ML20206F201

Discusses Tech Spec Interpretation Re Inoperability of Sys Providing Support Function.Actions to Close Out Listed

ML20206F201
Person / Time
Site:	Clinton
Issue date:	11/02/1988
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8811210020
Download: ML20206F201 (4)

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UNITED STATES

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HEMORANDUM FOR: Dennis H. Crutchfield Acting Associate Director for Projects FROM: Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V and Special Projects

SUBJECT:

TECHNICAL SPECIFICATION INTERPRETATION REGARDING IN0PERABILITY OF SYSTEMS PROVIDING A SUPPORT FUNCTION

• Region III requested technical assistance from NRR in August 1988 (TIA III-88-07) concerning the applicability of the definition of operability to support systems that are not addressed under a Limiting Condition for Operation (LCO) within the Clinton Power Station Technical Specifications (TS). Region III also requested that NRR be included in their discussions with Illinois Power Company (IPC) concerning the application of the definition of operability to five systems that provide a support function for essential systems at Clinton. Due to the inability of the licensee to adequately respond to our questions, IPC agreed with Region III that they should conduct a more detailed systems analysis and submit this information to the NRC for our review. This information was submitted on September 20, 1988.

NRR responded to TIA III-88-07 on September 30, 1988. Follow-u) discussions between NRR and Region III indicated some misunderstanding of tie guidance on this subject included in Part 9900 of the Inspection Manual. This guidance stated that system operability requirements extend to support systems regardless of the existence of support system requirements. Region III incorrectly assumed that it.spection. requirements should be limited to the LCOs specified rather than using the definition of operability to determine the appropriate Action Statements to be followed. Therefore, it was decided that NRR would restate and provide further guidance on requirements that are applicable to support systems, whether or not a support system is addressed by a requirement in the TS. This guidance will be proposed to be included in Part 9900 of the Inspe:: tion Manual as a restatement of the current guidance on this subject included in this Part dated 5/12/85.

It was also decided that a meeting would be held between NRR and Region !!! to discuss these issues. A subsequent meeting would also be held between the NRC and IPC. The desire for these meetings was confirmed during a discussion on October 24, 1988 between myself, Martin Virgilio, Ernie Rossi, Ed Butcher,

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2-Rich Emch Daniel Muller, and Janice Stevens. Richard Knop of Region III was informed on this scme date of NRR's continued desire to meet with Region III on this topic.

In sumary, actions to close out this issue are as follows:

ACTION DATE

- Meeting with RIII Staff and NRR November 9

- Meeting with IPC, NRR, and RIII November 10

- Revised / Updated Guidance prepared Early November

- Revised / Updated Guidance included Late November in Inspection Manual

- Prepare Generic Letter 1989 Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V and Special Projects cc: Edward G. Greenman, RIII

, November 2,1986 l .

Rich Emch, Daniel Muller, and Janice Stevens. Richard Knop of Region III was infonned on this same date of NRR's continued desire to meet with Region III on this topic.

In sumary, actions to close out this issue on as follows:

ACTION DATE

- Meeting with RIII Staff and NRR November 9

- Meeting with IPC. NRR, and RIII November 10

- Revised / Updated Guidance prepared Early November

- Revised / Updated Guidance included Late November in Inspection Manual

- Prepare Generic Letter 1989 Original signed by:

Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V and Special Projects cc: Edward G. Greenman, RIII DISTRIBUTION Central ru e NRC & Local PORs PDIII-2 r/f GHolahan MVirgilio LLuther DMuller JStevens PDIII-2 plant file FMiraglia JSniczek TMuricy

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Rich Emch, Daniel Muller, and Janice Stevens. Ri ard Knop of Region III was informed on this same date of NRR's continued de ire to meet with Region III on this topic.

Since ly.

a y M. Holahan, Acting Director Division of Reactor Projects III, IV, V and Special Projects cc: Edward G. Greenman, RIII DISTRIBUTION

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