ML12032A027

From kanterella
Jump to navigation Jump to search
Comment (4) of Raj Rana, on Behalf of Himself, on NUREG-1482, Rev 2, Appendix B
ML12032A027
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 12/19/2011
From: Rana R
Energy Northwest
To: Gurjendra Bedi
Office of Administration, Office of Nuclear Reactor Regulation
References
76FR52355 00004, NUREG-1482, Rev 2
Download: ML12032A027 (3)


Text

Mendiola, Doris From:

Sent:

To:

Cc:

Subject:

Attachments:

Rana, Raj [RRANA@energy-northwest.com]

Monday, December 19, 2011 4:58 PM Bedi, Gurjendra Rana, Raj; Smith, Christopher J.; Wolfgramm, Richard P.

Comments on NUREG-1482, Rev. 2 Appendix B COMMENTS ON NUREG1482Rev2.doc Mr. G.S Bedi:

Please see attached comments on NUREG-1482, Rev 2 Appendix B.

AS discussed during the December 2011 ASME OM Code meeting at Clearwater Beach Florida, I agree with having a stand alone document Appendix A for snubbers examination and testing.

Please call me if you need any clarification on my comments.

Raj Rana Snubber and IST Program Manager Energy Northwest Columbia Generating Station P.O.Box 968 4,

M/S PE 27 Richland WA 99352 PH: 509-377-4313 E Mail: rrana(*enerqy-northwest.com

/<,{ y5~5j~

'Ti

~~~1 S

.,J 7ZJ C.10 6-,~z~ k3xv-~

COMMENTS ON NUREG-1482, Rev. 2 Company: Energy Northwest, Columbia Generating Station Contact Name: Raj Rana Phone: 509-377-4313 Email: rraana@energy-northwest.com APPENDIX B COMMENTS No.

Section Comment Throughout Appendix B replace "IST and examination" with 1

"examination and testing", replace "inspection" with

"'examination" 1.1 & 1.2 Discuss Regulatory History before Regulatory Basis. Delete 2

duplication of requirements, most of the text in section 2.1 is repeat of section 1.1.

2.1 & 2.5 Delete relief requests information from section 2.1 as it is 3

provided in section 2.5 2.2 Delete introductory paragraph before section 2.2.1 as it will 4

generate confusion.

5 2.2.1 Delete 2 nd and 3rd paragraphs, repeat of information in section 1.1. Most of the other paragraphs are repeat of Appendix A pump and valve requirements and are not really applicable to snubbers.

Revise second to last paragraph to read as "Tables 2.1 and 2.2 (which appear at the end of this appendix) provide examples of systems with valves that licensees typically include in their IST program. These tables may be used for developing licensee's snubber program scope."

6 2.2.2 Last sentence of last paragraph; add "components" after

........ piping or other components may be...."

7 2.2.3 This section is copied from Appendix A. Delete last sentence of paragraph one. Delete 2 nd and 3rd paragraphs. Replace "ISI" with "examination" in paragraph 1 and throughout the Appendix..

8 2.3 Delete this section as it is already covered under para. 2.2.1 9

2.4.3 Please reference the snubber RIS and EGM here. There was no requirement in Technical Specification/TRM to submit Snubber Program Plan to the NRC. Owners updating the snubber programs IAW latest rulemaking using OM Code will have to submit snubber program plan to the regulatory authorities. Last sentence of this para. should be clarified accordingly.

10 2.4.4 Middle of the paragraph; delete "each" from.... where a list of each snubbers is kept....

11 2.4.4.1 Delete item 1, it is part of ISI program plan. All other items

are either ISTD or TRM requirements that are detailed in the implementing surveillance procedures.

12 2.4.4.2 Change title to "Inservice Operational Readiness Testing."

Delete items 4 through 7, these items are either ISTD or TRM requirements that are detailed in the implementing surveillance procedures.

13 2.4.4.3 Middle of the Ist paragraph; replace "in" with "is" in the sentence,.... every refueling outage, and is not Predictive.....

Delete last sentence of 2 nd paragraph regarding consulting with SNUG.

14 2.4.5 Delete the requirement to list revision date on each page of the bases document. Under test frequency change to read, list the frequency of visual examination and testing. Also delete the requirement to list relief request(s) in the snubber list.

15 2.4.6 Change "Snubber Programs" to "Snubber Program Plan" in the Title and throughout this section.

16 2.6 Change Title to read "Snubber Program Plan Update".

Change "program documents" to "program plan" throughout this section. Change "ISI and testing" to "examination and testing" throughout this section. Change second "ISI" to "NRC" in first sentence.

17 2.8 Revise first sentence by adding "or other applicable Subsection",.......Section XI, Subsection IWF or other applicable Subsection, ASME OM Code...."

18 Table 2.1 Revise the Title, "Typical Systems or portions of systems in

& Table the scope of 10 CFR 50.55a where snubbers are....."

2.2 19 Figure 1 Add "Preservice" to the Title.