ML23145A232
| ML23145A232 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/25/2023 |
| From: | Mark Yoo NRC/NRR/DNRL/NLRP |
| To: | Peters K Vistra Operations Company |
| References | |
| Download: ML23145A232 (1) | |
Text
REQUEST FOR CONFIRMATION OF INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION COMANCHE PEAK UNITS 1 & 2 LICENSE RENEWAL APPLICATION REVIEW VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK, UNITS 1, 2 DOCKET NO. 05000445, 05000446 Set 2 RCI B.2.3.15-1 Table 3.5.2-15, Fire Barrier Commodity Group - Summary of Aging Management Evaluation, in the License Renewal Application (LRA) cites Aging Management Review (AMR) items 3.5-1, 095 (no aging effects or Aging Management Program (AMP)) and 089 (Boric Acid Corrosion AMP) for managing the galvanized steel damper housing commodity exposed to indoor uncontrolled air and air with borated water leakage, respectively.
During the audit of the Fire Protection AMP, the applicant stated that the Fire Protection AMP was not cited for managing the fire dampers because NUREG-1800, Revision 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (ML103490036), does not identify aging effects that require management for galvanized steel in indoor uncontrolled air. However, the U.S. Nuclear Regulatory Commission (NRC) staff notes that Revision 4 of Procedure No. MSM-P0-0705, Fire Damper Inspection and Cleaning, includes visual inspection of the fire damper surfaces for changes or degradation, which would ensure the damper housing continues to perform its intended fire barrier intended function during the period of extended operation (PEO).
Please confirm that the visual inspection of the fire damper surfaces for changes or degradation under Procedure No. MSM-P0-0705 will continue during the PEO.
RCI B.2.3.15-2 Section 6.1 of EPRI 3002013084, Long-Term Operations: Subsequent License Renewal Aging Effects for Structures and Structural Components (Structural Tools), dated November 2018, states, in part, wire and other appurtenances used to secure fire wrap to the item being protected - is considered to be part of the fire wrap itself.
During the audit of the Fire Protection AMP, the applicant stated that radiant energy shields are secured to the raceway with stainless steel straps. In addition, the applicant stated that the stainless steel straps exposed to indoor uncontrolled air do not have aging effects consistent with NUREG-1800, Revision 2. However, the staff notes that Revision 3 of Procedure No. FIR-311, Fire Rated Assembly Visual Inspection, states that exposed surfaces (top, bottom, sides, and ends) of radiant energy shields are visually inspected.
Please confirm that the stainless steel straps used to secure radiant energy shields to raceways are inspected as part of the visual inspection of the radiant energy shields exposed surfaces performed under Procedure No. FIR-311, and these inspections will continue during the PEO.
RCI B.2.3.15-3 The Monitoring and Trending program element for the Fire Protection AMP in Revision 2 of NUREG-1801, Generic Aging Lessons Learned (GALL) Report (ML103490041) states that the inspection results for penetration seals, fire barriers, and doors are trended for future actions and periodic tests of the halon fire suppression system provides data for trending.
During the audit of the Fire Protection AMP, the applicant stated that evaluation and trending by the Fire Protection Strategic Engineering Engineer is not limited to the halon system and noted that Revision 8 of Procedure No. STA-722, Fire Protection Program, states that fire protection systems are evaluated and trended by the Fire Protection Strategic Engineering Engineer.
Please confirm, per Procedure No. STA-722, that the inspection results for penetration seals, fire barriers, doors, and the halon system are trended, and trending these inspection results will continue during the PEO.