ML20127C449
| ML20127C449 | |
| Person / Time | |
|---|---|
| Site: | 05000000, LaSalle |
| Issue date: | 01/29/1985 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML082410334 | List: |
| References | |
| FOIA-85-243 NUDOCS 8502040828 | |
| Download: ML20127C449 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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JAN 29.I E.
PEMORANDUM FOR:
C. E. Norelius, Director Division of Project and Resident Program l
Region III i
FROM:
D. G. Eisenhut, Director Division of Licensing, NRR
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SUBJECT:
REQUEST FOR INTERPRETATION AND RESOLUTION OF SEVERAL ISSUES AT LA SALLE COUNTY STATION IN CONNECTION WITH SNUBBERS AND MECHANICAL SUPPORTS - TIA-83-116 l
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I In your letter dated November 1,1983, you indicated that Mr. Guldemond, a past l
Senior Resident Inspector at La Salle County Station, had uncovered several issues concerning snubbers and mechanical supports in the La Salle Technical Specifications requiring our, interpretation for resolution.
Specifir: ally, the interpretation was asked for the Action Statement in Specification 3.7.9.
Mr. Guldemond maintained the traditional position in that a support system becomes inoperable when a supporting snubber or a supporting mechanical restraint l
is found to be inoperable.
It was indicated that the discrepancy is between i
this above stated position and the Action Statement, i
The Specification 3.7.9 Action states, "With one or more snubbers inoperable.
l within-72-hours replace or restore the inoperable snubber (s) to OPERABLE status l
and perfom an engineering evaluation per Specification 4.7.9.C on the supported l
c5Eponent"6r declare the supported system inoperable and follow the appropriate Action Statement'for that system." Three aspects of your concern require clarification:
- 1. Whether the Action Statement conflicts with the above stated position, if the inoperable element is a snubber, 2. What is intended if the i
inoperable element is a mechanical restraint, and 3. When should the time count I
start.
l Following is our response to the above aspects requiring clarification:
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I.
The Action Statement does not conflict with the above stated position.
When a snubber is found to be inoperable, the supported system is imediately suspected to be inoperable.
However, snubbers are installed to resist dynamic loadines such as seismic loadings for the system, and do not resist loadings. caused by nomal operating conditions.
Theref" ore, when inoperable snubbers are discovered, a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is permitted for the plant to l
continue its nomal operation before restoring or replacing the inoperable, snubbers.
Also, in recogni:ing the practice that redundant snubbers are frequently used to support a system for dynamic loadings, plants are permitted l
to evaluate the system within that 72. hour period to deterrine (a) whether tht inoperabic snubber has adversely af#e:ted the operability of the support l
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. system such as in the case of a permanently locked up snubber, and (b) whether the inoperable snubber is required by the supported system to resist the dynamic loadings for which it was designed. The system may be declared as. operable only when both answers are negative.
It should
-be noted, however, that many plants have individual snubbgrs listed in their technical specifications and absent a license amendment the operability requirements for these snubbers must be met regardless of the supported system operability.
2.
Since a mechanical restraint is used to support a system during its normal operation, the failure of a mechanical restraint would render the supported system'into an inoperable status immediately when discovered and the Technical Specification Action Statement for that system should be implemented at that time.
3.
The 72-hour count in the case of snubbers should start from the time that the inoperable snubber is discovered.
We trust that the information provided is responsive to your concerns, and the NRR responsibilities under TIA No.83-116 have been completed.
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3/Darrel O Eisen
. Director V Division of Licensing Office of Nuclear Reactor Regulation
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T. Ma.rtin, Region I J. 01shinski, Region II R. Denise, Region IV D. V,1rsch, Region V G. Dick, NRR 6
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system such as in the case of a permanently locked up snubber, and (b) whether the inoperable snubber is reouired by the supported system to resist the dynamic loadings for which it ~was designed. The system may be declared as operable only whe,n both answers are negative.
It should be noted, however, that many plants have individual snubbers listed in their technical specifications and absent a license amendment the operability requirements for these snubbers must be met regardless of the supported system operability.
2.
Since a mechanical restraint is used to support a system during its normal operation, the failure of a mechanical restraint would render the supported system into an inoperable status immediately when discovered and the Technical Specification Action Statement for that system should.
be implemented at that time.
3.
The 72-hour count in the case of snubbers should start from the time that the inoperable snubber is discovered.
We trust that the information provided is responsive to your concerns, and the NRR responsibilities under TIA No.83-116 have been completed.
D6rrel G i
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, Director
' Division of Licensing
- Office of Nuclear Reactor Regulation cc
T. Martin, Region I J. Olshinski, Region II R. Denise, Region IV D. Kirsch, Region V G., Dick, NRR Distribution:
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RB 15 BBS Docket No. 50-412 I
MEMORANDUM FOR:
Harold Denton, Director Office of Nuclear Reactor Regulation FROM:
James P. Knight, Acting Director Division of Engineering
SUBJECT:
TECHNICAL SPECIFICATION FOR PR' ESSURE ISOLATION VALVES AT BEAVER VALLEY UNIT 2
' Current instructions to the staff regarding second plant technical specifications at two unit sites is that the technical specifications should be the same as those of the first unit (Office Letter No. 38 Supplement).
However, the Beaver Valley 1 technical specifications for pressure isolation valves do not reflect post TMI-2 staff concerns about intersystem LOCA events both inside and outside containment as now written, and should, therefore, not be extended to Beaver Valley 2.
Specifically, the list of pressure isolation valves for Beaver Valley Unit 1 only covers the " Event V" valves and not all pressure isolation valves as has been done for all plants licensed since the TMI-2 accident. Only six valves of a total of about 34 pressure isolation valves are currently covered in the Beaver Valley 1 technical specifications.
The purpose of including all pressure isolation valves in the technical specifications is to assure that these valves are subjected to limiting conditions for operation (LCO) and surveillance requirements in order to reduce the potential for a LOCA either inside or outside containment. The
" Event V" valve list was based solely on the WASH 1400 study which addressed only a LOCA which bypassed containment. The " Event V" orders, which mandated surveillance and LC0 for an abbreviated list of valves, was intended to address only the WASH-1400 dominant accident scenario (Event V). Thereafter, the staff, through its review of IST programs at operating reactors.and review.
of complete pressure isolation valve lists in NTOL technical specifications, has been requiring complete lists of pressure isolation valves in the technical specifications. This is in accordance With requests from the Division of Systems Integration as well as previous agreements between the Division of Engineering and the Division of Licensing.
Accordingly, we request approval to impose the latest standard technical specifications together with the complete list of pressure isolation valves for Beaver Valley 2.
CONTACT:
- 0. Rothberg, DE:MEB, x27864 1,. - ',-
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Harold Denton During the forthcoming review of the Beaver Valley Unit 1 first full 120 month Inservice Testing Program for Pumps and Valves, scheduled for completion in September,1986, we will recomend to the Division of Licensing that the Unit I technical specifications be amended to include all of the pressure isolation valves.
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J s P. Knig6, Acting Director
' vision of Engineering cc:
R. Bosnak F. Cherny E. Sullivan
- 0. Rothberg J. Page C. Hamer H. Bramer l:':""
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