ML20236L580
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A. Bill Beach
-2 August 31, 1994 The USQ criteria in 10 CFR Section 50.59 were established to identify changes in plant design or operation that are not encompassed by the license.
The concepts discussed above are described further in the attached memorandum.
If you have any questions regarding this response, please contact Bill Reckley at (301) 504-1314.
i Docket No. 50-482
Attachment:
January 24, 1994, Memorandum,
" Relationship between the General Design Criteria (GDC) and Technical Specifications" cc w/ attachment:
R. Cooper, Region I E. Mershoff, Region II E. Greenman, Region III DISTRIBUTION:
Central File EPeyton PDIV-2 Reading WReckley SVarga CGrimes JRoe BGrimes TQuay FRingwald C 015B Background Bo j
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August 31, 1994 MEMORANDUM T0:
A. Bill Beach, Director Division of Reactor Projects Re ion IV A^m FROM:
nor
- ensam, ssistant Director for Region IV Reactors l
Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
SUBJECT:
TASK INTERFACE AGREEMENT (TIA) 94TIA0009 - VOLUNTARY ENTRY INTO TECHNICAL SPECIFICATION ALLOWED OUTAGE AND SHUTDOWN TIMES - WOLF CREEK GENERATING STATION (TAC N0. M89579) l In a memorandum dated May 31, 1994, Region IV requested a clarification of an NRR response to a Region II TIA (92-08) regarding the voluntary use of shutdown time in technical specifications (TS) for corrective maintenance.
l Specifically, Region IV asked whether the voluntary use of a 6-hour shutdown time at Wolf Creek constituted an unreviewed safety question (USQ); the licensee had isolated one of four accumulators to backseat a leaky check valve.
The NRR response to Region Il noted that "[i]f a licensee responsibly concludes that plant shutdown should be delayed or corrective action can be accomplished so that an unnecessary plant transient can be avoided, we believe that such a decish:r. is permitted as long as the shutdown times specified by i
the TS are observed, including the ' default' (3.0.3) provision, and no violation should be imposed." The only constraint we consider appropriate in using allowed outage times (A0Ts) and shutdown time is whether such use is ceasonable and responsible.
Technical specifications provide limited time periods to correct specific deviations from the limiting conditions for operation (i.e., A0Ts) and to shut down the plant if the condition cannot be corrected within the A0T. The TS also provide limited periods to shut down the plant if a condition occurs that is not addressed by the limiting conditions for operation or is outside the design basis. These time limits are based on the relative safety significance of a loss of redundancy or other deviation from the safety system design basis and have been established as a constraint of the license.
Issues associated with the duration of equipment inoperability cannot constitute USQs if conformance with the A0Ts and shutdown time is maintained.
CONTACT:
Bill Reckley, DRPW/PD4-2 504-1314 i
I.
O A. Bill Beach
-2 The USQ criteria in 10 CFR Section 50.59 were established to identify changes in plant design or operation that are not encompassed by the license.
The concepts discussed above are described further in the attached memorandum.
l If you have any questions regarding this response, please contact Bill Reckley at (301) 504-1314.
Docket No. 50-482
Attachment:
January 24, 1994, Memorandum,
" Relationship between the General Design Criteria (GDC) and Technical Specifications" cc w/ attachment:
R. Cooper, Region I E. Mershoff, Region II E. Greenman, Region III i
i e
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