CP-201500780, Relief Request C-2, Second Ten Year Inservice Inspection Interval from 10CFR50.55a Inspection Requirements Due to Physical Interferences (1998 Edition of ASME Code, Section XI, 2000 Addenda Second Interval Start Date: August
| ML15224B366 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/2015 |
| From: | Flores R, Madden F Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-201500780, TXX-15120 | |
| Download: ML15224B366 (6) | |
Text
Rafael Flores Luminant Power Senior Vice President P0O Box 1002 Chief Nuclear Officer 6322 North FM 56 Rafae[.Flores@Lurninant~com Glen Rose, TX 76043 Lum inant 2548975590 CP-201500780 Ref. # 10CFR50.55a(g)(5)iii TXX-15120 August 3, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NO. 50-446 RELIEF REQUEST C-2 FOR UNIT 2 SECOND TEN YEAR INSERVICE INSPECTION INTERVAL FROM 10CFR50.55a INSPECTION REQUIREMENTS DUE TO PHYSICAL INTERFERENCES (1998 EDITION OF ASME CODE, SECTION XI, 2000 ADDENDA SECOND INTERVAL START DATE: AUGUST 3, 2004 SECOND INTERVAL END DATE: AUGUST 2, 2014)
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(g)(5)(iii)), Luminant Generation Company, LLC (Luminant Power) is submitting Relief Request C-2 (see attachment) for Comanche Peak Unit 2 for the second ten year inservice inspection interval. Luminant Power has determined that certain inspection requirements of ASME Section XI are impractical due to physical interferences.
The geometry of the containment spray heat exchanger makes the Code required examination coverage requirements impractical. Ultrasonic Testing (UT) of the subject weld was performed during the second interval to the maximum extent practical based on design configuration restrictions. Pressure test VT-2 visual examinations were also performed with no evidence of leakage identified for the subject component. No undue risk to the public health and safety is presented by this request.
This conmmuication contains no new licensing basis commitments regarding Comanche Peak Unit 2.
U. S. Nuclear Regulatory Commission TXX-1 5120 Page 2 of 2 08/03/2015 Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725.
Sincerely, Luminant Generation Company LLC Rafael Flores By:
- /-
/*rd--.
adden Director, External Affairs - Relief Request C-2 for Unit 2 Second Ten Year 1S1 Interval from 10CFR50.55a Inspection Requirements due to Physical Interferences - Examination Data Sheets and Sketch (2 pages) c -
Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Rob D. Troutt, TDLR Jack Ballard, ANII, Comanche Peak
Attachment I to TXX-1 5120 Page 1 of 2 COMANCHE PEAK NUCLEAR POWER PLANT UNIT 2 Relief Request Number C-2 for Unit 2 Second 10 Year ISI Interval From 10CFR50.551 Inspection Requirements due to Physical Interferences (Second 10-Year ISI Interval Start Date: August 3, 2004; End Date: August 2, 2014)
- 1.
ASME Code Component Affected:
Class 2 Containment Spray Heat Exchanger (CP1 -CTAHCS-02) Shell Circumferential Weld:
Code Cat/Item No.
Description Weld No.
C-A / C1.16 CT HX 1-02 Shell to Flange Weld TCX-2-1180-1-2
- 2.
Applicable Code Edition and Addenda
The applicable ASME Boiler and Pressure Vessel Code (hereafter referred to as the "Code')
edition and addenda is ASME Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1998 Edition through 2000 Addenda.
- 3.
Applicable Code Reqiuirement:
ASME Section XI, Figure IWC-2500-1 (a) 1998 Edition through 2000 Addenda, requires a minimum volumetric examination of the weld volume extending into the base metal on the vessel and flange sides for the circumferential weld (Code Item C 1.10).
The Comanche Peak Nuclear Power Plant (CPNPP) second ten-year interval Inspection Program Plan also implements Code Case N-460, which is endorsed by the NRC in revision 17 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability ASME Section XI, Division 1." Code Case N-460 states, in part, when the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class 1 or Class 2 weld may be accepted, provided the reduction coverage for that weld is less than 10 percent.
NRC Information Notice (IN) 98-42, "Implementation of 10 CFR 50.55a (g) Inservice Inspection Requirements," termed a reduction in coverage of less than 10 percent to be "essentially 100 percent." IN 9 8-42 states, in part, "The NRC has adopted and further refined the definition of "essentially 100 percent" to mean "greater than 90 percent"... has been applied to all examinations of welds or other areas required by ASME Section XI."
- 4.
Impracticality of Compliance:
The examination of the subject component weld is limited by the configuration of the flange design and the proximity of two welded support plates on the shell side of the heat exchanger.
As shown on the Attachment 2, the proximity of the welded supports and the flange configuration limit the parallel scans (circumferential). Perpendicular (axial) scans are limited mainly by the welded supports on the shell side of the weld. This yields a composite coverage of 86% of the required examination volume (see Attachment 2). The examinations were conducted in accordance with procedure TX-ISI-214, "Ultrasonic Examination Procedure for Welds in Piping Systems and Vessels."
to TXX-15120 Page 2 of 2 COMANCHE PEAK NUCLEAR POWER PLANT UNIT 2 Relief Request Number C-2 for Unit 2 Second 10 Year 181 Interval From 10CFR50.551 Inspection Requirements due to Physical Interferences (Second 10-Year ISI Interval Start Date: August 3, 2004; End Date: August 2, 2014)
- 5.
Burden caused by Compliance:
The design configuration restrictions of the subject components make the Code required examination coverage requirements for the weld volume impractical. Plant modifications or replacement of components designed to allow for complete coverage would be needed to meet the Code requirements. This would cause considerable burden to CPNPP.
- 6.
Proposed Alternative and Basis for Use:
Proposed Alternative:
The following alternatives are proposed in lieu of the required examination coverage of essentially 100 percent:
- 1. Ultrasonic testing (UT) of the subject component weld was performed to the maximum extent practical during the second ten-year interval. No recordable indications were noted.
- 2. Pressure test VT-2 visual examinations were performed, as required by Code Category C-H, during the second ten-year interval. No evidence of leakage was identified for this component.
Basis for use:
The basis for use of this alternative is that it provides the best examination coverage practical within the limitations of the current configuration. Based on the percentage of the examination volume completed and the lack of any indications identified, there is a high level of confidence in the continued structural integrity of the weld. CPNPP believes that there is no undue risk to the public health and safety presented by this request.
- 7.
Duration of Proposed Alternative:
The second ten-year ISI interval for Unit 2 began on August 3, 2004 and ended on August 2, 2014.
- 8.
Precedents:
Relief Request C-9 was submitted in letter TXX-98170 from CPNPP to USNRC in July 22, 1998 for the first ten-year interval for Unit 1.
Relief Request C-7 was submitted in letter TX(X-10092 from CPNPP to USNRC in December 15, 2010 for the second ten-year interval for Unit 1.
Atachmentio 2ato Sheet12 Iof 2 PDI Calibration Data Sheet LI.~
Plant / Unit COMANCHE PEAK UNIT 2 Company WESDYNE Camp!/ System HXICONTAINMENT SPR Procedure No.
TX-IS 1-214 Rev / Chng. No.
4 / N/A Cal. Block No.
TBX-31 / PDI-03 Cal. Block Temp 780 Comp. Temnp 800 Therm S/N:
TU-2361 Size 16" Sch.
N/A.625...
T" E*Ferritic
[*Austenitic Data Sheet #
11 UT-06 Page
[
of 2~-.
Cal. Checks Time Initial Calib.
1300 Initial Calib. Date 9/18/09 Intermediate N/A Intermediate N/A Final Calib.
1640 Final Calib. Date 9/18/09 80 60 40 20 I _____
______I
__,-z 80 60
-Ie t 40 20 0
2 4
6 8
1 CRT Div. =
.4424" 0
2 4
6 8
1 CRT Div. =
.4424" Cal. Direction:
Axial Circ.
Both X Couplant Scan Area:
_L to Weld
[.to Weld Type::
ULTRA GEL II Batch:
06225 Recordable Access Indications Exam Sens.
Examination Area /Weld Yes No Geom TCX-2-1180 1-2 2-SIDED X
34.5 dB TCX-2-1180 1-3 2-SIDED X
34.5 dB TCX-2-1180 1-4 2-SIDED X
34.5 dB Remarks / Reason for Incomplete Scan(s)
°°t"0, 86% EXAMINATION VOLUME ACHIEVED 6[ t~j~l,- i-a)
WELDS 1-3 & 1-4 100% EXAMINATION VOLUME ACHIEVED Search Unit #1 Manufacturer:
KBA Serial No.:
00YHTT Freq.: 2.25 MHz Size:
.25" Shape:
ROUND Exam Angle:
45" Model:
COMP G Measured Angle:
450 Wedge Style:
MSWQC Search Unit Cable Type:
RG-174 Search Unit #2 Manufacturer:
KBA Serial No.:
00YHTT-Freq.: 2.25 MHz Size:
.25" Shape:
ROUND Exam Angle:
45" Model:
COMP 0 Measured Angle:
45" Wedge Style:
MSWQC Search Unit Cable Type:
RG-174 Length:
12' No. of Connectors:
0 Instru*ment Settings Make / Model:
KBA / USN 60 SW Serial No.:
SAP 105211 Length:
12'~ No. of Connectors:
0 Instrument Settings Make / Model:
KBA I USN 60 SW Serial No.:
SAP 105211 Dis.Delay:
0.000 pJS Range:
Prb.Delay:
4.8550 ps Pwidth:
M'tl Cal/Vel:
.1258 ps Pulser:
Damping:
500 C) Reject:
Rep. Rate:
AUTOHIGH Freq.:
Filter:
FIXED Mode:
Voltage:
450 Rectify:
Reference Sensitivity (Sens.)
4.424" 220 SQUARE 0%
2.25 MHz P/E FULLWAVE Examiner:
CAREY LASOYA Examiner:
Level II Date 9/1 8/09 Dis.Delay:
0.000 ps Range:
Prb.Delay:
4.8550 p~s.Pwidth:
M'tI CalNel:
.1258 ps Pulser:
Damping:
500 D. Reject:
Rep. Rate:
AUTOHIGH Freq.:
Filter:
FIXED Mode:
Voltage:
450
,Rectify:
Reference Sensitivity (Sens.)
Axial:
24.5 dB Circ:
SDH Sensitivity:_______
4.424" 220 SQUARE 0%
2.25 MH; PIE FULLWAVE Level
,o, Date Axial:
24.5 dB Circ:
24.5 dB
_________SDH Sensitivity: ___________
Further Evaluation Required?
[]
Yes
[]
No 24.5 dB
'~I'l Reviewer I Date
/-,"//
Reviewer/ Date lg53c
5 IIdt-c-r-o*,
___ to T)(X-15120 REPORT I*.Of4B*e2 WESTINGHOUSE NUCLEAR SERVICES.DIVISION
,l
- 1PA G E
.2 O F
- 2
.LIMITATION TO EXAMINATION "PLAN comc*
Peak UNIT
- 2 SKETCH TCX-
- 2-1180 Rev..2 SYSTICOMP
,CONTAINMENT:SPRAY PROCEDURE "X-lSI-214 Rev. 2 "F-C N/A EXAMINER N/A
,LEVEL N/A DATE COMPONENT ID TCX-2-118O-1-2 RELATED TO O. MT QOPT
- UIT Q VTl "PROVIDE.SUFFICIENT INFORMATION TO DESCRIBE SIZE, LOCATION AND TY'PE OF LIMITATION.
COMMENTS/SKETCH/DErAILS 14% NOT EXAMINED DUE TO WELDED SUPPORTS.
WELD,*
i TU ELECTRIC REVIEW I DATE
,o hnZ~~
ql/-II fTU ELECTRIC LEVEL III REVI1EW / DATE I,