ML20236N385

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Discusses TS Clarification at Quad Cities Re Interpretation of Application of Action 3 of TS 3/4.5.A,in Event High Pressure Cooling Injection Pump Made Inoperable for Surveillance Testing Concurrent W/Inoperable LPCI Pump
ML20236N385
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 09/09/1997
From: Capra R
NRC (Affiliation Not Assigned)
To: Grant G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 TAC-M99236, NUDOCS 9807150107
Download: ML20236N385 (3)
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Text

i NUCLEAR REGULATORY COMMISSION

(%, wasmoro=, o.c. sonesem Septent>er 9,1997 MEMORANOUM TD: Geoffrey Grant, Director Division of Reactor Projects, Region I t f

T90M: Rcbort A. Capra, Director ,

W lA9 Ir '

Prsject Directorate 1112 '

Division of Reactor Projects II NRR SUBJEG- TECHNICAL SPECIFICATION CLARIFICATION AT QUAD CITIES (TIA 97036) (TAC NO. M99236) i By memorandum dated July 19,1997, Region til, Division of Reactor Projects, requested NRR, Division of Reactor Projects !!!/IV, to prepare a written interpretation of the application of Action 3 of Technical Specification (TS) 3/4.5.A, " Emergency Core Cooling System - Opeisting," at Quad Cities, Units 1 and 2, in ti,0 event the high pressure cooling injection (HPCI) pump is made inoperable for surveillance testing concurrent with an inoperable low pressure coolant injection (LPCl! purup. Region 111 requested this TS interpretation to support its conclusion that Quad Cities had, on June 23 and June 24, 1997, inadvertently entered TE 3.0.C, The basis for Region Ill's conclusion is found in the language of Action 3, which addresses an inoperable HPCI system. Action 3 states:

Mth the HPCI system inoperable, provided both CS [ core spray subsystems, the LPCi subsystem, the ADS ! automatic depressuriza-tion system) and the Reactor Core isolation Cooling (RCIC) system are OPERABLE, restore the HPCI system to Operable status within 14 days or be in at 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 />.

Urdess the other listed subsystems are operable, Region !!! concludod th:t Action 3 wou'd not apply in the event of an inoperable HPCI system. Thus, with n > action requirement specified in TS 3/4.b.A for the condition of an inoperable HPCI system concurrent with an inoperable LPCI pump, Region 111 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 ACTl5N 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 ttne time of failure to meet the Limiting Condit.on' for Operstion."

/

The troerpretation held by the licenses is that Action 3 is entered for HPCI inoperable l rega.wasa of the compliment of remaining operable subsystems. If one or more of these subsystems becomes inoperable anytirne before expiration of the 14-day period, then the

}k unit must to 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 wet as the 14-day time clock would start immediately.

NBC RLE CEHER COPY

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4 O J. A. Grobe While the language of Action 3 of TS 3/4.5.A has some ambiguity, both interpretations i ensure appropriate actions are taken. With Region !!!'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 spply. The licensee's interpretation is more restrictive.

The staff reviewed the Quad Cities TS that were in place prior to the Technical Specificatl6ns Upgrade pogram and the staff sa'ety evaluation for the conversion of these TS to the current TS. For the conditions of regt.ated TS interpretation, the original TS cicarfy would have required taking actions consistent with Action 3 of current TS 3/4.5.A.

Based on this and the safety evaluation discussion of these requirements, the intent of the conversion to the current TS was to maintain the previous action requirements for an inoperable HPCI system. However the conversion tmintentionally introduced an ambiguity into the applicability of these actiore requirements. This ambiguity makes plausible the applicability of TS 3.0.C in place of Action 3. While a degree of ambiguity exists,its resolution is not critical because both Action 3 and TS 3.0.C require shutting the unit down within a short period. The staff's review thows that the intent of the current TS is to allow 14 days before requiring a shutdown in the ever't 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 un!? 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 reactor steam dome pressure must be less than 150 psig 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 ill also asked what the NRC's pr.sition is with respect to voluntary entry into a shutdown action staternen , id TS 3.0.C. iEr' . ting guidance in Part 9900 of the NRC Inspection Manual does *.ot addre'i this question. Mwever, NRR's Technical Specifications Branch 0%d) he', previotasly addressed this issue in its December 11,1992, response to TIA 92 08 rege%ng use of shutdown times for corrective actinn at Sequoyah.

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

The licenses has submitted LER 97-017 for Unit I which states that the LCO was

" inappropriately entered." Quad Cities understands that voluntarily making redundant systems or components inoperable at the same time is a nonconservative action. The licenses states; 'Tne root cause of the inappropriate entries into the LCO was a scheduling error by the LUP [ Lead Unit Planner) in not recognizing these LCO entries were con:rary to the bases for TS 3.0.A. These entries into the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Hot Shutdown LCO were not conservative.*

Docket Nos. 50-254, 50-265

Attachment:

As stated l

cc w/stich: J. Wiggins J.Jaudon A . H o w e!!

4; , .- J. A. Grabe .

While the language of Action 3 of TS 3/4.5.A has some ambiguity, both interpretations ensure appropriate actions are taken. With Region til's interpretation, the 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> shutdown action time clock of TS 3.0.C would appiv; under the licensee's interpretation the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shutdown action time clock of Action 3 would apply. The licensee's interpretation is more restrictive.

The staff reviewed the Oued 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. For the conditions of requested TS interpretation, the original TS clearly woulc have required taking actions consistent with Action 3 of current TS 3/4.5.A.

Based on this and the safety evaluetion discussion of these requirements, the intent of the conversion to the current TS was to maintain the previous action requirements f r en inoperable HPCI system. However, the conversion unintentionally introduced an ambiguity into the applicability of these action requirements. This ambiguity makes plausible the applicability of TS 3.0.C in place of Action 3. While a degree of ambiguity exists, its resolution is not critical becauss both Action 3 and TS 3.0.C require shutting the unit down within a short period. The staff's review shows that the intent of the 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 abw 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 e.ent 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 reactor steam dome pressure must be less than 150 psig 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 111 e!so 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 nct address this question. However, NRR's Technical Specifications Branch (TSB) has previou.:ly 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.

The licensee has submitted LER 97 017 for Unit I which states that the LCO was

" inappropriately entered." Quad Cities understands that voluntarily making redundant systems or components inoperable at the same time is . nonconservative action. The licensee states; "The root cause of the inappropriate entries into the LCO was a scheduling error by the LUP ILead Unit Plannerl in not recognizing these LCO entries were contrary to the bases for TS 3.0.A. These entries into the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Hot Shutdc,wn LCO were not conservative."

DISTRIBUTION:

Docket Nos. 50-254, 50-265 Docket File PDill 2 t/f RCapra EAdensam RPulsifer CMoore .

Attachment:

As stated AChaffee JLieberman BBoger WKropp, Rl!! CMiller, SRI MRoyle (MLP4) cc w/sttch: J. Wiggins WBeckner SBloom (SDB1)

J.Jaudon A. Howell b eueneve e sepy er see esoumera, momene m en som "c = copy wanout enesswee t = copy ce e,onswes w = wo copy yqb 0FFICE PM:PDill-2 le LA:PDill-2 l NRR:TSBurAl D:PDill 2 l ( A)W$PW 'l 14AME RPULSIFEl W > CM00RE&rw W BBECKNER RCAPRA A + EADENRM DATE 08/tp/97 05/t /97 08/4 /97 0#/o5/97 09/4/97 JOCUMEM DAME: QUAD \QCWu30.MLM OU ICIAL RELORD COPi

.% N.' ..

.f f3-l UNTTED STATES

..,g j NUCLEAR REGULATORY COMMISSION wAswmoron. o.c.seus

,,,,, December 11, 1992 MEMORANDUM FOR: Frederick J. Hebdon, Otractor Projact Directorate II-4 )

Division of Reactor projects I/II fRON: Christopher I. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support

SUBJECT:

USE OF SHUTDOWN TIMES FOR CORRECTIVE MAINTENANCE (TIA 92-08) 1 l

In a memorardus dated February 5, 1992. Region !! requested generic guidance on a Technica? 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 time (A0T) is insufficient or there is no ADT.

Region !! 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 tice period, can the licensee remove a component from service with the intention of completing the repair during the shutdown tke, and risk a hasty plant shutdown if they subsequently find the repair cr.nnot 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, L:th 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 15 are observed, including the " default" (3.0.3) provision, and no violation should be imposed.

, , ATTACHMENT wm ha

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2-If the licensee subsequently exceeds the shutdown times specified in tb % I 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 recognize 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 cf 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 stan:tard TS and is sufficiently subjective that it is unenforceable. The Office of Enforcement concurs in the foregoing general position on the application of T5 shutdown provisions.

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 increaseJ 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 reautrements to avoid these circumstances.

However, we also understa9d 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 regr M af February 14, lH1, the licensee concluded that an onlim esthod did not appear to he feasible as a near term solution to this problem. However, the final safety Analysis Report describet such an online drainir.g 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 stay be appropriate to include a limit in the accumulator LCO for the maximum leakage for which the drain and f111 procedure is acceptable, in addition to the leakage limit for the accumulator isolation valve as a pressure isolation valve.

n,h Chrstopher1(UGrimes, Chief Technical Specifications Branch Division of Operating Reactor Support cc: J. Partlow C. Hehl, RI

5. Varga E. Merschoff, RII J. Roe E. Greenman, RIII

! B. Grimes A. Beach, RIV l J. Lieberman, OE K. Perkins, RV s

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