CP-200901349, Supplemental Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spay Systems
| ML092650236 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/21/2009 |
| From: | Flores R, Madden F Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-200901349, GL-08-001, TAC MD7813, TAC MD7814, TXX-09118 | |
| Download: ML092650236 (3) | |
Text
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 CP-200901349 Ref. # 10 CFR 50.54(f)
Log # TXX-09118 September 21, 2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION, DOCKET NOS. 50-445 AND 50-446, SUPPLEMENTAL RESPONSE TO NRC GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS (TAC NOS. MD7813 AND MD7814)
REFERENCE:
- 1. NRC Generic Letter 2008-01 Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems dated January 11, 2008 (ML072910759)
- 2. Luminant Power letter, Logged TXX-08120, from Mike Blevins to the Nuclear Regulatory Commission dated October 14, 2008 (Nine Month Response)
- 3. Luminant Power letter, Logged TXX-08138, from Mike Blevins to the Nuclear Regulatory Commission dated November 11, 2008 (Supplemental Response)
Dear Sir or Madam:
The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1) to request that each licensee evaluate the licensing basis, design, testing, and corrective action programs for the Emergency Core Cooling System (ECCS), Residual Heat Removal (RHR) system, and Containment Spray System (CSS), to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified. Reference 2 provided the Luminant Generation Company, LLC (Luminant Power) nine-month response to NRC GL 2008-01 and Reference 3 reported the completion of confirmatory testing.
Section B2 of the Attachment to Reference 2 indicated the following (Commitment Number 3618664):
As a result of the GL 2008-01 evaluation, a new Gas Intrusion Program is required to be developed. The program will include as a minimum:
Ultrasonic Testing (UT) of selected system and local high points after unit refueling outages to confirm that the systems are full of water.
Condition based evaluation process that is initiated upon the occurrence of any event identified as a potential source for gas intrusion, including UT examinations and continued frequency requirements.
Rafael Flores Senior Vice President
& Chief Nuclear Officer rafael.flores@luminant.com Luminant Power P O Box 1002 6322 North FM 56 Glen Rose, TX 76043 T
C F
254 897 5590 817 559 0403 254 897 6652
U. S. Nuclear Regulatory Commission TXX-09118 Page 2 09/21/2009 Engineering evaluation of work orders identified to contain a breech of an ECCS, RHR, or CSS piping system.
Addition of a Design Impact in the design control program for any piping configuration change to ECCS, RHR, or CSS system.
Providing additional training for Operations, Maintenance, and Engineering on gas intrusion potential.
Schedule/Basis for Schedule:
The Gas Intrusion Program will be developed by October 11, 2009. Comanche Peak has not historically had issues with gas accumulation in these systems. The evaluation supporting this response has indicated that the existing process is adequate.
The commitment number is used by Luminant Power for the internal tracking of Comanche Peak commitments.
Luminant Power is revising the schedule for formal implementation of the Gas Intrusion Program (commitment number 3618664) from October 11, 2009 to March 31, 2010. This was discussed on a phone call between the NRC Staff (Balwant Singal, et. al.) and Luminant Power (Carl Corbin, et. al.) on September 21, 2009.
Comanche Peak has been working with the Nuclear Energy Institute (NEI Gas Accumulation Team) to develop a generic gas intrusion program. Theses efforts are ongoing and will not be completed by October 11, 2009. Revising the implementation date allows Comanche Peak to complete the efforts supporting the generic program and gain the benefit of industry input. As noted in Reference 2, the practice of Ultrasonic Testing (UT) of selected system and local high points after unit refueling outages to confirm that the systems are full of water has been implemented. Potential gas intrusion mechanisms are entered in the corrective action program for evaluation.
During the conversations on September 21, 2009, Luminant Power understands that a request for additional information will be forwarded to Luminant Power in the near future. The ultrasonic testing and corrective action program efforts will be described in more detail in the response to the request for additional information.
The corrective action (commitment number 3618672 from Reference 2) to install vent valves and pressure gauges prior to startup from the refueling outage in the fall of 2009 (Unit 2) and the refueling outage in the spring of 2010 (Unit 1) remains on schedule. Procedure OPT-521A/B, Operations Testing Manual/ECCS Operability, was revised to clarify that performance of the procedure is an integral part of dynamic fill for the ECCS systems and was credited as part of the GL 2008-01 response (commitment number 3618694 from Reference 2).
This communication contains no new licensing basis commitments regarding Comanche Peak Units 1 and 2.
The conclusions provided in Reference 2, that subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance, remain unchanged.
U. S. Nuclear Regulatory Commission TXX-09118 Page 3 09/21/2009 I state under penalty of perjury that the foregoing is true and correct.
Executed on September 21, 2009.
Should you have any questions, please contact Mr. Carl Corbin at (254) 897-0121.
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