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' l , h , l' .1 MEMORANDUM FOR: Theodore R. Quay, Pro; Director V, PD5 Division of Reactor .'roje ts, NRR FROM: Christopher I. Gr* mas, Chief Technical Specifications Branch Division of Op<r.,'ing Reactor Support, NRR
SUBJECT:
CONTAINMENT b flh PoiENTIAL FOR DRAINING THE REACTOR VESSEL By note of June 3, 1993. Phillip H. Johnson, Region V, requested NRR's interpretation of an APPL!r ABILITY footnote that applies to several containment Technical Specif44tions far BWRs. The footnote is "when l
irradiated fuel is being handled in ti.e secondary containment and during CORE All[RA110NS and operation? with a potential for draining the reactor vessel."
At issue is the use "of the phrase " operations with a potential for draining the reactor vess.
In the 15, the - i
- potential" means "something that exists in a state of potency or possib ity for changing or developing into a state of actuality."
It follows from this definition that even thnugh features are provided to prevent draining the reactor vessel, the potential for such draining can continue to exist. The operation described was the use of the residual heat removal (RHR) sy tem to lower the water level in the reactor cavity. Two independent s.ction valves .rere designed to satomatically isolate at a specified water level. However, since the failure of both is possible, this is an "operatson with a potential for :frain mq the reactor vessel."
If a licensee believes that any conditio- dtscribeu by *noerat tuns ."h a potenttal for draining the reactor vessel" shou'. not require the establishment of secondary containment, a request for change along with justification (e.g., compensatory action) should be made i the staff. f. good avenue to propose the change is through the Owners Groups in the implementation of improved Standard Technical Specifications.
s o:n. c : , P m v. o. t" Christopher.1. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support, NRR DISTRIBUTION: ,
0158 R/f DORS R/F N Central files BKGrimes SHWeiss AEthaffee i GHMarcus CIGrimes RJBarrett RCJones RHLo CWMoon Clifford JBradfoote CSSchulten l l
l DOCUMENT NAME: G: DRAIN.CWM
- See Previous Concurrence i t!
l OTSB: DORS:NRR O1SB: DORS:NRR SXRB:NRR SCSR:NRR C:01SB: DORS:pRR /1 l CWMoon* RHLo* RCJones* RJBarrett' f)ilGrknet, M r N}'
06/22/93 06/22/93 06/24//93 06/21/93 y07/gf93
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