ML19332C803

Forwards Criteria to Be Used to Interpret Term Verify Operable, Per Util 890531 Proposed Tech Spec Changes, Reflecting LPCI Mods During Reload 1/Cycle 2 Refueling Outage & Eliminating Need for Redundant Surveillance Tests

ML19332C803
Person / Time
Site:	FitzPatrick
Issue date:	11/20/1989
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JPN-89-076, JPN-89-76, NUDOCS 8911290017
Download: ML19332C803 (4)

Text

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014 681.0240 [

s, .' f hk [ John C. Brons s Nu G r erat o 4

November 20,1989 JPN-89-076 U. S. Nuclear Regulatory Commission Attention: Document Control Desk ,

, Mail Stop P1137

. .L Washington, D. C. 20555

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Proposed Changes to the Technical Specifications Regarding Low Pressure Coolant injection and Demonstrate / Verify Terminology (JPTS-80-011)

Definition of Term Demonstrate and Verg

Reference:

1. NYPA letter, J. C. Brons to USNRC, dated May 31,1989 (JPN 89-034) regarding the same subject.

Dear Sir:

-7 In Reference 1, the Authority subr11tted a proposed change to the FitzPatrick Techn! cal

- Specifications to incorporate two dis inct changes.- The first change revised the specifications to reflect LPCI (low pressure coolant injection) modifications installed during the Reload 1/ Cycle 2 refueling outage. The second change eliminated the need for redundant and unnecessary surveillance tests by making the terminology consistent with an NRC Generic Letter on the term operable.

The NRC's Project Manager for FitzPatrick asked how the term " verify operable" would be intarpreted if the proposed specification were issued. He expressed the concern that operability could not be assured simply by confirming that a system (or component) successfully passed its most recent surveillance test and that the test was performed on schedule.

Attached is a description of the criteria the Authority will use to interpret the term " verify operable" as used in the FitzPatrick Technical Specifications. Operators will be notified of this criteria after the amendment is issued by the NRC.

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Should you or your staff have any questions regarding this interpretation, please contact .

Ms. S. M. Toth of my staff.

3-Very truly yours, h John C. Vice Executive Brons President Nuclear Generation i

cc: U' S. Nuclear Regulatory Commission Region i 475 Allendale Road .

King of Prussia, PA 19406 i

- Office of the Resident inspector U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 '

Mr. Dave LaBarge Project Directorate 11 Division of Reactor Projects- 1/il U. S. Nuclear Regulatory Commission Mail Stop 14 B2 Rockville, MD 20555 i-1 l

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i 4 k Attachment to JPN 89476 NewYoi Power Authority Criteria to interpret the Term " Verify O >erable*

in the James A. FitzPatrick Nuclear Sower Plant Technical Specifications The following guidelines will be used when ver!fying the operability of redundant components (or systems) when Technical Specifications require a component (or system) to be ' verified operable."

1. Inspect the appropriate records to determine if the system (or component) satisfactorily comp!sted its most recent surveillance test.

2. Inspect the appropriate records to detwmine if the most recent surveillance test is currently valid. The most recent surveillanc.e test would be invalid (" expired") if the elapsed time interval since the last test is greater than the maximum allowable test interval.

For example,if the technical specifications require quarterly testing a test would be valid (i.e., not expired) if the most recent surveillance test was conducted within the past 92 (+25%) days.

3. Review the temporary modification log (lumper log) to determine if any jumpero (or temporary modifications) are currently in placo that would prevent the system (or component) from performing its intended function.

4. Review the protective tagging system records to determine if any protective tags are currently in place that would prevent the system (or component) from performing its intended function.

5. Inspect the controls, annunciators and indicators associated with the system (or component) to determine if any parameters or controls indichte that it would not perform its intended function. Both control room mounted and local controls, annunciators and indicators may require inspection.

6. Review the operating logs and shift turnover records to determine if any other conditions exist that would prevent the system from performing its intended function.

The NRC's April 10,1960 Generic Letter on the term operable implicitly d;stinguishes between

' demonstrate" and

• verify." Demonstrate means 'co- *' *:t a test to show," while verify means "the associated surveillance activit!es have been satisfactr....y performed within the specified time i

interval."

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.-. r-6 For example, the actual performance of a test (stch as starting a pump and observing norma! l discharge pressure) oonducted with the express intent of satisfying a technical specification  !

requirement constitutes a demonstration. Verification involves reviewing test records, logs, i' controls, indicators and annunciators in unusual situations, verification may also include actually inspecting the equipment and its locat controls.  !

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