ML031820444

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Draft Information Input Faxed on June 4, 2003 (50-446) Comanche Peak Unit 2 Relief Request A-9 to Inservice Inspection from 1996 Edition of ASME Code,Section XI, No Addenda
ML031820444
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 06/04/2003
From: Bhatty O
TXU Generation Co, LP
To: Jaffe D
NRC/NRR/DLPM
Gramm R, NRR/DLPM,415-1302
Shared Package
ML031830124 List:
References
Download: ML031820444 (16)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Properties (3EDE19B1.028: 14: 20520)

Re: Unit 2 Code Relief A-9 Creation Date: 6/4/03 12:08PM From: <obaidb@txu.com>

Created By: obaidb@txu.com Recipients nrc.gov owf4_po.OWFNDO DHJ (David Jaffe)

Post Office Route owf4Mpo.OWFNDO nrc.gov Files Size Date & Time MESSAGE 948 06/04/03 12:08PM RPV Studs and Nuts.pdf 151140 RPV Studs and Nuts.doc 100864 Mime.822 347514 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard

David Jffe - Re: Unit 2 Code Relief A-9 Page'e From: <obaidb~txu.com>

To: <DHJ@nrc.gov>

Date: 614/03 12:09PM

Subject:

Re: Unit 2 Code Relief A-9 Ok I separated them and hi-lighted the new changes.....

Please just let me know when you get via e-mail (See attached file: RPV Studs and Nuts.pdf)(See attached file: RPV Studs and Nuts.doc)

Thanks.

Obaid Bhatty obaidb~txu.com (254) 897-5839 Confidentiality Notice: This email message, including any attachments, contains or may contain confidential information intended only for the addressee. If you are not an intended recipient of this message, be advised that any reading, dissemination, forwarding, printing, copying or other use of this message or its attachments is strictly prohibited.

If you have received this message in error, please notify the sender immediately by reply message and delete this email message and any attachments from your system.

-.. Deleted: 03048 IThX-4x- . -...

Page 2 of 2 Ref: 10 CFR 50.55a(a)(gX4)(iv)

CPSES-,200300XXX [Deieted: 2003057 ]

I Log# TXX- 3_XXX-_.. -- - Deleted: 304szi l JuneXX,2003 -- Deleted: M.fh 6 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-446 RELIEF REQUEST A-9 TO THE UNIT 2 INSERVICE INSPECTION (ISI) FROM 1986 EDITION OF ASME CODE, SECTION XI, NO ADDENDA (SECOND INTERVAL START DATE: AUGUST 2003)

Pursuant to 10 CFR 50.55a(aXgX4)(iv), TXU Generation Company LP (TXU Energy) hereby requests NRC approval of the enclosed relief request (A-9) for second ten-year inservice inspection interval for Unit 2. Relief is requested from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, 1986 Edition with no Addenda, Table IWB-2500- 1, Category B-G-I., - Deleted: (seettachmens for Odails) and I TXU Energy requests approval of this relief request by August of 2003. The approval I invdoes Code CaseN-307-3 (aclosureN).

date was selected to allow for NRC review and approval prior to the fall refueling outage.

I, . Deleted: Plese note dua TXU Eney I will be aubmitting the hservice btspection Plan in August 2003, committing o dhe American Society of Mechanical Eineers (ASME) Boiler and Pressure Vessel Code, 1998 Edition thru the 2002 AddendLa

-Sectione Break (Neat Page)-

I rxx-OPx ........ - - Deleted: 0304s Page 3 of 2 This communication contains no new licensing basis commitments regarding CPSES.

If you have any questions regarding this request, please contact orObaid Bhaty at - Comment:

C.. PRAffairs you need toput (254) 897-5839. ux_ ho.

Deleted: Douglas W. Snow e (254) 3974448 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:

Roger D. Walker Regulatory Affairs Manager IPAB/dws - Deleted: DWS Attachment I,v . . -.-. -.... . .. - - .. - Deleted: Enclos}ure c- E. W. Merschoff, Region IV W. D. Johnson, Region IV D. H. Jaffe, NRR Resident Inspectors, CPSES Terry Parks, Chief Inspector, TDLR J.C. Hair ANII, CPSES

Enclosure I to TXX-03048 Page I of 2 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-9 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA I PURSUANT TO 10 CFR5.55a(g)(4Xiv), . Dekted: AND INVOKING CODE I CASE N-M-A L. System/Comnonent for Which Relief is Requested:

ASME Class I Reactor Pressure Vessel (RPV) Closure Head Nuts and Studs. The subject items are depicted as TBX-I-1400-37 through 54 in the Comanche Peak Steam Electric Station Unit I ISI Program Plan.

11. Applicable Code Edition and Addenda:

ASME Section Xl, "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-I for the following:

I) Table IWB-2500-1 requires that the examinations include both a surface and [emphasis added]

volumetric method when the studs are removed.

2) Exam Figure IWB-2500-12 for Item No. B6.30 requires that the examination volume be defined as the full volume of the load-bearing portion of the studs.
3) Table IWB-2500-1 for Item No. B6.10 requires a surface examination for closure head nuts.

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

TXU Energy proposes to use 1998 Edition, 1999 Addenda and 2000 Addenda of the ASME Section XI 4- - Formatted: Body Text ndent, No wkiw/orphan axntrok Tabs: Not at Table IWB-2500-1 for category B-G-1, Item No. B6.30, Closure Studs when removed. Additionally, -58.S4ptP+ 368pt + 72 pt1+ 108 pt TXU Energy proposes to use 1998 Edition, 1999 Addenda and 2000 Addenda of the ASME Section XI + 144pt+ l8Opt+ 198pt+ 234 Table [WB-2500-1 for category B-G-1, Item No. B6.10, Closure Head Nuts. Additionali, -rXU Energy pt + 288 pt will comply with the corresponding Items tor Category B-G-I (i.e., B6.10, B6.30. B6.40. B6.50). Formatted: Hlgbflght Except Item B6.20 "Closure Studs, in place", because ,jt is C'PSES practice to examine the RPV Closure Ddleted:l XJ Studs, when removed. and not in place.

Enclosure I to TXX-03048 Page 2 of 2 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-9 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA I PURSUANT TO 10 CFR S0.55a(g)(4)(iv), - *Deleted: AND INVOKING CODE CASE N-307-3 (Continued)

Items 1) & 2): ,Table IWB-2500-1 in the 2000 Addenda of the ASME Code Section XI for Item B6.30 Deleted:

,pecifies that a volumetric or [emphasis added]surface examination be performed when Formatted: ent Le 36 pt, the RPV studs are removed. TXU E:nergy will c perronning Volumetric x ination Hanging: 81 Pt of the removed RPV studs as described in the 2000 Addenda of the ASME Code., Deleted:

.Deleted: Additio~nally. Code Came N4-307-3 firther reduces the Item 3): Table IWB-2500-1 in the 2000 Addenda of the ASME Code Section Xl specifies that a amnontionuirnofSectwn visual, VT-1 examination be performed for Item B6. IO(Reactor Vessel Closure Head FigureIWBM-250- Iten1B6.30.

Nuts). TXU Energy is proposing to use the examination requirements from Table IWB- codCnieni volumeete to ofa 2500-1 in the 2000 Addenda of the ASME Code Section Xl for Item B6.10 . volumetric cylinder, 114deep fonm the

  • tor*cdOithtreals TM Emu ist Irposingto use the Code Case N-307-3 and the carnination requirements from Table IWB-2500-1 in V. Basis of Usine Subseauent Code Editions and Addenda and Code Case: the 200DAddenda ofitheASME Code Sectian xl for ItemB6.30.

The 1998 Edition, 1999 Addenda and 2000 addenda of the ASME Section XI allows the method of Formatted- Went: Left: 36 pt examination oronosed by TXU Energy. The NRC staff incorporated these changes by reference in 10 Hanging: 81 pt, Tabs: Not at 108 pt CFR 50.55a(b). The changes to Table IWB-2500-1 examination criteria do not affect other parts of the Code. Additionally, the volumetric examinations will be performed with procedures and personnel qualified in accordance with ASME Section Xl, Appendix Vill as required by 10 CFR 50.55a(gX6XiiXC). Therefore, the proposed change will result in an acceptable level of quality and safety.

Deleted: I With respe ttothe utilization ofCode In lieu of the examination requirements of AS-ME Section Xl 1986 Edition, Figure IWB-2500-12, Item Cm N-307-3. portions of dteCode Case B6.30. The 2000 Addenda of ASMIF Section Nlreduces the examination egion to that of a volumetric [as identified in revision 21have been incorporaSed inthe 2000 Addenda ofdhe cylinder 114" deep from the root of the threads. The root of the threads are stress risers and preferred ASME Code Section XI The 2000 sites for crack initiation. Cracks at the root of the threads would be perpendicular to straight beam UT Addenda of dheCode reduces the required volume depicted in the 1916 Edition. I performed from the stud ends, and the cracks would create a corner trap for angle beam UT Deleted: ¶ examinations performed from a center hole in the stud. The capabilities of a UT examination finding CodeCaseN-307-3 cracks in a stud are demonstrated through procedure and personnel qualifications. These are Deleted: volume performance-based qualifications according to the requirements of Section Xl, Appendix Vill, Supplement 8.

Enclosure I to TXX-03048 Page 3 of 2 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-9 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA PURSUANT TO 10 CFR 50.55a(g)(4Xiv)

(Continued) [1111111111 leeed:

CAS ANDINVOCINGCODE Additionally, the examination requirements of the 2000 addenda of ASME Section Xl, Table IWB-2500-1, Item B6.30,,eliminates surface examination of the RPV closure stud when removed. The Deleted: Code CeN-307-3 function of UT examination is to find cracks in the stud volume. These cracks, if they exist, initiate from the surface. The function of the surface examination is to find cracks on the surface. Performing both volumetric and surface examinations on a stud duplicates the intent of the examinations which is to find cracks. Ofthe two nondestructive examination methods, surface examinations are tedious and subjective, and performance-based UT provides demonstrated assurances for finding cracks.

Therefore, elimination of the surface examination does not diminish the effectiveness in detecting cracks.

For Item 3 the 1998 Edition, 1999 Addenda and 2000 addenda of the ASME Section XI allows the use of a Visual, VT-I in lieu of a surface examination. Therefore, the proposed change will result in an acceptable level of quality and safety.

t should be noted that this is the third period of the C13SES Unit 2, First interval. Additionally, this is - {Formatted: HOW g the last outage of the first interval. CP§SES inservice program is in accordance with inspection program B (IWA-2432), only I8 RPV Closure Nuts. Closure Studs, Closure Washers, Bushings and Threads are left to do during this upcoming refueling outage. Moreover. it is CPSES practice to examine the RPV Closure Studs, when removed. and not in place. Therefore, Examination Category B-G-1. Item B6.20 "Closure Studs. in place" does not apply.

T-~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Deleted:

Vl. Duration of Pronosed Alternative:

TXU Energy requests approval of this relief request by August of 2003. The approval date was selected to allow for NRC review and approval prior to the fall refueling outage.

VII. Similar Precedents:

1. Letter from NRC to Vogtle Electric Generating Plant dated February 20, 2002 (TAC No. MB3242 and MB3243)
2. Letter from NRC to Edwin I. Hatch Plant dated July 2, 2002 (TAC No. MB3060 and MB3061) l ...-- _._ -......-_.._......__.

............. Brea e .V - _ _

01-540 '-h'Ovti6; ds -and Nuts.doc SPage 1I Ref: 10 CFR 50.55a(a)(g)(4)(iv)

CPSES-200300XXX Log # TXX-03XXX June XX, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-446 RELIEF REQUEST A-9 TO THE UNIT 2 INSERVICE INSPECTION (ISI) FROM 1986 EDITION OF ASME CODE, SECTION XI, NO ADDENDA (SECOND INTERVAL START DATE: AUGUST 2003)

Pursuant to 10 CFR 50.55a(a)(g)(4)(iv), TXU Generation Company LP (TXU Energy) hereby requests NRC approval of the enclosed relief request (A-9) for second ten-year inservice inspection interval for Unit 2. Relief is requested from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, 1986 Edition with no Addenda, Table IWB-2500-1, Category B-G-1.

TXU Energy requests approval of this relief request by August of 2003. The approval date was selected to allow for NRC review and approval prior to the fall refueling outage.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

9 David Jaffe - RPV Studs and Nuts.doc Page 221 Page ]

I!David Jdffe RPV Studs and Nuts.doc TXX-03xxx Page 2 of 2 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Caliaway . Comanche Peak

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

[,".

ba--Vidjifte-- RPV'Studs"and'NuAs'-.do'c Page Page 31 3

David Jffe - RPV Studs and Nuts.doc TXX-03xxx Page 3 of 2 This communication contains no new licensing basis commitments regarding CPSES.

If you have any questions regarding this request, please contact or Obaid Bhatty at (254) 897-5839.

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:

Roger D. Walker Regulatory Affairs Manager OAB/dws Attachment C- E. W. Merschoff, Region IV W. D. Johnson, Region IV D. H. Jaffe, NRR Resident Inspectors, CPSES Terry Parks, Chief Inspector, TDLR J.C. Hair ANII, CPSE3S A member of the STARS (Strategic Teaming and Resource Sharing) AJllance Callaway e Comanche Peak a Diablo Caniyon

  • Palo Verde
  • Wolf Creek

~avid Jaffe - RPV Studs and Nuts.doc Page 4 Attachment I to TXX-03048 Page 4 of 3 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-9 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 I Reactor Pressure Vessel (RPV) Closure Head Nuts and Studs. The subject items are depicted as TBX-1-1400-37 through 54 in the Comanche Peak Steam Electric Station Unit I ISI Program Plan.

H. 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-I, 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:

I) Table 1WB-2500-1 requires that the examinations include both a surface and

[emphasis added] volumetric method when the studs are removed.

2) Exam Figure IWB-2500-12 for Item No. B6.30 requires that the examination volume be defined as the full volume of the load-bearing portion of the studs.
3) Table IWB-2500-1 for Item No. B6. 10 requires a surface examination for closure head nuts.

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

TXU Energy proposes to use 1998 Edition, 1999 Addenda and 2000 Addenda of the ASME Section XI Table IWB-2500-1 for category B-G-1, Item No. B6.30, Closure Studs when removed. Additionally, TXU Energy proposes to use 1998 Edition, 1999 Addenda and 2000 Addenda of the ASME Section XI Table IWB-2500-1 for category B-G-1, Item No. B6.10, Closure Head Nuts. Additionally, TXU Energy will comply with the corresponding Items for Category B-G-I (i.e., B6.10, B6.30, B6.40, B6.50). Except Item B6.20 "Closure Studs, in place", because, it is CPSES practice to examine the RPV Closure Studs, when removed, and not in place.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Page 6]

David -

. ... ..Studs JOte - RPV David Jffe and Nuts.doc and1.Nuts.doc I -- l-I Page 612 Attachment 1 to TXX-03048 Page 6 of 3 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Woll Creek

David Jafle - RPV Studs and Nuts.doc Page 7 Attachment 1 to TXX-03048 Page 7 of 3 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 2 SECOND TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. A-9 PROPOSED USE OF SUBSEQUENT ASME CODE EDITION AND ADDENDA PURSUANT TO 10 CFR 50.55a(g)(4)(iv)

(Continued)

Additionally, the examination requirements of the 2000 addenda of ASME Section XI, Table IWB-2500-1, Item B6.30, eliminates surface examination of the RPV closure stud when removed. The function of UT examination is to find cracks in the stud volume.

These cracks, if they exist, initiate from the surface. The function of the surface examination is to find cracks on the surface. Performing both volumetric and surface examinations on a stud duplicates the intent of the examinations which is to find cracks.

Of the two nondestructive examination methods, surface examinations are tedious and subjective, and performance-based UT provides demonstrated assurances for finding cracks.

Therefore, elimination of the surface examination does not diminish the effectiveness in detecting cracks.

For Item 3 the 1998 Edition, 1999 Addenda and 2000 addenda of the ASME Section XI allows the use of a Visual, VT-1 in lieu of a surface examination. Therefore, the proposed change will result in an acceptable level of quality and safety.

It should be noted that this is the third period of the CPSES Unit 2, first interval.

Additionally, this is the last outage of the first interval. CPSES inservice program is in accordance with inspection program B (IWA-2432), only 18 RPV Closure Nuts, Closure Studs, Closure Washers, Bushings and Threads are left to do during this upcoming refueling outage. Moreover, it is CPSES practice to examine the RPV Closure Studs, when removed, and not in place. Therefore, Examination Category B-G-1, Item B6.20 "Closure Studs, in place" does not apply.

VI. Duration of Proposed Alternative:

TXU Energy requests approval of this relief request by August of 2003. The approval date was selected to allow for NRC review and approval prior to the fall refueling outage.

1. Similar Precedents:

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek
0 sI~

[ bav'id Jdffe'- ROV studs and Nu'ts'.doc Page Page a...l..

81 Studs David - and Nuts~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~doc JiffeRPV ... -,

Attachment I to TXX-03048 Page 8 of 3

1. Letter from NRC to Vogtle Electric Generating Plant dated February 20, 2002 (TAC No. MB3242 and MB3243)
2. Letter from NRC to Edwin L Hatch Plant dated July 2, 2002 (TAC No. MB3060 and MB3061)

A member of the STARS (strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

[ David Jaffe - RPV Studs and XNuts.doc Pagie 99.}I Pacie

[David Jafte RPV Studs and Nuts.doc Enclosure I to TXX-03048 Page 9 of 2 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

t DavidJaffe - RPV Studs and Nuts.doc page 10 Enclosure I to TXX-03048 Page 10 of 2 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek
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