ML20246J382

Responds to Concerns Re NRC Position on Application of Plant Tech Spec for Inoperable Support Sys.Analysis Prepared by NRR Which Responds to Questions Raised Encl

ML20246J382
Person / Time
Site:	Clinton
Issue date:	08/21/1989
From:	Murley T Office of Nuclear Reactor Regulation
To:	Hall D ILLINOIS POWER CO.
References
NUDOCS 8909050132
Download: ML20246J382 (14)

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UNITED STATES NUCLEAR REGULATORY COMMISSION

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AUG 21 1999 Docket No. 50-461 Mr. D. P. Hall Senior Vice President Illinois Power Company P. O. Box 678-Clinton', Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS

This is in response to your concerns .regarding the NRC staff's position on the application of the Clinton Technical Specifications (TS) for inoperable support - systems. These concerns were expressed in your letters dated September 20 and December 9, 1988, and were discussed with me during my visit to the Clinton Station.

I am enclosing an analysis prepared by the NRR staff which responds to the questions you raised.

I share your desire for improved TS and hope this letter and its enclosure adequately address your specific concerns. There is still a great deal more that can be done by the NRC and industry to improve TS. I believe that the concerns raised by Illinois Power Company will contribute to the success of those efforts and I encourage your continued support of our TS improvement efforts.

Sincerely, o

f g J.o f / W -

omas E. Murley, Direc r 0 fice of Nuclear Reactor Regulation

Enclosure:

NRR Staff Analysis cc w/ enclosure:

See next page OFvf I

t 8909050132 890821 FDR ADOCK 05000461 P FDC

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Mr. D. P. Hall Clinton Power Station Illinois Power Company Unit.1

'CC:

Mr. Dale L. Holtzscher Illinois Department Acting Manager - Licensing and Safety of Nuclear Safety Clinton Power Station Division of Engineering P. O. Box 678 1035 Outer Park Drive, 5th Floor Mail Code V920 Springfield, Illinois 62704 Clinton, Illinois, 61727 Mr. R. D. Freeman Mr. Donald Schopf er Manager-Nuclear Station Engineering Dept. Project Manager Clinton Power Station Sargent & Lundy Engineers P. O. Box 678 35 East Monroe Street Clinton, Illinois 61727 Chicago,. Illinois 60603 Sheldon Zabel, Escuire Schiff, Hardin & Waite 7200 Sears Tower 133 Wacker Drive Chicego, Illinois 60606 Resident Inspector U. S. Nuclear Regulatory Comission RPJ3, Box' 229 A' Clinton Illinois 61727 Mr. L. Larson Project Manager General Electric Comp 6ny 175 Curtner Avenue, N/C 395 San Jose, California 95125 Regional Administrator, Region Ill 799 Roosevelt Road, Bldg. f4 Glen Ellyn, Illinois 60137 Chairman of DeWitt County c/o County Clerk's Office DeWitt County Courthouse Clinton, Illinois 61727

- ___-____ __-____ __ a

NRR Staff Analysis Technical Specification Requirements Clinton Power Station Staff Position The Clinton Technical Specifications (TS) include the standard definition of OPERABLE-0PERABILITY that exists in the TS for most plants. This definition establishes the principle that a system

• is operable when it is capable of performing its specified function and when all necessary support systems are also capable of performing their related support functions. The corollary is that a system is inoperable when it is not capable of performing its specified function or when a necessary support system is not capable of performing its relaTed support function.

The definition of operability affects the manner in which the requirements for a Limiting Condition for Operation (LCO) and its associated remedial actions are applied when a support system is inoperable. If the licensee determines that a TS system is capable of performing its intended function with an inoperable support system, then no additional action is needed. If the licensee determines that a TS system could not perform its intended safety function with an inoperable support system, then the TS LCO must be entered and appropriate remedial actions taken. This action shall occur regardless of whether or not the support system is covered by TS.

Moreover, other TS systems similarly affected by the inoperable support system must be treated likewise. Though the most limiting or restrictive action would influence the licensee's action, all other TS system LC0's must be reviewed for applicability and entered, if appropriate, and necessary remedial actions taken for those systems affected. This may include entering TS 3.0.3 as deemed necessary.

Licensee Concerns The licensee's concerns with the remedial actions that apply when support systems are inoperable were summarized as follows:

1. Plant shutdowns would be required in circumstances which do not justify such action in order to maintain plant safety.

2. The time to perform preventative maintenance on support system is reduceo or eliminated.

3. Some support system TS requirements will be meaningless because supported system LCO's will require more restrictive remedial actions.

4. Unnecessary test starts of diesel generators are required.

• 5ystem as useo herein includes a system, subsystem, train, component, or device.

(

I __ -___ - - __ -___-__ _ -

s Two examples were cited to support the licensees concerns and are sumarized as follows:

Example 1 If the essential switchgear heat removal system is removed from service for planned maintenance, the associated DC battery charger, which occupies the same cooled space, must be declared inoperable. The battery charger has a 2-hour allowed outage time (A0T) af ter wl.ich the unit must shutdown.

Shutdown on such a schedule is unnecessary because neither AC or DC power has been lost and cooling of this equipment is provided by other equipment.

The A0T with AC power de-energized is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which is moot because it supports the battery charger that has a 2-hour A0T. Concerns 1, 2, and 3 above were identified as being applicable for this example.

Example 2 A diesel generator may be taken out of service to perform planred preventive maintenance or testing without requirements for test starts of the other diesel generators. However, if a support system for a diesel is removed from service for maintenance, the diesel generator would have to be declared inoperable and other diesel generators tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Concern 4 above was identified as being applicable for this example.

Staff Response to Licensee Concerns Some support systems play an indirect role in ensuring that a system is capable of performing its specified function. The Citnton switchgear heat ,

removal system, noted in example 1, is a case in point where a support system 1 maintains an acceptable environment for that equipment which is directly involved in performing functions that ensure plant safety. The question of whether a HVAC system performs a necessary support function, in any particular application, is a matter which licensees must consider in a manner that is consistent with the plant design basis. For the Clinton example, the FSAR states that the switchgear cooling (VX) system performs a necessary support function under conditions that normal cooling for the switchgear areas would not be available. Thus, this system is encompassed by the TS definition of o3crability and the retedial actions for the supported equipment, including tie battery charger, apply when this system is not capable of performing its specified function. It should be noted that credit cannot be taken for the cooling of support systems by the non-essential switchgear cooling that is normally in operation. In a design basis accident under loss-of-offsite-power conditions, this cooling source would be unavailable.

There may be some cases where a support system could be removed from service for preventivc traintenance or testing, and it would not be necessary to treat i all systems that are dependent upon that support function as being inoperable. 1 Such cases coulo involve the closure of a valve that would preclude a support system from performing its support function, yet there could be sufficient time for an operator to respond and restore that suppcrt system to service such that it would be capable of fulfilling its specified function. This approach, which could be identified and evaluated as part of an operability ,

determination of the supported system is not applicable in situations where the  !

plant design and licensing bases rely upon the support function being performed automatically or where there is insufficient assurance that the support system could be returned to service at the required time to perform its specified function consistent with the assumptions of the safety analysis.

With regard to the concerns that were identified based on the TS requirements that apply when the switchgear cooling system is inoperable, there are two potential solutions to these concerns. The first would be a proposed TS amendment to modify the TS such that a longer A0T would be available when equipment is inoperable solely due to the inoperability of the switchgear area cooling system. The second would be the potential for an analysis cecer 10 CFR Part 50.59 or through a license amendment to provide a technical justification for revising the design basis, through an FSAR revision, that demonstrates the switchgear area cooling system is not a necessary support function; i.e.,

there may be alternatives to assure an acceptable environment for the affected equipment in the absence of the operability of this system under design basis accident conditions.

In response to concern regarding excessive diesel generator start tests, it is the staff's position that when a support system for a diesel generator is inoperable due to planneo preventive maintenance or testing, the associated diesel ger.erator is also inoperable for the very same reason, i.e., for planned preventive maintenance or testing. Hence, consistent with the requirements of the current TS, this is not a case where start testing of the remaining diesel generators is mandatory.

With respect to the gereric aspects of the concerns that were identified, the staff recognizes that the need for understanding the design basis and conserva-tively applying the remedial actions of LCO's for the supported systems places a burden upon the licensee management and plant operators. However, as noted above, an inoperable support system may lead to either multiple or redundant supported systems being inoperable and the need to implement forced shutdown requirements. This could occur when a condition exists that one supported system is inoperable and its redundant counterpart system becomes inoperable due to an inoperable support system. Therefore, any guidance that a liter.see can de/elop to aid operator decisions related to design bases and ineperable support systfms will help to ensure that the appropriate actions are taken, and will reduce the burden on operators when support systems are inoperable.

Finally, a goal of the industry's and the NRC's TS improvement program is to remove inconsistencies in 15 requirements. TS which include remedial actions for systems that are more restrictive than those that exist for their associated support systems are an example of such inconsistencies and are unintended as well as undesirable. These will be addressed to the extent practical in the new STS being developed by industry. If licensees encounter situations where < unnecessary plant shutdowns would occur due to the implementation of remedial actions that apply when support systems are inoperable, they should discuss the matter with the Resident Inspector or the L'irector of the Division of Reactor Projects at the HRC Regional Office for their facility. Relief from TS requirements may be granted for situations that could result in unnecessary plant shutdowns provided that the appropriate administrative processes are followed and adequate technical justification is provided.

S_950.ry

-The definition of. OPERABLE-0PERABILITY embodies a principle that a system can '

' perform.its function (s) only if necessary support systens are capable of performing their related support functions. When a support system is inoperable, licensees must evaluate the impact that this has upon systems whose operability is dependent upon that support function. This clarification of required actions does not constitute a new or different staff position on the proper application of TS requirements for support systems. i Furthermore, as part of the TS im)rovement program, the dependency between support systems and the systems t1ey support will be re-examined to arrive at l

A0T's for support systems. The established A0T's will be consistent, assuring that the capability of the system they support would not be degraded below an unacceptable level when the support system is out of service.

_ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ .~

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/ J DockiN No. 50-461 /

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I Mr. D.-P. Hall /

Vice President /

Illinois Power Company ,f t

P. O. Box 678 /

Clinton, Illinois 61727

/,

'/

Dear Mr. Hall:

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SUBJECT:

TECHNICAL-SPECIFICATION REQUIREMENTS

This in in respons;p to your concerns on the NRC staff's position on the y

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application of the Clinton Technical Specifications (TS) for inoperable

. support systems. These concerns were expresspd in your letters dated

September 20 and December 9, 1988, and were discussed with me during my visit to the Clinton Station. /

th NPR staff which responds to the I:amenclosingananalysispreparedby/

questions you raised.

/

I share your desire for improved TS and hope this letter and its enclosure adequately address your specific cop'cerns. There is still a great deal more that can be done by the NRC and industry to improve TS. I believe that the concerns raised by Illinois P6xer Company will contribute to the success of those efforts and encourage y6ur continued support of our TS improvement efforts. /

/

/ Sincerely, i

/ Thomas E. Murhy, Director

/' Office of Nuclea Reactor Regulation

/

Enclosure:

, NPR Staff Analysis cc w/er. closure:

Lee next page

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DISTRIBUTION ~

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• PREVIOUSLY CONCURRED

• PDIII-2 *PDIII-2 *PDIII-2 *0TSB *RIII *D:00EA JHickman<tm LLuther DMuller EButcher EGreenman CRossi 1/31/89 1/31/89 2/1/89 4/20/89 O 5/3/89 5/3/89 l

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l Docket No. 50-461 Mr. D. P. Hall Vice President Illinois Power Company P. O. Box 678 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS ,f This in in response to your concerns on the NRC staff's'/

application of the Clinton Technical Specifications (4S)forposition on the inoperable support systems. Theseconcernswereexpressedinfourlettersdated September 20 and December 9,1988, and were ci:cus, sed with it.: durir.g .7j visit to the Clinton Station.

I am enclosing an analysis prepared by the N staff which responds to the questions you raised.

I share your desire for improved TS and e this letter and its enclosure adequately address your specific concerp)s. There is still a great deal more that can be done by the NRC and irfdustry to improve TS. I believe that the concerns raised by Illinois Powep' Company will contribute to the success of those efforts and encourage your continued support of our TS improvement efforts.

Sincerely, 7

Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

/

NRR Staff Analysis /,-

/

cc w/ enclosure: /

See next page /

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• PREVIOUSLY CONCURRED

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Docket No. 50-461 Mr. D. P. Hall Vice President Illinois Power Company P. O. Box 678 Clinton,. Illinois 61727 ,/

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS ,/'/.

[ This is in response to your concerns on the NRC staff's position on the applicationoftheClintonTechnicalSpecifications(TS)forinoperable support systems. These concerns were expressed in~your/l etters dated September 20 and December 9, 1988, and were discussed with me during my visit to the Clinton Station.

/

,/

.I am enclosing an analysis prepared by the NRR staff which responds to.the questions you raised. ,/

/

I share your desire for improved TS and hope this letter and its enclosure adequately address your specific concerns. There is still a great deal more that can be done by the NRC and industry to improve TS. I believe that the concerns raised by Illinois Power Company will contribute to the success of those efforts and enco. rage your continued support of our TS improvement efforts. /

/

j

/ Sincerely,

/

,/ Thomas E. Murley, Director

/ Office of Nuclear Reactor Regulation

/

Enclosure:

/

NRR Staff Analysis /

cc w/ enclosure: /

See next page /

/ t' h

DISTRIBUTION /

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'Mr. D. P. Hall Vice President

" Illinois Power Company P.O. Box 678 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS This is in response to your concerns on the NRC staff's p ition on the

! application of the Clinton Technical Specifications (TS for inoperable support . systems. These concerns were expressed in you letters dated September 20 and December 9,1988, and were discusse with se during my visit to the Clinton Station.

I am enclosing an analysis prepared by the NRR s ff which responds to the^

questions you raised.

I share your desire for improved TS and hop this letter and its enclosure adequately address your specific concerns., .There is still a great deal-more that can be done by the NRC and indeTtry to. improve TS. I believe that the concerns raised by Illinois Power C pany will contribute to the success of those efforts and encourage your co inued support of our TS improvement-efforts.

Sincerely.

Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

NRR Staff Analysis cc w/ enclosure:

See next page DISTRIBUTION Docket file NRC & Local PDRs PDIII-2 r/f LLuther LReyes MVirgilio DCrutchfield' .DMuller EButcher LCallan

. JSniezek Tliurley JHickman REmch RZinmerman CRossi EGreenman GHolahan WKane

• PREV OUSLY CONCURRED

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'Mr. D. P. Hall

.Vice President

' Illinois Power Company /

P.O. Box 678 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS This is in response to your concerns on the NRC staff's post ion on the applicationoftheClintonTechnicalSpecifications(TS)f inoperable support systems. Theses concerns were expressed _ in your etters dated September 20 and December 9,1988, and were discussed .w h me during my

( visit to the Clinton-Station.

I am' enclosing an analysis prepared by the NRR staf which responds to the questiord you raised.

'I share your desire for improved TS and hope th letter and its enclosure

. adequately addresses your specific concerns. ere is still a great deal.

more that can be done by the NRC and industry o improve TS I believe that the concerns raised by Illinois Power Compan will contribute to the success of those efforts and encourage your continu d support of our TS Improvement efforts.

incerely, Thomas E. Murley, Director Office of Nuclear Reactor Regulation Encilosure:

As stated cc w/ enclosure:

See next page DISTRIBui10N bocket file NRC &. ocal PDRs PDIII-2 r/f LLuther LReyes MVirgilio DCrutthfield DMuller EButcher LCallan JSniezek TMupley JHickman REmch RZimmerman CRossi= EG 'eenman GHolahan WKane

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Mr. D. P. Hall Vice President Illinois Power Company P.O. Box 678 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS This is in response to your concerns on the NRC staff's position on he applicati(noftheClintonTechnicalSpecifications(TS)forinop able support systems. Theses concorres trere expressed in your letters dated Septen.bar 20 and December 9, 1986, and were discussed with me ring my recent visit to the Clinton Station.

I am enclosing an analysis prepared by the NRR staff which responds to the questions you raised.

I shared your desire for improved TS ans hope this let/er and its enclosure adequately addresses your specif t: concerns. There is still a great deal more that can be : lone by the NRC and industry to improve TS. I believe that the concerns ratsed by Illinois Power Company wilVcontribute to the success of those efforts and encourage your continued support of our TS Improvement efforts.

Since/rely, omas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page DISTRIBUTION Docket file NRC & Local PDRs PDIII-2 r/f LLuther MVirgilio DCrutchfield DMuller EButcher JSniezek TMurley JHickman CRossi EGreenman GHolahan .

I

• PREVIOUSLY CONCURRED ,"'

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I l

./

/

Mr. D. P. Hall Vice President Illinois Power Company P.O.. Box 678 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS This is in response to your concerns on the NRC staff's posi ion on the application of the Clinton Technical Specifications (TS) f inoperable support systems. These concerns were expressed in your letters d ed September 20 and December 9,1988, and were discussed with me during my r cent visit to the Clinton Station.

I am enclosing an analysis prepared by the NRR staf which responds the questions you raised.

I share your desire for improved TS and hope th' letter and its enclosure adequately addresses your specific concerns. ere is still a great deal more that can be done by the NRC and industry to i .pross TS. I believe that the concerns raised by Illinois Power Company w' 1 contribute to the success of those efforts and encourage your continued upport of our TS improvement efforts.

Sincerely, Thomas E. Murley, Director 5

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure: See ne t page DISTRIBUTION Docket file 'RC & Local PDRs PDIII-2 r/f GHolahan MVirgilio DCrutchfield DMuller LLuther JSniezek -

TMurley JHickman EButcher CRossi EGreenaan yW /

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I AUG 211999 ,

Docket No. 50-461 Mr. D. P. Hall Senior Vice President I Illinois Power Compuny )

P. O. Box 678 1 Clinton, Illinois 61727

SUBJECT:

TECHNICAL SPECIFICATION REQUIREMENTS This is in response to your concerns regarding the NRC staff's position on the application of the Clinton Technical Specifications (TS) for inoperable support systems. These concerns were expressed in your letters dated Septecce 20 and December 9,1988, and were discussed with me during sqy visit to the Clinton Station.

I am enclosing an analysis prepared by the NRR staff which responds to the questions you raised.

I share your desire for improved TS and hope this letter and its enclosure adequately address your specific concerns. There is still a great deal more that can be done by the NRC and industry to improve TS. I believe that the concerns raised by Illinois Power Company will contribute to the success of those efforts and I encourage your continued support of our TS improvement efforts.

Sinqerely.

Ongmal signed by James H. Sniezek Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

NRR Staff Analysis

! cc w/ enclosure:

l See next page

! DISTRIBUTION l Docket file NRC & Local PDRs PDIII-2 r/f LLuther LReyes MVirgilio PShemanski(A) EButcher LCallan JSniezek TMurley JHickman JHannon LKokajko REmch L RZimmerman CRossi EGreenman GHolahan WKane

• PREVIOUSLY CONCURRED

• PDIII-2 *PDIII-2 *PDIII-2 *0TSB *RIII *D:DOEA JHickman: km LLuther DMuller EButcher EGreenman CRossi 1/31/89 1/01/89 2/1/89 4/20/89 5/3/89 5/3/89

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