ML20042F190

Summary of 891122 Working Meeting & Discssion W/Regional Representatives Re Guidance on Operability Determinations in Current & Improved Tech Spec Program.Attendance List & Result of Meeting Encl

ML20042F190
Person / Time
Issue date:	04/25/1990
From:	Partlow J Office of Nuclear Reactor Regulation
To:	Davis A, Ebneter S, Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9005070361
Download: ML20042F190 (14)

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NUCLEAR REGULATORY COMMISSION 5

.A WASHINGTON, D. C,20556 k....+ f April 25, 1990 MEMORANDUM FOR: Thomas T. Martin, Regional Administrator RI Stewart D. Ebneter Regional Administrator, RII A.BertDavis,RegIonalAdministrator,RIII Robert D. Martin, Regional Administrator, RIV John B. Martin, Regional Administrator, RV FROM:

James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation

SUMMARY

OF WORKING MEETING AND DISCUSSION; GUIDANCE FOR OPERABILITY DETERMINATIONS IN CURRENT AND IMPROVED TECHNICAL SPECIFICATION PROGRAM By memorandum dated November 22, 1989, NRR initiated a working meeting and discussion with regional representatiu s on existing guidance on OPERABILITY, questions that remain open or are perceived to remain open on the issue, and the need to supplement guidance to the licensees. On December 14, 1989 membersofNRRmetwithRegionalrepresentativesandmembersoftheOffleeof the General Counsel and the Office of Enforcement. The attendance list is enclosed as Enclosure 1.

As a result of the meeting, Enclosure 2 entitled "0PERABILITY - Assuring The i

Capability To Perform A Safety Function" has been developed as an initial step to achieve consistency in approach to applying OPERABILITY guidance to licensees. The enclosure may be used as interim guidance pending the develop-ment and formal issuance of guidance on the overall subject of OPERABILITY.

Our current plans are to prepare this as a revision to the Inspection Manual Part 9900, Technical Guidance.

The meeting presentations included five topics.

These were listed in the Hovember 22 memorandum as:

Licensee Actions on Degraded / Nonconforming Conditions, System Operability Status with Inoperable Support Systems.

Technical Specification Improvement Program, Current OPERABLE Guidance, and Supplemental Guidance and OPERABILITY Determination Developed by Region III Gary M. Holahan discussed licensee actions on degraded / nonconforming conditions. The focus of the discussion dealt with eight principals for j

dealing with OPERABILITY questions. These principals are included in the Jose Calvo with staff members Rich Emch, Chris Hoxie, and Mark Reinhart presented information en existing OPERABILITY guidance; the purpose of Technical Specification limiting conditions for operations (LCOs), allowed CONTACT:

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'}#I D. Wigginton, NRR l h' 49-23027 9005070361 900425 h

PDR ORG NRRD PDC hf l

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Regional Administrators 2

outagetimes(A0Ts),andOPERABILITY;supportandindirectsupportsystems; cascading Technical Specifications as required by the definition of OPERABLE; and surveillances requirtd for supported systems restored to opereble. Puch of this discussion led to the resolutions included in Enclosure 2 regarding Discussion Tc. pics Surrounding OPERABILITY Decisions.

Hubert fliller of Region III presented a proposed supplemental guidance to licensees which described a process for operability determinations.

Subsequent to the meeting, KRR respondcd, by memorandum dated December 25, 1989, to the Region !!! request with NRR concerns with the proposal.

The meeting representatives were very rerponsive to ongoing OPERABILITY questions and actively participated in developing acceptable resolutions. The regional participation is viewed as essential as we continue working on these issues.

Our next sttp will be to prepare a revised section on OPERABILITY to be included in Part 9900 of Inspection and Enforcement lianual (see Reference 4 ofEnclosure2).

If you have any suggestions in this regard, please let us know, original signed by:

James G. Partlow Associate Director for Projects Office of Nuclear Recctor Regulation

Enclosures:

1)

Meeting Attendance 2)

OPERABILITY. Assuring Safety Capability cc w/ enclosures:

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OFFIG hl RECORD CDPY Document flame: !!EETIt!G SUl&ARY l

P,tgional Adrinistr6 tors -

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l outage tir es (A0TS), and OPERALILITY; support arid indirect support syster:.s; cascading Technic 61 Specific 6tions as required by the definition of OPERABLE; I

and surytillances required for supporttd systerns restored to operable. Much of this discussion led to the resolutions included in Enclosure 2 regarding l

Discussion Topics Surrounding OPERADILITY Decisions.

I Hubert liille-r of Region 111 presented a proposed suppler: ental guidance to licensees which described a process for operability deterrninetions. Subsequent 3

to the ineeting, NRR responded, by n+rnorandurn dated Decenber 25, 1989, to the Region !!! requtst with NRR concerns with the proposal.

The tweting represt>ntativts stre very responsive to ongoing OPERABILITY questions and ectively p6tticipated in developirg acceptable resolutions.

The regierel particip6 tion is viewt-d as essential 6s wt continue working on these is,$ues.

Cur rat ster will be to prepart a revised section on OPERA 0lLITY to be includtd in part 9000 of the 1 Wction arid Enforcerient l'anuel (see Rtference 4 of Enc 1csurt t).

If you h6vr.

.i suggestions in this regard, please let us knew, i

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l Jeres G. Partlow Associate Director for projects Office of Nucle 6r Reactor Regulation

Enclosures:

1) 1:etting Attend 6tice 2) 0FEFIBILITY - Assurirp $6fety Capetility I

cc w/u. closures:

T. l'urity J. Snitrek F. liiraglia i

i MEETING

SUMMARY

- DECEMBER 14,1989 f

DISTRIBtlT10N

.q6g NRC PDR Local PDR PD4 Reading-F. Hebdon D. Wigginton OGC-Rockville E. Jordan ACRS--(10) i C. Abbate, DRSP M. Reinhart, DOEA -

-J. Zwo11nski, DRSP R. Dudley, DRSP L. Wiens, DRP G. Imbro, DRIS 1

L. P11sco, DONRR M. Slosson, DRP A. Mendiola DRP P. Milano, DRSP W. Swenson, DRSP l

J. Partlow, ADP' S. Varga, DRP E. Rossi,.DOEA G Holahan, DRSP J. Calvo, DOEA C. Hoxie, DOEA R. Emch, DOEA T. Ross, DRSP S. Hoffman, DRP G.:Leinas, DRP H. Berkow, DRP J. Thoma DRSP B. Boger, DRP B. Grines, DRIS S. Lewis, 000 J. Luehman, OE R. Perfetti, OE B. Borchardt, ED0 P. Swetland, RI D.' Kirsch, RV M. Lesser, RII

. L. Reyes, RII e

W. forney, RIII J. Wiggins, RI J. Callan, RIV

,H. Miller, RIII R. Knop, RIII L. Kolonauski, R1

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ATTENDEES FOR OPERADILITY MEETING DECEMBER 34, 1969 Office of Nuclear Reactor Regulation Office of General Counsel O ll= ate, DK5)

T.'Iewis M. Reinhart, DDEA J. Zwolinski, DRSP Office of Enforcement F. Hebdon, DRSP J. Luehman' R. Dudley, DRSP R. Perfetti L. Wiens, DRP G. Imbro DRIS Office of EDO L. P11sco, DONRR B. Borchardi.-

M. Slosson, DRP A. Mendiola,RSP DRP Regional Offices P. Milano, D U.wetliiid',T

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W. Swenson, DRSP D. Kirsch, PV J. Partlow, ADP H. Lesser, RII S. Varga, DRP L. Reyes, P.ll E. Rossi, DOEA H. Forney, Rlll G. Holahan, DRSP J. Wiggins, RI J. Calvo, DOEA J. Callan, RIV C. Hcxie, DOEA H. Miller, Rill R. Emch, DOEA R. Knop, Rll!

T. Ross, DRSP L. Kolonauski, RI S. Hoffman, DRP G. Laines, DRP D. Wigginton, DRSP H. Berkow, DRP J. Thoma DRSP P.,

P.cger. DRP B. Grimes, DRIS

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i 1/29/90 OPERABILITY-AS_SURING THE CAPAblLITY TO PERFON' A SAFETY FUNCTION Introduction

!ssues surrounding the definition arad application of OPERABILITY determinations were discussed in December 1989.

Specific issues as they relate to OPERABILITY are presented herein and when taken together with the :rior guidance to licensees (see references), represent the NRC position.

It is tle licensee's responsibility to make the OPERABILITY determination in a renner consistent with the guidance.

i It is the NRC's responsibility te audit the deten.11 nations and challenge those I

with questionable bases or promptness.

J To the extent that related guidance is under developrent or in trial use, this document should also be considered preliminary.

General Statement The Standard Technical Specifications define OPERABLE or OFERAEILITY es follows:

"A system, subsystem train, component, or device shall be OPERABLE or have OPERABILITYwhenitIscapableofperformingitsspecifiedfunction(s),

and when all recessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are rcquired for the system, subsystem, train, ccaponent, or device toperformitsfunction(s)arealsocapableofperformingtheirrelated support function (s)."

Thepurposeofthetechnicalspecifications(TS)istoreflectthesignificant safety aspects of the design basis and to preserve the validity of the safety analyses.

The design basis and the safety analysis, are concerned with Loth the prevention ar.d mitigation

• of accidents.

It has always been the intent i

that OPERABILITY is to relate directly to the safety capability and deal, therefore, with prevention and/or mitigation whichever is specified for the perticular system, subsystem, train, component, or device in question.

It further follows that since prevention is ongoing and the ability to mitigate raust be continuously assured, the process of determining OPERABILITY for safety or safety support systems is ongoing and continuous.

Processes That involve OPERABILITY Decisions Examples of processes that will all contribute to the continuous / ongoing OPERABILITY decision making process by the licensee include the day-to-day operation of the facility, performance of surveillance requirements especially those required by technical specifications, implementation of programs such as inservice testing and inspection, plant walkdowns or tours, and observations from the control rocm. These are all directly related to assuring the

• For general purposes herein, 1) prevention and mitigation may be referred tc as safety and ?) systems, subsystems, train, component or device may be referred to,Vibe safety context, as safety or safety support systems.

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necessary quality of systems is maintained, that facility operation will be l

within the safety limits, and that limiting conditions of operation will be tiet. An indication that any of these may not be met is indicative of a po-tential deficiency or loss of quality which licenseer, should promptly resolve or confirm. Other prominent and ongoing examples of qualification intensive efforts include design basis reconstitution and Safety System Functional Inspecticns, i.e., their purpose should be to establish or reestablish the quality basis so that, among other things, future technical assesstnents of OPEpABILITY are sound. These efforts, however, may reveal deficiencies and to assure safe 03eration while the corrective ection is pursued, a prompt deter-mination of O'ERABILITY is necessary. Here, as in any operation or program where questions may arise, the safety of the public is assured through the tinely determination of OPERABILITY.

In tht course of activities such as review of operational events, design modifications to facilities, examinations of records, additions to facilities, or perhaps as h result of vendor reviews or inspections, a licensee raay become aware of a potential deficiency or loss of quality related to safety or sefety support systems. These and other paths cf deficiency identifications including reports f rom industry and other utilities, result in the licensee promptly identifying and correcting the deficiency in accordance with 10 CFR Part 50, Appendix B, Criterion XVI " Corrective Actions". The following circumstances require a feri..a1 0FERAtlLITY determination and follow-on correctivo actions:

1.

Discovery of degraded conditions of equipment where performance or potentiel for perfornanct is called into question, E.

Discovery of noncenforming conditions where the qualification (conformance to codes and stardards, etc.) is called into question, or 3.

Discovery of an unanalyzt.d tendition asscciated with the current design basis (i.e., an unanalyzed condition which should have been analyzed).*

The above circumstances and other related concerns are displayed in detail by the enclosed chart.

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PrinciplesFor_DealingWithOPERABIRTYlssues From guidance issued to licensets and the ebove processes depicting required OPERA 51LITY determinations, the following principles are derived for dealing with OPERABILITY issues.

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1.

Focus on safety.

2.

Deal with OPERABILITY and qua_lification separately.

Wn "unanalyzed ccndit.ioni that significantly compromises plant safety" is to be reported by 10 CFR 50.72.

If the unanalyzed ccndition is not pert of the cutient cosien basis, the licu.see may be required to ccrrect thc deficiency throughthebackfitprocess(see10CFR50.109(a)(5)).

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3.

OPERABILITY is the capability to perform its specified function.

4 Qualificationconstitutesconformingtoallaspectsofthedesignbasis i

including codes and standards, design criteria, regulations, etc.

l 5.

Determining OPERABILITY and plant safety is a continuous decision-making l

process.

6.

Timeliness of OPERABILITY determinations should be commensurate with the safety significance of lhe issue.

7.

Timeliness of corrective action (i.e.,10 CFR Part 50 Appendix B, Criteria XVI requirement for " prompt" corrective action) should be commensurate with the safety significance of the corrective action.

8.

" Justifications for Continued Operations (JCOs)" are 'the licensee's technical basis for operating in otherwiseprohibitedn.anner(e.g.,

outsideTS, regulations, license) 9.

Waivers of compliance are NRC's temporary response to JCOs.

Discussion Topics surrounding OPERABILITY Decisions

- Indeterminate A safet function (s) y system is OPERABLE when it is capable of performing its specified l

and when ell its support systems, etc. are also capable of per-forming their related support functions (see definition). Otherwise the system is INOPERABLE. When a licensee has cause to question the OPERABILITY state of o system, the process of determination is to be prompt; the timeliness of the determination commensurate with the potential safety significance of the issue.

The determination process during this time must, however, be based on the licensee's reasonable expectation that the equipment or system is OPERABLE and that the prompt determination process will support that expectation.

If, as a l

result of the prompt determination process, the equipment or system is deter-l mined to be INOPERABLE the licensee's actions are guided by the regulations, TechnicalSpecifications(entertheLCO),plantprocedures,etc.

In addition.

the licensee should determine when and under what circumstances the equipment or system became INOPERABLE so that reporting requirements may be met and NRC followup actions may properly reflect the circumstances and licensees. he-efforts to correct and prevent reoccurreaces. With these determinations, t equipment or system is either OPERABLE or INOPERABLE at all tin,es.- Indeter-minate is not a recognized state in these determinations.

1

'A licensee analysis and determination that operation is acceptable because it remains within the design basis (e.g., because required equi or where allowed, reasonable assurance of safety is assured)pment is OPERABLE is sometimes referred to as a JCO. This other type of JC0 does not require any NRC action.

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- Use of PRA Probabilisticriskassessment(PRA)providesavaluabletoolforrelative evaluation of accident scenarios while considering, among other things, the probabilities of. occurrence of accidents and/or external events. The OPERABILITY j

definition states, however, that the safety or safety support system must be 1

capable of performing its specified function.

The inherent assumption is that-the occurrence conditions or event exists and the safety function (prevention, mitigation,orboth)canbe3erformed. The use of PRA or probabilities is not otherwise acceptable for OPETABILITY decisions.

However, PRA considerations may provide valid and useful information in dealing with continued operation j

inJCOsandNRCresponsestothem)andin 1

with INOPERABLE equipment (i.e.ficance of components and systems.

predetermining the safety signi This latter information is useful in the licensee's defense of the timeliness of OPERABILITY determinations.

-JCOs By the NRC's preferred definition, " Justifications for Continued Operation" (JCOs) are the licensea's technical besis for operating in an otherwise pro-hibited manner and, as such, are submitted to the NRC as a' request for waiver of compliance *.

It may be acceptable to use PRA or probabilities in this JCO.

There is another licensee application of the term "JC0" commonly used to document site decisions and information. A licensee may consider all or a part of the process depicted in the attached chart as a "JC0" to include such things as the basis for OPERABLITY, PRA/ probability projections, corrective action elements, alternative operations, etc. The OPERABILITY basis portion of this "JC0" must be clear and defensible and meet all the standards for an acceptable OPERABILITY determination. There should be no objection to the licensee's use of the term "JC0" in any of these cases as long as the process is appropriate.

. Suryeilla,n,c,e,,T,e,s,t,inq, i,n, S,afety,Ko,de Many systems are designed to operate in bcth a normal mode and accident response or safety mode.

Itispreferablethatthespecifiedfunction(prevention, mitigation, or both) be demonstrated by testing in the safety mode of operation.

However, testing in the normal mode of operation may be required for systems where testing in the safety mode will result in unwarranted safety concerns or y

transients. Conversely for these latter systems, failure in the normal mode of i

operation may imply loss of function in the safety mode and licensees should proceed with a prompt determination of OPERABILITY.

' Temporary Waiver of Compliance may be provided by the Regional Administrator (previously referred to as Enforcement Discretion) or by NRR in advance of an Emergency Technical Specification amendment.

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.TechnicalSp,ecificationOPERABILITYvs._AsyESection_XIOperativecriteria The Technical Specifications sometimes contain limiting values for com onents performance which, if met, will validate the design basis and/or safety ana ysis.

l Where present, these values e.g., pump flow, valve closure time, etc., are OPERABILITY criteria. Codes and standards for these same components, particularly ASME Section XI for pumps and valves, may include different limits on these values which, if met, will assure the operational readiness of the component.

The code limits on these values determine the inservice life of the pump or valveandwhennotmet(seeArticles!WPandIWVofSectionXI)thepumpor valve is declared " inoperative" and not returned to service until corrected.

The impact of the pump or valve being "not in service" and the correction allowed by the Code are factors in determining OPERABILITY of the system.

- Support Equipment Operability The definition of OPERABILITY establishes the principle that a system is OPERABLE when it is capable of performing its specified function and when all necessary support systems are also capable of performing their reTiited support functions. The corollary is that a system is INOPERABLE when it is not capable of performing its specified function which may be the result of a necessary support system not being capable of performing its related support function. A licensee, upon determining that a system is INOPERABLE, must also examine that system's sup) ort functions, if any, to other systems. The support function may be accomplis 1ed by other acceptable alternatives er under certain circumstances may not be required.

It is the licensee's responsibility to male the support function findings and if alternatives are involved, to assure that-the support function as accomplished by the alternative remains within the design basis or that a 10 CFR 50.59 review is performed.

The definition of OPERABILITY affects the manner in which the requirements for a Limiting Condition for Operation (LCO) and its associated remedial actions are applied when a support system is INOPERABLE.

If the licensee determines that a TS system could not perform its intended safety function with an INOPERABLE support system, then the TS LCO must be entered and apprcpriate remedial actions taken. This action shall occur regardless of whether or not the support system is covered by TS.

If the licensee determines that a TS system is capable of performing its intended function with an INOPERABLE support 1

system, then the TS system may be censidered OPERABLE.

However, appropriate corrective action would need to be taken to deal with the support systems INOPERABILITY on a schedule commensurate with the need of the support system.

Moreover, all other TS systems affected by an INOPERABLE support system must be addressed. Though the most limiting or restrictive action would influence the licensee's action, all TS system LCO's must be reviewed for applicability and entered, if appropriate, and necessary remedial actions taken for those systems affected. This may include entering TS 3.0.3 as deemed necessary. This process of one TS or support system being INOPERABLE and affecting the OPERABILITY status of another TS s both or more systems (ystem resulting in entering the LCO action statements for sometimes referred to as cascading) is derived directly from the definition of OPERABLE. The documentation and reporting requirements depend upon the licensee's required actions and the requirements of his license and the regulations.

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0 In addition, if a supported system is declared IN0pERABLE due solely to the support system not being OPERABLE and the support function can be adequately tested upon return to-service, licensees may forego the supported system return-to-service surveillances unless they are actually needed to make an edequate technical assessment of the supported system's capability.

Enclosures:

1 References 2 Chart on " Licensee Actions for Resolution of Degraded or Nonconforming Conditions" i

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References OPERABLE and JCOs 1.

April 10, 1980 Generic Letter on use of the term OPERABLE as it applies to the Single Failure Criteria.

2.

August 26,19831E Information Notice No. 83-E5 ' Operability of Required Auxiliary Equipment"t Indirect Support Equipment Operability.

3.

July 8, 1985 D. Crutchfield memo on " Technical Specification Operability Requirements" 4

May 12, 1986 Inspection and Enforcenient tianuel Part 9900: Technical Guidance on " Standard Technical Specifications STS Section 1, OPERABILITY" 5.

April 7, 1988 Generic Letter 88-07 modified enforcement policy relating to 10 CFR 50.49, " Environmental Qualification of Electrical Equipment important to Safety For Nuclear Power Plants".

6.

April 3, 1989 Generic letter 89-04 " Guidance on Developing Acceptable Inservice Testing Programs.

7.

April 18-20, 1989 G. Holahan presentation at Regulatory Information Conference " Equipment Operebility; Promptly Determining Operability and Establisting Corrective Action Plans For Degraded or Nonconforming Safety Equipment" 8.

July 19, 1989 T. Murley memorandum on " Guidance on Action to be Taken Following Discovery of Potentially Nonconforming Equipment"; Definition of Prompt for Determination of Operable.

9.

August 9,1989 J. Partlow memorandum on Guidance on Licensee Actions That Should Be Taken When Equipment Is Discovered to be Potentially Nonconforming"; Basic Foundation Principal is Prompt Determination of Operable.

(IssuedforTrialUseandDevelopment.)

10.

August 21, 1989 T.HurleylettertoIllinoisPowerCompany(Clinton)on

" Technical Specification Requirements"; Technical Specification Interpretation of Direct and Indirect Support Equipment Operability.

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LICENSEE ACTIONS FOR RESOLUTION OF DEj 1

OPERAtluTY IDENTIFICATION PROMPT FOLLOWUP ACTION DETERMINATION REPORTING DETERMINE REPORTABI IDENTIFY DEGRADED ASSURE PUBUC HEALTH AND SAFEW OPERABLE AND NON-CONFORMING (50.72, 50.73, 50.9(b).

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CONDmONS ADVERSE TECHNICAL TO SAFETY OR QUAUTY SPECIFICATIONS, OF SAFETY OR SAFETY IF IMMEDIATE THREAT!

PART 21 SUPPORT COMPONENTS s

PLACE PLANTIN SAFE OTHER)

OR SYSTEMS TO:

CONDmON e MEET REQUIREMENTS OR OF REGULATIONS MAKE PROMPT DETERMINATION OF OPERABLE:TIMEUNESS e CONFORM TO s

APPUCABLE COMMENSURATE WITH CODES AND POTENTIAL SAFETY STANDARDS SIGNIFICANCE OF THE ISSUE DETERMINE REPORTA9 OT WEMBW e SATISFY UCENSING l-AS ABOVE AND/OR DESIGN PARTICULARLY 50.9(b)

BASIS -

INMATE CORRECTIVE ACTION

• PLAN TO:

e RESOLVE CONDmON ADVERSE TO SAFETY N

e IDENTIFY ROOT CAUSE e PRECLUDE REPETITION OF CONDmON ADVERSE TO QUAUTY NOTE:

BULLETINS AND GENERIC LETTERS, AMONG OTHERS, MAY PROVIDE GUIDANCE SPECIFIC TO AN ISSUE BUT COUNTER TO THE GENERALLY ACCEPTED APPROACH HEREIN. EXAMPLES OF DEVIATIONS FROM THE ABOVE APPROACH INCLUDE GENERIC LETTER 88-07 ON ENVIRONMENTAL QUAUFICATION OF ELECTRICAL EQUIPMENT AND GENERIC LETER 87-02 ON SEISMIC ADEQUACY (SEE USE OF JCO).

• 50.59 MAY BE USED AT ANYTIME TO MAKE A CHANGE IN FACILITY AS DESCRIBED IN SAR WHICH WOULD RESOLVE THE CONDITION ADVERSE TO SAFETY OR QUAUTY SO THAT THE DEGRADED AND NON-CONFORMING CONDmON NO LONGER EXISTS. DELAY OR PARTIAL CORRECTION OF CONDmON ADVERSE TO SAFETY OR QUAUTY IS CONSIDERED A CHANGE IN FACluTY OR PROCEDURES AND SUBJECT TO 50.59 REVIEW.

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' EALTJANUL W a RADED AND NON-CONFORMING CONDmONS LONG TERM DECISION CATEGORY INTERIM OPERATION DEFICIENCY RESOLUTION FOLLOW-UP I

ITY TECHNICAL AUTHORIZED Y

SPECIFICATION BY UCENSE g

NOT TECHNICAL OPERATION SPECIFICATION ACCEPTABLE S

N RESTORE OPERABLE IF NOT TECHNICAL g

NOT OPERABLE SPECIFICATION Y

WHERE REASONABLE ASSURANCE OF SAFETY AND J

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OPERATION ACCEPTABLE PROMPT CORRECTIVE REVISE AND/OR DURING CORRECTIVE O

ACTION

• PER APPENDIX

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EXIST UPDATE PROGRAM ACTION B (TIMEUNESS DOCUMENTATION OR COMMENSURATE WITH h AS NECESSARY

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DOES NOT EXIST F CO DmON GN CE OF THE PARTICULARLY CORRECTIVE ACTION),

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e.g., REPAIR OR l

TECHNICAL ONLY AS ALLOWED BY REPl.ACEMENT, PERFORM

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ANALYSIS OR TEST, SPECIFICATION hSTAL FOLLOW LCO ACTION CONDmON g UF1 TlON OR r

OBTAIN LCO OR OTHER REUEF SUBMU TO NRR:

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1) EMERGENCY TS AMENDMENT (AND APFRTURE

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2) JCO FOR CONTINGENT UPON

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NRR ACTION TEMPORARY WAIVER OF Also Availabic On COMPUANCE Aperture Card-SUBMIT TO REGION:

1) JCO" FOR CONTINGENT UPON

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TEMPORARY REGIONAL ACTION

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WAIVER OF COMPLIANCE 90bMn103lo O\\

5 3 JUSTIFICATION FOR CONTINUED OPERATION (JCO) TO COVER PERIOD 50.59(c) AMENDMENTISIN ACCORDANCE FROM IDENTIFICATION OF ADVERSE CONDITION UNTIL CORRECTED OR WITH 50.90; HOWEVER, CODE REUEF MAY UNTilTECHNICAL SPECIFICATION APPROVAL BY NRR.

BE OBTAINED PURSUANT TO 50.55a AND AN EXEMPTION PROVIDED PURSUANT TO 50.12 WHERE APPLICABLE.

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