U-601261, Forwards Interpretation Re Inoperability of Sys Providing Support Function,For Comments

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Forwards Interpretation Re Inoperability of Sys Providing Support Function,For Comments
ML20207J496
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/20/1988
From: Holtzscher D
ILLINOIS POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
U-601261, NUDOCS 8809280007
Download: ML20207J496 (17)


Text

i o

U-601261 L46-88(09-20)-LP 1A.120 til/NDIS POWER 00AIPANY CL;NTON PCniq STATION. P.o. Box 678. CLINTON. ILLINOIS 61727 September 20, 1988 10CFR50.56 Docke r, No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Interpretation Regarding Inoperability of 9ystems Providing a Support Function Dear Sirt Questions concerning the definition of OPERABLE - OPERABILITY, as it relates to support systems, have occasionally been raised by the utilities and addressed by the Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation (NRR) .* The definition in the Clinton Power Station Technical Specifications, which Illinois Power Company (IP) believes is the some as what is currently and generally accepted throughout the indus:ry, extends the OPEkABILITY requirements for a system addressed by the Technical Specifications to include those components or systema which provide a support function and which may not be specifically addressed in the Technical Specifications.

As the requirements of a Limiting Condition for Operation (LCO) are extended to include the support system (a) or component (s), additional

onsideration muot be given to how the ACTION requirements under a particular LCO should be applied to the support system (s) or component (s). In rome cases, when a supporc system (s) or cowponent(s) must be declared inoperable, it does not seen appropriate to tLie the ACTION (s) specified in the Technical Specifications for the supported system (s) when the ACTION requirement (s), including the specified out-of-service time (s) s pears to be based on inoperability of the supported equipmens .cself and not necessarily on the inoperebility or degradation of the supporting equipment.

IP has prepared the attached written interpre stion, "Inoperability of Systems Providing a Support Function." This interpretation p eseribes the means for complying with the operability requirements extended eo support systems and for ensuring that the appropriate ACTIONS (including the allowed out-of-setvice times) are taken for support systems when they are declared inoperable. This interpretation addresses five systems that provide a support function for essential systems at Clinton and provides ; specific interpretation for each.

  • Reft (1) NRC Letter from D. G. Eiesenhut to All Power Reactor Licensees dared April 10, 1980; (2) NRC Memorandus f rom D. M. Crutchfield to Distribution, "Technical Specification Operability Requirements," dated [tDU July 8, 1985.

8809280007 880920 g PDR ADOCK 05000461 P PDC

. U-601261 L46-88(09-20)-LP 1A.120  ;

The purpose of this letter is to request the h'RC to review IP's interpretation and provide concurrence or comments. IP would appreciate notification oi NRR's position regarding this interpretation at the earliest possible time since it will impact the planning of maintenance to be performed on support systema and may therefore impact planning currently underway for the firat refueling outage.

Sincerely yours, i

-.7/. / ~ ,

D. L. Holtzscher Acting Manager - Licensing and Safety TBE/kar i Attachment cc: NRC Resident Office NRC Region III, Regional Administrator NRC Clinton Licensing Project Manager ,

Illinois Department of Nuclear Safety L

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. Attcchment to U- 601261 Page 1 of 15

,INOPERABILITY OF SYSTEMS PROVIDING A SUPPORT FUNCTION QUESTION / CONCERN According to the definition of OPERABLE - OPERABILITY in the Technical Specifications (DEFINITION 1.27), "A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s) and when all necessary attendant instrumentation, controls, electric power, coo?.ing or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capabic of performing their related support function (s)."

This definition of OPERABILITY is worded such that it extends tha OPERABILITY requirements for a particular system addressed by the Technical Specifications to include those components or systems which provide a support function and which may not be specifically addressed in the Technical Specifications. For example, there are no Limitirg Conditions for Operation and Surveillance Requirements specf fied for the ECCS Equipment Cooling Ventilation System (VY) and Diesel Gene'stor Room Ventilation (VD) systems although the systems which they support (ECCS and Emergency Onsite Electrical Power) are specifically addressed by the Technical Specifications (3.5.1/3.5.2 and 3.8.1.1/3.8.1.2 respectively).

The same situation exists for the Switchgear Heat Removal Ventilation (VX) System and the Screenhouse and Makeup Water Pump House Ventilation (VH) System.

A question which has often been asked ib, "What ACTION should be taken when a system or component which performs a support function is determined to be inoperable or rendered inoperable by performing testing or maintenance?"

Preliminary investigation suggests that it is not the intent of the Technical Specifications (i.e., the OPERABLE - OPERABILITY definition) to prohibit performing maintenance or testing on support systems during power operation. That is, considerat?on of Specification 3.0.3 should not be required if suitable ACTIOh. and/or a limited out-of-service time can be established for a support system contistent with the Limiting Conditions for Operation specified in the Technical Specifications for the essential sefety .ystem supported by that system.

In some cases, when a support system (s) or component (s) is iclared inoperable, it does not seem appropriate to take the ACTION ( ) specifiad

. in the Technical Specifi ations for the supported essential system (s) vhen the ACTION reouitement(s) or allowed out-of-service time (s) appears to be based on inoperability of the supported equipment itself and not '

t.ecessarily on the inoperability or degradation of the supporting equipment. For example, if it is desired to perform maintenance on the VX system, which provides cooling to the switchgear and battery charger areas and the battery and inverter rooms, must the ACTION specified.

say, for an inoperable wattery charger (Technical Specification

- - - .x

Attecht.ent to i 4

U-601Xii l

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3.8.2.1/3.8.2.2) be applied even though portions of the system could be i

maintained operable to su}. port normal plant operation? The  !

d out-of-service time permitted for an inoperable battery charger is only  !

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This would probably not allow sufficient time to complete maintenance on the VX system before a plant shutdown would be required. t Another example where it is not clear which ACTIONS in the Technica.

Specifications associated with the different affected equipment should ,

be taken, is when a Shutdown Service Water (SX) loop 14 declared inoperable. The ACTION statement in the Technical Specifications for i the SX system requires declaring the associated diesel generator i q

inoperable. When the LCO for the diesel generator (s) (Technical Specification 3.8.1.1) is entered and the ACTIONS are taken. ACTION "b" 3 (or "d") requires starting end loading the diesel generator (s) in the  ;

other division (s). This seems inappropriate when it is known that the

, problem is in the SX system and not in the diesel generator itself. It would seem most appropriate to investigate the SX system, which would not necessarily require starting and loading the diesel generator (s).

, (In addition, starting and loading the other diesel generator (s) under l normal plant conditions would not necessarily reveal a problem in the SX l i

system since plant service water, and not SX water, is aligned to  ;

essential loads during normal plant conditions.) L

! I j INTERPRETATION  ;

! The following is extracted from an NRC letter dated April 10. 1980.

This letter, which was issued to all reactor power licensees, effected a revision to tne Standard Technical Specifications (STS) which <

incorporated the expanded definition of OPERABLE that now appears in the {

! STS and the Clinton Technical Specifications. l L

1

{ The NRC's Standard Technical Specifications (STS) were f0mulated j

to preserve the single failure criterion for systems that are }

! relied upon in the safety analysta report. By and large, the i j single failure criterion is preserved by specifying Limiting l Conditions for Operation (LCOs) that require all redundant  !

i j components of safety related systems to be OPERABLE. Whe'. the j required redundancy is not maintained, either dua to equipment ,

i failure or maintenance outage, action is required, within a

specified time, to change the operating mode of the plant to place i it in a safe condition. The specified time to take action, usually ,

j called the equipeent out-of-service cine. is a temporary relaxation  !

I of the single failure criterion, which, consistent with overall ,

system reli?bility considerations, provides a limited time to fix I l equipment or otherwise mate it OPERABLE. If equipment can be i l returned to OPERABLE status within the specified time, plant  !

shutdown 10 not required. l i  !

j LCOs are specified for each safety related system in the plant, and ['

with few exceptions, the ACTION statements address single outages

, of components. trains or subsystems. For eny particular system. [

1 the LCO doen not address multiple outages of redundant components, j 4  ;

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5

. Attechnent to

. U-601261 Page 3 of 15 nor does it address the effects of outages of any support systems -

such as electrical power or cooling water - that are relied upon to maintain the OPERABILITY of the particular system. This is because of the large number of combinations of these types of outages that are possible. Instead, the STS employ general specifications and an explicit definition of the term OPERABLE to encompass all such cases. These provisions have been formulated to assure that no set of equipment outaFee would be allowed to persist that wo;4d result in the facility being in an unprotected condition.

Another letter was issued by the NRC (dated July 8,1985) to further address how the operability requirements for a particular system explicitly aC *ressed by the Technical Specifications should be extended to those systems or components which perform a related support function.

The following key points are extracted from that letter.

(1) The definition of operability extends the requirements of an LC0 for those systems or components which directly perform a specified function to those which perform a related support function. Support functions are defined to include all necessary attendant instrumentation, controls, electric power, cooling or seal water, lubrication or other auxilia y equipment that is required to perform a supporting function.

(2) For many items that perform supporting functions, the Technical Specifications do not specify an LCO for these specific items. Therefore, a knowledge of the plant design bases is essential to the proper application of the Technical I Specification operability requirements for items which perform as support functions.

j (3) For the majority of the Technical Specifications, redundant systems or components are required to be operabie to assure

that the requirements of the single failure criterion are j satisfied. When a system or componeut is inoperaole, actions j

are required to restore the system or co gonant to operable status within specified time limits or to place the plant in a j mode or condition for which the LCO no longer applies. The i requirements have been generally based on engineering judgment rather than specific event analysis.

]

(4) The Technical Specifications do allow exceptions to the requiremet.t, of the General Design Criteria (GDC) for limited periods of time. For example, systems or components are allowed to be out of service for testing or maintenance for specified time intervals. During such times the requirements of the single failure criterion as specified in the GDC for specific systems may not be satisfied.

In view of the guidance provided in these letters it is clear that no system or component which provides a support function should be removed from service or otherwise rendered inoperable without consideration of its impact on the essential supported system or equipment.

Inoperability of the supporting equipment or avstem may or may not have

Attschsont to U- 601261 Page 4 of 15 any immediate impact on the supported system or equipment during power operation or existing plant conditions but could impact operation of the supported system or equipment during accident conditions. In some cases it is difficult to predict how performance of the essential system would be affected or how long it could adequately perform its safety function under accident conditions with an inoperable or degraded supporting system or component.

The ACTION (s) specified under a particular LCO for an essential system provides an allowed out-of-service time (A0T) and/or compensatory measures that may be taken to permit continued plant operation for a limited period of time. The A0T and specified compensatory measures or actions however are based on the associated essential system itself being inoperable and not necessarily on the support system (s) alone being inoperable. Thus, although the LCO for an essential safety system must be extended to include the support system (s), some of the actions and A0Ts specified in the ACTION statements for such systems in the l Technical Specifications are not appropriate for situations when the  !

inoperable condition may exist only in a support system (s). Additional interpretation is therefore needed to provide a means of complying with the operability requirements extended to support systems or components but also to ensure that appropriate ACTIONS and A0Ts are implemented for such rystems when they are rendered inoperable. The following five specific support systems are addressed:

1. Shutdown Service Water (SX) System II. Switchgear Heat Removal (VX) Ventilation System III. Diesel Generator Room Ventilation (VD) System IV. Screenhouse and Makeup Water Pump House Vantilation (VH)

System j V. ECCS Equipment Cooling (VY) Ventilation System.

The interpretation provided for each of these systems is based on concurrence and compliance with the intent of the noted NRC letters and the extended definition of OPERABILITY as it applies to support systems in that an "LCO will be entered" when applicable support systems are declared inoperable. In most cases, the interpretation supports the conclusion that the ACTIONS specified in the Technical Specifications i for the supported essential system must be taken when tha associated support system is declared inoperable. Special conrideration however is given to the SX, VH and VD systems in that the ACTIONS required when the associated diesel generator is declared inoperable (due to the support system befug declared inoperable) require additional clarification. The VX system is also given special consideration. If the VX systen is declared inoperable, rather than enter an LCO specified in the Technical Specifications for each ot' the supported components or systems, the "LC0" that will be entered shall be administrative 1y imposed according to the interpretation provided for the VX system. The "LC0" for the VX syctem will include the ACTIONS e be taken based on a review of the LCOs specified in the Technical Specifications for the affected systems addressed in the Technical Specifications. In all cases, the concerns

Attechment to U. 601261 Page 5 of 15 expressed in the noted NRC correspondence will be resolved because outages of support sysrems will be monitored and accounted for in accordance with or consistent with the Technical Specifications.

Each of the five support systems (SX, VX, VD, VH and VY) are addressed on the followinr,pages. An interpretation prescribing the appropriate action to be taken when the applicable support system is declared inoperable is provided for each.

4 Attechmsnt to U 601261 Page 6 of 15 I, SX System (FSAR Section 9.2.1.2)

The SX, VD, VH, VY and VX systems may all be considered to be support systems. However, the SX system is specifically addressed by the Technical Specifications under Clinton Technical Speci.fication 3.7.1.1, while the VD, VH, VY and VX systems do not have specific LCOs stated in the Technical Specifications. Specific ACTIONS under Specification 3.7.1.1 are therefore required when an SX loop (s) is declared inoperable. Interpre6ation is provided to address these specific ACTIONS and to ensure that other necessary and appropriate ACTIONS are taken.

The current ACTION under Clinton Techt,1 cal Specification 3.7.1.1 reads as follows:

i With a shutdown service water loop (s) inoperable and with its associated system (s) or component (s) required to be OPERABLE, declare the associated system (s) or component (s) inoperable and take the ACTION required by Specification (s) 3.4.9.1, 3.4.9.2, 3.5.1, 3.5.2, 3.8.1.1, 3.8.1.2, 3.9.11.1, and 3.9.11.2, as applicable.

This ACTION statement thus refers to the ACTIONS specified under other LCOs systems (SX loads) which depend on SX to perform their safety function concurrent with a single failure such as a less of offsite power. A comprehensive review of these ACTIONS and all of the SX system loads has verified the need to provide additional interpretation regarding (1) how the actions under the LCOs referred t.o under Technical Specification 3.7.1.1 should be fulfilled when entering those ACTIONS duo only to on inoperable SX loop, and (2) what actions, in addition to those specifically referred to, should be taken when declaring all of "the associated system (s) or components (s) inoperable" as a result of an SX loop (s) being declared inoperable. This interpretation is provided as follows.

Interpretation With an SX loop (division) inoperable and with its associated system (s) or component (s) required to be OPERABLE, declare the associated system (s) or component (s) inoperable and take the ACTION (s) required under the noted LCOs as specified under Technical Specification 3.7.1.1, with the following clarification:

When declaring the associated diesel generator inoperable in OPERATIONAL CONDITIONS 1, 2, 3, only certain ACTIONS under Technical Specification 3.8.1.1 will be required: Spe cifica1.l y, only ACTICN "e" (for either Div I or II only) and part of either ACTION "b" or "d" will be required depending on which diesel generator (i.e., division) is inoperable. (Additional explanation is given below.) The remaining ACTIONS (a, c f, g, h and i) should not apply for the condition of having only a single SX division or loop inoperable with no other concurrent inoperable

Attechacnt to U- 601261 Page 7 of 15 condition addressed by those ACTIONS existing.

In addition to those ACTIONS, the following trains, systems or components should be declared inoperable so that the associated LCOs are entered and the corresponding ACTIONS are placed into effect:

System. Train or Componen*. Technical Specification LCO Control Room Ventilation (VC) System (s) 3.7.2 Standby Cas Treatment (VG) Syctem(s) 3.6.6.3 Hydrogen Recombiner (HG) Systems (s) 3.6.7.1 MSIV Leakage Control (IS) System Subsystem (s) 3.6.1.4 Action "e" (applicable when the diesel generator associated with either Div I or Div II only is declared inoperable) requires verifying, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, that all required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a

source of emergency power are also OPERABLE. This ACTION is appropriate i

because it ensures that the essential equipment requir d to mitigate the

consequences of an accident assoc.iated with the other (operable) '

division is available to perform its safety function when the division associated with the inoperable SX subsystem is declared inoperable.

ACTION "b" (for Div I or II) or "d" (for Div III) requires (1) verifying correct breaker alignment and indicated power availability more frequently than usual, and (2) starting and loading the diesel l generators in the other OPERABLE divisions (when a diesel is declared  !

inoperable due to any cause other than preplanned preventive maintenance t or testing). Performance of the first part of ACTION "b" (or "d") is i required because it verifies that offsite power is available. IP's  ;

interpretation is that the latter part of this ACTION, however. is not required because it is not necessary to assume that an inoperable ,

condition existing within the SX system constitutes a condition in which the OPERABILITY o mustbeverified.jthedieselgenerator(s)itselfinanoth9rdivision It should be determined as soon as possible that the i

This interpretation does not specifically address situations in which i nore than one SX loop is inoperable or, for example, when an SX loop is inoperable concurrent with an inoperable AC electrical power source. I Such situations 'aust be considered on a case-by-case basis for which the 3

guidance provided by this interpretation may or may not apply. In j general, such concurrent inoperable conditions will require ACTION involving a much shorter A0T.

I i This interpretation applies to a problem liscovered within the SX system such that an SX loop (s) had to be declared inoperable. It to ,

< already smderstood that preplanned preventive maintenance or testing perforced on an SX or other support subsystem is equivaleat to preplanned preventive maintenance or testing performed on the associated diesel generator (s) such that the starting and loading of the redundant '

1 OPERABLE diesel generator (s) otherwise required by ACTION "b" or "d" i does not have to be performed. l l

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Attachmsnt to U- 601261 Page 8 of 15 problem is not a generic problem applicable to all of the SX loops, but

this would not necessarily require starting and loading the diesel generators themselves. This interpretation is consistent with industry and NRC policy (Generic Letter 84-15) directed at reducing the risk and excessive wear caused by excessive and unnecessary diesel generator

, testing.

The additional ACTIONS required for the VC, VG, HG and IS systems are a necessary extension of the ACTION under Technical Specification 3.7.1.1 which states, "declare the associated system (s) or component (s) inope rable . " It is appropriate to "enter an LC0" for each of these systems to ensure that their degraded condition is noted and accounted 1

for. These systems (i.e., train or subsystem within the affected 1

division) must be declared inoperable because, under accident conditions (concurrent with a loss of offsite power), the SX system supplies j essential cooling water to the room coolers associated with these i systems.

The room coolers provide adequate heat removal to limit the maximum

temperatures in the affected rooms or areas to within acceptable limits.

The room coolers along with the associated systems are identified as follows:

) System Equipment Description EIN Division VC Control Room HVAC System Chiller OVCl3A I VC Control Room HVAC System Chiller OVCl3B II j VG SGTS Room 1A Coil Cabinet OVG055A I VG SGT3 Room IB Coil Cabinet OVG055B II i HG Hydrogen Recombiner Room 1A Coil 0VG075A I 4 Cabinet l HG Hydrogen Recombiner Room 1R Coil OVC075B II l Cabinet IS MSIV-LCS Inboard Roco Coil Cabinet IVY 09S I l IS MSIV-LCS Outboard Room Coil Cabinet IVY 10S II It should be noted that, consistent with the original intent of this

)

Specification (3.7.1.1), the ef fect of the most limiting ACTION (under LCOs 3. 5.1/3. 5. 7. and 3.8.1.1/ 3. 8.1. 2) , out of all of the LCOs that I apply, is to limit the out-of-service time for a single inoperable SX loop or divicion to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (before a plant shutdown is required)

I duri g OPERATIONAL CONDITIONS 1, 2, 3.

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Attachmant to '

U- 601261 Page 9 of 15 II. VX System (FSAR Section 9.4.5.2)

In accordance with the design basis, operability of the switchgear heat removal system (VX) is required for ensuring adequate heat removal to limit the maximum temperatures in the affected areas or rooms esnsistent with equipment ambient temperature ratings and requirements under normal or abnormal station conditions. The essential areas served by the VX system include the Div. 1, 2 and 3 switchgear areas, Div. 1, 2, 3 and 4 battery rooms, cable spreading rooms, and the Division 1, 2 and 4  ;

inverter rooms.  !

For the switchgear cooling portion of the VX system, independent l redundant cooling trains are provided for each of the three divisional switchgear areas. One train is non-safety related and has a coil supplied with cooling water from the plant chilled water system. The  !

redundant safety-related train contains a direct expansion refrigeration t unit supplied with cooling water from either the shutdown service water l (SX) et plant service water (WS) system, depending on plant conditions,  ;

and has its own supply air distribution network. This train is utilized ,

during abnormal (accident) conditions or upon failure of the non-safety related switchgear heat removal train.

A complete outage of a VX division during normal plant operation, in  ;

which both the safety-related and non-safety related switchgear heat

  • removal trains would be out of service, would likely cause temperatures [

~

to rise to unacceptabla levels in at least some of the affected rooms and would therefore not be permitted. The nonsafety train can be i removed from service for an indefinite period of time with no Technical Specification ACTION required since the safety-related train provides the required cooling. Howevtr. a temporary outage of a safety-related i train should be permitted to perform maintenance so long as normal t temperatures can be maintained (by means of the non-safety train). A reasonable A0T should therefore be permitted during plant operation when it is evident that the non-safety portion of the system can maintain normal room temperature. Some of the aff=cted rooms contain independent  ;

safety-related roon coolers and therefore do not solely depend on the i switchgear heat removal trains to maintain acceptable roon temperatures.  !

l Based on a review of the plant Technical Specifications and the (

equipment situated in the various rooms for which the VX system is l associated VX must be considered a support syr. tem for both the AC arid '

DC power systems which are specifically addressed by Technical l Specifications 3.8.1.1/3.8.1.2, 3.8.2.1/3.8.2.2 and 3.8.3.1/3.8.3.2. Of these LCOs, Specification 3.8.2.1/3.8.2.2, which specifies OPERABILITY a requirements for DC sources (batteries / chargers), contains the most limiting ACTION: With a Div. I or II battery or charger inoperable, an A0T of only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is permitted.* This A0T is appropriate when the ,

t

  • The basis for this severe A0T is described in Regulatory Guide 1.93, j "Availability of Electric Pow 1r Sources." As acted in the BASES of the l Technical Specifications (which refer to Reg. Guide 1.93), the OPERABILITY of the various power sources are based upon maintaining at least Div. I or II of the onsite AC and DC power sources and associated ,

distribttion systems OPERABl.E during accident conditions coincident {

with an assumed loss of offsite power and single failure of the other onsite AC source. L i

. Attachmsnt to U- 601261 Page 10 of 15 battery or charger itself within a particular division is inoperable, but it is unnecessarily restrictive when only the supporting safety-related switchgear heat removal train in that division is inoperable. Considering the fact that the safety-related portion of VX requires the SX and emergency power systems to be operabic in order to perform its function, the A0T for a single safety-related switchgear train out of service should be no more restrictive than the A0T permitted for those systems. A review of the ACTIONS prescribed according to the LCOs for those systems (as discussed previously for SX) shows that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is permitted providing the other divisions and all of the essential equipment associated with the other divisions is OPERABLE.

To repeat, a 72-hour A0T will be allowod for any VX component or combination of VX components such that only one division of affected equipment is impacted at a tine. However, if the impact of declaring an SX loop inoperable is consideoed, inoperability of the Division Il SX loop simultaneously renders the VX safety-related coil cabinet ror both the Division II and Division IV inverter rooms incapable of providing essential cooling during accident conditions concurrent with a loss of offsite power. This is due to the fact that both of these coil cabinets are supplied with emergency cooling water from the Division II SX loop.

(Inoperability of either the SX Division I loop or the SX Division III loop does not result in a similar condition of having two coil cabinets for two different divisions of equipment inoperable at the same time.)

An outage of the Division II SX loop thus seems contrary to the intent of allowing equipment within one division at a time to be impacted by an allowed VX outage.

Further consideration shows, however, that although an outage of the Division II SX loop may be considered a worst case condition (because it impacts VX cooling capability for two divisions of equipment), its impact is not significantly worse than an outage of either of the other two SX divisions (I and III). This is because of the redundancy built into the design of the HPCS actuation logic, some of which is powered from the Division III Nuclear Systems Protection System (NSPS) buss, and some of which is powered from the Division IV NSPS buss.

Since automatic UPCS initiation can still be effected with Division IV NSPS power unavailable (assuming no ad.fitional failures), a loss of the Division IV inverter VX room cooler concurrent with a loss of the Division II inverter VX room cooler, due to an inoperable Division II SX division, will not result in a loss of the HPCS automatic initiation capability. That is, an outage of the Division 11 SX loop will not result in an outage of more than the associated Division II ECCf despite the impact on the VX system as discussed above.

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. Attach;cnt to  ;

U- 601261 1 Page 11 of 15 In aussary, it is appropriate to allow a single VX component or train to t be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (such that only a single division of I equipment is affected) even though it is recognized that the 72-hour A0T also allowed for an SX loop (according to the Technical Specificatio:.s) can result in a degradation of VX cooling capability for more than one [

division of equipment. (The latter condition can only exist with respect to the SX Division II loop as discussed previously.)

Interpretation In lieu of an allowed out-of-service time specified for the VX system in the Technical Specificatists, Operation with an inoperable VX safety-related switchgear heat removal train or ,

component is permd.tted for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided that the  ;

affected room temperatures can continue to be maintained within l acceptable Ifmits and that only one division of equipment (cooled

! by the VX train or component) is affected at a time. (That is, for the special case discussed previously for the VX room coolers f associated with the Division II and Division IV inverter rooms,  ;

emergency room cooling for the Division II and Division IV inverter rooms should be maintain)d operable to the extent that both coolers

, are not removed from service at the same time except as allowed for an outage of the SX system.)

l If the system cannot be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the plant must te in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in 4 COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Plant Opera ns will track the condition in the "LCO losbook" with an entry based on this interpretation in a manner equivalent to the " schnical Specification LCOs. .

It should be emphasized that a violation of this "LC0" ACTION. which is based on applicable Technical Specification LCOs (3.8.1.1/3.8.1.2. et.

al.) that have been extended to inc.'ude the VX cystem through the ,

OPERABLE-OPERABILITY definition. constitutes a condition prohibited by ,

the plant Technical Specifications and is reportable as such.  ;

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Attechmsnt to U-601261 Page 12 of 15 III. VD System (FSAR Section 9.4.5.1)

As described in the FSAR, the VD system is designed to operate under nocual and abnormal conditions. Durin8 normal operating canditions a non-safety makeup ventilation system operates mainly to prevent the possible accumulation of oil fumes in the three diesel generator rooms and in the corresponding day tank and oil storage tank rooms. During accident conditions when the diesel generators are in operation, divisional ventilation fans operate automatically to limit the maxinue temperature in each associated diesel generator room to 130'F in conformance with the diesel- ;enerator equipment ratings.

l During normal plant operation, outagen of the nonsafety \V makeup system can be tolerated if room temperatures do not exceed the above noted temperatures. However, if the essential ventilation fan for a particular diesel generator is unavailable such that unacceptable room temperatures (130*T) could be attained during discel operetion, then it ,'

is appropriate to declare the diesel gene-;ior inoperable in a manner similar to when the associated SX laop is declared inoperable.

Therefore, IP's position regarding inoperability of a safety-related 3 essential VD ventilation fan is similar to that expressed for inoperability of an SX loop or division with respect to the ACTION 3 required when declaring the associated diesel generator inoperable.

P Interpretation, When a diesel generator safety-related ventilation fan (lvD01CA, CB, CC) is declared inoperable, then the a:sociated ciesel generator must be declared inoperable and an "LCO vili be entered" by Operations on the LCO log under Technical Specification 3.8.1.1/3.8.1.2 However, for OPERATIONAL CONDITIONS 1, 2, 3, only certain ACTIONS under Technical Specification 3.8,1,1 are required (for the same reasons as discussed for the SX system):

Specifically, only ACTION "e" .for either Div. I or Div. 11) and part of either ACTION "b" or "d" will be required depending on which diesel generator (i.e., division) 14 inoperable. (Additienal explanation is given below.) The remaining ACTIONS (a, c, f, g, h and 1) should not apply for the condition of having only a single divisional VD (safety-rela ted) ventilation fan inopetable with no other concurrent inoperable condition addressed by those ACTIONS existing.

Action "e" (applicable to eithet Piv. I or Div. II only) requires verifying, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, that all required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLF. This ACTION is appropriate because it ensures that the essential equipment I required to uitigate the consequences of an accident associated with the other division is available to perform its safety function if the 3

division associated with the inoperable diesel generator is rendered j inopetable.

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U- 601261 Page 13 of 15 ACTION "b" (for Div I or II) or "d" (for Div III) requires (1) verifying

' correct breaker alignment and indicated power availability more frequently than usual, and (2) starting and loading the diesel generators in the other OPERABLE divisions (when a diesel is declared

  • inoperable due to any cause ottor than preplanned preventive maintenance or testing). Performance of the first part of ACTION "b" (or "d") is required because it verifies that offsite power is available. IP's interpretation is that the latter part of this ACTION. however is not rec.uired because it is not necessary to assume that an inoperable condition existing within the VD system constitutes a condition in which the OPERABILITY o '

i mustbeverified.fthedieselgenerator(s)itselfinanodierdivision It should be determined as soon as possible that the problem is not a generic problem applicable to all of the VD subsystems.

but this would not necessarily require starting and loading the diesel generators themselves. This interpretation is consistent with industry and NRC policy (Generic Letter 84-15) directed at reducing the risk and

, excessive wear caused by excessive and unnecessary diesel generator testing.

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4 i This interpretation applies to a problem discovered within the VD j system such that a VD subsystem had to be declared inoperable. It is

! already understood that preplanned preventive maintenance or testing  ;

l perforned on a VD or other support subsystem is equivalent to l l preplanned preventive maintenance or testing performed on the i

associated diesel generator (s) such that the starting and loadiar of the redundant OPERABLE diesc1 generator (s) otherwise required by  ;

) ACTION "b" or "d" does not have to be perforned.  ;

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Attachmint to

n. 601261 Paus 14 of 15 IV. VH System (FSAR Section 9.4.5.4)

The VH system provides ventilation for the make up water pump house and the screenhouse. The nuclear safety-related part of the system provides room cooling for each of the three shutdown service water (SX) pumps.

Each divisioa or subsystem contains a cooling train capable of dissipating the heat produced by the operation of the correspe,nding ptcp a and motor to limit the associated inside room temperature to 122'F.

, Each cooling train is powered from an essential safety bus serving the associated SX pump. A cooling coil associated with each cooling train j is supplied by shutdown service water.

Inoperability of the cooling train associated with a particular SX puup could cause the ambient temperature within the room to exceed acceptable limits. Therefore the following interpretation is provided to address inoperability of this support system.

I Interpretation j i When a safety-related cooling train for a particular division of the VH system 19 made or declared inoperable, the associated SX l loop must be declared inoperable and an LCO must be entered on the LCO logbook under Technical Specification 3.7.1.1. However, the

ACTIONS under Specification 3.7.1.1 may be taken in accordance with
the interpretation provided earlier for inoperability of an SX loop or division.

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. Attach: nt to U- 601261 Page 15 of 15 V. VY System (FSAR Section 9.4.5.3)

The ECCS Equipment Area Cooling (VY) System is designed such that a '

cooling train is provided for each ECCS equipment cubicle. Each cooling train is capable of dissipating the heat produced by the operation of the associated ECCS equipment and limiting the cubicle temperature to a j maximum of 150'F and 90% relative humidity af ter a design basis accident. The cooling coils utilize either plant service water or shutdown service water depending on plant conditions. Although the VY system is designed such that it can be used during normal operating conditions, ventilatica for the ECCS cubicles during normal conditions is providtd by the fuel building HVAC system.

Inoperability of a cooling train associated with a particular ELJS cubicle could, during accident conditions, cause ambient cubicle  :

temperatures to exceed acceptable limits. Therefore the following  !

interpretation is provided to address inoperability of the VY aupport l system. (

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Interpretation for Inoperability of the VY System When a VY system cooling train is declared inoperable, the ,

I associated ECCS equipment must be declared inoperable and an LCO must be entered on the LCO logbook for Technical Specification 3.5.1/3.5.2. ACTION must be taken according to the plant Technical Specifications (3.5.1/3.5.2) for the associated inoperable ECCS.

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