CP-202000428, (CPNPP) - Response to Request for Additional Information Regarding Proposed Alternative SNB-1 for a One-Time Extension of Snubber Testing

(CPNPP) - Response to Request for Additional Information Regarding Proposed Alternative SNB-1 for a One-Time Extension of Snubber Testing

ML20218A853
Person / Time
Site:	Comanche Peak
Issue date:	08/05/2020
From:	Sewell S Luminant, Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202000428, TXX-20065
Download: ML20218A853 (16)

Text

Steven K. Sewell Comanche Peak Senior Director, Nuclear Power Plant Engineering & Regulatory Affairs (Vistra Operations Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6113 CP-202000428 TXX-20065 August 5, 2020 U. S. Nuclear Regulatory Commission Ref 10 CFR 50.55a ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket No. 50-445 Response to Request for Additional Information Regarding Proposed Alternative SNB-1 for a One-Time Extension of Snubber Testing

References:

1. Submittal dated July 14, 2020 from Vistra Operations Company LLC to the NRC requesting authorization of proposed alternative SNB-1 to the ASME Code for Operation and Maintenance of Nuclear Power Plants for a one-time extension of the testing interval for snubbers at the Comanche Peak Nuclear Power Plant Unit 1 from the fall 2020 refueling outage (1RF21) to the Spring 2022 refueling outage (1RF22) due to Covid-19 issues (ML20196L823)

2. NRC email from Dennis Galvin to Jack Hicks, Comanche Peak Unit 1 - Request for Additional Information - Proposed Alternative SNB-1 to ASME OM Code for One-Time Extension of Snubber Testing (EPED: L 2020-LLR-0095, dated July 28, 2020

Dear Sir or Madam:

Vistra Operations Company LLC (Vistra OpCo) hereby submits a response to the NRC request for additional information (RAI) (Reference 2) regarding the snubber relief request submitted with Reference 1.

The attachment to this letter provides Vistra OpCos response to the RAI.

The enclosure with this letter provides a supplemented snubber Relief Request with the RAI response information incorporated.

This communication contains no new commitments regarding CPNPP Units 1 and 2.

TXX-20065 Page 2 of 2 Should you have any questions, please contact Jim Barnette at (254) 897-5866 or James.barnette@luminant.co m.

Sincerely, Steven K. Sewell

Attachment:

CPNPP Response to NRC RAis (SNB-1)

Enclosure:

CPNPP Full Text of Relief Request SNB-1 (Supplemented) c (email) - Scott Morris, Region IV [Scott.Morris@nrc .gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

Attachment toTXX-20065 Page 1 of 5 Attachment to TXX-20065 CPNPP Response to NRC RAIs (SNB-1)

Attachment toTXX-20065 Page 2 of 5 CPNPP Response to NRC RAIs (SNB-1)

Note: The page and paragraph locations described in the CPNPP RAI responses are in reference to the full text version of the relief request submitted as an attachment to the original request submitted via the NRC on-line portal. The Enclosure with TXX-20065 provides a full text of the relief request with supplemental information from the RAI responses indicated in red.

The NRC information request will be listed first, followed by the CPNPP response.

1. The licensees electronic submittal inconsistently describes the alternative request as one- time relief, deferral, or elimination of snubber testing throughout the document. The NRC staff considers this alternative request to propose a one-time extension of the ASME OM Code Inservice testing (IST) snubber program for specifically identified snubbers to the spring 2022 Refueling Outage (1RF22). Please clarify (and revise, as necessary) the description of this alternative request throughout the submittal.

CPNPP Response:

SNB-1 Relief Request has been updated by changing the word deferral or elimination to extension, throughout the document as noted below.

Page 2 of SNB-1 RR 3rd paragraph changed defer to one-time extension.

Page 3 of SNB-1 RR 6th paragraph removed reference to deferring and added a one-time extension testing from the fall of 2020.

Page 3 of SNB-1 RR 7th paragraph changed defer to one-time extension.

Page 4 of SNB-1 RR 2nd paragraph changed defer to one-time extension.

Page 4 of SNB-1 RR 3rd paragraph changed elimination to one-time extension.

Page 6 of SNB-1 RR 3rd paragraph changed delay to refer to the one-time extension.

Page 7 of SNB-1 RR bullet 2 added one-time extension.

Attachment toTXX-20065 Page 3 of 5

2. The licensee has provided a list of 37 snubbers as part of Table 1 of the submittal.

Paragraph ISTD-5251, DTPGs General Requirement, of the ASME OM Code requires that defined test plan groups (DTPGs) include all snubbers, except replacement snubbers and snubbers repaired or adjusted as a result of not meeting the examination acceptance requirements of ISTD-4200. Paragraph ISTD-5253, Additional DTPG Requirements for Pressurized Water Reactors, also states that snubbers attached to the steam generator and snubbers attached to the reactor coolant pump shall be at least one, separate DTPG.

The licensees proposed alternative does not provide any details regarding the snubbers for reactor coolant pumps or steam generators. Please clarify if these snubbers are included in the current proposed 37 sample plan or have a separate DTPG for the 1RF21 refueling outage.

CPNPP Response:

There are no snubbers attached to CPNPP Reactor Coolant Pumps or Steam Generators in Unit-1.

Added to page 3, of SNB-1 RR 5th paragraph:

Note; Unit-1 Steam Generator Snubbers were removed during Refueling Outage 1RF12, (Steam Generator replacement project, Ref FDA-2005-000659). Also, the Reactor Coolant Pumps were not designed with snubber type supports.

Attachment toTXX-20065 Page 4 of 5

3. In Section 21 of the submittal, Subsection Basis for Use, the first paragraph states, in part, that as evidenced by the CPNPP Unit 1 operational readiness test history during the past 10 years, the snubber population is well maintained within the examination, testing and service life monitoring program. Some of the snubbers listed in Table 1 have Not Tested in the Test History column. The ASME OM Code, Subsection ISTD, requires visual examination, functional testing and service life monitoring for all snubbers within the scope of the ASME OM Code. The submitted alternative request does not provide any information about the visual examination of snubbers. Please summarize the visual examination history (including failures) during the last 10 years for all snubbers within the scope of the ASME OM Code, including those listed in Table 1 as Not Tested CPNPP Response:

Added to page 5 of SNB-1 RR 1st paragraph:

Note: All 1443 Unit-1 snubbers in scope of the ASME OM Code, which includes the 37 snubbers in Table 1 of SBN-1 RR were visually inspected during 1RF19 and 1RF20, with the exception of two (CS-1-258-700-A53K and CS-1-259-700-A53K) which could not be inspected due to a Locked High Radiation Area. These two are currently scheduled to be inspected in September of 2020, for this is the first available time to inspect these prior to a resin transfer. Out of 1441 snubbers inspected there was only one UNSAT, CC-1-043-013-A43K. This snubber was found with a pipe clamp out of the required maximum 5-degree angle; its As-Found Condition was 8-degrees. Condition report CR-2019-003979 was issued to evaluate the operability concerns and to correct the noted condition. It was determined by EV-CR-2019-003979-1 that the noted condition had no impact on the operating system. The condition as noted was corrected by work order 5754043.

Attachment toTXX-20065 Page 5 of 5

4. Table 1 of the submittal shows the service life expiration for each snubber. Please (1) clarify when the service life for each snubber was last evaluated, in accordance with Paragraph ISTD-6200, Service Life Evaluation, of the ASME OM Code, and (2) provide an explanation of having an equal service life for all mechanical snubbers even though they are installed in various locations and systems with various operating environments (i.e., temperature, humidity, radiation, etc.).

CPNPP Response:

Note: CPNPP Service life plan. Added to page 5 of SNB-1 RR 1st paragraph:

All 1443 snubbers are evaluated at the close of each Refueling Outage. The last time this was completed was at the end of 1RF20 as required by ISTD-6200 and as recommended by PSA vendor document DR3020. All 1443 snubbers in the Unit-1 PSA mechanical snubbers DTPG are currently evaluated to 40 years service life, the current licensed life of the plant. To date there have not been any failed snubbers attributed to environmental or operational causes. None of the snubbers in the scope of the Snubber Program are in areas with environmental conditions that would warrant a reduced service life. As noted in this report CPNPP has experienced very few failures, only one failed test and one UNSAT visual in the last ten years. These and any other failures are evaluated under the CPNPP corrective action program for cause and extent of condition. To date none have required a reduction of service life to maintain operational readiness.

Enclosure with TXX-20065 Page 1 of 8 Enclosure With TXX-20065 CPNPP Full Text of Relief Request SNB-1 (Supplemented)

Enclosure with TXX-20065 Page 2 of 8 CPNPP Full Text of Relief Request SNB-1 (Supplemented)

1. Title of Project RELIEF REQUEST SNB Snubber Testing

2. Licensee Vistra Operations Company LLC (Vistra OpCo)

3. Licensee Contact Jim Barnette

4. Licensee Contact Phone Number 254-897-5866

5. Licensee Contact Email Address James.barnette@luminant.com

6. Plant Identification Number N/A

7. Plant Name Comanche Peak Nuclear Power Plant (CPNPP)

8. Plant Units Unit 1

9. Docket Numbers 50-445

10. License Numbers NPF-87

11. Requested Completion Date August 14, 2020

12. Applicable Regulation and Inservice Inspection (ISI) or Inservice Testing (IST) 10 CFR 50.55a(z)(2) IST

13. Proposed Alternative Number or Identifier:

SNB-1

14. Applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, or ASME Operations and Maintenance (OM) Code, Edition and Addenda:

American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through the 2006 Addenda (Ref. 1)

Enclosure with TXX-20065 Page 3 of 8

15. ISI or IST Program Interval Number and start/end dates (as applicable):

IST Program Third Interval Start Date:

August 3, 2013 End Date: August 2, 2023

16. ASME Code Class ASME Code Class 1, 2 & 3

17. Applicable Components and or System Description (if applicable):

Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 snubbers that are within the scope of the ASME OM Code as listed in Table 1, Snubber Tests Requested for One-Time Extension to the spring of 2022 (1RF22).

18. Describe the Applicable Code Requirements:

ISTD-5240, Test Frequency, which states in part:

Tests of snubbers from the facility shall be performed every fuel cycle

19. Reason for Request:

The U.S. Federal Government made a COVID-19 declaration of emergency pursuant to the Stafford Act on March 13, 2020. The U.S. Center for Disease Control (CDC) determined that COVID-19 poses a serious public health risk. In the state of Texas, where CPNPP is located, a Major Disaster Declaration was declared on March 25, 2020, to take actions necessary to reduce exposure to the virus associated with the COVID- 19 outbreak. Although many of the state restrictions have been lifted or reduced, the CDC has indicated that many U.S. States could experience another increased surge in the spread of the virus again this Fall.

The (CDC) continues to recommend social distancing and the use of masks as it applies to COVID-19. The CDC defines social distancing as "remaining out of congregate settings, avoiding mass gatherings, and maintaining distance (approximately 6 feet or 2 meters) from others when possible."

In response to the COVID-19 Pandemic and to comply with CDC guidance, Vistra Operations LLC (Vistra OpCo) established the following guidelines and restrictions that remain in effect at Comanche Peak Nuclear Power Plant (CPNPP):

1. Employees who do not have a critical need to be at CPNPP facilities must work remotely.

2. Employees who must work from a CPNPP facility are to practice strict social distancing.

3. 1RF21 Outage scope shall be reduced to limit the number of supporting contract personnel.

These guidelines and restrictions were established to eliminate the potential of inadvertently spreading the COVID-19 virus to critical personnel who are necessary to complete 1RF21 refueling outage activities, return the unit safely to service, and to maintain the unit operational to meet its power demands along with the surrounding community.

A large concern with spreading the virus focuses on outside specially trained and qualified resources who perform work to supplement the small CPNPP staff during outages. The concerns

Enclosure with TXX-20065 Page 4 of 8 associated with outside resources consists of the risk of their availability either due to the potential for travel restrictions and quarantine requirements imposed by both the U.S.

Government and the State of Texas making it extremely difficult to travel from out of state to site, or because of illness. Bringing contract personnel on site with unknown medical history and their potential exposure to COVID-19 virus increases the risks of infecting the CPNPP personnel with COVID-19 virus. It is an extreme hardship for CPNPP to quarantine incoming contractors for sufficient durations to ensure they are free of COVID-19 virus symptoms or to conduct adequate testing of all contractors for COVID-19 virus. However, without these safeguards, the CPNPP staff and surrounding community are at increased risk of contracting COVID-19 virus, which has the potential of affecting the outage and future operation of the station.

Additionally, in general, work during outages tends to be in close spaces and does not allow for social distancing which can be a large contributor towards the spread of the virus as well.

Many of the planned 1RF21 Outage activities are being postponed until future outages based on the above guidelines, restrictions and concerns such that compliance with the applicable code requirements for inspection and testing results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current and future concerns related to the pandemic. Testing and inspections mandated by the Code of Federal Regulations in Title 10, Part 50, Section 55a, (10CFR50.55a) cannot be postponed without prior NRC approval.

Relief is being sought based on the existence of satisfactory snubber operational readiness performance data and that compliance would involve activities that would be detrimental to the occupational health and safety of the workforce and result in the potential to spread the virus. The basis of the request is that compliance results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current COVID-19 pandemic.

Subsection ISTD 5240 requires snubbers to be tested for operational readiness during each fuel cycle. The number of snubbers to be tested is based on a sample test plan defined by article ISTD-5260, Testing Sample Plans.

CPNPP Unit 1 has 37 sample plan which are all mechanical snubbers. Using the appropriate sample plan, a selection of snubbers is chosen for operational readiness testing during each fuel cycle. Table 1 represents the population of snubbers scheduled to be tested under the snubber test plan for the 1RF21 refueling outage.

Note: Unit-1 Steam Generator Snubbers were removed during Refueling Outage 1RF12, (Steam Generator replacement project, Ref FDA-2005-000659). Also, the Reactor Coolant Pumps were not designed with snubber type supports.

This relief request demonstrates that there is reasonable assurance that the operational readiness of each identified snubber will be maintained through the next refueling outage currently scheduled for the spring of 2022 (1RF22). The technical justification utilizes available data from the last 10 years of snubber testing and includes a review of the service life monitoring history for the snubber population. This provides the technical justification necessary to show that the proposed One-Time Extension from the fall of 2020 until the next refueling outage in the spring of 2022 is acceptable and provides reasonable assurance that the snubbers maintain operational readiness.

Enclosure with TXX-20065 Page 5 of 8

20. Brief Description of the Proposed Alternative (500 characters or less):

Vistra OpCo is requesting this one-time relief from the following ASME OM Code requirement:

ISTD-5240 requires that tests of snubbers from the facility shall be performed every fuel cycle.

Vistra OpCo proposes a One-Time Extension of the 37 Plan originally scoped to 1RF21 to the refueling outage currently scheduled for spring of 2022 (1RF22) so that the entire 1RF22 snubber testing scope includes only the 37 Plan originally scoped to 1RF21 and any scope expansion that may result from that testing.

21. Full Description of the Proposed Alternative:

Proposed Alternative Vistra OpCo is requesting this one-time relief associated with performing the identified snubber testing activities pursuant to 10 CFR 50.55a(z)(2) on the basis that compliance results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current pandemic due to the COVID-19 outbreak. Vistra OpCo proposes this one-time relief from the following ASME OM Code requirements and provides the proposed alternative testing as follows:

ISTD-5240 requires that tests of snubbers from the facility shall be performed every fuel cycle. Vistra OpCo proposes a One-Time Extension of the 37 Plan originally scoped to 1RF21 to the refueling outage currently scheduled for spring of 2022 (1RF22) so that the entire 1RF22 snubber testing scope includes only the 37 Plan originally scoped to 1RF21 and any scope expansion that may result from that testing.

Based on the CPNPP Unit 1 snubber test history, the One-Time Extension of snubber testing during Refueling Outage 1RF21 will not impact the ability of the untested snubbers to perform their intended safety function until Refueling Outage 1RF22 when testing will resume. In the last 10 years, 241 snubbers have been tested with only one (1) snubber test failure that occurred during the spring of 2016 (1RF18). The test failure occurred in the Component Cooling (CC) system of the mechanical snubber population and was evaluated with corrective action taken per the CPNPP corrective action program (CR-2016-004366). The evaluation of this failure concluded that the piping system to which this snubber was attached remained within design parameters and would have fulfilled its safety function. This snubber failed the Drag part of it test. See more detail below:

Snubber CC-1-007-034-A63K failed due to a higher drag value than allowed by the acceptance criteria. The snubber was disassembled to assess cause of failure. Inspection of removed parts showed that the recirculating ball screw assembly was degraded due to friction rubbing (would move side to side and wobbled on the shaft). This resulted in increasing high drag during testing and a failed test result. This condition has not been noted during any previous testing performed at CPNPP or by industry operating experience (OE). Also, the snubber location drawing BRHL CC-1-AB-046 shows this snubber as the only snubber located on this pipe line. All other restrains are of a rigid type, except for one spring can. This configuration is not known to exist at any other snubber location. Snubber CC-1-007-034-A63K was replaced. Due to this failure, 19 more snubbers were randomly selected from the Pacific Scientific (PSA) Mechanical Snubber population and tested for operational readiness, all 19 passed their test. The snubber population at CPNPP Unit 1 has been operating at a high level of performance for the past ten years and this performance provides reasonable assurance that the entire CPNPP Unit 1 snubber population will

Enclosure with TXX-20065 Page 6 of 8 be capable of performing their required safety function over the extended interval proposed.

Since 1RF20, there have been no dynamic events or transients during operation that might affect snubber performance or place a need for added emphasis on a specific snubber or group of snubbers.

Basis for Use As evidenced by the CPNPP Unit 1 operational readiness test history during the past 10 years, the snubber population is well maintained within the examination, testing and service life monitoring program, and are performing well in their environment and operating conditions. There are no planned changes to the snubber environments or operating conditions that would affect the snubbers differently than represented in past surveillance testing. No deficiencies, adverse trends or open maintenance work orders were identified that would impact or degrade any snubbers performance capability and exclude it from this one-time interval extension RR. Each snubber in the scope of this RR will remain within the predicted service life interval, in accordance with ISTD-6100, Predicted Service Life, through 1RF22. Considering the entire snubber population and the current level of acceptable performance, there is reasonable assurance that each snubber will continue to be operationally ready to perform their safety functions during the use of this RR.

Note: All 1443 Unit-1 snubbers in scope of the ASME OM Code, which includes the 37 snubbers in Table 1 of SBN-1 RR were visually inspected during 1RF19 and 1RF20, with the exception of two (CS-1-258-700-A53K and CS-1-259-700-A53K) which could not be inspected due to a Locked High Radiation Area. Those two are currently scheduled to be inspected in September of 2020, for this is the first available time to inspect these two prior to a resin transfer. Out of 1441 snubbers inspected there was only one UNSAT, CC-1-043-013-A43K. This snubber was found with a pipe clamp out of the required maximum 5-degree angle; its As-Found Condition was 8-degrees.

Condition report CR-2019-003979 was issued to evaluate the operability concerns and to correct the noted condition. It was determined by EV-CR-2019-003979-1 that the noted condition had no impact on the operating system. The condition as noted was corrected by work order 5754043.

Note: CPNPP Service life plan.

All 1443 snubbers are evaluated at the close of each Refueling Outage. The last time this was completed was at the end of 1RF20 as required by ISTD-6200 and as recommended by PSA vendor document DR3020.

All 1443 snubbers in the Unit-1 PSA mechanical snubbers DTPG are currently evaluated to 40 years service life, the current licensed life of the plant. To date there have not been any failed snubbers attributed to environmental or operational causes. None of the snubbers in the scope of the Snubber Program are in areas with environmental conditions that would warrant a reduced service life. As noted in this report CPNPP has experienced very few failures, only one failed test and one UNSAT visual in the last ten years. These and any other failures are evaluated under the CPNPP corrective action program for cause and extent of condition. To date none have required a reduction of service life to maintain operational readiness.

Enclosure with TXX-20065 Page 7 of 8 In summary, based on the information provided above, snubber testing has demonstrated that the snubber population at CPNPP Unit 1 is reliable, and there have been no dynamic events or transients at CPNPP Unit 1 or recent operating experience that might affect snubber performance.

Therefore, extending the testing interval for each snubber in the scope of this RR to the next refueling outage scheduled for the spring of 2022 (1RF22) would not adversely impact the function of the snubber or result in a reduction in plant safety.

In the current pandemic environment, performing the required tests would result in an increased risk of virus exposure to plant personnel and a reduction in occupational health and safety without a compensating benefit. Therefore, this one-time RR meets the criteria in 10 CFR 50.55a(z)(2) for relief on the basis that compliance results in hardship or unusual difficulty without a compensating increase in level of quality or safety during the current COVID-19 pandemic.

22. If needed, include additional information for Question 21:

23. Description of the Basis for Use:

Basis for Use As evidenced by the CPNPP Unit 1 operational readiness test history during the past 10 years, the snubber population is well maintained within the examination, testing and service life monitoring program, and are performing well in their environment and operating conditions. There are no planned changes to the snubber environments or operating conditions that would affect the snubbers differently than represented in past surveillance testing. No deficiencies, adverse trends or open maintenance work orders were identified that would impact or degrade any snubbers performance capability and exclude it from this one-time interval extension RR. Each snubber in the scope of this RR will remain within the predicted service life interval, in accordance with ISTD-6100, Predicted Service Life, through 1RF22. Considering the entire snubber population and the current level of acceptable performance, there is reasonable assurance that each snubber will continue to be operationally ready to perform their safety functions during the use of this RR.

In summary, based on the information provided above, snubber testing has demonstrated that the snubber population at CPNPP Unit 1 is reliable, and there have been no dynamic events or transients at CPNPP Unit 1 or recent operating experience that might affect snubber performance.

Therefore, extending the testing interval for each snubber in the scope of this RR to the next refueling outage scheduled for the spring of 2022 (1RF22) would not adversely impact the function of the snubber or result in a reduction in plant safety.

24. If needed, include additional information for Question 23:

25. If requesting an alternative based on 10 CFR 50.55a(z)(2), describe hardship or unusual difficulty without compensating increase in the level of quality and safety associated with compliance with applicable code requirement. For requests under 10 CFR 50.55a(z)(1), leave this section blank.

On March 13, 2020, President Donald Trump declared the Coronavirus (COVID-19) pandemic a national emergency. In addition, Texas Governor Greg Abbott declared a state of disaster due to the COVID-19 pandemic on March 25, 2020. The U.S. Center for Disease Control (CDC) has determined that COVID-19 poses a serious public health risk. The CDC identified most U.S.

states reporting community spread of COVID-19. Currently CPNPP is operating in accordance

Enclosure with TXX-20065 Page 8 of 8 with the CPNPP Pandemic Response Guideline. Due to the COVID-19 pandemic, there is a desire to minimize the potential of inadvertently spreading the COVID-19 virus to CPNPP personnel from outside contractors who perform testing for the snubber program. Due to the potential spread of COVID-19 to CPNPP personnel, Vistra OpCo has identified performance of testing as a hardship without a compensating increase in the level of quality and safety in accordance with 10 CFR 50.55a(z)(2). As an alternative, Vistra OpCo is proposing this One-Time Extension of snubber testing from fall 2020 (1RF21) to spring 2022 (1RF22).

26. Proposed duration of the alternative:

The proposed alternative, upon approval, will be implemented at CPNPP, Unit 1, starting from 1RF21, which is scheduled to begin on October 18, 2020, through the end of Refueling Outage 1RF22, which is scheduled to begin in the spring of 2022.

27. Include any additional information, as necessary:

28. Precedents (optional):

Similar relief to extend snubber testing due to pandemic-related issues was verbally authorized by the NRC on April 4, 2020, to Energy Harbor Nuclear Corporation for Beaver Valley Power Station Unit 2, and to Vistra Energy for Comanche Peak Nuclear Power Plant Unit 2 (TXX-20027

/ CP-2000262) on April 10, 2020 via Verbal Authorization by the NRC Office of Nuclear Reactor Regulation for 10 CFR 50.55a Request L-20-118-SRR-1, Revision 0, Snubber Testing, dated April 3, 2020. (ML20095J099)

29.

References:

1. American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through the 2006 Addenda

2. 10CFR50.55a, Code and standards, June 3, 2020.

30. Do you have attachments?

Yes x Table 1 - Snubber Tests Requested for One-Time Extension to 1RF22

Attachment to Enclosure With TXX-20065 Page 1 of 1 Comanche Peak Unit 1 RELIEF REQUEST NUMBER SNB-1 Table 1 - Snubber Tests Requested for One-Time Extension to 1RF22 Defined Test Snubber Service Life

1. Snubber Component Plan Group Test Test History Model Expiration (DTPG) Required 1 CC-1-030-008-S33K 3 PSA Sample Tested SAT 1RF06 2030 2 CC-1-043-011-A43K 10 PSA Sample Not Tested 2030 3 CC-1-043-022-A33K 3 PSA Sample Not Tested 2030 4 CC-1-066-013-S33K 10 PSA Sample Tested SAT 1RF15 2030 5 CC-1-RB-005-006-3A 1/2 PSA Sample Tested SAT 1RF08 2030 6 CC-1-RB-009-001-3 1/4 PSA Sample Tested SAT 1RF16 2030 7 CS-1-106-706-C42K 1/4 PSA Sample Not Tested 2030 8 SI-1-066-709-C42K 1/4 PSA Sample Tested SAT 1RF04 2030 9 CS-1-252-710-A55K 1/2 PSA Sample Tested SAT 1RF12 2030 10 CS-1-906-038-S42K 1/2 PSA Sample Tested SAT IRF04 2030 11 CS-1-001-006-C42K 1/4 PSA Sample Tested SAT 1RF02 2030 12 FW-1-018-709-C72K 100 PSA Sample Tested SAT 1RF02 2030 13 FW-1-020-704-C42K 100 PSA Sample Not Tested 2030 14 MS-1-004-007-C72KA 100 PSA Sample Tested SAT 1RF06 2030 15 FW-1-097-036-C62K 3 PSA Sample Not Tested 2030 16 FW-1-103-700-S62K 3 PSA Sample Tested SAT 1RF06 2030 17 MS-1-001-007-C72K 35 PSA Sample Not Tested 2030 18 MS-1-002-007-C72K 100 PSA Sample Tested SAT 1RF15 2030 19 CT-1-051-418-C72KA 1 PSA Sample Not Tested 2030 20 DO-1-038-003-S63KA 35 PSA Sample Tested SAT 1RF11 2030 21 MS-1-150-062-C52K 1/4 PSA Sample Not Tested 2030 22 MS-1-344-005-C52K 1 PSA Sample Tested SAT 1RF09 2030 23 MS-1-RB-033-010-2 1/4 PSA Sample Tested SAT 1RF01 2030 24 MS-1-SB-053-015-2 1/4 PSA Sample Tested SAT 1RF05 2030 25 RC-1-052-026-C41K 1 PSA Sample Not Tested 2030 26 RC-1-103-705-C75K 1/4 PSA Sample Not Tested 2030 27 RC-1-112-003-C86K 3 PSA Sample Tested SAT 1RF15 2030 28 RH-1-002-012-C41K 10 PSA Sample Tested SAT 1RF01 2030 29 SI-1-051-024-C42K 1 PSA Sample Tested SAT 1RF18 2030 30 SI-1-091-009-C41K 10 PSA Sample Tested SAT 1RF02 2030 31 SW-1-001-018-F33K 10 PSA Sample Tested SAT 1RF16 2030 32 FW-1-096-701-C62KA 10 PSA Sample Tested SAT 1RF06 2030 33 FW-1-098-013-C62KA 3 PSA Sample Tested SAT 1RF19 2030 34 RC-1-901-701-C82KA 1/4 PSA Sample Tested SAT 1RF15 2030 35 CS-1-RB-024-011-5B 1/2 PSA Sample Tested SAT 1RF08 2030 36 CT-1-097-414-C42KA 1/2 PSA Sample Tested SAT 1RF04 2030 37 MS-1-026-008-S72K 3 PSA Sample Not Tested 2030 NOTE: The service life of all CPNPP Unit 1 snubbers is based on 40 years of expected service, (based on manufacturer's recommendation) and is evaluated each refueling outage to make adjustments, if needed. Due to the performance of the CPNPP Unit 1 snubber population, there has not been a need to adjust the service life of any snubber location to date. In accordance with ISTD-5200 Inservice Operational Readiness Testing, CPNPP implements The 37 Testing Sample Plan for a single DTPG (Defined Test Plan Group) that includes all Unit 1 snubbers. In accordance with ISTD-5400, 37 snubbers are randomly selected for testing each refueling outage from the Unit 1 DTPG of 1,443 snubbers. Since the test sample plan requires a random selection, some snubbers from the DTPG have not been tested.