CP-201000157, Response to Request for Additional Information Regarding Request for Delaying the Code of Record Inservice Inspection Program
| ML100570066 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/18/2010 |
| From: | Flores R Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-201000157, TAC ME1703, TXX-10020 | |
| Download: ML100570066 (4) | |
Text
u Luminaont Rafael Flares Senior Vice President
& Chief Nuclear Officer rafael.flores @ urnina nt.com Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201000157 Log # TXX-10020 Ref. #
10 CFR 50.55a February 18, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NO. 50-445 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR DELAYING THE CODE OF RECORD FOR UNIT 1 INSERVICE INSPECTION PROGRAM (TAC NO. ME1703)
REFERENCES:
- 1. Letter logged TXX-09081 dated July 8, 2009, from Rafael Flores of Luminant Power to the NRC submitting Request to Delay the Code of Record for the Unit 1 Inservice Inspection Program
- 2.
Letter dated January 29, 2010, from Balwant Singal of NRR to Rafael Flores.
Dear Sir or Madam:
Per Reference 1, Luminant Generation Company LLC (Luminant Power) requested 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.
On January 29, 2010, the NRC provided Luminant Power with a request for additional information (RAI) via Reference 2. The NRC requested response to the January 29, 2010 letter within 30 days of the date of the letter. The attachment provides the responses to the RAIs.
This communication contains the following revised licensing basis commitments which will be completed or incorporated into the Comanche Peak licensing basis as noted:
Number Commitment Due Date 3891111 Luminant Power will revise its current procedures to prohibit the use of August 13, 2010 paragraph IWA-4340 until the next code of record update for Unit 1.
3891114 Luminant Power will revise its current procedures to invoke the use of August 13, 2010 paragraph IWA-4540(c) until the next code of record update for Unit 1.,
I A member of the STARS (Strategic Teaming and Resource Sharing) Alliance A O(ý7 Callaway
- Comanche Peak
- Diablo Canyon Palo Verde
- San Onofre South Texas Project - Wolf Creek f4
U. S. Nuclear Regulatory Commission TXX-10020 Page 2 02/18/2010 Should you have any questions, please contact Mr. Jack Hicks at (254)897-6725.
Sincerely, Luminant Generation Company LLC Rafael Flores By: &j 2<27QA=
Fred W. Madden Director, Oversight & Regulatory Affairs Attachment -
Luminant Power Response to NRC Request for Additional Information c -
E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Anthony Jones,TDLR Brian Welch, ANIL, Comanche Peak
ATTACHMENT TO TXX-10020 Response to NRC Request for Additional Information
Attachment to TXX-10020 Page 2 of 2
- 1.
NRC QUESTION The ASME Code,Section XI, 1998 Edition through the 2000 Addenda, allows the use of IWA-4340, Mitigation of Defects by Modification, but the NRC staff has concerns about some of the provisions of this paragraph. If the Code of record were updated at the frequency intended by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, the use of this paragraph would not be permitted. If the request to delay the Code of record is authorized, does the licensee intend to use the provisions of IWA-4340? If the licensee intends to use the provisions of IWA-4340, please provide justification for its use and discuss whether the staffs concerns, documented in the proposed rule for amending 10 CFR 50.55a, code and standards (ADAMS Accession No. ML031740349), is valid.
LUMINANT POWER RESPONSE The original Code of Record update for the Unit 1 Inservice Inspection (ISI) Program would have been required by August 14, 2010. Luminant Power will revise its procedures by August 14, 2010, to prohibit the use of paragraph IWA-4340 until the next Code of Record update for Unit 1. The next Code of Record update for Unit 1 will be completed by August 3, 2014.
- 2.
NRC QUESTION The requirements to pressure test Class 1, 2, and 3 mechanical joints undergoing repair and replacement activities were deleted in the 1999 Addenda of the ASME Code Section XI.
Therefore, pressure testing of mechanical joints is not required by Section XI, when performing IWA-4000 repair and replacement activities and when using the 2000 Addenda of Section XI, but would be required if the Code of record were updated at the frequency intended by 10 CFR 50.55a(b)(xxvi). If the request to delay the Code of record is authorized, does the licensee intend to perform pressure testing of mechanical joints in accordance with the requirements of IWA-4540(c) of the 1998 Edition of Section XI? If pressure testing of mechanical joints will not be performed, please provide justification, and discuss how the public health and safety will be adequately protected.
LUMINANT POWER RESPONSE The original Code of Record update for the Unit 1 Inservice Inspection (ISI) Program would have been required by August 14, 2010. Luminant Power will revise its procedures by August 14, 2010, to invoke the use of paragraph IWA-4540(c) of the 1998 Edition of the ASME Code,Section XI, until the next Code of Record update for Unit 1. The next Code of Record update for Unit 1 will be completed by August 3, 2014.