CP-201400070, Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date August 2, 2014)

Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date August 2, 2014)

ML14038A256
Person / Time
Site:	Comanche Peak
Issue date:	01/23/2014
From:	Thomas McCool Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201400070, TAC MF2997, TXX-14004
Download: ML14038A256 (4)

Text

Rafael Flores Luminant Power OR Senior Vice President

& Chief Nuclear Officer Rafael.Flores@Luminant.com P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201400070 Ref. # 10CFR50.55a(a)(3)(ii)

TXX-14004 January 23, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NO. 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR RELIEF REQUEST NO. C-3 FOR THE UNIT 2 REACTOR PRESSURE VESSEL LEAK-OFF FLANGE (SECOND ISI INTERVAL START DATE. AUGUST 3,2004; SECOND ISI INTERVAL END DATE: AUGUST 2, 2014)(TAC NO. MF2997)

REFERENCES:

1. Letter logged TXX-13145 dated October 31, 2013, from Rafael Flores to the NRC submitting Relief Request No. C-3 for the Unit 2 Reactor Pressure Vessel Leak-Off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date:

August 2, 2014)

2. Email dated January 3, 2014, from NRC to Rafael Flores submitting Request for Additional Information for Unit 2 Relief Request C-3 (TAC No. MF2997)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Luminant Generation Company LLC (Luminant Power) submited Relief Request C-3 for Comanche Peak Nuclear Power Plant (CPNPP) Unit 2 for the second ten year inservice inspection interval via Reference 1. Per Reference 2, the NRC provided a request for additional information regarding the subject relief request.

Attached is the Luminant Power response to the request for additional information.

This communication contains no new commitments regarding CPNPP Unit 2.

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

A member of the STARS Alliance 041 Callaway. Comanche Peak. DiabloCanyon. PaloVerde. Wolf Creek

'Z-/1/7A0 '/-

U. S. Nuclear Regulatory Commission TXX-14004 Page 2 of 2 01/23/14 Sincerely, Luminant Generation Company LLC Rafael Flores By:

Thomas P. mcCool Vice President, Station Support

Attachment:

Response to Request for Information Regarding Relief C-3 or the Reactor Pressure Vessel Leak-Off Flange (Second 10-Year ISI Interval Start Date:

August 3, 2004) c- Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Jack Ballard, ANII, Comanche Peak Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P.O. Box 149347 Austin, TX 78714-9347

Attachment I to TXX-14004 Page l of 2 COMANCHE PEAK NUCLEAR POWER PLANT UNIT 2 RESPONSE TO REQUEST FOR INFORMATION REGARDING RELIEF REQUEST C-3 FOR THE REACTOR PRESSURE VESSEL LEAK-OFF FLANGE (SECOND 10-YEAR ISI INTERVAL START DATE: AUGUST 3,2004)

. (TAC NO. MF297)

NRC Request I from Reference 2:

The NRC requires deviations from the ASME Code,Section XI, be pre-approved in accordance with Title 10 of the Code of FederalRegulations (10 CFR) 50.55a(a)(3)(ii). The licensee submitted RR C-3 for the second 10-year ISI interval which commenced on August 3,2004, and will end on August 2, 2014. The RPV flange leak-off piping is subject to a system leakage test each inspection period in accordance with the ASME Code,Section XI. Please discuss whether the system leakage tests have been performed in accordance with the ASME Code,Section XI, IWC-5220, in the previous inspection period(s) of the second 10-year ISI interval. If the answer is No, please discuss the reason(s) for not obtaining the NRC prior-authorization for deviation from the requirement in the previous inspection period(s) of the second 10-year ISI interval. If the answer is Yes, please discuss why the required test cannot be performed in the current inspection period of the second 10-year ISI interval.

Luminant Power Response to Request 1:

No, the system leakage tests performed in the previous inspection periods of the second 10-year ISI interval for Unit 2 were not completed in accordance with the ASME Code,Section XI, IWC-5220. The timing of the submittal and NRC review of request for relief C-9 for the second 10-year ISI interval for CPNPP Unit 1 occurred after inspections using the alternate method had been performed in previous inspection periods for CPNPP Unit 2 as explained below.

Upon completion of the second 10-year ISI interval for CPNPP Unit 1 by letter dated December 15,2010 (Accession No. ML103560595) and supplemented by letter dated October 13, 2011 (Accession No. ML11292A052), Luminant Generation Company LLC submitted request for relief C-9 from the ASME Code Section XI inspection requirements pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations. In response, by letter dated December 19, 2011 (Accession No. ML113110092), the Nuclear Regulatory Commission informed Luminant Generation Company LLC that "alternative methods of examination are to be authorized by the NRC staff prior to the application of the alternative."

The cause for the deviation at the time of the C-9 submittal was misinterpretation by Luminant of paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations that require NRC approval prior to implementation of the alternative VT-2 system pressure test method. The NRC staff informed Luminant Generation Company LLC that for this reason the NRC could not grant authorization to use the alternative method for the second 10-year ISI interval for Unit 1. However, based on the results of the visual examinations that were performed, the NRC staff saw no need for the Licensee to repeat the VT-2 examination. The NRC Region IV staff was made aware of this subject, with discussions held between Region IV and CPNPP personnel.

Prior to this issue and resolution, CPNPP Unit 2 had completed the final refueling outage of the second inspection period (2RF12 in April 2011) using this alternative testing method. Therefore, authorization to use the alternative testing method for Unit 2 had not been requested as was the similar case for Unit 1.

Thus, no previous Unit 2 request for relief was submitted. Request for relief C-3 was then submitted for the third and final inspection period for the subject alternative test method that requires approval by the NRC prior to use.

to TXX-14004 Page 2 of 2 COMANCHE PEAK NUCLEAR POWER PLANT UNIT 2 RESPONSE TO REQUEST FOR INFORMATION REGARDING RELIEF REQUEST C-3 FOR THE REACTOR PRESSURE VESSEL LEAK-OFF FLANGE (SECOND 10-YEAR ISI INTERVAL START DATE: AUGUST 3,2004)

(TAC NO. MF297)

NRC Request 2 from Reference 2:

Could the subject piping be pressurized and inspected at the beginning of a refueling outage before removing the RPV head? Please discuss the hardship and potential personnel radiation exposure for performing the system leakage test in accordance with the ASME Code,Section XI, IWC-5220. The NRC staff notes that the licensee addressed this question in the Request for Additional Information response dated January 9, 2013 (ADAMS Accession No. ML130250339) for the CPNPP, Unit 1, as a supplement to the request for RR C-2 dated August 23, 2012 (ADAMS Accession No. ML12250A670). Please state if the licensee's response for CPNPP, Unit I be applicable to CPNPP, Unit 2?

Luminant Power Response to Request 2:

Yes, the licensee's response for CPNPP Unit 1 is applicable to CPNPP Unit 2 as well. Pressurizing the line externally with the head installed would cause the inner o-ring to be put in a condition opposite of the design function likely causing damage and the need for replacement. Therefore, the only time, other than an o-ring failure that the leak-off lines are fluid filled under any type of pressure is when the head is removed and the cavity is flooded.