ML20040H244
| ML20040H244 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/25/1982 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8202170494 | |
| Download: ML20040H244 (4) | |
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JAN 2 51992 DISTRIBUTION DBrinkman Docket File Dhunnicutt NRC PDR Wjohnson L PDR JCallan Docket Nos. 50-313 NSIC 50-368 TERA ORB #3 Rdg DEisenhut m
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Mr. William Cavanaugh, III I&E-3 Senior Vice President ACRS-10
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RE @ ED 42 Energy Supply JHeltemes 82 Arkansas Power & Light Company PMKreutzer-3 T
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little Rock, Arkansas 72203 RAClark Gray File q
Dear Mr. Cavanaugh:
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Subject:
Surveillance Requirements for OPERABLE Status.
Our office of Inspection and Enforcement informed you in a Hotice of Violation dated October 6, 1901 of their findings with respect to the conduct of serveillance testing pursuant to ANO-2 Technical Specification TS 3.8.2.5.
Your response, dated November 17, 1981, stated that you did not agree that the. currently written AN0-2 TS 4.0.3 would require that, upon discovery of missed surveillance tests, the subject equipment should be declared 'inoperability.
He have reviewed your stated interpretation of the requirements of the present ANO-2 TS 4.0.3 and agree that although the wording of the current ANO-2 TS states thatsuccessfulsurveillancetestsaresufficienttoestablic[h_0PERABILI-TYthey are not explicitly stated to be necessary to es,tablish OPERBI IH.
However, trie in-tent of the staff's requirement on this matter has been that successful surveillance tests conducted within the specified time intervals are necessary to establish a basis for OPERABILITY. The need to clarify.the language of TS 4.0.3 has been recognized and resolved in a previous licensing action. This clarification has also been incorporated into the CE standard Technical Specification, NUREG-0212 Revision 2, issued in the fall of 1980.
We have discussed this matter with representatives of the AP&L Co. licensing staff in Little Rock and with the plant staff. As a result we have improved our under-standing of events related to this matter and believe the AP&L Co. staff under-i stands the NRC staff's interpretation of the requirements of TS 4.0.3.
Accordingly we conclude that to ensure that henceforth the implementation of AN0-2 TS 4.0.3 will be consistent with the staff's safety concern, the ANO-2TS should be modified to reflect the language of the current CE STS.
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NRC FORM 318 00-89 NRCM CNO
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This interpretation applies equally to the A!!0-1 TS. Therefore we request that you submit a request for modification of the Afl0-1 and the At!0-2 Technical Specifications which incorporates the language of STS 4.0.3 as set forth in the enclosure.
Sincerely, Original signed by:
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Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing Original signed by:
Jo$NiI$f611bChief Operating Reactors Branch #4 Division of Licensing
Enclosure:
CE-STS cc: See next page omcey suanaut>
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APPLICABILITY l
SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Op; ration unless otherwise stated in an individual Surveillance Requirement.
4.0.2 Each Surveillance Requirement shall be performed,within the specified time interval with:
a.
A maximum allowable extension not to exceed 25% of the surveillance interval, and b.
The combined time interval for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified surveillance interval.
4.0.3 Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Liciting Condition for Operation.
Exceptions to these requirements are stated in the individual specifications.
Surveillance Requirements do not have to be performed on inoperable equipment.
4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance intsrval or as otherwise specified.
4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
Inservice inspection of ASME Code Class 1, 2 and 3 components and a.
inservice testing ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).
b.
Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:
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,CE-STS 3/4 0-2 OCT 171980 I,
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Arkansas Power & Light Company cc:
Mr. David C. Trimble Manager, Licensing Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 U.S. Environmental Protection Agency Mr. James P. O'Hanlon Region VI Office General Manager ATTN:
Regional Radiation Arkansas Nuclear One Representative P. O. Box 608 1201 Elm Street Russellville, Arkansas 72801 Dallas, Texas 75270 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 420 7735 Old Georgetown Road S. L. Smith, Operations Officer Bethesda, Maryland 20014
- Arkansas Nuclear Planning &
Response Program Nicholas S. Reynolds, Esq.
P. O. Box 1749 c/o DeBevoise & Liberman Russellville, Arkansas 72801 1200 Seventeenth Street, N.W.
Washington, D. C.
20036 C
Arkansas Polytechnic College Russellville, Arkansas 72801 Mr. Charles B. Brinkman Manager - Washington Nuclear Operations C-E Power Systems 4853 Cordell Avenue, Suite A-1 Bethe.sda, Maryland 20014 e
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