CP-201700252, Response to Request for Relief Request 283-1 Examination of Reactor Vessel Closure Head Penetration Nozzles
| ML17097A090 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/28/2017 |
| From: | Sewell S Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF9282, CP-201700252, TXX-17042 | |
| Download: ML17097A090 (2) | |
Text
Steven K. Sewell Senior Director of Engineering & Regulatory Affairs Steven.Sewell@Luminant.com Luminant Power P 0Box1002 6322 North FM 56 Glen Rose, TX 76043 Luminant CP-201700252 TXX-17042 March 28, 2017 Ref:
T 254 897 6113 c 817 776 0798 F 254 897 6652 10CFR50.55a(z)(2)
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NO. 50-446 RESPONSE TO REQUEST FOR INFORMATION FOR RELIEF REQUEST 2B3-1 EXAMINATION OF REACTOR VESSEL CLOSURE HEAD PENETRATION NOZZLES (CAC NO. MF9282)
REFERENCES:
- 1. Letter logged T:XX-17023 dated February 14, 2017, from Steven K. Sewell to the NRC submitting Relief Request No. 2B3-1 for the Unit 2 Third Ten Year Inservice Inspection Interval from 10CFR50.55a Inspection Requirements due to Geometric Limitations Third Interval Start Date: August 3, 2017 Third Interval End Date.: August 2, 2023
- 2. Email dated March 28, 2017, from Maggie Watford of the NRC to Timothy Hope of Vistra Operation Company LLC regarding additional information regarding Relief Request No. 2B3-1 (CAC No. MF9282)
Dear Sir or Madam:
Per reference 1, Vistra Operations Company LLC ("Vistra OpCo") submitted Relief Request 2B3-1 for Comanche Peak Nuclear Power Plant (CPNPP) Unit 2 for the third ten year inservice inspection interval.
Vistra OpCo has determined that certain inspection requirements of ASME Code Case N-729-1, "Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division l," are impractical due to geometric limitations. Per reference 2, the NRC provided a request for additional information regarding the subject relief request.
The proposed alternative in reference 1 was submitted under 10 CFR 50.55a(z)(l). Vistra OpCo requests that the applicable regulation under which the proposed alternative in reference 1 was submitted be changed to 10 CFR 50.55a(z)(2). Sufficient basis to demonstrate hardship was provided in the enclosure to reference 1.
U. S. Nuclear Regulatory Commission TXX-17042 Page 2 of 2 03/28/2017 Specifically, relief is requested from the minimum coverage requirements for ultrasonic examination provided by American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Code Case N-729-1, "Alternative Examination Requirements for PWR [Pressurized-Water Reactor]
Reactor Vessel Upper Heads with Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1," for control rod drive mechanism nozzles 74 through 78. Compliance with the requirements of Code Case N-729-lwould result in hardship without a compensating increase in the level of quality and safety.
No undue risk to the public health and safety is presented by this request.
Vistra OpCo requests approval of this relief request by April 7, 2017, to support the upcoming CPNPP Unit 2 refueling outage.
This communication contains no new licensing basis commitments regarding CPNPP Unit 2.
Should you have any questions, please contact Mr. Jack Hicks at (254) 897-6725 (email:
jack.hicks@luminant.com).
Sincerely, Vistra Operations Company LLC Steven K. Sewell Senior Director of Engineering & Regulatory Affairs c -
William M. Dean, Director, Office of Nuclear Reactor Regulation Kriss Kennedy, Region IV MargaretM. Watford,NRR Resident Inspectors, Comanche Peak Brandon Kneupper, ANII, Comanche Peak Mr. Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin TX, 78714-9347