ML20237C397

Forwards SER Re Approval of risk-informed Inservice Testing Program for Plant,Units 1 & 2

ML20237C397
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1998
From:	Hannon J NRC (Affiliation Not Assigned)
To:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20237C399	List: ML20237C397 ML20237C406
References
FACA, TAC-M94165, TAC-M94166, TAC-MA1972, TAC-MA1973, NUDOCS 9808210133
Download: ML20237C397 (5)

Text

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l-f  % UNITED STATES g g NUCLEAR REGULATORY COMMISSION o WASHINGTON, D.C. atNIM.0001

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• .* August 14, 1998 [ g 9, // h 4 Mr. C. Lance Terry TU Electric Senior Vice President & Principal Nuclear Officer Attn: Regulatory Affairs Department '

P. O. Box 1002 Glen Rose, TX 76043

SUBJECT:

APPROVAL OF RISK-INFORMED INSERVICE TESTING (RI-IST) PROGRAM FOR COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 (TAC NOS. M94165, M94166, MA1972, AND MA1973) l

References:

1. Letter, C. L. Terry, TU Electric,in the NRC, logged TXX-95260, November 27,1995.

2. Letter, T. J. Polich, NRC, to C. L. Terry, TU Electric, March 15,1996.

3. Letter, C. L. Terry, TU Electric, to the NRC, logged TXX-96371, June 3, 1996.

4. Letter, H. G. Hamzehee, TU Electric to M. Check, NRC, July 2,1996.

5. Letter, C. L. Terry, TU Electric, to the NRC, logged TXX-96458, September 12,1996.

6. Letter, T. J. Polich, NRC, to C. L. Terry, TU Electric, March 12,1997.

7. Letter, T. J. Polich, NRC, to C. L. Terry, TU Electric, April 25,1997.

8. Letter, T. J. Polich, NRC, to C. L. Terry, TU Electric, June 9,1997.

9. Letter, D. R. Woodlan, TU Electric, to the NRC, logged TXX-97189, I September 30,1997.

10. Letter, C. L. Terry, TU Electric, to the NRC, logged TXX-98134, May 21, 1998.

11. Letter, C. L. Terry, TU Electric, to the NRC, logged TXX-98153, June 24, 1998.

Dear Mr. Terry:

On November 27,1995, TU Electric, the licensee for the Comanche Peak Steam Electric Station (CPSES) Units 1 and 2, submitted a request to the Nuclear Regulatory Commission (NRC) as pari of a pilot plant initiative to utilize a risk-informed inservice testing (RI-IST) program to determine inservice test (IST) frequencies for certain valves and pumps that are categorized as low safety significant. Such an authorization would represent an attemative to

'certain IST requirements specified in Section XI of the Boiler and Pressure Vessel Code promulgated by the American Society of Mechanical Engineers (ASME), as required by Title 10, Section 50.55a, of the Code of FederalRegulations (10 CFR 50.55a).

i l As the staff's review of TU Electric's initial RI-IST proposal progressed, TU Electric's RI-IST 1 l Program Description was expanded to address test methods (as wel! as test frequencies) and performance-based concepts for IST. On March 15,1996, the NRC staff transmitted to m i ]

TU Electric an initial request for additional information (RAI) related to the proposed RI-IST QU i

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1 i C. Lance Terry 2 I l l program (Ref. 2). The NRC staff subsequently met with TU Electric at the CPSES site on April 25,1996, to discuss the RAl. TU Electric then responded to the NRC staff's initial RAI on June 3,1996, and submitted a revised RI-IST program to the NRC (Ref. 3).

TU Electric also supplemented its response by submitting letters to the NRC dated July 2 and i September 12,1996, containing additional information in support of its proposed RI-IST program (Refs. 4 and 5). The NRC staff transmitted second and third round RAls to TU Electric on March 12, April 25, and June 9,1997 (Refs. 6,7, and 8). On July 14 through 18,1997, the NRC staff and its contractors reviewed probabilistic risk assessment (PRA) models, backup calculations, and data at CPSES. TU Electric subsequently responded to the second and third round RAls on September 30,1997 (Ref. 9). On December 9 and 10,1997, the staff met with TU Electric to obtain clarification concerning several of TU Electric's responses to the staff's RAls. Finally, on May 21,1998, TU Electric provided the staff with a revised RI-IST Program Description (Ref.10) and proposed alternative.

in preparing the enclosed safety evaluation report (SER), the staff used the decision guidelines contained in the risk-informed regulatory guides (i.e., RG 1.174 and RG 1.175) and the risk-informed Standard Review Plans (i.e., SRP Chapter 19 and SRP Section 3.9.7) as contained in SECY-98-015 and SECY-98-067. The licensee's RI-IST program meets the acceptance guidelines specified in RG 1.175 (as contained in SECY-98-067) and, therefore, is acceptable.

Consequently, the staff authorizes the licensee's proposed risk-informed IST program as an alternative to the ASME Code Section XI requirements related to the test frequencies and methods used to ensure operational readiness of certain pumps and valves in the CPSES plant, pursuant to 10 CFR 50.55a(a)(3)(i) based on the alternative providing an acceptable level of quality and safety. The authorization of this alternative will not adversely impact safe operation of the CPSES Units 1 and 2.

The staff authorization of this alternative is for the remainder of each unit's plant life. TU Electric will not be expected to resubmit its RI-IST Program Description unless significant changes are made to the Rl-IST Program Description that could potentially affect the staff's overall conclusions. However, the licensee is still required to submit its 120-month updates of its IST Program Plan for pumps and valves including requests for relief from impractical Code requirements pursuant to 10 CFR 50.55a(f)(5). Failure to comply with the RI-IST Program Description as reviewed and approved by the NRC staff and authorized pursuant to 10 CFR 50.55a(a)(3) (e.g., including scope, test strategy, documentation, and other programmatic requirements] constitutes noncompliance with 10 CFR 50.55a and is enforceable.

In conjuction with the RI-IST on June 24,1998, TU Electric, submitted Relief Request V-8 (Revision 2) (Ref.11), to use ASME Code Case OMN-1," Alternate Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Power Plants, OM Code-1995 Edition, Subsection ISTC," in lieu of ASME O&M Code Part 10 paragraph 4.2.1 at CPSES Units 1 and 2. The NRC staff reviewed that submittal as part of Appendix B to the enclosed SER and concluded that TU Electric's proposed attemative, Relief Request %8 (Revision 2), to use ASME Code Case OMN-1 together with the conditions  !

specified is authorized for CPSES Units 1 and 2, pursuant to 10 CFR 50.55a(a)(3)(i).

i 4

C. Lance Terry 3 1

1 The NRC is evaluating ASME Code Case OMN-1 for possible endorsement through rulemaking or by a regulatory guide. At that time, if CPSES intends to continue to implement this relief request. TU Electric should follow the provisions of OMN 1 with any limitations or conditions specified in the NRC staff endorsement.

TU Electric has made a substantial commitment in resources to participate in the RI-IST pilot effort. You and your staff should be commended for your leadership and commitment in pursuing this first-of-a-kind risk-informed inservice testing initiative to completion.

Sincerely, ORIGINAL SIGNED BY:

John N. Hannon, Director Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Safety Evaluation cc w/ encl: See next page DISTRIBUTION:

Docket File) OGC PUBLIC GHill (4) MBoyle ACRS TPolich (2) TGwynn, RIV PDIV-1 r/f DLange CHawes JHannon EAdensam (EGA1) RWessman GParry DFischer(10) JColaccino MCheok(2) RBarrett WHardin MRubin HHamzehee THarris (TLH3)

Document Name: CP94165.LTR ,)

OFC PM/PD4-1 LA/PD4-1 OGCtJW PD/PDI[1 NAME TPolich/v7 CHawbN [dh) JHannon DATE f/t1/98 TV S /98 i//I[9d[ f/h/98 COPY YES/NO YES/NO YES/[O YES/NO OFFICIAL RECORD COPY l

J

l C. Lance Terry 3 The NRC is evaluating ASME Code Case OMN-1 for possible endorsement through rulemaking or by a regulatory guide. At that time, if CPSES intends to continue to implement this relief

, request, TU Electric should fohow the provisions of OMN-1 with any limitations or conditions l specified in the NRC staff endorsement. ,

TU Electric has made a substantial commitment in resources to participate in the RI-IST pilot effort. You and your staff should be commended for your leadership and commitment in l pursuing this first-of-a-kind risk-informed inservice testing initiative to completion. I Sincerely, j ORIGINAL SIGNED BY:

John N. Hannon, Director Project Directorate IV-1 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Safety Evaluation cc w/ encl: See next page DISTRIBUTION:

W Mis) OGC PUBLIC GHill(4) MBoyle ACRS TPolich (2) TGwynn, RIV PDIV-1 r/f DLange CHawes JHannon EAdensam (EGA1) RWessman GParry DFischer(10) JColaccino MCheok(2) RBarrett WHardin MRubin HHamzehee THarris (TLH3)

Document Name: CP94165.LTR ,)

OFC PM/PD4-1 LA/PD4-1 OGCIJC PD/PDI[1 NAME TPolich/vk CHa M [31 JHannon DATE if/l1/98 T/ O /98 i //k9h f/h/98 COPY YES/NO YES/NO YES/[O YES/NO OFFICIAL RECORD COPY l

l C. Lance Terry 3 The NRC is evaluating ASME Code Case OMN-1 for possible endorsement through rulemaking or by a regulatory guide. At that time, if CPSES intends to continue to implerr'nt this relief request, TU Electric should follow the provisions of OMN-1 with any limitations or conditions specified in the NRC staff endorsement.

TU Electric has made a substantial commitment in resources to participate in the RI-IST pilot effort. You and your staff should be commended for your leadership and commitment in pursuing this first-of-a-kind risk-informed inservice testing initiative to completion.

Sincerely, John N. Hannon, Director Project Directorate IV-1 Division of Reactor Projects til/IV Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Safety Evaluation cc w/ encl: See next page l

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, Mr. C. Lance Teny l l TU Electric Company Comanche Peak, Units 1 and 2 '

cc:

Senior Resident inspector Honorable Dale McPherson l U.S. Nuclear Regulatory Commission ~ County Judge P. O. Box 2159 P. O. Box 851

- Glen Rose, TX 76403-2159 Glen Rose, TX 76043 l

Regional Administrator, Region IV Office of the Govemor l 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 j

Citizens Association for Sound Energy L 1426 South Polk Arthur C. Tate, Director Dallas, TX 75224 Division of Compliance & Inspection

)

l Bureau of Radiation Control i 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 Jim Calloway Public Utility Commission of Texas l George L. Edgar, Esq. Electric Industry Analysis Morgan, Lewis & Bocklus P. O. Box 13326 j

.1800 M Street, N.W. Austin, TX 78711-3326 Washington, DC 20036-5869 1

1 l

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