NRC Generic Letter 1989-04
UNITED STATES bAc lc NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C.20555 April 3, 1989 TO: ALL HOLDERS OF LIGHT WATER REACTOR OPERATING LICENSES AND
CONSTRUCTION PERMITS
SUBJECT: GUIDANCE ON DEVELOPING ACCEPTABLE INSERVICE TESTING PROGRAMS
(GENERIC LETTER NO. 8904)
BACKGROUND
Paragraph 50.55a(g) of 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," requires that certain ASME Code Class 1, 2, and 3 pumps and valves be designed to enable inservice testing and that testing be performed to assess operational readiness in accordance with the Section XI
requirements ot the ASME Boiler and Pressure Vessel Code. The inservice testing of ASME Code Class 1, 2, and 3 pumps and valves should be viewed as one part of a broad effort to ensure operational readiness of equipment rather than viewed in the narrow sense as compliance with 10 CFR 50.55a(g). The intent of the testing is to detect degradation affecting operation and assess whether adequate margins are maintained. While this letter has been written to provide guidance relative to meeting the requirements of 10 CFR 50.55a(g), it is only one part of other ongoing industry and regulatory activities. Recent efforts have been undertaken by the nuclear industry and NRC sponsored research to provide information and techniques for enhanced assurance of equipment operability. NRC
staff concerns regarding equipment operability led to the issuance of Bulletin 85-03, dated Novemiber 15, 1985, and Bulletin 85-03, Supplement 1, dated April 27, i988. An expansion of the requirements of this bulletin in the form of a generic letter is being considered by NRC. In addition, NRC is considering rulemakino on IST to develop requirements to address the inadequacies in the current scope and methods of testing per 10 CFR 50.55a(g).
Light Water Reactor (LIR) licensees have submitted to the NRC inservice testing (IST) programs for pumps and valves pursuant to 10 CFR 50.55a(g). The editions and addenda applicable to IST program intervals are outhlned in 10 CFR 50.55a(g)(4).
If the licensee believes thdt conformance with certain code requirements is impractical, that conformance to the Code would cause unreasonable hardship without a compensating increase in safety or that a proposed alternative provides an acceptable level of quality and safety, 10 CFR 50.55a allows the licensee to request relief from the Code by notifying the Commission and submitting infor- nation to support this determination. Following the evaluation of this infor- mation, the Conmiassion may grant relief and may impose alternative requirements.
All IST programs contain requests for relief from various Coae requirements. In addition, the surveillance requirements of technical specification (T.S.) 4.0.5 for most plants state that this testing of pumps and valves must be performed in accordance s:ith ASME Section XI except where specific written relief has been granted by the Coruviissiori. Because of the general nature of the :5T
sections of the ASNE Code which does not consider plant specific designs and the resulting cifliculty in complying with all the ASME Code requirements, utilities frequently revise their programs as more experience with IST is acquirca. Progrcrms at most plants are revised several times during the
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I 1
-3- Based on the staff's experience the positions contained in Attachment 1 can be implemented at all plants. However, should licensees be unable to comply with one of these positions because of design considerations or personnel hazard, as opposed to inconvenience, any alternative testing must fulfill the basic test objective of detecting component degradation. Alternative testing should be individually evaluated by the licensee and the licensee's plant safety review committee (or equivalent). When evaluating testing, licensees should address the following:
1. Maintenance history of the individual (specific) component,
2. Maintenance history of related components in a similar environment,
3. Component vendor records of degradation at other facilities, and
4. Records on degradation of the same or like component from other utilities.
Licensees may utilizE in-plant recoros, the NPRDS and other referenceable sources to compile data to address the dbove four areas. A lack of service experience or test results by itself is not sufficient to justify the alternative test.
The alternative test is not considered acceptable unless the above data is sufficient to justify its adequacy for detecting degradation and ensuring continued operability. Justification for the alternative test should be documented and retained in the IST program.
For plants not listeo on either Table 1 or 2, currently submitted IST program relief requests are hereby approved for licensees who have not received an SER
provided that they (1) review their most recently submitted IST programs and implementation procedures against the positions delineated in Attachment 1 and (2) within 6 months of the date of this letter confirm in writing their conformance with the statec positions. In cases where conformance with the stated positions woula result in equipment modifications, the licensee should provide in his confirmation letter a schedule fcr completing the required modifications. All modifications must be completed within 18 months of the date of the confirmatory letter or the first scheduled refueling outage following the confirmation letter, whichever occurs later. Changes to the IST
programs as a result of this generic letter, should be submitted to the NRC
along with the confirmation letter. Approval is granted provided the programs are consistent with the positions taken in Attachment I or, for positions that necessitate a plant modification, will be consistent with Attachment I on the schedule noted above. Where a deviation needs to be taken from a specific position in Attachment 1, the approval is granted provided the adequacy of the proposed alternative testing for detecting degradation is justified as discussed above.
C. Programs With Completed NRC Reviews For the plants listed ir Table 2 the staff has completed its review of the IST
program arid issued an SEIR. These plants need not respond with the confirimation letter discussed above. The status of the relief requests approved in the SER is not affected by this letter. Tile relief requests that were approved in the SER may continue to be implemented, and those that were denied should be
I I
-5- the operational readiness of pumps and valves have been or will be the subject of regulatory actions such as generic letters and rulemaking. Provided the provisions of this letter are followed, the staff has determined that relief is granted to follow the alternative testing delineated In positions 1, 2, 6,
7, 9, and 10, pursuant to 10 CFR 50.55a(g)(6)(i), is authorized by law, ano will not endanger life or property or the common defense and security anid is otherwise in the public interest. In making this determination the staff hds considered the imprdcticelity of performing the required testing considering the burden if the requirements were imposec.
This request is covered by Office of Management and Budget Clearance Number
3150-0011 which expires December 31, 1989. The estimated average burden hours is 700 man-hours per owner response, including assessment of the hew recom- mendations, sedrching data sources, gathering and analyzing the data, and preparing the required letters. These estimated average burden hours pertain wnly to these identified responst-related matters anG do not include the tine for actual implemnentdtiorn of the requested dctions. Comments on the accuracy of this estlrldte and suggestions to reduce the burden may be directed to the Otfice of Management and Budget, Ruom 3208, New Executive Office Building, Washingtcn, D.C. 20503, dnd the U.S. Nuclear Reguldtory Commission, Records and Reports Management Branch, Office of Administration and Resources Manage- wleit, Washington, D.C. 20555.
Sincerely, evenR. ,A .g Associate Director o Projects Office of Nuclear Reactor Reguldtion Enclosures:
Tdbles I and 2 w/Attachmetit 1
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TABLE 1 PLANTS WITH SERs TO BE ISSUED IN NEAR FUTURE
Beaver Valley 1 Peach Bottom 2&3 Braidwood 1i& Rancho Seco Brunswick River Bend Calvert Cliffs 1&2 Robinson 2 Clinton Seabrook 1 Comanche Peak SONGS 2&3 D.C. Cook 1&2 St. Lucie 2 Farley 1&2 Summer Ft. Calhoun Surry 1&2 Hatch 1&2 Vogtle 1 Hope Creek Waterford 3 Kewaunee Wolf Creek Limerick 1&2 WNP 2 McGuire 1&2 Zion 12 Millstone 2 Nine Mile Point 1 hine Mile Point 2
4 ATTACHMENT 1 POTENTIAL GENERIC DEFICIENCIES RELATED TO
IST PROGRAMS AND PROCEDURE
I. Full Flow Testing of Check Valves.
Section XI of the ASME Code requires check valves to be exercised positions in which they perform their safety functions. A to the fuil-stroke to the open position may be verified by passing check valve's required accident condition flow through the valve. This the maximum is considered by the staff as an acceptable full-stroke. Any flow rate less than this will be considered a partial-stroke exercise. A valid full-stroke by flow requires thdt the flow through the valve be known. exercise the total flow through multiple parallel lines does not provide Knowledge of only of flow rates through the individual valves and is not a valid verification exercise. full-stroke Full flow testing of a check valve as described above may perform for certain valves. It may be possible to qualify be impractical to to confirm that the valve is exercised to the position requiredother techniques its safety function. To substantiate the acceptability of to perform technique for fleeting the ASfIE Code requirements, licensees any alternative minimum adaress and document the following items in must as a the IST program:
1. The imrpracticality of performing a full flow test,
2. A description of the alternative technique used and a sumnary of the procedures being followed, A description of the method and results of the program the alternative technique for meeting the ASME Code, to qualify
4. A description of the instrumentation used and the maintenance calibration of the instrumentation, and
5. A description of the basis used to verify that the baseline has been generated when the valve is known to be in good working data oroer, such as recent inspection and maintenance of the valve internals, and
6. A description of the basis for the acceptance criteria for alternative testing and a description of corrective actions the be taken if the acceptance criteria are not fiet. to An acceptable alternative to this full-stroke exercising requirement is stated in positior 2 below.
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A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage, until the entire group has been tested. If the disassembled valve is not capable of being full-stroke exercised or there is binding or failure of valve internals, the remaining valves in that group must also be disassembled, inspected, and manually full-stroke exercised during the same outage. Once this is completed, the sequence of diassembly must be repeated unless extension of the interval can be justified.
Extending the valve sample disassembly and inspection interval from disas- sembly of one valve in the group every refueling outage or expanding the group size would increase the time between testing of any particular valve in the group. With four valves in a group and an 18-month reactor cycle, each valve would be disassembled and inspected every six years. If the fuel cycle is increased to 24 months, each valve in a four-valve sample group would be disassembled and inspected only once every 8 years.
Extension of the valve disassembly/inspection interval from that allowed by the Code (quarterly or cold shutdown frequency) to longer than once every 6 years is a substantial change which may not be justified by the valve failure rate datd for all valve groupings. When disassembly/
inspection data for a valve group show a greater than 25% failure rate, the licensee should determine whether the group size should be decreased or whether more valves from the group should be disassembled during every refueling outage.
Extension of the valve disassembly/inspection interval to one valve every other refueling outage or expansion of the group size above four valves should only be considered in cases of extreme hardship where the extension is supported by actual in-plant data from previous testing. In order to support extension of the valve disassembly/inspection intervals to longer than once every 6 years, licensees should develop the following information:
a. Disassemble and inspect each valve in the valve grouping and document in detaii the condition of each valve and the valve's capability to be full-stroked.
b. A review of industry experience, for example, as documented in NPRDS,
regarding the same type of valve used in similar service.
c. A review of the installation of each valve addressing the "EPRI Appli- cations Guidelines for Check Valves in Nuclear Power Plants" for problematic locations.
3. Lack Flow Testing of Check Valves.
Section XI requires that Category C check valves (valves that are self actuated in response to a system characteristic) performing a safety func- tion in the closed position to prevent reversed flow be tested in a manner that proves that the disk travels to the seat promptly on cessation or reversal of flow. In addition, for category A/C check valves (valves that
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On April 20, 1981, the NRC issued an Order to 32 PWRs and 2 BWRs which required that these licensees conduct leak rate testing of their PIYs, based on plant-specific IIRC supplied lists of PIVs, and required licensees to moaify their TS accordingly. These orders are known as the "Event V Orders" and the valves listed therein are the 'Event Vu PIVs. The Event V PIVs are a subset of PIVs.
Based upon the results of recent inspections, it has been determined that the following implementation problem still exists with respect to testing of PIVs. The staff has determined that in some cases the procedures are inadequate to assure that these valves are individually leak tested and evaluated against the leakage limits specified in the TS; in other cases, the procedures were adequate but were not being followed. Specifically, some check valves were tested in series as opposed to individually and some check valves were not tested when required.
Licensees shoula review their testing procedures to ensure the Event V
PIYs are individually leak rate tested.
5. Limiting Values of Full-Stroke Times for Power Operated Valves The Code intent with respect to measuring the full-stroke times of power operated valves is to verify operability and to detect valve degradation.
Measurement of full stroke times for air operating valves fulfills this intent. However, reviews of operating experience have identified several problems with motor operated valves (MOVs) including limitations with stroke time as a measure of operational readiness of the MOV. As a result, the industry has made extensive efforts to improve the knowledge and under- standing of operational characteristics of motor operated valves. This effort has been conducted by industry groups (NUMARC, INPO, NMAC, EPRI),
iniiavidual licensees, equipment vendors, and national standards groups.
We believe the information arid knowledge developed by these groups should be reviewed and utilized. Some of the information publicly available includes an INPO white paper titled, 'Motor-Operated Valve Performance Update," issued October 4, 1988. This document identifies MOV problem areas and provides the key elements for a comprehensive MOY program.
Another document is the "Technical Repair Guidelines for the Limitorque Model SMB-OGG Valve Actuator," issued by the Nuclear Maintenance Applica- tion Center (HMAC) in January 1989. This guide addresses several areas such as setting torque and limit switches, preventive maintenance, actuator failure modes, failure analysis to determine root cause and corrective action, and preoperational and post-maintenance testing.
NRC staff concerns regarding MOV operability led to the issuance of Bulletin
85-03 and Bulletin 85-03, Supplement 1. Expansion of this bulletin in the forrm of a generic letter is being considered by the NRC.
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-7- Most plants have many power operated valves that are capable of stroking in 2 seconds or less such as small solenoid operated valves. Licensees encounter difficulty in applying the Code 50' increase of stroke time corrective action requirements for these valves. The purpose of this requirement is to detect and evaluate degradation of d valve. For valves with stroke times in this range, much of the difference in stroke times from test to test comes from inconsistencies in the operator or timing device used to gather the data.
These differences are compounded by rounding the results as allowed by the Code. Thus, the results may not be representative of actual valve degradation.
The following discussion illustrates the problem that may exist when complying with the Code requirements for mdny of these rapid-acting valves:
A valve may have a stroke time of 1.49 seconds during one test and a stroke time during the following test of 1.51 seconds. If stroke times are rounded to the nearest second as allowed by the Code, the difference between these tests would exceed the 50% criteria and would require an increased frequency of testing until corrective action is taken. This can result from a stroke time difference of 0.02 seconds, which is usually not indicative of significant valve degradation.
Power operated valves with normal stroke times of 2 seconds or less are referred to by the staff as "rapid-acting valves." Relief may be granted from the requirements of Section Xl, Paragraph IWV-3417(a) for these valves provided the licensee assigns a maximum limiting value of full-stroke time of 2 seconds to these valves and, upon exceeding this limit, declares the valve inoperable and takes corrective action in accordance with IWV-3417(b).
An acceptable alternative to the Code stroke timing requirements is the above stated rapid-acting valve position. Since this represents a devi- ation from the Code requirements, it should be specifically documented in the 1ST program.
7. Testing Individual Control Rod Scram Valves in Boiling Water Reactors (BWRs)
B11Rs are equipped with bottom-entry hydraulically driven control rod drive mechanisms with high-pressure water providing the hydraulic power. Each control rod is operated by a hydraulic control unit (HCU), which consists of valves and an accumulator. The HCU is supplied charging and cooling water from the control rod drive pumps, and the control rod operating cylinder exhausts to the scram discharge volume. Various valves in the control rod orive system perform an active function in scramming the control rods to rapidly shut down the reactor.
The NRC has determines that those ASME Code Class valves that must change position to provide the scram function should be included in the IST
program and be tested in accordance with the requirements of Section XI
except where relief has been granted in a previously issued Safety Evaluation Report or as discussed below.
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oefined in the plant TS can be an acceptable alternate method of detecting degradation of these valves. Also, trending the stroke times of these valves may be impractical and unnecessary since they are indirectly stroke timed and no meaningful correlation between the scram time and valve stroke time may be obtained, and furthermore, conservative limits are placed on the control rod scran insertion times. If the above test is used to verify the operability of scram inlet and outlet valves, it should be specifically documented in the 1ST program.
8. Starting Point for Time Period in TS ACTION Statments ASME Section XI, IWP-3220, states "All test data shall be analyzed within
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test". IWP-3230(c) states, in part, "If the deviations fall within the 'Required Action Range' of Table IWP-3100-2, the pump shall be declared inoperative,...."
In many cases pumps or valves covered by ASME,Section XI, Subsections IWP
and TWV, are also in systems covered by TS and, if declared inoperable, woula result in the plant entering an ACTION state-ment. These ACTION
statements generally have a time period after which, if the equipment-is still inoperable, the plant is required to undergo some specific action such as commence plant shutdown.
The potential exists for a conflict between the aforementioned data analysis interval versus the TS ACTION statement time period.Section XI, IWP-6000
requires the reference values, limits, and acceptance criteria to be included in the test plans or records of tests. With this information available, the shift individual(s) responsible for conducting the test (i.e., shift supervisor, reactor operator) should be able to make a timely determination as to whether or not the data meets the requirements.
When the data is determined to be within the Required Action Range of Table IWP-3100-2 the pump is inoperable and the TS ACTION statement time starts. The provisions in IWP-3230(d) to recali-brate the instruments involved and rerun the test to show the pump is still capable of fulfilling
- ts function are an alternative to replacement or repair, not arl additional action that can be taken before declaring the pump inoperable
"he above position, which has been stated in terms of pump testing, is equally valid for valve testing.
In summary, it is the staff's position that as soon as the data is recog- nized as being within the Required Action Range for pumps or exceeding the limiting value of full-stroke tine for vlaves, the associated component must be declared inoperable and the TS ACTION time must be started.
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1C. Containment Isolation Valve Testing All containment isolation valves (CIYs) that are included in the Appendix J,
Category A or A/C valves.
program should be included in the IST program as and requirements The staff has determined that the leak test procedures50, Appendix J are for containment isolation valves specified in 10 CFR
However, the equivalent to the requirements of IUV-3421 through 3425. and Corrective licensee must comply with the Analysis of Leakage Rates Action requirements of Paragraph IWV-3426 and 3427(a).
test frequencies
1WV-3427(b) specifies additional requirements on increased or replacement over the for valve sizes of six inches and larger and repairs utilities and staff requirements of IWV-3427(a). Based on input from many of IWV-3427(b) does review of testing data at some plants, the usefulness Since this not justify the burden of complying with this requirement. it should be position represents a deviation from the Code requirements, documented in the IST program.
1i. IST Program Scope The 10 CFR 50.55d requires that inservice testing be performed on certain XI Subsections ASME Code Class 1, 2, and 3 pumps and valves. Sectionvalves to be tested IWP-1100 and IWV-1100 defines the scope of pumps and The plant's FSAR (or in terms of plant shutdowns and accident Mitigation. equipment to meet these equivalent) provides definitions of the necessaryprogram reviews and functions. The staff has noted during past IST
include the necessary equipment inspections that licensees do not always IST programs to in their IST programs. Licensees should review their that are frequently erroneously omitted ensure adequate scope. Examples from IST prcgrams are:
a. bWR scram system valves, b. control room chilled water system pumps and valves, c. accumulator motor operated isolation valves, or accumulator vent valves, d. auxiliary pressurizer spray system valves, e. boric acid transfer pumps, f. valves in emergency boration flow path,
9. control valves that have a required fail-safe position, h. valves in mini-flow lines.
pumps and valves do not It should be recognized that the above examples of for all plants.
meet the IWP/and IWV scope statement requirements B, Criterion XI, is The intent of 10 CFR 50 Appendix A, GDC-1, and Appendix necessary for safe operation that all components, such as pumps and valves, they will perform satisfactorily in are to be testtd to demonstrate that the testing requirements service. Therefore, %hile 10 CFR 50.55a delineatesthe testing of pumps and for ASME Code Class 1, 2, and 3 pumps and valves,
valves is not to be limited to only those covered by
LT RRt LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of lteean e teueAd oa Letter No. WUDJCct 60,w,,- ------ --
89-03 OPERATOR LICENSING NATIONAL 3/24/89 ALL POWER REACTOR
EXAMINATION SCHEDULE LICENSEES AND
APPLICANTS FOR AN
OPERATING LICENSE
89-02 ACTIONS TO IMPROVE THE 3/21/89 ALL HOLDERS OF
DETECTION OF COUNTERFEIT OPERATING LICENSES
AND FRAUDULENTLY MARKETED AND CONSTRUCTION
PRODUCTS PERMITS FOR NUCLEAR
POWER REACTORS
89-01 IMPLEMENTATION OF 1/31/89 ALL LICENSEES HOLDING
OPERATING LICENSES
PROGRAMMATIC CONTROLS
FOR RADIOLOGICAL EFFLUENT AND CONSTRUCTION
TECHNICAL SPECIFICATIONS PERMITS FOR NUCLEAR
IN THE ADMINISTRATIVE POWER REACTOR FACILITIES.
CONTROLS SECTION OF THE
TECHNICAL SPECIFICATIONS
AND THE RELOCATION OF
PROCEDURAL DETAILS OF
RETS TO THE OFFSITE DOSE
CALCULATION MANUAL OR TO
88-20 INDIVIDUAL PLANT 11/23/88 ALL LICENSEES HOLDING
EXAMINATION FOR SEVERE OPERATING LICENSES
ACCIDENT VULNERABILITIES - AND CONSTRUCTION
10 CFR 50.54(f) PERMITS FOR NUCLEAR
POWER REACTOR FACILITIES
88-19 USE OF DEADLY FORCE BY 10/28/88 ALL FUEL CYCLE FACILITY
LICENSEE GUARDS TO PREVENT LICENSEES WHO POSSESS*
THEFT OF SPECIAL NUCLEAR USE, IMPORT, EXPORT,
MATERIAL OR TRANSPORT FORMULA
QUANTITIES OF STRATEGIC
88-18 PLANT RECORD STORAGE ON 10/20/88 ALL LICENSEES OF
OPTICAL DISKS OPERATING REACTORS
AND HOLDERS OF
CONSTRUCTION PERMITS
88-17 LOSS OF DECAY HEAT REMOVAL 10/17/88 ALL HOLDERS OF
10 CFR 50.54(f) OPERATING LICENSES
OR CONSTRUCTION
PERMITS FOR
PRESSURIZED WATER
REACTORS
ENCLOSURE A
GUIDANCE FOR THOSE PLANTS COVERED
BY TABLES 1 AND 2 OF GL 89-04 Table 1 Plants
2. PM issues IST SE to the licensee.
3. No confirmation letter required from the licensee.
4. Relief requests approved by SE are unaffected by GL 89-04 and may continue to be implemented.
5. Relief requests denied in SE should be resolved in accordance with SE.
6. If licensees have modified or plan to modify their IST program beyond that which was the basis for the SE, follow Enclosure C to this memorandum.
Table 2 Plants
1. No confirmation letter required.
2. Relief requests approved by SE are unaffected by GL 89-04 and may continue to be implemented.
3. Relief requests denied in SE should be resolved in accordance with SE.
4. If licensees have modified or plan to modify IST program beyond that which was the basis for the SE, follow Enclosure C to this memorandum.
ENCLOSURE B
GUIDANCE FOR THOSE PLANTS NOT LISTED IN EITHER
TABLE 1 OR TABLE 2 OF GL 89-04
1. GL 89-04 constitutes required approval for the implementation of IST program relief requests provided licensee reviews their IST program and amends it to:
(a) conform with the Code requirements explained in Positions 1, 3, 5, and 11 of Attachment 1 of GL 89-04;
(b) conform with the Technical Specification (TS) requirements explained in Positions 4 and 8 of Attachment 1 of GL 89-04;
(c) conform with applicable Code requirements or staff approved alternatives in Positions 1, 2, 6, 7, and 10 of Attachment 1 of GL 89-04; and'
(d) justify and document, where required, alternative testing as noted in item 2. below. These justifications may be evaluated during inspections.
2. Where a deviation from a Position in Attachment 1 needs to be taken due to design considerations or personnel hazard, alternative testing (a) must fulfill the basic test objective of detecting component degradation;
(b) should be individually evaluated by the licensee and licensee's plant safety review committee addressing:
(i) maintenance history of the specific component;
(ii)maintenance history of related components in a similar environment;
-2- (iii)component vendor records of degradation at other facilities;
and (iv)records of degradation of the same or like components from other utilities.
NOTE: In-plant records, NPRDS, and other referenceable sources may be utilized to compile data to address the above areas. Lack of service experience or test results by itself is insufficient to justify an alternate test. Data must be sufficient to justify the alternative test's adequacy for detecting degradation and ensuring continued operability.
(c) should be documented and retained in the IST program. This may be reviewed during plant inspections.
3. Licensee is to confirm by letter by 10/3/89:
(a) their conformance, as noted above, to the Positions of Attachment 1 to GL 89-04;
(b) a schedule for equipment modifications required by conformance to the Positions of Attachment 1 of GL 89-04; and NOTE: All modifications must be made by the latter of:
(i) first scheduled refueling outage following their confirmatory letter; or (ii)within 18 months following their confirmatory letter.
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-3- (c) that procedures have been reviewed and amended to address deficiencies related to the implementation of Positions in Attachment 1 of GL 89-04.
4. PMs should review the confirmation letter for consistency with Item 3 above.
5. For areas of non-conformance between the confirmation letter and GL, see CASE 3 of Enclosure C.
yj, ENCLOSURE C
GUIDANCE FOR THOSE FACILITIES MODIFYING THEIR IST PROGRAM BEYOND
THE IST PROGRAM SUBMITTAL AS OF 4/3/89 (i.e. PROGRAM UPDATES/REVISIONS)
CASE 1: IST Program Changes for Which Specific Acceptable Alternatives Are Provided in Attachment 1 of GL 89-04 GL constitutes the required approval, and no plant specific TAC
is required.
CASE 2: IST Program Relief Request for Which Specific Acceptable Alternatives Are Not Provided in Attachment 1 of GL 89-04 (i.e., in Positions 1, 2, 6,
7, and 10).
1. 10 CFR 50.55(a)g applies.
2. Plant specific TAC to be issued by the PM.
- CASE 3: IST Program Changes Taking Exception to the GL or Its Attachment.
1. This case would constitute non-conformance to the GL.
2. For areas of exception, the licensee would not have NRC approval to implement the change and would be outside the applicable regulation, 10 CFR 50.55a, if they did.
3. The licensee is liable to enforcement action under T.S. 4.0.5 until NRC review is completed and resolution implemented in the licensee's testing procedures.
- This case is not really covered by the GL