ML25142A312
| ML25142A312 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/22/2025 |
| From: | Dennis Galvin Plant Licensing Branch IV |
| To: | Hicks J Vistra Operations Company |
| Lee, Samson | |
| References | |
| EPID L-2025-LLR-0044 | |
| Download: ML25142A312 (2) | |
Text
From:
Dennis Galvin To:
Jack Hicks (Jack.Hicks@luminant.com)
Cc:
Nic Boehmisch (Nicholas.Boehmisch@luminant.com); Barnette, James; Tony Nakanishi
Subject:
Comanche Peak - Acceptance of Requested Licensing Action - Proposed Alternative Regarding CP-ISI-2025-3 Containment Moisture Barrier Inspection (EPID: L 2025-LLR-0044)
Date:
Thursday, May 22, 2025 12:05:00 PM
Dear Mr. Hicks,
By letter dated April 16, 2025 (Agencywide Documents Access and Management System Accession No. ML25106A319), Vistra Operations Company LLC (the licensee) submitted a proposed alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) at Comanche Peak Nuclear Power Plant (Comanche Peak) Units 1 and 2. The licensee requested a proposed alternative to inservice inspection requirements for the containment moisture barrier due a hardship without a compensating increase in quality and safety.
The purpose of this email is to provide the results of the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs acceptance review of this proposed relief request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Pursuant to Sections 50.55a(z)(1) and 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR), the applicant shall demonstrate that the proposed alternatives would provide an acceptable level of quality and safety, or that compliance with the specified requirements of Section 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.
The NRC staff has reviewed your application and concluded that it provides technical information in sufficient detail to enable the staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review, as compared to the detailed technical review, there may be instances in which issues that impact the staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. You will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.
Based on the information provided in your submittal, the NRC staff has not identified any clear precedents. However, for the purpose of estimating resources and schedule, the NRC has identified several similar licensing actions. Based on those actions, reviews have historically required an average of 185 hours0.00214 days <br />0.0514 hours <br />3.058862e-4 weeks <br />7.03925e-5 months <br /> and 245 days. To support a more efficient process, the NRC is setting a goal of a 15% improvement. Accordingly, our estimate for this review is 157 hours0.00182 days <br />0.0436 hours <br />2.595899e-4 weeks <br />5.97385e-5 months <br /> and 208 days. The NRC staff expects to complete this review by December 15, 2025. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date or significant changes in the forecasted hours, the reasons for the changes, along with the new estimates, will be
communicated during the routine interactions with the assigned project manager.
These estimates are based on the NRC staffs initial review of the application and they could change, due to several factors including requests for additional information, and unanticipated addition of scope to the review. Additional delay may occur if the submittal is provided to the NRC in advance or in parallel with industry program initiatives or pilot applications.
Please contact me with any questions.
Respectfully,
Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256
Docket Nos. 50-445, 50-446