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

November 21, 1997

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)]."

9711180029

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.