ML101320564

Request for Additional Information, Relief Requests VRR-01, PRR-03, PRR-02, and PRR-01 for Third 10-Year Interval Inservice Testing Program for Pumps and Valves (TACs ME3515 Through ME3522)

ML101320564
Person / Time
Site:	South Texas
Issue date:	05/12/2010
From:	Thadani M Plant Licensing Branch IV
To:	Harrison A, Walker P South Texas
Thadani, M C, NRR/DORL/LPL4, 415-1476
References
TAC ME3515, TAC ME3516, TAC ME3517, TAC ME3518, TAC ME3519, TAC ME3520, TAC ME3521, TAC ME3522
Download: ML101320564 (3)

Text

From: Thadani, Mohan Sent: Wednesday, May 12, 2010 2:39 PM To: Harrison, Albon; Walker, Philip Cc: Burkhardt, Janet; Lent, Susan; Morris, James

Subject:

3RD 10 YEAR IST INTERVAL_RAI-TAC NO. ME3515 Wayne/Phillip:

Attached is an RAI regarding relief requests submitted in third 10 year IST program. I request STPNOC response by June 5, 2010 to facilitate the review schedule. If response by the requested date is not feasible, please let me know, so that I can advise the NRC staff accordingly.

Thanks.

Mohan C Thadani Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-1476 Mohan.Thadani@nrc.gov Request for Additional Information (RAI)

South Texas Project Operating Company South Texas Project Electric Generating Station Units 1 and 2 Third 10-year Interval Inservice Testing Program for Pumps and Valves Docket Nos. 50-498 AND 50-499 (TAC Nos. ME3515, ME 3516, ME3517, ME3518, ME3521, and ME3522)

RAI P-1-1: Pump Alternative Request - PRR-01 Please explain how the alternative in PRR-01 is acceptable and why this alternative is a reasonable alternative to the Code for Operation and Maintenance of Nuclear Power Plants (OM Code) requirements. See the following documents (Agencywide Documents Access and Management System Accession Nos. ML090650668, ML091670464, ML092640690, ML093140302, and ML100820061) for examples of the information needed to evaluate this alternative request.

RAI P-1-2: Pump Alternative Request - PRR-03 Regulatory Guide (RG) 1.175, An Approach for Plant-Specific, Risk-Informed Decision-Making:

Inservice Testing, August 1998, describes an acceptable alternative approach for applying risk insights from probabilistic risk assessment, in conjunction with established traditional engineering information, to make changes to a nuclear power plants IST program. The

approach described in RG 1.175 addresses the high-level safety principles specified in RG 1.174, An Approach For Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes To The Licensing Basis, Revision 1, November 2002, and attempts to strike a balance between defining an acceptable process for developing risk-informed IST programs without being overly prescriptive. It is intended that the approach presented in RG 1.175 should be regarded as an example of acceptable practices, and that licensees should have some degree of flexibility in satisfying regulatory requirements on the basis of their accumulated plant experience and knowledge.

As discussed in RG 1.175, please describe how the proposed alternative in PRR-03 is consistent with defense-in-depth philosophy and how the change maintains sufficient safety margins. Also describe the performance measure strategies for monitoring the proposed alternative in PRR-03.

The use of Code Case OMN-3, Requirements for Safety Significance Categorization of Components Using Risk Insights for Inservice Testing of LWR Power Plants, is conditionally approved in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 0, dated June 2003. Please explain why you did not propose to use the provisions in Code Case OMN-3 to extend the test frequency for the residual heat removal pumps.

RAI V-1-1: Valve Alternative Request - VRR-01 The OM Code does not consistently assign revision numbers to code cases that have been changed. For example, minor revisions were made to Code Case OMN-1 in the 2002 Addendum of the OM Code and Code Case OMN-1 was revised in its entirety in the 2006 Addendum of the OM Code. No revision numbers were assigned to OMN-1 in the 2002 or 2006 Addenda. There are two versions of OMN-1 in the 2009 Edition of the OM Code (OMN-1 and OMN-1-1). OMN-1-1 is described as Revision 1 in the 2009 Edition of the OM Code. Please clarify which version of OMN-1 that you plan to use to implement the alternative in VRR-01.

E-mail Properties Mail Envelope Properties (0A64B42AAA8FD4418CE1EB5240A6FED11293E8298A)

Subject:

3RD 10 YEAR IST INTERVAL_RAI-TAC NO. ME3515 Sent Date: 5/12/2010 2:38:56 PM Received Date: 5/12/2010 2:38:56 PM From: Thadani, Mohan Created By: Mohan.Thadani@nrc.gov Recipients:

awharrison@STPEGS.COM (Harrison, Albon)

Tracking Status: None plwalker@STPEGS.COM (Walker, Philip)

Tracking Status: None Janet.Burkhardt@nrc.gov (Burkhardt, Janet)

Tracking Status: None Susan.Lent@nrc.gov (Lent, Susan)

Tracking Status: None jrmorris@STPEGS.COM (Morris, James)

Tracking Status: None Post Office:

HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 11786 5/12/2010 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: