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Forwards Summary of 880526 Enforcement Meeting W/Util in Arlington,Tx Re Violations Noted in Insp Repts 50-498/88-11 & 50-498/88-24.List of Attendees & Licensee Presentation Matl Encl
	ML20155D006
Person / Time
Site:	South Texas
Issue date:	06/08/1988
From:	Callan L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Goldberg J; HOUSTON LIGHTING & POWER CO.
References
	NUDOCS 8806140436
	Download: ML20155D006 (12)
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JUN 8 1988 In Reply Refer To:

Docket: 50-498 EA 88-112 Houston Lighting & Power Company ATTN: J. H. Goldberg, Group Vice President, Nuclear P.O. Box 1700 Houston, Texas 77001 Gentlemen:

This documents the enforcement meeting held on May 26, 1988, in the Region.IV office between members of your staff and Region IV representatives, as identified in attendance list. The meeting was held to discuss apparent violations of NRC requirements identified in Inspection Reports 50-498/88-11-dated April 28, 1988, and 50-498/88-24 dated May 24, 198 Houston Lighting & Power Company presented their views on the apparent violations including the causes and corrective actions either taken or planne The topics covered are described in the enclosed meeting summary, it is our opinion that this meeting was beneficial and provided a better understanding of the concerns identified during the inspectio In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Roo Should you have any questions concerning this letter, we will be pleased to discuss them with yo

Sincerely, Otiginal Signed By:

l'. J. CALLAN L. J. Callan, Director Division of Reactor Projects

Enclosures:

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1. Meeting Notice 2. Meeting Suninary

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8 ARLINGTON. TEXAS 76011-MAY 2 01988 frTICE OF SIGNIFICANT MEETING Name of Licensee: Houston Lighting and Power Name of Facility: South Texas Project Docket Number: 50-498 Date and Time of Meeting: May 26, 1988, 10:00 th Floor Conference Room Location of Meeting: Region IV Office Arlington, Texas Purpose of Meeting: Enforcement Conference to discuss three recent violations of NRC requirements: (1) The isolation of 7 of the 12 feedwater flow transmitters (FWFT) while the plant (Unit 1) was in operational Mode 3 as described in NRC Inspection Report 50-498/88-11, dated April 28, 1988, .

(2) inadequate review of low power physics test results and (3) improperly I entering Technical Specification 3.0.3.. when 3 of the 4 power operated relief valves (PORVs) were inoperable as described in NRC Inspection Report 50-498/88-2 NRC Attendees:

L. J. Callan, Director, Division of Reactor Projects A. B. Beach, Deputy Director, Division of Reactor Projects-G. L. Constable, Chief, Project Section 0 D. R. Carpenter, Senior Resident Inspector J. Bess, Resident Inspector H. Scott, Acting Enforcement Officer G. Dick, Project Manager, NRR Licensee Attendees:

J. Goldberg, Group Vice President G. Vaughn, Vice President, Nuclear Operations W. Kinsey, Plant Manager M. McBurnett, Manager, Support Licensing NOTE: Attendance at this meeting by NRC personnel other than those listed I above should be made known by 4 p.m. on May 25, 1988, via telephone call to G. L. Constable FTS 728-815 w

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Notice of Significant Licensee 2 Meeting

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Distribution:

J. M. Taylor, DEDR0 T. E. Murley, D/NRR F. J. Miraglia, ADP/NRR ADT/NRR,(P-415) 1 J. Lieberman, D/0E l L. J. Chandler, Asst. GC for En !

P. Xadambi, Project Manager, NRR ,

T. O. Martin, DEDRO Staff l R. D. Martin, RIV 1 J. Gilliland, PAO, RIV NRC Attendees l DMB(IE45)

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I Enclosure 2 MEETING - MAY 26, 1988 l

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l Licensee: Houston Lighting & Power Company (HL&P) l Facility: South Texas Project (STP), Unit 1 i

Docket: 50-498 Operating License: NPF-76 !

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Subject: Enforcement Ccnference

, Concerning NRC Inspection Findings (NRC Inspection Reports

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50-498/88-11; 50-498/88-24 On May 26, 1988, representatives of HL&P met with NRC Region IV and NRR personnel in the NRC office in Arlington, Texas, to discuss the findings documented in NRC Inspection Report 50-498/88-11, dated April 28, 1988, and 50-498/88-24, dated May 24, 1988. The attendance list and the licensee ,

presentation material are attached. The meeting was held at the request of the '

NRC, Region I l

The licensee discussed root causes for the events and corrective actions to' ,

preclude recurrence, l l

The NRC staff expressed particular concern regarding the three events discussed ,

below, Voluntary Entry Into Technical S)ecification (TS) 3.0.3 on April 24, l 1988, to Test Steam Generator P01V's l The licensee agreed that a shift supeNisor should not voluntarily enter TS 3.0.3 and they have taken appropriate correcti.ve action to prevent future occurrence. HL&P management said that an important root cause of this violation was the ambiguous wording of the techoical specificatio The licensee believes that they self identified this issue although i.:icir reaction to the violation did not appear to begin until after the issue was raised to a shift supervisor by the NRC Senior l Resident Inspecto Seven of Twelve Feedwater Flow Transmitters Found Isolated While l in Mode 3 - TS 3. The licensee found that their program for system alignment was wea This problem was self identified and no additional examples we,e found during a 100 percent double verification. Extensive corrective actions were described which appeared to be adequate. Although this

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was clearly a violation of NRC requirements when it occurred, the licensee has requested and received approval to delete this requirement from the T ~ Calculation Error - Isothermal Temperature Coefficient of Reactivity The licensee acknowledged the violatio Inadequate reviews of tes data was a.significant cause of the event. No other tests were affected.and a review of 63 other tests did not disclose any significant. error The licensee also discussed their evaluation of two additional violation .

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Attendees South Texas Project Unit-1 Enforcement Conference May 26, 1988 Houston Lighting & Power J. H. Goldberg, Group Vice President, Nuclear G. E. Vaughn, Vice President Nuclear Operations

- H. Kinsey, STP Plant Manager M. A. McBurnett, Manager, Operations Support Licensing

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Central Power & Light Company B. McLauchlin, STP Activities City Public Service Board - San Antonio M. T. Hardt, Director, Nuclear Division U.S. Nuclear Regulatory Commission -

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L. J. Callan, Director, Division of Reactor Projects (DRP)

J. L. Milhoan, Director, Division of Reactor Safety (DRS)

H. L. Scott, Enforcement-G. L. Constable, Chief, Projects Section D (DRP)

G. F. Sanborn, Enforcement Officer D. R. Carpenter, Senior Resident Inspector (DRP)

J. E. Bess, Resident Inspector (DRP)

E. J. Holler, Chief, Project Section C (DRP) i J. B. Baird, Technical Assistant (DRP) '

G. Dick, Froject Manager (NRR)

J. P. Clausner, French Atomic Energy Commission j W. C. Seidle, Chief, Test Programs Section (DRS)

A. R. Johnson, Reactor Inspector (DRS) I D. M. Hunnicutt, Senior Projects Engineer (DRP) l T. F. Stetka, Chief, Plant Systems Section (DRS) 1 I

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PROJECT l: NRC ENFORCEMENT CONFERENCE

> ARUNGTON, TEXAS MAY 26,1988

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AGESDA /

l- e INTRODUCTION - J.H. GOLDBERG i

i e ENFORCEMENT ISSUES - W.H. KINSEY l

e VOWNTARY ENTRY INTO

, T.S. 3.0.3 / 4-24-88

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o ENTRY INTO MODE 3 WITH FEEP' VATER TRANSMITTERS l'

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! e INADEQUATE REVIEW OF LOW l

POWER PHYSICS iwis

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r CONDITIONS FOR ENTRY l INTO T.S. 3.0.3 / 2 -12 - 8 8 i

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e CONCERNS WITH LIFTED WIRE, JUMPER, & FUSE CONTROL j PROGRAM

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e QUESTIONS / ANSWERS

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EVENT

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VOLUNTARY ENTRY INTO TECHNICAL SPECIFICATION 3.0.3 ON j APRIL 24,1988 TO TEST STEAM GENERATOR PORV'S 18 AND 1C l

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CONCERN ABOUT VOLUNTARY ENTRIES INTO T.S. 3.0.3 RAISED j ON MAY 1,1988

COMMENCED UNIT SHUTDOWN ON MAY 1,1988

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ROOT CAUSE

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! e THE SHIFT SUPERVISOR MADE AN INTERPRETATIONOF THE l .. TECHNICAL SPECIFICATION. At ItR CAREFUL REVIEW OF THE i BASES HE CONCLUDED THAT IN THIS PARTICULAR CASE HE

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CORRECr1VE ACTION

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OPERATIONS SUPERVISOR ISSUED NIGHT ORDER ON MAY 2,1988 PROHIBmNG INTENTIONAL ENTRY INTO T.S. 3.0.3 TO PERFORM MAINTD4ANCE OR It.silNG.

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l # PLANT MANAGER MET WITH ALL UNIT ONE SHIFT SUPERVISORS

! ON MAY 11,1988 TO DISCUSS EVENT AND TO ENSURE PROPER

!. UNDERSTANDING ON ENTRY INTO T.S. 3.0.3

, # PLANT MANAGER ISSUED MEMORANDUM ON SUBJECT ON MAY 12,1988 i 4

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. # TECHNICAL SPECIFICATION INTERPRt'.. .JN PREPARED ON MAY 12,1988

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i # PLANT CONDUCT OF OPERATIONS PROCEDURE, OPGP03-ZO-0004 TO BE l REVISED TO REFLECT PROPER PHILOSOPHY ON ENTRY INTO T.S. 3.0.3 BY j

JUNE 6,1988

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,3,/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

//4.0 APPLICABILITY J.IMITING CONDITION FOR OPERATION _ _ _ _

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3. Compliance with ...

3. Noncompliance with ...

3. When a Limiting Condition for Operation is not met, except as provided in the associated ACTION '

requirements, within i hour action shall be *

initiated to place the unit in a HvDE in which the specification does not apply by placing it, as applicable, in At least HOT STANDBY within the next 6 i hours, !

I At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and , At least COLD SHUTDOWN within the subsequent 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Where corrective measures are completed that permit operation under the ACTION requiroments, the actior may be taken in accordance with the specified time limits as measured from the timo of failure to meet the Limiting Conditions for Oporatio Exceptions to these requirements are stated in the individual apecifieation j This specification is not applicable in MODE 5 or .

3. Entry into ...

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3.4.0 APPLICABILITY BASES (Continued)

limits of the ACTION requirements are applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to comply with ACTION requirements, the plant may have entered a MODE in which a new specification becomes applicable. In this case, the time limits of the ACTION requirements woald apply from the point in time that the new specification becomes applicable if the requirements of the Limiting Condition for Operation are not me Specification 3. establishes that noncompliance with a specification exists when the requirements of the Limiting Condition or Operation are not met and the associated ACTION requirements have not been implemented within the specified time interval. The purpose of this specification is to clarify that (1) implementation of the ACTION requirements within the specified time interval constitutes compliance with a specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition for Operation is restored within the time interval specified in the associated ACTION requirement Specification 3. establishes'the shutdown ACTION requirements that must be implemented when a Limiting Condition for Operation is not met and the condition is not specifically addressed by the associated ACTION requirement The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown MODE when plant operation cannot be maintained within the limits for safe operation defined by the Limiting Conditions for Operation and its ACTION requirement It is not i n t e n rt e d to ba used as an operational convenience which permits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant aystama or componenta baing inoperabl One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time permits the oporator to coordinate the redaction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum, required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applie If remedial measures permitting limited continued operation of the f acility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance for the completion of the required action SOUTH TEXAS - UNIT i B 3/4 0-2

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jp n n as%, U.NITED STATES

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MEMORANDlH FOR: William T. Russell, Regional Administrator, Region I ,

J. Nelson Grace, Regional Administrator, Region II

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A. Bert Davis, Regional Adnillistrator, Region III Robert D. Martin, Regional. Administrator, Region IV j John B. Martin, Regional' Administrator, Fegion V FROM: Thomas E. Murley, Director Office of Nuclear Reactor Regulation

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SUBJECT: INTENTIONAL ENTRY INTO TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION 3. This is in response to Region Y's memorandum of March 18, 1937, (Enclosure 11 wherein they referred to an inappropriate use of Technical Specification 1 l Limiting Condition for Operation (LCO) 3.0.3 by the Palo Verde licensee. It was suggested that it might be beneficial for i:RR to issue some generic I com.unication to reiterate NPC's positicn on the intended purpose of LC0 3. and clarify the NRC's expectation concern?ng licensee management ccntrol of entry into i LCO 3.0.3 is not intended to be used as an operational convenience which pemits redundant safety systems to be out of service for a limited pericd of time. Its intended purpose is to provide guidance on the time limits for an

"orderly" shutdown when the individual Limiting Conditions for Operation or ACTION statements in other specifications cannot be complied with. Voluntary entry into LCO 3.0.3 deliberately removes the last echelon of defense against deleter:ous events by all.owing removal of a system from service when its redundant counterpart is alreedy out of service or inoperable. An action such as this would. show a significant disregard for plant safety and is unacceptabl It should also be emphasized that removal of a system from service is justified only for test, maintenance, or repair purpose On June a,1987. as part of the short tem Technical Specifications Improvement Program we issued Generic letter 87'-09 which, among other things, addresses this subject in a rewritten BASES for LCO 3.0.3 (Enclosure 2). Additionally, we recomend that all Regions increase communication with resident inspectors and plant management on this subject, thereby promoting a heightened awareness

~ by the inscectors, licensee management and plant personnel of the intended limited use of LC0 3.0.3. We'believe these actions will be sufficient to address this proble . . '

. Thomas E. Furley, L mor Office of Nuclear Reactor Regulation Enclosures: >

<<a o As stated 4 M~f{7 k ' o -

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WALNUT CREE K.CALIFCRNI A N696 ggg 151937 MEFORANDUM FOR: Harold R. Denton, Director

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Office of Nuclear Reactor Regulation FRCH: J. B. Martin, Regional Administrator Region Y .

SUBJECT: INTENTIONAL EKTRY INTO TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION 3. '

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As the result of our review of a recent event which occurred at the Palo Yerde site, wherein a shift supervisor intentionally bypassed an engineered safety feature as an apparent operational convenience, and thereby entered liciiting condition for operation (LCO) 3.0.3, Region Y has concluded that it may be benef.'cial for the nRC to reit' rate e to both, the NRC staff and power -

reactor licensees, the intent of LCO 3.0.3 and our expectations concerning licensee canagement control of entry into LCO 3.0.3. Licensee entry into this section of the Technical Specifications appears to occur for one of the following three reasons:

Unintentional entry due to equiptrent failure, design error, precedural error, or personnel error, which places the facility outside the ACTION statecent of other LCO' *

Intentional entry to perform a maintenance'or surveillance task on equipment with scoe type of unusual design feature which necessitates entry into LCO 3.0.3 to perfonn the tas *

Intentional entry for operational convenienc Region Y recognizes that occasional entry into LCO 3.0.3 for surveillance or maintenance purposes r.ay be appropriate, however, this activity should be well thcusht-out in advance and strictif controlled by r.anage:ent oversight and apprcpriate procedures. Further, licensees should be encouraged to eliminate, where practical, those design features which result in repeateo entries into LCO 3.0.3. Region Y contends that intentional entry into LCO 3.0.3 for operational convenience'should not be r,ade, except under extremely unusual circumstances where,a detailed review by the licensee has concluded that no reduction in safety.will resul Althcugh this issue may have been addressed in past NRC guidance to licensees, a reiteration of the NRC positiwr n ntry into LCO 3.0.3 via an Information Notice or a Generic Lette.rdppears a propriat . Nl

..B. Martin, Regional Ad:.inistrator Region'Y

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BASES

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Teplementec wnen a Limiting Condition for Operation d ACTION requirements.

. condition is not specifically addressed by the . associate The purpose of this specification is to delineate the time limits for placing '

the unit in a safe shutdown MODE when plant operation cannot

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for be maintained within the limits for safe operation defined by the Limiting ConditionsIt is not inten Operation and its ACTION requirement operational convenience which permits One hour is(routine) volun

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result in redundant systems or components being inoperabl allowed to prepare for an orderly shutdown,before initiating a change in plant operatio T,his time permits the operator to coordinate the reduction in ele:trical generation with the load dispatcher to ensure the stability andThe availability of the electrical gri NODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cocidown capabilities of the f acility assuming only the minimum req ecuipment is OPERASLE, primary ecolant system and the potential for a pla safety systems order conditions for which this specification applie If remedial reasures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, th may be terminated.from the point in tire there was a f ailure to meet a limiting Conditio Therefore, the shutdown may be terminated if the ACTION Operatio requirements have been met or the time limits of the ACTION requirenents have not expired, thus providing an allowar.ce for the completion of the required action .

pWR STS

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Info UNITED STATES Recd: G/43/

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NUCLEAR REGULATORY COMMISSION WASHING TO N, D. C. 20555 . .

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%,..... [cu June 4, 1987 gu3 p g sm n

/t i TO ALL LTGHTWATETREACTOR LICENSEES AND APPLICANTS

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Gentlemen: ,

SUBJECT: SECTIONS 3.0 AND 4.0 0F THE STANDARD TECHNICAL SPECIFICATIONS (S ON THE APPLICABILITY OF LIMITING CONDITIONS FOR OPERATION AND .

SURVEILLANCE REQUIREMENTS (Generic Letter 87-09)

As a part of recent initiatives to improve Technical Specificati'ons (TS), the NRC, in cooperation with the Atomic Industrial Forum (AIF), has developed a program for TS improvements. One of the elements of this program.is the -

implementation of short-term improvements to resolveimediate concerns that have been identified in investigations of TS problems by both NRC and AI The guidance provided in this generic letter addresses three specific problems that have been encountered with the general requirements on the appitcability of Limiting Conditions for Operation (LCO) and Surveillance Requirements in Sections 3.0 and 4.0 of the ST There are five enclosures to this Generic Letter. Enclosure 1 applies to both PWR and BWR STS and provides a complete discussion of the three problems and the staff's position on acceptable modifications of the TS to resolve them. These modifications should result in improved TS for all plants and are consistent with the recomendations of NUREG-1024, "Technical Specifications -- '

Enhancing the Safety Impact" and the Comission Pc4 icy Statement on Technical Specification Improvements. Enclosures 2 and 4 provide Sections 3.0 and 4.0 of the PWR and BWR STS, respectively, which incorporate the modifications being made by this Generic Letter. Enclosures 3 and 5: (a) provide the staff's update of the bases for the PWR and BWR STS, respectively; (b) reflect the modifications of Sections 3.0 and 4.0 of.the STS; and (c) include . improved ,

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bases for the unchanged requirements in these section The staff concludes that these modifications will result in improved TS for all plants. Licensees and applicants are encouraged to propose changes to their TS that are consistent with the guidance provided in the enclosures; l

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however, these changes are voluntary for all licensees and i:urrent OL applicant The staff would like to point out three important points connected with the present TS effort. First, it is aware that the TS can be clarified, l simplified, and streamlined both as a whole and with respect Nonetheless,to the in

specifications that are the subject of this Generic lette keeping with its short-term and purposefully narrow focus, it decided to ketp these proposed modifications: (a) focused on the three problems; (b) relatively ;

simple; and (c) consistent with the phrasing of existing TS. Second, after l

the resolution of these and other identified TS problems, the staff will

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notify licensees and applicants of its co'nc'1usions and resulting proposals for additional short-term TS improvements. Finally, the staff is not proposing to formally amend the STS at this time. Instead the changes will be factored into .

the development of the new STS anticipated as a part of the implementation o the Comission's Policy Statement on Technical Specification Improvement y .-

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The following is a surmiary of the three problerns covered by the enclosure The first problem involves unnecessary restrictions on mode changes by ~

Specification 3.0.4 and inconsistent application of exceptions to it. The <

practical solution is to change this specification to define the conditions-under which its requirements apply. With respect to unnecessary mode chary s,

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Specification 3.0.4 unduly restricts facility operation when confomance with Action Requirements provides an acceptable' level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements. The solutiort also resolves the problem of inconsistent application of exceptions to Specification 3.0.4: (a) which' ,

delays startup under conditions in which confomance to the Action Requirements establishes an acceptable. level of safety for unlimited continued operation of the facility; and (b) which delays a return to power operation when the facility is required to be in a' lower mode of operation as a consequence of other Action Requirement The second problem involves unnecessary shutdowns caused by Specification 4.0.3 when surveillance intervals are inadvertently exceede The solution is to clarify the applicability of the Action Requirements, to specify a specific acceptable time limit for completing a missed surveillance in certain circumstances, and to clarify when a missed surveillance constitutes a violation of the Operability Requirements of an LCO. It is overly conservative to assume that systems or components tre inoperable when a surveillance has not been perfomed because the vast majority of surveillances do in fact demonstrate that systems or components are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the performance of a Surveillance Requirement. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time for perfoming a missed surveillance before Shutdown Requirements apply, the TS should include a time limit that allows a delay of required actions to pemit the perfomance of the missed surveillance based on consideratien of plant conditions, adequate planning, availability of i personnel, the time required to perfom the surveillance, and, of course, the safety significance of the delay in completing the surveillance. The staff has concluded that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements ;

are less than this limit, or when time is needed to obtain a temporary waiver of I the Surveillance Requiremen l The third problem involves two possible conflicts between Specifications 4. )

and 4.0.4. The first conflict arises because Specification 4.G.4 prohibits entry into an operational inode or other specified condition when Surveillance i Requirements have no.t been perfomed within the specified surveillance I interval. A conflict with this requiremen_t exists when a mode change is l required as a consequence of Action Requirements and when the Surveillance Requirements that become applicable have not been perfomed within the specified surveillance interval. Specification 4.0.4 should not be used to prevent passage through or to operational modes as required to comply with Action

. Requirements because to do sq: (a) would increase the potential for a plant

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l usset; and (b) would challenge safety systems. Also, certain surveillances' I s,ould be allowed to be serformed during a shutdown to comply with , Action 1 Requirements. Along wit 1 the modification of Specification 4.0.3 to pemit a !

- delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the applicability of Action Requirements, *

Specification 4.0.4 has been clarified to allow passage through or to l- I

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operational modes as required to comply with Action Requirement .

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A second conflict could arise because, when Surveillance Requirements can only l be completed after entry into a mode or specified condition for which the Surveillance Requirements apply, an exception to the requirements of i Specification 4.0.4 is allowed. However, upon entry into this mode or '

condition, the requirements of Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed surveillance interval. Therefore, to avoid any conflict between Specifications '

4.0.3 and 4.0.4, the staff wants to make clear: (a)that it is not the intent i of Specification 4.0.3 that the Action Requirements preclude the performance of surveillances allowed under any exception to Specification 4.0.4; and (b) that the delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in Specification 4.0.3 for the applicability of Action Requirements now provides an appropriate time limit for the completion of those Surveillance Requirements that become applicable as a consequence of I allowance of any exception to Specification 4. If you have any questions on this matter, please contact your project manage

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FrankJ.9iiragla,AsscciateDirector for Projects Office of Nuclear Reactor P.egulation

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Enclosures: .

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Enclosure 1 to Generic Letter 87-09

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ALTERNATIVES TO THE STS REQUIREMENTS TO RESOLVE THREE SPECIFIC PROBLEMS WITH LIMITING CONDITIONS FOR OPERATION AND SUPl<EILLANCE REQUIREMENTS

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INTRODUCTION ,

Generic Letter 87-09 discusses three problems regarding the general requirements of Sections 3.0 and 4.0 of the STS on the applicability of Limiting Conditions

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for Operation (LCO) and Surveillance Requirements. The guidance provided in this enclosure addresses :lternatives to.the Standard Technical Specifications (STS) to resolve these problem Problem #1 -- UNNECESSARY RESTRICTIONS ON MODE CHANGES (Specification 4.0.3)

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BACXGROUND The definition of an LCO is given in 10 CFR 50.36 as the lowest functioral capability or perfomance level of equipment required for safe operation of the facility, Further, it is stated that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remdial action permitted by the TS until the condition can be me Consistent with NRC's regulatory requirements for an LCO, the TS include two basic types of Action Requirements that are applicable when the LCO is not met. The first specifies the remedial actions that permit continued operation of the facility not restricted by the time limits of Action Requirements. In this case, confomance to the Action Requirements trovides an acceptable icvel of safety for continued operation of the facility, and operation may oroceed indefinitely as long as the remedial Action Requirements are met. The second .

type of Action Requirement specifics a time limit in which the LCO must be met. This time limit is the time allowed to restore an inoperable system or component to operable status or to restore parameters within specified limits.

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If these actions are not completed within the allowable outage time limits, action must be taken to shut down the facility by placing it in a mode or condita of operation in which the LC0 does not appl l Specilication 3.0.4 of the ST'S states tilat entry into an operational mode or other specified condition shall not be made unless the LCO is met without reliance on the provisions of the Action Requirements. Its intent is to ensure that a higher mode of operation is not entered when equipment is inoperable or when parameters exceed their specified limits'. This precludes a plant startup when actions are being taken to satisfy an LCO, which -- if not completed within the time limits of the Action Requirements -- would result in a plant shutdown to comply with the Action Requirement .

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The BWR STS use the ten "operational co}idition" instead of the tem '

"operational mode" that is used in PWR STS. As used here, "operational mede" ,

l means "operational condition" for BWRs, ,

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l Specification 3.0.4 also precludes entering a mode or specified c'ondition if an "

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LCO is not met, even if the Action Requirements would pemit continued operation '

of the facility for an unlimited period of time. Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not. apply. However, exceptions to Specification 3.0.4 have not been consistently applied and their b::es are not -

well documented. For example, approxinately two-thirds of the actions which permit continued operation in the Westingbouse STS are exempt from Specifica' tion 3.0.4. Although the staff encourages the maintenance of all plant systems and components in an operable condition as a good practice, the TS generally have not precluded entering a mode with inoperab,le equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operatio * -

STATEMENT OF THE PROBLEM - -

Inconsistent application of exceptions to Specification 3.0.4 impacts the operation of the facility in two ways. First, it delays startup under conditions in which confomance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facilit Second, it delays a return to power operation when t1e facility is required to be in a lower mode of operation as a consequence of other Action Requirement In this case, the LCO must be met without reliance on the Action Requirements before returning the facility to that operational mode or, other specified condition for which unlimited continued operation was previously pemitted in accordance with the Action Requirements. -

STAFF POSITION .

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Specification 3.0.4 unduly restricts facility operation when confomance to the Action Requirements provides an acc'eptable level of safety for continued operation. For an LCO that has Action Pequirements pemitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be pemitted in accordance with those Action Requirements. This is consistent with NRC's regulatory requirements for an LCO. The restriction on a change in operational modes or other specified conditions should apply only where the Action Requirements f establish a specified time interval in which the LCO must be met or a shutdown i of the facility would be recuired. However, nothing in this staff position I sho~uld be interpreted as encorsing or encouraging a plant startup with inoperable equipment. The staff believes that good practice should dictate that I the plar.t startup should nomally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rul * -

CHANGE TO SPECIFICATION 3. ,

The practical solution to this problem is not the modification of TS to note that Specification' 3.0.4 does not apply, but rather a change to Specification j 3.0.4 to define the conditions under whichMts' requirements do appl ~

Therefore, Specification 3.0.4 will be revised to state: ,

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- "Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met !

within a specified time interva Entry into an OPERATIONAL MODE or !

specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for ,

an unlimited period of time." -

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CHANGES TO INDIVIDUAL SPECIFICATIONS EXEMPT FROM SPECIFICATION 3. .

As a consequence of the modification describedibove to Specification 3.0.4, individual specifications with Action Requirements pemitting continued operation '

no longer need to indicate that Specification-3,0.4 does not apply. They should be revised to delete the noted exception to avoid confusion about the applicability of Specification 3.0.4. However, exceptions to Specification 3.0.4 should not be deleted for individual specifications if a mode change would be precluded by Specification 3.0.4 as revised. For example, some specifications ,

would not satisfy the provisions under which mode changes are pemitted by the revision to Specification 3.0.4 and, therefore, the exception to Specification 3.0.4 need not be deleted. It is not the staff's intent that the revision of Specification 3.0.4 should result in more restrictive requireinents for individual specification Problem #2 -- UNNECESSARY SHUTDOWNS CAUSED BY INADVERTENT SURPASSING OF SURVEILLANCE INTERVALS (Specification 4.0.3)

BACKGROUND

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Surveillance Requirements are defined in 10 CFR 50.36 as those requirements relating to test, calibration, or inspection to ensure that the necessary ,

quality of systems and components is maintained, that the facility will be within the safety limits, and that the LCO will be met, j i

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Consistent with the NRC's regulatory framework for Surveillance Requirements, Specification 4.0.3 states that the failure to perfom a surveillance within the specified time interval shall constitute a failure to meet the LCO's Operabilit Requirements. .Therefore, if a Surveillance Requirement is not met as a result j of the failure to schedule the perfomance of the surveillance, the LCO would i

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not be met. Consequently, the LCO's Action Requirements must be met as when a surveillance verifies that a system or component is inoperabl ' Generally, the Action Requirements include a specified time interval (i.e.,

allowable outage time limit) that permits corrective action to be taken to satisfy the LCO. When such a specified time interval is included in the Action Requirements, the completion of a missed surveillance within this time interval '

satisfies Specification 4. ,

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STATEMENT OF PROBLEM Some Action Requirenent's have allowable outage time limits of only one or .two

. hours and do not establish a practical time limit for the completion of a missed Surveillance Requirenent. If surveillances cannot be completed within these .

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time limits, a plant shutdown would usually be required. Even if the Action -

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Requirements include remedial measures that would pemit continued operation, they may be stated in such a way that they could prevent the perfomance of the -

required surveillance. A plant shutdown would also be required if the missed surveillance applies to more than the minimum number of systems or components reouired to be operable for operation under the allowable outage time limits of -

the Action Requirement In this case, the individual specification or ,

Specification 3.0.3 would require a shutdow If a plant shutdown is required before a missed surveillance is completed, it is likely that it would be conducted when the plant is being shut down because completion of a missed surveillance would terminate the shutdown requiremen This is undesirable since it increases the risk to the plant and public safety for two reasons. First, the plant would be in a transient state involving changing plant cenditions that offer the potential. for an upset that could lead ,

to a demand for the system or component being tested. This would occur when the system or component is either out of service to allow perfomance of the surveillance test or there is a lower level of confidence in its operability because the nomal surveillance interval was exceeded. If the surveillance did demonstrate that the system or component was inoperable, it usually would be preferable to restore it to operable status before making a major change in plant operating conditions. Second, a shutdown would increase the pressure on the plant staff to expeditiously complete the required surveillance so that the plant could be returned to power operation. This would further increase the potential for a plant upset when both the shutdown and surveillance activities place a demand on the plant operator *

STAFF POSITION

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It is overly conservative to assume that systems or components are inoperable when a surveillanca requirement has not been performed. The opposite is in fact the case; the vast majority of surveillances demonstrate that systems or components in fact are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the perfomance of the required surveillance. Because the allowable outage time limits of some Action Requirements do not provide an appropriate time limit for perfoming a missed surveillance before shutdown requirements may apply, the TS should include a time limit that would allow a delay of the required actions to pemit the perfomance o.f the missed surveillanc This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perfom the surveillance, as well as the safety significance of the delay in completion of the surveillance. After reviewing possible limits, the staff has concluded that, based on these considerations, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the Action Requirements are less than this time limit or when shutdown Action Requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completino the sur.veillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Actinn Pequirements

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before the surveillance can be complet,e . .

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A1though a missed surveillance would generally be completed in .liss time than

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this 24-hour limit allows, special circumstances may require additional teme to r

ensure that the surveillance can be conducted in a safe manner. The time limits of Action Requirements for surveillances should start when it is :

identified that Surveillance Requirements have not been perfomed, except when l

the 24-hour delay is allowed in the implementation of the Action Requirement *

j Where the 24-hour time limit is allowed, the time limits of the Action - .

l Requirements are applicable either at the end of the 24-hour limit if the surveillance has not been completed or at the time the surveillance is i

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performed if the system or component is found To be inoperabl '

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Several issues need to be clarified regarding the additional 24-hour time limi First, this limit does not waive compliance with Specification 4. Under Specification 4.0.3, the failure to perform a Surveillance Requirement will continue to constitute noncompliance with the Operability Requirements'of an LCO and to bring into play the applicable Action. Requirement Second, Specifications 3.0.2 and 4.0.3 should not be misinterprete Specification 3.0.2 notes that a TS is being complied with when the Action Requirements are met within the specified time intervals. Although Specification 4.0.2 provide * an allowance for extending the surveillance interval and allows for the c w letion of the surveillance within this time interval without violation of t11s Specification, under Specification 4. nonperformance of a Surveillance Requirement, within the a' lowed surveillance interval defined by Specification 4.0.2, constitutes a violation of the Operability Requirements of an LCO, as defined by Specification 4.0.3, and is subject to enforcement actio To avoid any conflict among or misreading of SpeciYications 3.0.2, 4.0.3, and 4.0.2, the staff wishes to make clear (1) that Specification 3.0.2 shall not be '

construed to imply.that the completion of'a missed surveillance within the allowable outage time limits of the Action Requirements -- whether or not the additional 24-hour time limit is included -- negates the violation of Specification 4.0.3, and (2) that the failure to perfom a surveillance within the allowable a reportable surveillance event under 10 CFR interval defined by(Specification 50.73(a)(2)(1) B) because it is a 4.0.2 constitutes condition prohibited by,the plant's T ,

Third, even though an additional 24-hour time limit may apply for missed surveillances, another consideration is the possibility that plant conditions may preclude the perfomance of the specified requirements. The provision of a 24-hour delay in the application of the Action Requiremdnts for the completion

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of a missed surveillance would provide time to obtain a temporary waiver of a Surveillance Requirement that could not otherwise be completed because of current plant conditions. If a surveillance can be perfohned only when the !

plant is shut down, there are only two options available to licensees when a missed surveillance is discovered during power operation and continued e operation'is not allowed under the Action Recuirements. The first is to shut down the plant and perfom the required surveillance. The other option is to seek relief from the Surveillar.:e Requirement. Such relief would result in the processing of a TS amendment. As a matterJof e'xisting policy,'a temporary waiver of compliance with a TS that would unnecessarily require a shutdown or ,

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delay startup absence of some relief may be granted by NRC. A teinporary -

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waiver of compliance may be granted if the licensee has demonstrated in a written submittal, provided before the TS LCO expired, that the facility can safely continue to operate without compliance with the TS during the time it will take to process the TS amendment. reques .

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CHANGE TO SPECIFICATION 4. .

Spccification 4.0.3 will be revised as follows to clarify whe'n a missed surveillance constitutes a violation of the Operability Requirements of an LCO and to clarify the applicability of the Ac, tion Requirements and the time during which the limits apply:

"Failure to perfom a Surveillance Requirement within the allowed surveillance interval ~, defined by Specification 4.0.2, shall' constitute '

noncomplianceiwith the OPERABILITY requirements for a Limiting Condition for Operation'. The time limits of the ACTION requirements are applicable ,

at the time it is identified that a Surveillance Requirement has not been perfomed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to pemit the completion of the surveillance when the allowable outage time limits of the. ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

Specification 4.0.3 previously included the statement that exceptions to it are stated in individual specifications. This statement is deleted because Specification 4.0.3 is always applicable, i.e., the implied exceptions for individual specifications do not exis Problem #3 -- CONFLICTS BETWEEN SPECIFICATt0NS 4.0.3 ANO 1. RELATED TO MODE CHANGES (Specification 4.0.4)

There.are two parts of the ger' .1 problem of conflicts between Specifications 4.0.3 and 4.0.4 related to mode changes. Each of these parts is discussed separately belo Part 1 -- SURVEILLANCE REQUIREMENTS THAT BECOME APPLICABLE DUE TO ACTION ElQUIREMENTS .

STATEMENT OF THE PROBLEM Specification 4.0.4 prohibits entry into an operational mode or other specified condition when Surveillance Requirements have not been perfomed within the specified surveillance interva First, a conflict with this TS exists when a i mode change is required as a consequence of shutdown Action Requirements and '

j when the Surveillance Requirements that become applicable have not been performed within the specified surveillance interva For instance, the plant '

could previously have been in a mode for which ~the Surveillance Pequirements were not applicable and, therefore, the surveillance may not have been performed *

within the specified time interval. Consequently, the Action Requirements of the LCO associated with these Surveillan'cb Requirements apply and the tinit may have to be placed in a lower mode of operation than that required by the

. original shutdown Action Requirements, or other remedial actions may have to be

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taken, if the surveillance cannot be completed within the time 1 bits for these actions. This is a second problem that may be encountere .

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The first problem arises because 'conformance with Spec'ification 4.0.4 would .

require the performance of these.surveillances before entering a mode for which thby apply. Source and intermediate range nuclear instrumentation and cold '

overpressure protection systems in PWRs are examples of systems for which'

Surveillance Requirements may become applicable as a consequence.of mode f '

changes to comply with shutdown Action P.squirer,ents. The second problem has been mitigated by the change in Specification 4.0.3 to permit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the applicability of the Action . Requirements, thereby placing an appropriate time limit on the completion of Surveillance Renuirements that become applicable as a consequence of mode changes to comply with Action Requirements. However, the first problem can be further resn1ved by a change to Specification 4. .

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STAFF POSITION The potential for a plant upset and challenge to safety systems is heightened if surveillances are performed durir.g a shutdown to comply with Action Requirement It is not the intent of Specification 4.0.4 to prevent passage through or to operational modes to comply with Action Requirements and it should not apply when mode changes are imposed by Action Requirements. Accordingly, Specification, 4.0.4 should be modified to note that its provisions shs11 not prevent passage through or to operational modes as required to comply with Action Requirements. A similar provision is included in Specification 3. ,

CHANGE TO SPECIFICATION 4. >

The following will clarify Specification 4.0.4 for mode changes as a conseguence '

of Action Requirements:

"This provision shall not prevent passage through or to OPERATIONAL PODEs as required to comply with ACTION Requirements."

Part 2 -- SURVEILLANCE REQUIREMENTS FOR EXCEPTIONS TO SPECIFICATION 4. . .

STATEMENT OF THE PROBLEM l

An exception to Specification 4.0.4 is allowed when Surveillance Requirements I can be completed only after entry into a diode or specified condition for which they apply. For example, the TS on' power distribution limits are generally .

exempt from Specification 4.0.4 However, upon entry into the mode or specified condition, Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the allowed i surveillance interval. Generally, these Surveillance Requirements apply to I redundant systems, and Specification 3.0.3 would apply because they are treated i as inoperable under Specification 4.0.3. Therefore, allowance of an exception to Specification 4.0.4, can create a conflict with Specification 4. .

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STAFF POSITION .

It is not the intent of Specification 4.0.3 that the Action Requirements should preclude the performance of surveillances when an exception to Specification 4.0.4 is allowed. However, since Specification 4.0.3 has been changed to pemit a delay of up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the appli'cability of the Action Requirements, an -

appropriate time ifmit now exists for the completion of those Surveillance Requirements that become applicable when an eveeption to Specification 4.0.4 is

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Enclosure 2 to Generic Letter 87-09 - l

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIRE !

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3/4.0 ' APPLICABILITY _ ,

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[ NOTE: Only Specifications 3.0.4, 4.0.3, and 4.0.4 are being modified, as

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shown in the underlined provisions. The other specifications are shown for-

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informationonly.]

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LIMITING CONDITIONS FOR OPERATION 3.0.1 Compliance with the Limiting conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL H0 DES or other ,

conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be me .0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated If theACTIONLimitingrequirements Condition are for not met within the specified time interval Operation is restored prior to expiration of the specified time intervals, ccmpletion of the ACTION requirements is not require .0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to place it, as applicable, in: >. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and At least COLD SHUTDOWN within, the subsequent 24 hour:,.

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Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for l

Operation. Exceptions to these requirements are stated in the individual specification This specification is not applicable in MODES 5 or ,

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION reouires a shutdown if they are not met within a -

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specified tirre interval. Entry into an OPERATIONAL H0DE or specified cc.ndition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION * requirements. Exceptions to these requirements are stated in the individual specification .

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SURVEILLANCE REOUIREMENTS 4.0.1 Surveillance Requirements sha11 be met during the OPERATIONAL H0 DES or other conditions specified for individual Limiting Conditions for -

Operation unless otherwise stated in an individual Surveillance Requiremen .0.2 Each Surveillance Requirement shall lie performed within the specified time interval with: -

' A maximum allowable extension not to e'xceed 25% of the surveillance interval, but The combined time interval'for any three consecutive surveillance ,

intervals shall not exceed 3.25 times the specified surveillance interva ,

4.0.3 Failure to perfom a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performe The ACTIGN requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the comDletion of the surveillance when the allowable outage time limits of the ACTION recuirements are less than 7.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Surveillance Requirements do not have to be performed on inoperable equipreen .0.4 Entry into an OPEP.ATIONAL H00E or other specified condition shall not be made unless the Surveillance Requirement (s) associated with a limiting Condition of Operation has been performed within the stated surveillance interval or as othenvise specified. This provision shall not pervent passage through or to OPERATIONAL H0 DES as required to comply with ACTION recuirement .

4.0.5 Surveillance Requirements for inservice inspection and testing of ASHE Code Class 1, 2, and 3 components shall, be applicable as follows: Inservice inspection of ASME' Code Class 1, 2, and 3 companonts and inservice testing of ASHE Code Class 1, 2, and 3 pumps and v31ves shall be performed in accordance with Section XI of the ASME Bciler and Pressure Vessel Code and applicable Addenda as req'uired by 1S CFR 50, Section 50.55afg), except where specific written relief has <

I been granted by the Comission pursuant to 10 CFR 50. Section 50.55a(g)(6)(i).

Suryd11ance intervals specified in .Section XI of the ASHE Boiler

' and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and

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APPLICABILITY .

SURVEILLANCE REQUIREMENTS Fressure Vessel Code an'd applicable Addenda shall be applicable as -

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follows in these Technical Specifications: .

Required frequencies ASME Boiler and Pressure Vessel ..

for performing inservice Code and applicable Addenda terminology for inservice inspection and testing inspection and testino activities,. activities

Weekly At least once per 7 days l

Monthly At least once per 31 days -

Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months' At.least once per 184 days ,

Every 9 months At le'ast once per 276 da3s Yearly or annually At least once per 366 days I The provisions of Specification 4.0.2 are applicable to the above .

required frequencies for performing inservice inspection and testing activitie Performance of the above inservice inspection and testing activities shall be in addition to other specified Surveillance Requirement Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirements *of any Technical Specificatio ,

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Enclosure 3 to Generic I.etter 87-09

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE 3/4.0 APPLICABILITEThis enclosure provides revised Bases for all specifications in *

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Sections 3.0andd. BASES Specification 3.0.1 through 3.0.4These}equirements establish the general are basedrequirements en the applicab to Limiting. conditions for Operation. requirements for Limiting Conditi Federal Regblations,10 CFR 50.35(c)(2): ' . . '

"Limiting conditions for operation are the lowest functional capability or perfomance levels of equipment required for safe operation facilit "

met, the licensee shall shut down the reactor or follow any remedial action pemitted by the technical specification until the condition can be met."

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Specification 3.0.1 establishes the Applicab.lity i statement within each individual specification as the requirement for when (i.e., in which OPERATIONAL MODES or other specified conditions) confomance Theto the Limiting Conditions for Operation is required for safe operation of the facilit ACTION requirements establish those remedial measures

Operation are not me There are two basic types of ACTION requirements. The first specifies the remedial measures that aemit continued operation of the facility which is not In this further restricted by tie time limits of the ACTION requirement case, confomance to the ACTION requirements provides an acceptable level of safety for unlimited continued operation as long as the ACTION re continue to be me limit in which conformance to the conditions of the Limiting Condition for Operation must be me This time limit is the allowable outage time to restore an inoserable system or component to OPERABLE status or for r parameters the allowabl. witiin specified limits.e outage time limits, a shutdown It is is required to p in a MODE or condition in which the specification no longer applie not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntar'y removal of a system (s) or .

component (s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperabl The sp'ecified time limits of the ACTION requirements al

me The time limits of the ACTION requirement.s are also applicable when a system or component is removed from service for surveillance testing orIndivid investigation of opera ~tional problem Surveillance Requirement when a specified time limit for the completion.of atIn this case, the allowable outage time equipment is removed from servic .

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3/4.0 APPLICABILITY ,

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BASES (Con't)

limits of the ACTION requirements are, applicable when this limit expires if the surveillance has not been completed. When a shutdown is required to .

comply with ACTION requirements, the plant may have entered a MDE in which a ,

new specification becomes applicable. In this case, the time limits of the ACTION requirements would apply from the point in time that the new specification becomes applicable if the re,quirements of the Limiting Condition for Operation are not me ,

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Saecification 3.0.2 establishes that noncompitance with a specification exists w1en the reouirements of the Limiting Condition for Operation are not met and ;

the associated ACTION requirements have not been implemented within the specified time interva The purpose of this specification is to clarify that >

(1) implementation of the ACTION requirements within the specified tire interval constitutes compliance with a . specification and (2) completion of the remedial measures of the ACTION requirements is not required when compliance with a Limiting Condition of Operation is restored within the time interval specified in the associated ACTION requirement Specification 3.0.3 establishes the shutdovm ACTION requirements that must be implemented when a Limiting Condition for Operation is not .~et and the condition is not specifically addressed by the associated ACTION requirement The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown H0DE when plant o)eration cannot be maintained within the Ifmits for safe operation defined )y the Limiting Conditions for Operation and its ACTION requirements. It is not intended to be used as an operational convenience which pemits (routine) voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable. One hour is allowed to prepare for an orderly shutdown before initiating a change in plant operation. This time pemits the operatnr to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach lower MODES of operation pemit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the cooldown capabilities of the facility assuming only the minimum required equipment is OPERABLE. This reduces thermal stresses on components of the primary coolant system and the potential for a plant upset that could challenge safety systems under conditions for which this specification applie If remedial measures permitting limited continued operation of the facility under the provisions of the ACTION requirements are completed, the shutdown may be terminated. The time limits of the ACTION requirements are applicable from the point in time there was a failure to meet a Limiting Condition for l Operation. Therefore, the shutdown may be terminated if the ACTION requirements have been met or the time limits of the ACTION requirements have not expired, thus providing an allowance 'for the completion of the required actions, j

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PWR STS B 3/4.0-2

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3/4.0 APPLICABILITY BASES (Con't)

The time limits of Specification. 3.0.3 allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months . for the plant to be in -

the COLD SHUTDOWN MODE when a shutdown is required during the POWER MODE of operatio If the plant is in a lower MODE of operation when a shutdown i required, the time limit for reaching the nex.t lower MODE of operation ap-plies. However, if a lower MODE of operation is reached in less time than allowed, the total allowable time to reach COLD SHUTDOWN, or other applicable MODE, is not reduced. For example, if HOT STANDBY is reached in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the time allowed to reach HOT SHUTDOWN is the next 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months because the total time to reach HOT SHUTDOWN is not reduced from the allowable ifmit of 13 hour1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months Therefore, if remedial measures are completed that would pennit a return to p0WER operation, a penalty is not incu'rred by having to reach a lower MODE of ,

operation in less than the total time allowe The same principle applies with regard to the allowable outage time limits of the ACTION requirements, if compliance with the ACTION requirements for one specification results in entry into a MODE or condition of operation for another specification in which the requirements of the Limiting Condition for Operation are not met. If the new specification becomes applicable in less time than specified, the difference may be added to the allowable outage time limits of the second specification. However, the allowable outage time limits of ACTION requirements for a higher MODE of operation may not be used to extend the allowable outage time that is applicable when a Limiting Condition for Operation is not met in a lower MODE of operatio The shutdown requirements of Specification 3.0.3 dB not apply in H0 DES S and 6, because the ACTION requirements of individual specifications define the remedial measures to be take Specification 3.0.4 establishes limitations on MODE changes when a Limiting Condition for Operation is not met. It precludes placing the facility in a higher MODE .of operation when the requirements for a Limiting Condition for Operation are not met and continued noncompliance to these conditions would result in a shutdown to comply with the ACTION requirements if a change in MODES were permitted. The purpose of this specification is to ensu,e that facility operation is not initiated or that. higher MODES of operation are not '

entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits. Compliance with ACTION requirements that pennit continued operation of the facility for an unlimited period of time provides an accept-able level of safety for continued operation without regard to the status of the plant before or after a MODE change. Therefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements. The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startu )

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3/4.0 APPLICABILITY BASES (Con't) _

When a shutdown is required to comply with ACTION requirements, the provisions of Specification 3.0.4 do not apply because they would delay placing the facility in a lower MODE of operatio . .,

Soecifications 4.0.1 throuch 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations,

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10CFR50.36(c)(3):

"Surveillance requirem nts are requirements relating to test, calibra-tion, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met." ,

Specification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES' or other conditions for which the ,

requirements of the Limiting Conditions for Operation apply unless othenvise stated in an individual Surveillance Requirement. The purpose of this speci-fication is to ensure that surveillances are serfomed to verify the opera-tional status of systems and components and tlat parameters are within speci-fied limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable. Surveillance Requirements do not have to be perfomed when the facility is in an OPERATIONAL MODE for which the reauf rements of the associated Limiting Condition for Operation *do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exceptiori to the requirements of a specificatio Specification 4.0.2 establishes the conditions under which the specified time interval for Surveillance Requirements may be extended. Item a. permits an allowable extension of the nomal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the, surveillance; e.g., transient conditions or 'other ongoing surveillance or maintenance activities. Item b. limits the use of the provisions of item a, to ensure that it is not used repeatedly to extend the surveillance interval beyond that specified. The limits of Specification 4.0.2 are based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. These provisions are sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interva . '

Specification 4.0.3 establishes the failure to perfonn a surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPEPMILITY requirements for a Limiting Condition for Operation. Under the !

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provisions o'f this specification,, systems and components are ' assumed to be '

OPERABLE when Surveillance Requirements have been satisfactorily perfomed within the specified time interval. However, nothing in this provision ~is to-be construed as implying that systems or components are OPIRABLE when they are found or known to be inoperable although still meeting the Surveillance l

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Requirements. This specification also clarifies that the ETION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of tie ACTION requirements .pply from the point in time it is identified that a surveillance has not been perfomed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the , 1

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allowable outage time limits of the ACTION requirements restores compliance with the requirements of Specification 4.0.3. However, this does not negate

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the fact that the failure to have perfomed the surveillance within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, was a violation of the OPERABILITY requirements of ? Limiting Condition for Operation that'is subject to enforcement action. Further, the failure to perform a l surveillance within the provisions of Specification 4.0.2 is a violation of a l Technical Specification requirement and is, therefore, a reportable event under the requirements of 10 CFR 50.73(a)(2)(1)(B) because it is a condition prohibited by the plant's Technical Specification If the allowable outage time limits of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or a shutdown is required to comply with ACTION requirements, e.g.,

Specification 3.0.3, a 24-hour allowance is provid#d to pemit a delay in implementing the ACTION requirements. This provides an adequate tima limit to complete Surveillance Requirements that have not been performed. The purpose of this allowance is to pemit the completion of a surveillance before a

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shutdown is required to comply with ACTION requirements or before other ;

remedial measures would be required that may preclude completion of a surveillance. The basis for this allowance includes consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, and the safety significance of the delay in completing the required surveillance. This provision also provides a time limit for the completion ~of Surveillance Requirements that become applicable as a consequence of MODE changes imposed by ACTION requirements and for completing Surveillance

' Requirements that are applicable when an exception to the requirements of Specification 4.0.4 is allowed. If a surveillance is not completed within the .

24-hour allowance, the time limits of the ACTION requirements are applicable at that time. When a surveillance is performed within the 24-hour allowance and the Surveillance Requirements are not met, the time limits of the ACTION requirements are applicable at the time that the surveillance is teminate Surveillance Requirements do not have to be perfomed on inoperable equipment because the ACTION requirements, define the remedial measures that appl However, the Surveillance Requirements have to be met to demonstrate that inoperable equipment has been restored to OPERABLE statu .

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3/4.0 APPLICABILITY

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Specification 4.0.4 establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement. The purpose of thip - .

specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which'

these systems and components ensure safe opefation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startu Under the provisions of this specification, the applicable Surveillance Requirements must be perfomed within the specified surveillance in.terval to ensure that the Limiting Conditions for Operation "

are met during initial '

plant startup or following a plant outag When a shutdown is req'uired to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operatio Specification 4.0.5 establishes the requirement that inservice inspection of A5M Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be perfomed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as' required by 10 CFR 50.55a. These requirements apply except when relief has been provided in writing by,the Comissio This specification includes a clarification of the frequencies for perfoming the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and to remove any ambiguities relative to the frequencies for perfoming the required inservice inspection and testing activities, j Under the terms of this specification, the more restrictive requirements of ,

the Technical Specifications take precedence over the ASME Boiler and Pressure l Vessel Code and applicable Addenda. The requirements of Specification 4. to perform surveillance activities before entry into an OPERATIONAL MODE or other specified condition takes precedence over the ASME Boiler and Pressure ~

Vessel Code provision which allows pumps and valves to be tested up to one week after return to normal operation. Tne Technical Specification definition of OPERABLE does not allow a grace period before a component, that is not capable of perfoming its specified function, is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of perfoming it's specified function for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before being declared inoperabl C ..

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EVENT <

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VIOLATED TECHNICAL SPECIFICATION 3.3.2 FOR EXCESSIVE [

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COOLDOWN INSTRUMENTATION REQUIREMENTS e PLANT STAFF DISCOVERED ON FEBRUARY 9,1988 SEVEN OF !

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TWELVE FEEDWATER FLOW TRANSMITTERS ISOLATED e DISCOVERY WAS SELF INITIATED BY REQUIREMENTS USTED IN PREREQUISITE SECTION OF LOW POWER PHYSICS TEST, 1 PEPO 4-ZL-0064, PRE CRITICAL AUGNMENT OF STEAM AND FEEDWATER FLOW INSTRUMENTATION

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IMMEDIATELY RESTORED ISOLATED TRANSMITTERS TO SERVICE

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IMMEDIATELY INITIATED A 100% DOUBLE VERIFICATION OF UNEUP .

OF ALL TECHNICAL SPECIFICATION INSTRUMENTATIO NO OTHER INSTRUMENTS WERE FOUND MISALIGNED

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ROOT CAUSE

PROGRAM FOR SYSTEM AUGNMENT WAS WEAK BECAUSE IT DID =

NOT INCLUDE ALL INSTRUMENT VALVES IN A SYSTEM ALIGNMENT l PROCEDURE acas-

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CORRECr1VE AC110X

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i e SYSTEM AUGNMENT PROCEDURES HAVE BEEN REVISED TO REQUIRE j VERIFICATION OF ALL INSTRUMENTS WHEN A SYSTEM AUGNMENT

IS PERFORMED. AUGNMENTS HAVE TWO INDEPENDENT VERIFICATIONS j FOR TECHNICAL SPECIFICATION INSTRUMENTS .

e PLANT STARTUP PROCEDURES HAVE BEEN REVISED TO REQUIRE

VERIFICATION OF TECHNICAL SPECIFICATION INSTRUMENT AUGNMENT i PRIOR TO CHANGING MODES FOR WHICH THE INSTRUMENTS ARE i REQUIRED. AUGNMENTS HAVE TWO INDEPENDENT VERIFICATIONS FOR

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TECHNICAL SPECIFICATION INSTRUMENTS

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i l e PLANT STARTUP PROCEDURES HAVE BEEN REVISED TO REQUIRE

! SYSTEM AUGNMENTS, WHICH NOW INCLUDE INSTRUMENT AUGNMENTS, i PRIOR TO INITIAL CRITICAUTY, POST REFUEUNG, OR AF ILR OUTAGES l OF 30 DAYS OR LONGER

!

l e THE UNIT 2 SYSTEMS OPERATONAL CONFIGURATION CONTROL

! PROGRAM WILL ADDRESS THE WEAKNESSES IDENTIFIED IN THE

! UNIT 1 PROGRAM PRIOR TO IMPLEMENTATION l

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NRCOO4-

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s EVEMI_g RggghggZ APRIL 24, 1987 - 7 OF 12 FEEDWATER FLOW APRIL 28, 1987 TRANSHITTERS CALIBRATED FOR CPERATION NOTE: CALIBRATION PROCEDURE LEAVES INSTRUMENTS LINED UP FOR OPERATIO A DOUBLE VALVE LINEUP CHECK IS PERFORMED AS PART OF THE PROCEDURE.

APRIL 29, 1987 PLANT IMPLEMENTED A UNIT 1 SYSTEMS OPERATIONAL CONFIGURATION CONTROL PROGRA NOTE: PROGRAM WAS DEFICIENT IN THAT IT DID NOT ADDRESS START DATE OF SURVEILLANCE TEST PROGRAM AND IT RELIED ON SYSTEM OPERATING PROCEDURES TO ALIGN ENTIRE SYSTEM WHEN IN FACT SYSTEM ALIGNMENTS DID NOT INCLUDE INSTRUMENT ALIGNMENTS.

APRIL 30, 1987 HYDROSTATIC TESTING OF THE )

FEEDWATER 7 LOW TRANSMITTER !

SENSING LINES PERFORMED, ALL 12 l TRANSHITTERS VALVED OUT OF l SERVICE TO PROTECT THEM FROM l HYDRO PRESSURE NOTE: MAIN FEEDWATER SYSTEM WAS STILL JURISDICTIONALLY CONTROLLED BT STARTUP AT l THIS TIM THE HYDRO !

PROCEDURE WAS NOT APPROVED BT NPOD AND DTD I NOT CONTAIN RESTORATION STEPS FOR THE TRANSMITTER _ . __ -_ , - , , - - , - .- _ _

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l MAY 1, 1987 - 5 OF 12 FEEDWATER FLO l JUNE 8, 1987 TRANSMITTERS CALIBRATED FOR

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OPERATIO THESE 51 REPRESENT l THE REMAINING S OF THE' 12 NOT l CALIBRATED IN APRIL 24, TO APRIL 28 TIME PERIOD.,

NOTE: ON FEBRUARY 9 ', 1988 WHEN

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THE TRANSHITTER' ISOLATION WAS DISCOVERED..THESE j FIVE WERE FOUND TO'BE VALVED IN SERVIC l MAY 7, 1987 - MAIN FEEDWATER SYSTEM VALVE MAY 20, 1987 ALIGNMENT 2 E il F O R M E D . *

NOTE: THE PROCEDURE R E Y.I S I O N USED TO COMPLETE THIS ALIGNMENT ONLY REQUIRED PLANT ODBRATORS TO. VERIFY ROOT VALVES TO INSTRUMENTS VERE OPE THE PLANT PHILOSOPHY AT THIS POINT WA3 THAT THE I&C GROUP WOULD COMPLETE THESE INSTRUMENT ALIGNMENTS THROUGH THEIR PROCEDURES, WHICH FOR TECHNICAL SPECIFICATION INSTRUMENTS WAS THE SURVEILLANCE TEST FOR EACH INSTRUMEN JUNE 6, 1987 MAIN FEEDWATER SYSTEM JURISDICTIONALLY TRANSFERRED TO-NPO ,

AUGUST, 1987 PLANT OPERATIONS DEPARTMENT CHANGED PHILOSOPHY TO INCLUDE IN PROCEDURES CHECKLIST TO VERIFY INSTRUMENTS WERE PROPSRLY ALIGNE COMMITMENT WAS TO REVISE ALL SYSTEM OPERATING PROCEDURES BY THE END OF THE '

BIENNIAL REVIEW CYCLE, j

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NOVEMBER 4, 1987 MAIN FEEDWATER SYSTEM PROCEDURE WAS REVISED TO INCLUDE REQUIREMENTS FOR INSTRUMENT ALIGNMENT IN ACCORDANCE WITH AUGUST COMMITMEN NOTE: A DECISION NOT TO REPERFORM THE MAIN FEEDWATER SYSTEM VALVE ALIGNMENT, INCLUDING THE INSTRUMENT CHECKLIST, WAS MADE BASED ON THE FACT THAT THE SYSTEM HAD APPARENTLY BEEN OPERATING SUCCESSFULLY FOR A PERIOD OF TIME AND THAT THE INSTRUMENT ALIGNMENTS HAD BEEN PREVIOUSLY MADE USING THE SURVEILLANCE TESTING PROGRA FEBRUARY 9, 1988 7 OF 12 FEEDWATER FLOW TRANSMITTERS WERE IDENTIFIED AS BEING ISOLATE NOTE: FEEDWATER FLOW INSTRUMENTS ARE REQUIRED TO BE OPERATIONAL IN MODES 1, 2, & THE PLANT HAD ENTERED MODE 3 ON 3 OCCASIONS PRIOR TO FEBRUARY 9, 1988:

NOVEMBER 22, 1987, JANUARY 30, 1988 AND

FEERUARY 7, 198 !

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AXALYSIS (PAGE 10F 2)

THE tt1DWATER FLOW TRANSMil ItxS WHICH WERE ISOLATED l AS A RESULT OF THIS EVENT PROVIDE INPUTS TO EXCE5SiVE COOLDOWN l PROTECTION, THE THREE ELEMENT Ft1DWATER CONTROL SYSTEM AND l tti.UWATER FLOW INDICATION.

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ONE OF THE PROTECTIVE ACTIONS PROVID'ED BY THE

! EXCESSIVE COOLDOWN PROTECTION SCHEME IS tt1DWATER j ISOLATION AND TURBINE TRIP ON HIGH FEEDWATER FLOW

! COINCIDENT WITH LOW RCS FLOW OR LOW TAVG TO PREVENT -

RETURN TO CRITICALITY DUE TO A STEAM LINE BREAK l '.

i l e THE PROTECTION IS ONLY ACTIVE WHEN EITHER OR BOTH j OF THE FOLLOWING ARE TRUE:

i - REACTOR TRIP BREAKERS OPEN j - REACTOR POWER I FRS THAN 10%

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! e NO CREDIT IS TAKEN FOR EXCESS COOLDOWN PROTECTION IN ANY FSAR CHAPitx 15 ACCIDENT ANALYSI NRC011

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l ANALYSIS (PAGE 2 OF 2)

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e A TECH SPEC CHANGE DELETING THIS FEATURE l'

HAS BEEN APPROVED BY NR e THE INOPERABLE STATUS OF THE Ft1DWATER FLOW ..

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l TRANSMll itxS WAS DETEC1t.u DURING PRECRITICAUTY l it. STING. SINCE THE RCS WAS BORATED AT 2500 PPM '

l (REFUEUNG CONDmONS) AT THE TIME, THE- ACCIDENT '

! FOR WHICH THIS PROTECTIVE FEATURE WAS DESIGNED -

! COULD NOT HAVE RESULTED IN REACTOR CRITICAUT ,.

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, THE THREE ELEMENT FtiuWATER CONTROL SYSTEM WILL NOT OPERATE IN THE AUTOMATIC MODE WITHOUT A Ft1UWATER FLOW SIGNAL 5 -

i * LACK OF ttiuWATER FLOW INDICATION WOULD BE

! OBVIOUS ONCE SIGNIFICANT FLOW RATES WERE ATTAINED.

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OFFICE MEMORANDUM ,

7b DISTRIBUTION April 29, 1987 ST-P2-HS 426 ffom W. H. Kinsey PFN: X5 Subject Unit 1 Systems. Operational Configuration Control SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

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Unit 1 completion status is now at a stage where NPOD must begin a concentrated effort toward obtaining operational configuration control of plant systems in order to ensure licensing and technical specification requirements for equipment operability are met to support receipt of an Operating License and subsequent fuel loading on June 1, 1987. To accomplish configuration control, NPOD must complete all associated valve, slectrical and switch lineups on each system to baseline the system status. Following baselining, Operations must control all subsequent activities associated with changes to system configuration to ensure the configuration is known at all times and the

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system can be readily restored to operable status in ac,cordance with approved plant procedure In order to establish and maintain operational configuration control, the following measures will be implemented taginning May 1, 1987: All work' activities on Unit 1 systems shall be approved by the NPOD Shif t/ Unit Supervisor prior to implementation. This includes any wore activity, including work performed under SWRs as well as CWRs and HWRs which has not actually commenced by this date. For SWRs this approval shall,be denoted by Shif t/ Unit Supervisor's signature and date in Block 24 of the SWR form. The Shif t/ Unit Supervisor shall retain a copy of all SWRs approved for implementation. The -

NPOD Shif t/ Unit Supervisor shall be notified of work completion on Unit I system For SWRs this notification

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shall be documented by Shif t/ Unit Supervisor's signature and date in Block 2 , System operati.on and testing shall be performed in accordance

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with approved plant or start-up test procedures; OWORs and

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IOPs shall no longer be used for plant operations. Use of

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approved procedures to realign systems for operation and

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testing shall be controlled by the Shif t/ Unit Superviso ;

' All work activities on Unit 1 systems shall be scheduled via

.the NEOD Daily Work Activity Schedule (DVAS). This should

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__' include 3 day prior' notification o.f_vork_ start for all, planned work activitie Exceptions may be handled on a case by case basi ,

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- L __ , The schedule for placing systems under operational -

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configuration'contiol is provided in Attachment 1. 'This schedule shall be updated daily to reflect actual statu The organization responsible and reason for preventing

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placement of systems -into configuration- control shall be ,--------

Icentified on the schedul .

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.e 1oceA(188)

Houston Lighting & Power Company

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0FFICE MEMOR ANDUM Pa e 2 .

To sT-P2-HS-426 W. H. Kinsey PFN: K5 From Unit 1 Systems Operational Configuration Control Sub/tet SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

.. .. .. - NPOD Operations shall be responsible for performing the necessary lineups to place each system under operational configuration control as scheduled, for documenting completion control alignment using Attachment 2, and for __

maintaining configuration control. Alignments shall be performed using approved plant procedure . Individuals found working on systems under configuratica control without proper authorization shall be subj ect to '

disciplinary actio , Technical Specification Lim ting Conditions for Operation 8 (LCO) and action times for Mode 6 requiremants shall be initiated and enforced beginnic: Msy 15, !?!? for systems under configuration control. This vill limit the number of trains that can be out of service and length of time equipment may be out of service. Exceptions may be handled on a case by case basi . Temporary Alterations shall not be authorized to any system under configuration c.ontrol. All temporary alterations shall be restored to aporoved design status or converted to Temporary Modifications as part of the establishment of configuration contro . All modifications (permanent or temporary) to systems under configuration control shall require evaluation by NPOD Operations to determine the need to revise operating procedures, if the system is to be returned to service with the modification in effec Any such procedures shall be revised prior to returning the system to servic . Following establishment of operational configuration control,

, surveillance tests shall be performed on technical specification related systems, as necessary to ensure required operability to support receipt of an Operating License and Mode 6 Technical Specification requirement __

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/ VHK/JWL/dms .,

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VMii ! SYSIB C0kFIGURST10N CONT 10Ll0FEAA81LliY TRACXING llSi PAGE!

l F SCF.0ULED ACTUAL ;

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5YSIG DESCilPTION TVbOVER / CONF 16 (ONI CONF 16 CONI OREAX12ATIC#l DATE A DATE DATE REASON

.

AC CLOSEDLOOP.AVIC00LINEWATER 16-Sep-86A 01-hr-47 AF AVI FEE 0 WATER SYSTEM 30-Apr-87f 01-hr-87 CC CCMf0NENTCOOLINGSYSTB 081!ar-87F 01-Mar-87 CD CCNDENSATE SYSia 2Ner-87F 01 h 7-87 CH CHILLEOWATERHVAC 21-Mar-87F 01-hr-87 OL LIEHi!X60!ESEL60!iATOR 29-Apr-57F 01-Mar-87 ES ESTRACTICN SIEM SYTEM 30-Apr-87F 01-Mar-87 EW ES$!NTIALCOOLINGWATERSYSTEM 12-Dec-86A Char-87 HF FUELHANDLINGBLOHVAC 01-Mar-37F 01-hr-87 IA INSiiVMai AIR SYSTEM 30-hn-!6A 01-Mar-87 OW 0!LYWASTESYSTEM 13-Mar 87A OHar87 RH RESIDUALHEATREMOVALSYSIB 30-Apr87F 0Har-87 S3 SG.!LCWOOWN. SYSTEM 01 Mar-87F 01-Mar-!7 ;

SI SAFETYINJECT10NSYSTEM OHar-87F 01-hr-37 iM MAINTURBINE 29-Apr-87F 0Har-37 6M MAINGDERATOR 0 H pr-37 A 0 Mar-87 SA STATIONAIRSYSTEM 30-hn-36A 02-Mar 87 SM ESFSTAIVSMONITOR 2Mct-!6A 03-br-37 VM Y!BRAi!CNMONITORINGSYSTEM 16-ha-37 hr-57 ES 7300 PROCESSOR 23-Apr-87A 04-Mar-37 (S CCNTAINXENTSPRAYSYSTEM 30-Apr-37F 0Har-87 CW (!!CULAilNGVATERSYSTEM 0 Hay-87F 0 H ay-37 OB DIESELEBERATOR(iOP) 30-Apr-37F 04-Mar-87 63 TV!!!NESLANDSEALSYSTEM iMir-57A 04-hy-37

'

Hi OlESEL6BERATORSLOHVAC 0Har-87F Char-87 a !EACIGR MKE-UP VATER SYSIB 24-Oct-!6A 0 H ay-57 F0 FUEL 0!L STOR 1 IEMS SYSTEM 16-Sep-!6A 05-hr-87 L0 LV!EDILFURIF! tai!0NSiOR&TRAMSSYST 15-Sep-!6A? 05-hr-87 00 Of8 LOC? AVI CCOLING SYSia OMar-37A 05-hr-87 SC ClicWATERSCREENS 13-Sip-86A 05-Mar-37 SS SECON0ARY SMPL!NG SYSTEM 2N;r-87A Char-87 0! 43VDCNON-CLASS 1ESYSTEM INpr-56A 04 0 7-37 AN EEFCA? ! 1VALIFIED DISPLAY 1i00. SYSID 04-ha-37 F 07-hr-37 D MIN STEM VENTS & ORAlWS SYSIBS IN;r:57 A 0Har-37 NL : Nii2 Cia STORAGE SYSTEM 30-hn-!!A 07-hr-37 i) 4XV AC NON lE PWR 20-Oct-36A 07-hr37 0 G a H2 S.0. SYSI B INaa-87A 07-h1-87 AS AUIS3MSYSTEM i M n-86 A 01-hr87 <

!

--

-ER-- ECACN RECYCLE SYSTEM - - iMar-37.F-. 08-Mar 87 (? CODDSATE?]L13HINGSYSTEM '07-hr-87F 05-Ly-37

- - - ~

9 EEATERDRI?SYSIB 07 h r-!7 F 08-hr-37

-- - --2

.

--

PL- ~ .450V AC LCAD CBIER31E - --- - - -23-Oct-36 A---03-br-37-15 ECDCCNi3ClSYSiu .

2N;r 37 F C H ar-37 . .

I Li u!NTU?3!NELUBEGILSYSIB liA;r-37A 07 b r 17 VA !:0VACCLASS!E 17-0:H6A 07 b r 37 AN ANT.'NCIAICR

~~~

13-Oct!6A 10-br-37 - "- -~ ~

~ ~ 02 ' N32AD ORAINS & SL'MPS ~ T !!-i; H 7 A 10-517-37- ..

E0 STATORC30LINGWATERSYSTB 03-Feb-57A 10-hr-37 13 A"! !!ANSFOME3 '

1Hir-37F .10-br-37

?? 4!0V MC:'S 1Hir-87F 10 b r-17 l Pi 13.3X" O !li a CY FCM R . ! Hay-37F 10-hr-37

?! O.!KV ?!:i!EY iPANS IHay-37? 1HiM7 .

.

, UNIT-1 STE!B 'C0'i IShit!0N CONTR0Ll0FERA81LITY TRAulW6 LIST ,

PAGE2 F SCHEDULED ACTVAL SYSIB DESCRIPTICW TUU0VER / C0HF16 (Mi CBf!6 CONT CliANIIAii0s/

DATE A DATE DATE REASCN O CCNTAIMENTMCNITORING.SYSia (Har-87F' iMay-87

..

EH EHCSYSTEM 22-Art-87A it-Mar-87 fH FUELHAHLINGSYSta 2Har87 F lHar87 FV FEE 0WATEXSYSta 0Har87 F iMar87 11 INCOREINSTAVMENTAi!0N OMae87F 1Har87 __

L6 ERMALACLIGHilNG OHar87 F 11-Mar 87 NI NUCLEARINSTRUMENTATIC4 04-Ju-87F !Har-!7 PE 480VLOADCENTERS 21-ha-87 A IHar87 BA BREATHINGAIRSYSTEM 30-Apr-87F 12-Mar 87 '

CV CHEM 8V0LCONTROLSYSIM IHar-87F iMar-87 DC 250VDCXONlEBATTERIES 03-Feb-87A 12-Mar 87 FF fliEPiOTECTICNSYSTEM IHar87F !HarS7 6E MAINIVRBINEEICITER ON;t-87A !Har87 .

PM 4!0V AC MCC'S lE 23-Oct-85A 12-Mar 87 SH S0DIUMHYP0CHLORITESYSTEM INu 86 A 12-Mar 87 VC 120V AC NON 1E VliAL 23-Oct-86A 12-Mar 87 0A 1:5VOCNON!E 30-Oct-86A IHar87 65 GENH28002 INu-87 A - 13-Mar 87 IB LOCSEFARTSMONITORINGSYSTEM 27FtH7A 13-Mar 87 SF ESFSYSTEMS C H n-87 F 13-Mar-87 TW SEiVICEWATERSVPFLYSYSTEM IH;r-!6A 13-hr-87 CF BOPCHDICALFEE0 SYSTEM OHn 86 A li-Mar 87 FC S?ENTFUELP0OLCOOLINGSYSTB 16-hn-87 A IHar87

. PC 13.!KVACAVIILIARYF0WERSYSTEM' 24-Oct-!6A 14-En-87

'

SW F3ESHVATERSUFFLYSYSTEM 1Har-86A 14-Mar 87 C5 (CNTAINCCMBUSTEASCNTALSYSTEM 2 Hay-87F 15-Mar 87 CR COEENSERAIRREMOYALSYSTEM 03-FeH7A 15-Mar 81 05 DIE 3EL EDERATORS OHar-87 iMar87 DJ 125VDCCLASS1ESYSTEM 06-OcH6A 15-hr87 OW ODINE!ALIZE! WATER SYSTEM 0?-hM4 A IHar-87 E) FA010ACTIVEYENTS&ORAINS iMar87 F 15-h7-87 EP E35ENilALCOOLINGFCNDMAKE-UPSYSTM iMar-!6A 15-Mar-87 HB CONTROL 200MHVAC 2Har-87F tHar87 HE EABFENETRATIONSPACEHVAC 2Har87 F 15-Mar 87 LLi RIVERSERVICESTRANS.ANDSVITCH6 EAR 30-Nn-84A iMar-87 LM' RESERV0!RMAKEUPPUMPlN6 STATION 3 H n-84 A 15-hr-87 MS MAINSTEAMSYSIB Char 87 F 15-Mar-87 NC NOMA 010ACilVECHEMICALWASTESYSTEM 0Htr-85 A lHar-87

-

M FREEZEPR0iECT10N ONu 87 F _ IHar87 i

-

FA - SIAHSY TRANSF0BER-- 02-Oct-!5t 15-Mn-87

- - - - -

F3 FRIMARYSAMPLINGSYSTEM OHar87 F 15-br-87 .,

IA RADIAI!ONMCNITGi!NGSYSTM ~ ~ ~ O H n-87 F 15-br-87 .

~ OHirl7 F' 'lHaN7

~

=

S? SOLID STATE PROTECTION "

SY' SEISMICMONITORINGSYSIB -

- 0Ha-87 F- 15-87-87 W WELLWATERSYSIB 15A:r!5A 1Hn-87 HC CONTA! MENT BUILDING HVAC 2HU-87 F 18-hr87 NZ _ .ELECi!! CAL M!SC ._. . .. . ._

ONu 87 F 20/20 AEACIOR COOL SYS/REACIOR HEAD DE6AS -0Har8? FlHu . _1Har87 87 - -- - -

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R L!iV!)VAsiEPiOCESSSYS.IB O H u -!? F 1Har37 Hi IURBINEBUILO!NGHVAC 0Har!7 F 17-hr87 ;

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!

UNii-1 SYSID CONFISU!ATION (CNTROL/0PERABILITY ilACXING LIST ,

PAGE3 J

!

,

.. . .............................. .. . . .............. . .......... . _- ......... ;

F SCHE 0"LE3 ACTUAL SYSTEM DESCRI?i!CN TUEN0'IER I CONFli G i CONFI6CCNT OR6AN!!Ai!0N/

OATE A 0 ATE DATE REASCN

..... .............................. ..... .. ............ .......... . ....... ...... ..........

.. a ID;CN 6AL, IUEEL 'iENT S-SYST NON CHILL 23-Ma7-37F 25-?ar-37 LA E.".!!SENCY I E35DTIAL Ll6HilNG 0!-ha-37 F 25-Mir!7 M CA?E;iC ?!0iECIICN 01-ha-37F 25-Xir37

'i! US P'.ANI 'iENT H22 OH!ar-37F 25-Mar-17 Vi GAi!:US VASTE ?!XESS SYSTEM 04 ha 87 F 25137-37 -

E! ?:) ?]!I: ION LUICATCR SYSTEM 27-An-37F 26-Nir17 W3 57.!0VAS!EP30:E55 SYSTEM !?-ha-37 F 15 ha 37 11 ;;iAr.!WA?ElSY3?EM 07 hl-17 F Oi-hM7

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,

e OPERATIONAL CONFIGURATION CONTROL CHECKLIST REV 0 System:

,

'

Review Cri.teriai,

.

YES N0** N/A**

Valve Lineup Completed per l l l l]l Procedure N ,.Re * Electrical Lineup Completed per l l l l l]]

Procedure N , Re .

Switch Lineup Completed per l l l l l[l Procedure N , Re *

.

. Temporary Alterations Restored or l l l l l]l Converted to Temporary Hodifications Operational Configuration Control l l l l l]l Established Notes:

Items not required to be completed where performance requires removing an operating system from servic ** Require explanation in Remarks Sectio REMARKS:

'

.

Recommended by: /

. , Shift Supervisor Date

.

__ .. _ . .-. .. .._ '

Reviewed by: / .

.. . - . . . . . _ . .

_

. - -

.- Unit -Operat ions-Supe rvisor-- ---- Date - - - - - -

. . -

.

Approved by: /

Plant Superintendent Date --

. . _ . . . . . . . _ . . . - - . . . - - - - -

. _. . . . _

, , , e - & -

'

.

l

,

4 .

J

_ - ._ _.

l

'

l l EVEXT i * ON APRIL 13,1988 NRC INSPECTOR DISCOVERED AN ERROR IN :

THE CALCULATION FOR ISOTHERMAL TEMPERATURE COEFFICIENT MEASURED ':

, AND CALCULATED BY LOW POWER PHYSICS ILST IPEP04-ZX-0004 '

i PERFORMED ON MARCH 9,1988

UPON NOTIFICATION, HL&P IMMEDIATELY ASSESSED IMPACT

~

'

OF ERROR AND DEILNMINED THAT THE ACCEPTANCE CRITERIA OF THE SUBJECT It:si WERE STILL MET AND THAT NO OTHER 16TS UTILIZED i THE ERRONEOUS INFORMATION OR WAS AFFEC1EU BY THE ERRONEOUS l lNFORMATION

! ,;

ROOT CAUSE

! * THE PERSON RESPONSIBLE FOR FIRST PERFORMING THE CALCULATIONS

'

MADE A MISTAKE IN READING THE STRIP CHART RECORDER FOR 1 RAW DATA REQUIRED IN THE CALCULATIONS l e THE PERSON RESPONSIBLE FOR REVIEWING THE CALCULATIONS i DID NOT START WITH THE SOURCE OF THE DATA, i.e. THE STRIP CHART '

l RECORDER, BUT ONLY VERIFIED THE NUMERICAL MANIPULATIONS i

I NRC005

)'

_ _ - _ - _ _ _ _ _ _ - _ _ _ _ - --__-__ ___ _--__ . _ _ __

. - _ _ _ _

! DORRECr1VE ACTION l

l e REVIEWED ALL OTHER LOW POWER PHYSICS TESTS AND PRECRITICAL i TESTS AND HAVE FOUND ONLY 3 OTHER MINOR, NON-SIGNIFICANT, ,

NON-lMPACTING CALCULATIONAL ERRORS. THIS REVIEW INCLUDED

! 63 TESTS AND MORE THAN 4000 INDIVIDUAL NUMERICAL j MANIPULATIONS

!

, PROCEDURE 1 PEPO 4-ZA-0003, DOC'JMENTATION OF INmAL STARTUP l It.si RESULTS, HAS BEEN REVISED TO EMPHASIZE RESPONSIBILITIES I OF THE REVIEWER, AND AN ADDITIONAL REVIEW ON A SAMPLE

BASIS HAS BEEN ADDED TO THE PROGRAivi. ADDITIONAi_LY, A REVIEW j ATTRIBUTE SHEET HAS BWN DEVELOPED FOR THE PROGRAM r

!

It.5T DIRECTORS AND SHIFT TEST DIRECTORS HAVE BEEN RETRAINED l

l ON THE RESPONSIBluTIES FOR TEST PACKAGE REVIEW, IN PARTICULAR l ON THE IMPORTANCE OF PERFORMING TOTALLY INDEPENDENT REVIEWS,

! FROM THE ORIGINAL RAW DATA TO THE FINAL CALCULATIONS l

l

!

~

!

i NRC006-

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _____-___ ___ - _- - - -__ - - ______

. _ - _ _ _ _ _ _ _ _ ____ _ _ -

. , , .

1 .

,.

.- . _ _ .a 4 . .

. . .

.

Initial Startup Test Procedure Package Review Checklist The following is a list of the minimum requirements for test packages:

.

Yes No Are all blanks completed as required by the test procedure? Are all procedure entries regarding procedure numbers, *

revisions, and titles, within the procedure being reviewed, correct? Is all documentation required by Section 8.0 of the procedure, in the procedure package?

. Have all calculations required by the procedure been verified, starting from the original sources of infarmation (strip charts, graphs, x-y plots, etc.)? Is there sufficient data in the test package to demonstrate that all acceptance criteria were met? Have all required log entries been made:

.

6.1 Pretest briefing conducted 6.2 Date and time of start of test and completion of test 6.3 Name of personnel participating in test 6.4 Limits or precautions exceeded during test 6.5 Reverification of test prerequisites or initial conditions following significant delays in testing 6.6 Amounts of boric acid or demin water added during physics tests -

,

J 6.7 QA/QC notified of test l I

i All data recorded in ink l l All test data not part of the original test (e.g. chart recorder traces, computer printouts, etc.) initialed and dated? All corrections single line strike out, initialed anJ dated? '

i Any items answered "No" shall be documented and evaluated by attaching a Supplementary Evaluation For .

Reviewed by: -Date

.

, 4

. l

. ._ _

EVEXT

'

=

e DURING THE PERIOD OF FEBRUARY 11,1988 THROUGH MARCH 31,1988 NRC INSPECTORS NOTED A WEAKNESS IN THE PROGRAM FOR CONTROLUNG UFTED LEADS, JUMPERS, AND FUSES ROOT CAUSE/DISCUSSI0X

THE CONTROL OF UFTED LEADS, JUMPERS, AND FUSES DURING MAINTENANCE TROUBLE-SHOOTING ONLY IS NOT EXPUCITLY ADDRESSED IN STATION PROCEDURES. THE STATION MAINTENANCE WORK REQUEST PROGRAM DOES, HOWEVER, REQUIRE MAINTENANCE PERSONNEL TO - -

RECORD ALL ACTIONS TAKEN, WHICH INCLUDES THE ACTIONS OF CONCER THIS PRACTICE HAS BEEN CONS'STENTLY FOLLOWED BY STP PERSONNEL '

STP ELECTRICAL DEPARTMENT PERSONNEL HAVE A PROCEDURE THAT EXPUCITLY ADDRESSES THIS ISSUE AND AT THE TIME OF THE F1NDING STP l&C PERSONNEL HAD A DRAFT OF A PROCEDURE IN PROGRESS. l&C PERSONNEL IN UEU OF A PROCEDURE PRACTICED THE PHILOSOPHY NOTED ABOVE 9 TO DATE, STP HAS NOT HAD ANY INCIDENTS OR ANY INDICATION

'

OF PROBLEMS AS A RESULT OF THE CURRENT APPUED PRACTICE OF NOTING ACTIONS TAKEN ON THE MAINTENANCE WORK REQUEST FORM NRC007

!

._

'n

!

CORRECr1VE ACHOX I

AT THE DIRECTION OF THE PLANT MANAGER, RESULTING FROM

THE NRC'S CONCERNS, THE MAINTENANCE MANAGER PERFORMED AN l IN-DEPTH REVIEW OF THE ENTlRE PROCESS FOR CONTROLLING Lit Itv i

LEADS, JUMPERS, AND FUSES. AS A RESULT,9 PROCEDURES THAT 1 IN SOME FORM ADDRESS THE SUBJECT ACTIONS WILL BE

!

l REVISED BY JUNE 15,1988 TO ENSURE PROGRAM COHESIVENESS. A .

, SINGLE NEW PROCEDURE WILL BE DEVELOPED FOR CRAFT PERSONNEL '

!

! USE DURING TROUBLE-SHOOTING. THIS PROCEDURE WILL BE DEVELOPED BY JUNE 15,1988 i

i l

!

'

I I

( NRC008

.. . - - - - - _

l t

EVEST

!

! * ON HBRUARY 13,1988, AT 4:17 A.M. THE PLANT OPERATORS VIOLATED TECHNICAL SPECIFICATION 3.5.2 FOR ADEQUATE I NUMBER OF OPERABLE ECCS TRAINS. THE PLANT WAS IN COMPLIANCE

! WITH TECHNICAL SPECIFICATION 3.0.3 PRIOR TO THIS TIME WITH 1 A COOLDOWN IN PROGRESS

ON RBRUARY 13,1988, AT 12:07 P.M., THE PLANT OPERATORS

!

RECOGN! ZED THAT THEY WERE NOT IN COMPLIANCE WITH TECHNICAL

! SPECIFICATION 3.5.2 AND RE-ENTERED TECHNICAL SPECIFICATON 3.0.3, i PROCEEDED WITH THE PLANT COOLDOWN AND REACHED MODE 4 AT '

I 1:17 A.M. ON FEBRUARY 14,1988

! .

l ROOT CAUSE

8 PERSONNEL ERROR IN THAT THE OPERABILITY TRACKING LOG WAS l

! INCORREC11_Y UPDATED AND MAINTAINED WITH REGARD TO AFFECIt.D

! ESF EQUIPMENT

!

j NRC009 i

_ _ - _ _ . _ _ _ _ l l CORRECr1VE ACr10X ..

-

!

! * PLANT OPERATIONS PROCEDURE OPOP01-ZQ-0030 HAS BEEN REVISED i TO PROVIDE A MORE STRUCTURED TECHNICAL SPECIFICATION REVIEW FOR

'

IMPACT OF INOPERABLE EQUIPMENT BOTH FOR THE EQUIPMENT DIRECTLY

'

AFFEC1w AND EQUlPMENT INDIRECTLY AFFECIw. THE REVISED PROCEDURE REQUIRES A THREE PARTY REVIEW FOR EACH TRACKING LOG ENTRY, .

i SHIFT SUPERVISOR, UNIT SUPERVISOR AND STA '

, i

!

i * SPECIAL TRAINING HAS BEEN CONDUCIw FOR UCENSED PERSONNEL, i

EMPHASIZING THE IMPORTANCE OF ACCURATELY DEImMINING THE SUB-

'

SYSTEMS AFFEC1w BY INOPERABLE COMPONENTS USING THIS INCIDENT l AS AN EXAMPLE

i

,

!

COMPUTERlZED MODEL OF THE TECHNICAL SPECIFICATIONS FOR l ANALYZING OPERABILITY ISSUES IS NOW BBNG USED TO j ENHANCE OPERABILITY DtimMINATION

I

!

_

!

NRC010 i

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Maintenance of Plant Operations Lop, books OPOP01-ZQ-0030 Rev. 4 Operability Tracking Log Page 14 of 16

-

OPOP01-ZQ-0030-1 (Page 1 of 1)

.

TRAIN / T. MODES MODE INOPERABLE

_OTL5 SYS OPERABLE COMPONENT CHANNEL LCO RE RESTR. DATE TIME DATE TIME

!

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This Form Shall be Retained a Minimum of One Year.

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hi a inle n a m:e . n L l'1 a nL_Qn e r.M in u rt _ingluwAa o Po Po 1-20 -0030 21'EHlLillI.LT.Y_._IRAC K.I t1G FO R M nev. 4 OPOPol-ZQ-0030-2 Page 15 of 16 (Page 1 of 1)

$

-

OTL# -

_TS LCO# _ Modes applicable - System Component CE- INOP OflTE/ TIME D Eause of INOP Condition HES10HHTION REQUlHED:DHTE TIME 3 HEQUlHED HCTION IF HESTollHTION TIME EllCEEDED:

E d Control Room Log Heulewed? (Initiol)

@ GIL# Entered !n Control Room Log?(Initiol) Comments

$ Tos.Traccing Computer Checked? (Initial)

@i Other Equipment /LCD fiffected !

Prepared By: Unit Su S. Shift Su Action Required IUnite IN0? _ - _ = _ , - _ _ _

.

$

g Initial Actions Performed By

'

g Unit Superulsor's Initials indicate required actions completed. Enter time(enter tirne next next action due indue nentbelow)

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IR 05000498/1988011

Text

Enclosures:

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Text

Enclosures:

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