ML20248D331
| ML20248D331 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1989 |
| From: | Oreilly P, Plumlee G NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| References | |
| NUREG-1275, NUREG-1275-V04, NUREG-1275-V4, NUDOCS 8904110441 | |
| Download: ML20248D331 (109) | |
Text
v NUREG-1275 Vol. 4 Operating Experience Feedback Report - Technical Specifications Commercial Power Reactors U.S. Nuclear Regulatory Commission Office for Analysis and Evaluation of Operational Data P.D. O'Reilly, G.L. Plumlee ill p a "ra q, u
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AVAILABILITY NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:
1.
The NRC Public Document Room, 2120 L Street, NW, Lower Level, Washington, DC 20555' 2,
The Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082,.
Washington, DC 20013-7082 3.
The National Technical information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC Office of 4
Inspection and Enforcement bulletins, circulars, information notices, inspection and investi-I gation notices; Licensee Event Reports; vendor reports and correspondence; Commission i
papers; and applicant and licensee documents and correspondence.
The following documents in the NUREG series are available for purchase from the GPO Sales i
Program: formal NRC staff and contractor reports, NRC-sponsored conference proceed-ings, and NRC booklets and brochures. Also available are Regulatory Guides NRC regula-tions in the Code of Federal Regulations, and Nuclear Regulatory Commission issuances.
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i Documents available from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from public and special technical libraries include all open literature items, such as books, journal and periodical articles, and transactions. Federal Register l
notices, federal and state legislation, and congressional reports can usually be obtained from these libraries, j
Documents such as theses, dissertations, foreign reports and translations, and non-NRC conference proceedings are available for purchase from the organization sponsoring the j
publication cited.
Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of information Resources Management. Distribution Section, U.S.
Nuclear Regulatory Commission Washington, DC 20555.
Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available there for reference use by the public. Codes and standards are usually copy-righted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York, NY 10018.
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s NUREG-1275 Vol. 4
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l Operating Experience Feedback y
Report - Technical Specifications
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Commercial Power Reactors Manuscript Completed: August 1988 Date Published: March 1989 P.D. O'Reilly, G.L. Plumlee lil'
' Presently employed with Impell Corporation, Fort Worth, TX 76116 Office for Analysis and Evaluation of Operational Data U.S. Nuclear Regulatory Commission Washington, DC 20555
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e ABSTRACT 1
This report documents a trends and patterns analysis of technical specification (TS)-related licensee event reports (LERs) conducted by the Nuclear Regulatory Commission's (NRC's). Office for Analysis and Evaluation of Operational Data (AEOD).
The objectives of this analysis were (1) to identify and catalog technical specification-related LERs, (2) to categorize and evaluate the events reported in these LERs, (3) to identify any issues arising from the evaluation which appear to have generic safety significance, or which relate to the on-going Technical Specification Improvement Program, and (4) to trend the results obtained from the analysis (f the data obtained in (1) through(3).
Data collected from the LER review were then trended for insights _concerning i
such parameters as years of operational experience, nuclear steam supply system (NSSS) vendor, type of events, type of plant TSs, category of TS involved, system involved. general cause category and component involved.
In addition to trends and patterns analyses, this stuoy also considered recent TS improvement efforts, particularly actions taken by the Technical I
Specification Improvement Program, such as Generic Letters 86-10 and 87-09, as well as the NRC staff's trial application of the proposed criteria for
' determining TS content.
In all, 3183 events reported in response to the requirements of 10 CFR l
50.73(a)(2)(1) were reviewed in detail for this study: 737 for 1984, 1189 for 1985, and 1257 for 1986. A total of 37 events was excluded from further analysis, since they either dealt only with beginning a shutdown, a situation which is not reportable according to 10 CFR 50.73, or were plant-specific special reports required by TSs that were submitted in LER f onra t.
The remaining events fell into onc of the following three cate-gories: (1) a TS violation - 91%, (:') a plant shutdown required by TSs - 6%,
or (3) entry into Specification 3.0.3 or the equivalent - 3%. An additional 1505 events reported in 1987 were used in a limited manner to obtain insights about trends.
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TABLE OF CONTENTS Page J
ABSTRACT
.................................................i11 ACKNOWLEDGEMENT.......................................... x1 EXECUTIVE
SUMMARY
...................................... xiii 1.
INTRODUCTION........................................
I 1.1 Objective......................................
I 1.2 Background.....................................
1 1.2.1 Evolution of Technical Specifications...
1 1.2.2 Technical Specification Improvement Efforts.................................
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1.3 Scope and Limitations..........................
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1.4 Organization...................................
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ANALYSIS METHODOLOGY...............................
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RESULTS.............................................
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3.1 Trends in Technical Specification-Related Events.........................................
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3.2 Technical Specification-Related Shutdowns.....
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3.3 Technical Specification Violations and Compliances...................................
19 3.3.1 LC0 Violations.........................
19 3.3.1.1 Influence of NSSS Vendor and Technical Specification Type.. 20 3.3.1.2 Systems Involved in LC0 i
Violations.................... 24 3.3.1.3 Causes of LC0 Violations......
27 3.3.1.4 Compliances................... 28
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3.3.2 Surveillance Requirement Violations....
31 3.3.2.1 Influence of NSSS Vendor and Technical Specification Type.. 31 3.3.2.2 Systems Involved in Surveillance Requirement Violations........
36 3.3.2.3 Causes of Surveillance Requirement Violations........
38 4
SUMMARY
OF FINDINGS, CONCLUSIONS, AND SUGGESTIONS...
39 LIST OF REFERENCES................................. 44 v
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TABLE OF CONTENTS Page 1
1 APPENDIX A COMPILATION OF TECHNICAL SPECIFICATION-1 SHUTDOWNS
...................................A-1 APPENDIX B SYSTEMS INVOLVED IN TECHNICAL SPECIFICATION-RELATED SHUTDOWNS............................B-1 l
1 APPENDIX C SYSTEMS INVOLVED IN TECHNICAL SPECIFICATION i
VIOLATIONS
...................................C-1 l
APPENDIX D GENERIC LETTER 86-10 (WITHOUT ENCLOSURES).....D-1 l
APPENDIX E GENERIC LETTER 87-09 (WITHOUT ENCLOSURES).....E-1
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v TABLE OF CONTENTS j
Page List of Figures 4
Figure 3-1
- TECHNICAL SPECIFICATION-RELATED EVENTS Distribution According to Event Type and Relative Safety Potential............
11 Figure 3 NORMALIZED FREQUENCY OF TECHNICAL SPECIFICATION VIOLATIONS Number of Violations / Plant:
5-Mth Moving Average..........................
12 Figure 3 1984-86 PLANT UNAVAILABILITY:
ALL PLANTS..
17 Figure 3 TECHNICAL SPECIFICATION-RELATED EVENTS Distribut1on of Violations and Compliances.............................. 21 Figure 3 NORMALIZED A'.1 RAGE LC0 VIOLATION RATES Mature Plants with STS, Outliers Removed. 22 Figure 3 NORMAllZED AVERAGE LC0 VIOLATION RATES Mature Plants with Custom TSs, Outliers Removed..................................
23 Figure 3 TECHNICAL SPECIFICATION-RELATED EVENTS q
Entry Into Specification 3.0.3:
1985-86 Data.....................................
30 Figure 3 NORMALIZED AVERAGE SURVEILLANCE REQUIREMENT VIOLATION RATES Mature Plants with STS, Outliers Removed. 33 Figure 3 NORMALIZED AVERAGE SURVEILLANCE REQUIREMENT VIOLATION RATES Mature Plants with Custom TSs, Outliers Removed.................................
34 List of Tables Table 3-1
- Completed Shutdowns Required by Technical Spec'fications...........................
16 Table 3-2
- Ratio of '.00 Violation Rate for Plants with STS to tnu LC0 Violation Rate for Plants with Custom TSs..........................
24 Table 3-3
- Summary of System Involvement in LCO Violations...............................
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I TABLE OF CONTENTS Page List of Tables (Continued)
Table 3-4
- Estimated Reduction in Number of LCO Violations Under NRC Staff's Proposed Modi fied TS Content Criteria.............
27 Table 3-5
- LCO Violations: Leading Contributors to Cause Category Distribution..............
27 Table 3-6
- Ratio of Surveillance Requirement Violation Rate for Plants with STS to the Surveillance Requirement Violation Rate for Plants with j
Custom TSs...............................
35 Table 3-7
- Ratio of LC0 Violction Rate to Surveillance 4
Requirement Violation Rate...............
36 l
Table 3-8
- Sumary of System Involvement in Surveillance Requirement Violations......
37 Table 3-9
- Estimated Reduction in Number of Surveillance Requirement Violations Under NRC Staff's Proposed Modified TS Content Criteria.................................
38 Table 3 Surveillance Requirement Violations:
Leading Contributors to Cause Cate Di s tri bu ti on..................... gory 38 Table A-1
- Technical Specification-Related Shutdowns Du r i n g 19 84............................... A-2 Table A-2
- Technical Specification-Related Shutdowns Du r i n g 19 8 5........... r................... A-8 Table A-3
- Technical Specification-Related Shutdowns Du r i n g 19 86............................... A-15 Table B-1
- Systems Involved in Technical Specification-Rel ated Shu tdowns Duri ng 1984............. B-2 Table B-2
- Systems Involved in Technical Specification-Rel ated Shutdowns Duri ng 1985............. B-3 Table B-3
- Systems Involved in Technical Specification-Related Shutdowns During 1986............. B-4 Table C-1
- Systems Involved in LC0 Violations During l
1984...................................... C-2 l
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v TABLE OF CONTENTS Page List of Tables (Continued)
Table C-2
- Systems Involved in Surveillance Requirement Viola tions During 1984...................... C-4 Table C-3
- Systems Involved in LC0 Violations During i
1985...................................... C-5 Table C-4
- Systems Involved in Surveillance Requirement Viola tions Du ring 1985.................... C-7 Table C-5
- Systems Invol"ed in LC0 Violations During 1986....................................... C-9 l
Table C-6 Systems Involved in Surveillance Requirement l
Violations During 1986.................... C-11 l
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l ACKNOWLEDGEMENT The assistance of Carl Lovell and members of the Operational Data Analysis and Evaluation staff at EG&G Idaho, Inc., particularly Keith Penny, in the preparation and maintenance of the data base used in this study is gratefully a knowledged.
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- v-I EXECUTIVE
SUMMARY
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I Introduction One specific project in the review of operational data conducted'by the i
Nuclear Regulatory Commission's (NRC's) Office for Analysis and Evaluation
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of Operational Data (AE0D) is a trends and patterns analysis of technical i
specification (TS)-relatedlicenseeeventreports(LERs).
The objectives of this project are: (a) to identify and catalog technical specification-related LERs, (b) to categorize and evaluate the events reported in these LERs, (c) l to identify any issues arising from the evaluation which appear. to have generic safety significance, or which relate to the on-going Technical Specification Improvement Program, and (d) to trend the results obtained
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from the analysis of the data obtained in (a) through (c).
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Background
Since January 1,1984, the NRC has required reactor licensees to provide l
written reports of operational events in accordance with the LER Rule, 10 CFR 50.73. This rule provides a particular focus on experience related to plant TSs'through paragr^ph 50.73(a)(2)(i), which requires that licensees report:
"(A) The completion of any nuclear plant shutdown required by the plant's Technical 5 specifications; or (B) Any operation prohibited by the plant's Technical Specifications; or (C) Any deviation from the plant's Technical Specifications authorized pursuant to 50.54(x) of this part (10 CFR 50)."
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The LERs which describe events that meet any of these three criteria served as the major source of information for this report.
l In this report, events covered by 10 CFR 50.73(a)(2)(1)(A) are termed " shutdowns", events covered by 50.73(a)(2)(1)(B) are termed either j
" violations" (either failure to meet an LC0 and the appropriate Action l
Statement, or failure to perform a Surveillance Requirement), or " compliances."
(entry into Specification 3.0.3 of the Standard Technical Specifications (STS)ortheequivalent).
No events covered by 10 CFR 50.73(a)(2)(1)(C)
(actions that depart from the TSs in an emergency in order to protect the public health and safety) were reported i ring the period covered by this study.
Methodology In performing this study, all LERs submitted by ' licensees during 1984, 1985, and 1986 were screened to identify those which reported TS-related events.
l The group of LERs screened in this manner contained reports of some events I
which, although reportable under 10 CFR 50.72, are not reportable under 10 i
CFR 50.73 (e.g., a TS-required shutdown was initiated, but the plant had not xiii Q
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reached the first operating mode that required the reactor to be subcritical before the Action Statement was satisfied and the LC0 exited).
Events of this type were not considered further in the analysis, j
i During the Peer Review of the draft report, limited, preliminary results became available regarding the 1987 LER data.
These were used to provide I
additional insights concernir; trends.
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The 1984 portion of the data was extracted and compiled from LERs by Science Applications International Corporation (SAIC) under the direction of NRR as part of the Technica1 Specification Improvement Project (TSIP). Data for 1985 and 1986 we m compiled by EG&G Idaho, Inc. under the direction of AE0D.
I Cause and root component trending was performed by AE00 analysts and engineers for 1985 and 1986.
The 1984 analysis did not include cause and component trendir.g.
j Pertinent information regara bg each eve A was extracted and encoded into a data base. Special effort was aewtd
',,o ensuring consistency of approach throughout the period analyzed. Thus, the trends cited in this report are a i
reflection of industry experience, and did not arise from a shift in methodology.
The information characterizing each event in the data base included: plant name, type of TSs (STS or Custom), LER number, event date, i
I type of event (violation, shutdown, or compliance), power level, outage l
duration, TS category (Limiting Condition for Operation (LCO), Surveillance l
Requirement, Administrative, or Safety Limits and Limi,ing Safety System i
Settings), system involved, cause (1985 and 1986 only), component involved, l
safety potential (High, Medium, or Low), and event description.
The data thus collected were then trended for insights concerning such parameters as years of operational experience, NSSS vendor, type of event, type of plant TSs, category of TS involved, system involved, general cause I
category and component involved, In addition to trends and patterns analyses, this study also considered recent TS improvement efforts, particularly actions taken by the Technical Specification Improvement Program, such as Generic Letters 86-10 and 87-09, as well as the NRC staff's trial application of the proposed criteria for determining TS content.
In all, 3183 events reported in response to the requirements of 10 CFR 50.73(a)(2)(1) were reviewed in detail for this study: 737 for 1984, 1189 for 1985, and 1257 for 1986. A total of 37 events was excluded from further analysis, since they either dealt only with beginning a shutdown, a situation which is not reportable according to 10 CFR 50.73, or were plant-specific special reports required by TSs that were submitted in LER format. The remaining events fell into one of the following three categories: (1)aTS I
violation - 91%, (2) a plant shutdown required by TSs - 6%, or (3) entry into Specification 3.0.3 or the equivalent - 3%.
An additional 1505 events reported in 1987 were used in a limited manner to obtain insights about trends.
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Findings and Conclusions Major findings and conclusions of this study are as follows:
From the analysis of the overall distribution of TS-related events:
The distribution of TS-related events was dominated by TS violations (91%) throughout the four-year period, 1984-87, as opposed to shutdowns-(6%) and compliances (3%).
The number of TS violations increased significantly from 1984 (668) to 1985(1074), eith only a small increase noted from 1985 to 1986 (1110) and a larger ti1 crease seen in 1987 (1269).
The average violation rate L
per plant went from 7.5 violations per plant in 1984 to 11.0 violations l
per plant in 1985 to 10.7 violations ser plant in 1986, increasing in 1987 to 11.4 violations per plant.
Tae. number of TS violations' considered to be of relatively high safety potential actually decreased between 1985 and 1986. The increase observed in the number of violations over these two years was due solely to an increase in violations of " medium" safety potential.
The frequency of completed, TS-related shutdowns was relatively low throughout the four-year period 1984-1987 compared to the frequency of TS-related events, reaching a maximum of 73 in 1985. An estimated 4-5%
of total industry unavailability was related to TS-required shutdowns.
The leading contributors to system involvement in TS-required shutdowns were the PWR reactor coolant system and the BWR reactor recirculation system. Most of the shutdowns involving these systems were carried out to identify and isolate or repair sources of unidentified leakage.
From the analysis of the distribution of TS violations:
The distribution of TS violations over the period of interest consisted of contributions from three distinct groups of plants:
(1) newly licensed plants (with disproportionately high violation rates, a subject extensively discussed in the New Plant Study, " Operational Feedback Report: New Plants," NUREG-1275, Volume 1), (2) a few mature plants in each year which experienced relatively high violation rates, and (3) the remainder of the mature plants.
l The small group of mature plants with relatively high violation rates in each of the three years 1984-1986 experienced one or more sets of repetitious (three or more of the same general type) events, each set of which had similar characteristics and involvod the same system and/or cause. The sets of repetitious events.iffered from plant to plant, but they represented a sigr.ificant port ton of each plant's contribution to the overall distribution of violations.
From early 1984 through early 1985, the increasing trend for the group of mature plants excluding outliers was largely responsible for the overall increasing tre'd in the industry's TS violation rate, although there was also some increase in the contribution from newly licensed plants. This mature plant t end could not be traced through data analysis to any systematic reason, cuch as a general increase in violations for a few systems, or an increase in a certain type of xv
violation (e.g., LCO-related violations).
During peer review af the draf t report, other NRC staff suggested possible underlying reasons for the increasing trend during this period:
(1) Increased NRC emphasis on enforcement (e.g., more frequent inspections, stricter enforcement, increased NRC onsite presence),.
(2) NRC issuance of the definition ur " operability" and its subsequent incorporation into individual plant TSs, and (3) Clearer understanding on the part of licensees of the reporting l
requirements in 10 CFR 50.73.
1 Throughout most of 1985 and into 1986, the mature population TS violation rate turned over, but then resumed increasing in 1987.
A detailed review of LERs for a sample of plants in this group indicated that, in contrast with the general situation for outliers (which experienced high numbers of repetitive violations of the same TSs),
these plants had lower overall numbers of violations involving a variety of TSs, but the underlying causes were repetitive.
We perceive'that some licensees may be pursuing root causes and implementing corrective action on an event-specific basis, rather than broadening their scope to assess a whole range of events which, although they may involve different systems and different scenarios, have the same underlying causal factors. As a result, the TS violation rate is not decreasing.
I from an analysis of LC0 and Surveillance Requirement violations experienced by mature plants, excluding outliers, for the influence of NSSS vendor and I
type of TSs (STS or Custom):
In general, the results indicated an increasing trend in LCO violation rate over the three-year period regardless of NSSS vendor or TS type.
A possible exception was the case of CE plants with STS, whose LC0 violation rate, on the average, showed little change during the entire period. The average LC0 violation rate for GE plants with STS was high compared with the most recent data for LCO violation rates for CE and Westinghouse plants with STS.
Finally, in the case of GE. plants, the LCO violation rate for plants with STS exceeded the violation rate for plants with Custom TSs, while the reverse was true for the case of Westinghouse plants.
After the first half of 1984, the LC0 violation rate for GE plants with STS was generally higher than the violation rates for CE and Westinghouse plants with STS, by as much as a factor of two. The LC0 violation rate for CE plants with STS showed little change over the three-year period, remaining about 1.8-2.0 violations per plant per 6-month interval. The LC0 violation rate for Westinghouse plants with STS showed a steady increase over the three-year period from approximately 1.3 violations per plant per 6-month interval at the beginning of 1984 to about 2.2 violations per plant per 6-month interval at the end of 1986. Except for a possibly anomalous data point in the first haTf o'T 1984, the LC0 violation rate for GE plants with STS exceeded the LC0 violation rate for GE plants with Custom TSs, j
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by as much as a factor of two.
The LC0 violation rate for Westinghouse plants with Custom TSs was greater than the LC0 violation rate for STS plants from the second half of 1985 through the end of 1986.
From the first half of 1984 through the second half of 1985, the violation rate for STS plants was slightly greater.
During the first half of 1985, the Surveillance Requirement violation rate for GE plants with STS was greater than the co~ osponding LCO violation rate by about a factor of two.
In all othe cases,however,)
i the LC0 violation rate was greater than (by as much as factor of six or equal to the Surveillance Requirement violation rate > or the entire three-year period across all NSSS vendors and TS types.
From the analysis of all LCO and Surveillance Requirement violations for 1985 and 1986 regarding general cause category and component involved:
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The same three cause categories, personnel error, equipment problems, l
and problems with procedures, in that order, dominated the cause category distribution for LC0 violations in both 1985 and 1986.
The dominant root components for LCO violations caused by equipment problems during these two years were isolation / shutoff valves, door / cover / hatch problems, seals, fire barriers, and damper / louver s
components, in that order. Most of these problems were reportable under the fire protection TS requirements.
The same four systems (radiation monitoring system, fire detection system, containment isolation control system, and fire protection system (passive)) dominated the distribution of systems involved in LC0 violations for each of the three years, 1984, 1985, and 1986. The radiation monitoring system was the leading contributor to the distribution of systems involved in Surveillance Requirement violations during the three-year period.
However, the composition of the remainder of the group of systems representing the highest contributors to this distribution differed from year to year.
l Only two cause categories, personnel error and problems with procedures, dominated the cause category distribution for Surveillance Requirement violations in both 1985 and 1986, a result which was not unexpected since almost all violations of Surveillance Requirements are of human origin.
Our study also considered several of the short-term actions taken by the Technical Specification Improvement Program, notably Generic Letters 86-10 (Appendix 0) and 87-09 (Appendix E).
In these generic letters, the program was dealing with situations where the industry had indicated difficulty in coping with TS requirements.
Under current reporting requirements, information regarding difficulty encountered by licensees in complying with specific TSs is not captured.
However, we can feed back for information's sake those situations when licensees were unsuccessful in coping with TS requirements (i.e., there was a violation).
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In the case of Generic Letter 86-10 regarding fire protection requirements, the results of our analysis of 1985 and 1986 data supported the TSIP conclusions, based on consideration of one year (1984) of data, that (1) the fire protection (detection and suppression) systems have been dominant contributors to the distribution of systems involved in TS violations, and (2) most of the events involving these systems have been of relatively low or medium safety potential. As a result of the actions prescribed in Generic Letter 86-10, it appears that the number of reported TS-related events will decline, based on the forthcoming relocation of the fire protection requirements from the TSs to the program plan, although some licensees do not plan to do so.
It follows that the visibility of performance in the area of fire protection may decline.
From our experience, we have found that the reporting of operational events, even those of relatively low safety significance, does provide a stimulus for licensees to conduct root cause analyses and to effect corrective action to prevent recurrence of such events.
This consideration must be carefully weighed when contemplating modification of reporting requirements for operational events with relatively low safety significance.
l Our consideration of the issues addressed in Generic Letter 87-09 was l
limited by the fact that, with the exception of Specification 3.0.3 of the STS, entry into one of the " Motherhood Clauses" in the STS has not been generally viewed as a reportable event.
Consequently, except for Specification 3.0.3, only violations of these specifications have been reported.
In our analysis of TS-related shutdowns, we found that none of the TS-required shutdowns reported over the three-year period 1984-86 were traceable to the presumed inoperability of equipmen due to missed I
surveillance. This finding relates to a concern about Specification 4.0.3 stated in Generic Letter 87-09 that it is overly conservative to assume l
systems or components are inoperable when a required surveillance has not been performed.
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Another issue addressed in Generic Letter 87-09 was the potential adverse impact of Specification 4.0.4 of the STS on plant operations.
Our review of 1985-86 TS-related data identified four cases in which Specification 4.0.4 was actually violated. These results indicate that, although licensees may be having difficulty complying with this specification, reported instances in which Specification 4.0.4 was actually violated have been relatively few.
Finally, our review of the number of entries into Specification 3.0.3 of the STS determined that most of the voluntary entries to perform surveillance or to do maintenance were repeated entries made by two plants. For this reason, we conclude that this practice, which is contrary to the intent of Specification 3.0.3, is not widespread, but occurs on an isolated basis, and has been limited to a relatively few plants.
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Suggestions The apparent increasing trend in TS violation rate is a matter of concern.
Therefore, we suggest that NRR and the Regional Offices take new initiatives to ensure that the root cause analyses and corrective actions taken by licensees in response to TG violations address the programmatic root cause of such events rather than restricting their focus to specific events.
For example, the ISEG review of a plant's root cause analyses and corresponding corrective actions implemented in response to reportable events could be used to provide this assurance.
We believe that licensee corrective action analysis and implementation i
should continue for violations of requirements (including fire protection) that are removed from the TSs. Therefore, we suggest that NRR take steps to ensure that: (a) licensee corrective action analysis and im not diminished by removal of requirements from TSs, and (b)plementation are this analysis and implementation are readily available for NRC inspection.
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1 1.
INTRODUCTION 1.1 Objective One specific project in the review of operational data conducted by the Nuclear Regulatory Commission's (NRC's) Office for Analysis and Evaluation of Operational Data (AE00) is a trends and patterns analysis of technical specification-related licensee event reports (LERs). The objectives of this i
project are: (a) to identify and catalog technical specification-related LERs, (b) to categorize and evaluate the events reported in these LERs, (c) to identify any issues arising from the evaluation which appear to have generic safety significance, or which relate to +Se on-going Technical 3
Specification Improvement Program, and (d) to trend the results obtained from the analysis of the data obtained in (a) through (c).
1.2 Background
Since January 1,1984, the NRC has required reactor licensees to provide j
written reports of operational events in accordance with the LER Rule, 10 j
CFR 50.73. This rule provides a particular focus on experience related to plant Technical Specifications (TSs) through paragraph 50.73(a)(2)(i), which requires that licensees report:
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"(A) The completion of any nuclear plant shutdown required by the plant's Technical Specifications; or (B) Any operation prohibited by the plant's Technical Specifications; or (C) Any deviation from the plant's Technical Specifications authorized pursuant to 50.54(x) of this part (10 CFR 50)."
The LERs which describe events that meet any of these three criteria served as the major source of information for this report.
Thus, in this study the experience of operating plants has been viewed through the filter of plant TSs. Only those events reportable under the requirements of TSs have been examined.
For this reason, the history of variation in the content of TSs raises a flag of caution regarding the ability to analyze the accumulated data at the industry-wide level. The following section provides some highlights of the development of TSs in order to characterize the differences which exist among licensed plants.
1.2.1 Evolution of Technical Specifications The content of TSs has been evolving throughout the licensing history of the NRC and its predecessor, the Atomic Energy Commission (AEC).
The licensed reactor population contains plants having TSs in the following major groupings, with plant-to-plant variations within each group:
Custom, licensed prior to 1969 (4 plants).
Custom, licensed between 1969 and 1974 (44 plants).
Custom, licensed from 1975 to the present (5 plants).
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Standard, licensed from 1975 to the present (52 plants, as of December 31,1986).
Standard, converted from custom, licensed prior to 1975 (4 plants).
This variety limits the degree to which a generalization about TSs or related operational experience can be understood to apply to a specific plant's situation.
It also impacts the interpretation of any plant-to-plant statistical comparisons.
The Atomic Energy Act of 1954 provides that an applicant for an operating license for a commercial nuclear power plant shall state such TSs, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and other information the Commission may, by rule or regulation, deem necessary to enable it to find that the utilization or production of special nuclear material will be in accordance with the common defense and security and will provide adequate protection to the health and safety of the public.
This statutory directive has been implemented in 10 CFR 50.36 of the Commission's regulations, entitled " Technical Specifications." Within this framework, three stages of increasingly prescriptive guidance for TS form and content have evolved.
Before 1968,10 CFR 50.36 stipulated only that Technical Specifications include:
"...those significant design features, operating procedures, and operating limitations which were considered important in providing reasonable assurance that the facility (would be) constructed and operated without undue hazard to public health and safety."
Five plants (one subsequently converted to STS) were licensed during this era, including for example, Big Rock Point, San Onofre 1, and Yankee Rowe.
TSs prepared by licensees in this era generally contained too much detailed design information, varied widely in format, unduly restricted reactor operation, and required a large number of changes.
As a result, in December 1968, 10 CFR 50.36 was revised to include a more precise definition of those categories of TSs that must be included in an application for an operating license. TSs were to be derived from the analyses and evaluation included in the FSAR and include items in the l
following categories currently enumerated in 10 CFR 50.36:
i l
1 Safety Limits and Limiting Safety System Settings - the limits upon important process variables which are found to be necessary to reasonao' ly protect the integrity of certain of the physical l
barriers which guard against the uncontrolled release of radioactivity.
1 Limiting Conditions for Operation - the lowest functional capability or performance levels of equipment required for safe operation of the facility.
l l
Surveillance Requirements - requirements relating to test, l
calibration, or inspection to assure that the necessary quality of l
I 2
1 systems and components is maintained, that facility operation will be within safety limits, and that the Limiting Conditions for Operation will be met.
)
Design Features - those features of the facility such as the materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in the categories described above.
1 Administrative Controls - the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
l Forty-seven plants (three subsequently converted to STS), including for example, Fort Calhoun, Hatch 1, Oconee 1,2, and 3, and Zion 1 and 2 were j
l licensed with this guidance.
However, the amended guidance was still subject to varying interpretations and failed to bring about the intended consistency.
l Finally, for operating licenses issued subsequent to 1975, the NRC has required the use of Standard Technical Specifications (STS) as the starting point for preparation of TSs by the licensee.
These STS were developed for each of the four light water reactor nuclear steam supply system (NSSS) designs (i.e., Bebcock & Wi'cox Co., Combusi. ion Engineering Inc., General Electric Co., and Westinghouse Electric Corporation), Three licensees with plants that were already operating also elected to convert to the STS. These STS are now contained in each utility's application for an operating license j
along with the necessary modifications to address any plant-specific l
differences.
They are each consistent in format, scope, and each contains the above categories required by 10 CFR 50.36.
All STS are relatively consistent in addressing the same requirements, but still contain modifications to accommodate plant-specific design differences (which were reflected in the licensing basis).
l 1.2.2 Technical Specification Improvement Efforts 1
On December 31, 1984, +.e Director of the NRC's Office of O clear Reactor Regulation (NRR) established a Technical Specification Improvement Project (TSIP) to reconsider the entire subject of TSs and provide recommendations for their improvement. There was close coordination between this project and a similar industry effort sponsored by the Atomic Industrial Forum (AIF).
Both the TSIP and the AIF subsequently issued reports (Refs. I and 2) which made two major recommendations - first, the NRC should adopt the criteria for defining the scope of TSs proposed in the TSIP and AIF reports in a revision of the existing STS, and second, a parallel program of short-term improvements in both the scope and the substance of existing TSs should be initiated in addition to developing a new set of STS. An analysis of 1984 TS-related data formed part of the bases for the TSIP conclusions. This study in part provides an extension of the TSIP data analysis.
In so doing, we have revisited the TSIP conclusions, which were based on a limited look at one year of TS-related operating experience.
In a followup action to the TSIP and AIF work described above, the NRC staff and the Alf independently applied the deterministic criteria for TS content 2
l l
i i
j developed by the TSIP and the AIF to the TSs for two plants, a BWR (Limerick) and a PWR (Wolf Creek). The two parties then met to discuss the results of the trial application.
Subsequent to these discussions, the NRC staff issued a complete report (Ref. 3) on the trial application. The staff's over-all conclusion was that the criteria would work well but that they needed some refinement in order to achieve consistent results. As part of our study of TSs, we applied the staff's proposed modified criteria from a system perspective to obtain estimates of their effect on the number of TS violations reported during 1984-86.
The Commission subsequently requested that the NRC staff prepare a policy paper on TS improvements.
On February 6,1987, an Interim Coanission Policy Statement on Technical Specification Improvements was published for public comment. The Policy Statement was made immediately effective.
As a result of the above-mentioned recommendations, the NRC staff and each of the NSSS vendor owners groups have proposed or are considering many changes to TSs.
These changes will be proposed as short-term improvements to existing TSs to be implemented in parallel with NRC and industry longe -term i
efforts to completely rewrite / streamline the STS.
Since a major portion of the actions which have occurred as a result of this effort took place in the latter part of 1986 and during 1987 (Generic Letters 86-10 and 87-09), there is no cause-effect impact on the TS-related data for the period analyzed.
However, we can comment on the anticipated impact which these actions will i
have on future reporting patterns.
It should be emphasized that the j
above-identified generic letters dealt with situations that licensees had i
indicated were difficult to cope with.
Under current reporting requirements, I
we do not obtain information regarding situations in which licensees had difficulty in complying with specific TSs.
However, we can feed back for information's sake the related situations for which we do have information, namely the times when licensees were unsuccessful in coping with certain TS requirements (i.e., a violation resulted).
1.3 Scope and Limitations i
This report covers events reported in accordance with 10 CFR 50.73(a)(2)(i) for the years 1984 through 1986. During the course of the Peer Review of the draf t report, some limited, preliminary results regarding 1987 data became available, and these were used as indicated to provide additional insights regarding trends.
Reportable events, such as required by 10 CFR 50.73(a)(2)(1), are individually reviewed, analyzed, discussed and followed up on from a number of perspectives by various segments of the NRC staff. For example, before an event is even documented as an LER, it may be the subject of a licensee 10 CFR 50.72 report or a preliminary notification (PN) prepared by the appropriate NRC regional office, and may even be discussed by the staff during the NRC's daily teleconference on potentially significant events.
Also, within AE00 each LER receivec an individual screening and assessment for both plant-specific and generic safety implications. Certain violations l
4
v i
l of TSs may result in some level of formal NRC enforcement action initiated by a resident inspector, a field inspector, or the appropriate NRC regional office.
These actions are carried out and followed up within the jurisdiction of the NRC's Enforcement Program.
Trends and patterns analyses complement this event-by-event review by seeking to characterize and evaluate industry-wide trends and patterns from collected experience in a given area.
To that end, potentially significant trends and patterns are pursued only to the point where their generic nature can be determined.
Thus, detailed treatment of plant-s'ecific situations and problems, limited to a few events or to a small segmenc of the operating plant population, are outside the scope of the analyses.
1.4 Organization Section 2.0 describes the detailed methods used for categorizing events reported in accordance with 10 CFR 50.73(a)(2)(i).
Section 3.0 summarizes the results of this study. Trends in TS-related events are discussed in Section 3.1.
Section 3.2 deals with TS-related shutdowns. Technical I
Specification violations and compliances (specifically, entry into Specification 3.0.3 of the STS) are examined in Section 3.3.
Section 4.0 provides a summary of the findings and conclusions discussed in this report.
The severity level of most 15 violations does not exceed the threshold for initiation of formal enforcement action.
Therefore, no one-to-one relationship exists between the number of TS violations and the number of NRC enforcement actions.
1 I
5
2.
ANALYSIS METHODOLOGY in performing this study, all LERs submitted by licensees during 1984, 1985, and 1986 were screened to identify those which reported TS-related events.
The group of LEPs screened in this manner contained reports of some events which, although reportable under 10 CFR 50.72, are not reportable under 10 CFR 50.73 (e.g., a TS-required shutdown was initiated, but the plant had not reached the first operating mode which required the reactor to be subcritical before the Action Statement was satisfied and the LC0 exited).
Events of this type were not considered further in the analysis.
Limited, preliminary results concerning the 1987 LER data which became available during the Peer Review of the draft report were used to provide additional insights regarding trends.
The data for 1984 were extracted and compiled from LERs by Science Applications International Corporation (SAIC) (Ref. 4) under the direction of l
NRR as part of the TSIP, Data for 1985 and 1986 were compiled by EG&G Idaho, Inc. (Refs. 5 and 6) under the direction of AE0D.
Cause and component trending was performed for 198F and 1986 only, since the 1984 data base did not include cause and component identification.
Pertinent information regarding each event was extracted and encoded into a data base.
Special effort was devoted to ensuring consistency of approach throughout the period analyzed. Thus, the trends cited in this report are a reflection of industry experience, and did not arise from a shift in methodology.
The data thus collected were then trended for insights concerning such parameters as years of operational experience, NSSS vendor, type of event (violation, shutdown, compliance), type of plant TSs (Standard or Custom),
I category of TS involved (e.g., LCO, surveillance requirement), system
)
involved, general cause category and component involved. This report presents a summary of those areas in which the results have been deemed significant.
During this study, the results of the data analysis of ten gave rise to certain specific issues.
In order to pursue these issues to determine their l
safety significance, it was necessary to obtain further information regarding the events of interest.
This often required reviewing individual LERs for more detail than was contained in the data base.
Several hundred events were reviewed in this manner.
In addition to LERs, other pertinent documents which were consulted when further information was needed included the Gray Book (NUREG-0020), the monthly plant-specific operating reports submitted by licensees, the STS for each NSSS design (NUREGS-0103, 0123, 0212, and 0452),
reports issued by the TSIP and documents recently produced as part of the Technical Specification Improvement Program (i.e., implementation of the Commission's Policy Statement on Technical Specification Improvements).
Each event in the data base was characterized by the following items of information:
Plant Name Type of Technical Specification (Standard or Custom)
LER Number Event Date 6
E----_----
TypeofEvent(Shutdown, Violation,orCompliance)-
PowerLevel(%)
Plant Status Outage Duration (Hours)
Technical Specification Category Limiting Condition for Operation (LC0),
Surveillance, Administrative Safety Limits and Limiting Safety System Settings (LSSS)
System Involved Cause (1985 and 1985 only)
Component involved (1985 and 1986 only)
Safety Potential (High, Medium, or Low)
Event Description.
The detailed methodology, as described in References 4 through 6, is J
generally straightforward, and pertinent aspects are described in more detail in Section 3 in connection with specific results.
The assignment of event type and relative safety potential, however, requires further explanation.
In this report, events covered by 10 CFR 50.73(a)(2)(1)(A) are terr.ed " shut-downs", events covered by 50.73(a)(2)(1)(B) are termed either " violations" or
" compliances," as described No events covered by 10 CFR 50.73(a)(2)(1)(C),in the following paragraphs.
were reported during the period covered by this study.
As mentioned previously, 10 CFR 50.73(a)(2)(1)(B) requires the reporting of any plant operation which is prohibited by the plant's TSs.
These situations are comprised in large part of violations of TSs, which can be further broken down according to the category of TS involved (LCOs, Surveillance i
Requirements, Administrative Controls. Safety Limits and Limiting Safety l
Settings (SL&LSSS)).
In the LC0 category, upon a plant's-failure to meet an LCO, the plant nust comply with the requirements specified l
in the associated Action Statement. Events which involved a failure to meet an LC0 and the appropriate Action Statement were classified as "LC0 violations" in this study.
Some TSs have LCOs that do not have specific LC0 Action Statements. When these LCOs or when LC0 specific Action Statements cannot be met, the plant enters what is commonly called the " Motherhood Clause" (e.g., Section 3.0.3 of the STS) which requires that the licensee correct the condition or within one hour place the plant in a MODE in which the specification does not apply.
NUREG-1022, Supplement No.1 (Ref. 7), directed licensees to report entry into l
the " Motherhood Clause", even though TSs are not violated, since the plant was.
J operating with a " condition prohibited by the plant's Technical I
Specifications." These events are termed " compliances" in this report.
TS-related events vary widely in safety potential.
In order to reflect this gradation, SAIC (Ref. 4) developed a subjective methodology for the 1984 data, which was then subsequently applied to the 1985 and 1986 data.
The safety i
4 10 CFR 50.73(a)(2)(1)(C) covers reports of actions that depart from the Technical Specifications in an emergency in order to protect the public health and safety.
J 7
i
-v l
s potential evaluation involved a qualitative assessment of the events with resultant rankings of low, medium, and high. Because of the judgmental
. element of this assignment, a more sophisticated ranking scheme-would not be appropriate. A low safety potential ranking is indicative of an event that would not be expected to impact the quantitative results of a probabilistic risk assessment-(PRA). Such an event could be associated with l
a system that has not contributed to the dominant sequences of past PRAs or could have so negligible an effect on any system as to be of little or no
-significance. An event given a high relative safety potential would have to affect one of the systems considered important to safety and would have to have a significant impact on that system's availability. The events ranked medium in relative safety potential encompass a wide range of events that induce large impacts on the availability of some important systems. The assessment of relative safety potential was lowered.for events which occurred during a shutdown and which could occur only during a' shutdown.
For all other cases, the power level at the time of the event did not influence the relative safety potential rankings.
The safety potential of three systems was not determined by their direct impact on the core damage frequency.or risk due to core damage accidents.
These three systems (fire protection, heating, ventilation and air condition-ing (HVAC), and seismic protection) were ranked acco: ding to the importar,ce of the system they supported if the event description provided enough information to determine which system was supported.
For example, a failure
]
of the fire detection or suppression system in a vital switchgear room would 3
be rated high in relative safety potential, while the same failure in a 4
machine shop or other non-vital area would be ranked low in relative safety potential.
l t
l l
l l
l l
8
l 3.
RESULTS In all, 3183 events reported in response to the requirements of 10 CFR 50.73(a)(2)(1) were reviewed in detail for this study: 737 for 1984, 1189 f' -
1985, and 1257 for 1986. A total of 37 events was excluded from further analysis, since they either dealt only with beginning a shutdown, a situation which is not reportable according to 10 CFR 50.73, or were plant-specific special reports required by TSs that were submitted in LER format. The remaining events fall into one of the following three categories: (1) a TS violation - 91%, (2) a plant shutdown required by TSs - 6%, or (3) entry into Specification 3.0.3 or the equivalent - 3%. An additional 1505 events reported in 1987 were used in a limited manner to obtain insights about trends.
3.1 Trends in Technical Specification-Re!ated Events TS violations have dominated throughout the period, as shown by the annual event totals in Figure 3-1.
The number of violations increased signi-ficantly (61%) from 1984 to 1985. Only a small increase (3%) in the number of violations was noted from 1985 to 1986.
The frequency of completed, TS-related shutdowns was relatively low throughout the three-year period compared to the frequency of TS-related events, beginning with 57 in 1984, rising to 73 in 1985, and then decreasing slightly to 65 in 1986. The growing tendency on the part of a few plants to report entry into one of the
" Motherhood Clauses" in TSs is indicated by the increasing trend in the number of compliances in Figure 3-1.
The review and encoding of the TS-related LER data for 1987 are still in pr]gress. Preliminary results indicate a total of 1505 TS-related events were reported during 1987. The breakdown of the events is as follows:
1269 (84%) violations, 165 (11%) compliances, and 71 (5%) shutdowns.
The corresponding breakdown of the 1985 and 1986 data was:
1985 - 90%
violations, 6% shutdowns, 4% compliances; 1986 - 88% violations, 5%
shutdowns, 7% compliances.
These preliminary results indicate that the total number of TS-related events reported for 1987 is (approximately 20%) higher than the number reported for 1986.
In addition, relative to the 1986 data, the total number of violations has increased (1269 versus 1110), the total number of compliances has increased (165 versus 82), and the total number of TS-related shutdowns has increased slightly (71 versus 65).
Figure 3-1 also shows the trend in the three event types further distinguished by relative safety potential category.
Although the data indicate an increasing trend in the number of TS violations, the number of violations considered to be of relatively high safety potential actually decreased between 1985 and 1986.
The increase noted in the number of violations over these two years was due solely to an increase in the " medium" ca tegory.
Due to the dominance of TS violations, the trends in TS-related events were examined by considering the group of TS violations reported during 1984, 1985, and 1986 in detail.
Preliminary results obtained with the 1987 data were also used.
TS violation rates for 1984 ranged from 0 violations (in the case of ten plants) to 37 violations (one plant), with an average of 7.5 violations per 9
i plant.
As mentioned above, there was a significant increase in the total number of violations reported in 1985,(with a range from 0 violations (in the case of five plants) to 63 violations one plant), with an average of 11.0 violations per plant.
Violation rates for 1986 moderated somewhat relative to 1985, ranging from 0 violations (in the case of four plants) to 58 violations (one plant), with an average of 10.7 violations per plant.
For 1987, the average rate rose to 11.4 violations per plant.
Figure 3-2 shows trends in.TS violations over the four-year period 1984-87 in terms of the five-month moving average for the number of violations per plant per month. Three curves are shown in Figure 3-2.
The first curve presents the data for all plants.
The average normalized TS violation rate for all plants increased from 0.5 violations per plant per month in March 1984 to about 0.7 violations per plant per month in July 1984, and remained at approximately this value for the Mst of that year.
The average normalized violation rate increased significantly during the first three months of 1985 to about 1.0 violations per plant per month and then moderated somewhat, decreasing to about 0.90 violations per plant per month by'the end of 1985.
During early 1986, the average normalized violation rate increased slightly to about 1.0 violations per plant, and slowly decreased to about 0.90 violations per plant per month by the end of the year.
The second curve in Figure 3-2 shows the average normalized violation rate for mature plants only. With the contribution from newly licensed plants removed, the average normalized violation rate shows approximately the same behavior as in the case of all plants, except that the magnitude of the violation rate is about 0.1 violations per plant per month lower during 1984 and about 0.2 violations per plant per month lower during 1985 and 1986.
During 1987, the violation rate tends to be about 0.1 violations per month lower.
The third curve shows the violation rate data for mature plants with the plants that experienced relatively high (
2 standard deviations) violation I
rates (six plants in 1984, three in each lif the years 1985 and 1986, and four in 1987) removed. With the contribution from outliers removed, the normalized average violation rate is smoothed somewhat, but still shows a slowly increasing trend from approximately 0.34 violations per plant per j
month at the beginning of 1984 to about 0.65 violations per month in March 1985.
The average normalized violation rate remained at about 0.63 violations per plant per month through the end of 1986.
During 1987, the data show an increase to about 0.78 violations pe-plant per month by May 1987, remaining near this value for the rest of t o year.
On an annual basis, the normalized violation rate for the group of mature plants excluding outliers increased from 5.1 violations per plant in 1984 to 7.3 violations per plant in 1985, moderatec to to 7.2 violations per plant in 1986, and then i
increased to 8.7 violations per plant in 1987.
This amounts to a net average increase of about 3 violations per plant over the four-year period.
The subject of disproportionately high TS violation rates experienced by newly licensed plants and the characteristics of these events has been extensively addressed in the New plant Study, NUREG-1275, Volume 1 (Ref. 8).
The contribution to industry rates from this source will diminish since fewer plants will be operating in their first two years, i
10
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q The small group of mature plants with relatively high violation rates in each of the three years 1984-1986 was examined further to obtain insights regarding event characteristics, systems involved, and the causes of these events.
It was found that most of these plants had experienced one or more sets of repetitious (three or more of the same general type) events, each set of which had similar characteristics and involved the same system and/or cause.
The sets of repetitious events differed from plant to plant, but they represented a significant portion of each plant's contribution to the overall distribution of violations.
Characteristics of these events are discussed below.
During 1984:
On several occasions due to personnel error, required fire watches were not established at Cook 1'within the TS-allowed time limit when l
fire barriers were inoperable (5 events).
Required sampling of radioactivity levels (either normal daily sampling or sampling specified by TSs as backup to inoperable radiation monitors) was not performed within the TS-allowed time
'imits at Cook 1 due to personnel error (3 events).
LaSalle 1 experienced several occurrences involving failure to establish aM/or maintain positive administrative control over a high radiation area due to personnel error (8 events).
No similar occurrences v,ere experienced at LaSalle 1 during subsequent years.
LaSalle 1 had equipment problems with fire barriers that were l
determined to have been inoperable due to improper sealing for periods of time that exceeded TS limits (5 events).
I Sequoyah 1 experienced difficulties due to personnel error with fire
{
watches that either were missed or not established when required at times when fire detection (e.g., thermal detector) or protection l
(e.g., deluge valve) equipment was inoperable (3 events).
During 1985:
l Problems with procedures at Cook 1 resulted in a discrepancy between the TS surveillance requi ements for the reacte cooltnt system and the plant surveillance procedures. As a result, tha surveillance performed failed to satisfy the TS requirements and the system was considered to be inoperable. This situation existed for a period in excess of the TS-allowed time limit (5 events).
- There were three outliers during 1984, San Onofre 2 TMI-2, and Zion 1, which did not have any repetitious events (i.e., three or more events with similar characteristics that involved the same system and/or cause).
13
Cook I had trouble with failures to establish and/or maintain TS-required fire watches within the TS-allowed time limit when fire detection equipment was inoperable.
Some of these violations were due to personnel error (e.g., omission, lack of communication), and several were due to equipment problems (e.g., broken fire door latch, undetected inoperable fire penetration seals) (15 events).
Because of problems with procedures, Cook 1 experienced difficulty satisfying the TS requirements for calibration of the power range nuclear monitoring system instrumentation (3 cvents).
Cook 2 experienced the same difficulty as Cook I with procedural problems causing failures to satisfy TS requirements regarding calibration of the power range nuclear monitoring system (4 events).
Cook 2 also had the same kinds of problems regarding(6 events).
fire watches that were experienced at Cook 1 as identified above j
1 Cook 2 also had equipment problems with fire barriers similar to those at Cook 1 which resulted in barriers being inoperable for periods of time that exceeded allowable TS limits (4 events).
Sequoyah I had many difficulties with missed or late fire watches j
due to equipment problems (such as broken door latches or locks),
personnel error (e.g., failure to follow procedures), and other reasons (airborne radioactivity or radioactive contamination prohibiting entry into fire watch area) (30 events).
During 1986:
Cook 2 had trouble with inoperable fire barriers due to personnel error (removal of sealant material), inadequate procedures, and unknown causes which resulted in barriers being inoperable for periods of time that exceeded TS-allowed time limits (4 events).
The number of such events at the two Cook units has significantly decreased during subsequent years.
Sequoyah 1 experienced a number of missed fire watches due to personnelerror(e.g.,lackofcommunication, omission), equipment problems (e.g., sticking fire doors, computer malfunction, broken door handles) and other reasons (high radiation levels prohibited entry into area) (12 events).
Sequoyah I had difficulties with failure to satisfy TS requirements regarding leak testing of the containment isolation control system due to inadequate procedures (3 events).
Due to procedural problems, Sequoyah I had difficulty (complying with the TS surveillance requirements for various systems 5 events).
14
v 1
Sequoyah 2 failed to conduct the TS-required radioactivity sampling when radiation monitoring system equipment was out of service (3 events).
Sequoyah 2 had difficulties satisfying TS requirements for leak testing of the. containment isolation control system due to procedural problems (6 events).
At Sequoyah 2, operation with inoperable fire barriers for periods' of time in excess of the TS allowable time limits due to personnel error or procedural problems (inadequate procedures) occurred several times (3 events).
Finally, the set of violations experienced during 1984-86 by the. group of mature plants excluding outliers was examined.
For the period from early 1984 through early 1985, the increasing trend for this group was largely responsible for the overall industry trend up, although there was also some increase in the contribution from newly licensed plants. This mature plant trend could not be traced through data analysis to any systematic reason, such as a general increase in violations for 'a few systems, or an increase in.
a certain type of violation - e.g., LCO-related violations (further analysis.
is provided in Section 3.3).
During peer review of the draft report, other flRC staff suggested possible underlying reasons for the increasing' trend during this period:
(1)
Increased tiRC emphasis on enforcement (e.g., more frequent.
inspections,stricterenforcement),
(2) flRC issuance of the definition for " operability" and its subsequent incorporation into individual plant TSs, and (3) Clearer understanding on the part of licensees of the reporting l
requirements in 10 CFR 50.73.
Throughout most of 1985 and into 1986, the mature population TS violation rate turned over, but then resumed increasing in 1987..A detailed review of LERs for a sample of plants in this group indicated that, in contrast with the general situation for outliers which experienced high numbers of repetitive violations of the same TSs, these plants had. lower overall numbers of violations involving a variety of TSs, but the underlying causes were repetitive.
The following are some typical examples.
(1)
Out of the 13 TS violations reported by)one mature PWR during 1986, seven (over an eight-month period were attributed to plant procedures which were not in conformance with the plant's-TSs.
(2) Ten of the 18 TS violations reported by one mature BWR in 1986 consisted of the failure to comply with surveillance test procedures, or to satisfy LC0 Action Statements due to lack of.
attention to detail.
(3) Out of 12 TS violations reported by a mature BWR during 1985, eight (over a 10-month period) consisted of problems with procedures which resulted in Surveillance T: requirements not being satisfied.
15
v (4) Out of the nine TS violations reported by a mature PWR during 1985, six (over a five-month period) consisted of personnel failing to comply with the applicable Action Statements for various systems.
We thus perceive that so..c licensees may be pursuing root causes and implementing corrective action on an event-specific basis, rather than broadening their scope to assess a whole range of events which, although they may involve different systems and different scenarios, have the same underlying causal factors.
As a result, the TS violation rate is not decreasing Therefore, we sug1est that NRR and the Regional Offices take new initiatives to ensure that the root cause analyses and corrective actions taken by licensees in response to TS violations address the programmatic root cause of such events rather than restricting their focus to specific events.
For example, the ISEG review of a plant's root cause analyses and corresponding corrective actions implemented in response to reportable events could be used to provide this assurance.
3.2 Technical Specification-Related Shutdowns The operational constraints imposed by LC0 Action Statements rarely force a plant to completely shut down and thus generate an LER.
In most cases, the required corrective action is completed in the time allowed by the Action Statement, or the licensee may begin the shutdown, but then increase power when the corrective action is completed.
The licensee may also request emergency relief (temporary waiver of compliance or enforcement discretion) in order to extend the allowed time to correct a problem without shuttino down. The preliminary count for 1987 was 71.
The number of completed TS-required shutdowns peaked in 1985 at 73, as shown in Table 3-1.
The preliminary count for 1987 was 71.
T,able 3-1 Completed Shutdowns Required by Technical Specifications 1984 1985 1986 Number of Shutdowns 57 73 65 Shutdowns per 10,000 critical hours 0.09 0.13 0.11 Number of P! ants Affected 41 41 44 Total Technical Specification Shutdown Hours 11,205 7,674 10,558 Average Hours Shut Down 220 105 165 Based on data in the LERs, Gray Book (NUREG-0020), and, where more detail was needed, licensee monthly operating reports, it was estimated that between 4 and 5 percent of total industry unavailability was related to TS-required shutdowns (See Figure 3-3).
Around 40 different plants 16
1984-86 PLANT UNAVAILABlUTY:
ALL P U NTS Forced Outoges i
. 22.7%
Technical Specifications 4.7%
j i
f Schedu!*d Outogee 1984 Forced Outoges 24.3%
Technical Specifications 3,7%
j ses.du:,, out,,,,
1985 Forced Outoges 25.9%
Technical specifications 4.7%
es.4 Scheduled Outop figure 3-3 1986
v experienced one or more shutdowns in a given year, and while. hours lost to an individual plant could be significant (e.g., exceed a month), this was the exception rather than the. rule. Appendix A provides a compilation of TS-related shutdowns for 1984-86.
About 40 different systems were involved in TS-required shutdowns over the three-year period. The reactor coolant ' system for PWRs and the equivalent BWR reactor recirculation system were the leading contributors,. accounting for 41 and 16 shutdowns, respectively (see Appendix B for complete listing of systems). The most frequent problem with these systems involved unidentified leakage which required the plant to shut down to safely identify and isolate or repair the source of leakage.
Some TS-required shutdowns may place a greater challenge on plant safety systems than if the plant were allowed to continue to operate for a limited time while necessary repairs to equipment were being made.
Such shutdowns may be counterproductive to the assurance of safety. These events generally involve degraded operation of systems that are necessary both to provide mitigating functions (maintaining reactor water level, neat removal,-etc.)
under accident coriditions and to effect a safe shutdown under normal con-ditions. These systems include (but are not necessarily limited to) ac and dc electric power, PWR auxiliary feedwater and PWR and BWR residual heat I
removal systems. Five events were identified from 1984 data in which one of the above systiens was in a degraded condition and the plant was shut down.
The number of such events increased to 15 during 1985. During 1986, there j
were five such events reported. A review of each of the events reported during 1985 showed that there were 10 instances of repetitious events involv-ing the same system at a given plant. These events had no apparent generic implications.
As mentioned earlier, completion of a p? ant shutdown is only the most extreme outcome (from the standpoint of impact on plant operations) when a plant enters an LC0. We estimate.that an LCD is entered approximately 24,000 timer a year across the industry.
In contrast, approximately 100 TS-required shutdowns are ?ctually begun in a yeu with, as we have seen, about 50 going to completion.
There are two regulatory mechanisms by which, under certain limited circum-stances, the NRC staff may grant relief from TS LCOs that would unnecessarily require a plant to shut down or to delay startop, absent some relief -
temporary waivers of cortpliance and enforcement discretion. These are discretionary acts on the part of the NRC staff that are not. exercised unless the staff is :learly satisfied that (1) there is good cause, and (2) the exercise of such action is consistent with the public health and safety. A temporary wai',er of compliance is a vehicle for the NRC's Office of Nuclear 1
)
. Data on LC0 entry from three plants differing in vintage and NSSS vendor design showed a surprisingly consistent number of LC0 entries,. averaging about 60 entries per calendar quarter. Across a 100-plant industry, this scales up to 24,000 times a year.
18
i Reactor Regulation (NRR) to grant relief from a LC0 where a license amendment is appropriate, but the amendment could not be processed before the LCO Action Statement time limit expired.
Enforcement discretion is a vehicle for the NRC Regional Administrators to grant relief from LCOs in certain, limited circumstances in which a license amendment would not be appropriate.
Granting temporary relief requires the licensee to demonstrate that the facility can safely continue to operate without compliance, possibly through other compensating measures.
For example, enforcement discretion may be used when the licensee can complete a repair within a short time after the LC0 time limit would elapse, and thus avoid putting the plant through a power reduction, with the concomitant increased potential for a plant transient.
Unfortunately, data on the use of temporary waivers of compliance or enforce-ment discretion are not centrally collected, and thus frequency of use and circumstances cannot be analyzed.
Generic Letter 87-09 addressed an issue from the TSIP report, namely that l
most TSs were structured with the potential for causing a plant shutdown because a missed surveillance could not be performed in time.
This comes i
about because the STS direct that, in the absence of evidence provided by surveillangg, the affected equipment mu:t be presumed inoperable until proven otherwise.
Prior to Generic Letter 87-09, upon discovering that a surveillance had been missed, a plant could find itself in a situation where an allowed outage time had already elapsed, or an allowed outage time was running out while the plant.was trying to perform surveillance to re-establish operability.
None of the TS-required shutdowns over the three years could be traced to the presumed inoperability of equipment due to missed surveillance.
3.3 Technical Specification Violations and Compliances Reports of plant operations prohibited by TSs can be subdivided into four major classifications:
(1) violations of Limiting Conditions for Operation (LCOs), (2) violations of Surveillance Requirements (i.e., missed or improperly performed surveillance), (3) violations of Safety Limits or Limiting Safety System Settings (LSSS), and (4) violations of Administrative Controls (Section 6 in the STS).
These categories align with four of the major TS categorics established by 10 CFR 50.36 in 1968.
I 6m Memorandum, Denton to Regional Administrators, " Relief From Technical Specification LCOs", February 27, 1987.
Specification 4.0.3 of the Standard Technical Specifications states, l
" Failure to perform a Surveillance Requirement within the specific time I
interval shall constitute a failure to meet the OPERABILITY l
requirements for a Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications."
"* Generic Letter 87-09 clarified the applicability of Action Requirements, specified a specific acceptable time limit for completing a missed surveillance in certain circumstances (E4 hours), and clarified when missed surveillance constitutes a violation of LC0 Operability Require-I ments. Closely related to violations of LCOs are entries into 19
Specification 3.0.3 of.the STS or the equivalent.
Such situations arise when a particular. LC0 is not met, except as provided in the associated ACTION requirements. Although such entries do not constitute a violation, previous regulatory guidance has interpreted them as operations prohibited by TSs and, 3
therefore, reportable.
I 3.3.1 LCO Violations Figure 3-4 illustrates how LC0 violations comprised the dominant portion of TS violations during the period 1984-86. The number of LC0 violations in a given year exceeded the number of violations of Surveillance Requirements by.
greater than a 3-to-1 ratio. The number of LC0 violations generally reflected the behavior of the overall distribution of violations in that there was a significant increase in LC0 violations from 1984 to 1985, with only a slight increase noted from 1985 to 1986.
The data for LC0 violations were further evaluated for insights regarding:
(1) the influence of the specific NSSS vendor and the type of TSs (STS or Custom), (2) the systems involved in these violations, and (3) the causes of the violations.
3.3.1.1 Influence of NSSS Vendor and Technical Specification Type The possible systematic influence of both the NSSS vendor and the type of TSs (i.e., Standard or Custom) on the rate of LC0 violations was examined -
using data that excluded events from plants during their first two years of licensed operation. Data for mature plants which were found to be. outliers
( 2 standard deviations) in a given year were also removed from the data base for that year prior to the analysis.
Since there are only three Combustion Engineering (CE)-designed plants with Custom TSs, and just two Babcock and Wilcox (B&W)-designed plants with STS, data for these five plants were also omitted from the analysis. Average normalized.LC0 violation rates were then calculated and plotted for 6-month intervals for the remaining NSSS design and TS type combinations.
In general, the results indicated an increasing trend in LC0 violation rate over the three-year period regardless of NSSS vendor or TS type. A possible exception was the case of CE plants with STS, whose LC0 violation rate, on the average, showed little change during the entire period. As discussed below, the average LC0 violation rate for GE plants with STS was high compared with the most recent data for LC0 violation rates for CE and Westinghouse plants with STS. Finally, in the case of GE plants, the LC0 violation rate for plants with STS exceeded the violation rate for plants with Custam TSs, while the reverse was true for the case of Westinghouse plants.
The results of the analysis of LC0 violation rates are summarized in Figures 3-5 and 3-6 for plants with STS and Custom TSs, respectively. A notable feature for the STS case is that the violation rate for GE plants, after the first half of 1984, is generally higher than the violation rates for CE and Westinghouse plants with STS, by as much as a factor of two. A review of each event in the set of LC0 violations for GE plants with STS during the i
20
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I second half of 1984, the second half of 1985, and during all of 1986 did not identify any obvious pattern among the various events experienced by each l
plant in each of these six-month periods.
It should be pointed out that, absent outliers, the population of mature GE plants changed significantly l
over the three-year period, from only three plants during the first five months of 1984 to ten plants by the end of 1986.
This shift in population I
clouds the interpretation of any trends observed in the data, j
On the average, the LC0 violation rate for mature CE plants with STS showed little change over the three-year period, remaining about 1.8-2.0 violations per plant per 6-month interval. The set of LC0 violations for mature CE i
plants with STS was also reviewed for patterns in the type of event or system involved.
None were identified in this manner.
The LC0 violation rate for mature Westinghouse plants with STS showed a steady increase over the three-year period, rising from approximately 1.3-violations per plant in the first half of 1984 to approximately 2.2 l
violations per plant during the second half of 1986.
On the average, the l_C0 violation rates for plants with Custom TSs showed a steadily increasing trend over the three-year period across all NSSS vendors (i.e., B&W, GE, and Westinghouse), increasing from 1-1.5 violations per plant per 6-month interval at the beginning of 1984 to about 2.5-3.0 violations per plant per 6-month interval by the end of 1986.
As can be seen from Table 3-2, with the exception of the first half of 1984 (which may be an anomaly for GE plants wich STS, as implied previously),
the LC0 violation rate for GE plants with STS was greater than the LC0 violation rate for GE piWs with Custom TSs, by as much as a factor of two.
In contrast, in the case of Westinghouse plants, the LC0 violation rate for plants with Custom TSs was greater than the LC0 violation rate for STS plants from the second half of 1985 through the end of 1986.
From the first half of 1984 through the second half of 1985, the violation rate for STS plants was slightly greater.
Table 3-2 Ratio of LC0 Violation Rate for Plants with STS to the LC0 Violation Rate for Plants with Custom TSs 1984 1985 1986 NSSS Vendor 1st Hal M nd Half 1st Halt-'Ind Half 1st Halt ~~~2nd Ha lf 1
l GE 0.42 2.02 1.17 1.27 2.15 1.42 Westinghouse 1.10 1.33 1.06 0.93 0.88 0.84 3.3.1.2 Systems Involved in LC0 Violations The group of all TS violations involving LCOs was reviewed for insights regarding the systems involved. Table 3-3, on the following page, presents a summary of significant results, i
24
1 1
Table 3-3 Summary of System Involvement in LC0 Violations Contribution To. Total Number of LCO Violations System 1984 1985 1986 Radiation Monitoring
'61/442 54/714 86/800.
j I
Fire Detection 47/442 135/714 129/800 Containment Isolation Control 45/442 51/714 57/800 FireProtection(Passive) 43/442 44/714 38/800 ReactorCoolant(PWR) 21/442 j
]
Control Rod Drive 29/714
]
Main / Reheat Steam 27/800
)
This system was not among the top five contributors to system involvement in LC0 violations for the year shown.
The same four systems (radiation monitoring system, fire detection system})
containment isolation control system, and fire protection system (passive dominated the distribution of systems involved in LC0 violations for each of the three years of interest.
As can be seen from Table 3-3, these four systems were involved in 194/442 (45%) LC0 violations in 1984,282/714(40%)LC0' violations in 1985, and 310/800 (39%) LC0 violations in 1986.
Further, in i
each of the three years of interest, the system with the fourth highest contribution was involved in almost twice as many violations as the fifth l
highest contributor. A detailed listing of the systems involved in each event may be found in Tables C-1 through C-3 in Appendix C.
Generic Letter 86-10, which represents one of the. first short-term efforts of the Technical Specification Improvement Program, basically required each licensee to incorporate the approved fire protection program, and its licensing basis, into the next update of 'he plant's FSAR.
In addition, the Generic letter 86-10,(c"opy included in Appendix D). Implementation of Fire Prote dated April 24, 1986 i
25
licensee was encouraged to take steps which would allow deletion of the fire protection TSs, since they would be replaced by a license amendment to implement and maintain the fire protection program as documented in the program plan.
This recommendation was based in part on the analysis of 1984 TS violations (Ref. 4), which indicated that most of these kinds of violations were of low or medium safety potential. The further analysis of 1985 and 1986 data did not alter this conclusion.
From the results of our study, it is evident that the fire protection (detection and suppression) TSs have been a major contributor to the number of TS-related events.
Therefore, as a result of the actions prescribed in Generic Letter 86-10, it appears that the number of reported TS-related events will decline, based on the forthcoming relocation of the fire protection requirements fron the TSs to the program plan, although some licensees do not plan to do so.
It follows that-the visibility of performance in the area of fire protection may decline.
In the past (Ref. 9), we have found that the reporting of operational events, even those of relatively. low safety significance, does provide a stimulus for licensees to conduct root cause analyses and to effect' corrective action to prevent recurrence of such events.
This consideration must be carefully weighed when contemplating modification of reporting requirements for operational events with relatively low safety significance, of which violation of fire protection requirements is but one example. We believe that measures should be taken to provide assurance that any requirements which are removed from the TSs ara adequately controlled to ensure that violations of these requirements ac'. acted upon with thorough root.cause corrective actions (i.e., that licensee corrective action analysis and implementation continue).
For this reason, we suggest that NRR take steps to ensure that (a) licensee corrective action analysis and implementation are not diminished by removal of requirements from the TSs, and (b) this analysis and implementation are readily available for NRC inspection.
As mentioned previously, we applied the NRC staff's proposed modified criteria for determining TS content to the 1984-86 TS violation data. This was done solely from a system perspective to obtain estimates of the effect of the criteria on the number of TS violations reported over the three-year period. Table 3-4, on the following page, summarizes the results of an analysis of the estimated effect of the proposed modified criteria on the number of LC0 violations if only those systems satisfying the criteria were included in the TSs. The estimated reductions in the total number of I
reported LC0 violations range from 26% to 33%.
26
Table 3-4 Estimated Reduction in Number of LCO Violations Under NRC Staff's Proposed Modified TS Content Criteria No. LC0 Violations That a
No. LC0 Violations Would Remain under Staif's Estimated j
Year Reported Moditied Criteria Reduction 1984 442 327 26%
1985 714 477 33%
1986 800 562 30%
1 3.3.1.3 Causes of LC0 Violations l
The group of all LC0 violations during 1985 and 1986 was also considered I
from a cause perspective.
In this case, general cause categories (personnel error, problems with equipment, problems with procedures, natural phenomena,
]
other, and unknown) were determined.
The category personnel error includes those violations which were caused by actions committed or omitted by personnel using correct procedures, cognitive failure on the part of l
operators to perform a required action within the specified time limit, failure to use an approved procedure, and selection of wrong switches, components, or equipment trains.
This contrasts with the procedural l
problems category, which ir,cludes correct use of an erroneous procedure, and ambiguous or unclear procedures.
Equipment-caused violations include those situations in which, because of problems with equipment, a condition l
l prohibited by the TSs existed (i.e., the plant was in a degraded mode j
allowed by the TSs) for a period of time longer than that permitted by the TS, even if the condition was not discovered until the allowable time had elapsed and the condition was rectified immediately after discovery.
l Design-related problems were also included in the equipment cause category in this study. Natural phenomena include such.causes as thunderstorms, flooding (not human-caused), wind, and seismic events.
I Table 3-5 summarizes the results of our review of the LC0 violation data for 1985 and 1986 (no cause data available for 1984) from a cause perspective.
l l
Table 3-5 LC0 Violations:
Leading Contributors to Cause Category Distribution 1985 Data 1986 Data l
Cause Category Contribution Percentage Contribution Percentage l
Personnel Error 350/714 48%
438/800 55%
Equipment Problems 216/714 30%
171/800 21%
Procedural Problems 111/714 15%
144/800 18%
i 27
As can be seen from Table 3-5, the same three cause categories, personnel i
error, equipment problems, and problems with procedures, in that order, dominated the cause category distribution for LC0 violations in both years, j
The set of LC0 violatics G:ed by equipment problems was.further examined for information regarding the root component involved in the event (for 1985 and 1986 only).
In this manner,'it was found that the lominant root components were isolation / shutoff volves, door / cover / hatch problems, seals, fire barriers, and damper / louver components, i.' that ceder. Most of the door / cover / hatch problems consisted of problems with fire doors or fire l
~
watches which were missed due to door malfunctions. Fire barrier problems were equipment problems that resulted in degraded fire barriers. Most of the
" damper / louver" component events involved fire damper problems, which were reportable under the fire protection TS requirements. The " seal" component events involved degraded fire barrier seals which were also reportable under fire protection requirements in the TSs.
3.3.1.4 Compliances As mentioned previously, the group of_ events classified as compliances in-this study is closely related to LC0 violations.
By compliances we mean the reported entry into Specification 3.0.3 of the STS or equivalent.
Recent actions taken by the Technical Specification Improvement Program dealt with 1
the matter of entry into Specification 3.0.3 and also with several other of the so-called " Motherhood Clauses" in the STS.
j On June 4, 1987, as one of the short-term TS improvement efforts, the NRC staff issued Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements" (copy included in Appendix E).
The guidance provided in this generic letter addressed three particular l
problems that have been encountered with the general requirements on the applicability of LCOs and Surveillance Requirements contained in the
" Motherhood Clauses" found in Sections 3.0 and.4.0 of the STS, including Specification 3.0.3.
Entry into Specification 3.0.3 is generally interpreted (See NUREG-1022, Supplement No. 1, Page 4, Item 2.4) as being a reportable event.
Generic Letter 87-09 revised the bases for Specification 3.0.3 in an attempt to clarify the intent of this specification to prevent its misuse.
This clarification has subsequently become important because of recent reports regarding incorrect use of the provisions.of Specification 3.0.3 by some licensees.
NRC Inspection Manual Part 9900, " Technical Guidance, STS Section 3.0.3,"-
also was recently issued to provide the following guidance to NRC inspectors on the intent and application of a licensee entering the general TS l
requirement for an LC0:
"LC0 as defined in STS 3.0.3 is not intended to be used as an operational convenience which permits redundarit safety systems to be out of service for a limited period of time.
Its intended purpose is to provide guidance on the time limits for an " orderly" shutdown when the individual LC0 or ACTION statements in other specifications cannot be complied with.
Voluntary entry into i
28 i
v LC0 3.0.3 deliberately removes the last line of defense against potentially harmful events. Doing so allows removal of a system from service when the redundant system is already inoperable. An action like this would show a disregard for plant safety and is unacceptab!e.
It should also be emphasized that removal of a system from service is justified only for test, maintenance, or repair purposes."
The results of our review of the TS-related data for 1985 and 1986 concerning the reported entry by licensees into Specification 3.0.3 are summarized in Figure 3-7.
This figure indicates a total of 119 reported entries into Specification 3.0.3.
Twenty-eight were due to equipment failures, 30 entries were classified as other (e.g., 25 cognitive personnel error events), and 61 were voluntary entries - 52 to perform surveillance and 9 to do maintenance.
Most (90%) of the 52 voluntary entries to perform surveillance were l
due to one plm t's contribution (47 events). This plant's events were mainly I
due to two problems. One (36 events) was due to the plant TSs not having a provision allowing for degraded voltage protection monthly surveillance.
Therefore, in order to perform the monthly degraded voltage protection surveillance on the Engineered Safeguard System buses, all degraded voltage protection on the bus was taken out of service, although the bus remained energized. An amendment to this plant's operating license changing the TSs was subsequently issued in July 1987 resolving this problem.
The second problem was due to an off-normal c'ontainment radiation monitoring (CRM) system configuration required whenever wetwell nitrogen addition or purging operations were performed, which forced an entry into the Motherhood Clause.
In order to reduce the potential for leakage from the CRM vacuum blowers identified during a previous leakage quantification test, one CRM is isolated and the other system is aligned to meet the TS requirements of drywell atmosphere particulate and noble gas monitoring during normal operation.
During suppression pool nitrogen addition and purging operations, the division monitoring the drywell is swapped to sample the wetwell.
Without a division monitoring the drywell, Specification 3.0.3 must be invoked.
Subsequently, the plant's operating strategy was reviewed, evaluated, and l
revised to obviate the need to enter Specification 3.0.3.
There were significantly fewer (9) events of voluntary entry into Specification 3.0.3 to perform maintenance. Most of these events (67%) were also due primarily to one plant's contribution.
These events related to opening the output breakers of both "A" and "B" emergency feedwater initiation and control (EFIC) channels, disabling the automatic function of this system. This was done to preclude possible spurious actuations while troubleshooting / repairs were being made.
The EFIC problems stem from either i
defective electronic modules within EFIC or faulty channel light emitting j
diodes which result in half-trip signals.
Our review of 1987 LERs revealed that Specification 3.0.3 was entered on five occasions for these same reasons, with the latest entry occurring in July. The licensee states that a special EFIC engineering task group is investigating the root cause for these problems, with a supplemental report forthcoming in late March 1988.
~
29
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v From these results, we conclude that voluntary entry into Specification 3.0.3 to perform surveillance or to do maintenance is not a widespread practice, but occurs on an isolated basis and has been limited to a relatively few l
plants.
l 3.3.2 Surveillance Requirement Violations f s shown in Figure 3-4, violations of Surveillance Requirements make up the second leading contributor to the distribution of TS violations. When the group of all TS violations involving Surveillance Requirements was examined, a significant increase was observed in the number of such violations from 1984 (165 violations) to 1985(305 violations).
l In another of its short-term TS improvement actions (the action regarding Specification 4.0.3 was discussed previously in Section 3.2), the Technical Specification Improvement Program addressed an issue directly related to Surveillance Requirements, namely the potentially adverse impact of Specification 4.0.4 of the STS on plant operations. Specification 4.0.4 of the STS prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been fulfilled within the specified surveillance interval. Generic Letter 87-09 indicates that conflict within this specification exists when a mode change is required as a consequence of shutdown Action Statement requirements, and the surveillance requirements that become applicable have not been. performed within the specified surveillance interval (e.g., the plant was previously in a mode for which this surveillance requirement was not applicable, therefore, the surveillance had not been performed within the specified interval).
From our review of the TS-related event data for 1985 and 1986, we identified only four cases in which Specification 4.0.4 was violated (i.e., a mode change occurred and the applicable surveillance had not been performed within the reouired interval),
which indicates that reported instances involving violations of this specification have been relatively few.
3.3.2.1 Influence of NSSS Vendor and Technical Specification Type In a manner similar to the case of LC0 violations, the rate of Surveillance Requirement violations was examined using data that excluded events from plants with less than two years of licensed operation. Again, the influences of NSSS vendor design and type of TSs (STS or Custom) were evaluated.
As mentioned previously, data from :
(1) outliers in a given year, (2) the three Combustion Engineering (CE)-designed plants with Custom TSs, and (3) the two B&W plants with STS were omitted from the analysis. Average normalized Surveillance Requirement violation rates were calculated and plotted for 6-month intervals for the remaining NSSS design and TS type combinations.
31
l l
The results generally indicated little change in the Surveillance Requirement violation rate over the three-year. period across all NSSS. vendors.
The only exception was the data for GE plants with STS, which showed a rise and a decline.between the second half of 1984 and the first half of 1985. This behavior was attributed to different sets of repetitious events which occurred at four different plants in the group.
The results of the analysis of Surveillance Requirement violation rate data regarding the influence of TS type proved inconclusive.
The results-of the analysis of Surveillance Requirement violation rates are j
summarized in Figures 3-8 and 3-9 for plants with STS and Custom TSs, i
respectively. A notable feature for the STS case is the rise and decline in the 1985 data'for GE plants, with the peak in the first half of that year.
A review of each event in the set of Surveillance Requirement violations for l
GE plants with STS during the first half of 1985 shewed that, out of the 31 l
such events which occurred at six plants during this period,17 (55%)
consisted of four different sets of repetitious events that occurred at four different plants as follows.
Brunswick I had problems with procedures which resulted in inadequate surveillance testing of several systems (4 events).
At La911e 1, a TS-required hydrogen sample was taken at the wrong location in the off-gas system due to personnel error (4 events)
Grand Gulf failed to perform TS-required dose equivalent iodine analysis-after a reactor scram on a number of occasions due to personnel error (5 events).
Susquehanna 1 had problems with procedures which resulteo in failure to perform TS-required surveillance testing of the service water and chilled water systems within specified time limits (4 events).
Although each of the events in a specific set involved the same system and/or l
cause, each set was unique and showed no generic implications.
If the surveillance requirement violation rate for GE plants with STS for this period were modified to exclude the contribution from plants with repetitious events, it would then be consistent with the corresponding rates calculated for the other NSSS designs.
l The data for mature CE and Westinghouse plants with STS-remained fairly constant throughout the three-year period, at approximately 0.5 to 0.8 violations per plant per 6-month interval.
The Surveillance Requirement violation rates for B&W, GE, and Westinghouse plants with Custom TSs all began and ended the three-year period at roughly) the same value (approximately 0.5 violations per plant per 6-month interval although their behavior in between was somewhat dissimilar.
32
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For GE plants, the variation in this ratio mirrors the variations in the violation rate for plants with STS discussed previously, in the case of Westinghouse plants, the variation in this ratio reflects the variations in the violation rate for plants with Custom TSs described above.
Overall, both the GE and the Westinghouse cases are too volatile to support any strong conclusions.
Table 3-6 l
Ratio of Surveillance Requirement Violation Rate for Plants with STS to the Surveillance Requirement Violation Rate for Plants with Custom TSs 1984 1985 1986 NSSS Vendor 1st Halt 7nd Half 1st Halt ~~Tnd Half 1st Hal M nd Half GE 0.92 3.33 5.73 2.36 0.71 1.47 Westinghouse L32 1.38 0.70 0.73 0.86 1.53 If the contribution to the relatively high LC0 violation rate in this period from plants sith repetitious events were removed, this ratio would be 2.97.
l Table 3-7, on the following page, shows the ratio of the LC0 violation rate to the Surveillance Requirement violation rate for mature GE and Westinghouse plants with STS and Custom TSs, excluding outliers, over the three-year period.
During the first half of 1985, the Surveillance Requirement I
violation rate for GE plants with STS was greater than the corresponding LCO j
violation rate by about a factor of two.
In all otner cases, however, the LC0 violation rate was greater than (by as much as a factor of six) or equal to the Surveillance Requirement violation rate for the entire three-year period across all NSSS vendors and TS types.
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l Table 3-7 Ratio of LC0 Violation Rate to Surveillance Requirement Violation Rate NSSS TS 1984 1985 1986.
Vendor Type l'st Ha lMnd Ha lf 1st Halt 7nd Half 1st Halt 7nd Half GE STS 1.13-1.89 0.52*
1.22 5.24 3.58 j
GE Custom.
2.44 3.11 2.52 2.27 1.73 3.71 West.
STS 2.73 3.38 2.37 3.37 2.30 3.63 West.
Custom 5.72 3.50 1.56 2.65 2.24 6.62 If the contribution to the Surveillance Requirement violation rate from plants with repetitious events were removed, this ratio would be 0.90.
3.3.2.2 Systems Involved in Surveillance Requirement Violations-As with LC0 violations, the group of Surveillance Requirement violations was reviewed for insights regarding the systems involved. The results, which are summarized in Table 3-8, were somewhat different than the results for the case of LC0 violations.
Out of the 40-odd systems which were involved in Surveillance Requirement violations during the three-year period, the leading contributor to the system distribution in each of the three years was the radiation monitoring system.
However, unlike the LC0 violation case, the composition of the remainder of the group of systems with relatively high contributions to the total number of violations differed from year to year.
In addition, the data for 1985 had entirely different characteristics from the 1984 and 1986 data.
Whereas the 1984 and 1956 data indicated that there were two systems which dominated the distribution of systems involved and accounted for about 25-30%
of the total for each year (in addition to the radiation monitoring system, these were the emergency onsite ac power system in 1984 and the containment isolation control system in 1986), the data for 1985 showed just one dominant system, which only represented about 10% of the total for that year.
Detailed results may be found. in Tables C-4 through C-6 in Appendix C.
-]
)
I 1
36
Table 3-8 Summary of System Involvement in Surveillance Requirement Violations Contribution To Total Number of Surveillance Requirement Violations System 1984 1985 1986 Radiation Monitoring 29/165 25/309 34/277 Emergency AC Power 26/165 12/277 31/277 Containment Isolation Control 13/165 Fire Detection 7/165 15/309 Incore/Excore Neutron Monitoring 7/165 17/309 14/277 Low Pressure Coolant Injection (BWR) 5/165 Low Pressure Safety Injection (PWR) 5/165 Fire Protection (Water) 5/165 Reactor Containment Building 14/309 l
13/309 13/277
)
ReactorRecirculation(BWR)
This system was not among the top five contributors to system involvement in LCO violations for the year shown.
In a nanner similar to the case of LC0 violations, we applied the NRC staff's l
proposed modified criteria for determining TS content to the Surveillance Requirement violation data for 1984-86 from a system perspective. The estimated reductions in the total number of Surveillance Requirement violations are summarized in Table 3-9, 1
1 37
v
- _ _ =
Table 3-9 Estimated-Reduction in Number of Surveillance Requirement Violations Under
.NRC Staff's Proposed Modified TS Content Criteria No. Surveillance Requirement No. Surveillance Violations That Would Remain-Estimated Year Requirement Violations Under Statt's Modified Criter_i_a_
Reduction 1984 165 143 13%
.1985 309 257 17%
1986 277 239 14%
l We then combined the above results with the corresponding results for the case of LC0 violations to obtain an estimated reduction in the total number of TS violations resulting from the application of the staff's criteria that ranged from 23-28% for each of the three years of interest.
3.3.2.3 Causes of Surveillance Requirement Violations Not surprisingly, at the general cause category level, Surveillance Requirement violations show a profile that differs from that of LC0 l
violations.
Specifically, equipment problems played no significant role in the Surveillance Requirement violation experience, as shown in Table 3-10.
Table 3-10 Surveillance Requirement Violations:
Leading Contributors to Cause Category Distribution 1985 Data 1986 Data Cause Category Contribution Percentage Contribution Percentage Personnel Error 173/309 56%
133/277 48%
Procedural Problems 109/309 35%
133/277 44%
Equipment Problems 19/309 6%
14/277 4%
There were only two cause categories, personnel error and problems with procedures, which dominated the cause category distribution for Surveillance Requirement violations in both 1985 and 1986. Personnel error was the i
leading contributor, followed by problems with procedures and equipment problems, in that order. This result was not unexpected, since almost all violations of this type are human in origin.
38
1 v
4.
SUMMARY
OF FINDINGS, CONCLUSIONS, AND SUGGESTIONS Significant findings from our analysis of TS-related events for the period
]
1984-86 are summarized below.
From the analysis of the overall distribution of TS-related events:
The distribution of TS-related events was dominated by TS violations (91%) throughout the four-year period, 1984-87, as opposed to shutdowns 4
(6%) and compliances (3%).
The number of TS violations increased significantly from 1984 (668) to 1985(1074), with only a small increase noted from 1985 to 1986 (1110) and a larger increase seen in 1987 (1269).
The average violation rate per plant went from 7.5 violations per plant in 1984 to 11.0 violations per plant in 1985 to 10.7 violations per plant in 1986, increasing in 1387 to 11.4 violations per plant.
The number of TS violations considered to be of relatively high safety potential actually decreased between 1985 and 1986. The increase observed in the number of violations over these two years was due solely to an increase in violations of " medium" safety potential.
The frequency of completed, TS-related shutdowns was relatively low throughout the four-year period.1984-1987 compared to the frequency of TS-related evente, reaching a maximum of 73 in 1985. An estimated 4-5%
of total industry unavailability was related to TS-required shutdowns.
The leading contributors to system involvement in TS-required shutdowns were the PWR reactor coolant system and the BWR reactor recirculation system. Most of the shutdowns involving these systems were carried out to identify and isolate or repair sources of unidentified leakage.
From the analysis of the distribution of TS violations:
]
The distribution of TS violations over the period of interest consisted of contributions from three distinct groups of plants:
(1) newly licensed plants (with disproportionately hi extensively discussed in Reference 8), (2) gh violation rates, a subject a few mature plants in each year which experienced relatively high violation rates, and (3) the remainder of the mature plants.
The small group of mature plants with relatively high violation rates in each of the three years 1984-1986 experienced one or more sets of repetitious (three or more of the same general type) events, each set of which had similar characteristics and involved the same system and/or cause. The sets of repetitious events differed from plant to plant, but they represented a significant portion of each plant's contribution to the overall distribution of violations.
Between early 1984 through early 1985, the increasing trend for the group of mature plants excluding outliers was largely responsible for the overall increasing trend in the industry's TS violation rate, although there was also some increase in the contribution from newly licensed plants.
This mature plant trend could not be traced through data analysis to any systematic reason, such as a general increase in violations for a few systems, or an increase in a certain type of 39
violation (e.g., LCO-related violations).
During peer review of the draft report, other NRC staff suggested possible underlying reasons for the increasing trend during this period:
(1) Increased NRC emphasis on enforcement (e.g., more frequent inspections, stricter enforcement, increased NRC presence onsite),
(2). NRC issuance of the definition for " operability" and its subsequent incorporation into individual plant TSs, and (3) Clearer understanding on the part of licensees of the reporting requirements in 10 CFR 50.73.
Throughout most of 1985 and into 1986, the mature population TS violation rate turned over, but then resumed increasing in 1987. A detailed review of LERs for a sample of plants in this group indicated that, in contrast with'the general situation for outliers (which experienced high numbers of repetitive violations of the same TSs),
these plants had lower overall numbers of violations involving a variety of TSs, but the underlying causes were repetitive.
We perceive that some licensees may be pursuing root causes and
]
implementing corrective action on an event-specific basis, rather than-broadening their scope to assess a whole range of events which, although l
they may involve different sy, stems and different scenarios, 'have the same und elying causal factors. As a result, the TS violation rate is not decreasing.
From the analysis of LC0 and Surveillance Requirement violations experienced by mature plants, excludina outliers, for the influence of NSUS vendor and typeofTSs(STSorCustom):
a in general, the results indicated an increasing trend in LCO violation rate over the three-year period regardless of NSSS vendor or TS type. A possible exception was the case of CE plants with STS, whose LC0 violation rate, on the average, showed little change during the entire period. The average LC0 violation rate for GE plants with STS was high compared with the most recent data for LCO violation rates for CE and Westinghouse plants with STS.
Finally, in the case of GE plants, the LC0 violation rate for plants with STS exceeded the violation rate for plants with Custom TSs, while the reverse was true for the case of Westinghouse plants.
After the first half of 1984, the LC0 violation rate for GE plants with STS was generally higher than the violation rates for CE and Westinghouse plants with STS, by as much as a factor of two. The LC0 violation rate for CE plants with STS showed little change over the three-year period, remaining about 1.8-2.0 violations per plant per 6-month interval. The LC0 violation rate for Westinghouse plants with STS showed a steady increase over the three-year period from approximately 1.3 violations per plant per 6-month interval at the beginning of 1984 to about 2.2 violations per plant per 6-month interval at the end of 1986.
Except for a possibly anomalous data point in the first half of 1984, the LC0 violation rate for GE plants with STS exceeded the LC0 violation rate for GE plants with Custom TSs, 40
by as much as a factor of two.
The LC0 violation rate for Westinghouse plants with Custom TSs was greater than the LC0 violation rate for STS plants from the second half of 1985 through the end of 1986.
From the first half of 1984 through the second half of 1985, the violation rate for STS plants was slightly greater.
During the first half of 1985, the Surveillance Requirement violation rate for GE plants with STS was greater than the corresponding LC0 violation rate by about a factor of two.
In all other cases, however, the LC0 violation rate was greater than (by as much as a factor of six) or equal to the Surveillance Requirement violation rate for the entire three-year period across all NSSS vendors and TS types.
From the analysis of all LC0 and Surveillance Requirement violations for 1985 and 1986 regarding general cause category and component involved:
The same three cause categories, personnel error, equipment problems, and problems with procedures, in that order, dominated the cause category distribution for LC0 violations in both 1985 and 1986.
The dominant root components for LCO violations. caused by equipment problems during these two years were isolation / shutoff valves, door / cover / hatch problems, seals, fire barriers, and damper / louver components, in that order.
Most of these problems were reportable under the fire protection TS requirements.
The same four systems (radiat' ion monitoring system, fire detection system, containment isolation control system, and fire protection system (passive) dominated the distribution of systems involved in LC0 violations for each of the three years, 1984, 1985, and 1986. The radiation monitoring system was the leading contributor to the distribution of systems involved in Surveillance Requirement violations during the three-year period.
However, the composition of the remainder.
of the group of systems representing the highest contributors to this distribution differed from year to year.
Only two cause categories, personnel error and problems with procedures, dominated the cause category distribution for Surveillance Requirement violations in both 1985 and 1986, a result which was not unexpected since almost all violations of Surveillance Requirements are of human origin.
Our study also considered several of the short-term actions taken by the Technical Specification Improvement Program, rectably Generic Letters 86-10 (Appendix D) and 87-09 (Appendix E), which dealt with situations where the industry had indicated difficulty in coping with TS requirements.
Under current reporting requirements, only those situations when licensees were unsuccessful in coping with TS requirements (i.e., there was a violation) are reported. However, it was deemed useful to feed back information regarding those instances where licensees were unsuccessful in coping with TS requirements.
41
-v In the case of Generic Letter 86-10 regarding fire protection requirements, the results of our analysis of 1985 and 1986 data supported the TSIP conclusions, based on consideration of one year (1984) of data, that (1) the fire protection (detection and suppression) systems have been dominant contributors to the distribution of systems involved in TS violations, and (2) most of the events involving these systems have been of relatively low or medium safety potential. As a result of the actions prescribed in Generic Letter 86-10, it appears that the number of reported TS-related events will decline, based on the forthcoming relocation of the fire protection requirements from the TSs to the program plan.
It follows that the visibility of performance in the area of fire protection may decline.
From our experience, we have found that the reporting of operational events, even those of relatively low safety significance, does provide a stimulus for licensees to conduct root cause analyses and to effect corrective action to prevent recurrence of such events.
This consideration must be carefully weighed when contemplating modification of reporting requirements for operational events with relatively low safety significance.
Our consideration of the issues addressed in Generic Letter 87-09 was limited by the fact that, with the exception of Specification 3.0.3 of the STS, entry into one of the " Motherhood Clauses" in the STS has not been generally viewed as a reportable event. Consequently, except for Specification 3.0.3, only violations of these specifications have been reported, in our analysis of TS-related shutdowns, we found that none of the TS-required shutdowns reported over the three-year period 1984-86 were j
traceable to the presumed inoperability of equipment due to missed surveillance.
This finding relates to a concern about Specification 4.0.3 stated in Generic Letter 87-09 that it is overly conservative to assume systems or components are inoperable when a required surveillance has not been performed.
1 Another issue addressed in Generic Letter 87-09 has the potential adverse impact of Specification 4.0.4 of the STS on plaut operations. Our review of 1985-86 TS-related data identified four cases in which Specification 4.0.4 was actually violated.
These results indicate that, although licensees may be having difficulty complying with this specification, reported instances in which Specification 4.0.4 was actually violated have been relatively few.
Finally, our review of the number of entries into Specification 3.0.3 of the STS determined that most.of the voluntary entries to perform surveillance or to do maintenance were repeated entries made by two plants.
For this reason, we conclude that this practice, which is contrary to the intent of Specification 3.0.3, is not widespread, but occurs on an isolated basis, and has been limited to a relatively few plants.
42
'l suggestions The apparent increasing trend in-TS violation rate is a matter of concern.
Therefore, we suggest that NRR and the Regional 0ffices take new initiatives j
to ensure that the root cause analyses and corrective actions taken by:
I licensees in response to TS violations address the. programmatic root cause of such' events rather than restricting their focus to specific events.
For example, the ISEG review'of a plant's root cause analysis and corresponding-corrective actions implemented in response to reportable events could be used a
to provide this assurance.
We believe that licensee corrective action analysis and implementation should continue for violations of. requirements (including fire protection) that are j
removed from the TSs. Therefore, we suggest that NRR take steps to ensure that: (a) licensee corrective action analysis and implementation are' not-diminished by removal of requirements from TSs, and (b). this analysis and implementation are readily available for NRC inspection..
S l
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1 l
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l 43.
l
[
LIST OF REFERENCES 1.
" Recommendations for Improving Technical Specifications," Technical Specification Improvement Project, Office of. Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C., September 30, 1985.
2.
" Technical Specifications Improveinents," Subcommittee on lechnical Specification Improvements of the Committee on Reactor Licensing and Safety, Atomic Industrial Forum, Washington., D.C., October 1,1985.
3.
"AIF/TSIP Criteria Tria Application - Wolf Creek / Limerick TS Split,"
Memorandum dated MSrch 21, 1986, to Edward J. Butcher, Chief, Technical Specification Coordination Branch, from Kulin D. Desai, Technical Specification Coordination Branch, Division of Human Factors Technology Office of Nuclear Regulation, U,S. Nuclear Regulatory Commission, Washington, D.C.
4
" Impact of Technical Specifications on Operating Reactors During 1984,"
SAIC-85/1777, D. Gallagher and B. Atefi, Science Applications International Corporation, McLean, Virginia, July 31, 1985.
5.
" Summary of 1985 Technical Spec.ification Related Licensee Event Report Data Base," EGG-REQ-7292, Car,1 J. Lovell and S. Keith Penny, EG&G-Idaho, Incorporated, Idaho Falls, Idaho, July 1986.
6.
" Summary of 1985 and 1986 Technical Specification Related Licensee Event Report Data Bases," EGG-NTA-7846, Carl J. Lovell and S. Keith penny, EG&G-Idaho, incorporated, Jdaho falls, Idaho, October 1987.
7.
" Licensee Event Repcrt System," NUREG-1022, St.rplement No.1, U.S.
Nuclear Regulatory Commission, Washingtcn, D. C., February 1984 8.
" Operating Experience feedback Report - New Plantsi" NUREG-12 5, Volume 1, R. L. Dennig ano P, D. O'Reilly, Office for Analysis and Evaluation of Operational Data, U.S. Nuclear Rc-gulatory Commissioc, Washington, D.C., July 1987.
9.
"RWCU System Automatic Isolation and Safety Significance," Engineering Evaluation Report, AE00/E705, W. Neill Themasson, Office for Analysis
.and Evaluation of Operati6nal Data, U.S. Pegulatory Commission,
{
Washington, D.C., March 1987.
44 L
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.v i
l APPENDIX D GENERIC LETTER 86-10 (WITHOUT ENCLOSURES) l l
i i
D-1
v
[,.a no UNITED STATES 8
NUCLEAR REGULATORY COMMISSION c
7,;
e WASHING TON, D. C. 205%
%,a....
April 24, 1936 J
TO ALL POWER REACTOR LICENSEES AND APPLICANTS FOR POWER REACTOR LICENSES Gentlemen:
SUBJECT:
IMPLEMENTATION OF FIRE PROTECTION REQUIREMENTS (GENERICLETTER86-10)
In the Spring of 1984, the Commission held a series of Regional Workshops on the implementation of NRC fire protection requirements at nuclear power plants. At those workshops, a package of recently developed NRC quidance was distributed to each attendee which included NRC staff responses to industry questions and a document titled " Interpretations of Appendix R."
The cover memo for the package explained that it was a draft package which would be issued in final fonn via Generic letter following the wnrkshops.
The guidance approved by the. Commission is appended to this letter, and is in the same format as the draf t package, i.e., " Interpretations of Appendix R" and responses have been modified from the draft package, and a number of 1
industry questions raised at or subsequent to the workshops have been added and answered. This package represents recent staff assessment of these questions and provides guidance as to acceptable methods of satisfying Commission regulatory requirements. Other methods proposed by licensees for complying with Comission regulations may also be satisfactory and will be considered on their own merits. To the extent-that this guidance may be.
inconsistent with prior guidance (including Generic letter 83-33), it is intended that the current letter takes precedence.
If you have any questions, you should contact the NRC Pro.iect Manager for your facility.
In the lettered sections below, some additional topics are covered which also bear on the interpretation and implementation of NRC fire protection requirements. The topics are: (Al schedular exemptions, (B) revised inspection program, (C) documentation required to demonstrate compliance, (D) quality assurance requirements applicable to fire protection systems, (E) notification of the NRC when deficiencies are discovered, and (F) addition of fire protection program into FSAR.
A.
Schedular Exemptions The Appendix R implementation schedule was established by the Comission in i
10 CFR 50.48(c), promulgated together with Appendix R in November of 1980 Allowing time to evaluate the need for alternative or dedicated shutdown systems, which require prior NRC approval before installation, and tine for design of and NRC review of such systems, the Comission envisioned that
)
implementation of Appendix R would be complete-in 4 to 5 years, or approxi-mately by the end of 1985. Many schedule extensions were granted by the l
o
_ staff under the " tolling provision" 50.48(c)(6), and under 10 CFR 50.12, the longest of which now extends into 1987.
Some licensees have proceeded expeditiously to implement Appendix R and are now finished or nearly finished with that effort. Others have engaged in lengthy negotiations with the staff while continuing to file requests for schedule extensions, and thereby have barely begun Appendix R modifications needed to comply with Section III.G and and III.L. Schedule extension requests have been received seeking implementa-tion dates of 1990 or beyond.
As the 50.48(c) schedule was intended to be a one-time schedule commencina in the 1980-1982 time frame and ending in the 1985 time frame, extensions well beyond this schedule (particularly where ma,ior modifications remain to be completed) undermine the purpose of the schedule, which was to achieve ex-peditious compliance with NRC fire protection requirements.
For that reasnn, additional schedular exemptions may be requested under 10 CFR Sn.12, but such requests will be granted sparingly based on the following criteria:
1.
The utility has, since the promulgation of Appendix R in 1980, l
proceeded expeditiously to meet the Corsnission's requirements.
2.
The delay is caused by circumstances beyond the utility's control.
3.
The proposed schedule for completion represents a best effort under the circumstances.
1 l
4 Adequate interim compensatory measures will be taken until com-l l
pliance is achieved.
~
The NRC is currently reviewing all dockets of plants covered by the 50.48 schedule to determine schedule deadlines. When this review is completed, each licensee will be informed of the deadlines.
B.
Revised Inspection Program In 1982, the NRC developed an inspection program to verify compliance with the requirements of 10CFR50, Appendix R.
This program was primarily oriented towards reviewing safe shutdown features of those pre-1979 licensees that had completed Appendix R modifications and selected NT0L plants.
From 1982 to the present, a number of Appendix R compliance inspections have been performed.
l In many of the initial inspections it was found that licensees had made significant errors in implementing a number of Appendix R requirements.
The NRC will continue to conduct inspection of fire protection features.
In the case of completed modifications, the inspection team will review com-pliance with applicable requirements.
In the case of incomplete modification, the inspection team will review licensee approach to compliance, plans and schedules for completino such modifications.
The NRC will attempt to review implementation of fire protection features on a schedule that will minimize the chances of licensees implementing features in a manner that does not meet with staff approval. Additionally, requests for this review and/or I
inspection by licensees will be granted within NRC resource constraints.
D-3
v 1 !
C.
Documentation Required to Demonstrate Compliance l
The " Interpretations" document attached to this letter states that, where the licensee chooses not to seek prior NRC review and approval of, for example, a fire area boundary, an evaluation must be perfonned by a fire I
protection engineer (assisted by others as needed) and retained for future l
NRC audit. Evaluations of this type must be written and organized to facil-itate review by a person not involved in the evaluation. Guidelines for what such an evaluation should contain may be found in:
(1) Section B of Appendix R and (2) Section C.1.b of Branch Technical Position (RTP) CMEB 9.5-1 Rev. 2 dated July 1981. All calculations supporting the evaluation should be available and all assumptions clearly stated at the outset. The NRC intends to initiate enforcement action where, for a given fire area, compliance with Appendix R is not readily demonstrable and the licensee does not have available a written fire hazard analysis for the area.
The tenn "readily demonstrable" includes situations where compliance is apparent by observation of the potential fire hazard and the existing protective features.
D.
Quality Assurance Requirements Applicable For fire protection systems the licensee should have and maintain a quality assurance program that provides assurance that the fire protection systems will be designed, fabricated, erected, tested, maintained and operated so that they will function as intended.
Fire protection systems are not -
" safety-related" and are therefore not within the scope of Appendix B to 10 CFR Part 50, unless the licensee has conunitted to include these systems under the Appendix B program for the plant.
NRC guidance for an acceptable
]
quality assurance pronram for fire protection systems, given in Section C.4 of Branch Technical Position CMEB 9.5-1 Rev. 2 dated July 1981, has generally been used in the review and acceptance of approved fire protection programs for plants licensed after January 1,1979.
For plants licensed prior to January 1,1979, similar guidance was referenced in footnotes 3 and 4 to l
10 CFR 50.48. They are contained in BTP APCSB 9.5-1. and Appendix A thereto l
and in " Nuclear Plant Fire Protection Functional Responsibilities, Adminis-trative Control and Quality Assurance" dated June 14, 1977.
I E.
, Notification of the NRC When Deficiencies are Discovered Licensees are reminded of their obligation to notify the NRC of fire protection deficiencies which meet the criteria of 10 CFR 50.72 or 10 CFR 50.73 as applicable.
i F.
Additinn of Fire Protection Program into FSAR Most licenses contain a section on fire protection.
License conditions for plants licensed prior to January 1,1979, contain a condition requirino imple-mentation of modifications committed to by the licensee as a result of the BTP review. These license conditions were added by amendments issued between 1977 and February 17, 1981, the effec.tive date of 10 CFR 50.48 and Appendix R.
D-4
i 4-l l
Two points should be noted in regard to these conditions:
(1) they did not explicitly cover required fire protection features where modifications to I
the existing plant configuration or procedures were not required, and (2) l some of the provisions in these conditions may have been supersedad by i
Sections III.G, J, 0, and L of Appendix R.
License conditions for plants licensed after January 1,1979 vary widely in i
scope and content. Some only list open items that must be resolved by a l
specified date or event, such as exceeding five percent power or the first
)
refueling outage. Some reference a comitment to meet Appendix R; some I
reference the FSAR and/or the NRC staff's SER. These variations have created problems for licensees and for NRC inspectors in identifying the operative and enforceable fire protection requirements at each facility.
These license conditions also create difficulties because they do not specify j
when a licensee may make changes to the approved program without requesting a j
license amendment.
If the fire protection program comitted to by the licensee is required by a specific license condition or is not part of the FSAR for the l
facility, the provisions of 10 CFR 50.59 may not be applied to make changes l
without prior NRC approval.
Thus licensees may be required to submit amendment I
requests even for relatively minor changes to the fire protection program.
l The aforementioned problems, in general, exist because of the many submittals that constitute the fire protection program for each plant. The Commission believes that the best way to resolve these problems is to incorporate the fire protection program and major comitments, including the fire hazards analysis, by reference into the Final Safety Analysis Report (FSAR) for the facility. In this manner, the fire protection program, including the i
systems, the administrative and technical controls, the organization, and l
other plant features associated with fire protection would be on a consistent status with other plant features described in the FSAR. Also, the provisions of 10 CFR 50.59 would then apply directly for changes the licensee desires to make in the fire protection program that would not adversely affect the ability to achieve and maintain safe shutdown.
In this context, the determina-tion of the involvement of an unreviewed safety question defined in 150.59(a)(2) would be made based on the " accident.... previously evaluated" being the postulated fire in the fire hazards analysis for the fire area affected by the change. The Comission also believes that a standard license condition, requiring licensees to comply with the provisions of the fire protection program as described in the FSAR, should be used to ensure uniform enforcement of fire protection requirements.
l Therefore, each licensee should include, in the FSAR update required by 10 CFR 50.71(e) that will fall due more than 6 months after the date of this letter, the incorporation of the fire protection program that has been approved by the NRC, including the fire hazards analysis and major comitments that fonn i
the basis for the fire protection program.
This incorporation may be by reference to specific previous submittals and the NRC approvals where appropriate. Upon completion of this effort, including the certification required by 10 CFR 50.71(e)(2), the licensee may apply for an amendment l
D-5
___-__-_-_a
v to the operating license which amends any current license conditions I
regarding fire protection and substitutes the following standard condition:
Fire Protection (Name of Licensee) shall implement and maintain in effect all provisions j
of the approved fire protection program as described in the Final Safety Analysis Report for the facility (or as described in submittals i
dated -------------) and as approved i n the SER dated ------------(and l
Supplements dated ------------I sub.iect to the following provision:
1 The licensee may make changes to the approved fire protection program without prior 6ppruLi of the Comistion only if thou changes i
would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
The licensee may alter specific features of the approved program provided (a) such changes do not otherwise involve a change in a license condition 1
or technical specification or result in an unreviewed safety question i
(see 10 CFR 50.59), and (b) such changes do not result in failure to complete the fire protection program as approved by the Comission. As i
with other changes implemented under 10 CFR 50.59, the licensee shell l
i maintain, in auditable form, a current record of all such changes, i
including an analysis of the effects of the change on the fire protection i
program, and shall make such records available to NRC inspectors upon l
request. All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e).
Temporary changes to specific fire protection features which may be neces-sary to accomplish maintenance or modifications are acceptable provided interim compensatory measures are implemented.
At the same time the licensee may request an amendment to delete the technical specifications that will now be unnecessary.
Inclusion of the fire protection program in the FSAR will be a prerequisite for licensing for all now under review.
The standard license condition will l
be included in new licenses.
Sincerely, h
arrell ise hut, puty' Director Office of clear Reactor Regulation
Enclosures:
1.
Interpretations'of Appendix R 2.
Appendix R Questions and Answers 3.
Fire Protection License Condition 1
d D-6
V APPENDIX E GENERIC LETTER 87-09 (WITHOUTENCLOSURES)
E-1
v
![r uey 'o.,
UNITED STATES NUCLEAR REGULATORY COMMISSION e
i I
WAssiNa ton. o. c. 20sss o
a
- /
June 4, 1987 TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTS Gentlemen:
SUBJECT:
SECTIONS 3.0 AND 4.0 0F THE STANDARD TECHNICAL SPECIFICATIONS (STS)
ON THE APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS (Generic Letter 87-09)
'i As a part of recent initiatives to improve Technical Specifications (TS), the NRC, in cooperation with the Atomic Industrial Forum (AIF), has developed a program for TS improvements. One of the elements of this program is the l
implementation of short-tenn improvements to resolve imediate concerns that have been identified in investigations of TS problems by both NRC and AIF.
The guidance provided in this generic letter addresses three specific problems that have been encountered with the general requirements on the applicability of Limiting conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the STS.
l There are five enclosures to this Generic letter. applies to both PWR and BWR STS and provides a complete discussion of the three problems l
and the staff's position on acceptable modifications of the TS to resolve them. These modifications should result in improved TS for all plants and are consistent with the recommendations of NUREG-1024, " Technical Specifications --
Enhancing the Safety Impact" and the Coninission Policy Statement on Technical-Specification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 of the PWR and BWR STS, respectively, which incorporate the modifications being made by this Generic Letter.
Enclosures 3 and 5: (a) provide the staff's update of the bases for the PWR and BWR STS, respectively; (b) reflect the modifications of Sections 3.0 and 4.0 of the STS; and (c) include improved bases for the unchanged requirements in these sections.
The staff concludes that these modifications will result in improved TS for all plarits. Licensees and applicants are encourageu to propose changes to their 15 that are consistent with the guidance provided in the enclosures; however, these changes are voluntary for all licensees and current OL applicants.
I The staff would like to point out three important points connected with the l
present TS effort. First, it is aware that the TS can be clarified, simplified, and streamlined both as a whole and with respect to the specifications that are the subject of this Generic Letter. Nonetheless, in keeping with its short-tenn and purposefully narrow focus, it decided to keep these proposed modifications: (a) focused on the three problems; (b) relatively simple; and (c) consistent with the phrasing of existing TS. Second, after the resolution of these and other identified TS problems, the staff will notify licensees and appliants of its conclusions and resulting proposals for additional short-tern. TS 1 improvements.
Finally, the staff is not proposing to formally amend the STS at this time.
Instead the changes will be factored into the developent of the new STS anticipated as a part of the implementation of l
the Comission's Policy Statement on Technical Specification Improvements.
P
)
POR ADoc1 05.200 0063 l
E-2 G fn60n00 D dM
y-The following is a surriary of the three problems covered by the enclorures.
The first problem involves unnecessary restrictions on mode changes by Specification 3.0.4 and inconsistent application of exceptions to it. The.
practical solution is to change this specification to define the conditions under which its requirements apply. With respect to unnecessary mode changes.
Specification 3.0.4 unduly restricts facility operation when confomance with
{
Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements. The solution also resolves the problerr of inconsistent application of exceptions to Specification 3.0.4: (a)which delays startup under conditions in which confomance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility; and (b) which delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements.
i The second problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceeded. The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO.
It is overly conservative to assume that systems or corrponents tre inoperable when a surveillance has not been perfomed bet. use the vast majority of surveillance do in fact demonstrate that systems or c.mponents are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the perfomance of a Surveillance Requirement. Because the allowable cutage time limits of some Action Requirements do not provide an appropriate time for perfoming a missed surveillance before Shutdown Requirements apply, the TS should include a time limit that allows a delay of required actions to permit the perfomance of the missed surveillance based on consideration of plant conditions, adequate planning, availability of personnel, the time required to perfom the surveillance, and, of course, the safety significance of the delay in completing the surveillance. The staff has concluded that 2a bours is an acceptable time limit for completing a l
missed surveillance when the allowable outage times of the Action Requirements are less than this limit, or when time is needed to obtain a terrporary waiver of i
l the Surveillance Requirement.
The third problem involves two possible conflicts between Specifications 4.0.3 and 4.0.4
.The first conflict arises because Specification 4.0.4 prohibits.
entry into an operational mode or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. A conflict with this requirement exists when a mode change is required as a consequence of Action Requirements and when the Surveillance Requirements that become applicable have not been perfomed within the specified l
surveillance interval. Specification 4.0.4 sheuld not be used to prevent l
passage through or to operational modes t.s recuired to comply with Action l
Requirements because to do so: (a) would increase the potential for a plant F?
i j upset; and (b) would challenge safety systems. Also, certain surveillance' should be allowed to be perfonned during a shutdown to comply with Action Requirements. Along with the modification of Specification 4.0.3't'o permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of Action Requirements, Specification 4.0.4 has been clarified to allow passage through or to operational modes as required to comply with Action Requirements.
l A second conflict could arise because, when Surveillance Requirement can only i
be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of Specification 4.0.4 is allowed. However, upon entry into this mode or condition, the requirements of Specification 4.0.3 may not be met because the Survedlance Requirements may not have been perfomed within the allowed surveillance interval. Therefore, to avoid any conflict between Specifications 4.0.3 ind 4.0.4, the staff wants to make clear: (a) that it is not the intent of 3pe.:ification 4.0.3 that the Action Requirements preclude the perfonnance of survei? lances allowed under any exception to Specification 4.0.4; and (b) that the de!ay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Specification 4.0.3 for the applicability of Action Requirencnts now provides an appropriate time limit for the completion of thc;e Surveillance Requirements that become applicable as a consequence of i
allowa see of any exception to Specification 4.0.4 l
If you have any questions on this matter, please contact your project staager.
Sincerely, l
Frank J.biragl a, Associate Director for Projects l
i Office of Nuclear Reactor Regulation l
l
Enclosures:
As stated E-4 L__-___
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75Y/E BIBLIOGRAPHIC DATA SHEET Vol. 4 itG eunavCuo~io~, t atvi.it
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3.1stLE ANo lutflTLG J L( Avt SLANE Operating Experience feedback Report - Technical Specifications
' o^" a"oa' cou'6"so
' Commercial Power Reactors l
,tA.
woo.
October 1988
- oAn a"*"ssuto P.D. O'Reilly, G.L. Plumlee, III*
MoNTM l
vtan March i
1989
- 7. P(RFompiNG onGAmil At aoh seAWE A8sD MAstia G Acont 33 tswiesi, te camp a PaoJECTiT A5KlWong geest huwata Division of Safety Programs
- Presently Not Applicable Office for Analysis and employed with
,,,s o. c Am,,vo tr.
Evaluation of Operational Data Impell Corp.
U.S.
Nuclear Regulatory Commission Fort Worth,TX Washington, DC 20555 76116 Not Applicable 10 $PoN$oMING oRG ANtJ Af ton N Auf A40 Wasting Aooma ss iswiesse le c. des tie Yvet of Atront Division of Safety Programs Office for Analysis and Evaluation of Operational Data Technical U.S. Nuclear Regulatory Commission a n aloo Covt at o <<~, - a->
Washington, DC 20555 01/01/84 - 12/31/87 a
12 SUPfLIMENT ART asoita i
i3 AssTRACT (100 weede er aesst This report documents the results of a trends and patterns analysis of operational experience with Techr.ical Specifications at commercial nuclear power reactors in the U.S., primarily during the period 1984-86. Limited use was made of preliminary results frcin 1987 data to provide additional insights regarding trends in Technical Specification violation rates. Major objectives-of this report prepared by the NRC's Office for Analysis and Evaluation of Operational Data are to:
(1) identify 3
and catalog technical specification-related licensee event reports (LERs),
i (2) categorize and evaluate the events reported in these LERs,, (3) identify any 1
issues arising from the evaluation which appear to have generic safety significance, or which relate to the on-going Technical Specification Improvement Program, and (4) trend the results of the analysis of the data obtained in (1) through (3).
le poCWuthf AN A4'liS e al vmonosiotscm *1 oms it Ava:LAsitiiv Technical Specifications, Violations, licensee Event Reports (LERs),
limiting Conditions for Operation (LCOs), Surveillance Requirements, unlimited Shutdowns
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..w.t.. t airon t ~ot o n a*5 unclassified iFag espects unclassified IPkVM$tmotPAGt$
is PRICE
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