ML20236N288

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Informs of Completed Review of Plant TS 3/4.5.A, ECCS Operating, & Provides Comments Which Addresses Inoperable HPCI Sys,Per Region III 970718 Memo
ML20236N288
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 08/13/1997
From: Beckner W
NRC (Affiliation Not Assigned)
To: Pulsifer R
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 TAC-M99236, NUDOCS 9807150075
Download: ML20236N288 (3)
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Text

ts: [ v . /_ W W C UNITED STATES p

g 'j NUCLEAR REGULATORY CCMMISSION waswinovow, o.c. sness som

% , August 13, 1997 l

MEMORANDUM TO: Robert M. Pulsifer, Project Manager Project Directorate 12 FROM: William D. Beckner, Chief Technical Specifications Branch

SUBJECT:

TECHNICAL SPECIFICATION CLARIFICATION AT QUAD CITIES (TIA 97036) (TAC NO. M99236) i By memorandum dated July 18,1997, Region ill, Division of Reactor Projects, requested NRR, Division of Reactor Projects Ill/IV, to prepare a written interpretation of the application

, of Action 3 of Technical Specification (TS) 3/4.5.A," Emergency Core Cooling System -

Operating," at Quad Cities Units 1 and 2 in the event the high pressure cooling injection (HPCI) pump is made inoperable for surveillance testing concurrent with an inoperable low pressure coolant injection (LPCI) pump. The NRR Licensing Project Manager for Quad Cities subsequently referred this request to the Technical Specifications Branch (TSB) on July 21, 1997. Region ill requested this TS interpretation to support its conclusion that Quad Cities had, on June 23 and June 24,1997, inadvertently entered TS 3.0.C. The basis for Region lil's conclusion is found in the language of Action 3, which addresses an inoperable HPCI l system. Action 3 states:

With the HPCI system inoperable, provided both CS (core spray) subsystems, I the LPCI subsystem, the ADS [ automatic depressurization system] and the Reactor Core isolation Cooling (RCIC) system are OPERABLE, restore the HPCI i system to Operable status within 14 days or be in et least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to s 150 psig within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Unless the other listed subsystems are operable, Region 111 concluded that Action 3 would not apply in the event of an inoperable HPCI system. Thus, with no action requirement specified in TS 3/4.5.A for the condition of an inoperable HPCI system concurrent with an inoperable LPCI pump, Region lli concluded that TS 3.0.C would apply. TS 3.0.C applies when an LCO is not met, "except as provided for in the associated ACTION requirements."

in addition, according to TS 3.0.C, in the event corrective measures are completed that

  • permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation?

I CONTACT: traig Harbuck,TSB/NRR 415-3140 i

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9807150075 980624 PDR FOIA tsNNERST98-155 PDR

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g R. Pulsif:r August 13, 1997 The interpretation held by the licensee is that Action 3 is entered for HPCI inoperable regardless of the compliment of remaining operable subsystems. If one or more of these subsystems becomes inoperable anytime before expiration of the 14-day period, then the unit must be shut down in the time specified. If one or more of the subsystems are inoperable at the time the HPCI system becomes inoperable, the shutdown action tires clock as well as the 14<isy time clock would start immediately.

While the language of Action 3 of TS 3/4.5.A has some ambiguity, both interpretations ensure appropriate actions are taken. With Region lil's interpretation, the 13-hour shutdown action time clock of TS 3.0.C would appiy; under the licensee's interpretation the 12-hour shutdown action time clock of Achon 3 would apply. The licensee's interpretation is more restrictive.

The staff reviewed the Quad Cities TS that were in place prior to the Technical Specifications Upgrade program and the staff safety evaluation for the conversion of these TS to the current TS. The staffs review shows that the intent of the current TS is to allow 14 days before rc:;uMng a shutdown in the event the HPCI system is inoperable with the specified portions of the CS, LPCI, ADS, and RCIC systems operable. Further, TS Actions allow no time before requiring a shutdown in the event the HPCI system is inoperable with less than the specified portions of these systems operable. In the event the TS require a shutdown, the unit must be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Thus the licensee should enter Action 3 of TS 3/4.5.A for the conditions of requested TS interpretation.

Region lli also asked what the NRC's position is with respect to voluntary entry into a shutdown action statement and TS 3.0.C. Existing guidance in Part 9900 of the NRC Inspection Manual does not address this question. However, TSB has previously addressed this issue in its December 11,1992, response to TIA 92-08 regarding use of shutdown times for corrective action at Sequoyah. It was concluded that voluntary entry into a shutdown action statement for a brief period is not a violation of the TS. A copy of TSB's response to TIA 92-08 is attached.

Attachment:

As stated cc- RZimmerman JRoe EAdensam RCapra . ,

1 1

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. . s R. Pulsifzr August 13, 1997 The interpretation held by the licensee is that Action 3 is entered for HPCI inoperable regardless of the compliment of remaining operable subsystems. If one or more of these subsystems becomes inoperable anytime before expiration of the 14-day period, then the unit must be shut down in the time specified. If one or more of the subsystems are inoperable at the time the HPCI ,

system becomes inoperable, the shutdown action time clock as well as the 14-day time clock '

would start immediately.

While the language of Action 3 of TS 3/4.5.A has some ambiguity, both interpretations ensure appropriate actions are taken. With Region ll!'s interpretation, the 13-hour shutdown action time clock of TS 3.0.C would apply; under the licensee's interpretation the 12-hour shutdown action

time clock of Action 3 would apply. The licensee's interpretation is more restrictive.

The staff reviewed the Quad Cities TS that were in place prior to the Technical Specifications Upgrade program and the staff safety evaluation for the conversion of these TS to the current TS. The staffs review shows that the intent of th3 current TS is to allow 14 days before requiring a shutdown in the event the HPCI system is inoperable with the specified portions of the CS, LPCI, ADS, and RCIC systems operable. Further, TS Actions allow no time before requiring a .

shutdown in the event the HPCI system is inoperable with less than the specified portions of these systsms operable. In the event the TS require a shutdown, the unit must be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Thus the licensee should anter Action 3 of TS 3/4.5.A for the conditions of requested TS interpretation.

Region til also asked what the NRC's position is with respect to voluntary entry into a shutdown action statement and TS 3.0.C. Existing guidance in Part 9900 of the NRC inspection Manual l does not address this question. However, TSB has previously addressed this issue in~its December 11,19g2, response to TIA 92-08 regarding use of shutdown times for corrective action

at Sequoyah. It was concluded that voluntary entry into a shutdown action statement for a brief l period is not a violation of the TS. A copy of TSB's response to TIA 92-08 is attached.

Attachment:

As stated cc: RZimmerman JRoe EAdensam RCapra DISTRIBUTION:

FILE CENTER WDBeckner TSB Staff TSB R/F DOCUMENT NAME: G:\ QUAD _A.MEM *See previous concurrence OFFICE TSB/NRR iSC/TSB/ADPR/NRR D/OE C/TSB/ADPR/NRR l NAME CCHarbuck* FMReinhart* JLieberman* WDBeckner C%ud! ,

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DATE 8 /1 /97 8 /5/97 8 /11 /97 iAJ97 l OFFICIAL RECORD COPY l

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kusog 8 UNITED STATES

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y, NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. M Q,

December 11, 1992 MEMORANDUM FOR: Frederick J. Hebdon, Director Project Directorate II-4 Division of Reactor Projects I/II i

FROM: Christopher I. Grimes, Chief l Technical Specifications Branch Division of Operating Reactor Support

SUBJECT:

USE OF SHUTDOWN TIMES FOR CORRECTIVE MAINTENANCE (TIA 92-08)

In a memorandum dated February 5, 1992, Region II requested generic guidance on a Technical Specification (TS) issue that arose at Sequoyah. This issue involves the intentional use of TS shutdown time to perform corrective maintenance when the TS allowed outage tima (A0T) is insufficient or there is no A0T.

Region II noted that TS 3.0.2 is clear: completion of a shutdown is not required if repairs started during an A0T are not completed during the A0T but are completed during the shutdown time. The generic concern is, if the A0T is so short that repairs are impossible during that time period, can the licensee remove a component from service with the intention of completing the repair during the shutdown time, and risk a hasty plant shutdown if they subsequently find the repair cannot be completed in that time.

A0Ts provide a reasonable time to perform corrective action that is limited by the safety importance of the associated limiting condition. Shutdown times, both those specified by the action statements and the general "3.0.3" shutdown requirement, provide a reasonable period to accomplish a controlled plant shutdown. However, the technical specifications do not specify how A0Ts or shutdown times are to be used; that is, when or how specific actions may be taken within those periods. Successful corrective actions depend on many factors, including the configuration of the plant at the time, the availability of spare parts, adequacy of procedures, and training of plant personnel. The licensee is responsible for assessing all of these considerations and determining the appropriate course of action which is in the best interest of plant safety.

Circumstances may arise when plant safety is better served by delaying a shutdown action to provide a safer configuration for a shutdown transient or to avoid an unnecessary shutdown transient. If 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 decision is permitted as long as the shutdown times specified by the TS are observed, including the " default" (3.0.3) provision, and no violation should be imposed.

l u___ _ - _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

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i If the licensee subsequently exceeds the shutdown times specified in the TS because of complicating factors, appropriate enforcement action should be taken. When a Level III action, or higher, is appropriate, the escalation and mitigation factors should be applied to the penalty depending upon the specific circumstances. If, in such cases, the licensee exceeds the specified shutdown time because of poor planning or failure to rwcognize plant conditions, and the licensee clearly delayed taking action after entry into the shutdown period, we would expect the enforcement action to apply the escalation of the penalty allowed under Appendix C of 10 CFR Part 2. In this regard, we note that many plant technical specifications refer to " preparing the plant for shutdown" during the shutdown period; such a requirement does not exist in the current standard TS and is sufficiently subjective that it is unenforceable. The Office of Enforcement concurs in the foregoing general position on the application of TS shutdown provisir.ns.

With regard to the specific circumstances that occurred at Sequoyah, we note that the improved standard technical specifications (STS) include changes related to each of the three examples in the TIA. Specifically, the improved STS allow time to readjust safety valve settings at hot conditions prior to power escalation, which should reduce the need for corrective maintenance at full power. The A0T for the accumulator isolation valve closed has been increased from "immediate" to one hour. A0Ts for other accumulator conditions have been increased from I hour to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore, the improved STS provide a basis upon which the licensee could modify its technical specification requirements to avoid these circumstances. .

However, we also understand that the need for taking the accumulator out of service would not have occurred if an online method to drain off the check valve leakage had been provided. In the amendment request of Febrary 14, 1991, the licensee concluded that an online method did not appear to be feasible as a near term solution to this problem. However, the Final Safety Analysis Report describes such an online draining capability as part of the system design. The licensee should reconcile this apparent discrepancy in the design capability of the accumulator system, Depending on the resolution of this issue, it may be appropriate to include a limit in the accumulator LCO for the maximum leakage for which the drain and fill procedure is acceptable, in addition to the leakage limit for the accumulator isolation valve as a pressure isolation valve.

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,IiLLLA Chrstopher15 Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support cc: J. Partlow C. Hehl, RI S. Varga E. Merschoff, RII J. Roe E. Greenman, RIII B. Grimes A. Beach, RIV J. Lieberman, OE K. Perkins, RV

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