CP-202000686, Supplement to Exigent License Amendment Request (LAR) 20-007 Revision to Technical Specification (TS) 3.7.8, Station Service Water System and TS 3.8.1, AC Sources - Operating

Supplement to Exigent License Amendment Request (LAR)20-007 Revision to Technical Specification (TS) 3.7.8, Station Service Water System and TS 3.8.1, AC Sources - Operating

ML20351A237
Person / Time
Site:	Comanche Peak
Issue date:	12/16/2020
From:	Thomas McCool Luminant, Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202000686, TXX-20107
Download: ML20351A237 (3)

Text

Thomas P. McCool Comanche Peak Gt Site Vice President Nuclear Power Plant (Vistra Operations Company LLC)

Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6042 CP-202000686 TXX-20107 December 16, 2020 U. S. Nuclear Regulatory Commission Ref 10CFR50.90 ATTN: Document Control Desk 10 CFR 50.91(b)(l)

Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Supplement to Exigent License Amendment Request (LAR)20-007 Revision to Technical Specification (TS) 3.7.8, "Station Service Water System" And TS 3.8.1, "AC Sources - Operating"

Reference:

1. Letter TXX-20086 from Thomas P. McCool to the NRC "Exigent License Amendment Request (LAR)20-007, Revision to Technical Specification (TS) 3.7.8, "Station Service Water System" And TS 3.8.1, "AC Sources - Operating," dated November 19, 2020 (ML20324A627)

Dear Sir or Madam:

Pursuant to 10 CFR 50.90 and 10 CFR 50.91, Vistra Operations Company LLC (Vistra OpCo) hereby submits a supplement to the exigent license amendment request (LAR) to the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and Unit 2 Technical Specifications in connection to LAR 20-007, Revision to Technical Specification 3.7.8, "Station Service Water System," and 3.8.1, "AC Sources - Operating," in Reference 1.

As a result of subsequent communications between the Nuclear Regulatory Commission and Vistra OpCo, Attachment 1 of TXX-20107 provides additional clarification of statements in Section 3.5.1 of the Enclosure to Reference 1 and Note 4 of Attachment 6 of Reference 1.

Vistra OpCo has determined that this supplement does not change the No Significant Hazards Consideration provided in the Enclosure submitted by Reference 1.

In accordance with 10 CFR 50.91(b)(l), a copy of the proposed license amendment is being forwarded to the State of Texas.

This letter contains no new regulatory commitments.

TXX-20107 Page 2 of2 Should you have any questions, please contact Carl Corbin at (254) 897-0121 or carl.corbin@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Executed on December 16, 2020.

Thomas P. McCool

Attachment:

1. Response to NRC Question 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]

Mr. Robert Free [robert.free@dshs.state.tx.us]

Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P.O. Box 149347 Austin, TX 78714-9347 to TXX-20107 Page 1of1 Response to NRC Question NRC Question:

On page 25 of 37, in section 3.5.1 [Enclosure 1 to TXX-20086 / ML20324A627], the application states, "No quantitative credit was taken in the PRA analysis for any of the proposed compensatory measures." In Note 4 of Attachment 6 [to TXX-20086 /

ML20324A627], the application states that no T&M is allowed on protected train equipment or the TDAFW pump. These two statements appear to contradict each other.

As a result, the staff would like to confirm the licensee's treatment of proposed compensatory measures in the licensee's PRAs used to develop risk insights.

Comanche Peak Nuclear Power Plant (CPNPP) Response:

CPNPP's normal work processes include scheduling all voluntary test and maintenance activities on one of the two trains for a given work week. No voluntary maintenance is normally performed on the other train (the protected train). Further, when certain components are removed from service, including the Station Service Water (SSW) pump, these processes restrict work on the turbine-driven Auxiliary Feedwater (AFW) pump. These normal work processes are not considered to be compensatory measures.

The PRA risk insights are based on the inclusion of these normal work processes.

However, no quantitative credit was taken in the PRA analysis for any of the proposed compensatory measures identified in the License Amendment Request submittal, such as hot work and transient combustible restrictions, roving fire watches, etc.