ML20138C987
| ML20138C987 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/25/1997 |
| From: | Polich T NRC (Affiliation Not Assigned) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| TAC-M94165, TAC-M94166, NUDOCS 9704300270 | |
| Download: ML20138C987 (5) | |
Text
___.
April 25 1997 0
Mr. C. Lance Terry TV Electric Group Vice President, Nuclear Attn:
Regulatory Affairs Department P. O. Box 1002 l
Glen Rose, TX 76043 i
SUBJECT:
CORRECTION TO SECOND ROUND REQUEST FOR ADDITIONAL INFORMATION (RAI)
ON RISK-INFORMED INSERVICE TESTING (RI-IST) PILOT PLANT -
3 COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1, AND 2 (TAC NOS. M94165 AND M94166)
REFERENCE:
1.
NRC letter from Timothy J. Polich to C. Lance Terry, dated March 12, 1997 l
Dear Mr. Terry:
i j
On March 12, 1997, our Second Round Request for Additional Information (RAI) i j
on Risk-Informed Inservice Testing (RI-IST) Pilot Plant was forwarded to Texas Utilities Electric Company (TV Electric). A similar RAI was sent to Arizona i
Public Service Company (APS), the other pilot plant.
Following receipt of those letters, APS and TV 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 APS. As a result of those discussions the staff revised three of the original RAI questions.
Enclosed are the three revised RAI questions the original question numbers were retained.
If you have any further questions please contact me at 301-415-1038.
Sincerely, ORIGINAL SIGNED BY-l Timothy J. Polich, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
As stated cc: See next page DISTRIBUTION:
Docket 0GC PUBLIC JRoe GHill (4)
ACRS TPolich (2)
JDyer, RIV PDIV-1 r/f CHawes CGrimes EAdensam (EGAl)
Document Name:
CP94165.00R OFC PM/PD4-1 LA/PD4-1 NAME TPolich:sp CHawesO///M 4 # 97 k/2697 DATE
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COPY YES/N0 YES/NO 0FFICIA! RECORD COPY I
b; 9704300270 970425 PDR ADOCK 05000445 P
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UNITED STATES p
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20N64001
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April 25, 1997 Mr. C. Lance Terry TU Electric Group Vice President, Nuclear Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
CORRECTION TO SECOND ROUND REQUEST FOR ADDITIONAL INFORMATION (RAI)
ON RISK-INFORMED INSERVICE TESTING (RI-IST) PILOT PLANT - COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1, AND 2 (TAC NOS. M94165 AND M94166)
REFERENCE:
1.
NRC letter from Timothy J. Polich to C. Lance Terry, dated March 12, 1997
Dear Mr. Terry:
On March 12, 1997, our Second Round Request for Additional Information (RAI) on Risk-Informed Inservice Testing (RI-IST) Pilot Plant was forwarded to Texas Utilities Electric Company (TU Electric). A similar RAI was sent to Arizona Public Service Company (APS), the other pilot plant.
Following receipt of those letters, APS and TU Electric requested a telephone conference call to clarify the questions in the RAls. On April 9 and April 22, 1997, telephone calls were held with your staff and the staff of APS. As a result of those discussions the staff revised three of the original RAI questions.
Enclosed are the three revised RAI questions, the original question numbers were retained.
If you have any further questions please contact me at 301-415-1038.
Sincerely, f
Timothy J. Polich, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
As stated cc: See next page
a Mr. C. Lance Terry TV Electric Company Comanche Peak, Units 1 and 2 cc:
Honorable Dale McPherson Senior Resident Inspector U.S. Nuclear Regulatory Commission County Judge P. O. Box 1029 P. O. Box 851 Granbury, TX 76048 Glen Rose, TX 76043 Regional Administrator, Region IV Office of the Governor U.S. Nuclear Regulatory Commission ATTN: John Howard, Director 611 Ryan Plaza Drive, Suite 400 Environmental and Natural Arlington, TX 76011 Resources Policy P. O. Box 12428 Mrs. Juanita Ellis, President Austin, TX 78711 Citizens Association for Sound Energy 1426 South Polk Arthur C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection Bureau of Radiation Control Mr. Roger D. Walker Texas Department of Health TU Electric 1100 West 49th Street Regulatory Affairs Manager Austin, TX 78756-3189 P. O. Box 1002 Glen Rose, TX 76043 Texas Utilities Electric Company c/o Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, MD 20814 George L. Edgar, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
i Washington, DC 20036-5869
COMANCHE PEAK STEAM ELECTRIC STATION. UNITS 1 AND 2 DOCKET NOS. 50-445. AND 50-446 REVISED RE0 VEST FOR ADDITIONAL INFORMATION REGARDING RISK-INFORi1ED INSERVICE TESTING (RI-IST) PILOT PLANT The following are the revised supplemental questions and comments that have been developed by several NRC staff reviewers who have been evaluating the proposed risk-informed inservice testing (RI-IST) program for Comanche Peak.
The original question numbers have been retained.
5.
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 LSSC, 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-1 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 specific 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 au fvities and how they relate to the IST strategy needs to be describid explicitly.
12.
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 Program updates. Will there be sufficient monitoring of both HSSC and LSSC to support the periodic updates? As noted in RAI
- 1, 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 a
provide meaningful data to validate the PRA inputs /assu.mptions used to justify changes to the IST program; incipient degradation is likely to be detected and corrective action e
taken; and appropriate parameters, as required by the ASME Code or ASME Code case, are trended.
ENCLOSURE u
j Does the proposed performance monitoring process ensure that degradation 4
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 i
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).