ML20198G527
| ML20198G527 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1985 |
| From: | Thompson H Office of Nuclear Reactor Regulation |
| To: | Grace J, James Keppler, Murley 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 8512110525 | |
| Download: ML20198G527 (3) | |
Text
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Eun UNITED STATES
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NUCLEAR REGULATORY COMMISSION y
9, WASHINGTON, D. C. 20555 j
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November 22, 1985 MEMORANDUM FOR: Thomas E. Murley, Regional Administrator Region I J. Nelson Grace, Regional Administrator Region !!
James G. Keppler, Regional Administrator Region III Robert D. Martin, Regional Administrator Region IV John 8. Martin, Regional Administrator Region V FROM.
Hugh L. Thompson, Jr., Director Division of Licensing, NRR
SUBJECT:
TECHNICAL SPECIFICATION INTERPRETATION
Reference:
1.
Memorandum from Darrell G. Eisenhut, Director, Division of Licensing to Charles E. Norelius, Director, Division of Projects and Resident Programs, dated March 11, 1983 2.
Memorandum from Hugh L. Thompson, Jr., Director, Division of Licensing to Richard W. Starostecki, Director, Division of Reactor Projects, Region I dated August 9, 1985 l
The purpose of this memo is to delineate NRR's interpretation of those l
provisions in the Standard Technical Specifications invoked when it is l
determined that a surveillance test has been missed. Specifically Specification 4.0.3 states " Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.
Exceptions to these requirements are stated in the individual specifications.
Surveillance Requirements dc not have to be performed on inoperable equipment;"
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Reference 1providedNRR'spositionrelativetowhenaTechnicalSpecification
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Action Statement is entered as a consequence of failure to perform required surveillance tests. Reference 1 stated that Action Statements are entered when the Surveillance Requirement should have been performed rather than at the time it is discovered that tests were not performed.
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J November 22, 1985 Regional Administrators Subsequently, NRR has revised its position. This revised position is documented in Reference 2 and can be summarized as follows:
Consistent with the provisions of Standard Technical Specification 4.0.3, the failure to perfonn a surveillance requirement within the specified time interval constitutes a failure to meet the operability requirements for a Limiting Condition for Operations. The time limitations of the Action Statement are applicable from the point in time that it is recognized that the Limiting Conditions for Operation are not However, in such a case the basis for detennining the safety met.
significance in an enforcement action should not be limited to consideration of when it was recognized that the surveillance requirement was not met but rather on the actual total time that the requirements of the Limiting Condition for Operation were not met.
This interpretation precludes having to initiate an immediate shutdown We view the potential upon discovering a surveillance has been missed.
incremental increase in risk associated with the time required to perfonn the missed surveillance small enough to justify this interpretation.
As noted in Reference 2, the Technical Specification Review Group is preparing additional guidance related to Section 3/4.0 of the Standard Technical This guidance will provide further clarifications of time Specifications.
limitation related to limiting conditions for operation and surveillance This guidance should be available for use by Resident Inspectors requi rements.
and Regional personnel in the near future.
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ugh L homp on, Jr., Director Division of Licensing cc:
J. Partlow l
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November 22, 1985 Regional Administrators Subsequently, NRR has revised its position. This revised position is documented in Reference 2 and can be summarized as follows:
Consistent with the provisions of Standard Technical Specification 4.0.3, the failure to perform a surveillance requirement within the specified time interval constitutes a failure to meet the operability requirements for a Limiting Condition for Operations. The time limitations of the Action Statement are applicable from the point in time that it is recognized that the Limiting Conditions for Operation are not met. However, in such a case the basis for determining the safety significance in an enforcement action should not be limited to consideration of when it was recognized that the surveillance requirement was not met but rather on the actual total time that the requirements of the Limiting Condition for Operation were not met.
This interpretation precludes having to initiate an imediate shutdown upon discovering a surveillance has been missed. We view the potential incremental increase in risk associated with the time required to perform the missed surveillance small enough to justify this interpretation.
As noted in Reference 2, the Technical Specification Review Group is preparing additional guidance related to Section 3/4.0 of the Standard Technical Specifications. This guidance will provide further clarifications of time limitation related to limiting conditions for operation and surveillance requirements. This guidance should be available for use by Resident Inspectors and Regional personnel in the near future.
.m n6ned by trua J. au radh*
hiugh L. Thompson, Jr., Director Division of Licensing cc:
J. Partlow DISTRIBUTION Central File TSRG File 1
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