CP-200900846, (Cpes) - Request to Delay the Code of Record for the Unit 1 Inservice Inspection (ISI) Program

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(Cpes) - Request to Delay the Code of Record for the Unit 1 Inservice Inspection (ISI) Program
ML092030380
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/14/2009
From: Flores R
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-200900846, TXX-09081
Download: ML092030380 (2)


Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael~flores@Luminant.com Glen Rose, TX 76043 Luminant 24965 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-200900846 Ref. #

10 CFR 50.55a(g)

Log # TXX-09081 July 14, 2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 REQUEST TO DELAY THE CODE OF RECORD FOR THE UNIT 1 INSERVICE INSPECTION (ISI) PROGRAM 1998 EDITION OF ASME CODE, SECTION XI, 2000 ADDENDA UNIT 1 INTERVAL DATES: AUGUST 13,2000 - AUGUST 12, 2010 UNIT 2 INTERVAL DATES: AUGUST 3,2004 - AUGUST 2,2014

REFERENCES:

1. Luminant Power letter, logged TXX-00041, from C. L. Terry to the U. S. Nuclear Regulatory Commission (NRC), dated February 24, 2000.
2. NRC Letter from David H. Jaffee to C. L. Terry, dated June 29, 2000 (TAC NO.

MA8310)

Dear Sir or Madam:

Luminant Generation Company LLC (Luminant Power) requests to delay the update of the Code of Record (1998 Edition of ASME Code,Section XI, 2000 Addenda) for the Unit 1 Inservice Inspection (ISI)

Program until the time of the required update for Unit 2. The third ten-year ISI interval for Unit 1 starts August 13, 2010. The code update for the third ten-year ISI interval for Unit 2 starts August 3, 2014.

Luminant Power had previously requested to delay the update of the Code of Record for the second interval of the Unit 1 ISI Program until the time of the required update for Unit 2 via Reference 1. This request was approved by the NRC via Reference 2.

In the interim prior to the required code update of Unit 2, Unit 1 will continue with its ISI in accordance with the requirements of the code edition of the second interval and will be subject to any additional ISI related requirements that may be mandated by subsequent rulemaking. Having both units on the same Code of Record provides many implementation benefits which will maintain or enhance the existing level of quality and safety and provides cohesive programs for ISI, Repairs/Replacements and Pressure Testing. Having two separate ASME Code years implemented on a two unit station can create procedural and programmatic differences that could potentially increase the likelihood of implementation errors.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance j y0l47 Callaway Comanche Peak

  • Diablo Canyon
  • Palo Verde - San Onofre South Texas Project - Wolf Creek

U. S. Nuclear Regulatory Commission TXX-09081 Page 2 07/14/2009 The Unit 1 ISI inspections will continue with a 10-year program plan for the third interval that references the same Code of Record used for the second interval (1998 Edition of ASME Code,Section XI, 2000 Addenda). All required piping and components will be selected, scheduled and examined in accordance with these Code requirements. At the time of the required Unit 2 Code update, the Unit 1 Program Plan will be revised to implement the updated Code of Record for the remainder of the Unit 1 third inspection interval, which is expected to include the second and third inspection periods in their entirety (approximately seven years).

This communication contains no new licensing basis commitments regarding Comanche Peak Units 1 and 2.

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

Sincerely, Luminant Generation Company LLC Rafael Flores By:

Fred W. Madden Director, Oversight & Regulatory Affairs c -

E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak A. Jones, TDLR Brian Welch ANII, Comanche Peak