ML17312B404
| ML17312B404 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/02/1997 |
| From: | Clifford J NRC (Affiliation Not Assigned) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| TAC-M94139, TAC-M94140, TAC-M94141, NUDOCS 9705050298 | |
| Download: ML17312B404 (8) | |
Text
May 2, 1997 Hr. James M. Levine Senior Vice President, Nuclear Arizona Public Service Company Post Office Box 53999
- Phoenix, Arizona 85072-3999
SUBJECT:
CORRECTION TO SECOND ROUND REQUEST FOR ADDITIONAL INFORMATION (RAI)
ON RISK-INFORMED INSERVICE TESTING (RI-IST) PILOT PLANT PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2,
AND 3 (TAC NOS.
- H94139, M94140 AND H94141)
REFERENCE:
NRC letter from J. Clifford to J.
Levine, dated March 21, 1997
Dear Mr. Levine:
On March 21,
- 1997, our Second Round Request for Additional Information (RAI) on Risk-Informed Inservice Testing (RI-IST) Pilot Plant was forwarded to Arizona Public Service Company.
(A similar RAI was sent to TU Electric, the other pilot plant).
Following receipt of those letters, APS and TU Electric requested a telephone conference'call to clarify the questions in the RAIs.
On April 9, and April 22,
- 1997, telephone calls were held with your staff and the staff of TU Electric.
As a result of these discussions, the staff revised three of the original RAI questions.
Enclosed are the three revised RAI questions.
Please note that the original question'umbers were retained.
If you have any further questions in this regard, please contact me at (301) 415-1352.
Sincerely, Original Signed By Charles R.
Thomas
~
~
James W. Clifford, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket Nos..STN 50-528, STN 50-529 and STN 50-530
Enclosure:
Revised guestions cc w/encl:
See next page DISTRIBUTION:
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Mr. James M. Levine May 2, 1997 cc w/encl:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street
- Phoenix, Arizona 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O.
Box 800
- Rosemead, California 91770 Senior Resident Inspector USNRC P. 0.
Box 40
- Buckeye, Arizona 85326 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission Harris Tower 5 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064
- Chairman, Board of Supervisors ATTN:
Chairman 301 W. Jefferson, 10th Floor
- Phoenix, Arizona 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street
- Phoenix, Arizona 85040 Ms. Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O.
Box 52034
- Phoenix, Arizona 85072-2034 Mr. John C. Horne, Vice President Power Supply Palo Verde Services 2025 N. Third Street, Suite 220
- Phoenix, Arizona 85004 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, 80604 Albuquerque, New Mexico 87102 Mr. Robert D. Bledsoe Southern California Edison Company 14300 Mesa
- Road, Drop D41-SONGS San Clemente, California 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251
~ Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901 Mr. Robert Burt Los Angeles Department of Water L Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051
C
ENCLOSURE PALO VERDE NUCLEAR GENERATING STATION UNITS I 2
AND 3 DOCKET NOS.
STN 50-528 STN 50-529 AND STN 50-530 REVISED RE UEST FOR ADDITIONAL INFORMATION REGARDING RISK-INFORMED INSERVICE TESTING RI-IST PILOT PLANT The following are the revised supplemental questions and comments that have been developed by NRC staff reviewers who have been evaluating the proposed risk-informed inservice testing (RI-IST) program for the Palo Verde Nuclear Generating Station, Units I, 2, and 3.
The original question numbers were retained.
5.
12.
Please provide a detailed risk-informed IST Program implementation plan (i.e., for both HSSCs and, LSSCs).
This implementation plan should contain details on how each component, or group of components, categorized as being LAC, will have its test interval extended.
For
- example, the staff needs to see a detailed description, or draft procedure, documenting how component test intervals will be extended in a step-wise manner (i.e., not just the "speed limit" test interval).
The implementation plan should describe how various component groupings were selected (e.g.,
using the guidance contained in NRC Generic Letter 89-04, Position 2 for check valves; Supplement 6 to NRC Generic Letter 89-10 and Section 3.5 of ASME Code Case OMN-I for motor-operated valves).
The implementation plan should document how the licensee proposes to use past performance, service condition, etc.
in establishing the test strategy for'pecific components (See question 7
below). If the licensee wants to take credit for other operations and maintenance activities to justify less frequent inservice testing, then the details of these other activities and how they relate to the IST strategy needs to be described explicitly.
I The licensee should describe in detail its performance monitoring plan and explain how sufficient data will be developed to facilitate PRA and risk-informed IST Pr ogram updates.
Will there be suffici ent monitoring of both HSSC and LSSC to support the periodic updates?
As noted in RAI
¹I, have the components that contribute most to risk increase been identified and a monitoring program specifically planned that could be used to modify assumed failure rate data that is currently either under or overly conservative?
Does the proposed performance monitoring process ensure:
enough tests are included, over gradually extending time periods, to provide meaningful data to validate the PRA inputs/assumptions used to justify changes to the IST program;
J Al
incipient degradation is likely to be detected and corrective action taken; and
~
appropriate parameters, as required by the ASME Code or ASME Code
- case, are trended.
Does the proposed performance monitoring process ensure that degradation is not significant for components that are placed on an extended test
- interval, and that failure rate assumptions for these components are not compromised by test data?
14.
Are there any RI-IST program changes that the licensee proposes to make without prior NRC approval other than changes explicitly described by the licensee in RI-IST program submittals and approved by the"staff (e.g.,
component categorization/re-categorization in accordance with an NRC approved methodology, gradual extension of a components test interval in a step-wise fashion as approved by the staff in its safety evaluation)?
Does the licensee have an adequate process or procedures in place to ensure that RI-IST program changes of the following two types get reviewed and approved by the NRC prior to implementation:
Test method changes that involve deviation from the NRC-endorsed Code requirements.
Changes to the risk-informed IST program that involve process changes (e.g.,
changes to key PRA assumptions that support the changes to the IST program, changes to the grouping, criteria or figures of merit used to group components, changes in the acceptance guidelines used by the licensee's integrated decision-making process).
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