ML20195D878

Responds to TIA 98-008 Requesting Assistance in Establishing Generic Regulatory Position on Period of Time & Under What Circumstances Acceptable to Remove Rod Control from Service

ML20195D878
Person / Time
Site:	Duane Arnold
Issue date:	11/12/1998
From:	Carpenter C NRC (Affiliation Not Assigned)
To:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20195D880	List: ML20195D878 ML20195D893
References
RTR-REGGD-01.160, RTR-REGGD-1.160 TAC-MA2237, NUDOCS 9811180185
Download: ML20195D878 (4)

Text

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30eeH001 l November 12, 1998 l l MEMORANDUM TO: John A. Grobe, Director l

Division of Reactor Safety

,5 Region lli l i- (,b @G:d80 FROM: Cynthia A. Carpenter, or I I

Project Directorate ill-1 Division of Reactor Projects lil/IV 4 Office of Nuclear Reactor Regulation 4

SUBJECT:

RESPONSE TO TECHNICAL ASSISTANCE REQUEST (TIA 98-008) j RELATED TO REMOVING NORMAL CONTROL ROD SYSTEM j CONTROLS FROM SERVICE ON AN OPERATING REACTOR i (TAC NO. MA2237) i 1

By memorandum dated June 18,1998 (attached), your office fonvarded the subject Task

, Interface Agreement (TIA) to NRR requesting assistance in establishing a generic regulatory position on the period of time and under what circumstances it is acceptable to remove rod 1 control from service.

} During a conference call on May 7,1998, Mel Leach of your staff discussed this issue with representatives from NRR's Reactor System Branch (SRXB), Technical Specification Branch (TSB), Quality Assurance, Vendor Inspection, and Maintenance Branch (HQMB), and Generic j_ lasues and Environmental Projects Branch (PGEB). The discussion during the conference call l focused on the normal rod control system not being a safety system, not being specifically

addressed in the TS or in the improved TS, and not being relied upon in accident analyses.

The conclusion reached during the call was that taking this system out of service at power falls under the provisions of the maintenance rule.

I The NRC published the maintenance rule on July 10,1991, as 10 CFR 50.65, " Requirements

for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," with a required l implementation not later than July 10,1996. Guidance on the maintenance rule is provided in

Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which endorses Revision 2 of NUMARC 93-01, " Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." As stated in 10 CFR 50.65(a)(3),"In performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety systems." NUMARC 93-01, Section 11.2.3, states that "On-line maintenance is a planned and scheduled activity to perform preventive or corrective maintenance, with the reactor at power, while properly controlling out-of service time of systems or equipment."

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, 't In summary, a generic regulatory position on the period of time and under what circumstances it is acceptable to remove rod control from service already exists in the form of the maintenance rule. This completes NRR's effort on TlA 98-008 and closes TAC No. MA2237. If you have any questions regarding this issue, please contact Rich Laufer of my staff at (301) 4151373.

Docket No. 50-331

Attachment:

TIA 98-008 cc: JWiggins, RI BMallett, Ril AHowell, RIV j i

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-2 November 12, 1998 3

in summary, a generic regulatory position on the period of time and under what circumstances it is acceptable to remove rod control from service already exists in the form of the maintenance rule. This completes NRR's effort on TIA 98-008 and closes TAC No. MA2237. If you have any questions regarding this issue, please contact Rich Laufer of my staff at (301) 415-1373.

, Docket No. ' 50-331

Attachment:

TIA 98-008

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! cc: JWiggins, RI l l BMallett, Ril- I L. AHowell, RIV l

l l- Distnbution- 1 l

- Docket File PPrescott, SRI PD3-3 R/F ' PUBLIC EAdensam (EGA1) OGC l RLanksbury, Rlll ACRS l DOCUMENT NAME: G:\DUANEARN\DUA97310.TIA

• see previous concurrence v....... ....n . . .. mn. m c.co .,..n u i.co .u- -ou ..~.u.. ,

OFFICE PM:PD31 E LA:PD31 E BC:HOMB C D;PD31 (A PW NAME RLaufer h EBarnhill k J SBlack

• CCarpenter '( EAde m l DATE il / $ /98 10/5/98 10 / 7 /98 11 /4 /98 /[V98 OFFICIAL RECORD COPY' l-L l l

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2 November 12, 1998 in summary, a generic regulatory position on the period of time and under what circumstances it is acceptable to remove rod control from service already exists in the form of the maintenance rule. This completes NRR's effort on TIA 98-008 and closes TAC No. MA2237. If you have any questions regarding this issue, please contact Rich Laufer of my staff at (301) 415-1373.

Docket No. 50-331

Attachment:

TIA 98-008 cc: 'JWiggins, RI BMallett, Ril AHowell, RIV Distribution:

' Docket File PPrescott, SRI PD3-3 R/F PUBLIC

' EAdensam (EGA1) OGC RLanksbury, Rill ACRS j DOCUMENT NAME: G:\DUANEARN\DUA97310.TIA

• see previous concurrence i To receive e copy of th6s document. Indicate in the box C = Copy w/o attachment / enclosure E = Copy with ettachment/ enclosure N = No copy OFFICE - PM:PD31 LA:PD31 BC:HOMB C D:PD31 RPW '

E E (A NAME RLaufer [d - EBarnhill h ,3 SBlack

• CCarpenter *( EA e m 4 DATE il / 6 /98 10/5/98 ' ' 0 /7/98 1 11 / 4 /98 / [498 OFFICIAL RECORD COPY 4

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