Issue Date: 05/12/86 - 1 - 9900 STS 4.5.1

NRC INSPECTION MANUAL DI

PART 9900: TECHNICAL GUIDANCE

STS451.TG

STANDARD TECHNICAL SPECIFICATIONS (BWR)

SECTION 4.5.1

A. PURPOSE

To provide guidance on Standard Technical Specifications (STS)

Section 4.5.1 as it relates to verifying valve positions, as

provided in an NRR memorandum dated August 21, 1985.

B. BACKGROUND

The licensee at the Susquehanna Steam Electric Station (SSES) used

control room position indicating lights instead of local valve

position indication to satisfy the surveillance requirements of SSES

Technical Specification Section 4.5.1 (Item 3b(1)). This technical

specification requires periodic verification that certain valves in

the emergency core cooling system flow path are in their correct

position. In an April 17, 1985 memorandum to NRR, J. G. Partlow

requested an interpretation of the intent of the technical

specification requirement with regard to the use of local or remote

position indication.

C. DISCUSSION

The intent of the surveillance requirement relating to valve

position verification is to assure that valves in the flow path for

systems such as the emergency core cooling systems are in their

correct position such that the system would not be rendered

inoperable due to a mispositioned valve. For valves which have

remote position indicating lights in the control room, the remote

position indication may be used to verify that valves are in the

correct position.

It was not the intent of the SSES technical specification surveillance requirement nor the STS surveillance requirement (section

4.5.1) that only local valve position indication be used. The

potential that the remote position indication would not be in

agreement with the actual valve position should be small. Concerns

for these types of failures are addressed by surveillance requirements which verify that there are no obstructions in the flow path

or by other maintenance or test procedures which would verify the
9900 STS 4.5.1 - 2 - Issue Date: 05/12/86

operability of the remote position indication. These specific

technical specification requirements are part of the inservice

inspection requirements of Section XI of the ASME Boiler and

Pressure Vessel Code. Article IWV-3300 requires that valves with

remote position indication be observed at least once every 2 years

to verify that valve operation is accurately indicated.
Issue Date: 05/12/86 - 3 - 9900 STS 4.5.1

D. CONCLUSION

At the request of NRR, the Nuclear Safety Information Center

searched the Sequence Coding Search System data base for licensee

event reports concerning problems with valve position indication.

Based on a review of the results of this search, NRR concluded that

the frequency of incorrect valve position indication events (i.e.,

indication of a valve as open when it is closed or vice versa) is

too low to justify recommending a technical specification

interpretation that would rely on just local valve indication.

E. REFERENCE

The guidance provided in this directive was extracted from a

memorandum from Hugh L. Thompson, Jr., Director, Division of

Licensing, NRR, to James G. Partlow, Director, Division of

Inspection Programs, IE, dated August 21, 1985, subject: Technical

Specification Interpretation. The complete memorandum is in the

Document Control System (DCS microfiche #68036-218).

END