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. y1-i.;:L GNd MEMORANDUM FOR: Distribution _ga,- i Dennis M. Crutchfield, Assistant Director FROM:
for Safety Assessment DL cc.[w M h ,.
SUBJECT:
TECHNICAL SPECIFICATION OPERABILITY REQUIREMENTS p.
c6 The enclosed provides guidance on the subject of Technical Specification Operability requirements. Questions are often raised with regard to the operability of support, systems due to the definition of operability included in technical specifications. Also, questions arise with regard to specific operability requirements for modes or conditions of operation other than those specifically addressed by plant safety analysis.
In that these and other potential questions on technical specification - - -
operability requirements rnay be answered by the enclosed guidance, it is provided for your use.
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Dennis M. Crutchf eld, sistant Director for Safety Assessmen Division of Licensing
Enclosure:
As stated 11 19er
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, 2 In that all nuclear plants were not designed and built in conforinance to the same regulatory requirements, the design basis events addressed in FSAR's include differences depending on requirements which existed at the time the construction permit and/or operating license was issued. However, some new regulatory requirements have been issued that are applicable to all plants while others have limited applicabilty. Thus, FSAR's as well as applicable regulatory requirements include information which is essential to the definition of design basis events for a facility.
Applicable Operatine Conditions The LCOs specify operability requirements in terms of plant operating modes or conditions.. For the majority of the specifications, redundant systems or components are required to be operable to assure that the requirements of the single failure criterion are satisfied. When a system or component is inoperable, actions are required to restore the system or component to operable status in specified time limits or to place the plant in a mode or condition for which the LCO no longer applies. The LCO requirements for some operating modes or conditions only require one rather than redundant systems or components to be operable.
' Although the operability requirements are specified in terms of operating modes or conditions, these are chosen to be consistent with the analysis of design basis events. For many events, the analysis is limited to consideration of the power mode of operation with emphasis on full power operation where conditions present the greatest challenge to safety limits.
For some events, consideration is given to 251 or zero power conditions if these cases represent a more limiting condition with respect to safety limits. Of ten only the bounding, i.e. most limiting, conditions are
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presented in FSAR safety analysis.
- With respect to LCO requirements for conditions or modes other than power operation, the requirements have been generally based on engineering judgement rather than specific event analysis. The ECCS are typical of those systems and components for which the LCO requirements for operability, other than the power mode of operation, have been based on engineering judgement for events which are classified as accidents and anticipated transients.
Even for those design basis events for which an analysis is provided during the power mode of operation, the Technical Specifications do allow exceptions to the requirements of the General Design Criteria (GDC) for limited periods of time. For example systems or components are allowed to be out-of-service for testing or maintenance for specified time intervals. During such times the requirements of tne single failure criterion as specified in the GDC for specific systems may not be satisfied.
For some events, particularly those due to natural phenomena such as earthquakes, floods, or stonns, the safety considerations relate to the capability to shutdown the plant and mairtain it in a safe condition.
Generally the operability requirements of systems or components are based on the modes or conditions for which these systems or components are effective to accomplish this function and may include essentially all operating modes. Fires, missiles, and accidents at nearby locations are another group of events for which similar requirements may apply.
Design basis events are analyzed to deinonstrate that a plant can be operated without undue risk to pud ic health and safety. Other than as specified by a regulatory requirement, each design basis event is taken as individual case and not in combination with other design bases events. For those systems for which the design criteria specify that the safety function shall be provided with either onsite or offsite power system operation assuming the other is unavailable, a situation exists where the event of a loss of offsite power is considered simultaneously with an event in which <
the safety function of such systems is required.
However, the fact that safety related structures, systems, and components are designed to remain functional during a Safe Shutdown Earthquake (SSE) and assure the integrity of the reactor coolant pressure boundary, the capability to shutdown the reactor and maintain it in a safe condition or the capability to mitigate thc consequences of accidents, as a design basis event the SSE is not assumed to occur simultaneous with accidents.
The fact that many systems and components perform dual function roles with regards to accident mitigation and for events for which safe plant shutdown
, is required, places additional reliance on a knowledge of design basis events for the correct application of operability requirements when applied
' to systems and components which provide support functions. Thus, it is essential to the proper application of the technical specifications operability requirements, to know the applicable design basis events for a facility.
For the Reactor Trip and Engineered Safety Feature Actuations systems, the technical specifications generally indicate specific modes or conditions for which automatic features of these systems are required to be operable. For many systems, manual initiation or operation capabilities are provided in addition to automatic features. When the technical specifications operability requirements are stated in terms of overall system requirements, specific control features such as automatic or manual may not be specif-ically addressed in the operability requirements. Further, in many cases the FSAR may only address bounding analysis, typically for the power mode of
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. operation, such that a specific design basis is not stated for other modes of operation.
In such cases, it is incorrect to assume that the safety analysis assumptions for a design basis event are applicable to all o+her modes of operation. From the standpoint of safety, the technical specifications set forth the limiting conditions of operation and actions which are appropriate for modes of operation other than those addressed by L specific design basis events analysis or applicable regulatory requirements.
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Table I summarizes the principal criteria for Technical Specification operability requirements.
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Table 1 1 Principal Criteria for Technical Specification Operability Requirements
- 1. The system
- operability requirements should be consistent with the safety analysis of specific design bases events and regulatory requirements. !
- 2. The system operability requirements including related regulatory requirements may be waived as a consequence of specified action statements. -
- 3. Design basis events are plant specific' and regulatory requirements rey be plant specific considerations related to technical specification
. operability requirements. -~
4 The system operability requirements that are based on safety analysis of specific design basis events for one mode or condition of operation rey not be the same for all modes or conditions of operation.
- 5. The system operability requirements extend to necessary support systems :
regardless of the existence or absence of support system requirements.
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- 6. The1 operability of necessary support systems includes regulatory requirements but not consideration of multiple (simultaneous) design basis events.
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- The term system is used in this table to include a subsystem, train, component or device as may be applicable to the STS operability requirements for the same. ,
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W i, l Tw f i EGM 85- 05 MEMORANDUM FOR: T. E. Murley, Regional Administrator, Region I ,
J. N. Grace, Regional Administrator, Region II l J. G. Keppler, Regional Administrator, Region III R. D. Martin, Regional Administrator, Region IV J. B. Martin, Regional Administrator, Region V FROM: Harold R. Denton, Director .
Office of Nuclear Reactor Regulation James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
RELIEF FROM TECHNICAL SPECIFICATION LCO'S It has come to our attention that some Regions have been granting relief from technical specification limiting conditions for operation upon request from licensees without following the procedures for granting license amendments and, in some cases, without obtaining NRR concurrence prior to granting the relief. In a number of instances, scme of which were documented in response to an April 5,1985 request from Hugh Thompson, licensees would have been In each case, required to shut down or to delay start-up absent some relief.
the licensees were permitted to continue in operation or to start up and the event was resolved under the rubric of " enforcement discretion."
We are writing this memorandum to clarify the approach to be used for granting or denying amendments in situations in which the amendment cannot be processed before the limiting condition for operation action statement time ,
expires. l Emergency relief from the technical specifications may be given only in rare i circumstances for the short period of time it takes to process an emergency license amendment. When a limiting condition for operation in a technical specification will be exceeded within a few hours and if, as a consequence, the licensee will have to shut down the plant or to delay start-up, a licensee I may seek a temporary waiver of compliance with the requirement for a sufficient period of time to allow the staff to process an emergency technical specification amendment. The appropriate Assistant Director of the Division of Licensing in NRR, with the concurrence of the responsible Regional Division Director, may grant a temporary waiver of compliance with the requirement if the '
licensee has demonstrated in a written submittel provided before the TS LC0 expires that the plant can safely continue to operate without compliance with the technical specification during the time it will take to process the amendment request. Such relief may be considered only if the licensee's last minute request I for immediate action was due to circumstances beyond the licensee's control i and the licensee could not have reasonably foreseen the need for relief in time I for normal processing of the amendment request.
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k j. 4 JUL 15 885 Regional Administrators The waiver should be documented by the Division of Licensing, NRR and should be for a fixed period of time, normally not to exceed the two working days it takes to process the amendment.
Enforcement action will not be taken for the period during which the waiver is in effect.
The Assistant Director of the Division of Licensing in NRR should proceed to expeditiously process the amendment request, in accordance with existing procedures for emergency amendments. If it is determined during the processing of the amendment that it raises a significant hazards consideration, the amendment should not be granted without prior notice and an opportunity for a hearing. In addition, if during the processing of the amendnent such a ,
finding is made, any temporary waiver is to be immediately suspended and the compliance with the action statement should be required.
As a separate matter, if it is four.d during the safety review that an LCO has no safety basis, it should be deleted or revised using existing procedures.
Except in the rare circumstances described above, if an LCO in a technical specification will be exceeded before a license amendment can be granted, the licensee must nonetheless take the action required by the action statement accompanying the LCO. Of course, a licensee may depart from its technical specifications, pursuant to the provisions of 10 CFR 50.54(x), without prior NRC approval in an emergency when it must act immediately tc protect the 4 public health and safety.
e to d R. e. on, irector Office of Nuclear Reactor Reculation
, l r.es M. Tay1 , Director ;
fice of In pection and Enforcemer.t I
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UNITO STATES 8 n NUCLEAR REGULATORY COMMISSION i 5 ! WASHiteo70ed, D. C. 305e6 patrJITy ROUTIRCe j
( November 22, 1985 y j -
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FIL M MEMORANDUM FOR: Thomas E. Murley, Regional Administrator Region !
J. Nelson Grace, Regional Administrator Region II James G. Keppler, Regional Administrator Region !!!
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Robert D. Martin, Regional Administrator Region IV j John B. Martin, Regional Administrator Region V FROM: Hugh L. Thompson, Jr., Director .
Division of Licensir,'g, NRR
SUBJECT:
TECHNICAL SPECIFICATION INTERPRETATION l l
Reference:
- 1. Memorandum from Darrell G. Eisenhut, Director, I Division of Licensing to Charles E. Norelius, j Director, Division of Projects and Resident j Programs, dated March 11, 1983 )
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- 2. Memorandum from Hugh L. Thompson, Jr., Director.
Division of Licensing to Richard W. Starostecki, Director, Division of Reactor Projects, Region !
dated August 9, 1985
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The purpose of this memo is to delineate NRR's interpretation of those provisions in the Standard Technical Specifications invoked when it is detemined that a surveillance test has been missed. Specifically l Specification 4.0.3 states " Failure to perfom a Surveillance Requirement l within the specified time interval shall constitute a failure to meet the l DPERABILITY requirements for a Limiting Condition for Operation. Exceptions i to these requirements are stated in the individual specifications. Surveillance I Requirements do not have to be performed on inoperable equipment."
Reference 1 provided NRR's position relative to when a Technical Specification l Action Statement is entered as a consequence of failure to perfom required surveillance tests. Reference I stated that Action Statements are entered when the Surveillance Requirement should have been perfomed rather tha the time it is discovered that tests were not performed. '
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-2 November 22, 1985 Regional Administrators Subsequently, NRR has revised its position. This revised position is documented in Reference 2 and can be summarized as follows:
Consistent with the provisions of Standard Technical i Specification 4.0.3, the failure to perform a surveitlance l requirement within the specified time interval constitutes a failure to meet.the operability requirements for a Limiting Condition for Operations. The time limitations of the Action Statement are applicable from the point in time that it is recognized that the Limiting Conditions for Operation are not met. However, in such a case the basis for determining the safety significance in an enforcement action should not be limited to consideration of when it was recognized that the surveillance requirement was not met but rather on the actual total time that j
the requirements of the Limiting Condition for Operation were not met.
This interpretation precludes having to initiate an immediate shutdown upon discovering a surveillance has been missed. We view the potential incremental increase in risk associated with the time required to perform the missed surveillance small enough to justify this interpretation. 4 As noted in Reference 2, the Technical Specification Review Group is preparing additional guidance related to Section 3/4.0 of the Standard Technical Specifications. This guidance will provide further clarifications of time limitation related to limiting conditions for operation and surveillance requirements. This guidance should be available for use by Resident Inspectors and Regional personnel in the near future.
<hugh L9fhomp Division on, Jr., Director of Licensing
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