United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 97-80: Licensee Technical Specifications Interpretations

UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001

November 21, 1997

NRC INFORMATION NOTICE 97-80: LICENSEE TECHNICAL SPECIFICATIONS INTERPRETATIONS

Addressees

All holders of operating licenses for nuclear power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees to problems identified with licensee technical specifications (TS) interpretations. For the purpose of this information notice, a "licensee TS interpretation" is written guidance developed by a licensee for use by the licensee's staff. NRC does not review or concur in licensee TS interpretations. It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances

Many licensees have established TS interpretations to help their plant staff understand and correctly implement TS requirements. Recent NRC reviews found that approximately 80 percent of reactor power plant licensees have TS interpretations. However, these reviews identified questionable interpretations of TS requirements and statements that implied NRC concurrences in the interpretation.

The following examples of inappropriate licensee TS interpretation were noted:

1.  A TS interpretation allowed the plant to operate at full power when only one 345-kilovolt transmission line was capable of supplying offsite power to the plant. This conflicted with the TS basis, which discussed reducing power to 50 percent when only one 345-kilovolt line was available.

2.  A TS interpretation for a pressurizer power-operated relief valve (PORV) did not require the PORV to be declared inoperable if the control switch in the control room was placed in the closed position. This was contrary to the TS and the NRC safety evaluation for a TS amendment implementing the licensee's response to Generic Letter 90-06, "Resolution of Generic Issue 70, `Power-Operated Relief Valve and Block Valve Reliability,' and Generic Issue 94, `Additional Low-Temperature Overpressure Protection for Light-Water Reactors,' Pursuant to Section 50.54(f) to Part 50 of Title 10 of the Code of Federal Regulations [10 CFR 50.54(f)]."

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3.  A TS interpretation related to annual auto-start testing of the emergency diesel generator (EDG) specified that only the breakers for the equipment loads need to operate in the correct sequence and at the correct time. Consequently some of the larger EDG loads were not started and sequenced onto the bus during the annual test and the EDG's ability to handle in-rush currents and the acceleration times of large motors was not demonstrated.

4.  A TS interpretation allowed the EDG fuel oil transfer system to be out of service for a predetermined time period without requiring the EDG to be declared inoperable. This was contrary to the TS operability definition for auxiliary equipment and related support functions.

5.  Numerous examples were found of TS interpretations referencing discussions between the licensee and an NRC inspector or project manager. In one instance, an NRC inspector's signature was on a TS interpretation, giving the appearance that the NRC had approved the interpretation.

Discussion

Licensee TS interpretations can enhance the safe operation of the plant by helping the plant staff understand and correctly implement TS requirements. However, licensees must exercise caution to ensure TS interpretations do not change the wording, the meaning, or the intent of TS requirements. Since the NRC does not endorse or approve particular TS interpretations, there should be no reference to NRC involvement in the TS interpretation. An exception is referencing official NRC correspondence in the TS interpretation. This is an acceptable practice.

Licensees should be aware that there are several NRC recognized methods for resolving TS questions or clarifying TS requirements. Licensees are encouraged to pursue one of these methods when they have a question concerning TS compliance and want the NRC to formally recognize their position. The methods include (1) amending the license to change the TS wording; (2) revising the TS bases via 10 CFR 50.59 or 50.90 (when an unreviewed safety question is identified) to clarify the TS requirement; or (3) formally requesting a written interpretation from the Office of Nuclear Reactor Regulation (NRR) regarding the intent of the TS requirement (for clarity these are referred to as "NRC-approved TS interpretations)."

NRC inspectors routinely review applicable TS interpretations when verifying that plant operations are in compliance with TS requirements. The inspection staff has been given guidance to never concur or become involved in the approval process for licensee TS interpretations. Licensees should not infer from an inspector having reviewed and not questioned a TS interpretation that the inspector has approved the interpretation.

This information notice requires no specific action or written response. If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

signed by

Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation

Technical contact: Ronald Frahm, Jr., NRR
301-415-2986
E-mail: rkf@nrc.gov
Page Last Reviewed/Updated Wednesday, December 04, 2013