ML20137Q034

Summary of 970320 Meeting W/Util Re TS Setpoints & Practice of Not Entering LCO Action Statements During Certain Surveillances.List of Attendees Attached

ML20137Q034
Person / Time
Site:	Duane Arnold
Issue date:	04/03/1997
From:	Kelly G NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9704100105
Download: ML20137Q034 (60)

Text

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t April 13,-1997 t

.i LICENSEE:

IES UTILITIES (INC.

~

{

~ FACILITY: 'DUANEARNOLDkNERGYCENTER(DAEC),

SUBJECT:

SUP91ARY.0F MARCH 20,-1997, MEETING ON TECHNICAL SPECIFICATION SETPOINTS AND THE PRACTICE OF NOT ENTERING LIMITING CONDITION OF-OPERATION (LCO) ACTION STATEMENTS DURING CERTAIN SURVEILLANCES On March 20, 1997, a'public meeting was held between the NRC and IES Utilities -Inc. ~(licensee) to gather information on the practices at DAEC of' treating Testical Specification setpoints as nominal values and not entering 4

LC0 action statements when certain equipment is inoperable because of the performance of a surveillance test procedure.

The list of attendees is found in Enclosure 1.

The staff and the licensee discussed these issues,-and the

.l licensee provided handouts in the meeting that are contained in Enclosures 2 and 3.

No final decisions were made by the staff at the meeting, and no i

action items were identified.

i Original signed by:

Glenn B. Kelly, Project Manager

(

Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation

. Docket No. 50-331 Eaclosures:. As stated cc w/encls: 'See next page DISTRIBUTION:

See next page 1

' DOCUMENT NAME:

G:\\DUANEARN\\DUA97I97.MTS

- To receive a copy of this~ document, indicate in the_ box:

"C" = Copy without attachment / enclosure-

"E" - Copy with attachment / enclosure "N" --No copy OFFICE LA:PDI!!*3

.-lE PM:POIII,3

_P NAME G loyle [lM GKetty @%L l DATE<

d '/ 3/9T(1 -

4 / 3 /97

' ]

OFFICIAL-RECORD COPY l

lBC RUECBm3 COPY 9704100105 970403 I

PDR ADOCK 05000331 l,

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PDR,

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%,*4 UNITED STATES y:

)-

NUCLEAR REGULATORY COMMISSION 4"

WASHINGTON, D.C. 30666 4001

'4,*****,o April 3, 1997

)

i LICENSEE:

IES UTILITIES INC.

4 FACILITY: DUANE ARNOLD ENERGY CENTER (DAEC)

SUMMARY

OF MARCH 20, 1997, MEETING ON TECHNICAL SPECIFICATION SETPOINTS AND THE PRACTICE OF NOT ENTERING LIMITING CONDITION OF OPERATION (LCO) ACTION STATEMENTS DURING CERTAIN SURVEILLANCES On March 20, 1997, a public meeting was held between the NRC and IES Utilities Inc. (licensee) to gather information on the practices at DAEC of treating Technical Specification setpoints as nominal values and not entering LCO action statements when certain equipment is inoperable because of the performance of a surveillance test procedure.

The list of attendees is found in Enclosure 1.

The staff and the licensee discussed these issues, and the licensee provided handouts in the meeting that are contained in Enclosures 2 and 3.

No final decisions were made by the staff at the meeting, and no action items were identified.

f*

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'GlennB.Kify",Pojec Manager Project Directorate II -3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosures:

As stated cc w/encls: See next page J

' W 6 Arnold Energy CGnter -

u E82ctric Light and Power Company i

i JatL Newman, Esquire

- Kathleen H. Shea, Esquire Morgan, Lewis, & Bockius 1800 M Street, NW.

Washington, D.C.

20036-5869 Chairman, Linn County-Board of Supervisors

- Cedar Rapids,. Iowa 52406 IES Utilities Inc.

ATTN: Gary Van Middlesworth Plant Superintendent, Nuclear 3277 DAEC Road

- Palo, Iowa 52324 Mr. John F. Franz, Jr.

' Vice President, Nuclear Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324 Mr. Ken Peveler Manager, Nuclear. Licensing j

Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324 3

i U.S. Nuclear Regulatory Commission j

Resident Inspector's Office Rural Route #1 j

Palo, Iowa 52324 l

Regional Administrator U.S. NRC, Region III R

801 Warrenville Road Lisle, Illinois 60532-4531 Ms. Parween Baig Utilities Division Iowa Department of Commerce j

Lucas Office Building, 5th-Floor Des Moines, Iowa.50319 Nr. Lee Liu' Chairman of the Board, President, and Chief Executive Officer IES Utilities,.Inc.

200 First Street, SE

' Post Office Box 351 3

- Cedar Rapids, Iowa 52406-0351 j

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t LIST OF ATTENDEES FROM MARCH 20, 1997, MEETING Nium Oraanization Ken Peveler IES Utilities Inc.

Tony Browning Chuck Nelson Jeff Mahannah Ken Putnam Rob Anderson Dean Curtland William Simmons

. John Franz Glenn Kelly NRC Elinor Adensam Christine Lipa Carl Shulten Chris Grimes Stevie Dupont i

Jim Luehman Cliff Doutt Bob Tjader Doug Weaver f

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ENCLOSURE 1

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wa 4/3/97 Distribution w/encls:

for Meeting Summary to IES. Utilities Inc. dated

,. Docket File (50-331)-

PUBLIC LPD3-3 Reading File OGC

- ACRS

- E-Mail S.~ Collins /F. Miraglia R. Zimmerman (RPZ)-

J. Roe.(JWR)

E. Adensam (EGAl)

G. Marcus-(GHM)

G. Kelly (GBK)c

- C. Boyle (CJB)

D. Ross (SAM)

C. Lipa'(CAL)

C. Schulten (CSSI)

C. Grimes (CIG)

T. Tjader.(TRT)

J. Luehman (JGL)

C. Doutt (CKD)

D. Weaver (DWW)

-S. Dupont (SGD)

B. McCabe (BCM)

W.-Axelson (WLA)

J. Caldwell, RIII i

BNI I

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400036 2

i-l UTUTES i

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Duane Arnold Energy Center l

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Meeting with NRC on 4

Technical Specification Setpoints l

and Entry Into LCO Conditions i

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March 20,1997 l

1 0c s OSuRL K

AGENDA INTRODUCTION J. FRANZ i

INSTRUMENTATION HISTORY K. PUTNAM-SETPOINT CONTROL PROGRAM C. NELSON L

.SETPOINT EXAMPLES J. MAHANNAH i

. DISCUSSION AS NEEDED i

i CLOSURE ON SETPOINTS K.PEVELER ENTRY INTO LCO'S FOR SURVEILLANCE T. BPOWNING 1

SUMMARY

J. FRANZ l

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DAEC Target - 97

0 E Assure continued compliance with DAEC Technical Specifications.

i E Rigorous Setpoint Control Program in accordance with standard methodology that supports outstanding level of safety.

EImproved Standard Technical Specifications implemented that are supported by the Setpoint Control Program.

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l DAEC - Licensed 2/22/74 l

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1 Custom T.S. with Plant Unique LSSS and Instrument Calibration Definition Pre-Standard Review Plan l

No Standard Setpoint Methodology i

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DAEC Technical Specification Definition 1.0.2 i

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Limitine Safety System Settine (LSSS)

... The limiting safety system setting plus the tolerance given in the system design control document gives t'he limiting trip point for operation... The j

inequality sign which may be given merely signifies 1

the preferred direction of operational trip setting.

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l Docketed Examples l

Two-sided tolerance under design control re-affirmed in j

the licensing basis for DAEC.

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--Amendment 1, 4/11/74

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--AO 75-49

--LER 77-61

--IR 81-13 i

--AO 75-52

--LER 78-05

--LER 82-04 i

--IR 75-13

--LER 79-34

--LER 83-03

--LER 76-09

--LER 80-08

--LER 77-05

--LER 81-31

--And Others I

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i Amendment 1 to DAEC License X

j "It is not necessary to include tolerances in the Technical Specification. Tolerances are given in the system design control documents as stated in i

1 Specification 1.0.2 of these Technical Specifications."

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i LER 76-009 m

' '::O "In accordance with the Technical Specifications, the limiting setpoint for operation is 204 F (200 F Tech Spec limit plus 4 F instrument tolerance)."

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l DAEC Integrated Plan Initiative m

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DAEC Integrated Plan Initiative to reconstitute and l

upgrade design bases of Technical Specification instrument setpoint margins. (11/4/91) l I

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Inspection Report 93-23 h a 1_0 "The LSSS trip set point in TS was the minimum j

"as-left" value, and the acceptable "as-found" range in the STP was based on the instrument tolerance and trending program. The " allowable value" was developed with adequate margin to 1

ensure the TS safety limit was never exceeded. As long as the "as-found" value was above the j

" allowable value" and the "as-left" value was above the TS trip setpoint, the instrument was considered operable."

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4 Inspection Report 93-23

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" Management from Region III and the Office of Nuclear Reactor Regulation initially determined the use of" allowable i

values" to determine the operability of an instrument was acceptable even though not described in the licensee's T.S. or j

surveillance procedures. The licensee had been in the process j

of developing and documenting the " allowable values" for the instruments in TS in order to support a TS amendment change. The licensee planned to submit the TS amendment change in late 1995 or early 1996."

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STS Conversion l

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December 1994 IES commits to conversion to STS NUREG 1433 and revises commitment for instrument setpoint to coincide with STS conversion.

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Conclusions:==

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E Original Licensing Bases allowed two sided tolerance around nominal trip setting.

l E Reconstitution and upgrade of Setpoint Control Program performed in accordance with DAEC Commitment.

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E Commitments made on 2/25/97 ensure compliance to current Technical Specifications.

E Transition from Custom T.S. approach for Instrument l

Setpoint to STS approach in acebrdance with DAEC l

Commitment.

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Setpoint Methodology i

Presentation to NRC March 20,1997 1

ChuckNelson Principal Engineer, DBD/UFSAR Team 1

IES Utilities i

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.i Introduction j

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e The DAEC Setpoint Control Program assures safe and conservative operation of the plant.

e The DAEC Setpoint Control Program complies with the current Technical Specifications, and supports the transition to the Standard Technical Specifications.

e The DAEC Setpoint Control Program is founded on the design and licensing bases.

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Agenda f

e Vocabulary e Methodology e Design Basis Reconstitution e Setpoint Changes 1

e Process Highlights l

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Vocabulary Terminology ITS/GE CTS STP SL SL e

Safety Limit AL AL e

Analytic Limit m,,

C (ALT),

Region of e

Operational Limit t

PEA, PMA, Inoperability AS-B M_S..-

e Allowable Value AV LTPO FOUND MAX AT D e

Limiting Trip Point for Operation

Cgitfi, AN D,

t o

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'M JALT) e As-Found Tolerance NTSP MS e

Limiting Safety System Setpoint NTSPaa o

Trip Level Setting p,

AS LSSS AS-LEFT e

Nominal Trip Setpoints MAX LER Avoidance As-Left Range

^U""

Spurious Trip Avaoidance o

As-Len Tolerance NTSPTA e

Actual Setpoint AN, D, C (ALT),

e Instrument Uncertainties t

o t

""^' ""^' #8 e

Instrument Drift OL

w A

e Setpoint Contml Cunent Technical Specifications Safety Limit l

Original Plant Design (AE

{

Margin Analysis)

Analytical Limit INOP Limiting Trip Point oP for Operation

. Tolerance of the STP As-Found Limit l

Instrumerit given in i

t system design documents Trip Level Settmg, e

Limiting Safety System Setting

. Technical Specification Value l

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l Setpoint Contml Standait! Technical Specifications

• Safety Limit Margm Analytic Limit a

From Plant Safety Analysis j

Allowance for or Design Basis Instrument Accuracy Reconstitution and Calibration, and other Uncertainties per GE Methodology, ISA-i INOP STo-s7.04 Allowable Value OP STP As-Found Limit Tech Spec Limit Allowance for Drift

= Actual Setpoint STP Values

I DAEC Setpoint History i

e 1974 - 1985 AE/NSSS Vendor Supplied Setpoints (Turnkey)- Amendment I to Technical Specifications e 1985 - 1991 Engineering Calculations based on some uncertainties, calculated head corrections replaced previously measured head corrections e 1991 - 1996 Industry Standard Methodology Design Basis Reconstitution l

e 1996 - 1997 Conversion to Standard Technical Specifications

Derivation of DAEC Setpoint j

l Control e 10 CFR 50.2 " Design Bases" i

e 10 CFR 50 Appendix B " Design Control" j

e RG 1.105 e ISA-S67.04 e GE Setpoint Methodology NEDC-31336 e DAEC Instrument Setpoint Guide DGC-E111 l

e Administrative Procedures 1203.70, 1203.701 1

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E ISA S67.04 Methodology e NRC Endorsed by RG I

Safety Limit 1.105 Analytical Limit

-- - )

Allowable Value

_..__._____ _ L Nominal Trip Setpoint

GE Setpoint Methodology Safety Limit e NRC Endorsed by Ar ** tical Limit SER e Use more conservative ofNTSP and NTSP

_ _n Allowable Value LER as bound for as-3 t__

left actual setpoint NTSP LER Nominal Trip Setpoint As-Left, AS Region o Spurious Trip NTSP STA Avoidance Operational Limit f

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Design Basis Reconstitution l

From AL with Acceptable LSSS

- At e Most common case i

during setpoint design basis reconstitution

,g, e Implement AV in Av Surveillance o,

Procedure i

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-- utse e :Vo Technical Specification Change tsss untilITS (AV)

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l Design Basis Reconstitution l

From AL with a More Restrictive NTSP

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AL e Must lower LSSS e Issue AR for Operability /Reportability based on AV e TS Change Submitted INOP with ITS (October,1996)

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.- AV op e AV implemented in Surveillance LSSS e Alternative is to

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g7 NTSP reanalyze, justify LSSS e

..~1 Reconstitution from AL vs Reengineered AL t

e Maximize Uncertainties Safety Umit Safety Limit (Margin) when working Analytical Limit from Analytic Limits F~

e Minimize Uncertainties Analytical Limit when back-calculating to c-derive conservative candidate AL and AV v

v Allowable Value Allowable Value e Future work based on this

____.._1--

AL, look for better basis' NominalTrip Setpoint Nominal Trip Setpoint l

or reanalyze Reconstitution Reengineering e Example - SLDS i

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Modification to Install a More Accurate Instrument

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i e No TS Change if keep current LSSS e TS Change to use new NTSP - example New AV INOP

- Av HPCI/RCIC Steamline

$p High Flow t

e New AV implemented a

- tsss

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in Surveillance

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4 Instrument Degradation - Increased Drift AL e Case may arise from trending or root cause of

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LER e Revise ALT to more l

Conservative NTSP i

NOP e TS Change under CTS

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Ay op e AV unaffected l

- Note that under Standard

-- { -

- tsss TS, no TS change is needed (AV doesn't

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change)

NTSP

O As-Left Tolerances e Cases 1 and 2 were ALT LSSS consistent with initial Licensing Basis e Case 3 would be permitted tsss by methodology provided full ALT is within NTSP i

e Per February 25,1997 case 2 Commitment Letter NG-97-0395 only Case 2 ALT will be used until ITS is tsss approved case 3 1

Process e Design Bases Research TransientAnalyses AccidentAnalyses Tech Specs, SAR, FSAR, UFSAR System Specifications, Drawings, Calculations StartupTesting i

DBDs - especially Design Safety Standards, Nuclear Safety Criteria, Nuclear Safety Operational Analyses, List of Safety i

Structures, Systems, and Components LERs, SILS, Operating Experience, Topical Reports, Modifications, Procedures i

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l Process e Multi-disciplinary Setpoint Control Review and Discussions to ensure understanding of the design bases e Engineering Calculations using GE Setpoint Methodology Independent Verification Actual plant calibration, drift data checked against assumptions i

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Process L

e Setpoint Control Program Owner e Setpoint Controls Interfaces Corrective Action Program

- Operability and Reportability

- Operating Experience UFSAR, Technical Specifications i

Modifications, Repairs, Replacements Maintenance, Surveillance Procedures Measurement and Test Equipment InstrumentTrending Safety, Transient Analyses

Process (Historical) e Low Low Low RPV Level Inaccuracy at Accident Conditions LER 92-001 e

HPCI/RCIC Steamline High Flow Isolation RTS-244 Amendment 187 e

RWCU Leak Detection RTS-248 Amendment 188 e

APRM High Flux SCRAM Margin DBD Issue Revised Reload Transient Analysis s

e Drywell Pressure SCRAM Margin DBD Issue Revised Reloads Transient Analysis, LOCA Analysis e

APRM 125% Clamp Not Tested LER 94-00I o

RCIC Low Steam Pressure Instrument Drift LER 94-002 e

Degraded Voltage Relay Harmonics LER 94-012 L

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EOC-RPT Technical Specification Acceptance Criteria RTS-286A Amendment 216 1

Process Evaluations e 1992 Safety Committee Audit e 1994 Comparison of Calculations to STPs e 1994 DAEC participated in Tech Specialist Exchange Audit at another plant o 1995 Engineering, Teclinical Support NRC Inspection o 1995 XRC System Based I&C Inspection e 1996 Reviews for GL 96-01, new cales for ITS j

e 1997 Review for this meeting

I Summary e The DAEC Setpoint Control Program is a STRENGTH.

1 Setpoint Control Program Ensures Compliance to Technical Specifications and Licensing Bases.

Setpoint Control Program has Improved Plant Knowledge and Understanding of Design Basis.

Setpoint Control Program is based on Approved Industry Methodologies and Conservative Decisions.

Setpoint Control Program has Improved Plant Safety and Reliability.

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_-__----.----_.~.--l Example Setpoints

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Presented by Jeff Mahannah

+ Main Steam Line Low Pressure

+ Reactor Vessel Low-Low-Low Level i

+ Regulatory & Design Control of DAEC Technical Specification Setpoints i

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Relationship Between Variables for Main Steam Line Low Pressure - PCIS Group I isolation AFTER 2/25/97 (GE Setpoint Methodology) i GE Meth CTS STP Infms Terms Terms sao psig OL

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AN, D. C (ALT),

t t

t PEA, PMA, BIAS A$+ALTl AS-LEFT 856 psig u

NTSPTA MAX As-Left Range TRIP /

850 psig AS LSSS AS-LEFT MIN 8M psig NTSPLER

- o 828 psig NTSP C( T) t C kLTI.

PEA PMA.

AS AS-FOUND 820 psig AV LTPO MIN o

AT,

t C (ALT).

Region of t

P PMA.

Inoperablllty E9 AL AL

-. - ~ -

a DAEC Chronology of the Reactor Water Level Low-Low-Low Setpoint AS-LEFT 69.BinRWL AS-LEFT 69.8inRWL MAX MAX TRIP /

63.8inRWL TRIP /

63.8inRWL AS-LEFT.

AS-LEFT AS-LEFT 52.SinRWi-MIN MIN MAX AS-FOUND 57.8inRWL 46.5inRWL MIN TRIP AS-LEFT/

40.SinRWL AS-FOUND MIN AS-FOUND 38.3inRWL MIN 28inCWD 45.31nRWL AS-LEFT 24.5inRWL offset offset MAX 18.SinRWL TRIP AS-LEFT/

12.SinRWL AS-FOUND MIN 0 inRWL Plant 1979/1982 1992 1993-Present Startup SIL-299 Rev.0 CAL-E92-006 GEllE Re-analysis DCR 1048 SIL-299 Sup.2 CAL-E93-016 i

LER 92-001 1

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DAEC Chronology-ofthe Reactor Vessel Low-Low-Low Setpoint Time Period Reactor Vessel Low-Low-Low Setpoint Plant Startup Nominal Setting is 18.5 inRWL, As-Left Tolerance (ALT) = As-Found Tolerance (AFT) =

+/-6 inRWL 1979-82 GE SIL-299 Rev 0 identifies potential 12.7% (28 inCWD) offset due to LOCA environmental conditions. SIL-299 does not clearly identify that offset is specified in units of inCWD differential pressure rather than inRWL.

i lE (and other utilities) erroneously incorporate 28 inCWD offset. DCR 1048 changes in-plant setting from 18.5 inRWL to 46.5 inRWL (i.e. 18.5+28=46.5 inRWL, ALT = AFT = +/- 6 i

inRWL) 1992 During setpoint reconstitution IE notices error in DAEC level setting and likely generic i

misinterpretation of SIL-299. IE immediately corrects DAEC settings and notifies GE that SIL-299 should indicate an 18% (45.3 inRWL) offset in terms of inRWL. in-plant setting changed from 46.5 inRWL to 63.8 inRWL (i.e. 18.5+45.3=63.8 inRWL, ALT = +6/0 inRWL, AFT = -6)

IE issues LER 92-001 and NRC commends DAEC for prompt corrective action and Setpoint Reconstitution Program. GE lssues Supplement 2 to SIL-299 with clarifications.

l 1993-Present GE/IE re-analyze setpoint and offset with latest information and methodology (CAL-E93-l 016). Results show existing in-plant settings are conservative. TRIP and ALT not changed.

AFT revised to be consistent with latest analysis.

Regulatory & Design Control of DAEC Technical Specification Setpoints BASIS FOR CONTROL:

1. Values in Technical Specifications have been reviewed by a formal Setpoint Reconstitution Project.

Results of reviews are formally documented.

2. Per NG-97-0395 dated February 25,1997, in-plant settings are left on the preferred side of the Technical Specification value or the setpoint calculation Nominal Trip Setpoint (which ever is more conservative).

Instrument operability will be determined by use of Surveillance Test Procedure As-Found criteria which corresponds to the Allowable Value determined during the Setpoint Reconstitution Project.

3. DAEC uses an NRC Approved GE Setpoint Methodology that establishes appropriate margin between the Nominal Setting, Allowable Value and Analytical Limit to account for drift and other uncertainties.

4. The DAEC has a dedicated Setpoint Control Coordinator responsible for reviewing changes to setpoints to ensure proper use of the GE Seipoint Methodology and consistency between DAEC procedures, design and licensing documents.

CONCLUSION:

The combination of these controls ensure the current DAEC Technical Specifications adequately protect operability of criticalinstrumentation.

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Entering LCOs during Tech Spec Surveillances Tony Browning Sr. Principal Licensing Eng.

IES Utilities Dm 1

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Entering LCOs during Tech Spec I:

Surveillances

+ History 1

EOriginal Licensing Basis EPlant Design Basis 1

EOriginal Tech Spec Basis

+ Hardships

+ Discussion of Possible Actions i

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-A Entering LCOs during Tech Spec I;

Surveillances

+ Original Licensing Basis EReliability Analyses i

APED-5736: Guideline for Determining Safe Test Intervals and Repair Times for Engineered Safeguards, (ref. TS 3.5 Bases)

NEDO-10739: Methods for Calculating Safe Test Intervals and Allowable Repair Times for Engineered Safeguard Systems, (ref. UFSAR Section 6.3.4.2.1) 3

Entering LCOs during Tech Spec Il Surveillances

+ Original Licensing Basis (cont.)

EReliability Analyses Purpose - Optimize Overall Reliability Test Time (Surveillance) = Maximize Availability Repair Time (LCO) = Minimize Risk i

>> Test Time << Repair Time l

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+ Design Basis ERecovery from " Secondary Modes of Operation"Not Assumed in Accident Analysis 1

"It shall not be necessary that the closing speed of the valves in the system test lines be greater than the manufacturer's standard (12"/ min). This shall be based on the philosophy that the Emergency Core Cooling System (ECCS) are not designed to i

recover from secondary modes ofoperation, such as testing, because the period of time that the ECCS are in these secondary modes of operation is so short that the effect on overall reliability is insignificant." (GE Spec. 22A1341) i f

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Entering LCOs during Tech Spec Surveillances j

+ Design Basis (cont.)

EKey Assumption of Accident Analysis is that systems are in " standby readiness" at the beginning of the event.

" Engineered safeguard systems are standby systems.

They are tested perio~dically to assure that they are operable and returned to standby status."

(ref. APED-5736) 6 i

+

Entering LCOs during Tech Spec surveillances

+ Design Basis (cont.)

EThey are not assumed to respond to the event i

from secondary modes of operation, even though they will re-align.

"The automatic control circuitry for the emergency core cooling i

systems is arranged to restore each of the systems to normal operation if a LOCA should occur during test operations.

l However, certain tests, such as flow tests of the emergency core cooling pumps, require manual override of the automatic circuitry and, following such tests, the system must be restored manually to automatic control."(UFSAR Section 7.3.4.2) 7

-4 Entering LCOs during Tech Spec Surveillances

+ Design Basis (cont.3 E System recovery time from secondary modes was not intended to support accident analysis mission time.

Example: Core Spray (CS) system Test Bypass Valve Stroke Time: 40 secs.

CS Mission Time (LOOP-LOCA) : 27 secs. (original) i CS Mission Time (LOOP-LOCA) : ~ 43 secs. (current) l 8

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Entering LCOs during Tech Spec Surveillances

+ Original Tech Spec Basis EDAEC Tech Specs were not constructed with the assumption that systems were inoperable during required surveillances.

" Conditional Surveillances": if"A" is inoperable, then test "B" immediately and daily thereafter.

IF systems are considered inoperable during testing, and the LCO actions entered, then this requirement creates a paradox that requires a plant shutdown, i.e., no LCO (repair) time would be allowed.

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Entering LCOs during Tech Spec Surveillances L

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+ Original Tech Spec Basis (cont.)

ECCS " Keep -fill" System LCO action requires that the affected ECCS be placed into test mode OR to cascade and j

declare the ECCS inoperable. The "or" logic implies that these actions are not the same.

>> HPCI quarterly flow testing requires RHR alignment in Torus f

l Cooling mode to maintain suppression pool temperatures l

within TS limits.

j IF both systems are considered inoperable during this test, because they won't support the accident analysis requirements, t

and the LCO actions are entered, a plant shutdown would be required.

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Entering LCOs during Tech Spec Surveillances l

+ Original Tech Spec Basis (cont.)

MDAEC has previously communicated this information to the Staff.

GL 89-10 (MOV Program) correspondence.

+ Meeting at NRR - Sept. 22,1994

+ IES Letter-Nov. 30,1994

+ IES Letter-Mar. 10,1995 I1

L Entering LCOs during Tech Spec J

L Surveillances

+ Examples of" Hardships" with Entering LCO Actions during TS Surveillances l

E "It is not the intent of surveillances or other similar program requirements to cause unwarranted plant l

shutdowns or to unnecessarily challenge other safety systems."(Generic Letter 91-18)

HPCI quarterly flow test, previously mentioned, would enter a l

shutdown action.

CS Simulated Auto Actuation test, affects both CS and its l

associated Diesel Generator, requiring entry into a shutdown action.

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Entering LCOs during Tech Spec Surveillances 4

+ Examples of" Hardships" with Entering LCO Actions during TS Surveillances (cont.)

Standby Liquid Control system quarterly flow test, affects both trains, requiring entry into a shutdown action.

Standby Gas Treatment system flow test, affects both trains, requiring entry into a shutdown action.

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Entering LCOs during Tech Spec Surveillances i

+ Why Enter LCOs?

EEnsures Operator Awareness of Plant Status.

E Requires " cross-train / loss-of-function" checks.

ELimits the amount of time system is out-of-service.

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'l Entering LCCis during Tech Spec t:

Surveillances i

+ Current Practices:

i N On-line work planning - coordinates system j

maintenance and surveillance testing.

E On-lme risk guidelmes - mimmizes plant risk during planned maintenance outages.

EPlanned Time in LCO is limited (~50% TS LCO Time).

m" Cross-train" checks done just prior to

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L performing Surveillance.

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