ML20236M148

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Recommends That PD III-3 Take Appropriate Formal Action to Direct Licensee to Change Current Practice of Not Entering LCO When Equipment Rendered Inoperable Due to Surveillance Testing or Support Sys Inoperability to Ensure Compliance
ML20236M148
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 01/16/1997
From: Charemagne Grimes
NRC (Affiliation Not Assigned)
To: Kelly G
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 AIT-96-278, NUDOCS 9807130315
Download: ML20236M148 (4)
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Text

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p f-..s1 UNITED STATES I

g NUCLEAR REGULATORY COMMIS810N wasmwatow. o.c. mesumet

..... January 16, 1997 MEMORANDUM TO: Glenn Kelly, Project Manager i

Project Directorate lil-3 i Division of Reactor Projects - Ill/IV, NRR FROM: Christopher 1. Grimes, Chief r

  • Technical Specifications Branch Associate Director for Projects, NRR

SUBJECT:

DUANE ARNOLD PHILOSOPHY ON ENTERING LIMITING CONDITIONS FOR OPERATION (LCOs) (AIT 96-0278)

You rLauested our review of a Task Interface Agreement (TIA) from Region 111 dated August 23,1996, concerning Duane Arnold's philosophy and practice for entering limiting conditions for operation (LCOs). In the TIA, the Region requested that NRR review the following:

1. The acceptability of Duane Arnold's practice of not entering LCOs for surveillance testing.
2. The acceptability of Duane Arnold's practice of not entering LCOs when certain support systems are out of service.
3. Duane Arnold's conversion to improved technical specifications (ITS) as it relates to the licensee's intent to maintain their current practices (stated in 1 and 2 above).

The Region stated that it is their position that the licensee should be entering the appropriate technical specification (TS) LCOs whenever a system is incapable of performing its design function due to surveillance testing or due to a support system being out of service.

TSB agrees with the Region's position. The Duane Arnold TS define operability as follows:

"A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s). Implicit in this definition shall be the assumption that all CONTACT: Nanette V. Gilles, NRR 415-1180, E-mail NVG l

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9807130315 900624 h 8-155 PDR -

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, G. Kelly -2 January 16, 1997 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)."

In the TIA, the Region provided several examples of systems that are inoperable during surveillance testing. In all of the examples, the system being tested is ant capable of performing its specified function, therefore it is inoperable. A number of the examples involved the High Pressure Coolant injection (HPCI) Subsystem. The requirements for the HPCI Subsystem are provided in LCO 3.5.D, "HPCI Subsystem," of the Duane Arnold TS. LCO 3.5.D.1 requires that the HPCI Subsystem be OPERABLE whenever there is irradiated fuel in the reactor vessel and reactor pressure is greater than 150 psig. LCO 3.5.D.2 states, "With HPCI inoperable, provided that both Core Spray subsystems, LPCl, ADS, and RCIC are verified to be OPERABLE, restore HPCI to OPERABLE status within 14 days."

When the licensee performs testing on the HPCI Subsystem that renders it incapable of performing its specified function, the licensee should declare the HPCI Subsystem inoperable and enter LCO 3.5.D.2. The same logic applies to all surveillance testing that renders equipment incapable of performing its specified function. As the Region pointed out, the licensee's position is also inconsistent with the guidance in Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," which states:

"If TS surveillance require that safety equipment be removed from service and rendered incapable of performing its safety function, the equipment is inoperable. The LCO action statement shall be entered unless the TS explicitly direct otherwise."

In the licensee's November 30,1994 letter to Mr. W. T. Russell, they state that their philosophy and basis for not declaring system inoperable for the purposes of entering LCOs during TS required testing is based on the reliability analyses referenced in the TS Bases and Updated Final Safety Analysis Report (UFSAR).

The licensee stated, "These analyses differentiate between system / component out-of-service time for repair, which determines the LCO time, and the out-of-service time due to periodic testing, which determines the sut veillance frequency. While they are mathematically related to one another, they are distinct parts of the establishment of overall reliability and are not interchangeable. Therefore, to enter the LCO for the purposes of TS-required surveillance would be inconsistent with the basis of our TS."

G. Kelly -3 January 16, 1997 '

l TSB does not agree with the licensee's assessment of the purpose of the LCO allowed outage tirne (AOT) (whet they call the *LCO time") and the surveillance frequency. In general, an AOT is the amount of time allowed for completing a required remedial action when an LCO is not met, it is true that AOTs in older TS were generally based on the mean repair time for the subject piece of equipment.

However establishment of an AOT should take into consideration all of the activities that may need to be completed during the AOT (i.e., repairs and testing that render the equipment inoperablu). Conversely, the survalliance frequency is generally DD.1 determined by the out-of-service time due to testing, but by the reliability of the equipment to be tested, since the surveillance frequency determines the time between tests.

In the TIA, the Region states that the licensee's reasons for their position regarding  !

surveillance testing include: (1) the plant and its TS are not designed for that, (2)

Duane Arnold has always done it this way, and (3) in some cases, entering LCOs for surveillance testing would place the plant in a 12-hour shutdown statement.

Regardless of what the licensee believes the TS are " designed" for, the licensee is not relieved from having to comply with their TS. If problems are encountered, the .

licensee has always had the option of requesting an amendment to the TS to reflect reasonable operational considerations, such as the necessary time to ,

perform required surveillance testing.

  • l l l Similar logic applies to the concern that the licensee does not enter an LCO for certain systems when those systems' support equipment is taken out of service.
The definition of operability in the Duane Arnold TS (cited above) clearly states l that support equipment operability is considered part of the operability of the sunoorted system. Again, as the Region pointed out, the licenseas position is also inconsistent with the guidance in Generic Letter 91-18 (Part 9900 inspection guidance), which states

"When a support system is determined to be inoperable, all systems j for which that support system is renuired for system operability i should be declared inoperable and the LCOs for those systems entered."

Consistent with the foregoing explanation, the improved standard technical specifications (STS) are constructed with a presumption that equipment will be declared inoperable during surveillance testing that renders the equipment incapable of performing its specified function; therefore, this issue must be resolved before the review of the Duane Arnold conversion to the STS can be completed. We recommend that PD 1113 take appropriate,10f. mal action to direct the liconese to change their current practice of AD.1 entering LCOs when

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, a, G. Kelly 4 January 16, 1997 equipment is rendered inoperable due to surveillance testing or support system inoperability to ensure compliance with their license requirements.

cc: RPZimmerman EGAdensam RWCooper, RI SAVarGa GMarcus EWMerschoff, Ril JWRoe JAZwolinski JEDyer, RIV JLCa: dwell, Rlli JLieberman, OE

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