ML14030A466

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NRR E-mail Capture - Follow-up Request for Additional Information for Relief Request C-3 - TAC MF2997
ML14030A466
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 01/30/2014
From: Balwant Singal
Division of Operating Reactor Licensing
To: Hope T
Luminant Generation Co
References
MF2997
Download: ML14030A466 (3)


Text

NRR-PMDAPEm Resource From: Singal, Balwant Sent: Thursday, January 30, 2014 8:35 AM To: 'Hope, Timothy' (Timothy.Hope@luminant.com)

Cc: Seawright, Jimmy (Jimmy.Seawright@luminant.com); 'Jack.Hicks@luminant.com' (Jack.Hicks@luminant.com)

Subject:

Follow-up Request for Additional Information for Relief Request C TAC MF2997 Attachments: MF2997-Followup-RAI.docx

Tim, Attached is the follow-up Request for Additional Information (RAI) for the subject Relief Request (RR). This request was discussed between your and NRC staff on January 28, 2014. Since Luminant Generation Company LLC (Luminant) has requested for an expedited review, it was agreed that Luminant will respond to this request as soon as possible, but no later than 30 days from the date of this e-mail. Please treat this e-mail as formal transmittal of the RAI.

Please advise if you have any questions.

Thanking you.

Balwant K. Singal Senior Project Manager (Comanche Peak and STP)

Nuclear Regulatory Commission Division of Operating Reactor Licensing Balwant.Singal@nrc.gov Tel: (301) 415-3016 Fax: (301) 415-1222 1

Hearing Identifier: NRR_PMDA Email Number: 1049 Mail Envelope Properties (Balwant.Singal@nrc.gov20140130083500)

Subject:

Follow-up Request for Additional Information for Relief Request C TAC MF2997 Sent Date: 1/30/2014 8:35:01 AM Received Date: 1/30/2014 8:35:00 AM From: Singal, Balwant Created By: Balwant.Singal@nrc.gov Recipients:

"Seawright, Jimmy (Jimmy.Seawright@luminant.com)" <Jimmy.Seawright@luminant.com>

Tracking Status: None

"'Jack.Hicks@luminant.com' (Jack.Hicks@luminant.com)" <Jack.Hicks@luminant.com>

Tracking Status: None

"'Hope, Timothy' (Timothy.Hope@luminant.com)" <Timothy.Hope@luminant.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 791 1/30/2014 8:35:00 AM MF2997-Followup-RAI.docx 22397 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST C-3 LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT 2 DOCKET NO. 50-446 By letter dated October 31, 2013 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML13312A121), Luminant Generation Company LLC (Luminant, the licensee) submitted for the U.S. Nuclear Regulatory Commission (NRC) approval relief request (RR) C-3. The licensee proposed an alternative to a certain requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI.

RR C-3 relates to the inservice inspection (ISI) requirement of IWC-5220 of the ASME Code,Section XI, for the system leakage test of the reactor pressure vessel (RPV) flange leak-off piping. The licensee submitted the request for the Comanche Peak Nuclear Power Plant (CPNPP), Unit 2.

The NRC staff requests the following additional follow-up information.

1. Section 5 Burden Caused by Compliance and Section 6 Proposed Alternative and Basis for Use of Attachment 1 of RR C-3 stated, in part, Therefore, compliance with the IWC-5220 system leakage test requirements results in an unnecessary hardship without a sufficient compensating increase in the level of quality and safety.

In lieu of the requirements of IWC-5220, a VT-2 visual examination of the accessible areas will be performed each period on the piping subjected to the static pressure head when the reactor cavity is filled. This test will be part of the reactor coolant Class 2 leakage test.

The NRC staff notes that the ASME Code,Section XI, IWC-5220 System Leakage Testing includes two sub-articles, IWC-5221 Pressure and IWC-5222 Boundaries.

(a) Please clarify whether the proposed system leakage test was submitted as an alternative to address only the pressure requirement as specified in IWC-5221. (b) IWC-5222(a) and (b) require specific pressure boundaries for the system pressure tests. The NRC staff notes that the licensees submittal did not address the requirements of IWC-5222(a) and (b). If IWC-5222(a) and IWC-5222 (b) are also the subject of this RR, please discuss the hardship caused by compliance with IWC-5222(a) and IWC-5222(b),

and provide corresponding alternatives.

2. Please discuss leakage detection capabilities at the plant, and or any measure(s) taken, to monitor and identify leakage in an unlikely event of a through wall leak in the RPV flange seal leak-off line piping concurrent with leak or failure of the RPV flange inner seal during normal operation.