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/ NUCLEAR REGULATORY COMMISSION y $ ; ttASHINGTON, D. C. 20006 k..... April 22,1993 MEMORANDUM FOR: Jack E. Strosnider, Chief Material and Chemical Engineering Branch Division of Engineering, NRR FROM: Christopher I. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support, NRR
SUBJECT:
STRUCTURAL INTEGRITY TECHNICAL SPECIFICATIONS Discussions in recent months between Projects, the Technica1 Specifications Branch (OTSB), and-the Materials and Chemical Engineering Branch (EMCB) have resulted in a number of questions concerning the treatment of structural integrity in the technical specifications. This memorandum will clarify OTSB's position in this area.
Previous Standard Technical Specifications (STS) specify Limiting Conditions for Operation (LC0), Action Statements, and Surveillance Requirements for structural integrity (Specifications 3/4.4.10 for Westinghouse and CE, 3/4.4.11 for B&W, and 3/4.4.B for the BWR's). The specifications basically state that the structural integrity of ASME Code Class 1, 2, and 3 components l shall be maintained in accordance with the Inservice Inspection Program, ASME l Boiler and Pressure Vessel (B&PV) Code Section XI and applicable Addenda, and 10 CFR 50.55a(g .
actions are requ) ired for ASME Class 1, 2 and 3 components.If the structural integr Although the requirements are contained in the LCO for the reactor coolant system, it is i not apparent that these requirements were intended to be restricted to the '
reactor coolant system. Rather, it appears that these requirements were intended to apply to all Class 1, 2, and 3 components.
For ASME Class 1 and 2 components the actions are similar; if structural integrity cannot be maintained the required action is that the structural ;
integrity must be restored or the component isolated prior to exceeding a i specified temperature in the RCS. Component isolation would cause a system operability determination in accordance with Generic letter (GL) 91-18 ;
" Degraded Conditions and Operability" which may result in additional actions i being taken due to the system LCO. If the RCS temperature is greater than the specified temperature when the structural integrity is impaired, an immediate shutdown is required (LCO 3.0.3). i For ASME Class 3 components, there is no RCS temperature requirement. When an ASME Class 3 component's structural integrity is found deficient, the required l action is to restore structural integrity or isolate the component. The time period in which restoration of structural integrity or component isolation is to be completed is dictated by the component's associated system or supported system LCO. As above, component isolation would cause a system operability ,
Robert J. Giardina, NRR 504-3152
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Jack R. Strosnider April 22, 1993 determination per GL 91-18 which may result in additional actions being taken due to system or support system LCO.
The structural integrity specification was evaluated in 1988 against the criteria specified in the Commission's Interim Policy Statement on Technical Specifications to a licensee controlled document. The staff's conclusion, .
stated in a letter dated May 9,1988, to the owners groups (the ' Split l Report") concluded that the requirements did not meet the criteria and, therefore, should be relocated outside technical specifications. Thus, the revised STS Revision 0 issued on September 30, 1992, does not include a structural integrity specification. However, the revised STS does require an Inservice Inspection Program (Section 5.7.2.11) for ASME Code Class 1, 2, and 3 components which meet the requirements of Section XI of the ASME B&PV Code and applicable addenda, and 10 CFR 50.55a. As stated in the enclosure in EMCB's letter to Bartholomew C. Buckley dated June 24, 1992, when a licensee i finds a degraded component, it must promptly determine its operability in I accordance with the guidelines and criteria specified in 10 CFR 50.55a and GL 91-18. Upon determining that the structural integrity of a ASME Code Class 1, 2, or 3 component does not meet the ASME structural integrity requirements, l the component is declared inoperable and the required actions to be taken are l those specified in the components's associated system or supported system LCO.
It has come to our attention that the guidance in GL 91-18 regarding structural integrity determinations of ASME Code Class 1, 2, and 3 components ,
could be clarified, particularly with respect to actions required by the ASME !
code. We request that EMCB review Sections 6.11, 6.13, 6.14 and 6.15 to determine if they correctly delineate the appropriate guidance for operability determinations for structural integrity considerations. If you conclude that the guidance could be clarified, please forward recommended changes to the guidance to OTSB so we can include it in a future revision.
Christopher I. Grimes, hief Technical Specifications Branch Division of Operating Reactor Support, NRR cc: J. E. Richardson R. A. Herman l l
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Jack R. Strasnider April 22, 1993 DISTRIBUTION:
OTSB R/F DORS R/F Central Files JGPartlow BKGrimes CIGrimes AEchaffee SHWeiss RJGiardina CLHoxie SAVarga JWRoe l
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t Jack R. Strosnider April 22, 1993 determination per GL 91-18 which may result in additional actions being taken due to system or support system LCO.
The structural integrity specification was evaluated in 1988 against the criteria specified in the Comission's Interim Policy Statement on Technical Specifications to a licensee controlled document. The staff's conclusion, stated in a letter dated May 9,1988, to the owners groups (the " Split Report") concluded that the requirements did not meet the criteria and, therefore, should be relocated outside technical specifications. Thus, the revised STS Revision 0 issued on September 30, 1992, does not include a structural integrity specification. However, the revised STS does require an Inservice Inspection Program (Section 5.7.2.11) for ASME Code Class 1, 2, and 3 components which meet the requirements of Section XI of the ASME B&PV Code !
and applicable addenda, and 10 CFR 50.55a. As stated in the enclosure in EMCB's letter to Bartholomew C. Buckley dated June 24, 1992, when a licensee finds a degraded component, it must promptly determine its operability in accordance with the guidelines and criteria specified in 10 CFR 50.55a and GL 91-18. Upon determining that the structural integrity of a ASME Code Class 1, 2, or 3 component does not meet the ASME structural integrity requirements, the component is declared inoperable and the required actions to be taken are those specified in the components's associated system or supported system LCO.
It has come to our attention that the guidance in GL 91-18 regarding structural integrity determinations of ASME Code Class 1, 2, and 3 components could be clarified, particularly with respect to actions required by the ASME code. We request that EMCB review Sections 6.11, 6.13, 6.14 and 6.15 to determine if they correctly delineate the appropriate guidance for operability determinations for structural integrity considerations. If you conclude that the guidance could be clarified, please forward recommended changes to the guidance to OTSB so we can include it in a future revision.
F. Mark Reinhart for
, Christopher I. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support, NRR cc: J. E. Richardson R. A. Herman
! DISTRIBUTION: Please see attached l
DOCUMENT NAME: G:\STRU.RJG
- See previous concurrences OTSB: DORS:NRR OTSB: DORS:NRR C:0TSB:DDRS:NRR RJGiardina* CLHoxie* CIGrimes 4 11/12/92 11/13/92 y /42/93 f I
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/, JUN 0 3 1 3 MEMORANDUM FOR: Gus C. Lainas, Assistant Director for Region II Reactors Division of Reactor Projects - I/II office of Nuclear Reactor Regulation FROM: Richard J. Barrett, Chief Containment Systems and Severe Accident Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation
SUBJECT:
RESPONSE TO TIA N0. 93 REQb 3T FOR TECHNICAL AS$1 STANCE IN DETERMINING REGULATORY BASIS FOR TECHNICAL SPECIFICATION 3/4.9.4, REACTOR BUILDING PENETRATIONS FOR SUP91ER PLANT (TAC N0. M86294)
This memorandum is our response to Region II's request for assistance (memorandum from E. W. Herschoff for G. C. Lainas, dated April 14,1993)in determining the regulatory basis for Technical Specification (TS) 3/4.9.4, Reactor Building Penetrations (Refueling Operations). Specifically, the request involves the use of temporary sealants to close primary containment (reactor building) penetrations during core alterations or movement of irradiated fuel. TS 3/4.9.4 states that each penetration providing direct access from the reactor building atmosphere to the outside atmosphere shall be either closed by an isolation valve, blind flange, or manual valve, or be capable of being closed by an operable automatic Reactor Building Purge and Exhaust isolation valve. The licensee had run temporary cables and/or ,
instrument wires through such a penetration to support refueling activities and had sealed up the penetration with temporary sealant (foam and Knowool).
1 For Summer and other plants with the Westinghouse Standard Technical Specifications (STS), the Technical Specif, cation on containment closure during times of fuel movement requires a closed isolation valve, blind flange, or manual valve. This would preclude the use of sealants as a means of meeting this requirement. However, the Bases for this specification demonstrates that the intent is to provide a leak-tight barrier, but not necessarily a pressure resistant barrier. Werecognizegthatthisintenthas been satisfied with barriers that do not meet the requirements of the specific TS language in most instances. Since the practice involved is loni,-standing and widespread, we do not believe the level of effort that would be required
- to include more explicit language in the TS justifies an amendment for each plant, as long as the staff's intent is satisfied.
The Improved Westinghouse STS, Rev. O, dated September 28, 1992, contains the added words, "or equivalent,' after the list of acceptable isolation barriers in TS 3/4.9.4. This TS would allow the practice of using temporary sealants to close penetrations during refueling operations if no pressurization is predicted.
CONTACT: J. Pulsipher 504-2811
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f Gus C. Lainas 2 As a result of the shutdown risk program, the staff intends to update the requirements related to containment isolation and closure during shutdown. At that time, we should update this section of Technical Specifications to explicitly allow non-pressure-resistant seals for closure during fuel movement, assuming that this remains consistent with the conclusions of the shutdown risk study regarding transients that may potentially pressurize containment during snutdown.
In conclusion, we find that the practice of using temporary sealant and other barriers to close containment penetrations during refueling operations meets the staff's intent as stated in the Bases of the Standard Technical Specifications, when they are prakt.j designed and installed.
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Richard J. Barrett, Chief Containment Systems and severe Accident Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation cc: G. Wunder J. Mitchell A. Gibson, RII -
E. Merschoff, RII DISTRIBUTION:
, Central File SCSB R/F Plant File .
JPulsipher RLobel RJBarrett CGrimes GHolahan
- SEE PREVIOUS CONCURRENCE A
- SCSB:DSSA *SCSB:DSSA OTSB: DORS DD: SSA ! :DSSA JPulsipher:1bk RLobel CGrimes MViriglio RJ8arrett 5/06/93 5/07/93 6/01/93 6/A/93 .5f0TM OFFICIAL RECORD COPY N7
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