ML20149L031
| ML20149L031 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/21/1997 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| FRN-62FR25979, RTR-REGGD-01.084, RTR-REGGD-01.085, RTR-REGGD-01.147, RTR-REGGD-1.084, RTR-REGGD-1.085, RTR-REGGD-1.147, TASK-*****, TASK-RE 62FR25979-00006, 62FR25979-6, TXX-97166, NUDOCS 9707310062 | |
| Download: ML20149L031 (2) | |
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C July 21, 1997 C. Lance Terry f
Govup Mce Presulent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
COMMENTS ON DRAFT REGULATORY GUIDES:
DG 1048, PROPOSED REVISION 31 TO REGULATORY GUIDE 1.84,
" DESIGN AND FABRICATION CODE CASE ACCEPTABILITY, ASME j
a SECTION III, DIVISION 1":
DG 1049, PROPOSED REVISION 31 TO REGULATORY GUIDE 1.85,
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" MATERIALS CODE CASE ACCEPTABILITY, ASME SECTION III, DIVISION 1": AND DG 1050, PROPOSED REVISION 12 TO REGULATORY GUIDE 1.147, J
" INSERVICE INSPECTION CODE CASE ACCEPTABILITY, ASME SECTION XI, DIVISION 1" REF: 1) Draft Regulatory Guide: Issuance, Availability, Federal Register, Volume 62 No. 91 May 12, 1997, 4
Pages 25979 through 25980.
Gentlemen:
By Federal Register notice dated May 12, 1997 (Reference 1), the NRC solicited comments for three draft regulatory guides regarding ASME Code Case Acceptability. These comments are submitted by TV Electric in response to the NRC notice of May 12, 1997 (Reference 1).
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Specific comments:
1)
DG 1050, Code Case N 416 1: The additional requirements imposed on the use of this case are overly conservative. ASME did research on this issue and developed a technical basis to support the code case without the additional Code Class 3 root pass NDE. Their basis concluded that performing a leakage test in lieu of the hydrostatic test resulted in no reduction of safety.
It was further concluded that the Section XI hydro was not a structural test but was merely an expensive leakage test. There is further concern that the root j
pass NDE may introduce the possibility of contaminates in the weld i
structure if a liquid penetrant exam is used.
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1 TXX 97166 Page 2 of 2 3
2)
DG 1050, Code Case N 521: The conditional acceptance specified for this Code Case causes impacts on schedules, resources and AllRA by-requiring some reactor nozzle examinations to be performed twice during a ten year interval.
For plants that performed reactor nozzle exams during the first 40 month period, as is the case for i
both CPSES Unit 1 and Unit 2, the same exams will have to be i
repeated at the first 10 year reactor examinations _ in order to meet-the conditional acceptance requirements. There are also two errors i
in the rationale for conditional acceptance of this Code case stated on page 21.
Footnote 2, not 21 should be referenced for Table IWB-25001 and the last word of the first sentence of the last pargraph under Section 1.2.4 should be " period" not " interval." Referencing footnote 21 implies that it applies on an examination item by item 3
basis however, the footnote applies to the entire examination category.
Many plants can satisfy the footnote without performing reactor nozzle examinations by the end of the first inspection j
period.
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- 3)
DG-1050, Item 1.3 of section "Value/ Impact Statement" There is an error in the last line.
Revision 30 should be revision 11.
l TV Electric appreciates'this opportunity to comment on the draft j
regulatory guides and requests that the Commission or NRC staff contact l
Carl Corbin at-(254) 897-0121 if there are any questions.
Sincerely, e.s. 6 u, C. L. Terry i
By:
M J
Roger T. Walker l
Regulatory Affairs Manager
'I i,
CBC/cbc c-E. W. Herschoff, Region IV J. I. Tapia, Region IV T. J. Polich, NRR Resident Inspectors, CPSES
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