Issue Date: 10/01/77 - 1 - 9900 STS Surveillance

NRC INSPECTION MANUAL

PART 9900: TECHNICAL GUIDANCE

STS_SURV.TG

STANDARD TECHNICAL SPECIFICATIONS

SURVEILLANCE SECTIONS - LOCKED OR OTHERWISE SECURED COMPONENTS

A. PURPOSE

To provide guidance to the IE inspector regarding the term "locked

valves" as used in the surveillance sections of Standard Technical

Specifications (STS), other TS, and the SAR.

B. DISCUSSION

The STS surveillance section generically requires that certain

systems be demonstrated operable at least once per XX days by

verifying that each valve (manual, power-operated, or automatic) in

the flow path (or servicing safety-related equipment) that is not

locked, sealed, or otherwise secured in position, is in its correct

position. Likewise, the TS or SAR often refer to a valve as being

locked open or locked closed.

To be locked, according to Webster's New World Dictionary, is to be

"fastened by means of a lock." A lock is defined in the same

reference as: "(1) a mechanical device furnished with a bolt and

usually a spring, for fastening a door, strongbox, etc., by means

of a key or combination," or "(2) anything that fastens something

else and prevents it from opening, turning, etc." Whereas these

definitions should be sufficient to preclude a licensee from using

a single tag on the handwheel as a lock of a manually operated

valve, they do permit a variety of mechanical devices to serve the

purpose of a lock provided they prevent opening, turning, etc.

The following positions are applicable to items specifically

designated in the SAR or TS as being locked. Manually or

power-operated components, for which requirements are not specified

in the TS or the SAR, may be controlled by whatever procedures the

licensee has developed for that purpose.

The position IE inspectors should take regarding the locking of a

component in position is as follows:

1. Manually-Operated Valve
9900 STS Surveillance - 2 - Issue Date: 10/01/77

a. The valve should be physically restrained from moving.

The methodology by which the restraint is removed should

be under administrative control. A key or combination

lock is the preferred methodology, but the use of a

"sealing" technique which will provide
Issue Date: 10/01/77 - 3 - 9900 STS Surveillance

evidence of unauthorized manipulation is acceptable

(e.g., cable secured by means of a lead seal).

b. A tag or similar device on a valve handwheel does not

meet the requirements for a locked valve in a fluid

system important to safety. Likewise, simply removing

the valve handwheel without securing the stem in position

is inadequate.

2. Power-Operated Valve

Electric power should be removed from the motor operator by

positive action, such as removing fuses or racking-out circuit

breakers in circuits supplying power to the components.

Administrative controls should include additional provisions

such as tagging the fuse holder or box or the breaker, and

specific instructions as to what steps must be taken to

restore power to the components involved.

This interpretation is in response to a request from Region IV, and

was developed after discussions with K. V. Seyfrit, DROI, T. A.

Ippolito, NRR, and W. M. Morrison, SD. J. I. Riesland is the

primary Headquarters contact regarding this matter.

END