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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20196H4831998-12-0202 December 1998 Forwards Facility Submitted Outline,Exam Submittal & as Given Operating Exam for Test Administered During Wk of 981026 at Dresden Nuclear Power Station ML20237E3131998-08-26026 August 1998 Forwards for Public Release,Info Re NRC SMM Held on 980714-15.Summary of January 1998 NRC SMM & Watch List Removal Evaluation Factors Also Encl ML20249B8451998-06-17017 June 1998 Notification of 980723 Meeting W/Util in Morris,Il to Inform Public of Licensee Plans for Decommissioning Plant,Unit 1 ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20211Q8741997-10-16016 October 1997 Notification of Significant Licensee Meeting W/Util on 971028 to Discuss Apparent Violations Described in to Js Perry ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20197B9141997-07-23023 July 1997 Forwards Safety Evaluation Re Concrete Expansion Anchor Safety Factors for High Energy Line Break Restraints,In Response to Region III 960920 Request ML20148D1981997-05-28028 May 1997 Forwards Signed Original of Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately),For Transmittal to Ofc of Fr,For Publication.W/O Encl ML20138J9791997-05-0707 May 1997 Notification of 970520 Meeting W/Commonwealth Edison in Rockville,Md to Discuss Commonwealth Edison Quality Initiatives & Plans for Dry Storage at Dresden ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20136C1031997-03-0606 March 1997 Forwards Correspondence Transmitted Via Internet to J Zwolinski from P Blanch During 970102-31.Requests Correspondence Be Placed in PDR ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20210N4271996-12-0202 December 1996 Informs About Drop in Meeting on 961203 for Update on Industry Restructuring & Deregulation,Unicom Strategic Planning & Mixed Oxide Fuel ML20217D5421996-11-27027 November 1996 Forwards Partially Withheld Background Briefing Package in Preparation for 961203 Meeting Between Comed,Nuclear Strategic Services & Chairman Jackson ML20210N3761996-08-12012 August 1996 Informs About Meeting on 960513 to Brief Chairman Jackson on Comed Response to Deregulation ML20217D4761996-07-31031 July 1996 Forwards Background Briefing Package in Prepartion of 960813 Meeting Between Commonwealth Edison Co & Chairman Jackson. Purpose of Visit to Discuss Recent Organizational Changes at Comed & Company Mgt Focus for Immediate Future ML20210N3381996-05-14014 May 1996 Discusses Courtesy Visit to Ceco on 960513 Re Listed Plants ML20210N2951996-05-0101 May 1996 Discusses Pre Briefing for Meeting on 960513 Re Mgt, Operations,Maint & Engineering ML20210N2681995-11-13013 November 1995 Discusses Paritially Withheld Chairman Briefing by Ceco on 951116 ML20217D5321995-11-0909 November 1995 Forwards Partially Withheld Background Briefing Package in Preparation for 951116 Meeting Between Commission & Senior Comed Mgt.Purpose of Visit to Discuss Performance at Each of Sites & Challenges & Issues Needed to Be Addressed ML20210N3971995-10-12012 October 1995 Informs of Courtesy Visit on 951011 to Util to Discuss Listed Topics.List of Attendees Encl ML20210N3701995-10-0505 October 1995 Forwards Background Briefing Package in Preparation for 951011 Meeting W/Company Executives & Chairmam Jackson ML20149D8681994-05-16016 May 1994 Forwards Signed Copy of Notice of Availability for Generic Communication That Has Been Issued for Transmittal to Ofc of Fr for Publication ML20134B5061994-04-13013 April 1994 Submits Plants Which Will Be Discussed in Categories Indicated Re Results of Screening Meetings for June 1994. Partially Deleted ML20248E7601994-02-16016 February 1994 Forwards Rept of Unit One Investigative Team Re 940202 Request to Review Unit 1 Off Gas Filter Bldg Water Pipe Leak Event,Unit 1 Sphere Water Pipe Leak Event & Various Issues Related to Unit 1 Fuel Storage ML20058N4811993-12-15015 December 1993 Informs of Decision to Expand Senior Mgt Oversight of Selected Plants,Per Recent Meeting W/J Martin & H Miller. Lists Assignment of Managers,Effective Immediately ML20062J4501993-10-27027 October 1993 Requests Addl Info Re Proposed EAL Changes in Util Generating Station Emergency Plan Annexes.Proposed EALs Reviewed Against Guidance in NUMARC/NESP-007,rev 2, Methodology for Development of Eals ML20059A4651993-10-20020 October 1993 Notification of Significant Licensee Meeting W/Util in Glen Ellyn,Il on 931104 to Review Status of Util Initiatives on QA & Corporate Engineering Support ML20057C9801993-09-27027 September 1993 Discusses 930927 Press Conference Re J O'Connor Announcement That Util Settled Six Rate Matters & Appeals Before Illinois Courts & Commerce Commission by Agreeing to Refund Listed Amount to Customers Over Next 12 Months ML20055C3521990-02-26026 February 1990 Notification of 900305 Meeting W/Util in Rockville,Md to Discuss Status of Licensing Activities for Facility ML20248E9391989-09-29029 September 1989 Forwards AEOD Technical Review Rept on Debris in Containment Recirculation Pumps.No Occurrences Found to Involve Actual Accumulation of Debris in Containment Sumps.Immediate Corrective Actions Completed ML20248C8311989-09-20020 September 1989 Request for Hearing by Alchemie.* Forwards Response & Request for Hearing,In Response to NRC 890818 Order Modifying License & Order to Show Cause Why Licenses Should Not Be Revoked,For Appropriate Action ML20247H9261989-09-0909 September 1989 Advises That SALP Meeting for Facilities Scheduled for 891115.Assessment Input Should Be Submitted by 891016 ML20245E8501989-08-0707 August 1989 Advises of Reassignments in Project Mgt Duties Due to Recent Reorganization of Standardization & Life Extension Project Directorate ML20245H6451989-08-0404 August 1989 Requests Closure of Outstanding Action Item 87-0198,per 870617 Request Re Review & Evaluation of Acceptability of Fairbanks-Morse Diesel Generator Bearings.Action Completed W/Submittal of Transfer of Lead Responsibility to NRR ML20248D1431989-07-27027 July 1989 Forwards Proposed Generic Ltr Requesting Voluntary Licensee Participation in ERDS & Requests That Proposed Generic Ltr Be Sent to All Licensees of Power Reactors,Except for Participants & Licensees of Listed Plants ML20247B7541989-07-19019 July 1989 Confirms That Licensee 880711,890221 & 0630 Responses to NRC Bulletin 88-004, Potential Safety-Related Pump Loss, Acceptable.Licensing Action for TACs 69886,69887,69893 & 69894 Considered Complete ML20247E6721989-07-17017 July 1989 Proposes Closeout of Plant Correspondence Control Ticket Re Environ Conservation Organization Request for Notification Whenever License Amend Requests Result in Impairment of Plant Operability.Intervenor Will Be Placed on Svc List ML20246K5991989-07-12012 July 1989 Notification of 890725 Meeting W/Util in Birmingham,Al to Discuss Status of Current Licensing Activities & Corporate Initiatives for Plants.Meeting Agenda Encl ML20246L6801989-07-10010 July 1989 Notification of Significant Licensee Meeting 89-101 W/Util on 890718 in King of Prussia,Pa to Discuss Util Engineering Reorganization ML20247A9561989-07-0606 July 1989 Notification of 890717 Meeting W/Lead Plant Utils in Rockville,Md to Discuss Implementation of Revised STS ML20246H3771989-05-12012 May 1989 ALAB-913.* Advises That Time Provided within Which Commission May Act to Review Aslab Decision ALAB-913 Expired.Commission Declined Review.Decision Became Final on 890501.W/Certificate of Svc.Served on 890512 ML20246P9601989-05-10010 May 1989 Discusses 890413 Meeting W/Rosemount & Industry Re Malfunctions of Rosemount Transmitters.List of Attendess, Agenda,Nrc Info Notice 89-042 & Viewgraphs Encl ML20245E9781989-04-17017 April 1989 Forwards Regulatory History AC83-2 Re Licensee Action During Natl Security emergency,10CFR50 (54FR7178) ML20245B6191989-04-15015 April 1989 Forwards Evaluation Rept Re BWR Overfill Events Resulting in Steam Line Flooding.All Events Included Reactor Depressurization Followed by Uncontrolled Condensate or Condensate Booster Pumps Injection or Both 1999-09-01
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20196H4831998-12-0202 December 1998 Forwards Facility Submitted Outline,Exam Submittal & as Given Operating Exam for Test Administered During Wk of 981026 at Dresden Nuclear Power Station ML20237E3131998-08-26026 August 1998 Forwards for Public Release,Info Re NRC SMM Held on 980714-15.Summary of January 1998 NRC SMM & Watch List Removal Evaluation Factors Also Encl ML20249B8451998-06-17017 June 1998 Notification of 980723 Meeting W/Util in Morris,Il to Inform Public of Licensee Plans for Decommissioning Plant,Unit 1 ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20211Q8741997-10-16016 October 1997 Notification of Significant Licensee Meeting W/Util on 971028 to Discuss Apparent Violations Described in to Js Perry ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20197B9141997-07-23023 July 1997 Forwards Safety Evaluation Re Concrete Expansion Anchor Safety Factors for High Energy Line Break Restraints,In Response to Region III 960920 Request ML20148D1981997-05-28028 May 1997 Forwards Signed Original of Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately),For Transmittal to Ofc of Fr,For Publication.W/O Encl ML20138J9791997-05-0707 May 1997 Notification of 970520 Meeting W/Commonwealth Edison in Rockville,Md to Discuss Commonwealth Edison Quality Initiatives & Plans for Dry Storage at Dresden ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20136C1031997-03-0606 March 1997 Forwards Correspondence Transmitted Via Internet to J Zwolinski from P Blanch During 970102-31.Requests Correspondence Be Placed in PDR ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M0471996-12-10010 December 1996 Forwards Internet Mail Received from PM Blanch ML20210N4271996-12-0202 December 1996 Informs About Drop in Meeting on 961203 for Update on Industry Restructuring & Deregulation,Unicom Strategic Planning & Mixed Oxide Fuel ML20217D5421996-11-27027 November 1996 Forwards Partially Withheld Background Briefing Package in Preparation for 961203 Meeting Between Comed,Nuclear Strategic Services & Chairman Jackson ML20210N3761996-08-12012 August 1996 Informs About Meeting on 960513 to Brief Chairman Jackson on Comed Response to Deregulation ML20217D4761996-07-31031 July 1996 Forwards Background Briefing Package in Prepartion of 960813 Meeting Between Commonwealth Edison Co & Chairman Jackson. Purpose of Visit to Discuss Recent Organizational Changes at Comed & Company Mgt Focus for Immediate Future ML20210N3381996-05-14014 May 1996 Discusses Courtesy Visit to Ceco on 960513 Re Listed Plants ML20210N2951996-05-0101 May 1996 Discusses Pre Briefing for Meeting on 960513 Re Mgt, Operations,Maint & Engineering ML20210N2681995-11-13013 November 1995 Discusses Paritially Withheld Chairman Briefing by Ceco on 951116 ML20217D5321995-11-0909 November 1995 Forwards Partially Withheld Background Briefing Package in Preparation for 951116 Meeting Between Commission & Senior Comed Mgt.Purpose of Visit to Discuss Performance at Each of Sites & Challenges & Issues Needed to Be Addressed ML20210N3971995-10-12012 October 1995 Informs of Courtesy Visit on 951011 to Util to Discuss Listed Topics.List of Attendees Encl ML20210N3701995-10-0505 October 1995 Forwards Background Briefing Package in Preparation for 951011 Meeting W/Company Executives & Chairmam Jackson ML20149D8681994-05-16016 May 1994 Forwards Signed Copy of Notice of Availability for Generic Communication That Has Been Issued for Transmittal to Ofc of Fr for Publication ML20134B5061994-04-13013 April 1994 Submits Plants Which Will Be Discussed in Categories Indicated Re Results of Screening Meetings for June 1994. Partially Deleted ML20248E7601994-02-16016 February 1994 Forwards Rept of Unit One Investigative Team Re 940202 Request to Review Unit 1 Off Gas Filter Bldg Water Pipe Leak Event,Unit 1 Sphere Water Pipe Leak Event & Various Issues Related to Unit 1 Fuel Storage ML20058N4811993-12-15015 December 1993 Informs of Decision to Expand Senior Mgt Oversight of Selected Plants,Per Recent Meeting W/J Martin & H Miller. Lists Assignment of Managers,Effective Immediately ML20062J4501993-10-27027 October 1993 Requests Addl Info Re Proposed EAL Changes in Util Generating Station Emergency Plan Annexes.Proposed EALs Reviewed Against Guidance in NUMARC/NESP-007,rev 2, Methodology for Development of Eals ML20059A4651993-10-20020 October 1993 Notification of Significant Licensee Meeting W/Util in Glen Ellyn,Il on 931104 to Review Status of Util Initiatives on QA & Corporate Engineering Support ML20057C9801993-09-27027 September 1993 Discusses 930927 Press Conference Re J O'Connor Announcement That Util Settled Six Rate Matters & Appeals Before Illinois Courts & Commerce Commission by Agreeing to Refund Listed Amount to Customers Over Next 12 Months ML20057C0051993-08-31031 August 1993 Staff Requirements Memo Re SECY-93-221, Approval of Decommissioning Plan & Amend of License for Dresden Nuclear Power Station,Unit 1 ML20055C3521990-02-26026 February 1990 Notification of 900305 Meeting W/Util in Rockville,Md to Discuss Status of Licensing Activities for Facility ML20248E9391989-09-29029 September 1989 Forwards AEOD Technical Review Rept on Debris in Containment Recirculation Pumps.No Occurrences Found to Involve Actual Accumulation of Debris in Containment Sumps.Immediate Corrective Actions Completed ML20248C8311989-09-20020 September 1989 Request for Hearing by Alchemie.* Forwards Response & Request for Hearing,In Response to NRC 890818 Order Modifying License & Order to Show Cause Why Licenses Should Not Be Revoked,For Appropriate Action ML20247H9261989-09-0909 September 1989 Advises That SALP Meeting for Facilities Scheduled for 891115.Assessment Input Should Be Submitted by 891016 ML20245E8501989-08-0707 August 1989 Advises of Reassignments in Project Mgt Duties Due to Recent Reorganization of Standardization & Life Extension Project Directorate ML20245H6451989-08-0404 August 1989 Requests Closure of Outstanding Action Item 87-0198,per 870617 Request Re Review & Evaluation of Acceptability of Fairbanks-Morse Diesel Generator Bearings.Action Completed W/Submittal of Transfer of Lead Responsibility to NRR ML20248D1431989-07-27027 July 1989 Forwards Proposed Generic Ltr Requesting Voluntary Licensee Participation in ERDS & Requests That Proposed Generic Ltr Be Sent to All Licensees of Power Reactors,Except for Participants & Licensees of Listed Plants ML20247B7541989-07-19019 July 1989 Confirms That Licensee 880711,890221 & 0630 Responses to NRC Bulletin 88-004, Potential Safety-Related Pump Loss, Acceptable.Licensing Action for TACs 69886,69887,69893 & 69894 Considered Complete ML20247E6721989-07-17017 July 1989 Proposes Closeout of Plant Correspondence Control Ticket Re Environ Conservation Organization Request for Notification Whenever License Amend Requests Result in Impairment of Plant Operability.Intervenor Will Be Placed on Svc List ML20246K5991989-07-12012 July 1989 Notification of 890725 Meeting W/Util in Birmingham,Al to Discuss Status of Current Licensing Activities & Corporate Initiatives for Plants.Meeting Agenda Encl ML20246L6801989-07-10010 July 1989 Notification of Significant Licensee Meeting 89-101 W/Util on 890718 in King of Prussia,Pa to Discuss Util Engineering Reorganization ML20247A9561989-07-0606 July 1989 Notification of 890717 Meeting W/Lead Plant Utils in Rockville,Md to Discuss Implementation of Revised STS ML20246D8841989-06-19019 June 1989 Staff Requirements Memo Re 890601 Briefing on Operating Reactors & Fuel Facilities in Rockville,Md.Commission Expressed Disappointment in Long Term Operating Performance of Turkey Point Nuclear Power Plant ML20246H3771989-05-12012 May 1989 ALAB-913.* Advises That Time Provided within Which Commission May Act to Review Aslab Decision ALAB-913 Expired.Commission Declined Review.Decision Became Final on 890501.W/Certificate of Svc.Served on 890512 ML20246P9601989-05-10010 May 1989 Discusses 890413 Meeting W/Rosemount & Industry Re Malfunctions of Rosemount Transmitters.List of Attendess, Agenda,Nrc Info Notice 89-042 & Viewgraphs Encl 1999-09-01
[Table view] |
Text
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MEMORANDUM FOR: Wi11iam V. Johnson,' Acting Director Division of Reactor Safety, Region I Albert F. Gibson, Director
! Division of Reactor Safety, Region II
, /Hubert J. Miller, Director V Division of Reactor Safety, Region III l
Ramon E. Hall, Acting Director Division of Reactor Safety & Pro.iects, Region IV Dennis Kirsch,-Director Division of Reactor Safety & Pro.iects, Region V FROM: Charles E. Rossi, Director Division of Operational Events Assessment, NRR
SUBJECT:
NRR's POSITION ON WHEN' TECHNICAL SPECIFICATION LCO ACTION STATEMENT' CLOCK BEGINS WHEN IST SURVEILLANCE RESULTS ARE IN THE REQUIRED ACTION RANGE (AIT F03007687)
This memorandum is in response to Mr. Chrissotimos's March 4, 1987. request for NRR's position on when the Technical Specification ACTION statement clock begins when IST surveillance results are in the Required Action Range as defined by Section XI of the ASME boiler and pressure vessel code. NRR's position on this issue is the same as that which was provided earlier by IE (memorandum from
- 5. Bryan, IE to R. L. Lewis, RII dated March 17, 1980, enclosed).
That is, the Technical Specification ACTION statement time begins upon detennining that the data falls into the Required Action Range and indicates that a tested component cannot perform within its design envelope. No time is allowed for an analysis to determine whether the component can be considered OPERABLE.
With respect to Mr. Chrissotimos's request for an Information Notice on this matter, I believe that regional management awareness of this position coupled with regional action makes ao'ditional generic communication unwarranted at this time.
Gharles E. Rossi,.c irec or$ Y Division of Operational Events Assessment, NRR
Enclosure:
As stated cc w/ encl:
. P. Shemanski, NRR
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SS!!:S ;!o. 6025 7
9 "EMORANDUM FOR: R. C. Lewis, Acting Chief, RO&NS Branch, Region II FR0": Sanuel E. Bryan, A/D for Field Coordination, DROI, IE \
SUSJECT:
OPERABILITY REQUIREMENTS FOR PUMPS (AITS NO. F02-700028-H07)
As we understand then, the questions in your february 1 memo are:
- 1. Do the Technical Specification ACTION statement time perios run consecutive er concurrently with the data evaluation time (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />) given in IWP-3220 of Section XI of the ASME Boiler and Pressure Yessel Code,1974 Edition sith Addenda thru the Sumer 1975, and
~ 2. When should the test results be reviewed and, if out-of-specification, the associated puup declared inoperable?
The answer to the first goestion is the Technical Specification ACTION state-
- ent ti~e period starts af ter the determination is made that the pump is inoperable as defined in W ion XI, SWP-3230fc). If the data is within the
!'equired Action Range of Table IWP-3100-2 and it is decided to recalibrates the instruments and rerun the test, as provided for in IUP-3230(b), the Technical Specification ACTION statement time starts when the determination is rade that the data is within the Required Action Range. The reasoning Lehind the prcceeding statement is that once the determination is made that the data is within the Required Action Range the pump must be declared inoperable. The provisions in IWP-3230 to recalibrates and rerun the test to show the pump is still capable of fulfilling its function are interpreted by us, as an alternative to replacement or repair, not an additional action that can be taken before declaring the pump inoperable.
The erswer to the second question is that~as soon as the data is recognized as being within the Required Action Range the pinp must be declared inoperable.
l Section XI, IVP-6230, " Inservice Test Plans", states" Eat the test plan shall include "The reference values (Tabic IWP-3100-1), limits of Pt and Tb (Table l IUP-3100-2), and any other values required by this Subsection." This statement CONTACT: J. C. Stone, IE rac7 x,tni t
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... o e R. C. Lewis 2 R I 71980 l
l then requires the acceptance criteria to be included in the test plan.
With that infomation available, the shif t supervisor should be able to make the determination as to whether or not the data meets the requirements.
The important point is that once the data becomes available that shows the pump cannot meet the inservice inspection requirements and by dM inttion cannot fulfill its function then the punp must be declared inope.able. ..
We have discussed the above interpretations with DDR personnel and the Standard Technical Specification Group and they agree. If you have any further questions, please call.
Samuel E. Bryan
. Assistant Director for Field Coordination
- Division of Reactor Operations Inspection, IE-cc: N. C. Moseley, IE J. S. Wetmore, STS G. Johnson, EB J. C. Stone, IE -
F. J. Nolan, IE J. 1. Riesland, IE S. P. Pessitt, RI!
E. J. Brunner, RI R. F. Heishman, RI!!
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FEB 011980 SSINS 6025 MDf0RA!MM FOR: S. E. Bryan, Division of Reactor Operations Inspection, Office of Inspection and Enforcement FROM: R. C. Lewis, Acting Chief, Reactor Operations and Nuclear Support Branch, Region II
SUBJECT:
OPERABILITY REQUIRDiENTS (AITS No. F02700028)
A concern was recently identified involving the starting point for time periods in Technical Specification ACTION statements.when equipment has been declared inoperable under the ASME Section XI testing program.
AS!!E fection XI, IVP-3220, states "All test data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test". IVP-3230(c) states, in part, "If the deviations f all within the ' Required Action Range' of Table IVP-3100-2, the pump shall be declared inoperative. . . . . "
In most cases equipment covered by ASME Section XI, IVP, is also covered by Technical Specifications and, if, declared inoperable, vould result in the plc.nt entering an ACTION statement. These ACTION statements generally have a time period af ter which, if the equipment is still inoperable, the pidat must perform some specific action (shutdown, cool down, etc.).
The concern arises in the area of the aforementioned data analysis interval versus the Technical Specification ACTION statement time period. It is quest unable whether or not these periods run consecutively, concurrently or otherwise. The enclosed scenario's detail likely plant events and are indicative of actual experience.
Region II believes that a reasonable time for data analysis is not more than two shif ts (16 hcurs) except in extreme circumstances. The Technical Specification ACTION time should start immediately af ter the data has been reviewed by the cognizant supervisor (shif t supervisor, foreman, etc.). Licensee procedures must require prompt review by the cognizant supervisor when test results fall outside acceptance criteria.
CONTACT: B. R. Messitt 242-5595 f "p m .
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FEB 011980
- s. E. Bryan ,,, l We do not believe that ASME Section XI statement on evaluation of test data relieves the licensee of action statements in Technical Specifications. i We request that this matter be reviewed and our understanding be confirmed or guidance issued to provide uniformity.
R. C. Lewis, Acting Chief Reactor Operations and Nuclear Support Branch l
Enclosure:
Field Experience Regarding Equipment Operability 1 1
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ENCLOSURE FIELD EXPERIENCES RECARDING EQUIPMENT OPERABILITY 4
- 1. A Section XI test is run on an engineered safety feature pump on Saturday mooring and the data f all on the lowest limit of the
" Required Action Range" just above the " Alert Range". The plant Performance Engineer, who performs the data review and would be the individual- to declare the pump inoperative, is not on site until Monday morning when the data set is reviewed. -
On Monday, the Performance Engineer reviews the data and declares the pumpinoperable per the Technical Specifications and thus
" starts the clock" on the ACTION statement time period.
Most Licensees would view this as acceptable due to the 96-hour statement included in IVP.
- 2. A saf ety-telated pump is tested and the data f all within the
" Required Action Range"The Performance Engineer orders that the instruments be recalibrates (24-36 hours) and the test re-run as allowed by IVP-3230(b). The test is re-run and the data are
. still in the " Required Action Range". The Performance Engineer declares the pump inoperable and " starts the clock".
Th$s might be done in order to extend operation until a scheduled j outage. -
l
- 3. A safety-related pump is tested and the shif t supervisor notes that the data appears to f all into the " Required Action Range"; however, he feels it should be further analyzed. The data are transmitted to the Ferf ormance Engineer who waits 2-3 days to make his analysis and then declares the pump inoperable thus " starting the clock" (at this point he could also request the test be re-run, adding more time to the cycle).
This also might be done to extend operations until a scheduled outage or to delay plant shutdown until the weekend.
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_ _ _ _ _ _ . _