CP-201000890, Relief Request No. C-7 for the Second 10 Year ISI Interval from 10 CFR 50.55a Inspection Requirements Due to Physical Interferences (Second Interval Start Date: August 13, 2000)

Relief Request No. C-7 for the Second 10 Year ISI Interval from 10 CFR 50.55a Inspection Requirements Due to Physical Interferences (Second Interval Start Date: August 13, 2000)

ML103560594
Person / Time
Site:	Comanche Peak
Issue date:	12/15/2010
From:	Madden F Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201000890, TXX-10092
Download: ML103560594 (8)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@Luminant.com Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201000890 Ref. # 10 CFR 50.55a(g)(5)(iii)

Log # TXX-10092 December 15, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NO. 50-445 RELIEF REQUEST NO. C-7 FOR THE UNIT 1 SECOND 10 YEAR ISI INTERVAL FROM 10 CFR 50.55a INSPECTION REQUIREMENTS DUE TO PHYSICAL INTERFERENCES (SECOND INTERVAL START DATE: AUGUST 13, 2000)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(5)(iii), Luminant Generation Company, LLC (Luminant Power) is submitting Relief Request C-7 (see attachment) for Comanche Peak Unit 1 for the second ten year inservice inspection interval. Luminant Power has determined that certain inspection requirements of ASME Section XI are impractical due to physical interferences.

The geometry of the containment spray heat exchanger makes the Code required examination coverage requirements impractical. Ultrasonic Testing (UT) of the subject weld was performed during the second interval to the maximum extent practical based on design configuration restrictions. Pressure test VT-2 visual examinations were also performed with no evidence of leakage identified for the subject component. No undue risk to the public health and safety is presented by this request.

This communication contains no new licensing basis commitments regarding Comanche Peak Unit 1.

Should you have any questions, please contact Mr. Jack Hicks at (254)897-6725.

Sincerely, Luminant Generation Company LLC Rafael Flores 7

By: Fred W. Madden Director, Oversight & Regulatory Affairs A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak Diablo Canyon Palo Verde . San Onofre

• South Texas Project Wolf Creek

U. S. Nuclear Regulatory Commission TXX-10092 Page 2 12/15/2010 Attachments - 1. Relief Request C-7 for Unit 1 Relief Request for Weld Examination Coverage for the Containment Spray Heat Exchanger

2. Drawing and Inspection Sheets for the Containment Spray Heat Exchanger c- E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Brian Welch, ANII, Comanche Peak Anthony Jones, TDLR

Attachment I to TXX-10092 Page 1 of 3.

10CFR 50.55a Request Number C-7 Relief Requested In Accordance with 10CFR50.55a(g)(5)(iii)

- Inservice Inspection Impracticality -

1. ASME Code Component Affected:

Class 2 Containment Spray Heat Exchanger (CP1-CTAHCS-02) Shell Circumferential Weld Code Cat / Item No. Description Weld No.

C-A / CI.10 CT HX 1-02 Shell to Flange Weld TBX-2-1180-2

2. Applicable Code Edition and Addenda

The applicable ASME Boiler and Pressure Vessel Code (hereafter referred to as the "Code") edition and addenda is ASME Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1998 Edition through 2000 Addenda.

3. Applicable Code Requirement

ASME Section XI, Figure IWC-2500-1(a) 1998 Edition through 2000 Addenda, requires a minimum volumetric examination of the weld volume extending 1/" into the base metal on the vessel and flange sides for the circumferential weld (Code Item C1. 10).

Comanche Peak Nuclear Power Plant (CPNPP) second ten-year interval Inservice Inspection Program Plan also implements Code Case N-460, which is endorsed by the NRC in revision 15 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability ASME Section XI, Division 1." Code Case N-460 states, in part, when the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class 1 or Class 2 weld may be accepted, provided the reduction coverage for that weld is less than 10 percent.

NRC Information Notice (IN) 98-42, "Implementation of 10CFR50.55a(g) Inservice Inspection Requirements," termed a reduction in coverage of less than 10 percent to be "essentially 100 percent." IN 98-42 states, in part, "The NRC has adopted and further refined the definition of "essentially 100 percent" to mean "greater than 90 percent"...has been applied to all examinations of welds or other areas required by ASME Section XI."

to TXX-10092 Page 2 of 3 10CFR50.55a Request Number C-7

4. Impracticality of Compliance:

The examination of the subject component weld is limited by the configuration of the flange design and the proximity of two welded support plates on the shell side of the heat exchanger. As shown on the Attachment 2, the proximity of the welded supports and the flange configuration limit the parallel scans (circumferential). Perpendicular (axial) scans are limited mainly by the welded supports on the shell side of the weld. This yields a composite coverage of 41.47% of the required examination volume. The examinations were conducted in accordance with procedure TX-ISI-214,"Ultrasonic Examination Procedure for Welds in Piping Systems and Vessels." Angle beams (450 shear and 700 longitudinal) scans were used to achieve the weld volume obtained.

5. Burden caused by Compliance:

The design configuration restrictions of the of the subject component makes the Code required examination coverage requirements for the weld volume impractical. Plant modifications or replacements of components designed to allow for complete coverage would be needed to meet the Code requirements. This would cause considerable burden to CPNPP.

6. Proposed Alternative and Basis for Use:

Proposed Alternative:

The following alternatives are proposed in lieu of the required examination coverage of essentially 100 percent:

1. Ultrasonic testing (UT) of the subject component weld was performed to the maximum extent practical during the second ten-year interval.

2. Pressure test VT-2 visual examinations were performed, as required by Code Category C-H, during the second ten-year interval. No evidence of leakage was identified for this component.

Attachment I to TXX-10092 Page 3 of 3 10CFR50.55a Request Number C-7 Basis for use:

The basis for use of this alternative is that it provides the best examination coverage practical within the limitations of the current configuration. Based on the percentage of the examination volume completed and the lack of any indications identified, there is a high level of confidence in the continued structural integrity of the weld. CPNPP believes that there is no undue risk to the public health and safety presented by this request.

7. Duration of Proposed Alternative:

The second ten-year ISI interval for Unit 1 began on August 13, 2000 and ends on August 12, 2010.

8. Precedents:

Relief Request C-9 was submitted in letter TXX-98170 from CPNPP to USNRC in July 22, 1998 for the first ten-year interval for Unit 1.

PDI Calibration Data Sheet CD0 TBX-31 PDI-03 03 Plant / Unit COMANCHE PEAK UNIT 1 Data Sheet # 14 UT-002 80 I~ 80 ;r d Company WESDYNE Page of o3 Comp / System CONTAINMENT SPRAY HX 60 60 Procedure No. TX-ISI-214 Cal. Checks Time C) 4M to Rev / Chng. No. 4 / N/A Initial Calib. 0900 40 40 Cal. Block No. TBX-31 / PDI-03 Intermediate N/A Cal. Block Temp 74' Comp. Temp 71° 20~ 20 Therm S/N: TU-2250 Intermediate N/A Size N/A Sch. .625" "T" Final Calib. T 1150 FD1 Ferritic 7XAustenitic Final Calib. Date 13/18/10 0 2 4 6 8 0 2 4 6 8 1 CRT Div. = 0.2907" 1 CRT Div. 0.2907" Cal. Direction: DAxial W1 Circ. r7Both Couplant Scan Area: _L to Weld Type: ULTRA GEL II Search Unit #1 Search Unit #2 to Weld Batch: 06225 Manufacturer: KBA Manufacturer: RTD Serial No.: 0OYH5B Freq.: 2.25 MHz Serial No.: 01-988 Freq.: 2.00 MHz Recordable Size: .5" Shape: ROUND Size: 2(8x14) Shape: RECT Access Indications Exam Sens. Exam Angle: 450 Model: COMP-G Exam Angle: 700 Model: TRL2 Examination Area / Weld Yes I No Geom Measured Angle: 45' S Measured Angle: 70' L TBX-2-1180 2-1 2-SIDED X 30dB/49 dB Wedge Style: MSWQC Wedge Style: INTEGRAL TBX-2-1180 2-2 1-SIDED _ X_, 30dB/49dB Search Unit Cable Search Unit Cable Type: RG-174 Type: RG-174 Length: 6' No. of Connectors: 0 Length: 6' No. of Connectors: -0 Remarks / Reason for Incomplete Scan(s) Instrument Settings Instrument Settings Make / Model: GE IT / USN 60 SW Make / Model: GE IT / USN 60 SW WELD TBX-2-1180 2-1, 100% EXAMINATION COVERAGE Serial No.: SAP 105204 Serial No.: SAP 105204 ACHIEVED Dis.Delay: 3.550 ps Range: 2.907 Dis.Delay: 3.550 ps Range: 2.907 Prb.Delay: 3.8016 ps Pwidth: 220 Prb.Delay: 10.6016 tiS Pwidth: 250 WELD TBX-2-1180 2-2, SEE PREVIOUS DATA FOR M'tl CalNel: .1228 ps Pulser: SQUARE M'tl Cal/Vel: .2423 Ijs Pulser: SQUARE LIMITATION DOCUMENTATION, 41.47% EXAMINATION Damping: 500 0 Reject: 0% Damping: 500 Q Reject: 0%

COVERAGE ACHIEVED Rep. Rate: AUTOHIGH Freq.: 2.25 MHz Rep. Rate: AUTOHIGH Freq.: 2-00 MH Filter: FIXED Mode: PIE Filter: FIXED Mode: P/3 Voltage: 450 Rectify: FULLWAVE Voltage: 450 Rectify: FULLWAVE Examiner: CAR SY4A Level i1 Date 3/18/10 Reference Sensitivity (Sens.) Reference Sensitivity (Sens.)

Axial: 18 dB Circ: 18 dB Axial: 43.5 dB Circ:

Examiner: N/A Level N/A Date N/A SDH Sensitivity: N/A SDH Sensitivity: N/A I IIII Further Evaluation Required? F-1 Yes W -No Reviewer I Date <~~9 ~ '-o'e Reviewer I Date

(ýL~-, L't-1'-1 0 to TXX-1 0092 Page 2 of 3 WESTINGHOUSE NUCLEAR SERVICES DIVISION REPORT NO UT-98-023 INSPECTION SERVICES PAGE 2 OF Z-.

- = PROFILE OF THE EXAMINATION VOLUME 3-PLANT Comanche Peak UNIT 1 SKETCH TBX.2-1180 Rev. 1 SYST/COMP CONTAINMENT SPRAY PROCEDURE TX4SI-214 Rev. 2 FC N;A EXAMINER Williams, Mark LEVEL 11 DATE 312019B EXAMINER - NIA LEVEL NIA DATE____________

COMPONENT ID TBX-2-1180-2-2 COMMENTS/S KETCHIDETAILS S '6& 5 /--

4 a V

~2i TU ELECTRIC REIEW I DATE U ELECTRIC LEVEL IIIREVIEW I DATE ANII REVIEW I DATE i I I I

- ciid to TXX-10092 Page 3 of 3 REPORT NO. 14 UT-002 PAGE 3 0F_

LIMITATION TO EXAMINi kTION PLANT COMANCHE PEAK UNIT 1 SKETCH TBX-2-1180 SYST./COMP. CONTAINMENT SPRAY PROCEDURE TX-ISI-214, REV. 4 EXAMINER CAREY LASOYA DATE 03/18/10

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