ML20217H361
| ML20217H361 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/26/1998 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR9581 63FR9581-00013, 63FR9581-13, TAC-M97978, TXX-98089, NUDOCS 9804030285 | |
| Download: ML20217H361 (3) | |
Text
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File # 10035.1 RULES & D.rR. EPANCH 7UELECTRIC Ref. # 10CFR50, App A.
US NRC March 26, 1998 C. Onace "Ibrry Senior Mce President
& PrincipalNuclear Oplcer Chief, Rules and Directives Branch, Division of Administrative Services.
U. S. Nuclear Regulatory Commission Mail Stop T6 D69, Washington, DC 20555 0001
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50-446 COMMENTS ON DRAFT GENERIC LETTER 97-XX," LABORATORY TESTING OF NUCLEAR GRADE ACTIVATED CHARC0AL (TAC N0. M97978)."
REF:
NRC Federal Register Notice, Volume 63 Number 37 Pages 9581 through 9589. February 25, 1998.
Gentlemen:
The NRC issued draft generic letter 97 XX, " Laboratory Testing of Nuclear Grade Charcoal (TAC No. M97978)" for public comment (See reference above),
and requested that comments be provided by March 27, 1998.
TU Electric supports industry comments provided by NEI (letter dated March 27, 1998) and NUBARG (letter dated March 27, 1998).
The following are specific TV Electric comments on the subject draft generic letter:
- 1) General;_
There will be additional implementation costs for plants (other than those plants in group 1).
Technical Specifications, the FSAR, and test procedures will have to be changed. Additional samples will have to be taken from plant ESF filtration units resulting in greater testing costs.
- 2) Discussion (Paae 9584);.
The generic letter Requested Actions indicate testing in accordance with ASTM D3803-1989 should be conducted within 60 days of the date of the generic letter.
For non group 1 plants this would require dual testing until such time as a Technical Specification change is approved by the NRC.
In order to avoid the dual testing requirement, the generic letter should be modified to require adoption of ASTM D3803 1989 after approval of a License l
Amendment.
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w RECElVED TXX 98089 Page 2 of 3 l ppg Apg g g
- 3) Reauested Actions (Pace 9584):
RULES & DtR. BRANCH US NRC The 60 day time. limit to retest charcoal samples is overly restrictive. As pointed out in the protocol. there are only two testing laboratories left.
Requiring several nuclear plants to send numerous samples within a 60 day period would likely exceed the capabilities of these laboratories and may. compromise the ability of the laboratories to maintain high quality. The charcoal sample l
testing should be performed at the next scheduled surveillance test or no later then 180 days after issuance of the generic letter, whichever is greater.
The proposed generic letter requests all licensees to submit to the NRC staff the results of tests performed to ASTM D3803-1989. This is a new requirement.
The generic letter does not explain the purpose of the submittal. The generic letter should be revised to only request that licensees notify the staff of r
revised commitments.
- 4) Reauested Information (Paaes 9584 and 9585):
For the plants adopting ASTM D3803 1989 requirements, a minimum of 90 days should be allowed from the issuance of the generic letter for submittal of the Technical Specifications Amendment Request.
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- 5) Reauested Resoonse (Paae 9585):
l' Sixty (60) days should be allowed from the issuance of the generic letter for l-submittal of the written response, j-
- 6) Backfit Discussion (Paae 9585):
For plants other than group 1, more rigorous testing would be required based on i
ASTM D3803 1989. Changes to Licensing bases, design bases and testing and operating procedures would also be required. As such, this constitutes a
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TXX 98089-Page 3 of 3 This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2 Sincerely, q
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C. L. Te By:
M Roge M f. Walker Regulatory Affairs Manager
.j c-E. W. Herschoff, Region IV J. I. Tapia, Region IV T. J. Polich, NRR Resident Inspectors, CPSES Mr. Kurt Cozens Nuclear Energy Institute.
L 1776 I.. Street, NW, Suite 400 uy >$
Washington, DC 20006 3708 m
Mr. Daniel F. Stengar 3M c c.
O Nuclear Utility Backfitting & Reform Group M
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Winston & Strawn
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