CPSES-200203451, Relief Requests A-5 Rev 2 to the Unit 1 Inservice Inspection (ISI) from 1986 Edition of ASME Code, Section XI, No Addenda (Interval Start Date: August 13, 2000, Second Interval)

Relief Requests A-5 Rev 2 to the Unit 1 Inservice Inspection (ISI) from 1986 Edition of ASME Code,Section XI, No Addenda (Interval Start Date: August 13, 2000, Second Interval)

ML022830345
Person / Time
Site:	Comanche Peak
Issue date:	10/01/2002
From:	Walker R TXU Energy, TXU Generation Co, LP
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CPSES-200203451, TXX-02175
Download: ML022830345 (5)

Text

t TXU TXU Energy C. Lance Terry Comanche Peak Steam Senior Vice President &

Principal Nuclear Officer Electric Station Ref: 10 CFR 50.55(a)(3)

PO Box 1002 (E01)

Glen Rose, TX 76043 Tel 254 897 8920 Fax 254 897 6652 lance terry@txu corn CPSES-200203451 Log # TXX-02175 File# 10010 October 1, 2002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445; RELIEF REQUESTS A-5 Rev 2 TO THE I UNIT 1 INSERVICE INSPECTION (ISI) FROM 1986 EDITION OF ASME CODE, SECTION XI, NO ADDENDA (INTERVAL START DATE: AUGUST 13, 2000, SECOND INTERVAL)

REF: 1) TXU Energy letter to the NRC dated July 18, 2002 logged TXX-02129

2) TXU Energy letter to the NRC dated September 24, 2002 logged TXX-02170

Dear Sir or Madam:

Pursuant to 10CFR50.55a, TXU Energy hereby requests NRC approval of the attached relief request. The relief from the ASME Code is being requested for the second interval of the inservice inspection program. The details of the 10CFR 50.55a request are enclosed.

Via reference 1 & 2, the relief requests (A-3, A-4, and A-5) proposed deferral of certain examinations (see attachments for details) until the end of the interval and to invoke Code Case N-307-3 for relief A-5. During telephone conference with your staff, TXU Energy requested to modify its relief requests. The modifications to Reference 1 were submitted in TXX-02170; however, during a telephone conference it was determined that a clarification was necessary for A-5 Rev 1.

The clarification is as follows:

A TXU TXX-02175 Page 2 of 2 For Relief Request A-5; Clarify Section IV as follows:

TXU Energy proposes to use 1995 Edition, 1996 Addenda of the ASME Section XI Table IWB-2500-1 for category B-G-1, B6.20, "Closure Studs, In Place", and B6.50, "Closure Washers, Bushing", and requests deferral of this inspection to the end of the interval as permitted.

Deferrals for scheduling purposes will be utilized, provided a 10-year maximum duration is not exceeded between examinations. A "re-zeroing" of examinations will be necessary if the 10-year maximum duration is exceeded between examinations.

This transmittal via its attachments submits relief request A-5 Rev. 2 for your review and approval by October 4, 2002.

This communication contains no new licensing basis commitments regarding Comanche Peak Steam Electric Station (CPSES) Unit 1.

If you have any questions or need additional information regarding this matter, please feel free to contact Obaid Bhatty at (254) 897-5839 or Douglas W. Snow at (254) 897-8448.

Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner C. L. Terry Senior Vice President and Principal Nuclear Officer By:

RBy oger . ,le Regulatory Affairs Manager OAB/dws Attachments

"A*TXU TXX-02175 Page 3 of 3 c- E. W. Merschoff, Region IV Resident Inspectors, CPSES W. D. Johnson, Region IV G. Bynog, TDLR D. H. Jaffe, NRR J. C. Hair ANII, CPSES to TXX-02175 Page 1 of 2 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-5 R-2 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA PURSUANT TO 10 CFR 50.55a(g)(4)(iv)

I. System/Component for Which Relief is Requested:

ASME Class 1 Reactor Pressure Vessel (RPV) Closure Head Nuts, Washers, and Studs. The subject items are depicted as TBX-1-1400-1 through 54 in the Comanche Peak Steam Electric Station Unit 1 ISI Program Plan.

II. Applicable Code Edition and Addenda:

ASME Section XI, "Rules for Inservice Inspection of Nuclear Power plant Components 1986 Edition, No addenda, Table IWB-2500-1 for category B-G-1, Reactor Vessel Parts.

III. Code Requirement from Which Relief is Requested:

TXU Energy requests relief from the 1986 Edition of the ASME Section XI Table IWB-2500-1, Category B-G-1 for the following:

1) Table IWB-2500-1 disallowing deferral for Items B6.20, "Closure Studs, In Place", and B6.50, "Closure Washers, Bushing".

IV. Proposed Subsequent Code Edition and Addenda and Code Case:

TXU Energy proposes to use 1995 Edition, 1996 Addenda of the ASME Section XI Table IWB-2500-1 for category B-G-1, B6.20, "Closure Studs, In Place", and B6.50, "Closure Washers, Bushing", and requests deferral of this inspection to the end of the interval as permitted.

Deferrals for scheduling purposes will be utilized, provided a 10-year maximum duration is not exceeded between examinations. A "re-zeroing" of examinations will be necessary if the 10-year maximum duration is exceeded between examinations.

V. Basis of Using Subsequent Code Editions and Addenda and Code Case:

The 1995 Edition, 1996 Addenda of the ASME Section XI allows the deferral of the aforementioned items to the end of the interval. The NRC staff incorporated these changes by reference in 10 CFR 50.55a(b). The changes to Table IWB-2500-1 examination criteria do not affect other parts of the Code.

Moreover, the change does not eliminate the examination or the required number of examinations; it only provides the option for consolidating the number of items examined at any one time. Additionally, the volumetric examinations will be performed with procedures and personnel qualified in accordance with ASME Section XI, Appendix VIII as required by 10 CFR 50.55a(g)(6)(ii)(C). Therefore, the proposed change will result in an acceptable level of quality and safety.

to TXX-02175 Page 2 of 2 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-5 R-2 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA PURSUANT TO 10 CFR 50.55a(g)(4)(iv)

(Continued)

VI. Duration of Proposed Alternative:

This relief is requested for the Comanche Peak Steam Electric Station Unit 1, second 10-year interval.