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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20210C7061999-07-16016 July 1999 Forwards Facility Submitted Outline & Initial Exam Submittal for Operator Licensing Exams Administered During Wk of 990607 ML20209H2231999-07-16016 July 1999 Forwards Operator Licensing Exam Repts 50-456/99-301(OL) & 50-457/99-301(OL) of Exam Administered During Wk of 990607 ML20206Q2751999-05-13013 May 1999 Forwards Official Case File for DPO-99-1,request of Review of Concerns Related to TS Setpoints & Allowable Value for Instrumentation Under Formal DPO Procedures,For Disposition in Accordance with Provisions of NRC MD 10.159 ML20206E9331999-05-0303 May 1999 Notification of 990524 Meeting with Commonwealth Edison,Co in Rockville,Md to Discuss Technical Issues Related to Proposed re-rack of SFPs at Braidwood Station & Byron Station ML20206Q3211999-02-19019 February 1999 Responds to e-mail Message Sent on 980202,re Status of Staff Actions on Recipient Dpv.With Regard to Dpv Concerning Dynamic Testing of Instrument Channels at Braidwood,Staff Pursuing Resolution of Issue with Licensee ML20206Q3391999-01-0505 January 1999 Provides Update on Status of Resolution of follow-up Actions from Resolution of Dpv on Dynamic Testing of Instrumentation at Braidwood Station ML20155E7361998-11-0202 November 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-305 & 50-457/98-305 for Tests Administered on 980914 ML20154G2361998-10-0707 October 1998 Responds to Memo Sent on 981002 Re Resolution of follow-up Actions for NRR Differing Professional View Panel on Dynamic Testing of Instrumentation at Plant ML20196D7921998-10-0202 October 1998 Forwards Comments Related to Staff Responses to follow-up Actions Re Dynamic Testing of Instrument Channels at Braidwood ML20196D7801998-09-21021 September 1998 Informs That Staff Completed Review of follow-up Actions Identified in Memo from Bw Sheron to Ba Boger, on Dymanic Testing of Instrumentation Channels at Braidwood ML20151V2951998-09-0202 September 1998 Informs That Braidwood Station Concurs with Encl Proposed 980904 Util Response to NRC Re IPEEE ML20197C8041998-09-0202 September 1998 Informs That Braidwood Station Concurs with Proposed Encl Response to NRC Re RPV Integrity at Braidwood & Byron Stations ML20197C8301998-09-0101 September 1998 Informs That Rev 2 to Calculation BYR98-109/BRW-98-339-E Has Been Reviewed & Found Acceptable for Transmittal to Nrc. Draft Util Ltr Re Thermo-Lag Ampacity Derating Factor Calculation,Encl ML20237D4331998-08-21021 August 1998 Notification of 980903 & 04 Meetings W/Util in Rockville,Md to Discuss Technical Issues Related to Byron & Braidwood Improved Std TSs Conversion,Including Section 3.3,beyond Scope Issues,Closeout Packages & Amends to Current TSs ML20196D7211998-08-0404 August 1998 Responds to 980720 Memo from Sj Collins to Lj Callan Re When & How Mesac Approved.Licensee Installed Mirco Electronic Surveillance & Calibration (Mesac) Sys Measurement & Test Equipment as Backup Sys to Normal M&TE ML20196D7711998-07-22022 July 1998 Discusses Staff Review of Braidwood Mesac System ML20249A2231998-06-12012 June 1998 Notification of 980625-26 Meeting W/Util in Rockville,Md to Discuss Technical Issues Re Byron & Braidwood Improved Std TSs Conversion ML20216B6731998-05-11011 May 1998 Discusses Closure of TAC M94439 for Braidwood,Unit 1,steam Generator Replacement ML20217P0131998-04-29029 April 1998 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered During Wk of 980413 ML20217P0731998-04-29029 April 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-304(OL) & 50-457/98-304(OL) (Including Completed & Graded Tests) for Tests Administered on 980413-15 ML20217E3881998-04-23023 April 1998 Notification of 980506 & 07 Meetings W/Util in Rockville,Md to Discuss Technical Issues Re Plants Improved STS Conversion ML20216H3401998-03-17017 March 1998 Notification of 980331-0402 Meeting W/Util in Rockville,Md to Discuss Reviewer Comments on Byron & Braidwood Improved Std TS Submittal ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20203G8551998-02-23023 February 1998 Notification of 980305 Meeting W/Util in Rockville,Md to Discuss Status of Byron & Braidwood Licensing Issues ML20198G4921998-01-0707 January 1998 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered During Wk of 971006 at Plant ML20198J6881998-01-0707 January 1998 Forwards NRC Operator Licensing Exam Rept w/as-given Written Exam for Tests Administered During Wk of 971006 at Plant ML20202E5831997-11-25025 November 1997 Notification of 971215 Meeting W/Commonwealth Edison Co in Rockville,Md to Review Schedule for Listed Plants Improved Std TS Conversion & Supplemental Submittals ML20203C3621997-11-25025 November 1997 Revised Notification W/New Starting Time of Meeting W/Ceco on 971215 in Rockville,Maryland to Discuss Review Schedule Byron & Braidwood Improved TS Conversion & Supplemental Submittals ML20202D2221997-11-25025 November 1997 Notification of Meeting W/Ceco on 971211 in Rockville,Md to Discuss Proposed Mod to Methodology for Estimating SG Tube Leakage Attributable to Outer Diameter Stress Corrosion Crack Indications Restricted from Burst for Plant SGs ML20236N5111997-10-22022 October 1997 Fowards Staff Response to 960912 TIA Re Containment Spray Additive Sys Conformance W/Design Basis & Tss.Analysis Concluded That 2,400-2,600 Ppm in RWST Acceptable ML20217K8271997-10-16016 October 1997 Notification of 971024 Meeting W/Util to Discuss Results of Comed Investigation Into Sensitivity of Proposed voltage- Dependent Growth Rates to Binning Strategy for ODSCC Indicators ML20212A1501997-10-15015 October 1997 Forwards Response for NRC RAI Re SG Interim Plugging Criteria 90 Day Rept for Braidwood,Unit 1 Sixth Refuel Outage (A1R06).Station Concurs W/Response as Proposed for CE ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20217B3901997-09-23023 September 1997 Forwards Questions Re Ceco Submittal of Revised SG Tube Rupture Analysis for Byron,Unit 1 & Braidwood,Unit 1 ML20149L1901997-07-22022 July 1997 Notification of 970723 Meeting W/Commonwealth Edison Co in Rockville,Md to Discuss Results of Spring 1997,Braidwood,1 SG Tube Eddy Current Insp.Time of Meeting Rescheduled ML20149F2731997-07-0303 July 1997 Notification of 970723 Meeting W/Util in Rockville,Md to Discuss Results of Spring 1997 Plant,Unit 1 SG Tube Eddy Current Insp Including Determination of Impact of Data ML20138D2781997-04-28028 April 1997 Notification of 970430 Meeting W/Util in Rockville,Md to Discuss Results of EC Insps of Plant SGs Conducted During Present Refueling Outage IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20236N0071997-04-0707 April 1997 Responds to Request for TS Interpretation on Containment Vent & Drain Valves at Braidwood ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M6901997-01-19019 January 1997 Notification of 970128 Meeting W/Commonwealth Edison Co to Discuss Licensee Proposed Program for Use of Mixed Oxide Fuel ML20133J5811997-01-15015 January 1997 Notification of 970122 Meeting W/Util in Rockville,Md to Discuss Licensee Status of Program for Replacement & Operation of New SG at Byron 1 & Braidwood 1 ML20133J4821997-01-15015 January 1997 Notification of 970123 Meeting W/Licensees in Rockville,Md to Discuss Contents of Plants TS Conversion Submittal, Provide Staff Comments Based on Initial Screening Review & Discuss Review Schedule ML20196D8881997-01-0202 January 1997 Provides Results of Review of Dpv That Was Expressed in 961017 Memo Re Dynamic Testing of Instrumentation Channels at Braidwood ML20196D8011997-01-0202 January 1997 Forwards NRR Ad Hoc Dpv Review of Recipient Differing Professional View Re Dynamic Testing of Instrumentation Channels at Braidwood,Per 961017 Memo ML20196D8671997-01-0202 January 1997 Submits Review of Ad Hoc NRR Dpv Review Panel Re 961017 Memo Dpv on Dynamic Testing of Instrumentation Channels at Braidwood 1999-09-01
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211K8611999-09-0101 September 1999 Informs That There Has Been Some Confusion Re Recently Issued ODCM Generic Section Rev Which Needs to Be Clarified. Clarifications Are Listed ML20210P1361999-08-0404 August 1999 Notification of 990817 Meeting with Util in Rockville, Maryland to Discuss Status of Licensing Actions Submitted by Comm Ed & Plan for Proposed Licensing Workshop ML20209H2231999-07-16016 July 1999 Forwards Operator Licensing Exam Repts 50-456/99-301(OL) & 50-457/99-301(OL) of Exam Administered During Wk of 990607 ML20210C7061999-07-16016 July 1999 Forwards Facility Submitted Outline & Initial Exam Submittal for Operator Licensing Exams Administered During Wk of 990607 ML20206Q2751999-05-13013 May 1999 Forwards Official Case File for DPO-99-1,request of Review of Concerns Related to TS Setpoints & Allowable Value for Instrumentation Under Formal DPO Procedures,For Disposition in Accordance with Provisions of NRC MD 10.159 ML20206E9331999-05-0303 May 1999 Notification of 990524 Meeting with Commonwealth Edison,Co in Rockville,Md to Discuss Technical Issues Related to Proposed re-rack of SFPs at Braidwood Station & Byron Station ML20206Q3211999-02-19019 February 1999 Responds to e-mail Message Sent on 980202,re Status of Staff Actions on Recipient Dpv.With Regard to Dpv Concerning Dynamic Testing of Instrument Channels at Braidwood,Staff Pursuing Resolution of Issue with Licensee ML20206Q3391999-01-0505 January 1999 Provides Update on Status of Resolution of follow-up Actions from Resolution of Dpv on Dynamic Testing of Instrumentation at Braidwood Station ML20155E7361998-11-0202 November 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-305 & 50-457/98-305 for Tests Administered on 980914 ML20154G2361998-10-0707 October 1998 Responds to Memo Sent on 981002 Re Resolution of follow-up Actions for NRR Differing Professional View Panel on Dynamic Testing of Instrumentation at Plant ML20196D7921998-10-0202 October 1998 Forwards Comments Related to Staff Responses to follow-up Actions Re Dynamic Testing of Instrument Channels at Braidwood ML20196D7801998-09-21021 September 1998 Informs That Staff Completed Review of follow-up Actions Identified in Memo from Bw Sheron to Ba Boger, on Dymanic Testing of Instrumentation Channels at Braidwood ML20197C8041998-09-0202 September 1998 Informs That Braidwood Station Concurs with Proposed Encl Response to NRC Re RPV Integrity at Braidwood & Byron Stations ML20151V2951998-09-0202 September 1998 Informs That Braidwood Station Concurs with Encl Proposed 980904 Util Response to NRC Re IPEEE ML20197C8301998-09-0101 September 1998 Informs That Rev 2 to Calculation BYR98-109/BRW-98-339-E Has Been Reviewed & Found Acceptable for Transmittal to Nrc. Draft Util Ltr Re Thermo-Lag Ampacity Derating Factor Calculation,Encl ML20237D4331998-08-21021 August 1998 Notification of 980903 & 04 Meetings W/Util in Rockville,Md to Discuss Technical Issues Related to Byron & Braidwood Improved Std TSs Conversion,Including Section 3.3,beyond Scope Issues,Closeout Packages & Amends to Current TSs ML20196D7211998-08-0404 August 1998 Responds to 980720 Memo from Sj Collins to Lj Callan Re When & How Mesac Approved.Licensee Installed Mirco Electronic Surveillance & Calibration (Mesac) Sys Measurement & Test Equipment as Backup Sys to Normal M&TE ML20196D7711998-07-22022 July 1998 Discusses Staff Review of Braidwood Mesac System ML20249A2231998-06-12012 June 1998 Notification of 980625-26 Meeting W/Util in Rockville,Md to Discuss Technical Issues Re Byron & Braidwood Improved Std TSs Conversion ML20216B6731998-05-11011 May 1998 Discusses Closure of TAC M94439 for Braidwood,Unit 1,steam Generator Replacement ML20217P0731998-04-29029 April 1998 Forwards NRC Operator Licensing Exam Repts 50-456/98-304(OL) & 50-457/98-304(OL) (Including Completed & Graded Tests) for Tests Administered on 980413-15 ML20217P0131998-04-29029 April 1998 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered During Wk of 980413 ML20217E3881998-04-23023 April 1998 Notification of 980506 & 07 Meetings W/Util in Rockville,Md to Discuss Technical Issues Re Plants Improved STS Conversion ML20216H3401998-03-17017 March 1998 Notification of 980331-0402 Meeting W/Util in Rockville,Md to Discuss Reviewer Comments on Byron & Braidwood Improved Std TS Submittal ML20216H6971998-03-17017 March 1998 Notification of 980326 Meeting W/Commonwealth Edison Co in Lisle,Il to Discuss Comed Request to Consolidate near-site Emergency Operations Facility Into Single Central EOF ML20203G8551998-02-23023 February 1998 Notification of 980305 Meeting W/Util in Rockville,Md to Discuss Status of Byron & Braidwood Licensing Issues ML20198J6881998-01-0707 January 1998 Forwards NRC Operator Licensing Exam Rept w/as-given Written Exam for Tests Administered During Wk of 971006 at Plant ML20198G4921998-01-0707 January 1998 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered During Wk of 971006 at Plant ML20202D2221997-11-25025 November 1997 Notification of Meeting W/Ceco on 971211 in Rockville,Md to Discuss Proposed Mod to Methodology for Estimating SG Tube Leakage Attributable to Outer Diameter Stress Corrosion Crack Indications Restricted from Burst for Plant SGs ML20202E5831997-11-25025 November 1997 Notification of 971215 Meeting W/Commonwealth Edison Co in Rockville,Md to Review Schedule for Listed Plants Improved Std TS Conversion & Supplemental Submittals ML20203C3621997-11-25025 November 1997 Revised Notification W/New Starting Time of Meeting W/Ceco on 971215 in Rockville,Maryland to Discuss Review Schedule Byron & Braidwood Improved TS Conversion & Supplemental Submittals ML20236N5111997-10-22022 October 1997 Fowards Staff Response to 960912 TIA Re Containment Spray Additive Sys Conformance W/Design Basis & Tss.Analysis Concluded That 2,400-2,600 Ppm in RWST Acceptable ML20217K8271997-10-16016 October 1997 Notification of 971024 Meeting W/Util to Discuss Results of Comed Investigation Into Sensitivity of Proposed voltage- Dependent Growth Rates to Binning Strategy for ODSCC Indicators ML20212A1501997-10-15015 October 1997 Forwards Response for NRC RAI Re SG Interim Plugging Criteria 90 Day Rept for Braidwood,Unit 1 Sixth Refuel Outage (A1R06).Station Concurs W/Response as Proposed for CE ML20217D4261997-09-30030 September 1997 Informs of Scheduled Visits W/Nuclear Services at Gpu on Nov 14th & Visit at Commonwealth Edison on Dec 3rd & Would Like to Receive Any Info Available.Supporting Documentation Encl ML20217B3901997-09-23023 September 1997 Forwards Questions Re Ceco Submittal of Revised SG Tube Rupture Analysis for Byron,Unit 1 & Braidwood,Unit 1 ML20149L1901997-07-22022 July 1997 Notification of 970723 Meeting W/Commonwealth Edison Co in Rockville,Md to Discuss Results of Spring 1997,Braidwood,1 SG Tube Eddy Current Insp.Time of Meeting Rescheduled ML20149F2731997-07-0303 July 1997 Notification of 970723 Meeting W/Util in Rockville,Md to Discuss Results of Spring 1997 Plant,Unit 1 SG Tube Eddy Current Insp Including Determination of Impact of Data ML20138D2781997-04-28028 April 1997 Notification of 970430 Meeting W/Util in Rockville,Md to Discuss Results of EC Insps of Plant SGs Conducted During Present Refueling Outage ML20217D5461997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission IA-97-178, Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission1997-04-18018 April 1997 Forwards Partially Withheld Background Briefing Package in Preparation for 970425 Meeting Between Comed & Commission ML20147J2391997-04-0909 April 1997 Notification of Meeting on 970416 W/Util in Rockville,Md to Discuss Overall Response & Present Addl Details Re Performance Indicators Used to Monitor Performance Stations ML20236N0071997-04-0707 April 1997 Responds to Request for TS Interpretation on Containment Vent & Drain Valves at Braidwood ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20149M6901997-01-19019 January 1997 Notification of 970128 Meeting W/Commonwealth Edison Co to Discuss Licensee Proposed Program for Use of Mixed Oxide Fuel ML20133J4821997-01-15015 January 1997 Notification of 970123 Meeting W/Licensees in Rockville,Md to Discuss Contents of Plants TS Conversion Submittal, Provide Staff Comments Based on Initial Screening Review & Discuss Review Schedule ML20133J5811997-01-15015 January 1997 Notification of 970122 Meeting W/Util in Rockville,Md to Discuss Licensee Status of Program for Replacement & Operation of New SG at Byron 1 & Braidwood 1 ML20196D8671997-01-0202 January 1997 Submits Review of Ad Hoc NRR Dpv Review Panel Re 961017 Memo Dpv on Dynamic Testing of Instrumentation Channels at Braidwood ML20196D8011997-01-0202 January 1997 Forwards NRR Ad Hoc Dpv Review of Recipient Differing Professional View Re Dynamic Testing of Instrumentation Channels at Braidwood,Per 961017 Memo ML20196D8881997-01-0202 January 1997 Provides Results of Review of Dpv That Was Expressed in 961017 Memo Re Dynamic Testing of Instrumentation Channels at Braidwood 1999-09-01
[Table view] |
Text
- . a p2asig e % UNITED STATES
,** s* y NUCLEAR RESULATORY COMMISSION l
& WASWNGTON, D.C. 300064m j
.,Q...,l April 7, 1997
)
i MEMORANDUM TO: Robert A. Capra, Director, l Project Directorate III-2 Division of Reactor Projects III & IV, NRR FROM: Christopher I. Grimes, Chief Technical Specifications Branch i l Associate Director for Projects, NRR
SUBJECT:
REQUEST FOR TECHNICAL SPECIFICATION INTERPRETATION ON i CONTAINMENT VENT AND DRAIN VALVES AT BRAIDWOOD ;
iI On October 4,1996, an operator identified two containment isolation valves on !
each of the Braidwood units that were not being surveyed on the station's '
outside containment isolation valve surveillance. The valves missing from the !
surveillance included a vent and a drain valve on a safety injection ter.t line ;
local pressure indicator. The licensee entered the LCO for containment i isolation valves, applied Technical Specifications (TS) 4.0.3, verified that I the valves in question were closed and capped, hung administrative control i tags, and submitted a procedure change to include the valves on the surveillance.
The licensee initiated an investigation and concluded that these valves are not required to be surveyed closed to meet TS 4.6.1.1.a or 10 CFR 50 Appendix J criteria for this style of containment penetration. The licensee's bases for their position are that this penetration is capable of being closed by operable containment automatic isolation valve and that TS 4.6.1.1.a applies only to penetrations not capable of being closed by operable containment automatic isolation valves.
The Resident Inspectors were concerned that in the event that the inboard automatic containment isolation valve failed to isolate that the vent and '
l drain valves would be outboard barriers to a release of radioactive materials
! outside of containment. Considering the potential consequences of the vent and drain valves being left open, the inspectors believe that TS 4.6.I.1.a requirements apply to the instrument vent and drain valves. The Resident Inspectors requested NRR provide an interpretation of the TS 4.6.1.1.a to l resolve this issue.
The Technical Specifications Branch (TSB) has reviewed the information provided, and we find that the licensee's interpretation of TS 4.6.I.I.a is incorrect. In a memorandum from Christopher I. Grimes, Chief, Technical Specifications Branch to Herbert H. Berkow, Director Project Directorate II-2, "St. Lucie Containment Vessel Integrity (TIA 91-23)(TAC No. M82930) dated June 22, 1992, TSB stated that "The staff considers any valve associated with a containment penetration no matter how small to be a CIV [ containment isolation CONTACT: R. J. Giardina, TSB/NRR 415-3152 9907140359 980624 9 PDR FOIA UNNERST98-155 PDR .
4 ,*
i' R. Capra April 7, 1997 l
valve) . Therefore, vent, drain, and test valves are considered CIVs and the requirements of TS 3.6.1.1 apply to them." In addition 10 CFR 50, Appendix A, l General Design Criterion (GDC) 55, 56,- and 57 describe the various containment l penetration isolation designs which are acceptable to the staff. GDC 55 and l 56 list four types of isolation systems: 1) Both valves locked closed; 2)
Automatic isolation valve inside containment and a locked closed valve outside containment; 3) The reverse of 2; and 4) Both valves are automatic isolation valves. GDC 57 deals with a closed system which requires automatic, locked closed or remote manual valve outside containment. The basis for the GDC i designs is that a single failure will not prevent or degrade containment integrity (the closed system in GDC 57 acts as one containment isolation l barrier).
With the above taken into consideration the interpretation of TS 4.6.1.1.a becomes fairly obvious. It is clear the wording of TS 4.6.1.1.a. particularly
! from the "*" footnote, requires that all manual valves, blind flange, or deactivated automatic valves, serving as an isolation barrier, are to be verified as being closed regardless of whether the other valve in the penetration (if any) is an automatic valve or not. In this case, the manual vent and drain valves serve as such an isolation barrier.
The improved Standard Technical Specifications (STS) (NUREG-1431 for Westinghouse plants) reinforce this interpretation. The Cases for the Containment Isolation Valve TS state in the Background section "The containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. These isolation devices are either passive or active (automatic)." Additionally, the Bases for the containment isolation valve surveillance (SR 3.6.3.3) state "This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that 'those containment isolation valves outside containment and capable of being mispositioned are in the correction position."
Braidwood's interpretation of TS 4.6.1.1.a apparently arises from the definition of containment integrity in the definition section of the Braidwood TS. The same definition in the improved STS has been relocated to the Bases for containment. The definition states that CONTAINMENT INTEGRITY l.7 CONTAINMENT INTEGRITY shall exist when:
- a. All penetrations required to be closed during accident conditions are either:
! 1) Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- 2) Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except i as provided in Table 3.6-1 of Specifications 3.6.3....
l l
1
1 ,~
e* R. Capra April 7, 1997 Definition 1.7.a.1) could be interpreted to apply to all those penetrations which have at least one automatic containment isolation valve. As long as a penetration had one automatic valve, the other valves forming the containment boundary whether they are manual valves, blind flanges, or deactivated automatic valves would not have to be verified closed. TSB acknowledges that the definition could be read in such a manner. However, such a reading is inconsistent with the intent of the TS and the GDCs. TSB believes the better reading of the definition is that each penetration is required to be capable of being closed by automatic containment isolation valves, closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed position or an approved combination of the above that provides the two barrier isolation. In turn, all manual valves, blind flanges or deactivated automatic valves secured in their position must be surveilled in accordance with TS 4.6.1.1.a.
Given that the containment integrity definition might not clearly provide the staff's intent, TSB along with Containment Systems Branch will reevaluate the containment integrity definition and propose appropriate changes to the improved sis which the licensee can consider adopting to avoid future questions.
Docket Nos. 50-456/457 cc: J. Roe ,
G. Halahan C. Berlinger 1
I i
- . R. Capra April 7, 1997 Definition 1.7.a.1) could be interpreted to apply to all those penetrations which have at least one automatic containment isolation valve. As long as a penetration had one automatic valve,'the other valves, forming the containment boundary whether they are manual valves, blind flanges, or deactivated automatic valves would not have to be verified closed. TSB acknowledges that the definition could be read in such a manner. However, such a reading is inconsistent with the intent of the TS and the GDCs. TSB believes the better reading of the definition is that each penetration is required to be capable of being closed by automatic containment isolation valves, closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed position or an approved combination of the above that provides the two barrier isolation. In turn, all manual valves, blind flanges or deactivated automatic valves secured in their position must be surveilled in accordance with TS 4.6.1.1.a.
Given that the containment integrity definition might not clearly provide the staff's intent, TSB along with Containment Systems Branch will reevaluate the containment integrity definition and propose appropriate changes to the improved STS which the licensee can consider adopting to avoid future questions.
Docket Nos. 50-456/457 cc: J. Roe G. Holahan C. Berlinger D11TRIMIION:
FILE CENTER TSB R/F CIGrimes JGLuehman RJGiardina
\ TSB Staff I VBackground Books DOCUMENT NAME: G:\RJG\ BRAID.MEM *see previous concurrences 0FFICE TSB/ADPR/NRR (A)SC:TSB:ADPR:NRR C:SCSB:NRR C:TSB:ADPR:NRR NAME RJGiardina* JGLuehman* CBerlinger* CIGrimesh/hr DATE 12/16/96 12/16/96 . 03/18/96 Ok't/g1M OFFICIAL MtCORD COPY j
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