05000461/FIN-2009003-04
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Finding | |
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| Title | Review of Applicability of TSSR 3.0.3 to Mulitple Missed Surveillance Intervals for Excess Flow Check Valves |
| Description | The inspectors noted that the licensee utilized the relief afforded by TSSR 3.0.3 for a missed surveillance to allow up to the limit of the specified frequency to perform missed surveillances and questioned whether doing so was appropriate for testing that had been discontinued many years before and therefore not performed for multiple test frequency periods. This issue is considered an Unresolved Item pending additional review by the NRC staff. The licensee identified that nine excess flow check valves were incorrectly removed from its Inservice Testing Program in 2002. The valves have a safety function to re-open following a design basis accident to provide instrumentation assumed to be available post accident. The ASME/ANSI Operations and Maintenance Code (OMa 1988, Part 10) would require a position verification test for these valves once every two years and an opening test once every three months, with exceptions allowed for refueling cycle frequency. The valves have not been tested since 2000. The licensee discovered this problem during its extent of condition review of another inservice testing issue. Previously, the licensee had identified that multiple spent fuel pool cooling system components (i.e., pumps and valves) were also incorrectly removed from its Inservice Testing Program in 2002. The licensee subsequently reestablished the appropriate inservice testing frequency for the spent fuel pool cooling system components and has completed the required testing. The licensees extent of condition review identified additional examples where plant components were incorrectly removed from its Inservice Testing Program, or where the applicable testing requirements were not correctly implemented in 2002. These examples included nine excess flow check valves (1CM002A, 1CM002B, 1CM003A, 1E22-F330, 1E22-F332, 1E51-F377A, 1E51-F377B, 1SM008 and 1SM009), the Division 3 shutdown service water pump discharge check valve (1SX001C), and the diesel fuel oil transfer pump discharge relief valves (1DO005A, 1DO005B, and 1DO005C). Upon discovery of the above testing issues, the licensee utilized the relief afforded by TSSR 3.0.3 for a missed surveillance to allow up to the limit of the specified frequency to perform missed surveillances. During review of the excess flow check valve testing issue, the inspectors questioned the licensee whether it was appropriate to utilize the relief allowed by TSSR 3.0.3 because these did not appear to be cases of a single missed surveillance. Recently, the NRC staff concluded in Task Interface Agreement (TIA) 2008-004, Evaluation of Application of Technical Specification (TS) 4.0.3, Surveillance Requirement Applicability, at Pilgrim; that a missed surveillance (i.e., inadvertently exceeded surveillance) is not equivalent to a never-performed surveillance for which TSSR 3.0.3 would not apply. The basis for the relief allowed by TSSR 3.0.3 is that the past surveillance testing history provides a level of confidence that the component or system is most likely operable. A surveillance that has never been performed does not have this basis for a presumption of operability. The NRC staff is currently working with the industry-sponsored Technical Specifications Task Force to develop a framework for the treatment of surveillances that have never been performed. Consistent with the level of confidence argument that was provided in TIA 2008-004, the inspectors questioned whether it would be correct for the licensee to apply TSSR 3.0.3 for the excess flow check valves. After all, the licensee removed the valves from its Inservice Testing Program and discontinued testing, now exceeding four previously defined test frequency periods without testing the valves. Therefore, the basis for a presumption of operability may not exist because the licensee was not demonstrating operability by performing the required testing of the excess flow check valves all along. An Unresolved Item (URI 05000461/2009003-04) will track the NRC staffs review of this issue to determine if additional NRC guidance is necessary to specify whether TSSR 3.0.3 applies in the case where more than one surveillance interval is exceeded. The licensee successfully completed testing one of the check valves that could be tested with the unit on line, has completed a risk evaluation, and has scheduled the performance of the other eight missed surveillance tests in the next refueling outage. The licensee has concluded that testing of the remaining eight valves would require cold shutdown conditions. The inspectors used the level of confidence argument provided in TIA 2008-004 as the basis to question the operability of the valves. Subsequently, the licensee revised the calculation defining the design basis function for the excess flow check valves to remove the active safety function of five of the check valves. Of the remaining four check valves that have an active safety function (1CM002B, 1E22-F332, 1E51-F377B, and 1SM008), one check valve (1E22-F332) was tested satisfactorily. In response to the inspectors questions, the licensee then performed an operability evaluation for the remaining three check valves. The inspectors review of this operability evaluation and resolution of questions was pending at the completion of this inspection period. An additional URI will track the NRC staffs review of the excess flow check valve operability evaluation as discussed in Section 1R15.b.(2) of this report |
| Site: | Clinton  |
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| Report | IR 05000461/2009003 Section 4OA2 |
| Date counted | Jun 30, 2009 (2009Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Draper M Mitchell M Ring S Mischke A Scarbeary B Kemker C Brown D Lords D Reeserb Kemker D Lords D Melendez_Colon E Coffman J Cassidy M Mitchell M Ring R Russell S Mischk |
| INPO aspect | |
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Finding - Clinton - IR 05000461/2009003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2009Q2
Self-Identified List (Clinton)
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