CP-201101442, Supplement to Relief Request C-9 for Alternative Pressure Testing Requirements for Reactor Vessel Flange Leak-Off Piping

Supplement to Relief Request C-9 for Alternative Pressure Testing Requirements for Reactor Vessel Flange Leak-Off Piping

ML11292A052
Person / Time
Site:	Comanche Peak
Issue date:	10/13/2011
From:	Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201101442, TXX-11128
Download: ML11292A052 (2)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Glen Rose, TX 76043 Lum inant rafael.flores@Luminant.com T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201101442 Ref. # 10 CFR 50.55a(a)(3)(ii)

Log # TXX-11128 October 13, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)

DOCKET NO. 50-445 SUPPLEMENT TO RELIEF REQUEST C-9 FOR ALTERNATIVE PRESSURE TESTING REQUIREMENTS FOR REACTOR VESSEL FLANGE LEAK-OFF PIPING REF: 1. Letter logged TXX-10156 dated December 15, 2010, from Rafael Flores to the NRC submitting Relief Request C-9 for the Unit 1 Second 10 Year ISI Interval From 10 CFR 50.55a Inspection Requirements Due to Hardship

2. Federal Register Notice dated May 4, 2010, 10CFR50 American Society of Mechanical Engineers (ASME) Codes and New and Revised ASME Code Cases; Proposed Rule (75FR 24324)

3. Conference call of 9/22/2011 with personnel from the Nuclear Regulatory Commission (NRC) Staff and personnel from CPNPP to discuss the status of Relief Request C-9

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(a)(3)(ii), Luminant Generation Company, LLC (Luminant Power) submitted Relief Request C-9 (Reference 1) for CPNPP regarding the Reactor Vessel Flange Leak-off piping on December 15, 2010. In the Federal Register notice, dated May 4, 2010, (Reference 2) the NRC recognized that the applicable 10CFR50.55a(a)(3) at the time of issuance of Relief Request C-9 did not clearly convey that proposed alternatives such as this must be submitted and authorized prior to implementation. During the phone call on September 22, 2011, (Reference 3) the NRC informed Luminant Power that CPNPP, like other Licensees, had improperly interpreted 50.55a(a)(3) to allow for obtaining NRC authorization of an alternative after its implementation.

NRC staff described the timing of the submittal as administrative in nature. NRC staff requested that CPNPP supplement the proposed Relief Request (Reference 1) describing the actual activities performed for alternative inspection and the results of those inspections.

The alternative examination of the reactor pressure vessel flange leak-off piping was performed as described in Reference I during refueling outage 1RF14, April 26, 2010, during the second interval, third period, second outage of Unit 1. Unit 1 was in Mode 6, the reactor vessel head was removed, A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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U. S. Nuclear Regulatory Commission TXX-11128 Page 2 of 2 10/13/2011 and the reactor cavity was filled. The associated ASME Code Class 2 piping system was subject to the static pressure head when the reactor cavity was filled. The accessible areas of the piping systems, identified by line numbers 3/4" RC-1-080, and 3/4" RC-1-081 up to valves 1-8076 and 1-8032 were VT-2 examined, with no evidence of leakage identified.

This communication contains no new licensing basis commitments regarding CPNPP Unit 1.

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

Sincerely, Luminant Generation Company LLC Rafael Flores By:

W. Madden Director, Oversight & Regulatory Affairs c - E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Jack Ballard, ANII, Comanche Peak Luis Ponce, TDLR