ML20236N608

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Responds to Task Interface Agreement Re Callaway Performance of During Shutdown Surveillance Test Requirements W/Unit at-power
ML20236N608
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/11/1998
From: Beckner W
NRC (Affiliation Not Assigned)
To: Bateman W
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 50-483-97-17, NUDOCS 9807150196
Download: ML20236N608 (3)
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4 g  %* UNITED STATES g

" , ; NUCLEAR RECULATORY COMMISSION wAsHmonu. o.c. sense.aeos

,,,,, March 11, 1998 l

MEMORANDUM TO: William H. Bateman, Director V Project Directorate IV-2, NRR ,,p M l FROM: William D. Beckner, Chief Technical Specifications Branch 4//

l Associate Director for Projects, NRR

SUBJECT:

TASK INTERFACE AGREEMENT (TIA) RESPONSE - CALLAWAY -

PERFORMANCE OF "DURING SHUTDOWN

  • SURVEILLANCE TEST REQUIREMENTS WITH THE UNIT AT-POWER  !

I INTRODUCTION in the subject Work Request, you requested that the Technical Specifications Branch (TSB) review the TIA, dated December 11,1997, and Union Electric's (UE) reply involving an unresolved item from inspection report No. 50-483/97017. The stated purpose of this l request is to provide a documented response of the TSB's position. Our review of the TIA is complete with the following evaluation of the licensee's practices of conducting at-power

, testing for Technical Specifications (TS) required shutdown surveillance testing. .

l BACKGROUND i

During reviews conducted by the licensee in accordance with Generic Letter 96-01, " Testing of Safety-Related Logic Circuits,' instances were found in which proper operation of relay contacts have not been verified by surveillance testing. The Callaway Plant determined that the relay contacts not tested were associated with TS 4.8.1.1.2.g.2.c.2 and TS 4.8.1.1.2.g.5 which verify the actual or simulated loss-of-offsite power signal and the automatic trips for each diesel generator. Although relay contacts are not specifically l

identified in TS surveillance requirements, the licensee determined that they should be tested in order to ensure complete testing and compliance with the TS surveillance requirements. As a result of these findings, the licensee entered TS 4.0.3 and performed the missed tests at-power in an attempt to satisfy TS requirements. These tests have historically been performed at shutdown within the prescribed 18 month period as required by TS surveillance requirements, but certain relay contacts, in this case, were not tested in  ;

the past.  !

Specifically, Region IV has requested that NRR evaluate the following:  ;

1

\N 1. Whether licensees have the latitude to apply judgement regarding testing of certain components at-power when these or similar components, which would normally be i

\ tested as a minor part of a major plant-controlling TS surveillance requirement CONTACT: J.W. Foster, TSB/NRR (301) 415 3647 s

9807150196 980624 /

PDR FOIA r)

UNNERST98-155 PDR /,2 e

\

W. Bateman March 11, 1998 ,

specified to be performed during shutdown, are identified to have either never been tested or have exceeded the surveillance frequency interval.

2. Whether NOED's would be required to permit testing in the above situation (i.e., test at-power instead of shutdown).
3. Whether the situation above would be different in the case of postmaintenance or postmodification testing.

DISCUSSION The Technical Specifications Branch (TSB) staff evaluated each element of the TIA as stated above. Based on the our review from the information as specified above, and from several meetings and conference calls with the licensee and Region IV personnel, the TSB staff concludes that the licensee does not have the latitude to apply judgement to test components at power which TS surveillance requirements require to be tested during shutdown. This also applies to situations that involve postmaintenance and postmodification testing, in the development of the Standard Technical Specifications (STS), during which the NRC staff gave considerable consideration to input from the industry, the issue of the appropriateness of " shutdown" vs. "st-power" testing of 'A. C. Sources" was discussed.

The staff determined that selected tests should continue to be performed only during ,

shutdown. The basis for this decision is that during operation with the reactor critical, performance of these surveillance requirements could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. With this in mind, the literal compliance of this TS surveillance requirements to demonstrate OPERABILITY must be met or entry into a Limiting Condition of Operation ACTION statement is required. The test under discussion is one that is required to be performed during shutdown.  ;

There are provisions in which the licensee may request a notice of enforcement discretion l (NOED) in order to avoid'the potential safety consequences of transients associated with l plant shutdown. The licensee may request to either postpone the surveillance requirement until the unit is shut down (or is in a condition or mode that is consistent with the safe conduct of that surveillance) or perform the actual testing at-power. Each will be reviewed on a case by case basis, but in either case, a NOED is required. >

in the past, licensees have also requested Technical Specification amendments to allow

! conduct of specific surveillance requirements at-power. The TSB staff has reviewed, and in some cases, approved the request based on plant specific configurations which allow such testing to be safely conducted at-power. If the licenses believes that this issue is generic,

s t W. Bateman March 11, 1998 l they may propose that this "at shutdown" issue be reviewed by the Technical Specification Task Force. This has historically been the conventional approach to solving generic issues that deal NUREG 1430-1434.

If you have any questions regarding this matter, please contact Mr. Jack Foster of my staff l on 415-3647.

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