ML20206E130
| ML20206E130 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/29/1999 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-99109, NUDOCS 9905050030 | |
| Download: ML20206E130 (3) | |
Text
-.
,6 $
MM
- llll:' =
~
Log # TXX-99109 File # 10010 1UELECTRIC 903 Ref. # 10 CFR 50 c.t w rry sentar nee Presuent
& Principal #asclear Officer April 29,1999 l
U. S. Nuclear Regulatory Commission.
Attn: Document Control Desk Washington, DC 20555
SUBJECT:
~ COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 STATUS OF TOPICAL REPORT ON CONTROL OF HAZARD BARRIERS REF: 1) TU Electric Letter, logged TXX-98161, from C. L. Terry to the NRC dated August 14,1998
- 2) NRC Letter from John N. Hannon to C.. Lance Terry dated May 28,1998
- 3) TU Electric Letter, logged TXX-98029, from C. L. Terry to the NRC dated February 13,1998 Gentlemen:
On February 26,1999,TU Electric, Southem California Edison, and Nebraska Public Power District met with the NRC Staff to discuss the topical report on " Control of Hazard Barriers" submitted via reference 1 as recommended per reference 2.
The following is TU Electric's understanding of the open items requiring NRC actions:
1)
During the course of the referenced meeting (and as outlined in Reference 3 above),
TU Electric presented two positions (see a. and b. below) which the NRC staff agreed to review for acceptability, a.
The subject hazard barriers are not technical specification support systems, but, l
are instead passive (with a few exceptions such as HELB dampers) design O
features that are implemented for specific scenarios (primarily to provide the protection needed to assure shutdown capability within those scenarios).
c p'Y b.
. The impairment of a hazard barrier to effect maintenance or modifications to components protected by the barrier, or to perform corrective or preventative maintenance to the barrier itself does not require a safety evaluation as described in 10CFR 50.59 (b) (2), because these conditions represent a 1
(A IE PEAK St EAM ELECTRIC STATION P.O. Box 1002 Glen Rose, Texas 76043-1002 9905050030 990429
~
PDR ADOCK 05000445 P
' Page 2 of 3 planned impairment for specific activities and not a design change. The licensee should, however, perform an evaluation to establish an allowed impairment time for the barrier impairment consistent with the barrier's importance to safety. A safety evaluation as described in 10CFR 50.59 (b) (2) would be required if a modification specific to the barrier itself were to be implemented.
TU Electric stated that if the NRC accepted these positions then the NRC staff's review of the topical report submitted via Reference 1 was no longer required. The methodology described in the topical report would then become one of several potential methods (i.e. maintenance rule methodology, etc.) that could be used to implement these positions.
2)
The NRC agreed to expedite a review of the TIA regarding an alleged barrier violation at Davis-Besse and issue any needed clarifications.
3)
The NRC will evaluate the potential applicability of maintenance rule methodology to hazard barrier impairments required to support activities such as maintenance, i
surveillance testing or plant modifications which enhance safety. If appropriate, guidance would be prepared regarding the implementation of this methodology for evaluating barrier impairments.
4)
If the NRC staff can not agree with the positions taken by TU Electric in this meeting (see open item 1 above) then TU Electric wishes to pursue NRC staff review of the topical report submitted via Reference 1 above and any associated license amendments that may be necessary to implement the topical report on TU Electric's docket. As part of these reviews, it is TU Electric's understanding that the NRC staff
. would initiate preliminary comments on our submittal via telephone conversations to be
- followed by formal requests for additional information (RAl's), if needed.
TU Electric's has consulted with Southern Califomia Edison and Nebraska Public Power District and they share this understanding of the open items from the February 26,1999 meeting; i
'P5g4 3 of 3 if you have questions concerning this matter, please contact either Jack Hicks (254-897-6725) or Roger Walker (254-897-8233) of my staff.
Sincerely, 00 C. L. Terry By:
M Roger MWalker Regulatory Affairs Manager JCH/gp]
c-E. W. Merschoff, Region IV J. l. Tapia, Region IV D. H. Jaffe, NRR Resident inspectors, CPSES
.