ML20236K853
See also: IR 05000277/1992032
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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wAssiwatoN, D. C. 20556
April 16, 1993
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NOTE TO:
Charles Miller, Project Director
Project Directorate I-2,
Assistant Director for Region I Reactors, NRR
THRU:
Chris Grimes, Chief
,
Technical Specifica. ions Branch
Division of Operating Reactor Support, N1R
FROM:
Carl Schulten, Senior Renctor Engineer
Review & Assessment Section,
Technical Specifications Branch
Division of Operating Reactor Support, NRR
SUBJECT:
PEACH BOTTOM UNITS 2 & 3 OPERABILITY ISSUES DURING LOGICAL SYSTEM
FUNCTIONAL TESTING (LSFT)
This note is in response to Jim Shea's note to Chris Grimes dated
February 12, 1993 (Enclosure 1). Based on our review of the information
provided regarding IR 50-277/92-32, we agree that the licensee does not
conform to the guidance in GL 91-18, unless equipment rendered inoperable
during maintenance or surveillance testing is declared inoperable and required
technical specifications (TS) are entered. We also agree that a core spray
LSFT will render two diesels inoperable which would require entry into
In order to conduct the next required core spray LSFT, we recommend
PECO seek a TS amendmer.t or request enforcement discretion.
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LSFT testing of either loop of core spray on either unit will affect redundant
trains of safety systems, which is a condition for which the licensee must
make an equipment operability determination. Based on your discussion, we
agree the LSFT renders two diesels inoperable since the test plug blocks the
LOCA initiation relays from performing their intended function, and inhibits
degraded voltage LOCA fast transfer to the Class IE emergency buses.
If the
TS de r.st specify a remedial action for this degraded condition then TS 3.0.C
applies.
We note however, that this also raises the questio~n of adequacy of plant TS to
establish appropriate plant conditions for performing an LSFT. As a result of
not declaring equipment removed from service during the core spray LSFT
inoperable, the licensee failed to recognize the affect of the test on'the
operability of related safety systems and thereby f ailed to recognize that
improper plant conditions were required for the testing. The industry
practice for LSFT is reflected in the improved STS which require testing at 18
month intervals (shutdown) because the end devices in the circuits are
actuated. This enables licensees to perform testing under conditions that do
not impact the availability of safety systems during modes which require those
systems to be operable.
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9007100100 900624
UNNERST98-155
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April 16, 1993
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The OTSB alternate train testing position in the April 10, 1992 memo, which you
referenced, and the core spray LSFT interpretation are related because both
address system unavailability due to testing. For alternate train testing, the
concern is that some plant TS required opposite train testing when one train
becomes inoperable. The staff recognized that alternate train testing together
with the staff operability guidance for trains removed from service for testing
could limit plant operation. That memo provides two specific recommendations to
avoid unnecessary operational limitations. First, if TS required testing results
in opposite train equipment being inoperable then the staff recommended the test
be rescheduled to take advantage of the TS schedule tolerance of 25%. Second,
the staff recommended licensees request TS license amendments to eliminate those
TS that require a special test of the alternate train when one train is
inoperable, and thus force a loss of safety function such that a shutdown may
have to be initiated. You should advise the licensee of these options to resolve
alternate train testing limitations in their plant TS, which could otherwise
resolved by amending the license to incorporate explicit testing' provisions like
those in the improved STS.
If you have any questions please do not hesitate to contact me at 504-1192.
ngs,al,53h.u ). f
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Carl S. Schulten, Senior Engineer
Technical Specifications Branch
Division of Operating Reactor Support, NRR
Enclosure:
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As stated
cc w/ enclosure:
B. K. Grimes
C. I. Grimes
S. H. Marcus
A, E. Chaffee
J. Shea
Distribution: w/o enclosure
OTSB R/F
DORS R/F
Central Files
\\0TSBMembers
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DOCUMENT NAME: G:\\93-15.ACT
- 5ee previous concurrences
OTSB:DOEA
SC:0TSB:DOEA
C:0TSB:DOEA
CSSchulten*
RHLo*
CIGrimes*
4/14/93
4/14/93
4/16/93
w/ corrections
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April 16,1993
The OTSB alternate train testing position in the April 10, 1992 memo, which you
referenced, and the core spray LSFT interpretation are related because both
address system unavailability due to testing. For alternate train testing, the
concern is that some plant TS required opposite train testing when one train
becomes inoperable. The staff recognized that alternate train testing together
with the staff operability guidance for trains removed from service for testing
could limit plant operation. That memo provides two specific recommendations to
avoid unnecessary operational limitations. First, if TS required testing results
in opposite train equipment being inoperable then the staff recommended the test
be rescheduled to take advantage of the TS schedule tolerance of 25%. Second,
the staff recommended licensees request TS license amendments to eliminate those
TS that require a special test of the alternate train when one train is
inoperable, and thus force a loss of safety function such that a shutdown may
have to be initiated. You should advise the licensee of these options to resolve
alternate train testing limitations in their plant TS, which could otherwise
resolved by amending the license to incorporate explicit testing provisions like
those in the improved STS.
If you have any questions please do not hesitate to contact me at 504-1192.
Carl S. Schulten, Senior Engineer
Technical Specifications Branch
Division of Operating Reactor Support, NRR
'
Enclosure:
As stated
cc w/ enclosure:
B. K. Grimes
C. I. Grimes
G. H. Marcus
A. E. Chaffee
J. Shea
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