RIS 2012-10, NRC Staff Position on Applying Surveillance Requirements (SR) SR 3.0.2 and 3.0.3 to Administrative Controls Program Tests: Difference between revisions

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| issue date = 08/23/2012
| issue date = 08/23/2012
| title = NRC Staff Position on Applying Surveillance Requirements (SR) SR 3.0.2 and 3.0.3 to Administrative Controls Program Tests
| title = NRC Staff Position on Applying Surveillance Requirements (SR) SR 3.0.2 and 3.0.3 to Administrative Controls Program Tests
| author name = Dudes L A, McGinty T J
| author name = Dudes L, Mcginty T
| author affiliation = NRC/NRO/DCIP, NRC/NRR/DPR
| author affiliation = NRC/NRO/DCIP, NRC/NRR/DPR
| addressee name =  
| addressee name =  
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| page count = 4
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{{#Wiki_filter:ML12079A393 August 23, 2012 NRC REGULATORY ISSUE SUMMARY 2012-10: NRC STAFF POSITION ON APPLYING SURVEILLANCE REQUIREMENTS 3. AND 3.0.3 TO ADMINISTRATIVE CONTROLS PROGRAM TESTS  
{{#Wiki_filter:UNITED STATES
                            NUCLEAR REGULATORY COMMISSION
                        OFFICE OF NUCLEAR REACTOR REGULATION
                                  OFFICE OF NEW REACTORS
                                WASHINGTON, DC 20555-0001 August 23, 2012 NRC REGULATORY ISSUE SUMMARY 2012-10:                 NRC STAFF POSITION ON APPLYING
                                                      SURVEILLANCE REQUIREMENTS 3.0.2 AND 3.0.3 TO ADMINISTRATIVE
                                                      CONTROLS PROGRAM TESTS


==ADDRESSEES==
==ADDRESSEES==
All holders of, and applicants for, power reactor operating licenses issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vesse All holders of and applicants for a power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under 10 CFR Part 52, "Licenses, Certifications, and Approvals for Nuclear Power Plants."
All holders of, and applicants for, power reactor operating licenses issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.
 
All holders of and applicants for a power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.


==INTENT==
==INTENT==
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS) to inform addressees that Enforcement Guidance Memorandum (EGM) 2012-001 was issued on February 24, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11258A243). The EGM was issued for testing requirements in Section 5.0, "Administrative Controls," Technical Specification (TS) 5.5, "Programs and Manuals," that make available surveillance requirement (SR) 3.0.2, SR 3.0.3, or bot This RIS does not transmit any new requirements and does not require any specific action or written response on the part of an addresse
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to inform addressees that Enforcement Guidance Memorandum (EGM) 2012-001 was issued on February 24, 2012 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML11258A243). The EGM was issued for testing requirements in Section 5.0,
Administrative Controls, Technical Specification (TS) 5.5, Programs and Manuals, that make available surveillance requirement (SR) 3.0.2, SR 3.0.3, or both. This RIS does not transmit any new requirements and does not require any specific action or written response on the part of an addressee.


==BACKGROUND INFORMATION==
==BACKGROUND INFORMATION==
Task Interface Agreement (TIA) 2010-001, "Evaluation of Application of Technical Specification SR 3.0.3, 'Surveillance Requirement Applicability,' at Clinton Power Station" (ADAMS Accession No. ML101100101), documented the NRC staff's review of that licensee's position that SR 3.0.3 from TS 5.5.6, "Inservice Testing Program" applies to non-TS excess flow check valve testing performed under 10 CFR 50.55a(f), "Inservice Testing Requirements." The specification in SR 3.0.3 allows licensees to apply a delay period before declaring the SR for TS equipment "not met" when the licensee inadvertently exceeds or misses the time limit for performing TS surveillanc The NRC staff determined that licensees cannot use TS 5.5.6 to apply SR 3.0.3 to an inservice test under 10 CFR 50.55a(f) that is not associated with a TS surveillanc To invoke SR 3.0.3, the licensee must first discover that a TS surveillance was not performed at its specified frequenc Therefore, the delay period SR 3.0.3 provides does not apply to non-TS support components tested under 10 CFR 50.55a(f), such as the excess flow check valves reviewed under the Clinton TI
Task Interface Agreement (TIA) 2010-001, Evaluation of Application of Technical Specification SR 3.0.3, Surveillance Requirement Applicability, at Clinton Power Station (ADAMS Accession No. ML101100101), documented the NRC staffs review of that licensees position that SR 3.0.3 from TS 5.5.6, Inservice Testing Program applies to non-TS excess flow check valve testing performed under 10 CFR 50.55a(f), Inservice Testing Requirements. The specification in SR 3.0.3 allows licensees to apply a delay period before declaring the SR for TS equipment not met when the licensee inadvertently exceeds or misses the time limit for performing TS
surveillance. The NRC staff determined that licensees cannot use TS 5.5.6 to apply SR 3.0.3 to an inservice test under 10 CFR 50.55a(f) that is not associated with a TS surveillance. To invoke SR 3.0.3, the licensee must first discover that a TS surveillance was not performed at its specified frequency. Therefore, the delay period SR 3.0.3 provides does not apply to non-TS support components tested under 10 CFR 50.55a(f), such as the excess flow check valves reviewed under the Clinton TIA.
 
ML12079A393


==SUMMARY OF THE ISSUE==
==SUMMARY OF THE ISSUE==
As a follow up to TIA 2010-001, the NRC staff considered the generic impact of the Clinton TIA positio This review determined that restructuring TS chapters during the development of improved standard technical specifications (STS) resulted in unintended consequences when Section 3.0, "Surveillance Requirement Applicability," provisions were made applicable to Section 5.0 T Specifically, applying STS rules of usage would prohibit licensees from using the SR 3.0.2 and SR 3.0.3 allowances in Section 5.0 TS, unless the Section 5.0 TS tests are associated with a TS S Therefore, the NRC staff concluded that applying either the SR 3.0.2 or SR 3.0.3 general provisions on the applicability of SRs to non-TS testing required by program tests is generic and applies to all addressees with plant-specific TS based on improved STS (NUREG-1430 through NUREG-1434). Plant-specific TS that do not match up with NUREG-1430 through NUREG-1434 may apply to this position, depending on the extent to which the SR applicability and TS 5.5 deviate from STS conten To ensure licensees appropriately apply the findings of its review, the NRC staff issued EGM 2012-00 Effect of EGM 2012-001 on Reactor Operations SR 3.0.2 and SR 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS S Therefore, programmatic test frequencies cannot be extended in accordance with SR 3.0.2, and programmatic test frequencies cannot be delayed in accordance with SR 3.0.3, when there is no associated requirement from SR 3.0.1 for program tests to be both performed and me Using SR 3.0.2 to extend a program test or using SR 3.0.3 to delay declaring a missed program test "not met" without having a TS SR related to the program test would result in noncompliance with TS or nonconformance with other regulatory requirements because these SR allowances cannot be applied to non-SR test The information provided in EGM 2012-001 provides guidance on how the NRC staff will disposition licensee noncompliance with Section 5.0, TS 5.5, testing requirements that make available SR 3.0.2, SR 3.0.3, or bot
As a follow up to TIA 2010-001, the NRC staff considered the generic impact of the Clinton TIA
position. This review determined that restructuring TS chapters during the development of improved standard technical specifications (STS) resulted in unintended consequences when Section 3.0, Surveillance Requirement Applicability, provisions were made applicable to Section 5.0 TS. Specifically, applying STS rules of usage would prohibit licensees from using the SR 3.0.2 and SR 3.0.3 allowances in Section 5.0 TS, unless the Section 5.0 TS tests are associated with a TS SR. Therefore, the NRC staff concluded that applying either the SR 3.0.2 or SR 3.0.3 general provisions on the applicability of SRs to non-TS testing required by program tests is generic and applies to all addressees with plant-specific TS based on improved STS
(NUREG-1430 through NUREG-1434). Plant-specific TS that do not match up with NUREG-1430 through NUREG-1434 may apply to this position, depending on the extent to which the SR applicability and TS 5.5 deviate from STS content. To ensure licensees appropriately apply the findings of its review, the NRC staff issued EGM 2012-001.
 
Effect of EGM 2012-001 on Reactor Operations SR 3.0.2 and SR 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.
 
Therefore, programmatic test frequencies cannot be extended in accordance with SR 3.0.2, and programmatic test frequencies cannot be delayed in accordance with SR 3.0.3, when there is no associated requirement from SR 3.0.1 for program tests to be both performed and met. Using SR 3.0.2 to extend a program test or using SR 3.0.3 to delay declaring a missed program test not met without having a TS SR related to the program test would result in noncompliance with TS or nonconformance with other regulatory requirements because these SR allowances cannot be applied to non-SR tests.
 
The information provided in EGM 2012-001 provides guidance on how the NRC staff will disposition licensee noncompliance with Section 5.0, TS 5.5, testing requirements that make available SR 3.0.2, SR 3.0.3, or both.


==BACKFIT DISCUSSION==
==BACKFIT DISCUSSION==
This RIS conveys the information in EGM 2012-001 for testing requirements in Section 5.0, TS 5.5, that make available SR 3.0.2, SR 3.0.3, or bot This RIS requires no action or written response and, therefore, is not a backfit under 10 CFR 50.109, "Backfitting." Consequently, the NRC staff did not perform a backfit analysi
This RIS conveys the information in EGM 2012-001 for testing requirements in Section 5.0,
TS 5.5, that make available SR 3.0.2, SR 3.0.3, or both. This RIS requires no action or written response and, therefore, is not a backfit under 10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.


===FEDERAL REGISTER NOTIFICATION===
===FEDERAL REGISTER NOTIFICATION===
The NRC did not publish a notice of opportunity for public comment on this RIS in the Federal Register because it is informational and does not depart from current regulatory requirements and practice The NRC intends to work with the Nuclear Energy Institute, industry representatives, members of the public, and other stakeholders to develop final guidance and revise related guidance document
The NRC did not publish a notice of opportunity for public comment on this RIS in the Federal Register because it is informational and does not depart from current regulatory requirements and practices. The NRC intends to work with the Nuclear Energy Institute, industry representatives, members of the public, and other stakeholders to develop final guidance and revise related guidance documents.


===CONGRESSIONAL REVIEW ACT===
===CONGRESSIONAL REVIEW ACT===
Line 38: Line 61:


===PAPERWORK REDUCTION ACT STATEMENT===
===PAPERWORK REDUCTION ACT STATEMENT===
This RIS does not contain information collection requirement Therefore, the NRC did not request Office of Management and Budget (OMB) review to determine requirements under Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).  
This RIS does not contain information collection requirements. Therefore, the NRC did not request Office of Management and Budget (OMB) review to determine requirements under Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).


===PUBLIC PROTECTION NOTIFICATION===
===PUBLIC PROTECTION NOTIFICATION===
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control numbe
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control number.


==CONTACT==
==CONTACT==
Please direct any questions about this matter to the technical contact listed belo /RA by JLuehman for/ /RA/ Laura A. Dudes, Director Timothy J. McGinty, Director Division of Construction Inspection Division of Policy and Rulemaking And Operational Programs Office of Nuclear Reactor Regulation Office of New Reactors  
Please direct any questions about this matter to the technical contact listed below.
 
/RA by JLuehman for/                                 /RA/
Laura A. Dudes, Director                             Timothy J. McGinty, Director Division of Construction Inspection                 Division of Policy and Rulemaking And Operational Programs                           Office of Nuclear Reactor Regulation Office of New Reactors  


===Technical Contact:===
===Technical Contact:===
Carl S. Schulten, NRR/DSS 301-415-1192 css1@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collection RIS 2012-10 
Carl S. Schulten, NRR/DSS
                    301-415-1192 css1@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
 
ML12079A393                    *via e-mail      TAC No. ME8199 OFFICE    NRR/DSS/STSB        Tech Editor*    NRR/DSS/STSB/BC NRR/DSS/D            OE/EB          OIS    NRR/PMDA
                                                                                    NHilton                  LHill NAME          CSchulten        JDougherty          RElliott        WRuland                      TDonnell (NColeman for)            (SWalker for)
DATE          03/20/12          03/22/12          05/07/12        05/11/12        05/21/12      05/31/12  05/31/12 NRR/DPR/PGCB/P NRR/DPR/PG NRR/DPR/PGC
OFFICE    NRR/DE/EPTB        OGC (NLO)*                                                      NRO/DCIP/D NRR/DPR/D
                                                      M              CB/LA*        B/BC*
                                                                                                  LDudes NAME        TMcMurtray        AGendelman          ARussell          CHawes        DPelton      (JLuehman  TMcGinty for)
DATE          06/07/12          06/22/12          08/03/12          08/03/12      08/21/12      08/23/12  08/23/12
}}
}}


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Latest revision as of 07:40, 12 November 2019

NRC Staff Position on Applying Surveillance Requirements (SR) SR 3.0.2 and 3.0.3 to Administrative Controls Program Tests
ML12079A393
Person / Time
Issue date: 08/23/2012
From: Laura Dudes, Mcginty T
Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking
To:
Schulten, Carl, NRR/DSS 415-1192
References
RIS-12-010
Download: ML12079A393 (4)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

WASHINGTON, DC 20555-0001 August 23, 2012 NRC REGULATORY ISSUE SUMMARY 2012-10: NRC STAFF POSITION ON APPLYING

SURVEILLANCE REQUIREMENTS 3.0.2 AND 3.0.3 TO ADMINISTRATIVE

CONTROLS PROGRAM TESTS

ADDRESSEES

All holders of, and applicants for, power reactor operating licenses issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

All holders of and applicants for a power reactor early site permit, combined license, standard design certification, standard design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

INTENT

The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)

to inform addressees that Enforcement Guidance Memorandum (EGM) 2012-001 was issued on February 24, 2012 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML11258A243). The EGM was issued for testing requirements in Section 5.0,

Administrative Controls, Technical Specification (TS) 5.5, Programs and Manuals, that make available surveillance requirement (SR) 3.0.2, SR 3.0.3, or both. This RIS does not transmit any new requirements and does not require any specific action or written response on the part of an addressee.

BACKGROUND INFORMATION

Task Interface Agreement (TIA) 2010-001, Evaluation of Application of Technical Specification SR 3.0.3, Surveillance Requirement Applicability, at Clinton Power Station (ADAMS Accession No. ML101100101), documented the NRC staffs review of that licensees position that SR 3.0.3 from TS 5.5.6, Inservice Testing Program applies to non-TS excess flow check valve testing performed under 10 CFR 50.55a(f), Inservice Testing Requirements. The specification in SR 3.0.3 allows licensees to apply a delay period before declaring the SR for TS equipment not met when the licensee inadvertently exceeds or misses the time limit for performing TS

surveillance. The NRC staff determined that licensees cannot use TS 5.5.6 to apply SR 3.0.3 to an inservice test under 10 CFR 50.55a(f) that is not associated with a TS surveillance. To invoke SR 3.0.3, the licensee must first discover that a TS surveillance was not performed at its specified frequency. Therefore, the delay period SR 3.0.3 provides does not apply to non-TS support components tested under 10 CFR 50.55a(f), such as the excess flow check valves reviewed under the Clinton TIA.

ML12079A393

SUMMARY OF THE ISSUE

As a follow up to TIA 2010-001, the NRC staff considered the generic impact of the Clinton TIA

position. This review determined that restructuring TS chapters during the development of improved standard technical specifications (STS) resulted in unintended consequences when Section 3.0, Surveillance Requirement Applicability, provisions were made applicable to Section 5.0 TS. Specifically, applying STS rules of usage would prohibit licensees from using the SR 3.0.2 and SR 3.0.3 allowances in Section 5.0 TS, unless the Section 5.0 TS tests are associated with a TS SR. Therefore, the NRC staff concluded that applying either the SR 3.0.2 or SR 3.0.3 general provisions on the applicability of SRs to non-TS testing required by program tests is generic and applies to all addressees with plant-specific TS based on improved STS

(NUREG-1430 through NUREG-1434). Plant-specific TS that do not match up with NUREG-1430 through NUREG-1434 may apply to this position, depending on the extent to which the SR applicability and TS 5.5 deviate from STS content. To ensure licensees appropriately apply the findings of its review, the NRC staff issued EGM 2012-001.

Effect of EGM 2012-001 on Reactor Operations SR 3.0.2 and SR 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.

Therefore, programmatic test frequencies cannot be extended in accordance with SR 3.0.2, and programmatic test frequencies cannot be delayed in accordance with SR 3.0.3, when there is no associated requirement from SR 3.0.1 for program tests to be both performed and met. Using SR 3.0.2 to extend a program test or using SR 3.0.3 to delay declaring a missed program test not met without having a TS SR related to the program test would result in noncompliance with TS or nonconformance with other regulatory requirements because these SR allowances cannot be applied to non-SR tests.

The information provided in EGM 2012-001 provides guidance on how the NRC staff will disposition licensee noncompliance with Section 5.0, TS 5.5, testing requirements that make available SR 3.0.2, SR 3.0.3, or both.

BACKFIT DISCUSSION

This RIS conveys the information in EGM 2012-001 for testing requirements in Section 5.0,

TS 5.5, that make available SR 3.0.2, SR 3.0.3, or both. This RIS requires no action or written response and, therefore, is not a backfit under 10 CFR 50.109, Backfitting. Consequently, the NRC staff did not perform a backfit analysis.

FEDERAL REGISTER NOTIFICATION

The NRC did not publish a notice of opportunity for public comment on this RIS in the Federal Register because it is informational and does not depart from current regulatory requirements and practices. The NRC intends to work with the Nuclear Energy Institute, industry representatives, members of the public, and other stakeholders to develop final guidance and revise related guidance documents.

CONGRESSIONAL REVIEW ACT

The NRC has determined that this RIS is not a major rule as designated by the Congressional Review Act (5 U.S.C. §§ 801-808).

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain information collection requirements. Therefore, the NRC did not request Office of Management and Budget (OMB) review to determine requirements under Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control number.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

/RA by JLuehman for/ /RA/

Laura A. Dudes, Director Timothy J. McGinty, Director Division of Construction Inspection Division of Policy and Rulemaking And Operational Programs Office of Nuclear Reactor Regulation Office of New Reactors

Technical Contact:

Carl S. Schulten, NRR/DSS

301-415-1192 css1@nrc.gov Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML12079A393 *via e-mail TAC No. ME8199 OFFICE NRR/DSS/STSB Tech Editor* NRR/DSS/STSB/BC NRR/DSS/D OE/EB OIS NRR/PMDA

NHilton LHill NAME CSchulten JDougherty RElliott WRuland TDonnell (NColeman for) (SWalker for)

DATE 03/20/12 03/22/12 05/07/12 05/11/12 05/21/12 05/31/12 05/31/12 NRR/DPR/PGCB/P NRR/DPR/PG NRR/DPR/PGC

OFFICE NRR/DE/EPTB OGC (NLO)* NRO/DCIP/D NRR/DPR/D

M CB/LA* B/BC*

LDudes NAME TMcMurtray AGendelman ARussell CHawes DPelton (JLuehman TMcGinty for)

DATE 06/07/12 06/22/12 08/03/12 08/03/12 08/21/12 08/23/12 08/23/12


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