ML20126D303
| ML20126D303 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/01/1980 |
| From: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Bryan S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20126D306 | List: |
| References | |
| NUDOCS 8004250217 | |
| Download: ML20126D303 (3) | |
Text
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UNITED STATIS h ' f/
g NUCLEAR REGULATORY COMMISSION C*
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tel MaeleTTA Sr. N.W SulTs 31es ATLANTA. eaosetA 30300
- eeee FEB 0 t 1980 SSINS 6025 MINORANDtM FOR:
- 3. E. Bryan, Division of Reactor Operations Inspection, Office of Inspection and Enforcemmat FRON:
R. C. Lewis, t.cting Chief, Reactor Operations and Nuclear a
j Support Branch, Regina II SURJECTs CFERABILITT REQUIREMENTS (AITS No. F02700028)
A concars was recently identified involving the starting point for time periods la Technical Specification ACTION neatements.when equipment has been declared inoperable under the ASME Section XI testing program.
ASNI section II, IvP-3220, states "All test data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completics of a test".
Iwp-3230(c) states, in part, "If the deviations fall within the ' Required Action Range' of Table IWF-3100-2, the pump shall be declared inoperative....."
la most cases equipseat covered by ASME Section XI, IVP, is also covered by Technical Specifications and, if, declared inoperable, would result in the plant entering an ACTION statement. These ACTION statements generally have a time period af ter which, if the equipeent is still inoperable, the plaat must perform some specific action (shutdown, cool down, etc.).
The concern arises in the area of the aforementioned data analysis interval versua the Technical Specification ACTION statement time period.
It is questionable whether or not these periods run consecutively, concurrently or otherwise. The enclosed scenario's detail likely plant events and are ladicative of actual experience.
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Region II believes that a reasonable time for data analysis is not more than two shif ts (16 hcurs) except in entreme circumstances. The Technical Specification ACTION time should start immediataly af ter the data has been reviewed by the cognisant supervisor (shif t supervisor.
foremen,etc.). Licensee procedures must requira prompt review by the cognisant supervisor when test results fall outside acceptance criteria.
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1 We do not br.lieve that ASME Section XI state:nent on evaluation of test data relieves the licenses of action statements in Technical Specificacicas.
W request that this matter be reviewed and our understanding be ccafirmed er guidance issued to provide uniformity.
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i R. C. Lewis, Acting Chief Reactor Operations and Nucisar i
Support Branch l
l Enclosuret Field Emperience Regarding l
Equipment Operability l
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I DICT.0SimE FIELD EXPERIENCES RICARDING EQUIPMENT OPERABILITT i
d A Sectica XI test is run on an engineered safety feature pump on 1.
Saturday mooring and the data f all on the lowest limit of the i
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" Required Action Range" just above the " Alert Range". 'the plant Forformance Engineer, who performs the data review and would be the individual to declare the pump inoperative, is not on site until Monday morning when the data set is reviewed.
On Monday, the Performance Engineer reviews the data and declares the pump taoperable per the Technical Specifications and thus
" starts the clock" on the ACTION statement time period.
Most Licensees would view this as acceptable due to the 96-hour statement included la IVP.
2.
A safety-related ptsey is tested and the data f all within the "liequired Action Range"*the Performance Engineer orders that the j
instruments be recalibrated (24-36 hours) and the test re-run as allowed by IVP-3230(b). The test is re-run and the data are still is the " Required Action Range". The Performance Engineer declares the pump inoperable and " starts the clock".
This might be done la order to extend operation until a scheduled outage.
i 3.
A safety-related pissp is tested and the shif t supervisot notes that the data appears to f all into the " Required Action Range": however, he feats it should be further analysed. The data are transmitted l
to the Performance tagineer who waits 2-3 dayr to make his analysis and then declares the pump inoperable thus " starting the clock" I,
(at this point he could also request the test be re-run, adding more time to the cycle).
This also might be done to extend operations until a scheduled outage or to delay plant shutdown until the weekend.
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