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i June 21, 1984 h
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l MEMORANDUM FOR:
Thomas E. Murley, Regional Administrator, Region I
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James P. O'Reilly, Regional Administrator, Region II i
James G. Keppler, Regional Administrator, Region III John T. Collins, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V FROM:
Richard C. DeYoung, Director Office of Inspection and -Enforcement
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SUBJECT:
RELEASE OF IE INSPECTION MANUAL TO LICENSEES j
AhD THE PUBLIC j
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The purpose of this memorandum is to provide you information and guidance on the release of the IE Inspection Manual to licensees and to the public. As (q
noted in the enclosed proposed Regional Office Notice to your staffs, there j
have been questions regarding the releasability of the Inspection Manual.
As j
L a general rule, all portions of the manual are placed in the Headquarters j
Public Document Room (PDR). The only exception to this rule is where a specific request is made by the issuing cognizant IE Division.
In those cases,
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a full explanation justifying the exception must be given.
At the present j
time, there are no manual chapters, or portions thereto, that have not been
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released.
In future such instances, you will be notified of the restriction by separate memorandum.
Therefore, there are no restrictions on the release of the IE Inspection Manual to licensees or the public. However, any requests for copies of the manuel should be referred to the PDR in accordance with 10 CFR 69.7, " Publicly available records," and 69.8, " Requests for records." The PDR maintains a complete up-to-i date set of the IE Panual, and separately, all the change notices.
Therefore, they are the most appropriate facility to provide any copies.
If you do provide any copies, an appropriate fee must be collected to cover the cost of reproduction.
For your information, the current cost for reproducing the entire IE Inspection Manual is $500.00.
This does not preclude resident inspectors or your staff from lending a copy for reproduction by the licensee or public at their expense.
It is hoped the foregoing clarifies any questions regarding release of the IE Inspection Manual. Appropriate additions will be made to the IE Manual to formalize this information.
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- j-Regional Administrators June 21,1984 i
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Please ensure that all regional staff members who may be requested to provide copies of the IE Inspection Manual, or porticns thereto, are aware of the foregoing. The' enclosed proposed Regional Notice is provided as a suggested method for promulgating this information.
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B. C. peyo;wz;ned gg Richard C. DeYoung, Director Office of Inspection and Enforcement
Enclosure:
Proposed Regional Notice DISTRIBUTION:
E!I QASIP Reading SRamos Reading-RCDcYoung JMTaylor JNGrace f
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SRamos EJordan DEPER Branch Chiefs DEPER Section Chiefs QASIP Branch Chief QASIP Section Chiefs CKime WMullinix JBlaha Regional Division Directors
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- See previous copy for concurrence IE:PSB: ADMIN IE:PSB: ADMIN IE:DIR/PSS
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'5/3/84 6/4/84 6/6/84 IE:TA/QASIP IE:0RPB IE:DD/QASIP IE:DIR/QASIP IE:D/ b c IE:
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PROPOSED
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'1 Regional Office Notice No.
RELEASE OF IE INSPECTION MANUAL TO LICENSEES AND THE PUBLIC A.
Purpose:
To inform the staff thet the IE Inspection Manual is available in the NRC Public Document Room (PDR), 1717..H Street, N.W., Washington, D.C.
20555.
B.
Discussion:
The question is often asked whether or not portions of the Inspection Manual may be released to licensees. The Inspection Manual (all three sections) is maintained up-to-date in the PDR. All updating materials (Change Notices) are maintained separately. Accordingly, this document
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is available in whole or in part to the public and licensees for copying in accordance with 10 CFR !$9.7 and 9.8.
There may be occasions when a manual chapter may not be released.
In these instances, a full explanation justifying such' restriction must be provided by the cognizant IE Division Director. At the present time, there are no manual chapters that are restricted.
You will be advised by sep6 rate Regional Notice of any restrictions on the releasability of any IE Inspection Manual Chapters.
Accordingly, there are no current restr:ctions on release of the IE Inspection Manu61 to licensees or the public. However, any reauest for copies should be referred to the NRC PDR. This does not preclude lending the Manual to a licensee or the public for reproduction at their own expense.
If copies are provided, you are reminded that an appropriate
' fee must be collected to defray the costs of reproduction.
C.
Action:
No specific action is expected on the contents of this Notice. However, all the professional staff should be knowledgeable of the information contained herein.
D.
Contact:
p Questions or cor:vnents regarding this Notice should be cirected to the DRMA at extension s
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Cancellation Date:
This Notice is cancelled for record purposes on October 31,$1984 Deputy Regional Administrator i
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MEMORANDUM FOR: Thomas E. Murley, Regional Administrator, Region I Ja s P. O'Reilly, Regional Administrator, Region 11 mes G. Keppler Regional Administrator, Region III Robert D. Martin,, Regional Administrator, Region IV John B. A'artin, Regional Administrator, Regi.on Y FROM:
Richard C. DeYoung, Director 1
Office of Inspection and Enforcement
SUBJECT:
NOTIFICATIONS TO THE NRC OPERATIONS CENTER AND REPORTING EVENTS IN LICENSEE EVENT REPORTS The purpose of this memorandum is to clarify the requirement for licensees to report to the Headquarters Operations Center en event nr condition that results in multiple failures of the reactor protection systerr RPS). This guidance is also applicable to the requirement for licensees to report events as Licensee Event Reports (LERs). This issue has arisen es a result of a recent event at Susquehanna Unit I where multiple failures occurred in the scram system, but the licensee did not consider it necessary to report the failures to the Headquarters Operations Center.
The Susquehanna Unit 1 event occurred on October 6,1984, while performing single ccntrol rod scram time testing.
One of the control rods scheduled for testing failed to scram when the scram pilot solenoid velve stuck in the energized position.
Subsequent testing of the remaining rods revealed that 3 additional rods would not scram and that 11 control rods exhibited initial hesitation.
Both Units 1 end 2 were at power when the problems occurred.
The paragraph of 10 CFR 50.72 that requires reporting of all multiple failures and some single failures is paragraph 50.72(b)(2)(iii), which requires the licensee to notify the NRC Operations Center as soon as practical and in all cases within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the occurrence of:
CONTACTS:
10 CFR 5C.72 C. E. Rossi, 1E (301)492-4193 30 )49
$5 IO CFR 50.73 2
F. J. Hebdon, AEOD (301)492-4480 45o%oSog-JM 14 d5 399
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-Regional Administrators (iii) Any event or condition that ekone cou(d have prevented the fulfillment of the safety function of structures or systems that are needed to:
J (a) Shut down the reactor and maintain it in a safe shutdown l
condition, (b Re, move residual heat, (c Co'ntrol the release of radioactive material, or (d Mitigate the consequences of an accident.
The comparable paragraph in 50.73, which contains identical words, is 50.73(a)(2)(v).
Several written documents provide guidance on interpreting these rules including NUREG-1022, " Licensee Event Report System," Supplement I to that NUREG, and the preambles to the Federal Register Notices used to publish 10 CFR 50.72 and 50.73.
For example, in regard to what is meant by "could" the Federal Register Notices that published these rules (10 CFR 50.72 and 10 CFR 50.73) have a preamble that says:
1 Finally, the Commission recognizes that the licensee has to decide when personnel actions could have prevented fulfillment of a safety function.
For example, when an individual ir. properly operates or mainteins a component, that person might conceivably have made the same error for all of the functionally redundant components (e.g.,
if an individual incorrectly calibrates one bistable amplifier in the Reactor Protection System, that person could conceivably incorrectly calibrate all bistable amplifiers).
In regard to whether even a single component failure is reportable, the preamble to the Federal Register Notice says:
If a component fails by an apparently randor mechanism, it may or may not be reportable if the functionally redundant component could fa'il by the same mechanism.
Anytime a single rod fails to scram, the licensee may have a reasonable doubt that other rods would fail to scram.
If multiple rods f ail to scram, there is little doubt that other rods could be affected and, thus, this is an event or condition that could prevent the fulfillment of the safety function (i.e., the RPS scram) needed to shut down the reactor.
In your interactions with licensees, please stress that the intent of both 50.72 and 50.73 is that multiple failures in safety systems should be reported.
If your staff or licensees have questions regerding interpretation of 10 CFR 50.72, please contact Eric Weiss or Ernie Rossi in IE.
If your staff or licensees have i
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Regional Administrators,
questions regarding interpretation of 10 CFR 50.73, please contact Fred Hebdon 4
(FTS492-4480) in AEOD. We will be glad to participate in discussions on i
problems which you have with interpretation and/or enforcement of these rulef.
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C.
'oung, Director
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cc w/ enclosure:
J. Axelrad, 1E H. Denton, NRR G. Holahan, NRR T. Dorian, ELD l
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STil 50-483 MEMORANDUM FOR:
Richard L. Spessard, Director Division of Reactor Safety Region III TROM:
Hugh L. Thompson, Jr., Director Divis'on of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
CLOSURE VERiflCATION Of NORMALLY CLOSED CHECK VALVES DURING PRE 0PERATION TESTING AT CALLAWAY (TIA 83-117)
REFERENCE:
Letter from R. L. Spessard to D. G. Eisenhut on the above subject, dated November 8, 1983.
The referenced letter requested the staff position regarding testing of normally closed check valves for closure capability during preoperational testing and during p' ant life.
The staff position is that normally closed check valves, that have a safety function in the closed position, shr,uld have the closure function verified both during preoperational testing and periodically throughout the plant life, in addition, the staff verifies that closure verification testing is specified in their normal review of the IST program, and if not, measures are taken to see that the program is revised.
I in an attempt to have the ASME clarify ambiguities within Section XI of the ASME Code rearding colve categorization and leak testing, the staff submitted an inquiry to the sv iety.
The response time from the society (approximately Enclosed one year) was a majv f actor in the delay of this response to you.
is a more detailed staff evaluation of the subject.
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]\\HughL.Thompsof],Jr., Dire 3 4
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Division of Licensing Office of huclear Reactor Regulation
Enclosure:
As stated cc:
T. Martin 7
P. Bemis N Q g(066]-
M-R. Denise g
L, 4 T. Bishop
, 4, P. Wohld g(.
.s P. Pelke
- 3. Little, Resident inspector
Contact:
T. Alexion, LB#1 (FTS 497-8929)
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The Code ambiguity arises from the fact that paragraph IWV-3522(b) "Normally.
p Closed Valves" discusses in detail the performance of tests for periodic i
verification of the valve opening function but does not specifically mention h
. periodic closure verification' tests.
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in an attempt to have ASME clarify the ambiguity ~in the Code paragraphs, the y
staff submitted a related inquiry to the society.
The response.to the inquiry, recently received, unfortunately was inconclusive.
The staff inquiry was
{f written in b' road terms to cover both check and gate valves used in applications where the valve disk in the closed position was essential to the fullfillment i
' of the valve's safety related function.
The inquiry asked whether such valves should'be categorized as'A or AC and leak tested in accordance with paragraph IWV-3420.
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If'the ASME response was'"no" to the A or AC categorization and leak tests, i
it was hoped that the reply would at least confirm that the intent of IWV-e 3522 for check' valves and IWV-3412 for gate valves was that some kind of closure verification-test was to be performed.
Unfortunately the response k
that was received is concentrated on the categorization aspect of the inquiry and simply states that categorization is the Owner's (licensee's) responsibility.
'Nevertheless, the staff personnel that participate in ASME-Section XI~ standards i
writing activities were present at some of the meetings when the inquiry was discussed.
The impression received at the meetings was that the intent of the Code for both check valves and gate valves was that periodic verification of
- closure function is required for valves, whether normally open or closed, if they perform a safety function in the closed position.
Verification would also be' required during preoperational testing by paragraph IWV-3100 " pre-l service Tests" which requires that all tests to be performed periodically I
during plant life per IWV-3000 also be performed after installation and prior to service.
-One additional item that supports the requirement for periodic closure verification testing is that the latest draft of. ANSI /ASME OM-10 " Inservice Testing of Valves"'
specifically requires that check valves be exercised or examined in a manner which verifies obturator travel to the closed, full open, or partially open position required to fulfill its function.
ANSI /ASME OM-10 is generally expected to be an eventual replacement for subsection IWV of ASME Section XI.
p In summary, the staff position is that normally closed check valves that have a safety related function in the closed position should be tested for closure capability during~preoperational testing and periodically during plant life in'accordance with the intervals specified in IWV-3520.
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i EflCLOSURE STAFF EVALUA110N REGARDlflG lESTING
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0F NORMALLY CLOSED CHECK VALVFS 4
FOR CLOS _UJJE CAPABILITY
Reference:
November 8, 1983 menorandum from R. L. Spessard, Region 111, to Darrell G. Eisenhut, NRR The referenced memorandum states that there is no apparent requirement in Section XI of the ASME Code to verify closure of normally closed check valves that are classified Category C in accordance with Subsection IWV of the code.
a It correctly points out that there are normally closed check valves, other l-than Containment Isolation Valves (CIVs) and Pressure isolation Valves (PlVs),
j that have a sefety related function in the closed position.
An example of j
such valves is given for the Callaway plant and stated to be a normally closed ECCS suction line check valve between the Refueling Water Storage Tank and the
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ECC? pumps.
It is stated that verification of the closure function of normally closed check valves is a generic safety concern to the extent that surveillance is never done after construction to verify the closure function.
Specifically, the staff position was requested regarding:
1)
Testing of normally closed check valves for closure capability during preoperational testing.
2)
Testing of normally closed valves for closure capability during plant life.
In response, the staff position is, and has been, that normally closed check valves, that have a safety function in the closed position, other than CIVs and PlVs, should have the closure function verified both durino preoperational testing and periodically throughout the plant life, in the staff's normal review of IST programs whenever a valve of this type is identified, the staff verifies that closure verification testing is specified in the IST program, and if not, the staff either requires that the program be revised to so specify or the staff specifies in the IST SER that closure testing must be performed.
Even though that is the position that the staff has beer implementing, the staff does believe that there is some ambiguity within ASME Section XI re-garding closure verification testing of normally closed check valves.
Check valve testing is specified in paragraph IWV-3520 of the 1983 Edition of Section XI.
Paragraph IWV-3522 " Exercising prncedure" requires that check valves be periodically exercised to the position renuired to fulfill their function.
Testing intervals required vary from a minimum of every three months to each Cold Shutdown.
(Earlier Section XI editions are essentially the same.)