ML17264A846

Discusses Differences & Documents Util Position Concerning Reportability of Missed Surveillances on 960224 of TS & IST at Ginna Station Per Amend 61

ML17264A846
Person / Time
Site:	Ginna
Issue date:	05/14/1996
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9704020118
Download: ML17264A846 (5)

Text

CATEGORY, j.

lj, REGULAT INFORMATION DISTRIBUTION ~TEM (RIDS)

ACCESSION NBR:9704020118 DOC.DATE: 96/05/14 NOTARIZED: NO DOCKET FACIAL 50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME 'AUTHOR AFFILIATION MECREDY,R.C.'ochester Gas & Electric Corp.

RECIP;NAME RECIPIENT AFFILIATION Region 1 (Post 820201)

SUBJECT:

Discusses differences & documents util position concerning reportability of missed sgrveillances on 960224 of TS a IST at Ginna Station per Amend 61.

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NOTES:License Exp date in accordance with 10CFR2;2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-l PD VISSING, G.

INTERNAL: AEOD/SPD/RAB 1 .BQihjCCZg DEDRO 1 FILE CEN NRR/DISP/PIPB 1 FB NRR/DRPM/PECB 1 NRR/DRPM/PERB NUDOCS-ABSTRACT 1 OE DIR OGC/HDS3 1 RGN1 FILE 01 EXTERNAL: LITCO BRYCE,J H 1 NOAC NRC PDR 1 NUDOCS FULLTEXT D

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gQQNQKR GA$ AIVDEIECNIC CORPORAL i S9 EASTMAN'/AVE,ROCHESlEIi'N Y. Qdl90(X(( AREA CCOE7Id SC&27%

ROBERT C. hLECQEOY VriPwu&ht Hadst Opetol'en'.S.

May 14, 1996 KH ERR Nuc!car Regulatory Commission Region I 475 AUendale Road g~

King of Prussia, PA 19406 'RR

Subject:

Reportability'of Missed Technical Specification and Inscaicc Testing SurvciHanccs Rochester.Gas k Electric Corporation R.E. Ginna Nuclear Power Plant Docket No. 50-244 Gentlemen,'n Pebruary 24, 1996, RGB'mplemented the Improve'd Standard Technical Specifications {ISTS) at Ginna Station per Amendment No. 61. As a rmlt of this conversion, an issue has been raised witii icspc<<t to t!ic icpoitability of iiiis~cd tccliu;vul spa;ifi<<ation aud inscivico ta ting (IST) survciGanccs pcr'0 CPR 50.73. This issue is duc to thc fact that previous NRC guidance in this area (NUIT-1022) does not specificaHy apply to the ISTS in several areas. The purpose of this letter is to discuss these differences and document RGkEs position concerninS reportabiiity of these missed survcillanccs.

In 1994, the NRC published asccond draft, revision 1 to NUREG-1022. Thc purpose of N "REG-1022 was to consolidateNRC reporting guidelines with respect to.10 CFR 50.72 and 50.73 into one document to help achicvo consistency vithia, thc'nuclear power industry. MJREG-10~M w(is developed using standard tcchnical specifications (STS) which preceded the ISTS. There are several differences between these two versions of technical spcciGcations which crcatc discrepancies when attempting to use the guidance of MJRECv-1022,.especially for the reportability nf missed techniiml

. specifications and IST survei0ances. These differences are discussed in detail below.

In STS, the relevant specifications in question are 4.0.1 and 4.0.3. These are resta>M below for discussion purposes:

4.0.1 SurvciHance Requirements shall be met during the OPEBATIONAI. MODES. or conditions specified for individual I.imiting Conditions for Qperauon unle:s 'ther otherwisc stated in an individual Surveillance Requirement,

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1 4.0.3 Failure 'to perform a Surveillance Requirement within the allowed surveillsni<

interval; de6ncd by SpeciQcation 4.0.2, shall constitute noncompliance with the OPERABILITYrequiretnents for a Limitina Condition for Operation. The time limits of the ACTION requirements are applicable at the tiine it is identified that a SurvciUance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the compli.tion of the surveBIance when the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SurvciHanco Requixcmcnts do iiot have tv bc performed or inopersblc equipment.

In summary, pcr Specifications 4.0.1 and 4.0,3, if the surveiBance frequency,for a component is exceeded, the subject component mtist be declared inoperable and the limiting condition (LCO) entered; howcvcr, a delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is provided before the for'peration associated ACTIONS must bc performed.

Kith respect to reportability, the bases for Specification 4.0.3 state that "the failure to perform a surveillancc~thin the provisions of Specification 4.0.2 is a violation of a Tcchnical SpccUicatioii

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requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73{a)(2)(i)(B) because itis a condition prohibited by the pla'nt's Technical Specifications." &HAG-1022 further expands on this by stating that a missed technical specification or TAT mirveillancc inust be reported when "enough time has elapsed that, as e result of the missed surveillance, a TS controlled system must bc dcchucd inopcrablc and thc LCO action suiiciiicut has been exceeded." That is, an LEE is required if the time period between the last test and thc test being performed is. greater than the speciGcd testing interval (multiplied by 1.25'per Specification'4.0.2) plus thc completion time for restoring the ~R'ected component to operable status. Jn this instance, the aKectcd component may be inoperable for a longer period of tiinc than the STS would allow (i.e., the plant is in a condition

.piohibitcd by technical specifications).

ln ISTS, there arc significant differences from Specifications 4.0. I and.4.0.3. The new versions of these Specifications arc rc8tatcd below from the Ginna Station tc"hnical, spccilicutions:

II Sk 3.0.1 SR shall bc met during thc MODES or other specified conditions in the Applicabilityfor indivirhisl I.COs, unless otherwise stated in the SR. Failure

. to meet a SR, whcthcr such failure is expmenced during the performance of ilia Suivcillancc or between performances of thc Surveillance, shall'be Failure to meet thc LCO: Failure to perform a Surveillance within the specified Frequency shaH'bc failure to meet the LCO except as provided in SR.3.0.3. Surveillance do not have to be performed on inopcrablc cquipmcnt, or variables outside specified limits.

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'R 3.0.3 Ifit is discovered that a Surveillance was not performed within its specified Fiequcncy, then compliance with the requirement to declare the LCO not met may be delayed, &om the time of'discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the lirrril of the specified Frequency, whichever is less. This delay is permitted to allow performance of the Surveillance, Ifthe'Surveillance is not performed within the delay period, the LCO must immediately bc declared not met, and the applicable Condition(s) must be entered.

Tlicrefore, pcr SR 3.0.1 and 3,0,3, ifa surveillance frequency is exceeded, a delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is provided in order to paform the surveillance prior to declaring any component inoperablc and the LCO not met. This is a significant rliffexence from STS in which the coinponent is first declared inoperablc and then a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay is provided prior to per&rming thc required actions. Kn addition, with respect to repuitability of a missed survcHlance, there is no longer any discussion in the bases for SR 3.0,3.

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Based on these difFcreneee, it'is RQkB's position that a.missed surveillance test is not a rcportabio event (i.c., LER) per the ISTS. At no time is the plant outside the ta:hnical specifications in this instance siircc no equlpmcm ls declared inoperable until thc allowed delay period from time of discovery has been exceeded (e.g, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) or the surveillance is failed upon its pcrfnrmanr.e.

These actions are speci6caHy piovided by SR 3.0.3 v hich is part of the technical specifications'per 10 CPR 50.36. In addition, a missed survciHance ta typically in adrnioistiative issue that does not directly affect plant operation unless thc affected component is failed. Therefore, if upon peforinance of the missed surveillance a'requited component is discovered inoperable, an LBR will be generated in accoahncc with the guidance provided in hKG~-1022 since tho componerrt mrry have been inoperable for a longer period of time than aHovIcd by the ISTS.

It is noted that ifa missed surveillance test indicates a substantial breakdown in the surveillance testing progrun (e.gsurveillance test has never been performef}, it vmuld be reported per 10 CFR. 50.73(a)(%Xi)(B). This is. consistent with NUREG 10 2 guidanco for rcportability of adruiriisu'aiivc control reIated errors. Since the IST program mpircmcrits are in the administrative controls section in ISTS (versus Specification 4.0.5 per STS), this guidance would also apply to raisscd or deficient IST program requirements.

Therefore, eFcctr'vo February 24, 1996, ROBOMB willonly generate an L ER per 10 CFR 50. /3 upon

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missed technical specification or IST surveillance if:

A component niust be declared iirnlr~sable and the time period between two rrucccssful surveHIMicc tests is greater'than 1.25 time the specified frequency plus the completion time for restoring the comporrerri io operable.status; or.

4 (2) Vhc missed surveillance(s) indicate a substantial breakdown in the surveillance testing program,

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Plebe contact George Wrobef, Manager of Nuclear Safety and Licensing at (7l6) 724-8070 ifyou require any further information. RGEcB would like to suggest that the NRC consider these issues in any future revisions of MJRFG-1022 Ver ly yours, Robert C Mecredy MDE845 XC: U.S. Nuclear Regulatory Commission Mr. Guy Vissing (Mail Stnp 1467)

PWR Project Directorate I-j Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Mr. Chris Grimes (Mail Stop i 1222)

Chief, Technical Specifications Branch Washington, D.C. Z0555 Ginna Senior Resident hspector TOTAL P.83