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tanuary 78. 1983 K.
M'EMORANDUM FOR:
D. G. Eisenhut Director, Division of Licensinfg F_ ROM:
C. E. Norelius, Director, Division of Project and Resident Programs
SUBJECT:
REQUEST FOR TECHNICAL ASSISTANCE - CLARIFICATION OF LA SALLE 1 TECHNICAL SPECIFICATION 3.8.1.2, ACTION a The number of *and/or" provisions in Technical Specification.3.8.1.2 Action a, makes it difficult to determine what is required by the action statement. A literal reading, to the best of our ability, tells us that with either (1) all offsite circuits inoperable, or (2) diesel generator 0,
.or (3) diesel generator 1A, or (4) any combinatioii of (1). (2), and (3),
h co're alterations and handling of irradiated fuel in the secondary containment and operations with a potential for draining the reactor vessel must be suspended. Discussions with members of your staff indicate that that was not the intent of Technical Specification 3.8.1.2, Action a.
They indicate that the intent was to allow either diesel generator 0 or IA to be taken out of service (made inoperable) without suspending activities if the loads on the diesel generator to be taken out of service are not needed.
We understand that position.and believe it to be sound.
Since there is a significant difference between the intent and the literal meaning of Technical Specification 3.8.1.2, Action a, as we understand them, we request you encourage the licensee to submit a proposed change to correct.
the difference as part of the licensee's next planned technical specification change submittal.
Rather than revising Technical Specification 3.8.1.2 Action a, you right give consideration to making Technical Specification 3.0.5 applicable in operational conditions 1 through 5 and
- and eliminating in its entirety Technitt.1 Specification 3.8.1.2.
In the interim, we request that you confirm to us your understanding of the intent of the action statement.
We would appreciate a response from you by 1
C. E. Norelius, Director 4
Division of Project and Resident Programs cc:
R. Wessman, NRR I
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MEMORANDUM FOR:
D. G. Eisenhut Director, Division of Licensing, NRR FROM:
C. E. Norelius, Director Division of Project and Resident Programs
SUBJECT:
REQUEST FOR TECHNICAL ASSISTANCE - NRR POSITION ON-WHEN AN ACTION STATEMENT IS ENTERED AS A CONSEQUENCE-i 0F FAILURE TO PERFORM SURVEILLANCE TESTS' l.
Licensees occasionally fail to perform technical specification surveillance tests as a result of oversight, scheduling errors, and inadequate test-procedures. Standard Technical Specification 4.0.3 clearly indicates that failure to perform surveillance tests renders the surveilled items inoperable and requires invocation of the applicable action statements. Although custom technical specification plants and older STS plants do not generally have statements similar to STS 4.0.3, all licensees are aware.,of and comply with STS 4.0.3.
However, licensee opinions differ as to when action state-ments are entered when surveillance tests are not performed - most take the position that action statements are entered at the time tests should have been performed but some take the position that action statements are entered at the time it is discovered that tests were not perfonned. We agree with l
the former position - the latter position effectively lengthens the technical specification allowed surveillance period when missed tests are l
not discovered due to program inadequacies or personnel error.
To enable us to assure licensees are uniformly dealing with this matter in a manner consistent with NRC policy, we request NRR provide us with a position on when action statements are entered when surveillance tests are not performed. We would appreciate a response by March 1, 1983.
T.T hC C. E. Norelius, Director Division of Project and Resident Programs i
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% ***' ' o M4 FEB D 1983 MEMORANDUM FOR:
D. G. Eisenhut, Director, Division of Licensing, NRR FROM:
C. E. Norelius, Director, Division of Project and Resident Programs q.
SUBJECT:
REQUEST FOR TECHNICAL ASSISTANCE - NRR POSITION ON
'I; SHDTOCWN TIME ALLOWANCES WHEN AN LCO IS NOT MET 1,
When operation is less conservative than an LCO, Technical Specifications allow a period of time ta c.orrect the condition and then provide times
.L within which specified desceriding levels of plant shutdown conditions (lower operational medw) uut be attained. _0ccasionally, the plantsiwill choose to enter a lower wde alhout using the full time allowed'in th~e.
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.i precedingmode(s).
In such cases, it is not clear if licensee's can' l
take credit for the unused portion of' the full time allowance in the preceding mode to determine the time allowed before the next descending mode must be attained; however, it seems clear that in no case can credit
'i be taken for allwable times in modes above the mode in which the problem
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was discovered.
The following mmples will clarify the issue:
Example 1
- l The action statement for B&W STS 3.6.2.1 states: "With one containment spray j
system inoperable, restore the inoperable spray system to OPERABLE status j
within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; ll restore the inoperable spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />".
- l If the licensee discovered 3 containment spray system inoperable when in the
.i power operations mode and attained the hot standby condition within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of discovery, does the licensee have a maximum of 154 hours0.00178 days <br />0.0428 hours <br />2.546296e-4 weeks <br />5.8597e-5 months <br /> (72-2=70 plus 6 plus 48 plus 30) after attaining hot standby before cold shutdown must be attained? Or does the licensee have a maximum of 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> (48 plus 30)?
In cases like this, wo believe the licensee should have 154 hours0.00178 days <br />0.0428 hours <br />2.546296e-4 weeks <br />5.8597e-5 months <br />.
f Example 2 i
If the licensee discovered the above problem when in the hot standby mode, 1
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does the licensee have a maximum of 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> (48 plus 30) before cold shutdown must be attained? Or does the licensee have a maximum of 156 hours0.00181 days <br />0.0433 hours <br />2.579365e-4 weeks <br />5.9358e-5 months <br /> (72 plus 6 plus 48 plus 30)? In cases like this, we believe the licensee should only have 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />.
To enable us to assure that licensee's are uniformly dealing with this matter in a manner consistent with NRC policy, we request NRR provide
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us with a position on licensee's adding unused portions of allowable time to get to the next lower descending shutdown condition. We would appreciate a response by March 15, 1983.
-8.-8, DM C. E. Norelius, Director Division of Project and Resident Programs cc:
W. G. Guldemond, SRI, LaSalle Station er
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s FEB 161983 s.
k MORANDUM FOR:
D. G. Eisenhut, Director, Division of Licensing, tiRR l
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C. E. fiorelius, Director, Division of Project and Pesident Programs S'? JI CT:
REOULST FOR TECHNICAL ASSISTANCE - TECHNICAL SPLCliICATION IfiTERPRLTATION (Alls F03008283) l Attached is a prorondem frW. Orc of cur Scnior Resident inspectors requestiag a T. d.nical Qecification interpretation by liRR rcgarding the subject of Am is to i oc,..est that interpretatic q.
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The purpose of my <
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In y ar 1Hier dated f pril 10,1EO, to "All '. ice 4 actors", all liccnsces
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s.a e 1, gested to sub;.it Technical Sb.cificat ion d.r.ges to change the definition of opet able to reed:
"A t ys te m, s t.bsyst. 9, train, ter ; nncnt or dm,> ice shall be OPMELE cr have Git: :$1LllY '.. hen it is c4able of performing its specificd functien(s).
I: clitit in this definif icn s' all Ee the assu:.ption that all necessary attemhnt instra mte t:cn, ccntiels, normal l
.d 4..encncy electrical po,ser sc;cces, cooling or scal water, lubricat on j
i or ohr miliaiy equipn.ent that are requiied for the rystem, subsystem,
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', nt or device to perform its function (s) are also capable of i
pa rtt. ng t heir related support function (s)".
T',e t'e ; ;:,it ion of t, eccble was further clarified as follows:
"When a syst,m, n' a.tcm, : rain, cu rr.c.nt or device is determined to be inoperrble W ly ' a _se its, et;r ncy. p0,ter sc ;rce,i_s _ inoperable _, or solely beo me i:s
.r. ul,. cr sc o ce is ii.0; ei Sle, it oy be ccnsGered OPERABLE fur c of
', fj ' ng f !. r wi e a.ts of its S plicable limiting
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on". (:,h; sis s It is very clear f rca, t!.e clove thet sysic:m, subsjstem, train, component or device is not inoperable for the purpose of satisfying the requirements of its LCO if the system, subsystem, etc., has merely lost its emergency power source. ':
.t.r, it is not clear to us whether the loss of caergency power to a.j '
, < 'c; sten, etc., would render that system, subsystcm, etc.,
- ire, i H:le Sr the pui pose of satisfying another sys tem, subsystem, etc., LCO.
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v1' D. G. Eistnhut s lhe attached racmorandum addresses this specific example: With the Core Sprey Syst(in degraded by loss of its emprgency power source, is the Core Spray System to be considered operable to meet the High Pressure Coolant injection System LCO?
We would appreciate a review of this issue by your staff and a response by lpril 15,1983.
Picase contact Ecgr r Walter of my staff on FTS 384-2565 if you have any questions regarding this matter.
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l MEMORANDUM FOR:
R. D. Walker, Chief, Reactor Projects Section 2C FROM:
N. J. Chrissotimos, Senior Resident Inspector,-
Quad-Cities Nuclear Power Station
SUBJECT:
TECHNICAL SPECIFICATION INTERPRETATION Recently I have been involved with a response to an Iowa Electric Light and Power Company's denial of a noncompliance involving operability of an emer-gency system.
In responding to the denial, it appears that Technical Specification require-ments allow unit operation to continue for seven days with two emergency systems concurrently inoperable.
Specifically, (a) when a diesel generator is inoperable, continued reactor operation is permissible for seven days provided that all of the low pressure core and containment cooling subsystems and the remaining diesel generator are operable.
If this requirement cannot be met, an orderly shutdown shall be init1ated and the reactor be placed in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(Duane Arnold Technical Specification 3.5.6.1)
(b) When the high pressure coolant injection (HPCI) system is inoperable, reactor operation is permissible for seven days provided that all active components of the ADS subsystem - the RCIC system, the LPCI subsystem and both core spray subsystems - are operable.
If this requirement is not met, the same 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown requirement is applied. (Technical Specification 3.5.D.2)
The situation was that the diesel generator was unknowingly inoperable for 17 days and within this time frame, HPCI was also inoperable for approxi-mately 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />.
The licensee was cited for violating the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO because it was felt that the equipment powered by the inoperable diesel generator (core spray, LPCI subsystem) was also considered to be inoperable and thus the HPCI LCO was violated.
The licensee believed that the inoperability of diesel generator 1G-21 did not render the B core spray subsystem inoperable for purposes of the seven day LCO in effect based on the following:
Under Amendment 77, the definition of OPERABLE is clarified to read: A system, subsystem, train, component or device shall be OPERABLE or have N
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10/15/82 OPERABILIIT when it is capable of performing its 'specified function (s).
Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment
. that are required for.the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related support function (s).
Amendment 77 also clarified the definition of Limiting Condition for Oper-ation as follows: When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided:
(1) its corre-sponding normal or emergency power source is OPERABLE: and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this specification.
(emphasis added)
Thus, under the foregoing interpretation of Technical Specification 3.5.D.2 on March 5-6, 1982, the B core spray subsystem was OPERABLE for the purpose of satisfying the then applicable seven day Limiting Condition for Operation because 'its normal power source was operable and its redundant subsystem (Core Spray Subsystem A) was OPERABLE.
Since the B. core spray subsystem was not inoperable for the purposes of Technical Specification 3.5.D.2, this Technical Specification was not violated.
By interpreting the specifications in this manner, we would be allowing a
. licensee to operate for seven days with both a HPCI system and diesel generator inoperable.
It should be realized that in this situation, under an accident condition with loss of offsite power, there would only be the minimal ECCS systems available to cope with the accident.
(One core spray pump and two LPCI pumps would not have power.)
When considering both the HPCI and diesel generater LCO's together, it is j
difficult for me to interpret that the core spray atd LPCI pumps associated
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with the inoperable diesel can be considered operable to satisfy the HPCI LCO.
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R. D. Walker-3 10/15/82 1 am requesting a position from.th'e Office'of Nuclear-Reactor Regulation on.the' applicability of the definition of operable with respect to this matter.
Although this is a specific problem,-it may also apply'to other BWR's which do not have standard Technical Specifications and thus should be looked at' generically.
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N. J. Chrissotimos
' Senior Resident Inspector Quad-Cities Nuclear Power Station
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Charles E. Norelius, Director l
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FROM:
Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
HRR POSITION ON WHEri AN ACTION STATEMENT IS ENTERED AS A CONSEQUEt;EE OF FAILURE TO PERFORM SURVEILLANCE TESTS
REFERENCE:
Memo frot C.E. Norelius to D.G. Eisenhut, dated 1
January 31, 1983, subject: " Request for Technical Assistence - NRR Position on When an Action State-ment is Entered es a Consequence of failure to Perform Sur,veillance Tests".
The referenced memorandum requests NRR's position on when an Action Statement is entered as e consequence of failure to perform required surveillance tests.
It is our position that Action Statements are entered when items required operable by Limiting Condition for Operations are known to be incperable.
Items may be determined int,perable (1) during use, (2) during a surveill-ante test, or (3) in accordance with Standard Technical Specification 4.0.3 which provides that items are inoperable when Surveillante Require-ments are not performed within the specified time intervals (after applying pe allowable tolerance). Therefore, we agree with your position that
- Action Statements are entered when the Surveillance Requirements should g;/ have been performed rather than at the time it is discovered th were not performed.
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'fMEMORANDUM FOR: Charles E. Norelius, Director
-i Division of Project and Resident Programs Region III i
TROM:
Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
CLARIFICATION OF LA SALLE 1 TECHNICAL SPECIFICATION 3.6.1.2, ACTION a Your memorandum of January 28, 1983 requested confirmation of the intent of LaSalle-Unit i Specification 3.8.1.2 Action a.
The definition of Operable-Operability.in the LaSalle Technical, Specifications requires that whenever required power source is inoperable, the equipment supplied by the inoperable power source also be declared inoperable.
Exceptions to this requirement (Spec 3.0.5) are provided for certain special conditions in Operational Conditions 1, 2 and 3..
The intent of Specification 3.8.1.2 is to ensure that each system and component required to be operable in Operational Condition 4, 5 or * (when handling irradiated fuel in the secondary containment) is capable of being supplied from two independent sources of AC power -- the off-site transmission network and an emergency diesel generator.
Since it is possible, even likely, that the systems and components selected by the licensee to be operable to satisfy the Technical Specification requirements will not all be capable of being powered from the same two independent sources of AC power, it is I
necessary to write the specification to be flexible enough to require the operability of the electrical power sources from which the systems and components' selected to meet these Technical Specification re'quirements can be powered.
Therefore, we believe that the term "and/or" should be retained to provide for those situations in which more than one pair of independent power sources are required to supply systems and components not capable of being supplied by the same pair of independent power sources.
MAR 251o93 g 503W40 APP 1
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Ct,arles E. Norelius,' Director MAR 2 21983
- t This memorandum also confirms previous distussions Taetween membe'rs of our staffs regarding operability requirements for diesel generators 0,ar l A during core alterations and handling of irradiated fuel in the ser.ondary containment or operations with a potential for draining the.reactoF vessel.
One of these diesel generators may be out of service without enter;ing the Action Statement if the loads.on this diesel generator are not required to be operable.
The required loads would be supplied by two independent power soTarces, an offsite source and the other diesel generator.
Based on the foregoing we do not intend to revise Technical Specification 3.8.1.2, Action a.
Please contact D. Hoffman (FTS 492-8518) if you have further questions.
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Darrell G. Eisenhut Director i
Division of Licensing Office of Nuclear Reactor Repulation i
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Charles E. Norelius, Director sto thaP WA (
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Darrell G. Eisenhut, Director
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NRR POSITION ON SHUTDOWN TIME ALLOWANCES Te-WHEN AN LCO IS NOT PET hWent Impnto/s ch
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REFERENCE:
Memo from C. E. Norelius to D. G. Eisenhut
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- dated February 9,1983, subject:
" Request for Technical Assistance - NRR Position on
__,, w. cwn:y Shutdown Time Allowances When an LCO Is Not Met"
._d_ ad Ohm The referenced memorandum requests NRR's position on licensees reducing p operational modes prior to the expiration of the allowable out-of-ser'vice tires specified in technical specification Action Statements and then being per-itted to utilize the unused portion of the higher mode allowable out-of-service time to extend the allowable time in a lower operational mode.
It is car position that it is acceptable for a licensee to initiate and com-by tne allowable out-of-service time specified in an Actio vided for operation in a lower operational mode.to add the unused por Furthermore, it is our position that a stated allowable out-of-service time (frequently 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or 7 days) should be applicable regardless of the operational mode in which the inoperability is discovered.
However a reduction in operational modes (e.g., ge,nerallthe times provided for achieving 2 tc Mode 3, and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from Mode 3 to Mode 4) y 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from Modes 1 or if the inoperability is discovered in a lower operation mode.should not be applicable The following examples are provided to clarify our positions:
Exar :>1e 1 B&W STS 3.6.2.1 requires two independent containment spray systems OPERABLE in P.0 DES 1, 2, 3 and 4.
The Action Statement for this LCO states:
- With ont to CPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STAN next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore the inoperable spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />".
MAR 25 G83 )
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Charles E. Norelius, Director N 2 I E33 This Action Statement provides up to 156 (72+6+48+30) hours' to achieve COLD SHUTDOWl: if a containment spray system is discovered inoperable while in POWER OPERATION (MODE 1) or STARTUP (v.0DE 2).
If the licensee discovered an inoperable containment spray system while in Mode 1 and attained HOT STANDBY within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, the licensee would brve before being required to attain COLD SHUTCOWN (MODE 5).140 (72+6-16+48430)
Example 2 If the licensee discovered the containment spray system inoperable while in HOT ST/J:DBY (MODE 3), the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> interval provided for achieving HOT STANDBY could not be added to the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> intervals to provide additional stay time in HOT STANDBY.
Therefore, the licensee would be required to attain COLD SHUTDOWN within 150 (72+48+30) hours.
Examole 3 If the licensee discovered the containmenispray system inoperable while in HOT SHUTDOWN (MODE 4) neither the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> interval, nor the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> interval could be added to the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 3D hour intervals to provide additional time for achieving COLD SHUTDOWN.
Therefore, the licensee would be required to attain COLD SHUTDOWN within 102 (72+30) hours.
Our positions are predicated on our. belief that safety is enhanced by minimizing plant transients associated with changing operational modes.
It.is for this reason that we have provided allowr.ble out-of-service times in all Standard Technical Specification Action Statements and it is our intention that the specified alio,eable out-of-service tines be applicable in whatever operational mode the inoperability is discovered.
We plan to revise the Bases sections of the Standard Technical Specifications to clarify our position on this matter during future revisions to those documents.
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[Darrell G. Eisenhut, Director y
Division of Licensing Office of Nuclear Reactor Regulation ccs: Eltgct335 Division of Project and Resident Programs Region I Region II 4JisEni11D Region IV Region Y J. G. Partlow, I&E I
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