ML20237K184

Responds to Chrissotimos 870304 Request for NRR Position on When Tech Spec Action Statement Clock Begins When Inservice Test Surveillance Results in Required Action Range.Nrr Position Same as That Provided in Bryan 800317 Memo

ML20237K184
Person / Time
Site:	Dresden, 05000000
Issue date:	08/31/1987
From:	Rossi C Office of Nuclear Reactor Regulation
To:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20235F425	List: ML20235F422 ML20237K184
References
NUDOCS 8709040240
Download: ML20237K184 (1)

Text

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MEMORANDUM FOR: Wi11iam V. Johnson,' Acting Director Division of Reactor Safety, Region I Albert F. Gibson, Director

! Division of Reactor Safety, Region II

, /Hubert J. Miller, Director V Division of Reactor Safety, Region III l

Ramon E. Hall, Acting Director Division of Reactor Safety & Pro.iects, Region IV Dennis Kirsch,-Director Division of Reactor Safety & Pro.iects, Region V FROM: Charles E. Rossi, Director Division of Operational Events Assessment, NRR

SUBJECT:

NRR's POSITION ON WHEN' TECHNICAL SPECIFICATION LCO ACTION STATEMENT' CLOCK BEGINS WHEN IST SURVEILLANCE RESULTS ARE IN THE REQUIRED ACTION RANGE (AIT F03007687)

This memorandum is in response to Mr. Chrissotimos's March 4, 1987. request for NRR's position on when the Technical Specification ACTION statement clock begins when IST surveillance results are in the Required Action Range as defined by Section XI of the ASME boiler and pressure vessel code. NRR's position on this issue is the same as that which was provided earlier by IE (memorandum from

5. Bryan, IE to R. L. Lewis, RII dated March 17, 1980, enclosed).

That is, the Technical Specification ACTION statement time begins upon detennining that the data falls into the Required Action Range and indicates that a tested component cannot perform within its design envelope. No time is allowed for an analysis to determine whether the component can be considered OPERABLE.

With respect to Mr. Chrissotimos's request for an Information Notice on this matter, I believe that regional management awareness of this position coupled with regional action makes ao'ditional generic communication unwarranted at this time.

Gharles E. Rossi,.c irec or$ Y Division of Operational Events Assessment, NRR

Enclosure:

As stated cc w/ encl:

. P. Shemanski, NRR

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MAR 17'1980 ROI Rdg.

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SS!!:S ;!o. 6025 7

9 "EMORANDUM FOR: R. C. Lewis, Acting Chief, RO&NS Branch, Region II FR0": Sanuel E. Bryan, A/D for Field Coordination, DROI, IE \

SUSJECT:

OPERABILITY REQUIREMENTS FOR PUMPS (AITS NO. F02-700028-H07)

As we understand then, the questions in your february 1 memo are:

1. Do the Technical Specification ACTION statement time perios run consecutive er concurrently with the data evaluation time (96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />) given in IWP-3220 of Section XI of the ASME Boiler and Pressure Yessel Code,1974 Edition sith Addenda thru the Sumer 1975, and

~ 2. When should the test results be reviewed and, if out-of-specification, the associated puup declared inoperable?

The answer to the first goestion is the Technical Specification ACTION state-

ent ti~e period starts af ter the determination is made that the pump is inoperable as defined in W ion XI, SWP-3230fc). If the data is within the

!'equired Action Range of Table IWP-3100-2 and it is decided to recalibrates the instruments and rerun the test, as provided for in IUP-3230(b), the Technical Specification ACTION statement time starts when the determination is rade that the data is within the Required Action Range. The reasoning Lehind the prcceeding statement is that once the determination is made that the data is within the Required Action Range the pump must be declared inoperable. The provisions in IWP-3230 to recalibrates and rerun the test to show the pump is still capable of fulfilling its function are interpreted by us, as an alternative to replacement or repair, not an additional action that can be taken before declaring the pump inoperable.

The erswer to the second question is that~as soon as the data is recognized as being within the Required Action Range the pinp must be declared inoperable.

l Section XI, IVP-6230, " Inservice Test Plans", states" Eat the test plan shall include "The reference values (Tabic IWP-3100-1), limits of Pt and Tb (Table l IUP-3100-2), and any other values required by this Subsection." This statement CONTACT: J. C. Stone, IE rac7 x,tni t

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l then requires the acceptance criteria to be included in the test plan.

With that infomation available, the shif t supervisor should be able to make the determination as to whether or not the data meets the requirements.

The important point is that once the data becomes available that shows the pump cannot meet the inservice inspection requirements and by dM inttion cannot fulfill its function then the punp must be declared inope.able. ..

We have discussed the above interpretations with DDR personnel and the Standard Technical Specification Group and they agree. If you have any further questions, please call.

Samuel E. Bryan

. Assistant Director for Field Coordination

- Division of Reactor Operations Inspection, IE-cc: N. C. Moseley, IE J. S. Wetmore, STS G. Johnson, EB J. C. Stone, IE -

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FEB 011980 SSINS 6025 MDf0RA!MM FOR: S. E. Bryan, Division of Reactor Operations Inspection, Office of Inspection and Enforcement FROM: R. C. Lewis, Acting Chief, Reactor Operations and Nuclear Support Branch, Region II

SUBJECT:

OPERABILITY REQUIRDiENTS (AITS No. F02700028)

A concern was recently identified involving the starting point for time periods in Technical Specification ACTION statements.when equipment has been declared inoperable under the ASME Section XI testing program.

AS!!E fection XI, IVP-3220, states "All test data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test". IVP-3230(c) states, in part, "If the deviations f all within the ' Required Action Range' of Table IVP-3100-2, the pump shall be declared inoperative. . . . . "

In most cases equipment covered by ASME Section XI, IVP, is also covered by Technical Specifications and, if, declared inoperable, vould result in the plc.nt entering an ACTION statement. These ACTION statements generally have a time period af ter which, if the equipment is still inoperable, the pidat must perform some specific action (shutdown, cool down, etc.).

The concern arises in the area of the aforementioned data analysis interval versus the Technical Specification ACTION statement time period. It is quest unable whether or not these periods run consecutively, concurrently or otherwise. The enclosed scenario's detail likely plant events and are indicative of actual experience.

Region II believes that a reasonable time for data analysis is not more than two shif ts (16 hcurs) except in extreme circumstances. The Technical Specification ACTION time should start immediately af ter the data has been reviewed by the cognizant supervisor (shif t supervisor, foreman, etc.). Licensee procedures must require prompt review by the cognizant supervisor when test results fall outside acceptance criteria.

CONTACT: B. R. Messitt 242-5595 f "p m .

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FEB 011980

s. E. Bryan ,,, l We do not believe that ASME Section XI statement on evaluation of test data relieves the licensee of action statements in Technical Specifications. i We request that this matter be reviewed and our understanding be confirmed or guidance issued to provide uniformity.

R. C. Lewis, Acting Chief Reactor Operations and Nuclear Support Branch l

Enclosure:

Field Experience Regarding Equipment Operability 1 1

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ENCLOSURE FIELD EXPERIENCES RECARDING EQUIPMENT OPERABILITY 4

1. A Section XI test is run on an engineered safety feature pump on Saturday mooring and the data f all on the lowest limit of the

" Required Action Range" just above the " Alert Range". The plant Performance Engineer, who performs the data review and would be the individual- to declare the pump inoperative, is not on site until Monday morning when the data set is reviewed. -

On Monday, the Performance Engineer reviews the data and declares the pumpinoperable per the Technical Specifications and thus

" starts the clock" on the ACTION statement time period.

Most Licensees would view this as acceptable due to the 96-hour statement included in IVP.

2. A saf ety-telated pump is tested and the data f all within the

" Required Action Range"The Performance Engineer orders that the instruments be recalibrates (24-36 hours) and the test re-run as allowed by IVP-3230(b). The test is re-run and the data are

. still in the " Required Action Range". The Performance Engineer declares the pump inoperable and " starts the clock".

Th$s might be done in order to extend operation until a scheduled j outage. -

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3. A safety-related pump is tested and the shif t supervisor notes that the data appears to f all into the " Required Action Range"; however, he feels it should be further analyzed. The data are transmitted to the Ferf ormance Engineer who waits 2-3 days to make his analysis and then declares the pump inoperable thus " starting the clock" (at this point he could also request the test be re-run, adding more time to the cycle).

This also might be done to extend operations until a scheduled outage or to delay plant shutdown until the weekend.

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