ML20149M814
| ML20149M814 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/1997 |
| From: | Holahan G NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| GL-96-06, GL-96-6, NUDOCS 9701280071 | |
| Download: ML20149M814 (5) | |
Text
, _.
pn R'co
+
UNITFD STATES yq
- Q21 _
9 NUCLEAR REGULATORY COMMISSION kih E
WASHINGTON, D.C. 20555-0001
'%... +
January 24, 1997 N
+
MEMORANDUM T0:
DRS Division Directors N
FROM:
Gary M. Holahan, Director Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation
SUBJECT:
STAFF GUIDANCE ASSOCIATED WITH PLANT STARTUP RELATIVE TO ISSUES ADDRESSED BY GENERIC LETTER (GL) 96-06, " ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS" The Regions as well as licensees have questioned to what extent the concerns expressed in GL 96-06 constitute restart issues.
The purpose of this memorandum is to provide guidance and assure consistency in the staff's follow-up actions associated with the generic letter.
Some licensees have contended that they do not need to perform a preliminary operability assessment, prior to completing the evaluation of the issues as requested by GL 96-06.
It is the staff's position that since information about a potential problem has been disseminated through the Westinghouse Nuclear Safety Advisory Letter (NSAL), Information Notices 96-45 and 96-49, and finally through issuance of Generic Letter 96-06, licensees should look at the generic issues and determine, consistent with 10CFR Part 50, Appendix B, Criterion XVI, " Corrective Act' i.' if they are susceptible to the phenomena.
If licensees determine that t'm cre susceptible, they should follow the quidar.ce in GL 91-18 and promptly,,erform an operability assessment.
"Promptly" in terms of an initial cursory operability assessment has been interpreted by the staff to mean as soon as possible but generally within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In this context, it is recognized that the operability d cision may only be an initial evaluation and may not be based on a detailed analysis.
However, consistent with the provisions of GL 96-06, it is the staff's expectation that detailed analyses will be completed and reflected in the information that licensees have been requested to submit to the NRC by January 28, 1997.
See the attached excerpts from GL 91-18 for additional guidance regarding operability assessments.
Should a licensee determine that plant systems are susceptible to one or more of the phenomena discussed in GL 96-06, the licensee must determine whether or not the system is operable and take actions as necessary to comply with NRC regulations and license requirements.
Licensees are not precluded from I,
N )#
h
Contact:
James Tatum, SPLB 415-2805
- This issue is somewhat related to Region III TIA 96-0383.
28004p'
]VI&
~ gyyyg fr0 T
vurs 9701290071 970124 lecee-PDR ORG NRRA PDR
Centicd e
M DRS Division Directors starting up from an outage or from continued operation with degraded conditions as long as the affected systems and components are operable, NRC 1
regulations and license conditions are satisfied, and the degraded condition is not in conflict with Technical Specification requirements.
If this is not the case, the licensee should follow their existing requirements or make the appropriate submittals for staff review and approval (exemption request, TS change request, etc.).
Specific guidance for judging operability of piping, pipe supports, support plates, and anchor bolts is discussed in the enclosure to GL 91-18.
Upon
)
discovery of a nonconformance associated with piping and pipe supports, the NRC staff has allowed licensees to use the criteria stated in Appendix F of Section III of the ASME Code for operability determinations.
Should licensees determine that piping and supports are degraded but operable using this interim criteria, plant restart from an existing outage may be appropriate depending on the safety significance of the degraded condition and if additional time is needed for engineering, procurement, planning, scheduling, and implementation of design modifications (i.e., if the current outage does not constitute the first practical opportunity to take corrective action).
The staff expects that in most cases, licensees will restore affected piping and supports to the criteria stated in the Final Safety Analysis Report for the facility during the next refueling outage.
Questions concerning the above guidance should be directed to James Tatum of my staff at (301) 415-2805 or at E-mail address JET 1.
Attachment:
As stated cc:
F. Miraglia A. Thadani R. Zimmerman B. Sheron
' istribution.,
n) entraT Files PDR Glainas Project Directorates SPLB R/F BWetzel KManoly (E-Mail)
Regional Administrators DRPE/DRPW DRPM Regional DRP Directors WDean GTracy JMitchell BMcCabe DOCUMENT NAME: G:\\SECTIONA\\TATUM\\GLGUIDAN.3
- SEE PREVIOUS CONCURRENCE To rcaceive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy 0FFICE SPLB E
SPLB E
BC:SPLB E
BC:EMEB BC:TSB D:D NAME JTatum
- GHubbard
- LMarsh
- RWessman
- CGrimes Tdrtin DATE
/
/96 11/27/96 11/27/96 11/27/96 12/02/96
/ /)3/97 0FFICE OGC
- dSSA I NAME
- JGoldber[hbolahan DATE 12/09/96 l /33 /97 0FFICIAL RECORD COPY
?'
1 Attachment With respect to operability assessments, Generic Letter 91-18 states:
Section
4.0 BACKGROUND
i
"...Without any information to the contrary, once a component or system is l
established as operable, it is reasonable to assume that the component or l
system should continue to remain operable, and the previously stated verifications should provide that assurance. However, whenever the ability of a system or structure to perform its specified function is called into question, operability must be determined from a detailed examination of the deficiency.
The determination of operability for systems is to be made promptly, with a timeliness that is commensurate with the potential safety significance of the issue.
If the licensee chooses initially not to declare a system inoperable, i
the license must have a reasonable expectation that the system is operable and that the prompt determination process will support that expectation.
Otherwise, the licensee should immediately declare the system or structure inoperabl e... "
Section 6.1 Scope and Timina of Operability Determinations
...Once a degraded or nonconforming condition of specific SSCs is identified, an operability determination should be made as soon as possible consistent with the safety importance of the SSC affected.
In most cases, it is expected that the decision can be made immediately (e.g., loss of motive power, etc.).
In other cases it is expected the decision can be made within approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery even though complete information may not be available.
Some few exceptional cases may take longer.
For SSCs in TS, the Allowed I
Outage Times (A0Ts) contained in TS generally provide reasonable guidelines for safety significance...
An initial determination regarding operability should be revised, as appropriate, as new or additional information becomes available..."
Section 6.8
" Indeterminate" State of Operability
...When a licensee has cause to question the operability of an SSC, the operability determination is to be prompt; the timeliness must be commensurate with the potential safety significance of the issue....." Indeterminate" is not a recognized state of operability..."
Section 6.13 Pipina and Pioe Support Reauirements
...Upon discovery of a nonconformance with piping and pipe supports, licensees may use the criteria in Appendix F of Section III of the ASME code for operability determinations.
These criteria and use of Appendix F are valid until the next refueling outage when the support (s) are to be restored to the FSAR criteria....Where a piping support is determined to be inoperable, a determination of operability should be performed on the associated piping system."
DRS Division Directors Specific guidance for judging operability of piping, pipe supports, support plates, and anchor bolts is discussed in the enclosure to GL 91-18.
Upon i
discovery of a nonconformance associated with piping and pipe support ;, the NRC staff has allowed licensees to use the criteria stated in Appendix of Section III of the ASME Code for operability determinations.
The sta expect that licensees will restore affected piping and supports to he FSAR criteri during the next available outage and in general, the sta expects that lic sees will restore equipment to the licensing basis c) eria prior to r
restart f m an outage. However, should licensees determine hat piping and supports a degraded but operable using this interim crit ia, plant restart and continue operation will be permitted for at most on fuel cycle to allow for the engine ing, procurement, planning, scheduling and implementation of design modificat ons. Crediting the interim operabi ty criteria beyond one fuel cycle of ope tion must be approved by the NR.
Questions concerning he above guidance should directed to James Tatum of my staff at (301) 415- 05 or at E-mail addre JET 1.
i Distribution:
Central Files SPLB R/F PDR Project Directorates Glainas BWetzel K k\\ano\\/
r#yIb f'
{'t lf,./h 4
p s
y /,n o-p DOCUME NAME: G:\\S 10NA\\TATUM\\GLGUIDAN.2 g%
To roceive a copy of this doctanent, i cate in the box C= Cop'r w/o attachment /enclos re E= Copy with attachment / enclosure N a No copy 0FFICE S PL'8 I SPl[ d[
BC:SPLBc)
BC:EMEB N
\\EC:TSB D:DRPM NAME
/katum G[ubbhh LMars N A RWessN b Ch im M TMartin M )h96 h /11/96 G/kh
/
/96 DATE
/
/96
/[/ /> ' /96
/
/
s 0FFICE OGC D:DSSA NAME GHolahan DATE
/
/96
/
/96 0FFICIAL RECORD COPY
/
DRS Division Directors Specific guidance for judging operability of piping, pipe supports, upport plates, and anchor bolts is discussed in the enclosure to GL 91-1.
Upon discovery of a nonconfermance associated with piping and pipe s ports, the NRC staff has allowed licensees to use the criteria stated in ppendix F of Section III of the ASME Code for operability determinations The staff expects that licensees will restore affected piping and ports to the FSAR criteria during the next available outage and in gener, the staff expects that licensees will restore equipment to the licensi basis criteria prior to restart from an outage. However, should licensees etermine that piping and supports are degraded but operable using this in rim criteria, plant restart and continued operation will be permitted for most one fuel cycle to allow for the engineering, procurement, planning, heduling, and implementstion of design modifications.
Crediting the inter operability criteria beyond one fuel cycle of operation must be approved y the NRC.
Questions concerning the above guida e should be directed to James Tatum of j
my staff at (301) 415-2805 or at E all address JET 1.
Distribution:
Central Files SPLB R/F PDR Project Directorates Glainas 8Wetzel s-!,g#g.b w
4 DO ME NAME: G:\\S 10NA\\TATUM\\GLGUIDAN.2 To rsceive a y of. his document, i cate in the box Cscop'r w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy 0FFICF/ SP[B I
SPLB BC:SPLB BC:EMEB BC:TSB D:DRPM NAM [
hatum GHubbard LMarsh RWessman CGrimes TMartin
/
DATE
/
/96
/
/96
/
/96
/
/96
/
/96
/
/96 0FFICE ON D:DSSA NAME 0 t 8 b-r GHolahan DATE
/ / I '/ /96
/
/96
/
[
OFFICIAL RECORD COPY
&yo i
4