ML20126H736
| ML20126H736 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/06/1985 |
| From: | Thompson H Office of Nuclear Reactor Regulation |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.6, TASK-TM NUDOCS 8506180433 | |
| Download: ML20126H736 (4) | |
Text
"
June 6, 1985 s
Distribution.
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""NRC"PDR L PDR ORB #1 RDG Memo file MEMORANDUM FOR:
R. L. Spessard, Director HThompson Glainas Division of Reactor Safety, JNorris SVarga Region III GHolahan EButcher FROM:
Hugh L. Thompson, Jr., Director Division of Licensing, Office of Nuclear Reactor Regulation
SUBJECT:
ZION 1 AND 2 -- INDEPENDENT VERIFICATION OF TAGGING EQUIPMENT 00T OF SERVICE TIA Task No. 85-17 requests our assistance in providing to Region III (1) our interpretation of requirements of NUREG-0737 Section I.C 6 relative to independent verification of tagging equipment out of service and-(2) our assessment of whether Zion verification practices satisfy I.C.6.
The documentation regarding this matter is composed of a Fet'ruary 23, 1985 memorandum from R. L. Spessard to H. L. Thompson, with anclosures. We have reviewed that documentation and provide below our evaluation.
We note that the word "should" as used in the ANSI Standard is defined to mean a recommendation. A similar connotation applies to the word "should" as used by the NRC staff. The words "where appropriate" are undefined in the ANSI Standard and thus are vague as to their precise meaning.
The licensee correctly notes that the 1972 version of the ANSI Standard, to which the licensee is committed, requires " independent verification, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented correctly." These same words are continued in the 1976 version of the Standard (5.2.6). Thus, in our view, the licensee was not committed to provide independent verification of tag-out of equipment important to safety unless he chose to interpret the words "where appropriate" as including such equipment.
Common sense and actual experience tell us, however, that unsafe conditions can develop when the wrong equipment is tagged out of service as well as when equipment is being put back into service. Therefore, we believe that independent verification is needed to assure that the proper equipment has been tagged out. That position is reinforced, we believe, by the 1982 version of ANSI /ANS 3.2.
The applicable section (5.2.6) of this version presents a significantly strongar, more positive, statement concerning this matter than did the 1972 version to which the licensee had comitted.
The appropriate portion is quoted below.
"When a system important to safety is removed from service, independent verification shall be provided to the extent necessary to assure that the proper system was removed. This may be accomplished by checking appropriate equipment and controls, or by indirect means such as observation of indicators and status-lights.
This requirement may be waived if the only way of accomplishing it would result in significant radiation exposure."
CONTACT:
J. Norris 8506180433 850606 29774 hDR ADOCK 050 5
s Mr. Spessard June 6, 1985 We note that the licensee has comitted to " require independent verification of proper system line-up on safety-related systems / components at the time the equipment is removed from service", see the licensee's letter of February 19, 1985; Enclosure 5 to Mr. Spessard's 2/28/85 request to Mr. Thompson.
It appears that Comonwealth Edison Company has seen the desirability of such verification.
In sumary, we feel that comitment to ANSI N18.7-1972 does not comit a i
licensee to independent verification of equipment tag out. The wording of the Standard certainly suggests that such independent verification be performed, but it does not require it. The wording of NUREG-0737 also
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strongly suggests that independent verification of equipment tag out be performed, but does not require it. We, thus, conclude that the licensee is correct in his contention that the charge of noncompliance is incorrect and should be withdrawn. At the same time, however, we feel that independent verification of the correctness of tag-out of equipment important to safety is an important step that should be taken by all licensees. We are pleased to note that Comonwealth Edison has comitted to change the procedures at all of its nuclear stations to require such independent verification in the future.
Original 1;igned by Hugh L Thompson, Jr.
Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation cc:
H. Denton D. Crutchfield G. Holahan E. Butcher S. Varga J. Norris T. Murley, RI J. N. Grace, RII J. Keppler, RIII R. Martin, RIV J. Martin, RV J. Taylor, IE
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We note that the licensee has committed to " require independen verification of proper system line-up on safety-related systems / component, at the time the equipment is removed from service", see the licensee'Vletter of February 19, 1985; Enclosure 5 to Mr. Spessard's 2/28/
request to Mr. Thompson.
It appears that Comonwealth Edison Co pany has seen the desirebility of such verification.
In summary, we feel that commitment to ANSI N18 -1972 does not commit a licensee to independent verification of equip t tag out. The wording of the Standard certainly suggests that such in pendent verification be performed, but it does not require it. The ording of huREG-0737 also strongly suggests that independent verifi tion of equipment tag out be performed, but does not require it. We, hus, conclude that the licensee t is correct in his contention that the c arge of noncompliance is incorrect and should be withdrawn. At the same ime, however, we feel that independent verification of the corr tness of tag-out of equipment important to safety is an important step that should be taken by all licensees. We are pleased to not that Commonwealth Edison has committed to change the procedures at all its nuclear stations to require such independent verification in the uture.
This memorandum closes TIA Ta No. 85-17. Because of generic implications of our position in this matt, we are sending copies of this memorandum to other Regions and to IE.
Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation cc:
D. Crutchfield G. Holahan E. Butcher S. Varga J. Norris T. Murley, RI J. N. Grace, RI J. Keppler, RII R. Martin, RIV J. Martin, RV J. Taylor, IE
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D Mr. Spessard We note that the licensee has committed to "r uire independent verification of proper system line-up on safety-related s tems/ components at the time the equipment is removed from service", see the licensee's letter of Februa ry 19, 1985; Enclosure 5 to Mr. Spe ard's 2/28/85 request to Mr. Thompson.
It appears that Commonwea h Edison Company has seen the desirability of such verification.
~In summary, we feel that commitment ANSI N18.7-1972 does not commit a licensee to independent verificatio of equipment tag out. The wording of the Standard certainly suggests th such independent verification be performed, but it does not require it. The wording of NUREG-0737 also strongly suggests that independe verification of equipment tag out be performed, but does not require t.
We, thus, conclude that the licensee is correct in his contention th t the charge of noncompliance is incorrect and should be withdrawn. At t e same time, however, we feel that independent verification of t e correctness of tag-out of equipment important to safety is an im rtant step that should be taken by all licensees. We are pleased note that Commonwealth Edison has committed to change the procedures at all of its nuclear stations to require such independent verification i the future.
This memorandum closes TI Task No. 85-17. Because of generic implications of our position in this atter, we are sending copies of this memorandum to other Regions and to IE Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation cc:
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