basis to utilize this definition.

At the most fundamental level Expectation and Assurance are describing entirely distinct concepts, with Expectation supporting the timely declaration of the results of an Immediate Operability Determination.

8 Deleted Deleted Deleted Wording: Alter the wording as follows:

The embedded example includes: The absence of these indirect effects could The absence of these indirect effects could be used to support a reasonable be used to support either the absence of a 06.06 Timing of expectation of continued operability. substantive functional impact or the Operability Basis: reasonable expectation of continued 9

Determinations This appears to be an attempt to provide guidance that might have be useful operability, depending upon whether the during a recent industry event. In that instance, the absence of indirect formal OD process was entered.

effects could have been used as part of demonstrating the absence of a substantive functional impact.

Wording: After; Any nonconformance with a GDC incorporated in the licensing basis by which Any nonconformance with a GDC the capability of an SSC to withstand a single failure is compromised should be incorporated in the licensing basis by which 08.02 Single Failures treated as a condition and evaluated to determine if an OD is warranted. the capability of an SSC to withstand a single 10 failure is compromised should be treated as Add the following words; a condition and evaluated to determine if an If the GDCs do not require single failure protection for a given situation, then, OD is warranted.

as introduced above, the GDC would be part of the facilitys design, but not part Add:

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NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation of its operation governed by a TS LCO. If the GDCs do not require single failure Basis: protection for a given situation, then, as If a plant, especially older sites were never intended to incorporate single introduced above, the GDC would be part of failure protection for an event. Therefore, even if redundant SSCs exist, then no the facilitys design, but not part of its entry into an individual LCO is possible. Sites that were designed and/or operation governed by a TS LCO.

licensed to the 1967 GDCs for protection against natural phenomena fall into this category.

Wording: This section has been largely copied from IMC 0326 Add these words at the end of this section:

08.05 Use of Basis: The use of 10 CFR 50.59 typically determines the acceptability of a given Licensees may use the guidance in NEI 96-Temporary Manual Manual Action. 07, Revision 1, Guidelines for Implementing Action in Place of 10 CFR 50.59, which is endorsed by 11 Automatic Action in Regulatory Guide 1.187, Guidance for Support of Operability Implementation of 10 CFR 50.59, Changes, Tests, and Experiments.

Wording: A decision by an SRO on the operating crew that there is reasonable Change assurance to expectation as this assurance that an SSC can perform its specified safety function(s). the word is associated with an SRO assessment.

expectation would be more appropriate.

Basis: Reasonable Expectation from previous IMC has been changed to A decision by an SRO on the operating crew Reasonable Assurance. As stated in Item #7 of this table, Reasonable that there is reasonable expectation that an 04.08, Operability 12 Expectation has been used since 1991 and currently used by SROs and we SSC can perform its specified safety Determination (OD) recommended keeping reasonable expectation. function(s).

Even if Reasonable Assurance definition is not changed back to Reasonable Expectation, expectation would still better match the description of the SRO action and is consistent with assurance and expectation usage throughout the document.

Wording: A Subsequent determination of operability should be based on the Change assurance to expectation as this licensees reasonable assurance from the evidence collected that the SSCs are is associated with an SRO assessment.

04.10, Reasonable capable of performing the word expectation would be more appropriate.

13 Assurance Basis: Reasonable Expectation from previous IMC has been changed to A Subsequent determination of operability Reasonable Assurance. As stated in Item #7 of this table, Reasonable should be based on the licensees Expectation has been used since 1991 and currently used by SROs and we reasonable expectation from the evidence 9

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation recommended keeping reasonable expectation. collected that the SSCs are capable of Even if Reasonable Assurance definition is not changed back to Reasonable performing Expectation, expectation would still better match the description of the SRO action and is consistent with assurance and expectation usage throughout the document.

1. Wording: A senior licensed operator on the operating shift crew Change senior licensed operator and

2. Wording: Whoever prepares the evaluation of the condition should inform licensed operators to licensed senior the licensed operators responsible reactor operator (SRO) 06.09, Operator Basis: Inconsistent usage of senior licensed operator vice licensed Senior 14 Awareness and Reactor Operator (SRO) as described in the IMC 0326-03 Applicability Section.

Responsibilities It is the responsibility of licensed Senior Reactor Operator (SRO) to Definitions and other sections of 0326 used SRO throughout. Only Section 06.09 needs to be updated.

Paragraph prior to ASME Class 1 Components section: in two places the phrase Replace phrase degraded but operable 15 8.12, Flaw Evaluation degraded but operable is used contradicting position under section 4.10 an with operable SSC is either operable or inoperable The wording in this section does not clearly describe the additional available 08.12 Flaw Evaluation, page 19 methods that can be used when evaluating operability. For example, as written, Change the last sentence above ASME Class the inspectors may assume that non-mandatory appendix U must be used to 1 Components to; evaluate class 2 or 3 moderate energy systems flaws and in support of an operability determination. Appendix U applies to piping, tanks, and vessels. To determine that Class 2 or 3 piping is When flaws are identified in valve bodies for example, the IMC does not operable, licensees should evaluate the provide information that ASME Sect. XI IWC & IWD for Class 2 & 3 moderate integrity of the component using 08.12 Flaw Evaluation/

energy systems allows for evaluation and acceptance criteria specified by the Nonmandatory Appendix U or other 08.13 Operational 16 owner. ASME Sect. XI companion guide Chapter 35 describes criteria that can technically acceptable methods defined by Leakage from Class 1, be used by the licensee when evaluating operability including; analysis, test or the licensee and should use reasonable 2, and 3 Components partial test, operating experience, and engineering judgement. This is important engineering judgement to select methods for online applications with systems in service as the available techniques and for other operability considerations.

assessment methods could be more limiting than during ISI exam windows with systems out of service. The use of engineering judgement and other technical 08.12 Flaw Evaluation, page 20, acceptable methods could play a larger role when performing operability In the 2nd paragraph under ASME Class 2 determinations with systems in service. The current wording could imply that a and 3 Components, system is inoperable if the use of code acceptable methods is not practical 10

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation resulting in a short duration TS LCO, premature removing of technical Change; specification equipment/trains from service, or even TS 3.0.3 entries for issues If it is identified that a flaw does not meet on common headers. The section also states; a relief request/alternative can the criteria in ASME Code, construction code be submitted and at a minimum, verbally approved by the NRC before the acceptance standards, or an NRC-accepted completion time expires. This implies that a relief request is a tool for ASME code case as listed in RG 1.147, the determining operability of a Tech Spec SSC and conflicts with the component should be declared inoperable responsibilities of a licensed SRO when assessing operability. and the applicable TS action statement is to be addressed at that time. Alternatively, a Consistent with RIS 2005-20 Rev. 1 addressing common header issues. relief request/alternative can be submitted and at a minimum, verbally approved by the The recommendations provided will expand on the areas described in section NRC before the completion time expires.

08.12 and 8.13 for what tools are available when assessing operability.

To; If the licensee determines that the flaw is unacceptable for continued operation, Additional considerations identified on 8/16. operability needs to be assessed for technical specification LCO applicability.

Consider adding a statement that if a licensee uses an alternative analytical method in an initial operability determination as discussed in 08.04 for evaluating structural integrity, it is expected that ASME Code, NRC approved Code 08.12 Flaw Evaluation, page 20, Paragraph Case, or GL 90-05 is used, if available, or a relief request is above Methods Acceptable to Evaluate submitted and approved by the NRC. Structural Integrity Another way to state this concept; Change; The table below summarizes methods for

It is not expected that the licensee will call a deficient condition evaluating structural integrity of defects inoperable solely on not being able to assess structural integrity found in boiling or pressurized water-cooled through an ASME or NRC approved method however, it is nuclear power facilities on components expected that the licensee follows the ASME requirements (including supports) classified as ASME Code including submitting a relief request for use of an alternative Class 1, Class 2, and Class 3 components.

analytical method, as applicable.

11

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation To; The table below summarizes methods for evaluating structural integrity of defects found in boiling or pressurized water-cooled nuclear power facilities on components (including supports) classified as ASME Code Class 1, Class 2, and Class 3 components.

When assessing operability for Class 2 & 3 moderate energy systems, operating experience and engineering judgement can be used in cases where other methods would be impractical.

08.13, Operational Leakage from ASME Code Class 1, 2, and 3 Components, page 22 2nd paragraph.

Change; Alternatively, the licensee may evaluate the structural integrity of leaking Class 2 or Class 3 moderate-energy components using the criteria of ASME code case N-513, N-705 or any other applicable NRC approved methodology as indicated in the table in Section 08.12, Flaw Evaluation.

To; Alternatively, the licensee may evaluate the structural integrity of leaking Class 2 or Class 12

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation 3 moderate-energy components using the criteria of ASME code case N-513, N-705 or any other applicable NRC approved methodology as indicated in the table in Section 08.12, Flaw Evaluation. Operating experience and engineering judgement are acceptable methods to assess operability especially in cases where other methods would be impractical.

Additional considerations identified on 8/16.

Consider adding a statement that if a licensee uses an alternative analytical method in an initial operability determination as discussed in 08.04 for evaluating structural integrity, it is expected that ASME Code, NRC approved Code Case, or GL 90-05 is used, if available, or a relief request is submitted and approved by the NRC.

Another way to state this concept;

It is not expected that the licensee will call a deficient condition inoperable solely on not being able to assess structural integrity through an ASME or NRC approved method however, it is expected that the licensee follows the ASME requirements including submitting a relief request for use of an alternative analytical method, as applicable.

13

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation In the first paragraph, change assurance to expectation. Change as highlighted below; Basis: To match the language that the SRO uses. Operability is assessed continuously and upon identification of a condition, the licensee shall assess the presumption of operability of the SSC immediately and 06.06 Timing of without unnecessary delay. If the condition 17 Operability results in a substantive functional impact on Determinations the SSC then the licensee should enter the OD process. While an OD may be based on limited information, the information should be sufficient to conclude that there is reasonable expectation that the SSC is capable of performing the required specified safety function.

In the 2nd paragraph, add words to ensure clarity when in the operability Change in the 2nd paragraph; determination process.

In any case, if the available information is Basis: Adds clarity with regards to actions in the OD process and changes incomplete, the licensee should collect any assurance to expectation to match the language that the SRO uses. additional information that is material to the determination (i.e., information that could result in a change to determination) commensurate with the safety significance 06.06 Timing of of the condition, and then promptly make an 18 Operability operability determination based on the Determinations complete set of information. If, at any time, information emerges that negates a previous determination that there is a reasonable assurance that the SSC is operable the licensee should declare the SSC inoperable.

To; 14

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation Following entry into the Operability Determination process, if additional information is warranted, the licensee should collect any additional information that is material to the determination (i.e.,

information that could result in a change to the operability determination's conclusion) commensurate with the safety significance of the condition, and then promptly make an operability determination based on the complete set of information. If, at any time, information emerges that negates a previous determination that there is a reasonable expectation that the SSC is operable the licensee should declare the SSC inoperable.

Eliminate the word root in the following statement. Test failures should be examined to determine the cause and correct the Basis: Root Cause is a specific CAP evaluation process. The cause should be problem before resumption of testing.

07.02 System identified, not root cause. Repetitive testing to achieve acceptable test Configuration during results without identifying the root cause or 19 Surv and Operability correction of a problem in a previous test is Testing not acceptable as a means to establish or verify operability and may constitute preconditioning.

Clarify the last sentence to reinforce that questions alone do not get addressed After the statement:

in the Operability Determination Process until a deficient condition is confirmed and has a substantive functional impact. Note that a question, concern or presence of 06.02 Presumption of a condition alone does not necessarily 20 Operability Basis: Questions alone would not screen through the Three Required Criteria invalidate the presumption of operability.

unless there is a deficient condition identified to have a substantive functional impact. This is a key element to the SRO burden reduction. Add:

Questions should be addressed through 15

NEI Comments on Draft IMC-0326, Operability Determinations Item Affected Section Comment/Basis Recommendation other appropriate station processes until such time that a deficient condition is confirmed.

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ML19247B792

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