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MONTHYEARML12251A1222012-09-0707 September 2012 Acceptance Review E-mail - Relief Request C-2 for the Reactor Pressure Vessel Leak-Off Flange, Third 10-Year Inservice Inspection Interval Project stage: Acceptance Review ML12345A1882012-12-10010 December 2012 Request for Additional Information E-mail - Relief Request C-2 for the Reactor Pressure Vessel Leak-Off Flange, Third 10-Year Inservice Inspection Interval Project stage: RAI ML13025A2612013-01-0909 January 2013 Enclosure to TXX-13003 Drawings for Response to RAI Question 2 Project stage: Response to RAI CP-201300002, Response to Request for Additional Information for Unit 1 Relief Request No. C-22013-01-0909 January 2013 Response to Request for Additional Information for Unit 1 Relief Request No. C-2 Project stage: Response to RAI ML13046A3852013-03-19019 March 2013 Relief Request C-2 for the Reactor Pressure Vessel Flange Leak-Off Piping, Third 10-Year Inservice Inspection Interval Project stage: Other CP-201301199, Relief Request No. C-3 for the Unit 2 Reactor Pressure Vessel leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date: August 2, 20142013-10-31031 October 2013 Relief Request No. C-3 for the Unit 2 Reactor Pressure Vessel leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date: August 2, 2014 Project stage: Request ML13350A6302013-12-16016 December 2013 NRR E-mail Capture - Acceptance Review for Relief Request C-3 for Comanche Peak Unit 2, - TAC No. MF2997 Project stage: Acceptance Review ML14007A0002014-01-0303 January 2014 NRR E-mail Capture - Request for Additional Information (RAI) - Relief Request (RR) C-3 - TAC No. MF2997 Project stage: RAI CP-201400070, Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date August 2, 2014)2014-01-23023 January 2014 Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End Date August 2, 2014) Project stage: Response to RAI ML14030A4662014-01-30030 January 2014 NRR E-mail Capture - Follow-up Request for Additional Information for Relief Request C-3 - TAC MF2997 Project stage: RAI CP-201400144, Clarification to Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-Off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End.2014-02-11011 February 2014 Clarification to Response to Request for Additional Information for Relief Request No. C-3 for Unit 2 Reactor Pressure Vessel Leak-Off Flange (Second ISI Interval Start Date: August 3, 2004; Second ISI Interval End. Project stage: Supplement ML14084A2912014-04-0404 April 2014 Relief Request No. C-3 for Reactor Pressure Vessel Leak-Off Flange for the Second 10-Year Inservice Inspection Interval Project stage: Other CP-201500157, Relief Request No. 2C3-1 for the Reactor Pressure Vessel Leak-Off Flange (Third ISI Interval Start Date: August 3, 2014; Third ISI Interval End Date: August 2, 2023)2015-02-24024 February 2015 Relief Request No. 2C3-1 for the Reactor Pressure Vessel Leak-Off Flange (Third ISI Interval Start Date: August 3, 2014; Third ISI Interval End Date: August 2, 2023) Project stage: Request 2013-03-19
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Category:Letter
MONTHYEARCP-202400030, License Renewal Application Revision 0 - Supplement 3, Revision 12024-01-31031 January 2024 License Renewal Application Revision 0 - Supplement 3, Revision 1 IR 05000445/20230042024-01-29029 January 2024 Integrated Inspection Report 05000445/2023004 and 05000446/2023004 CP-202400034, (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1)2024-01-29029 January 2024 (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1) ML24024A2102024-01-29029 January 2024 Summary of Regulatory Audit Regarding a License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML24025A0052024-01-25025 January 2024 Review of the Spring 2023 Steam Generator Tube Inspection Report ML24023A0242024-01-24024 January 2024 Correction to Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident Methodology ML24018A1072024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information ML23159A2082023-12-20020 December 2023 Request for Withholding Information from Public Disclosure ML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23348A2392023-12-19019 December 2023 Nonacceptance of License Amendment Request to Relocate Technical Specification 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual CP-202300575, (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 22023-12-13013 December 2023 (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 2 ML23333A0872023-12-13013 December 2023 Transmittal of Dam Safety Inspection Report - Public CP-202300566, (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation2023-12-12012 December 2023 (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation CP-202300494, License Renewal Application Revision 0, Supplement 32023-12-0606 December 2023 License Renewal Application Revision 0, Supplement 3 ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23291A4382023-11-30030 November 2023 Notice of Availability of the Draft Plant-Specific Supplement 60, to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Comanche Peak Nuclear Power Plant, Unit Numbers 1 and 2, License Renewal Applica ML23325A0182023-11-30030 November 2023 Schedule Revision for the License Renewal Application Review IR 05000445/20234022023-11-30030 November 2023 NRC Security Inspection Report 05000445/2023402 and 05000446/2023402 CP-202300349, License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation2023-11-20020 November 2023 License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation ML23308A0032023-11-17017 November 2023 Letter to R. Nelson, Executive Director; Achp; Re., Comanche Peak Draft Environmental Impact Statement ML23308A0022023-11-17017 November 2023 Letter to M. Wolfe, Executive Director; Shpo; Re., Comanche Peak Draft Environmental Impact Statement ML23317A3002023-11-13013 November 2023 Letter to R. Sylestine, Chairman, Alabama-Coushatta Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2972023-11-13013 November 2023 Letter to R. Martin, President, Tonkawa Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2872023-11-13013 November 2023 Letter to J. Garza, Chairman, Kickapoo Traditional Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2832023-11-13013 November 2023 Letter to D. Dotson, President, Delaware Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2852023-11-13013 November 2023 Letter to E. Martinez, President, Mescalero Apache Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23306A0302023-11-13013 November 2023 Letter to J. Cernek, Chairman; Coushatta Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2902023-11-13013 November 2023 Letter to M. Pierite, Chairman, Tunica Biloxi Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2982023-11-13013 November 2023 Letter to R. Morrow, Town King, Thlopthlocco Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2842023-11-13013 November 2023 Letter to D. Kaskaske, Chairman, Kickapoo Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2822023-11-13013 November 2023 Letter to D. Cooper, Chairman, Apache Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2962023-11-13013 November 2023 Letter to M. Woommavovah, Chairman, Comanche Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2812023-11-13013 November 2023 Letter to C. Hoskin, Principal Chief, Cherokee Nation; Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2862023-11-13013 November 2023 Letter to J. Bunch, Chief, United Keetoowah Band of Cherokee Indians Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3032023-11-13013 November 2023 Letter to W. Yargee, Chief, Alabama-Quassarte Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2882023-11-13013 November 2023 Letter to L. Johnson, Chief, Seminole Nation of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3012023-11-13013 November 2023 Letter to S. Yahola, Mekko, Kialegee Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2792023-11-13013 November 2023 Letter to B. Gonzalez, Chairman, Caddo Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3022023-11-13013 November 2023 Letter to T. Parton, President, Wichita and Affiliated Tribes Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2892023-11-13013 November 2023 Letter to L. Spottedbird, Chairman, Kiowa Indian Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23360A6312023-10-26026 October 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the Comanche Peak Nuclear Power Plant Medical Services Drill Evaluated on August 23, 2023 CP-202300416, Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements2023-10-12012 October 2023 Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements CP-202300432, Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 42023-10-0404 October 2023 Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 4 ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23263A0242023-09-21021 September 2023 Revision of Schedule for the Environmental Review of the Comanche Peak Nuclear Power Plant Units 1 and 2 License Renewal Application 2024-01-31
[Table view] Category:Safety Evaluation
MONTHYEARML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23237B4282023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 2, Draft Conforming License Amendments ML23237B4302023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0000) (Public) ML23198A3212023-07-27027 July 2023 Authorization and Safety Evaluation for Proposed Alternative RV-1 ML22192A0072022-08-22022 August 2022 Issuance of Amendment Nos. 183 and 183 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-505, Revision 2 ML22194A0592022-07-14014 July 2022 Correction to Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML22129A0722022-05-16016 May 2022 Review of Quality Assurance Program Changes ML22077A8412022-03-24024 March 2022 Proposed Alternative SNB-3 for the Snubber Inservice Program Third Interval Extension ML21321A3492022-02-24024 February 2022 Issuance of Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Rev. 1, Revised Frequencies for Steam Generator Tube Inspections ML21322A1032021-12-0707 December 2021 Proposed Alternative for the Continued Use of a Risk-Informed Process for the Selection of Class 1 and 2 Piping Welds for Inservice Inspection ML21132A0892021-06-0909 June 2021 Issuance of Amendment Nos. 181 and 181 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-567, Rev. 1, Add Containment Sump TS to Address GSI - 191 Issues ML21061A2172021-05-19019 May 2021 Issuance of Amendment Nos. 180 and 180 to Authorize Revision of Certain Emergency Action Levels of the Emergency Plan ML21103A0392021-04-23023 April 2021 Issuance of Amendment Nos. 179 and 179 the Adoption of Technical Specifications Task Force Traveler, TSTF-569, Revision 2, Revise Response Time Testing Definition (EPID L-2020-0147) ML21015A2122021-02-12012 February 2021 Issuance of Amendment Nos. 178 and 178 Regarding One-Time Revision to Technical Specifications 3.7.8 Station Service Water System (Ssws) and 3.8.1 AC Sources - Operating ML21022A1622021-02-0808 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0096 (COVID-19)) ML20346A0192021-02-0101 February 2021 Issuance of Amendment Nos. 177 and 177 Regarding Revision to Technical Specifications 3.8.1, AC Sources - Operating ML21021A1002021-02-0101 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0095 (Covid 19)) ML21013A1282021-01-28028 January 2021 Approval of Proposed Alternative to the Requirements of the ASME Code to Extend the Third Inservice Inspection Interval (EPID L-2020-LLR-0092 (COVID-19)) ML21021A0022021-01-28028 January 2021 Approval of Proposed Alternatives 1A4-1 and 1A4-2 from Certain Requirements of 10 CFR 50.55a for Inservice Inspection of Nuclear Power Plants ML20282A7092020-11-17017 November 2020 Proposed Alternative to the Requirements of the ASME Omcode to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0060 (COVID-19)) ML20281A4722020-11-0404 November 2020 Use of Later Code Edition to the Requirements of the ASME OM Code ML20255A1002020-10-0707 October 2020 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Test Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0061 and EPID L-2020-LLR-0062 (COVID-19)) ML20223A3492020-08-31031 August 2020 Issuance of Amendment Nos. 175 and 175 Regarding One-Time Revision to Technical Specification 3.7.19, Safety Chilled Water ML20226A0132020-08-17017 August 2020 Use of Later Code Edition to the Requirements of the ASME Code ML20167A3182020-07-0606 July 2020 Issuance of Amendment Nos. 174 and 174 Regarding Revision to Technical Specifications to Adopt TSTF-563, Revision 0 ML20108E8782020-04-17017 April 2020 Issuance of Amendment Nos. 173 and 173 Revision to TS 5.5.9, Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (Exigent Circumstances) ML20054A2762020-02-27027 February 2020 Approval of Change to the Quality Assurance Program as Described in the Comanche Peak Nuclear Power Plant Final Safety Analysis Report ML19267A0182019-11-0404 November 2019 Issuance of Amendment Nos. 172 and 172 to Revise Augmentation Times and Emergency Response Organization Staffing for the Emergency Plan ML18304A4872018-11-30030 November 2018 Issuance of Amendments 171 and 171 Regarding Revision to Technical Specifications for Engineered Safety Feature Actuation System Instrumentation ML18267A3842018-10-25025 October 2018 Issuance of Amendment Nos. 170 and 170 Revision to Technical Specification 3.8.4, DC Sources - Operating, Condition B (Exigent Circumstances) ML18221A6322018-08-15015 August 2018 Eicb Safety Evaluation - Comanche Peak Nuclear Power Plant, Units 1 and 2, License Amendment Request to Revise Technical Specification 3.3.2 Engineered Safety Feature Actuation System Instrumentation Docket/Epid 000976/05000446/L-2018-LLA-0 ML17129A0242017-06-29029 June 2017 Comanche Peak Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 169 and 169 Re: Administrative Change to Licensee Name (CAC Nos. MF8933 and MF8934) ML17074A4942017-04-13013 April 2017 Issuance of Amendment Nos. 168 and 168 Adoption of TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML17095A2512017-04-0707 April 2017 Request for Alternative 2B3-1 Re Examination of Reactor Vessel Closure Head Penetration Nozzles ML16334A1732016-12-14014 December 2016 Comanche Peak Nuclear Power Plant, Units 1 And 2; Safety Evaluation Regarding Implementation Of Mitigating Strategies And Reliable Spent Fuel Pool Instrumentation Related To Orders EA-12-049 And EA-12-051 ML16179A4052016-07-11011 July 2016 Relief Request Nos. B-9, B-3, B-10, and B-11 for Piping Welds, Second 10-year Inservice Inspection Interval ML16137A0562016-06-14014 June 2016 Issuance of Amendment Nos. 166 and 166, Request to Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 ML16096A2662016-05-0606 May 2016 Redacted Letter, Order, Safety Evaluation, and Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16096A2642016-05-0606 May 2016 Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16074A0012016-03-14014 March 2016 Relief Request 1B3-3, Alternative for Reactor Pressure Vessel Cold Leg Weld Inspection Frequency from Not to Exceed 7 Years to 9 Years for the Third 10-Year Inservice Inspection Interval ML16063A0012016-03-11011 March 2016 Relief Request No. B-15, C-2, and C-4 for Welds in the RPV and Containment Spray and Residual Heat Removal Heat Exchanger Shells, Second 10-year Inservice Inspection Interval ML16011A0732016-01-19019 January 2016 Relief Request T-1; Alternative to the ASME OM Code Frequency Specifications for Inservice Testing for the Third 10-Year IST Interval ML15309A0732015-12-30030 December 2015 Issuance of Amendment Nos. 165 and 165, Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, to Increase ILRT Test Interval from 10 to 15 Years and Type C Tests from 60 to 75 Mos ML15259A0042015-10-30030 October 2015 Relief Request 1B3-4, Alternative for Reactor Pressure Vessel Head Penetration Weld Inspection Frequency (from 10 to 15 Years), Third 10-Year Inservice Inspection Interval ML15257A2422015-09-18018 September 2015 Relief Request 2A3-1, from ASME Code Section XI Requirements, Risk-Informed Process for Selection of Class 1 and Class 2 Piping Weld Examinations, Third 10-Year Inservice Inspection Interval ML15257A2402015-09-15015 September 2015 Relief Request 2C3-1, from ASME Code, Section XI Requirements Reactor Pressure Vessel Leak-Off Flange for the Third 10-Year Inservice Inspection Interval ML15090A1042015-04-0303 April 2015 Relief Requests B-7, B-12, and B-13 - Steam Generator Head-to-Tube Sheet Welds for the Second 10-Year Inservice Inspection Interval ML15008A1332015-02-24024 February 2015 Issuance of Amendment Nos. 164 and 164, Revise Technical Specification 3.8.1 for a 14-Day Completion Time for Offsite Circuits ML14183A3422014-09-0808 September 2014 Issuance of Amendment Nos. 163 and 163 to Revise License Condition Related to Approval of Revised Cyber Security Plan Implementation Schedule 2023-09-28
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 4, 2014 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNIT 2 - REQUEST FOR RELIEF FROM PRESSURE TEST REQUIREMENTS ON REACTOR PRESSURE VESSEL FLANGE LEAK-OFF PIPING FOR THE SECOND 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. MF2997)
Dear Mr. Flores:
By letter dated October 31, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML ML13312A121 ), as supplemented by letters dated January 23 and February 11, 2014 (ADAMS Accession Nos. ML14038A256 and ML14055A318, respectively), Luminant Generation Company LLC (the licensee) submitted Relief Request No. C-3 for Comanche Peak Nuclear Power Plant (CPNPP), Unit 2, for relief from certain pressure test requirements for the reactor pressure vessel (RPV) flange leak-off piping. The request is for the second 10-year inservice inspection (lSI) interval, which began on August 3, 2004, and ends on August 2, 2014.
The licensee has proposed to perform a VT-2 visual examination of the accessible areas each period on the piping subjected to the static pressure head when the reactor cav1ty is flooded during refueling outage, in lieu of the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Paragraph IWC-5221 for the pressure test, which requires that system leakage test be performed with lines pressurized prior to performing VT-2 visual examination.
As set forth in the enclosed safety evaluation, the U.S. Nuclear Regulatory Comm1ssion (NRC) staff has reviewed the request and concluded that the proposed alternative provides reasonable assurance of structural integrity and leak tightness of the RPV flange leak-off piping and that complying with the specified ASME Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in Title 10 of the Code of Federal Regulations (1 0 CFR),
paragraph 50.55a(a)(3)(ii). Therefore, the NRC authorizes the use of the proposed alternative at CPNPP, Unit 2, for the remainder of the second 10-year lSI interval.
All other ASME Code,Section XI, requirements for which relief has not been specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
R. Flores If you have any questions, please contact Mr. Balwant Singal at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-446
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NO. C-3 SECOND 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAM LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT 2 DOCKET NO. 50-446
1.0 INTRODUCTION
By letter dated October 31, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13312A121 ), as supplemented by letters dated January 23 and February 11, 2014 (ADAMS Accession Nos. ML14038A256 and ML14055A318, respectively),
Luminant Generation Company LLC (the licensee), submitted Relief Request (RR) No. C-3 for Comanche Peak Nuclear Power Plant (CPNPP), Unit 2, for U.S. Nuclear Regulatory Commission (NRC) review and authorization. Specifically, the licensee requests relief from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Section XI system leakage test requirements for the reactor pressure vessel (RPV) flange leak-off piping. The licensee has proposed to perform a VT-2 visual examination of the accessible areas each period on the piping subjected to the static pressure head when the reactor cavity is flooded during refueling outage, in lieu of the requirements of ASME Code,Section XI, Paragraph IWC-5200 for the pressure test. However, in its letter dated February 11, 2014, the licensee clarified that the request for relief is from the requirements of IWC-5221, which requires that system leakage test be performed with lines pressurized prior to performing VT-2 visual examination.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.55a(a)(3)(ii),
the licensee proposed an alternative system leakage test on the basis that complying with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(g)(4), the ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The inservice examination of components and system pressure tests conducted during the first 10-year Enclosure
interval and subsequent intervals must comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b),
12 months prior to the start of the 120-month interval, subject to the conditions listed therein.
Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (i) the proposed alternatives would provide an acceptable level of quality and safety; or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Based on analysis of the regulatory requirements, the NRC has the regulatory authority to authorize the proposed alternative under 10 CFR 50.55a(a)(3)(ii) and the NRC staff has reviewed and evaluated the licensee's request accordingly.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Request for Alternative 3.1 .1 Components Affected The component affected by this request is ASME Code Class 2, IWC-2500, Table IWC-2500-1, Examination Category C-H, Item Number C7.1 0, pressure-retaining components. The licensee proposed alternative examination in lieu of the requirements of IWC-5220 for the leak-off piping (Line Numbers RC-2-080, RC-2-081, and RC-2-082) of the RPV head flange seal leak detection and collection system. The% inch RPV flange seal leak-off piping is SA-376 Type 304 or 316 stainless steel.
3.1.2 Code Requirements The Code of record for the second 10-year lSI interval at CPNPP, Unit 2, is the 1998 Edition through 2000 Addenda of the ASME Code.
The ASME Code,Section XI, IWC-2500, Table IWC-2500-1, Examination Category C-H, establishes requirements to conduct the system leakage testing according to IWC-5220 and the VT-2 visual examinations according to IWA-5240, for each inspection period. As required by IWC-5221, the system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability.
The licensee proposed an alternative to IWC-5221. The proposed alternative is to perform the VT-2 visual examination of the accessible areas of the RPV flange leak-off piping subject to a static pressure head when the vessel cavity is flooded during the refueling outage. This examination will be performed during each inspection period. The licensee estimated that the pressure head developed at the opening of the flange leak-off line from the elevation (24 feet and 5.5 inches) of water above the flange when cavity is flooded, will be 10.6 pounds per square inch gauge (psig).
3.1.3 Licensee's Reason for Request In its letter dated October 31, 2013, the licensee stated, in part, that The Reactor Pressure Vessel (RPV) head flange seal leak detection piping is separated from the reactor coolant pressure boundary by one passive membrane, which is an 0-ring located on the inner vessel flange as shown in Attachment 2 to [the licensee's letter dated October 31, 2013]. A second 0-ring is located on the outside of the tap in the vessel flange.
If the inner 0-ring leak during the operating cycle[,] it will be identified by an increase in temperature of the leak-off line above ambient temperature. This high temperature would actuate an alarm in the Control Room, which would be closely monitored by procedurally controlled operator actions allowing identification of any further compensatory actions required.
Failure of the inner 0-ring is the only condition under which this line is pressurized. In its letter dated February 11, 2014, the licensee stated, in part, that The procedure also addresses notifying chemistry department to increase monitoring of containment atmosphere to detect possible outer 0-ring failure; perform an operations test to determine leakage rate as applicable; and initiating corrective action documents to identify the condition and correct the condition as applicable.
In its letter dated October 31, 2013, the licensee stated, in part, that The configuration of this piping precludes system pressure testing while the vessel head is removed because the time required by personnel for the installation and removal of a threaded [1/8-inch] plug in the flange face to act as a pressure boundary would incur significant dose (estimated 20- 40 mRem/min
[milli roentgen equivalent man per minute], which would be an ALARA [as low as reasonable achievable] concern. This activity would also present Foreign Material Exclusion issue for the 1/8" plug that would be required to be installed to complete a leakage test at pressure.
The configuration [of the RPV flange leak-off piping] also precludes pressurizing the line externally with the head installed. The top head of the vessel contains two grooves that hold the 0-rings. The 0-rings are held in place by a series of retainer clips that are housed in recessed cavities in the flange face. If a pressure test were to be performed with the head on, the inner 0-ring would be pressurized in a direction opposite to its design function. This test pressure would result in a net inward force on the inner 0-ring that would tend to push it into the recessed cavity that houses the retainer clips. The thin 0-ring would likely be damaged by the inward force.
In its letter dated January 23, 2014, the licensee stated that its response to Question 6 of the NRC staff's request for additional information (RAI) for CPNPP, Unit 1 (letter dated January 9,
2013, available in ADAMS at Accession No. ML130250339}, applied to CPNPP, Unit 2. The licensee stated that pressurizing the leak-off lines with the head on would cause damage and failure of the inner 0-ring. This inner 0-ring failure would prevent pressure build-up by allowing water to pass by and enter the reactor vessel. To ensure that it was in fact an 0-ring failure and not a leak in the leak-off line piping, the portion of piping in the reactor vessel nozzle inspection areas ("sandboxes") would have to be inspected. In its letter dated January 9, 2013, the licensee stated that the conditions inside the "sandboxes" at the beginning of the outage prior to removing the head would be considered unsafe with extremely high temperatures and dose rates ranging from 150 to 250 mrem per hour (mrem/hr). The leak-off piping travels through three of the eight "sandboxes."
The licensee stated that there has been no known evidence of corrosion, stress-corrosion cracking, or fatigue in the subject flange leak-off piping at CPNPP, Units 1 and 2.
The licensee submitted this request for the remainder of the second 10-year lSI interval, which commenced on August 3, 2004, and will end on August 2, 2014.
3.2 NRC Staff Evaluation The components and piping being addressed are associated with the RPV closure head flange leakage detection system. The RPV closure head flange is designed with two concentric 0-rings that act as flange seals to enable the vessel to be pressurized during normal operation, with the inner 0-ring acting as the primary pressure seal for the RPV. The area between the 0-rings, the secondary outer 0-ring, and subject piping segments downstream are designed to support leakage detection should the primary inner 0-ring seal leak. These components are not pressurized by primary system water during normal reactor operation, and can only be tested using an external pressure source. The seal leak-off lines are essentially a leakage collection and detection system. Inner 0-ring leakage during the operating cycle is identified by an increase in the line temperature above ambient, actuating an alarm in the Control Room, which would be monitored by procedurally controlled operator actions allowing identification of any further compensatory actions required.
The NRC staff recognizes three possible methods for external pressurization of the subject lines to perform the ASME Code-compliant examination: 1) pressurizing the leak-off lines upon entering the refueling outage prior to removing the RPV head; 2) pressurizing the leak-off lines at the end of the outage after installing new 0-rings; and 3) installing a threaded plug in the flange face during the outage to act as a pressure boundary, and removing it after the examination.
In its letter dated January 23, 2014, the licensee stated that the response to CPNPP, Unit 1, RAI provided by letter dated January 9, 2013, is also applicable to CPNPP, Unit 2. Based on the information provided by the licensee in its letter dated January 9, 2013, the NRC staff concludes that performing the examination at the beginning of an outage would result in a relatively high radiation dose to personnel, which would constitute an ALARA concern and would present a hardship. Since 0-rings cannot be reused, pressurizing the subject lines and performing the visual VT -2 examination at the end of an outage would require removal of the RPV head after the examination to replace the newly installed 0-rings. The NRC staff concludes that ALARA
considerations and the heavy-lift evolution associated with replacing the 0-rings would present a hardship.
The NRC staff concludes that the third method of performing an ASME Code-compliant examination, installing a 1/8" plug to complete a leakage test with externally supplied pressure, would also present an ALARA consideration, as well as a Foreign Material Exclusion issue, either of which would present a hardship.
In lieu of IWC-5221, the licensee proposes to use the static pressure head of 10.6 psig developed from the elevation of the water above the vessel flange during the cavity flood-up, to perform the system leakage test of the RPV leak-off piping. The NRC staff determines that the proposed test pressure for leak testing is acceptable because the licensee will use the highest achievable pressure without any major design modifications to the vessel flange and the pipes.
If leakage originated from an existing flaw in the subject piping and its associated connections, the licensee will be able to detect it by the VT -2 visual examination performed according to IWA-5240, after maintaining the proposed test pressure. In addition, as stated by the licensee there has been no known evidence of corrosion, stress corrosion cracking, fatigue, etc. in the subject leak-off piping at CPNPP, Units 1 and 2.
The NRC staff determined that the licensee has sufficient reactor coolant system leakage detection capabilities (i.e., monitoring of containment atmosphere, sump, leakage rate, and increase in unidentified leakage) that notify the control room operator in an unlikely event of a through wall leak in the RPV flange seal leak-off line piping. The NRC staff concludes that even if the proposed alternative was not effective in identifying a through-wall leak, the existing reactor coolant leakage detection systems would be able to identify the leakage during normal operation and the licensee is required to take appropriate corrective actions in accordance with the plant technical specifications.
Therefore, the NRC staff concludes that the proposed system leakage testing with VT-2 visual inspection using low test pressure is adequate to provide a reasonable assurance of structural integrity and leak tightness of the RPV flange seal leak-off piping and demonstrates that leak-off lines can perform their intended function. The NRC staff also concludes that requiring compliance with the IWC-5200 system leakage test requirements would result in a hardship without a compensating increase in the level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff determines that the proposed alternative system leakage test provides reasonable assurance of structural integrity and leak tightness of the RPV head flange seal leak-off piping. The NRC staff concludes that complying with the specified ASME Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(3)(ii).
Therefore, the NRC staff authorizes the use of the proposed alternative at CPNPP, Unit 2 for the remainder of the second 10-year lSI interval, which commenced on August 3, 2004, and will end on August 2, 2014.
All other ASME Code,Section XI, requirements for which relief has not been specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear lnservice Inspector.
Principal Contributor: Ali Rezai, NRR/DEIESGB Date: April 4, 2014
R. Flores If you have any questions, please contact Mr. Balwant Singal at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Sincerely, IRA/
Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-446
Enclosure:
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PUBLIC RidsNrrLAJBurkhardt Resource LPL4-1 Reading RidsNrrPMComanchePeak Resource RidsAcrsAcnw_MaiiCTR Resource RidsOgcRp Resource RidsNrrDeEsgb Resource RidsRgn4MaiiCenter Resource RidsNrrDoriDpr Resource ARezai, NRR/DE/ESGB RidsNrrDorllpl4-1 Resource JNick, EDO RIV ADAMS Accession No.: ML14084A291 OFFICE NRRIDORULPL4-1/PM N RRIDORULPL4-1/LA NRRIDE/ESGB/BC N RRIDORL/LPL4-1/BC NAME BSingal JBurkhardt EMurphy (A) MMarkley DATE 3/31/14 3/28/14 3/31/14 4/4/14 OFFICIAL AGENCY RECORD