ML20125E079
| ML20125E079 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 01/07/1980 |
| From: | Satterfield R Office of Nuclear Reactor Regulation |
| To: | Brinkmon D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243 NUDOCS 8001290013 | |
| Download: ML20125E079 (13) | |
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WASHINGTON, D. C. 20555
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JAN 7 1930 MEMORANDUli FOR:
D. S. Brinkman, Acting Group Leader Standard Technical Specification Group, D0R FR0ft:
R.11. Satterfield, Chief Instrumentation & Control Systems Branch, DSS
SUBJECT:
CHANGES TO SEQUOYAH UNIT 1 TECHNICAL SPECIFICATION The enclosure presents our recommended chances.to the Sequoyah Unit 1 Technical Specifications and identifies some areas of concern and~ presents l
our recorr.endations regarding potential generic changes to the Westinghouse Standard Technical Specifications.
n R. II. 'Satterfield, Chief Instrumentation & Control Systems Branch Division of Systems Safety
Enclosure:
As stated cc:
T. Dunning D. Lasher 1 P m
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ENCLOSURE 1.
We note that the usage of the term " allowable value" in Table 2.2-1 and in the discussion of Section B-2-2 does not confom completely with the recommenpations of positions C1 and C6 of Regulatory Guide 1.105.
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" allowable value" as used in this technical specification includes only a small allowance for drift and therefore, does not address instrument accuracy or the other errors identified in Regulatory Guide 1.105. However, we further note that the licensee has committed. to conform fully with the reco=endations of Regulatory Guide 1.105 regarding instrument setpoints ririor to resuming operation following the first refueling outage.
It should be determined that the " trip setpoint" value includes sufficient margin to cover the instrument errors and limiting value uncertainties.
2.
In Table 3.3-2 the entry "Not Applicaole" is used several places instead of a value for the response time.
This usage is unacceptable for the following items since credit is taken for their operation in the accident 4
analyses.
a.
Item 3 - Power Range Neutron Flux, H'igh Positive ' Rate.
b.
Item 5 - Intermediate Range Neutron Flux c.
Item 6 - Source Range Neutron Flux d.
Item 8 - Overpower aT
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e.
Item 11 - Pressurizer Water Level - High f.
Item 15 - Steam /Feedwater Flow Mismatch; Low Steam Generator Water Level g.
Item 18 - Turbine Trip Provide response time values for these functions.
3.
Itens 3, 4,16,17, and 18 of Table 4.3-1 show the entry "NA" for channel check frequencies.
Provide values for check frequencies or Justify why no routine channel check is needed.
4.
For Table 3.3-3, Action Statement 15 states that one channel nay be bypassed for up to one hour for testing.
This could be interpreted to allow the remaining operable channel to be bypassed for up to an hour.
This statement should be modified to avoid this possible misinterpretation.
We suggest:
---; however, with the number of operable channels equal to the Total Number of Channels, one channel may be bypassed'for up to one hour for surveillance testing per specification 4.3.2.1.1."
5.
Table 3.3-4, Items 3.c.3, 4 do not have drift allowances for the Containment Gas Monitor and Containment Purge Air Exhaust Monitor high radioactivity setpoi nts.
Provide revised input showing drift allowances for these two
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functions or justify whey they are not needed.
6.
Items 6(c) and 7(a 1, 2) no allowance is made for drift in the zero voltage setpoint.
Provide information showing the drift allowance or explain and justify why an allowance for drift in the zero voltage setpoint is not needed.
t 7.
We note that Item 10 of Table 3.3-5 uses the term " Station Blackout" to refer to a loss of offsite power.
This is confusing since the term " Station Blackout" normally means a total loss of AC power both onsite and offsite.
We recommend that this item be redesignated as " Loss of Offsite Power".
8.
Table 4.3-2, Item 6(c) should also be redesignated " Loss of Offsite Power" to avoid confusion.
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Items 2(a) and 2(b) of Table 3.3-6 should be provided with factt l
enable conversion from uCi/cc to cpm.
L 10.
The Source Range Nuclear Flux Monitor, as shown by the entry in Table 4.3-6, is not subjected to a periodic channel calibration.
Since l
credit is taken for the operation of this monitor to provide a high flux at shutdown alarm to initiate action to control a Baron Dilution event we require that such surveillance be performed on this monitor.
Table 4.3-6 shall be revised to conform to this requirement.
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11.
(a) Technical Soecification 3.3.3.6 coes not require the chlorine monitors I
in the main control room ventilation intake to remain operable during I
l modes 5 and 6.
We believe that these monitors should be operable during h
any time that operators are on duty in the main control room including the time during modes 5 and 6.
The Standard Technical Specification
's should be revised to require this extended operability.
(b) Provide the basis for the choice of a 7 day outage allowance.
It does not appear reasonable that 7 days should be required to restore the inoperable detector to operable condition.
12.
(a) Table 3.3-5, Item 7b contains +%2 entry "Not Applicable" for response ti me.
This is not accentth'a 5 nce there are three control air lines that must close and the cemau/a,g 32 liquid line valves listed in Table 3.6-2 must also close in response to a phase B isolation signal.
Revise this entry to consider response times for the three air line valves separately from the response times for the liquid line valves and to supply times for the isolation of these two classes of lines.
(b) Table 3.3-5, Item 7d should have the response time specified as 600 1 10 seconds.
The table entry specifies any time less than 61' seconds as acceptable, however, the accident analysis specifies an actuation time of 600 seconds and allows an error band of i 10 seconds.
(c) Table 3.3-5 is also incomplete because it does not include the response time for Containment Ventilation isolation that is initiated by a high radiation signal from the Containment Purge Radiation Monitor.
The table and the Technical Specification should be revised to incidde this requirement and supply the required response time.
13.
Technical Specification 3.3.3.7 allows Post-Accident monitoring channels to remain inoperable for up to 30 days.
This is not conservative because (a) it' allows plant operation with degraded PAM capability for a much
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and (b) All PAM channels could be out of service since there is no stated limit to the number of allowable inoperable channels. This Action state-ment should be revised to shorten the allowable out-of-service time and to limit the number of out of service channels to one.
The revision should also establish applicability in modes 4 and 5.
14.
(a) Table 3.3-10, Items 1 and 2, the wide range Reactor Coolant THOT and T
measurements show only a total of two sets of T and T COLD H0T COLD measuring instruments.
This is not acceptable since these instruments are used to verify the establishment of natural circulation cooling of the core in certain accidents and the minimum number of operable channels would be one per primary loop.
The Technical Specification should be revised to cover the requirenents of a four loop reactor coolant system.
(b) Specify whether the pressurizer level measurement is wide or narrow range.
15.
(a) Technical Specification 3.6.4.1 allows one of the hydrogen analyzers
' to remain inoperable for up to 30 days. We believe this is a far longer outage time than is needed to restore the inoperable analyzer to operable condition.
This specification's action statement should be revised to shorten the allowable out of service time.
(b) The applicability statement limits the application to modes I and 2 on,1y.
Mode 3 also involves high primary coolant temperatures and pressures and could also presumably give rise to metal - water reactions with consequent release of hydrogen under accident conditions.
We believe it prudent to extend the applicability to Mode 3 and to appropriately modify the action statement to require going to Hot Shutdown rather tnan Hot Standby.
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- 16. Technical Specification 3.8.1.1 (ch state the basis for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance for restoration of one offsite power source.
17.
Item (d) of Technical Specification 3.8.1.1 Action Statement is confusing regarding the combinations of diesel generators that are allowed to be t
inoperable. This statement should be clarified by use of a table to show the various comb'inations of diesel generators that ray beinoperable.
- 18. The applicant's proposed changes to the Action Statement of Technical Specification 3.8.2.1 as included in the 8/8/79 package is incomplete because it does not specify acceptable actions to be taken in the event of loss of onsite or offsite power to be boards.
Also as written it could be interpreted to allow the icss of redundant boards for up to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
Suggest it be revised as follows;
6-
"(a) 1.
With less than the above complement of shutdown boards operable for reasons other than loss of their related onsite and/or offsite power sources, restore the inoperable board to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in' Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
2.
With less than the above' complement of shutdown boards operable due to loss of their related onsite an'd/or offsite power sources, take the action required by Technical Specifications _3.8.1.1.
(b) With one of the above listed Vital Instrument Power Boards and/or its related inverter inoperable, either :
1.
Restore the inoperable board and/or its inverter to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, or 2.
If the Vital Instrument Power Board is operable, energize it via an operable maintenance supply transfer switch within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; operation may then continue for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from time of initial loss, otherwise be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30. hours.
(c) With more than one of the above Vital Instrument Power Boards and/or their related inverters inoperable, restore the inoperable boards and/or inverters to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
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19.
(a) Technical Specification 3.8.2.2 is incomplete because it does not include all combinations of the 6900 volt shutdown boards.
Combinations 1A-A and 2B-B or IB-B and 2A-A should also be acceptable.
(b) The Action statement places no limit on how long the AC boards can remain in an inoperable status nor does it require cessation of operations involving. core alterations or positive reactivity changes. We suggest tnat the Action statement be revised as fo.llows:
"With less than the above complement of AC boards operable immediately suspend all operations involving Core Alterations or positive reactivity changes 'and establish Containment Integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />." We further suggest that consideration be given to how long the boards can remain out of service without alternate measures being taken to supply essential cooling loads, 4
etc.
- 20. These comments are on the proposal for revision of Technical Specification 4
3.8.2.3 received from the licensee at the December 6,1979 meeting. We assume that this proposal supersedes the.three previous proposals.
(a) Rewrite parts (a) and (b) of the Action statement to read:
"(a) with less than the above listed complement of battery boards operable, restore the inoperable board (s) to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at lea'st Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
(b) Redesignate parts (c) and (d) as parts (b) and (c) of the Action statement. These two parts of the Action statement will be acceptable only if it can be demonstrated that no safety-related D.C. power feeds to Unit 1 D.C. loads are supplied from Batteries and Boards III and IV.
Presently, we have identified the following loads and feeds that do not conform to this position:
(a)
The Unit I turbine - driven Auxiliary Feedwater Pump controls are D.C.
operated and derive their power from passive battery boards III and IV.
(b) The Unit II turbine - driven Auxiliary Feedaater Pump similarly devices its D.C. control power from battery boards I and II. These loads must be appropriately unitized to make new parts (b) and (c) of the Action statement acceptable.
21.
Surveillance requirement 4.8.1.1.2.d should have the words "both" changed to "the" in two places to read thus:
--- by starting the diesel generators
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, and "--- verifying that the diesel generators accelerate --."
22.
Surveillance requirement 4.8.1.1.3.a.3 < states that the pilot cell specific gravity must be > 1.195 but it is not clear that this value is applicable to the particular battery type installed at Sequoyah.
These batteries have a nominal specific gravity value of 1.220 at full charge and 1.195 would appear to be indicative of a partially discharged state.
The pilot cell specific
's gravity value should be relatable to the acceptance test value and the battery life.
23.
Surveillance requirement 4.8.1.1.3.a.4 states the pilot cell voltage must be > 2.05 volts, however, this value is not consistent with a minimum battery terminal voltage of 125 volts.
24.
The average specific gravity ofl.195 given in surveillance requirement 4.8.1.1.3.b.2 does not appear to apply to the battery type installed at Sequoyah since these batteries have a nominal specific gravity value of 1.220 at full charge.
Also these values should be relatable to the accep-tanc test values and limits should be placed on the loss of specific gravity from the acceptance test value.
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- 25. Surveillance requirement 4.8.1.1.3.b.5 may not be possible of performance because the Diesel Generator battery is composed of 10 un'its, each containing 6 cells in a corar.i case,and the individual cell teminals may not be accessible for measurement.
(12/6) 26.
Surveillance requirements 4.8.1.1.3.c.2, 3 should be written as "The bolted cell-to-cell arid terminal connections -- " and "--- resistance of each bolted cell-to-cell and terminal --."
(12/6) 27.
Surveillance requirement 4.8.2.3.1 includes the phrase" --- with tie breakers open --
." Sequoyah has no ties between the batteries, their buses or their boards.
This phrase is misleading, could be interpreted to mean that we allow such ties between redundant battery systems, and should be deleted.
'"/6)
- 28. Why eliminate surveillance requirement 4.8.2.3.2 item a.4 and add i t to 4.8.2.3.1?
If it is needed for 4.8.2.3.1 add it but leave it as item a.4 of 4.8.2.3.2.
(12/6)
- 29. Surveillance requirement 4.8.2.3.2.a.2 does not include the earlier requirement that if the pilot cell specific gravity is less than 1.195, surveillance requirement 4.8.2.3.2.b is to be performed immediately.
This omission should be corrected.
(12/5) 30.
For both parts (a) and (b) of surveillance requirement 4.S.2.3.2 verify that the cell voltage of 2.05 volts and the specific gravity value of 1.195 have been determined from actual tests performed on the as installed battery in its servicable, design condition and that the cell voltage as measured during the acceptance test is compatible with 2.05 volts as a lower limit.
The value of 1.195 for the minimum specific gravity should be determined to be compatible as a lower limit with the actual value of specific gravity recorded as acceptable for the acceptance test.
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- 31. Surveillance requirement 4.8.2.3.2.b.4 does not place a specific limit on on the cumulative decrease in specific gravity from test to test but rather implies a limit as being 1.185 as a minimum (averagt sp. gr.
.010).
It should be shown thatthis constitutes an acceptable lower limit based on the battery design and the full charge specific gravity as measured under equil brium conditions during the acceptance tests.
32.
For surveillance requirement 4.8.2.3.2.d confirm that the battery service test performed at least once per 18 months will be conducted only during shutdown.
There was some discrepancy between the various versions submitted for our review.
If the service test is conducted during plant operation, describe the procedures to be used and provide justification showing why it is acceptable to have one of the vitial 125V batteries out of service for an extended period during plant operation.
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33.
From the bases, part 3/4.8.3, page B 3/4-8-1 we have determined that a table listing all the electrical circuits that penetrate the containment and are protected by deenergizing during certain modes of operation should be provided as part of Technical Specification 3.8.3.1.
This table should specify the modes during which each circuit is deenergized to protect the containment penetrations.
Our review should assure that these circuits are required to be deenergized during any condition that requires containment integrity to be maintained.
34 We recomrnend ' changing surveillance requirement 4.8.3.1.a.1(b) to read as follows :
"An integrated system functional test which applies simulated overcurrents to the current transformers that generate the overcurrent trip signals for the containment penetration primary and backup protective circuit breakers shall be performed.
These tests shall demonstrate the proper automatic actuation of the protective devices including verifica-
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tion of breaker clearing times and that each relay, associated circuie breaker and control circuit functions as designed and as specified in Table 3.8-1."
35.
We recommend that Item a.2 of surveillance requirement 4.8.3.1 be revised to read as follows:
"a.2(a) For molded case and low voltage metal -
enclosed direct trip circuit breakers, by performance of a functional test of at least one circuit breaker of each type, such that all circuit breakers of each type are demonstrated operable at least once per N X18 months where N is the number of circuit breakers of each type. This functional test shall consist of injecting a current input at the specified setpoint to the circuit breaker and verifying that the circuit breaker functions as designed.
Should any tested circuit breaker fail to function as designed, all other circuit breakers of that type snall be tested.
a.2(b) For low voltage metal-enclosed indirect trip circuit breakers, by performance of an integrated system functional test as outlined in 4.8.3.1.a.1(a) of at least one circuit g
breaker of each type.
This testing shall ensure that all circuit breakers of each type are demonstrated operable at least once per N X 18 months where H is the number of circuit breakers of each type.
Should a tested circuit breaker fail to function as designed, all other circuit breakers of that type shall be tested."
36.
Our review of Table 3.8-1 has generated these concerns:
(1) On page 3/4 8-15 the four 6.9KV RCp primary breakers are stated to have a response time of less than 1 cycle (.015 sec.). This appears to be unusually fast since most air circuit breakers of that class require 4 to 6 cycles (.067 to.1 sec) to open, please clarify what this
" response time" includes.
Notes should be appended to tne tarie to show the correlation between these values and the time for which the penetration is qualified to carry the overcurrent.
(2)
The _ trip setpoint of 90 amperes for the containment air return. fans e
seems inconsistent with the current limiting fuse for 4/0 cable since current limit fuses for 1/0 cable are specified elsewhere for 90 ampere trip settings.
Please clarify and justify.
(3) Breaker 54-4c/B2 controlling -the reactor building crane is set to trip at 300 amperes.
Clarify if this is one of those to be disconnected when containment integrity is required.,
(4)
Some discrepancies in Table 3.8-1 exist in the primary profective device trip settings for the Ice Condenser Air Handling Units.
Two entries specify trip settings of 110 amperes while entries for the other two apparently identical units specify trip settings of 150 ampe res.
Clarify and correct these discrepanciss.
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S. E. Eryan, A/D for ield Coordiaation, Division of Rea: tor Operations :nspection, IE:HQ FRO:':
E. ^. M:Cabe, Chief, ?.eactor Projects Section No. 2, RO&f;S Eranc7, R:
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E. J. Brur.ner, _ Chief, RC&!LS 3 ranch, RI SU5 JECT:
STA';DAFJ TECHNICA!. S?ECIFICATION CHANGE (AITS F01004202)
FWR and BWR Standard Tec.nical S;ecificatien 3.0.3 states in part that, if an LCO and its action s: ate ents are ex:eeded, the facility shall be placed in. Hot Standby within c1e hour lPWR,' or six hcurs (BWR) of discovery of this condition.
Startine the tire clock #or shutdown u;or. " discovery" of the exceeding of an LCO is valic for e:cip e.t rrilfu.ctions because design conservatism, redundancy ar.d prescribed sur.eilla;ce tests are ac:e;ted safeguards for such events.
- But, c;sratir; ere:r is diffe e.t.
I; car cause, and has caused, unacceptable loss of safety func:ian.
That breach of safety begins when the operating error is -
effectec, nct when it is dis: overed.
It follows, therefore, that licensees should be held a:cou-tab:e f:r such breaches from the time of discovery.
Another sigr.ificant asse:t is that, frcm a safety viewpoint, a normal reactor shutdowr. ac; ears preferasle to a piart trip or scrac.
This factor indicates that a r.or al shatdoan should be pursued even if discovery of the exceeding of an LCO is belated.
The differen:e between the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> PWE shutdown and the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> BWR shutdown is also of concar.
Since 3WRs insert control rods individually, their normal shutdowr. does require rcre time. Eut, a significant SWR power reduction can be made by redu:ing recirculation ficw, anc the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time period does appear to permit urne:essar/ operation cucside the er.velope defined as safe. Moreover, tne safety hazard involved a: pears te be a direct function of power history, power level, and duraticr. cf tini cu: side the defined safe envelope.
It con-sequently a:: ears that t.e perr.issible operating times ou: side an LCO should be similar f:r 5:t'. ?';?.s ar.d S'.:R:.
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~L Recorrer.ded Standard Technical Scecification 3.0.3 "3.0.3 In the ever.t. Limiting Condition for Operation and/or associated ACTICS requirerer.cs car.r.ct be satisfied because of circumstances in excess of these addressed in the specification, a norcal reactor shutdown shall be imrieciately initia:sc and pursusd to expeditious completion.
The following establish full com;1ian:e with this shutdown requirement.
Reducticn of power below 50% of authorized power within one hour of a.
establishrent of the condition in excess of those addressed in the specifi-cation, with the facility to be placed in at least. HOT STANDBY within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and in CD D S"UTDOWN with the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless cor-rective measures are c:mpleted to permit op'eration under the permissible ACTION statements for :he specified tire interval as measured from the instant of establishre-t of the condition which exce'.ds the Linnting Con-dition for Operati:n ar.d/or its associated ACTION requirements, b.
Establishrent of a condition which exceeds a Limiting Condition for 0;eration and/or i:s associatec ACTION requirements is deemed to occur at the following ir.stants.
(1)
For condi-ion established by material malfunction, at the time of discovery of -he ralfunction or at the expiration of the permissible interval between successive required surveillance tests, whichever cccurs first.
(2)
For condi-icn estsblished by operating error, at the tire the condi-tion is imposed u;on the facility.
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y MEMORA'.DL'M FOR:
W. P. Ga. mill, A/D for Operating Reactor Projects, 00R, NP.R FROM:
Sa.muel E. Bryan, A/D for Field Coordination, ORDI, IE SUEJECT:
PROF 05ED REVISION - ACTIO.*i STATEMENTS IN STANDARD TECH'il:AL SPECIFICATI0';S (STS) 3.0.3 AND INDIVIDUAL TS Based en recent infor=ation from cur Region I office and previous information frcm c:her ' Regional offices, it is evident that the action statement language in facility TS needs clarification. This is needed to more clearly identify the NRC policy regarding time requirecer.ts for initiating hot standby and hot shutdo..n action state ent requiremer.ts when a system is found to be out of service because of persennel or procecure error vice equipment malfunction.
It appears that a number of licensees de not distinguish between the two failure moces.
In Our view the following basic philosophy applies to the cer.eral lancuace in 3.0.3 of the STS and the variations used in individual TS, e.g., aitien 1 on page 3/4 3-7 cf the W STS.
1.
?clicaing disco /ery of an out of service system, licensee personnel shcald promotly ascertain whether the system is covered by.TS action sta:e ent re:;uirements and whether the event rAsulted from equipment calfuncti:n or personnel error.
2.
If the event was caused by equipment calfunction, the clock for entry into the het standby mode shoulc start when the event is detected and the clock for initiating hot sht.tdov.n actions should start upon entry into the het stancby mode.
3.
For those cases where the event is attributed to personnel or procecural errcr, e.g., switch; ear in wrong positica, not fully racked in position, etc., the clock should start when the personnel or procedural error i
was made based on the following qualifications:
Fcr these cases where the tine limit for returning the system a.
te ar, c;erable status prior to entering h0t standby mode has not ex:: ired, the licensee has that fraction of time remaining to ccm;lete the effort, enter hot standby mode and if necessary start tne clock that governs hot shu:dcwn actions.
- . TACT:
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FEB 211980 W. P. Gamill -
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For these cases where the hot standby acticn time has elapsed and hot shutdown action should have been int ated and/or co aleted, the licensee should initiate prorapt action to achieve hot shutdown status within the minimum time required for this action. -Information discussed in the last para-crtph, page 1 of the enclosed memorandum from our Region I office indicates that a significant SWR power reduction can be achieved by reducing recirculatien flow.
Of course when the cor.dition is corrected, action to restore power to normal may begin upon correcticn.
'rle recerend that the STS be revised to reflect the above philosophy and that TS for all operating facilities be revised accordingly. My staff and I will be pleased te work with you in the development of appropriate TS language.
Samuel E. Bryan e
Assistant Director for Field Coordination Division of Reactor Operations Inspection, IE Encles'.re :
- '.e.orar3 m datsd 1/23/20 cc
E. C. McCabe, RI D. Erink,ti, MR/STS E. C. Brurner, RI R. C. Lewis, RII R. F. Meishman, RIII G. L. Madren, RIV J. L. Crev.s, P.V F. J. Nolan, IE J. I. Riesland, IE l
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q+5.,f MAR 171930 S S It'S No.~602E MEMORAfiDUM FCR:
R. C. Lewis, Acting Chief, ROLNS Branch, Region II FROM:
Samuel E. Bryan, A/D for Field Coordination, DROI, IE
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SUBJECT:
OPERABILITY REQUIREMENTS FOR PUMPS (AITS NO. F02-700028-H07)
As we understand them, the questions in your February 1 memo are:
1.
Do the Technical Specification ACTION statement time periods run consecutive er concurrently with the data evaluation time (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />) given in IWP-3220 of Section XI of the ASME Boiler and Pressure Vessel
~ Code,.1974 Edition with Addenda thru the Summer 1975, and 2.
When should the test results be reviewed and, if out-of-specification, the associated pump declared inoperable?
The answer to the first question is the Technical Specification ACTION statie-ment time. period starts after the determination is made that the pump is inoperatile as defined in 5eccion XI,.IWP-3230(c).
If the data is within the.
Required Action Range of Table IWP-3100-2 and it is decided to recalibrate the instruments and rerun the test, as provided for in IWP-3230(b), the Technical Specification ACTION statement time starts when the determination is made that the data is within th'e Required Action Range. The reasoning behind the preceeding statement is that once the determination is made that the data is within the Required Action Range the pump must be declared inoperable. The provisions in IWP-3230 to recalibrate and rerun the test to show the pump is still capable of fulfilling its function are interpreted by us as an alternative to replacement or repair, not an. additional action that can be taken before declaring the pump. inoperable.
The answer to the second question is that as soon as the data is recognized as being within the Required Action Range the pump must be declared inoperable.
Section XI, I'J -6230, " Inservice Test Plans", states tnat the test plan shall include "The reference values (Table IWP-3100-1), limits of Pi and Tb (Table IWP-3100-2), ar.d any other values required by this Subsection." This statement CC:: TACT:
J. C. Stone, IE (G1-3019) qD4%WD k,
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R. C. Lewis MAR 171980
.then requires the acceptance criteria to be included in the test plan.
With that information'available, the shift supervisor should be able to make the determination as to whether or not the data meets the requirements.
The important point is that once the data becomes available that shows the pump cannot meet the inservice inspection requirements and by definition cannot fulfill its function then the pump must be declared inoperable.
We have discussed the above' interpretations with 00R personnel and the Standard Technical Spicification Group and they agree.
If you have any
~
further questions, please call.
9V" Samue E. Bryant Assistant Direc or for Field Coordination Division of Reactor Operations Inspection, IE cc:
N. C. Moseley, IE J. S. Wetmore, STS G. Johnson, EB J.-C. Stone, IE F. J. Nolan, IE J. I. Riesland, IE B. R. Messitt, RII E. J. Brunner, RI R. F. Heishman, RIII G. L. Madsen, RIV J. L. Crews, RV b
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