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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217H6231999-10-18018 October 1999 Discusses Completion of Licensing Action for GL 98-01 & Suppl 1, Yr 2000 Readiness of Computer Sys at Npps, to All Holders of Operating Licenses for NPPs ML20217J4331999-10-15015 October 1999 Forwards Insp Rept 50-461/99-19 on 990913-17.One Violation Re Individual Failure to Follow Radiation Protection Procedures When Accessing High Radiation Area Noted & Being Treated as Noncited Violation U-603280, Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p)1999-10-12012 October 1999 Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p) ML20217C0871999-10-11011 October 1999 Forwards Proprietary Attachment Inadvertently Omitted from Encl 2 to Submitting Responses to NRC RAI Re License Transfer Application for Plant.Proprietary Encl Withheld U-603276, Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included1999-10-0808 October 1999 Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included U-603279, Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld1999-10-0707 October 1999 Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld U-603275, Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station1999-10-0707 October 1999 Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station ML20217A9881999-10-0101 October 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20217A7361999-10-0101 October 1999 Forwards Insp Repts 50-461/99-14 & 50-461/98-12 on 990729-0908.Two Violations Identified,One Re Failure to Place Control Switch in Proper Position to Identify Piece of out-of-svc Equipment & Being Treated as NCVs ML20217J1251999-09-30030 September 1999 Refers to Investigation 3-1997-040 Conducted from 971028- 980921 & Forwards Nov.Investigations Determined That During Jan 1997,supervisor Qv Dept Discriminated Against Qv Inspector in Retaliation for Inspector Contacts with NRC ML20217J1421999-09-30030 September 1999 Refers to Investigation 3-97-040 Conducted from 971028- 980921 & Forwards Nov.Investigation Concluded That Recipient Engaged in Deliberate Misconduct in That Recipient Discriminated Againt Qv Inspector for Having Contacted NRC ML20212G6751999-09-22022 September 1999 Forwards Comment Submitted to NRC by Environ Law & Policy Ctr Re Proposed License Transfer for Clinton Power Station U-603272, Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl1999-09-22022 September 1999 Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl U-603225, Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl1999-09-20020 September 1999 Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl ML20212G6981999-09-20020 September 1999 Requests That NRC Reject Proposed License Transfer for Clinton Power Station & That NRC State That Public Interest in Safe Nuclear Power Industry Will Not Be Subordinated to Interest in Maximizing Profit by Limiting Liability ML20217H3421999-09-17017 September 1999 Forwards Request for Addl Info Re Licensee 990723 Application for License Transfer & Conforming Administrative License Amend.Response Requested within 20 Days of Receipt of Ltr 05000461/LER-1996-010, Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events1999-09-13013 September 1999 Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events 05000461/LER-1999-011, Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments1999-09-10010 September 1999 Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments U-603269, Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed1999-09-10010 September 1999 Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed ML20211Q2671999-09-0808 September 1999 Informs That NRC Tentatively re-scheduled Initial Licensing Exams for License Operator License Applicants During Weeks of June 5 & 12,2000.Validation of Exams Will Occur at Station During Weeks of May 15,2000 U-603229, Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl1999-08-25025 August 1999 Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl U-603243, Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.71999-08-23023 August 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.7 ML20211D2201999-08-23023 August 1999 Confirms 990817 Telcon with J Neuschwanger & D Mcneil Re Arrangements Made for NRC to Inspect Licensed Operator Requalification Program at Plant U-603258, Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage1999-08-23023 August 1999 Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage ML20211B0871999-08-20020 August 1999 Responds to J Hopkins Inquiry Re Application for Order Consenting to License Transfer & Approving Conforming Administrative License Amend Filed by Ilpr & Amergen Energy Co on 990723 U-603259, Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired1999-08-19019 August 1999 Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired ML20211A8931999-08-19019 August 1999 Forwards Insp Rept 50-461/99-13 on 990611-0728.Two Violations Noted & Being Treated as Ncvs.Violation Re Three Examples Where Licensee Procedural Requirements for Minor Maint Work Were Not Followed U-603253, Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 9908131999-08-16016 August 1999 Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 990813 ML20210U3771999-08-12012 August 1999 Forwards Notice of Consideration of Approval of Transfer of FOL & Issuance of Conforming Amend & Opportunity for Hearing Re Amend Request for Approval of Clinton Power Station License NPF-62 Transfer to Amergen U-603250, Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 9907291999-08-10010 August 1999 Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 990729 U-603249, Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 9908091999-08-10010 August 1999 Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 990809 ML20210N2961999-08-0909 August 1999 Forwards Form of Nuclear Decommissioning Master Trust Agreement,Per CPS Application for License Transfer & Conforming Administrative License Amend U-603248, Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR551999-08-0606 August 1999 Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR55 U-603236, Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS1999-08-0202 August 1999 Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS ML20210J0541999-07-30030 July 1999 Forwards Three Original Signature Pages of Gr Rainey for Application for License Transfer & Conforming Administrative License Amend, for NRC Files U-603178, Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS1999-07-29029 July 1999 Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS U-603237, Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 0001311999-07-28028 July 1999 Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 000131 U-603240, Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.711999-07-27027 July 1999 Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.71 U-603235, Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.7901999-07-23023 July 1999 Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.790 ML20210A4401999-07-16016 July 1999 Forwards Insp Rept 50-461/99-10 on 990422-0610.Four Violations Being Treated as Noncited Violations ML20209G7671999-07-12012 July 1999 Ack Receipt of Encl FEMA Correspondence ,which Transmitted FEMA Evaluation Rept for 981118 Biennial EP Exercise at Clinton Power Station.No Deficiencies Were Observed ML20209D5691999-07-0707 July 1999 Forwards Insp Rept 50-461/99-12 on 990607-11.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Observations of Work in Progress & Interviews with Personnel U-603231, Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date1999-07-0707 July 1999 Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date U-603214, Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events1999-07-0606 July 1999 Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events ML20196J9651999-07-0202 July 1999 Confirms Discussion Between Members of Staffs to Conduct Meeting on 990714 at Clinton Power Station to Discuss Results of Restart Insp & Licensee Progress in Addressing Remaining Long Term C/A Actions to Sustain Improvements ML20196J7131999-06-30030 June 1999 Informs of Closure of Response to Requests for Addl Info to GL 92-01,Rev 1,Supplement 1, Reactor Vessel Structural Integrity, for Clinton Power Station Unit 1 U-603218, Provides Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. Attachment Provides Y2K Readiness Disclosure for Plant1999-06-28028 June 1999 Provides Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. Attachment Provides Y2K Readiness Disclosure for Plant U-603212, Forwards Response to NRC 990315 Telcon Re Proposed Amend of License NPF-62,implementing Feedwater Leakage Control Sys Mode of RHR Sys1999-06-24024 June 1999 Forwards Response to NRC 990315 Telcon Re Proposed Amend of License NPF-62,implementing Feedwater Leakage Control Sys Mode of RHR Sys U-603227, Provides Updated Rept on Status of Decommissioning Funding for Plant.Updated Rept Provides Min Decommissioning Fund Estimate,Per 10CFR50.75(b) & (C) Utilizing NUREG-1307,Rev 8 Methodology1999-06-24024 June 1999 Provides Updated Rept on Status of Decommissioning Funding for Plant.Updated Rept Provides Min Decommissioning Fund Estimate,Per 10CFR50.75(b) & (C) Utilizing NUREG-1307,Rev 8 Methodology ML20196A3471999-06-16016 June 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-461/99-11 Issued on 990430.Corrective Actions Will Be Examined During Future Inspections 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARU-603280, Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p)1999-10-12012 October 1999 Forwards Rev 27 to Clinton Power Station Physical Security Plan,Iaw 10CFR50.54(p).Encl Withheld from Public Disclosure, Per 10CFR50.54(p) ML20217C0871999-10-11011 October 1999 Forwards Proprietary Attachment Inadvertently Omitted from Encl 2 to Submitting Responses to NRC RAI Re License Transfer Application for Plant.Proprietary Encl Withheld U-603276, Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included1999-10-0808 October 1999 Forwards Rev 8 to CPS USAR, Which Includes Changes from 970701 Through 990630 & Available Changes Approved After 990630 That Reduce Overall Burden of Submittal Changes for Forthcoming Reporting period.10CFR50.59 Rept Included U-603279, Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld1999-10-0707 October 1999 Forwards non-proprietary & Proprietary Responses to NRC RAI Re License Transfer Application for Plant.Attached Responses Also Respond to Comments of Environ Law & Policy Center Dtd 990920.Proprietary Encl Withheld U-603275, Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station1999-10-0707 October 1999 Provides Updated Illinois Power Rept on Status of Decommissioning Funding for Clinton Power Station U-603272, Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl1999-09-22022 September 1999 Provides Update to Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. 3-D Monicore & Station Security Sys remediated.Y2K Readiness Disclosure for Cps,Encl U-603225, Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl1999-09-20020 September 1999 Provides Closure of Util Commitments Re Ci Cv Noted in Previous Ltr to Nrc.Basis for Expecting Valves to Remain in leak-tight Condition Throughout Operating Cycle & Basis That Justifies Not Performing mid-cycle Leak Testing,Encl ML20212G6981999-09-20020 September 1999 Requests That NRC Reject Proposed License Transfer for Clinton Power Station & That NRC State That Public Interest in Safe Nuclear Power Industry Will Not Be Subordinated to Interest in Maximizing Profit by Limiting Liability 05000461/LER-1996-010, Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events1999-09-13013 September 1999 Forwards LER 96-010-01, Plant Shutdown Due to Unidentified RCS Leakage from Degraded Reactor Recirculation Pump Seal Greater than TS Limit. Revised Rept Includes Cause of Event,Corrective Actions & Discussion of Similar Events U-603269, Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed1999-09-10010 September 1999 Certifies That DB Livingston,License OP-31136,successfully Completed Facility Licensees Requirements to Be Licensed as Ro,Per 10CFR55 & Has Need for RO License to Perform Assigned Duties.Five Significant Control Manipulations,Listed 05000461/LER-1999-011, Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments1999-09-10010 September 1999 Forwards LER 99-011-00 Re Improper Restoration of a APRM Which Caused Monitor to Not Meet Seismic Qualification Requirements.Rept Contains Listed Commitments U-603229, Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl1999-08-25025 August 1999 Provides Response to NRC RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Dtd 990528.Rev 0 to Calculation IP-M-0556 & Rev 0 to Calculation IP-M-0570,encl U-603243, Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.71999-08-23023 August 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Util Performing Testing of ESF Ventilation Sys Charcoal Samples Using ASTM D3803- 1989 Methodology as Required by TS 5.5.7 U-603258, Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage1999-08-23023 August 1999 Forwards ISI Summary Rept, IAW ASME Section Xi,Article IWA-6000.Summary Rept Addresses ISI Activities Performed at Plant from 950429-990527,including Extended Sixth Refueling Outage ML20211B0871999-08-20020 August 1999 Responds to J Hopkins Inquiry Re Application for Order Consenting to License Transfer & Approving Conforming Administrative License Amend Filed by Ilpr & Amergen Energy Co on 990723 U-603259, Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired1999-08-19019 August 1999 Provides Notification That Cl Kreidler Has Resigned Position with Util,Effective 990818.License Status Should Be Changed to Expired U-603253, Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 9908131999-08-16016 August 1999 Notifies NRC That Je Smith,License SOP-30819-1,has Resigned from Position with Ilpr Effective 990813.Status of License Should Be Changed to Expired,Effective 990813 U-603250, Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 9907291999-08-10010 August 1999 Notifies NRC That Ma Freihofer (License SOP-31296-1) Has Resigned from Position with Illinois Power Effective 990729 & License Status Should Be Changed to Expired Effective 990729 U-603249, Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 9908091999-08-10010 August 1999 Notifies NRC That He Bouska (License SOP-3055-1) Has Resigned from Position with Illnois Power Effective 990809. & License Status Should Be Changed to Expired Effective 990809 ML20210N2961999-08-0909 August 1999 Forwards Form of Nuclear Decommissioning Master Trust Agreement,Per CPS Application for License Transfer & Conforming Administrative License Amend U-603248, Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR551999-08-0606 August 1999 Requests Unrestricted License for Kc Scott,License SOP-31532.Scott Has Successfully Completed Facility Licensee Requirements to Be Licensed as Operator/Senior Operator Per 10CFR55 U-603236, Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS1999-08-0202 August 1999 Forwards Revised Data Point Ref File Sheets for Clinton Power Station Computer Points That Input to ERDS ML20210J0541999-07-30030 July 1999 Forwards Three Original Signature Pages of Gr Rainey for Application for License Transfer & Conforming Administrative License Amend, for NRC Files U-603178, Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS1999-07-29029 July 1999 Forwards Four ASME Section XI Relief Requests Re Performance of non-destructive Exams for First 120-month Inservice Insp for CPS U-603237, Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 0001311999-07-28028 July 1999 Informs That Util Will Provide Response to fire-related Questions One & Two of NRC RAI Re CPS Ipeee,By 000131 U-603240, Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.711999-07-27027 July 1999 Forwards Clinton Power Station semi-annual Fitness for Duty Rept for Period Ending 990630,IAW 10CFR26.71 U-603235, Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.7901999-07-23023 July 1999 Forwards Application for License Transfer & Conforming Administrative License Amend for OL NPF-62.Proprietary & Nonproprietary Asset Purchase Agreement Encl.Proprietary Info Withheld,Per 10CFR2.790 U-603231, Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date1999-07-0707 July 1999 Forwards Summary of Status of Plan for Excellence (Pee) Initiatives & Clinton Power Station (CPS) 1999 Business Plan.Encl Documents Provide Status & Disposition for Actions Not Completed to Date U-603214, Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events1999-07-0606 July 1999 Forwards Results of Analysis Performed on Recently Completed Vendor Contracts,Per GL 83-28, Required Actions Based on Generic Implications of Salem ATWS Events U-603218, Provides Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. Attachment Provides Y2K Readiness Disclosure for Plant1999-06-28028 June 1999 Provides Final Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. Attachment Provides Y2K Readiness Disclosure for Plant U-603212, Forwards Response to NRC 990315 Telcon Re Proposed Amend of License NPF-62,implementing Feedwater Leakage Control Sys Mode of RHR Sys1999-06-24024 June 1999 Forwards Response to NRC 990315 Telcon Re Proposed Amend of License NPF-62,implementing Feedwater Leakage Control Sys Mode of RHR Sys U-603227, Provides Updated Rept on Status of Decommissioning Funding for Plant.Updated Rept Provides Min Decommissioning Fund Estimate,Per 10CFR50.75(b) & (C) Utilizing NUREG-1307,Rev 8 Methodology1999-06-24024 June 1999 Provides Updated Rept on Status of Decommissioning Funding for Plant.Updated Rept Provides Min Decommissioning Fund Estimate,Per 10CFR50.75(b) & (C) Utilizing NUREG-1307,Rev 8 Methodology 05000461/LER-1999-007, Forwards LER 99-007-00,re Design Error Causing Main Steam Isolation Valve Leakage Control Sys to Be Outside Design Basis.Commitment Made by Util,Listed1999-06-12012 June 1999 Forwards LER 99-007-00,re Design Error Causing Main Steam Isolation Valve Leakage Control Sys to Be Outside Design Basis.Commitment Made by Util,Listed 05000461/LER-1999-008, Forwards LER 99-008-00,re Failure of Motor Driven Reactor FW Pump Regulating Valve.Commitment Made by Util,Listed1999-06-12012 June 1999 Forwards LER 99-008-00,re Failure of Motor Driven Reactor FW Pump Regulating Valve.Commitment Made by Util,Listed U-603213, Responds to NRC Ltr Re Violations Noted in Insp Rept 50-461/99-01.Corrective Actions:Calculation 19-AK-05, Calculation for DG Load Monitoring, Was Revised Using Correct Horsepower for Hydrogen Mixing Compressors1999-05-28028 May 1999 Responds to NRC Ltr Re Violations Noted in Insp Rept 50-461/99-01.Corrective Actions:Calculation 19-AK-05, Calculation for DG Load Monitoring, Was Revised Using Correct Horsepower for Hydrogen Mixing Compressors ML20209G7731999-05-27027 May 1999 Forwards Copy of Final Rept for 981118,Biennial Radiological Emergency Preparedness Exercise for Clinton Nuclear Power Station.No Deficiencies Were Noted U-603207, Provides Util Rept Confirming Completion of Actions Required by NRC Bulletin 96-003, Potential Plugging of ECCS Strainers by Debris in Bwrs1999-05-13013 May 1999 Provides Util Rept Confirming Completion of Actions Required by NRC Bulletin 96-003, Potential Plugging of ECCS Strainers by Debris in Bwrs U-603201, Forwards 4-yr Updated Certification Rept for Plant Training Simulator.Nrc Form 474, Simulation Facility Certification Also Encl Which Was Developed in Accordance with Reg Guide 1.149 & Ansi/Ans Std Ansi/Ans 3.51999-05-0505 May 1999 Forwards 4-yr Updated Certification Rept for Plant Training Simulator.Nrc Form 474, Simulation Facility Certification Also Encl Which Was Developed in Accordance with Reg Guide 1.149 & Ansi/Ans Std Ansi/Ans 3.5 U-603196, Provides Notification That Util Has Completed Thermo-Lag 330-1 Fire Barrier Corrective Actions as Described in 970619 & s in Addition to Repair of Butt Joint Described in1999-04-27027 April 1999 Provides Notification That Util Has Completed Thermo-Lag 330-1 Fire Barrier Corrective Actions as Described in 970619 & s in Addition to Repair of Butt Joint Described in U-603205, Forwards Annual Radioactive Effluent Release Rept for Clinton Power Station for Period Jan-Dec 1998. Rev 17 to ODCM for Clinton Power Station, Also Encl1999-04-27027 April 1999 Forwards Annual Radioactive Effluent Release Rept for Clinton Power Station for Period Jan-Dec 1998. Rev 17 to ODCM for Clinton Power Station, Also Encl U-603197, Provides Details of Other Activities Being Taken as Part of CPS Plan for Excellence Re Ensureing That CPS Physical Plant & Functional Characteristics Are Consistent with & Are Being Maintained IAW CPS Design Bases1999-04-24024 April 1999 Provides Details of Other Activities Being Taken as Part of CPS Plan for Excellence Re Ensureing That CPS Physical Plant & Functional Characteristics Are Consistent with & Are Being Maintained IAW CPS Design Bases U-603194, Provides Notification That Ta Staber,License SOP-31298,has Resigned Position,Effective 990401.License Status Should Be Changed to Expired1999-04-15015 April 1999 Provides Notification That Ta Staber,License SOP-31298,has Resigned Position,Effective 990401.License Status Should Be Changed to Expired U-603189, Requests That Status of License SOP-31187-1,for Le Anderson, Be Changed to Expired,Per 10CFR50.74.Util Determined That Individual No Longer Has Need for SRO License1999-04-0505 April 1999 Requests That Status of License SOP-31187-1,for Le Anderson, Be Changed to Expired,Per 10CFR50.74.Util Determined That Individual No Longer Has Need for SRO License U-603190, Provides Update for Certain 10CFR50.74(f) Info Addressed in Licensee 980619 Submittal,But Not Included in Final Response1999-04-0202 April 1999 Provides Update for Certain 10CFR50.74(f) Info Addressed in Licensee 980619 Submittal,But Not Included in Final Response U-603185, Forwards Response to NRC RAI Re CPS GL 96-05, Periodic Verification of Design-Basis Capability of SR Movs, Program1999-03-30030 March 1999 Forwards Response to NRC RAI Re CPS GL 96-05, Periodic Verification of Design-Basis Capability of SR Movs, Program U-603186, Forwards Rept on Status of Clinton Power Station Decommissioning Funding,Iaw 10CFR50.75(f)1999-03-29029 March 1999 Forwards Rept on Status of Clinton Power Station Decommissioning Funding,Iaw 10CFR50.75(f) U-603184, Submits Info Re Current Levels of Property Insurance & Sources of Insurance for CPS as Listed,Per 10CFR50.54(w)(3)1999-03-26026 March 1999 Submits Info Re Current Levels of Property Insurance & Sources of Insurance for CPS as Listed,Per 10CFR50.54(w)(3) 05000461/LER-1999-005, Forwards LER 99-005-00,re Inoperability of Standby Gas Treatment Sys Train a Caused by Inadequate Design of Control Circuit.Commitments Listed1999-03-15015 March 1999 Forwards LER 99-005-00,re Inoperability of Standby Gas Treatment Sys Train a Caused by Inadequate Design of Control Circuit.Commitments Listed U-603165, Forwards Revised Data Point Ref File Sheet for Clinton Power Station Computer Point That Inputs to Erds.Change Necessary to Support Plant Mods to Drywell Floor Drain Instrumentation1999-03-12012 March 1999 Forwards Revised Data Point Ref File Sheet for Clinton Power Station Computer Point That Inputs to Erds.Change Necessary to Support Plant Mods to Drywell Floor Drain Instrumentation U-603179, Provides Notification That RG Giuliani & R Zacholski,No Longer Have Need for Operating License.License Status Is Therefore Requested to Be Changed to Expired1999-03-10010 March 1999 Provides Notification That RG Giuliani & R Zacholski,No Longer Have Need for Operating License.License Status Is Therefore Requested to Be Changed to Expired 1999-09-22
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059L6571990-09-19019 September 1990 Advises That Dp Hall No Longer Associated W/Facility Since Dec 1989.Mail Should Be Addressed to Js Perry JSP-739-90, Requests Expedited Review & Approval of Proposed Change to Emergency Tech Specs Re Div III Nuclear Sys Protection Sys Inverter Concerning Inoperability of Emergency Shutdown Svc Water Sys Pump1990-09-12012 September 1990 Requests Expedited Review & Approval of Proposed Change to Emergency Tech Specs Re Div III Nuclear Sys Protection Sys Inverter Concerning Inoperability of Emergency Shutdown Svc Water Sys Pump U-601729, Notifies That Bn Chambers Permanently Reassigned to Position Not Requiring Operator License.Certification of Chambers Need to Hold License Previously Provided by Dp Hall Withdrawn1990-08-27027 August 1990 Notifies That Bn Chambers Permanently Reassigned to Position Not Requiring Operator License.Certification of Chambers Need to Hold License Previously Provided by Dp Hall Withdrawn JSP-676-90, Responds to 900725 Notice of Violation & Proposed Imposition of Civil Penalty Documented in Insp Rept 50-461/90-09. Corrective Action:Critique Initiated to Identify Precise Causes & Contributing Factors Leading to Event1990-08-23023 August 1990 Responds to 900725 Notice of Violation & Proposed Imposition of Civil Penalty Documented in Insp Rept 50-461/90-09. Corrective Action:Critique Initiated to Identify Precise Causes & Contributing Factors Leading to Event U-601723, Forwards Results of fitness-for-duty Program for 900103-0630,per 10CFR26.711990-08-16016 August 1990 Forwards Results of fitness-for-duty Program for 900103-0630,per 10CFR26.71 U-601722, Forwards Reissued NPDES Permit IL00369191990-08-10010 August 1990 Forwards Reissued NPDES Permit IL0036919 U-601721, Provides Response to Re Process for Requalification Exam Security Agreements.Security Agreement Forms Revised to Direct Individuals Not to Participate in Any Instruction Involving Operators or Senior Operators1990-08-0808 August 1990 Provides Response to Re Process for Requalification Exam Security Agreements.Security Agreement Forms Revised to Direct Individuals Not to Participate in Any Instruction Involving Operators or Senior Operators U-601716, Forwards Response to Violations Noted in Insp Rept 50-461/90-10.Response Withheld (Ref 10CFR73.21(c)(2))1990-08-0303 August 1990 Forwards Response to Violations Noted in Insp Rept 50-461/90-10.Response Withheld (Ref 10CFR73.21(c)(2)) U-601715, Provides Addl Info Re Proposed Amend to Plant Tech Spec 3/4.8.1.1, AC Sources - Operating, Per .Amend Will Allow Testing Frequency of Diesel Generator to Be Returned to Monthly1990-08-0202 August 1990 Provides Addl Info Re Proposed Amend to Plant Tech Spec 3/4.8.1.1, AC Sources - Operating, Per .Amend Will Allow Testing Frequency of Diesel Generator to Be Returned to Monthly U-601708, Forwards Revised Pages to Semiannual Radioactive Effluent Release Repts for Jul-Dec 1988,Jan-June 1989 & Jul-Dec 19891990-07-19019 July 1990 Forwards Revised Pages to Semiannual Radioactive Effluent Release Repts for Jul-Dec 1988,Jan-June 1989 & Jul-Dec 1989 U-601702, Forwards Rev 9D to Physical Security Plan.Rev Withheld (Ref 10CFR73.21)1990-07-0202 July 1990 Forwards Rev 9D to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20044A3001990-06-22022 June 1990 Forwards Update to 890817 Response to Bulletin 88-008,Suppl 3, Thermal Stresses in Piping Connected to Rcs. Unisolable Piping Connected to RCS Identified & Evaluated to Determine Which Piping Could Be Subj to Stratified Flow Phenomena ML20044A4601990-06-22022 June 1990 Provides Followup to 900622 Request for Waiver of Compliance Re Tech Spec Limiting Condition for Operation Concerning Standby Emergency Diesel Generator 1B.Rev to Attachment 1 of Original Request for Waiver Encl ML20043H5021990-06-19019 June 1990 Requests Changes to License NPF-62,correcting Typos, Refs to Fsar,Testing to Be Done During Initial Plant Startup & Incorporating Revised Operating Power/Flow Map for Two Reactor Recirculation Loop Operation ML20043G8221990-06-0707 June 1990 Provides Update to Util Response to Item 1 of Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. ML20043F0591990-06-0606 June 1990 Forwards Endorsements 44-50 to Nelia Policy NF-261 & 25-31 to Maelu Policy MF-121 & 10 & 11 to Maelu Policy N-85 & M-85,respectively ML20043D0531990-05-31031 May 1990 Forwards 1989 Annual Rept for Illinois Power Co & Soyland Power Cooperative,Inc ML20043C7501990-05-25025 May 1990 Forwards Rev 20 to Illinois Power Nuclear Program QA Manual. Rev Evaluated by Util as Not Reducing Quality Program Commitments ML20043B4891990-05-21021 May 1990 Informs NRC of Plant Initiatives for 1990 to Improve Corrective Action Program Effectiveness,In Response to SALP Rept & Violations Noted in Insp Rept 50-461/89-32. Centralized Commitment Tracking Sys Upgraded ML20043B1141990-05-17017 May 1990 Suppls 900330 Response to Station Blackout Rule.Calculation of Heatup of Main Control Room Due to Loss of Ventilation Following Station Blackout Revised to Properly Account for Heat Sinks & Credit Existing Masonry Walls ML20043D9901990-05-14014 May 1990 Responds to NRC 900413 Ltr Re Violations Noted in Insp Rept 50-461/90-02.Corrective Actions:Safety Evaluation Prepared & Reviewed for Level Instrumentation & Annunciators Identified in Updated SAR ML20043A9811990-05-14014 May 1990 Notifies That Wc Metzner Resigned from Position of Licensed Operator W/Util,Effective 900430 ML20042E6181990-04-13013 April 1990 Updates 890406 Response to Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety-Related Equipment. Condition Rept Initiated to Address Issue to Drain Instrument Air Filter Regulators ML20012E8991990-03-27027 March 1990 Forwards Rev 9C to Physical Security Plan.Rev Does Not Decrease Effectiveness of Plan.Rev Withheld (Ref 10CFR73.21) ML20012D9451990-03-20020 March 1990 Informs of Current Activities Re Restoration of Shutdown Svc Water (SX) Sys to Operability Following Cleaning of Div I HX Per Generic Ltr 89-13.SX Sys to Be Restored by Returning Sys Flows to Design Values ML20012D9641990-03-19019 March 1990 Lists Present Levels of Property Insurance Coverage & Sources of Insurance,Per 10CFR50.54(w)(2) ML20012D9901990-03-19019 March 1990 Responds to NRC 900216 Ltr Re Violations Noted in Insp Rept 50-461/89-38.Corrective Actions:Maint Supervision Added Critical Points to Existing Maint Work Requests & Preventive Maint Activities & Training Program Updated ML20012D4321990-03-16016 March 1990 Responds to Bulletin 88-008,Suppl 3, Thermal Stresses in Piping Connected to Rcs. Detailed Analytical Review & Proposed Schedule for Implementing Required Actions Scheduled to Be Completed by 900625 ML20012A2771990-02-28028 February 1990 Forwards Final Response to NRC Bulletin 88-010,Suppl 1, Nonconforming Molded Case Circuit Breakers. Actions Taken by Util Have Established That All safety-related Circuits Remaining in Stock Can Be Verifiably Traced to Mfg ML20012C2511990-02-23023 February 1990 Responds to Ninth SALP Rept 50-461/89-01 for Sept 1988 - Oct 1989.Rept Concluded That Overall Performance Satisfactory & Identified Strengths in Areas of Emergency Preparedness U-601611, Notifies That Gd Setser Resigned Position W/Util,Effective 9002131990-02-20020 February 1990 Notifies That Gd Setser Resigned Position W/Util,Effective 900213 ML20011F6501990-02-12012 February 1990 Responds to NRC 900112 Ltr Re Violations Noted in Insp Rept 50-461/89-37.Corrective Actions:Radiation Protection Technicians Provided W/Method for Identifying Radiation Work Permits Which Change Radiological Conditions ML20006C6721990-02-0505 February 1990 Responds to NRC 891207 Ltr Re Violations Noted in Insp Rept 50-461/89-35.Corrective Actions:Emergency Planning Bulletin Issued to All Emergency Response Organization Members Emphasizing Importance of Attending Required Training ML20006D1951990-01-30030 January 1990 Responds to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Util Intends to Discontinue Sending Ack Upon Receipt of Vendor Manual Matls ML20006A8291990-01-23023 January 1990 Forwards Rev 3 to Inservice Exam Plan. Changes to Text Described.Approval of Changes by 900601 to Allow Time to Plan Refueling Outage Activities Re Inservice Exam Program Requested ML20005H2711990-01-12012 January 1990 Advises That Licensee Will Remove Terminal Blocks for Control Circuits within 100% Relative Humidity Harsh Environ at Plant by End of Second Refueling Outage Currently Scheduled to Begin in Sept 1990 ML20006A7121990-01-10010 January 1990 Forwards Revised Pages to 1987 Radiological Environ Monitoring Rept ML20005F0001990-01-0505 January 1990 Responds to NRC Bulletin 88-004, Potential Safety-Related Pump Loss. Util Revised Plant Operating Procedures for Hpcs,Lpcs & RHR Pumps & Vibration Monitoring Program Expanded to Include ECCS Pumps at Plant ML20006A7921989-12-29029 December 1989 Responds to 891129 Ltr Which Forwarded Insp Rept 50-461/89-31,requesting Identification of Actions Underway to Ensure That Falsification of Interim Security Screening Records Would Be Detected in Timely Manner in Future U-601573, Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Detailed Procedures Controlling Actuator Adjustments,Repair,Preventive Maint & Other Activities Used & Updated Frequently1989-12-29029 December 1989 Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Detailed Procedures Controlling Actuator Adjustments,Repair,Preventive Maint & Other Activities Used & Updated Frequently ML20005E0891989-12-27027 December 1989 Advises That Revised Fitness for Duty Program Will Meet 10CFR26 Requirements,Effective 900103.Util Intends to Test for Substances Listed at Indicated cut-off Levels ML20006C2961989-12-21021 December 1989 Responds to NRC 891121 Ltr Re Violations Noted in Insp Rept 50-461/89-32.Corrective Actions:Review Performed to Identify Surveillances Which Require Lifting of Leads in Main Control Room ML20005D9521989-12-15015 December 1989 Forwards Monthly Operating Rept for Nov 1989 for Clinton Power Station Unit 1 & Corrections to Oct 1989 Rept ML20005E7781989-12-12012 December 1989 Advises That False Alarm Criteria Will Be Implemented by 900131,per Insp Rept 50-461/89-31.Util Established New Criterion of 100 False Alarms for Security Sys in 24 H Period ML20011D1741989-12-0707 December 1989 Informs of Changes Made to Util Fitness for Duty Program Procedure.Change Specifies That Supervisor - Medical Programs,Assistant Director - Labor Relations or Manager - Nuclear Planning & Support Will Generate Computer List ML19332F0071989-11-30030 November 1989 Responds to Violations Noted in Insp Rept 50-461/89-29. Corrective Actions:Preventive Maint for Ph Monitor & Liquid & Gaseous Gamma Monitors Added to Appropriate Tracking Programs ML19332E9431989-11-29029 November 1989 Forwards Executed Amends 4 & 5 to Indemnity Agreement B-91, Reflecting Change in Ownership of License,Effective 890327 ML19332D5031989-11-27027 November 1989 Responds to Generic Ltr 89-21 Re Status of Implementation of USI Requirements.Results of Util Review & Reporting of Status of Implementation of USIs Encl ML19332D0291989-11-22022 November 1989 Informs That Effective 891201,JS Perry Will Assume Responsibility for Mgt of Nuclear Program at Util ML19332D0431989-11-22022 November 1989 Informs NRC of Change in Schedule for Providing Info Re Environ Qualification Testing of Terminal Blocks for Control Circuits of Conax Electrical Penetrations.Wyle Labs Test Results & Util Review of Results Will Be Sent by 900112 1990-09-19
[Table view] |
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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
i r
t i
l l
. 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
] Page 2 uf 15 i L
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 ;
1 ,
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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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 [
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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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Attochment to '
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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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