CP-202100575, (CPNPP) - Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections

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(CPNPP) - Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections
ML21243A232
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/31/2021
From: Thomas McCool
Luminant, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202100575, TXX-21107
Download: ML21243A232 (35)
v • d • e


Text

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

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6042 CP-202100575 TXX-21107 August 31, 2021 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.90 ATTN: Document Control Desk 10 CFR 50.91 Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections"

Reference:

1. Letter to NRC from Thomas P.McCool, Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" dated July 27, 2021

[ADAMS Accession No. ML21208A023]

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Vistra Operations Company LLC ("Vistra OpCo") is supplementing a request for an amendment to the Technical Specifications (TS) for Comanche Peak, Units 1 and 2 made by Reference 1.

Vistra OpCo requests adoption of TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections," which is an approved change to the Standard Technical Specifications (STS), into the Comanche Peak, Units 1 and 2 TS. The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history.

Enclosure 1 provides an Executive Summary of the changes captured in the supplement. Enclosure 2 provides a revised description and assessment of the proposed changes. Attachment 1 provides the markup TS pages. Attachment 2 provides the proposed TS pages. Attachment 3 provides the revised (clean) TS pages. The TS Bases are not affected by the proposed changes.

Vistra OpCo requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Texas Official.

TXX-21107 Page 2 of 2 Should you have any questions, please contact Garry Struble at (254) 897-6628 or Garry.Sh*uble@luminant.com.

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

Executed on August 31, 2021.

Enclosures:

1. Executive Summary
2. Description and Assessment Attachments: 1. Markup Technical Specification Pages [TS 5.5.9 and 5.6.9]
2. Proposed Technical Specification Pages [TS 5.5.9 and 5.6.9]
3. Revised Technical Specification Pages [TS 5.5.9 and 5.6.9]

c (email) - Scott Morris, Region IV [Scott.Morris@mc.gov]

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

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@mc.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. 0. Box 149347 Austin TX, 78714-9347 to TXX-21107 Page 1 of 8 TXX-21107 Enclosure 1 Executive Summary to TXX-21107 Page 2 of 8 ENCLOSURE 1 Executive Summary Based on written feedback from the Comanche Peak Nuclear Power Plant (CPNPP)

NRC Project Manager (PM) the following Executive Summary is provided in response to each line item as shown in the attached review document, (Comanche Peak TSTF-577 LAR L-2021-LLA-0134 TS Markup Review).

General Comments

1. TSTF-577, Revision 1, is referred to as TSTF-577 in the model application, including in the cover letter and Section 1.0. TSTF-577-A is not used in TSTF-577, Revision 1 and is not a standard convention for TSTFs (it is a standard convention for approved topical reports.)

CPNPP Response:

The cover letter and Enclosure 1, Section 1.0 are revised to use only TSTF-577 following the model application.

2. LAR Attachment 2 is not a markup but a proposed revised TS in redline. Thus, it is the same as Attachment 3, except for the red line. It is not useful for comparing with the TSTF-577 changes.

CPNPP Response:

The initial submittal was made as described to facilitate ease of review. Attachment 1 to this submittal provides traditional markups, Attachment 2 provides the proposed change to TS in red, and Attachment 3 provides the revised TS pages .

3. The amendment numbers at the bottom of the page of LAR Attachment 2 should match the current TS amendment numbers. The amendment numbers are linked to the page, not the content.

CPNPP Response:

Amendment numbers at the bottom of each page of the proposed change are matched to the current CPNPP TS.

4. As described below, the NRC staff has identified multiple editorial differences in the markup unrelated to the Comanche Peak Units having different SG models.

The markup should be scrubbed to verify conformance with TS-577, except, as applicable, where adaptations are necessary for the different SG models. Any editorial differences retained should be described in the variations.

to TXX-21107 Page 3 of 8 LAR Attachment 2 TS 5.5 .9

  • "A SG Program shall be .. ." should read "An SG Program shall be ... " consistent with the TSTF.

CPNPP Response:

"A SG Program shall be ... " has been replaced with "An SG Program shall be ... "

TS 5.5.9.a

  • The word "an" before "SG" in the third sentence, which is in the current TSs and the TSTF, was replaced with "a". "an" is the correct word.
  • The word "in" was inserted before "which" in the last sentence that is not in the TSTF or in the courtesy copy markup . This was not identified as a variation .

CPNPP Response:

The word "a" before "SG" in the third sentence, which is not in the current TSs and the TSTF , is replaced with "an."

The word "in" is removed before "which" in the last sentence that is not in the TSTF or in the courtesy copy markup.

Also, removed hyphen from "as-found" in third sentence to match "as found" in second sentence. This is an administrative variation.

TS 5.5.9.b

  • The is a missing space after the 1st comma in the 2nd sentence (can be fixed in clean pages)
  • In Attachment 3, this Section has full justification. Left justification is consistent with the TSTF.

CPNPP Response:

The missing space after the 1st comma in the 2nd sentence is inserted .

Attachment 3 is left justified consistent with the TSTF.

TS 5.5.9.b .1

  • In the first line of both Attachment 2 and Attachment 3, "in service" is missing a hyphen compared to the TSTF.

CPNPP Response:

In the first line of Attachments 2 and 3, "in service" is replaced with "in-service."

to TXX-21107 Page 4 of 8 TS 5.5.9.d

  • It would be appropriate to insert a comma between "inspection methods" and "inspection intervals" (it should read "inspection methods, and inspection intervals"). Inserting the comma would also be consistent with the STS.

CPNPP Response:

Section now reads "inspection methods, and inspection intervals."

TS 5.5.9.d.2

  • In the parentheses in the first sentence in the second paragraph, "thermal" should be replaced with "thermally" . This would make it consistent with the current TS and the courtesy copy markup.

CPNPP Response:

The word "thermal" is replaced with "thermally" in the first sentence of the second paragraph.

TS 5.5.9.d.3

  • In the first sentence, it would be appropriate to retain "the" before degradation.

Should read " ... and potentially affected SG for the degradation mechanism .. . ".

"the degraded mechanism" is used in both the current TSs and the STS.

  • The split of d.3 into two paragraphs could be understood that the last sentence applies only to Unit 2. The paragraphs should be joined along with sentence in the current first paragraph with the first sentence in the second paragraph , using the following or similar words. This would preserve the intent of the TSTF.

o Current: "outage. For Unit 2, "

o New: ""outage, but for Unit 2,"

CPNPP Response:

The first sentence now includes, " ... and potentially affected SG for the degradation mechanism ... "

Section d.3 now has the paragraphs joined to preserve TSTF intent. The wording is revised from "outage. For Unit 2," to "outage, but for Unit 2,".

TS 5.6.9

  • It would be appropriate, though optional, to put "Steam Generator (SG) Program" in quotes to be consistent with the STS. This should be identified as a variation though an administrative change.

to TXX-21107 Page 5 of 8 CPNPP Response:

Steam Generator (SG) Program is now in parentheses. This is listed in Enclosure 1 as an editorial variation.

TS 5.6.9.a

  • The comma should be replaced with a semicolon consistent with TSTF-577.

CPNPP Response:

The comma is replaced with a semicolon .

TS 5.6.9.c.3 and c.4.

  • Since the optional TS 5.6.9.c.5 is not used, an "and" should be added at the end of TS 5.6.9.c.3 and "; and" at the end of TS 5.6 .9.c.4 should be replaced with a period . It is acknowledged that this is not explicit from the TSTF .

CPNPP Response:

An "and" is added to the end of TS 5.6.9.c.3 and a "period" is added to the end of TS 5.6.9.c.4.

TS 5.6.9.g

  • The comma at the end of this item should be replaced with a semicolon to be consistent with TS 5.6 .9.a to f.

CPNPP Response:

TS 5.6.9.g is replaced with what was previously included in TS 5.6.9.h, i, and j as they state identified plant-specific reporting requirements.

TS 5.6.9.h

  • The comma before the "and" at the end of this item should be replaced with a semicolon to be consistent with TS 5.6.9.a to f.

CPNPP Response:

TS 5.6.9.g is replaced with what was previously included in TS 5.6.9 .h, i, and j as they state identified plant-specific reporting requirements.

Attachment 3

  • It is not appropriate to show the change bar for all of TS 5.5.9 and TS 5.6.9 because these whole TSs are not changing .

CPNPP Response:

Change bars are realigned to the specific lines where changes occur.

to TXX-21107 Page 6 of 8 The following documents included in the original submittal under TXX-21083 [ADAMS Accession No. ML21208A023];

1. Enclosure 1, Description and Assessment
2. Attachment 1, Current Technical Specification Pages [TS 5.5.9 and 5.6.9]
3. Attachment 2, Proposed Technical Specification Changes [TS 5.5.9 and 5.6.9]
4. Attachment 3, Revised Technical Specification Pages [TS 5.5.9 and 5.6.9]

are supplemented or replaced by the following documents submitted under TXX-21107;

1. Enclosure 1 , Executive Summary
2. Enclosure 2, Description and Assessment
3. Attachment 1, Markup Technical Specification Pages [TS 5.5.9 and 5.6.9]
4. Attachment 2, Proposed Technical Specification Pages [TS 5.5.9 and 5.6.9]
5. Attachment 3, Revised Technical Specification Pages [TS 5.5.9 and 5.6.9]

to TXX-21107 Page 7 of 8 Comanche Peak TSTF-577 LAR L-2021 -LLA-0134 TS Markup Review General Comments:

  • TSTF-577 , Revision 1, is referred to as TSTF-577 in the model application, including in the cover letter and Section 1.0. TSTF-577-A is not used in TSTF-577, Revision 1 and is not a standard convention for TSTFs (it is a standard convention for approved topical reports.)
  • LAR Attachment 2 is not a markup but a proposed revised TS in redline. Thus it is the same as Attachment 3, except for the redline. It is not useful for comparing with the TSTF-577 changes.
  • The amendment numbers at the bottom of the page of LAR Attachment 2 should match the current TS amendment numbers. The amendment numbers are linked to the page ,

not the content.

  • As described below, the NRG staff has identified multiple editorial differences in the markup unrelated to the Comanche Peak Units having different SG models. The markup should be scrubbed to verify conformance with TS-577, except, as applicable ,

where adaptations are necessary for the different SG models. Any editorial differences retained should be described in the variations.

LAR Attachment 2 TS 5.5.9

  • "A SG Program shall be ... " should read "An SG Program shall be ... " consistent with the TSTF.

TS 5.5.9.a

  • The word "an" before "SG" in the third sentence, which is in the current TSs and the TSTF , was replaced with "a". "an" is the correct word.
  • The word "in" was inserted before "which " in the last sentence that is not in the TSTF or in the courtesy copy markup. This was not identified as a variation.

TS 5.5.9.b

  • The is a missing space after the 1st comma in the 2nd sentence (can be fixed in clean pages)
  • In Attachment 3, this Section has full justification . Left justification is consistent with the TSTF.

TS 5.5 .9.b.1

  • In the first line of both Attachment 2 and Attachment 3, "in service" is missing a hyphen compared to the TSTF .

TS 5.5 .9.d

  • It would be appropriate to insert a comma between "inspection methods" and "inspection intervals" (it should read "inspection methods, and inspection intervals"). Inserting the comma would also be consistent with the STS.

to TXX-21107 Page 8 of 8 TS 5.5.9.d.2

  • In the parentheses in the first sentence in the second paragraph , "thermal " should be replaced with "thermally". This would make it consistent with the current TS and the courtesy copy markup.

TS 5.5 .9.d.3

  • In the first sentence, it would be appropriate to retain "the" before degradation . Should read " .. . and potentially affected SG for the degradation mechanism ... ". "the degraded mechanism" is used in both the current TSs and the STS.
  • The split of d.3 into two paragraphs could be understood that the last sentence applies only to Unit 2. The paragraphs should be joined along with sentence in the current first paragraph with the first sentence in the second paragraph , using the following or similar words. This would preserve the intent of the TSTF.

o Current: "outage. For Unit 2,"

o New: " "outage, but for Unit 2,"

TS 5.6.9

  • It would be appropriate, though optional, to put "Steam Generator (SG) Program" in quotes to be consistent with the STS. This should be identified as a variation though an administrative change.

TS 5.6.9.a

  • The comma should be replaced with a semicolon consistent with TSTF-577 .

TS 5.6 .9.c.3 and c.4 .

  • Since the optional TS 5.6.9.c.5 is not used , an "and " should be added at the end of TS 5.6.9.c.3 and "; and" at the end of TS 5.6.9.c.4 should be replaced with a period. It is acknowledged that this is not explicit from the TSTF.

TS 5.6.9.g

  • The comma at the end of this item should be replaced with a semicolon to be consistent with TS 5.6.9.a to f.

TS 5.6.9.h

  • The comma before the "and" at the end of this item should be replaced with a semicolon to be consistent with TS 5.6 .9.a to f.
  • It is not appropriate to show the change bar for all of TS 5.5.9 and TS 5.6.9 because these whole TSs are not changing .

to TXX-21107 Page 1 of 5 TXX-21107 Enclosure 2 Description and Assessment to TXX-21107 Page 2 of 5 ENCLOSURE 2 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

Vistra Operations Company LLC ("Vistra OpCo") requests adoption of TSTF-577,"Revised Frequencies for Steam Generator Tube Inspections," which is an approved change to the Standard Technical Specifications (STS), into the Comanche Peak, Units 1 and 2 (CPNPP) Technical Specifications (TS). The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation Vistra OpCo has reviewed the safety evaluation for TSTF-577 provided to the Technical Specifications Task Force in a letter dated April 14, 2021. This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-577. As described herein, Vistra OpCo has concluded that the justifications presented in TSTF-577 and the safety evaluation prepared by the NRC staff are applicable to Comanche Peak, Units 1 and 2, and justify this amendment for the incorporation of the changes to the CPNPP TS.

The current SG TS requirements are based on TSTF-510, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection." The Unit 1 SG tubes are made from Thermally Treated Alloy 690 (Alloy 690TT) and the Unit 2 SG tubes are made from Thermally Treated Alloy 600 (Alloy 600TT).

2.2 Variations Vistra OpCo is proposing the following variations from the TS changes described in TSTF-577 or the applicable parts of the NRC staff's safety evaluation:

1) The CPNPP TS utilize different titles than the Standard Technical Specifications on which TSTF-577 was based and those differences are eliminated in the proposed change.

a) The TS Section 5.5.9 program is currently titled, "Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program." It is renamed "Steam Generator (SG) Program," for consistency with TSTF-577 and the Standard Technical Specifications (STS).

b) The TS 5.6.9 report is currently titled , "Unit 1 Model D76 and Unit 2 Model D5 Steam Generator Tube Inspection Report." It is renamed" Steam Generator Tube Inspection Report," for consistency with TSTF-577 and the STS.

to TXX-21107 Page 3 of 5 c) TS 5.5.9, paragraph d.2 contains the periodic inspection requirements for the Unit 2 SGs, and paragraph d.3 contains the periodic inspection requirements for the Unit 1 SGs . The revised periodic inspection requirements are contained in paragraph d.2 with the Unit 1 requirements preceding the Unit 2 requirements . Existing paragraph d.4 is renamed d.3. This improves ease of use and consistency with TSTF-577 and the STS.

These changes are administrative and do not affect the application of the requirements.

2) CPNPP TS 5.5.9, paragraph d.2 contains a one-time inspection interval extension for Unit 2. The extension permits an inspection period of 54 Effective Full Power Months (EFPM). TSTF-577 provides a permanent 54 EFPM inspection period for plants with Alloy 600TT SG tubes. As a result, the extension is not required and is deleted. This is an administrative change.
3) CPNPP TS 5.5.9 , paragraphs d and d.3 contain separate requirements for Unit 1 and Unit 2 due to the differences in the SG tube alloy. Most of these differences are eliminated by TSTF-577 which includes the exception, "except for any portions of the tube that are exempt from inspection by alternate repair criteria." In paragraph d.3 the Alloy 600TT allowance to defer an inspection after detecting cracking is made applicable to only Unit 2. These are administrative changes .
4) CPNPP TS 5.5.9.d , forth sentence currently contains," ... the requirements below

.. ." and TSTF-577 contains," .. . the requirements ofd.1, d.2, and d.3 below .. ."

CPN PP chooses to maintain current verbiage . This is an administrative variation that does not impact the intent of TSTF-577.

5) CPNPP TS 5.6.9, first paragraph contains" ... Specification 5.5.9, Steam Generator (SG) Program ..." in which the title of TS 5.5.9 is not in parentheses . In order to align with the STS, parentheses are added to TS 5.5.9 title as follows; ...

Specification 5.5.9 , "Steam Generator (SG) Program ." This is an administrative change.

The CPNPP SG Program TS currently contains a provision for an alternate tube plugging criteria. The description of the alternate tube plugging criteria in the proposed change is equivalent to the descriptions in the current TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Vistra OpCo requests adoption of TSTF-577 , "Revised Frequencies for Steam Generator Tube Inspections," which is an approved change to the Standard Technical Specifications (STS), into the Comanche Peak, Units 1 and 2 Technical Specifications (TS) . The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history.

to TXX-21107 Page 4 of 5 Vistra OpCo has evaluated if a significant hazards consideration is involved with the p r oposed amendment(s) by focusing on the three standards set forth in 10 CFR 50 .92 ,

"Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The SG inspections are conducted as part of the SG Program to ensure and demonstrate that performance criteria for tube structural integrity and accident leakage integrity are met. These performance criteria are consistent with the plant design and licensing basis. With the proposed changes to the inspection frequencies, the SG Program must still demonstrate that the performance criteria are met. As a result , the probability of any accident previously evaluated is not significantly increased and the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The proposed change does not alter the design function or operation of the SGs or the ability of an SG to perform the design function . The SG tubes continue to be required to meet the SG Program performance criteria . The proposed change does not create the possibility of a new or different kind of accident due to credible new failure mechanisms , malfunctions, or accident initiators that are not considered in the design and licensing bases.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated .

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response : No to TXX-21107 Page 5 of 5 The proposed change revises the inspection frequencies for SG tube inspections and associated reporting requirements. The proposed change does not change any of the controlling values of parameters used to avoid exceeding regulatory or licensing limits. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the U FSAR or the license.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Vistra OpCo concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore , pursuant to 10 CFR 51.22(b), no environmental impact statement or environmenta l assessment need be prepared in connection with the proposed amendment.

to TXX-21107 Page 1 of 8 TXX-21107 Attachment 1 Markup Technical Specification Pages

[TS 5.5.9 and 5.6.9]

to TXX-21107 Programs and Manuals Page 2 of 8 5.5 5.5 Programs and Manuals (continued) 5.5.7 Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendations of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, August 1975. In lieu of Position C.4 .b(1) and C.4.b(2), a qualified in-place UT examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (MT and/or PT) of exposed surfaces of the removed flywheels may be conducted at 20 year intervals.

5.5.8 Deleted 5.5 .9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program An SG Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained . In addition, the SG Steam Generator Program shall include the following :

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" "as found" condition refers to the condition of the tubing duringan SG inspection outage, as determined from the inservice inspection resultsor by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.
b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE .
1. Structural integrity performance criterion: All in-service SG steam generator tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cool down), all anticipated transients included in the design specification, and design basis accidents. This includes retain ing a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute sign ificantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination COMANCHE PEAK - UNITS 1 AND 2 5.5-4 Amendment No. 150, 168 to TXX-21107 Programs and Manuals Page 3 of 8 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (continued) with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
2. Accident induced leakage performance criterion : The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 1 gpm per SG.
3. The operational LEAKAGE performance criterion is specified in LCO 3.4 .13, "RCS Operational LEAKAGE."
c. Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
1. The following alternate tube plugging criteria shall be applied as an alternative to the 40% depth based criteria:
a. For Unit 2 only, tubes with service-induced flaws located greater than 14.01 inches below the top of the tubesheet do not require plugging. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 14.01 inches below the top of the tubesheet shall be plugged upon detection.
d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. For Unit 1, tThe number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except for any portions of the tube that are exempt from inspection by alternate repair 9,

criteri and that may satisfy the applicable tube plugging criteria. For Unit 2, the number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flai.vs of any type (e.g.,

volumetric flai.vs, axial and circumferential cracks) that may be present along the length of the tube from 14.01 inches belov,i the top of the tubesheet on the hot leg side to 14 .01 inches belov,' the top of the tubesheet on the cold leg side and that maysatisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements below, the inspection scope, inspection methods , and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection . A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and ,

based on this assessment, to determine which inspection methods need COMANCHE PEAK- UNITS 1 AND 2 5.5-5 Amendment No. 150, 161, 168 to TXX-21107 Programs and Manuals Page 4 of 8 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (continued) to be employed and at what locations.

1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.
2. For the Unit 1 model Delta-76 SGs (Alloy 690 thermally treated) after the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period .

2 Implement a one time change to TS 5.5.9.d.2, for Unit 2 Cycle 19 only, to inspect each SG at least every 54 effective full power months.

For the Unit 2 model D5 steam generators SGs (Alloy 600 thermally treated) after the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 54 effective full power months, which defines the inspection period . If none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period may be extended to 72 effective full power months. Enhanced probes have a capability to detect flaws of any type equivalent to or better than array probe technology. The enhanced probes shall be used from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except any portions of the tube that are exempt from inspection by alternate repair criteria. If there are regions where enhanced probes cannot be used, the tube inspection techniques shall be capable of detecting all forms of existing and potential degradation in that region. after the first refueling outage follmuing SG installation, inspect each SG at least every 48 effective full pov:er months or at least every other refueling outage (whichever results in more frequent inspections). In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period as defined in a, b, and c belmv. If a degradation assessment indicates the potential for a type of degradation to occur at a location not previously inspected with a technique capable of detecting this type of degradation at this location and that may satisfy the applicable tube plugging criteria, the minimum number of locations inspected 1Nith such a capable inspection technique during the remainder of the inspection period may be prorated. The fraction of locations to be inspected for this potential type of degradation at this location at the end of the inspection period shall be no less than the ratio of the number of times the SG is scheduled to be inspected in the inspection period after the determination that a new form of degradation could potentially be occurring at this location divided by COMANCHE PEAK - UNITS 1 AND 2 5.5-6 Amendment No. 150, 154, 158, 161, 168, 173 to TXX-21107 Programs and Manuals Page 5 of 8 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (continued) the total number of times the SG is scheduled to be inspected in the inspection period .

Each inspection period defined belmv may be extended up to 3 effective full power months to include a SG inspection outage in an inspection period and the subsequent inspection period begins at the conclusion of the included SG inspection outage.

a. /\fter the first refueling outage following SG installation , inspect100%

of the tubes during the next 120 effective full po 1.ver months . This constitutes the first inspection period;

b. During the next 96 effective full po 1.ver months, inspect 100% ofthe tubes . This constitutes the second inspection period; and C. Implement a one time change to TS 5.5.9.d.2.c, for Unit 2 Cycle 19 only, to inspect 100% of the tubes every 90 effectivefull po1,e,rer months .

During the remaining life of the SGs, inspect 100% of the tubes every 72 effective full power months. This constitutes the thirdand subsequent inspection periods .

3. For the Unit 1 model Delta 76 steam generators (Alloy 690 thermally treated) after the first refueling outage following SG installation, inspect each SG at least every 72 effective full power months or at least e1.iery third refueling outage (whichever results in more frequent inspections).

In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period as defined in a, b, c and d below. If a degradation assessment indicates the potential for a type of degradation to occur at a location not previously inspected with a technique capable of detecting this type of degradation at this location and that may satisfy the applicable tube plugging criteria , the minimum number of locations inspected 1,e,rith such a capable inspection technique during the remainder of the inspection period may be prorated. The fraction of locations to be inspected for this potential type of degradation at this location at the end of the inspection period shall be no less than the ratio of the number of times the SG is scheduled to be inspected in the inspection period after the determination that a new form of degradation could potentially be occurring at this location divided by the total number of times the SG is scheduled to be inspected in the inspection period .

Each inspection period defined below may be extended up to 3 effective full po1Ner months to include a SG inspection outage in an inspection period and the subsequent inspection period begins at the conclusion of the included SG inspection outage.

COMANCHE PEAK - UNITS 1 AND 2 5.5-7 Amendment No. 150, 154 , 158, 161 , 168, 173 to TXX-21107 Programs and Manuals Page 6 of 8 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Prog ram (continued)

a. /\fter the first refueling outage following SG installation, inspect100%

of the tubes during the next 14 4 effective full po 11,1er months. This constitutes the first inspection period;

b. During the next 120 effective full po1Ner months, inspect 100%of the tubes. This constitutes the second inspection period; C. During the next 96 effective full power months, inspect 100% ofthe tubes. This constitutes the third inspection period; and
d. During the remaining life of the SGs , inspect 100% of the tubesevery 72 effective full power months. This constitutes the fourth and subsequent inspection periods.
34. For Unit 1, ilf crack indications are found in any SG tube excluding any region that is exempt from inspection by alternate repair criteria , then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indications shall Ret-be at the next exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspections), but for Unit 2, the next inspection may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2. if crack indications are found in any SG tube from 14 .01 inches below the top of the tubesheet on the hot leg side to 14 .01 inches below the top of the tubesheet on the cold leg side, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indications shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspections). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s) , then the indication need not be treated as a crack.
e. Provisions for monitoring operational primary to secondary LEAKAGE.

COMANCHE PEAK - UNITS 1 AND 2 5.5-8 Amendment No. 150, 161, 168, 173 to TXX-21107 Reporting Requirements Page 7 of 8 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

1. WCAP-14040-NP-A; "Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves."
c. The PTLR shall be provided to the NRC upon issuance for each reacto r vessel fluence period and for any revision or supplement thereto.

5.6.7 Not used 5.6.8 PAM Report When a report is required by the required acti.ons of LCO 3.3.3 , "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, "Steam Generator (SG) Program ." The report shall include:

a. The scope of inspections performed on each SG,;
b. Degradation mechanisms found , The nondestructive examination techniques utilized for tubes with increased degradation susceptibility; C. Nondestructive examination techniques utili;z:ed for each degradation mechanism, For each degradation mechanism found:
1. The nondestructive examination techniques utilized;
2. The location, orientation (if linear), measured size (if available) , and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;
3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and
4. The number of tubes plugged during the inspection outage.

COMANCHE PEAK - UNITS 1 AND 2 5.6-5 Amendment No. 150, 154, 158, 161 to TXX-21107 Reporting Requirements Page 8 of 8 5.6 5.6 Reporting Requirements 5.6.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator Tube Inspection Report (continued)

d. Location , orientation (if linear), and measured sizes (if available) of service induced indications , An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria , including the analysis methodology, inputs, and results ;
e. Number of tubes plugged during the inspection outage for each degradation mechanism, The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG steam generator,;
f. The results of any SG secondary side inspections; and
g. The results of condition monitoring , including the results of tube pulls and in situte~

For Unit 2, the primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG , the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection which is the subject of the report; For Unit 2, the calculated accident induced leakage rate from the portion of the tubes below 14.01 inches from the top of the tubesheet for the most limiting accident in the most limiting SG . In addition, if the calculated accident induced leakage rate from the most limiting accident is less than 3.16 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined; and f7 For Unit 2, the results of monitoring for tube axial displacement (slippage). If slippage is discovered , the implications of the discovery and corrective action shall be provided .

COMANCHE PEAK- UNITS 1 AND 2 5.6-6 Amendment No. 150, 154 , 158 to TXX-2107 Page 1 of 6 TXX-21107 Attachment 2 Proposed Technical Specification Pages

[TS 5.5.9 and 5.6.9]

to TXX-21 0 7 Programs and Manuals Page 2 of 6 5.5 5.5 Programs and Manuals (continued) 5.5.7 Reactor Coo llant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendations of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, A u gust 1975. In lieu of Position C.4 .b(1) and C.4.b(2) , a qualified in-place UT examinati on over the volume from the inner bore of the flywheel to the circle one-half of the o u t er radius or a surface examination (MT and/or PT) of exposed surfaces of the remov ed flywheels may be conducted at 20 year intervals.

5.5.8 Deleted 5.5.9 Steam Generator (SG) Program An SG Prog r am shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the SG Program shall include the following :

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.
b. Perfo r mance criteria for SG tube integrity. SG tube integrity shall be maint ained by meeting the performance criteria for tube structural integrity, accid ent induced leakage, and operational LEAKAGE .
1. Structural integrity performance criterion : All in-service SG tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the powerrange , hot standby, and cool down), all anticipated transients includedin the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination COMANCHE PEAK - UNITS 1 AND 2 5.5-4 Amendment No. 150, 168 to TXX-2107 Programs and Manuals Page 3 of 6 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 1 gpm per SG.
3. The operational LEAKAGE performance criterion is specified in LCO 3.4 .13, "RCS Operational LEAKAGE."
c. Provisions for SG tube plugging criteria . Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
1. The following alternate tube plugging criteria shall be applied as an alternative to the 40% depth based criteria:
a. For Unit 2 only, tubes with service-induced flaws located greater than 14.01 inches below the top of the tubesheet do not require plugging . Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 14.01 inches below the top of the tubesheet shall be plugged upon detection.
d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flawsof any type (e.g. , volumetric flaws , axial and circumferential cracks) that may be present along the length of the tube , from the tube-to-tubesheet weld at thetube inlet to the tube-to-tubesheet weld at the tube outlet except for any portions of the tube that are exempt from inspection by alternate repair criteria , and that may satisfy the applicable tube plugging criteria . The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements below, the inspection scope, inspection methods , and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and , based on this assessment, to determine which inspection methods need COMANCHE PEAK - UNITS 1 AND 2 5.5-5 Amendment No. 150, 161, 168 to TXX-2107 Programs and Manuals Page 4 of 6 5.5 5.5 Programs and Manuals 5.5 .9 Steam Generator (SG) Program (continued) to be employed and at what locations.
1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation .
2. For the Unit 1 model Delta-76 SGs (Alloy 690 thermally treated) after the first refueling outage following SG installation , inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period .

For the Unit 2 model D5 SGs (Alloy 600 thermally treated) after the first refueling outage following SG installation , inspect 100% of the tubes in each SG at least every 54 effective full power months, which defines the inspection period . If none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period may be extended to 72 effective full power months. Enhanced probes have a capability to detect flaws of any type equivalent to or better than array probe technology. The enhanced probes shall be used from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except any portions of the tube that are exempt from inspection by alternate repair criteria. If there are regions where enhanced probes cannot be used, the tube inspection techniques shall be capable of detecting all forms of existing and potential degradation in that region.

If crack indications are found in any SG tube excluding any region that is exempt from inspection by alternate repair criteria , then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indications shall be at the next refueling outage but for Unit 2, the next inspection may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2 If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary to secondary LEAKAGE.

COMANCHE PEAK- UNITS 1 AND 2 5.5-6 Amendment No. 150, 161, 168, 173 to TXX-2107 Reporting Requirements Page 5 of 6 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

1. WCAP-14040-NP-A; "Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves."
c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto .

5.6.7 Not used 5.6.8 PAM Report When a report is required by the required actions of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9 , "Steam Generator (SG) Program. " The report shall include:

a. The scope of inspections performed on each SG ;
b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;
c. For each degradation mechanism found:
1. The nondestructive examination techniques utilized;
2. The location, orientation (if linear), measured size (if available), and voltage response for each indication . For tube wear at support structures less than 20 percent through-wall , only the total number of indications needs to be reported ;
3. A description of the condition monitoring assessment and results ,

including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4. The number of tubes plugged during the inspection outage .

COMANCHE PEAK - UNITS 1 AND 2 5.6-5 Amendment No. 150, 154 , 158, 161 to TXX-2107 Reporting Requirements Page 6 of 6 5.6 5.6 Reporting Requ ir-ements 5.6.9 Steam Generator Tube Inspection Report (continued)

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria , including the analysis methodology, inputs, and results;
e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG;
f. The results of any SG secondary side inspections; and
g. For Unit 2, the primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG, the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection which is the subject of the report; For Unit 2, the calculated accident induced leakage rate from the portion of the tubes below 14.01 inches from the top of the tubesheet for the most limiting accident in the most limiting SG . In addition, if the calculated accident induced leakage rate from the most limiting accident is less than 3.16 times the maximum operational primary to secondary leakage rate , the report should describe how it was determined; and For Unit 2, the results of monitoring for tube axial displacement (slippage). If slippage is discovered, the implications of the discovery and corrective action shall be provided.

COMANCHE PEAK - UNITS 1 AND 2 5.6-6 Amendment No. 150, 154 , 158 to TXX-21107 Page 1 of 6 TXX-21107 Attachment 3 Revised Technical Specification Pages

[TS 5.5.9 and 5.6.9]

to TXX-21107 Programs and Manuals Page 2 of 6 5.5 5.5 Programs and Manuals (continued) 5.5.7 Reactor Coolant Pump Flywheel Inspection Program This program shall provide for the inspection of each reactor coolant pump flywheel per the recommendations of Regulatory Position C.4.b of Regulatory Guide 1.14, Revision 1, August 1975. In lieu of Position C.4.b(1) and C.4 .b(2) , a qualified in-place UT examination over the volume from the inner bore of the flywheel to the circle one-half of t he outer radius or a surface examination (MT and/or PT) of exposed surfaces of the removed flywheels may be conducted at 20 year intervals.

5.5.8 Deleted 5.5 .9 Steam Generator (SG) Program An SG Program shall be established and implemented to ensure that SG tube integrity is maintained. In add ition, the SG Program shall include the following :

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found " condition refers to the cond ition of the tubing during an SG inspection outage , as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.
b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational LEAKAGE.
1. Structural integrity performance criterion: All in-service SG tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the powerrange, hot standby, and cool down), all anticipated transients includedin the design specification , and design basis accidents. This includes retaining a safety factor of 3.0 against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination COMANCHE PEAK - UNITS 1 AND 2 5.5-4 Amendment No. 150, 168 to TXX-21107 Programs and Manuals Page 3 of 6 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.
2. Accident induced leakage performance criterion: The primary to secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Leakage is not to exceed 1 gpm per SG .
3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13 , "RCS Operational LEAKAGE ."
c. Provisions for SG tube plugging criteria . Tubes found by inservice inspection to contain flaws with a depth equal to or exceed ing 40% of the nominal tube wall thickness shall be plugged.
1. The following alternate tube plugging criteria shall be applied as an alternative to the 40% depth based criteria:
a. For Unit 2 only, tubes with service-induced flaws located greater than 14.01 inches below the top of the tubesheet do not require plugging. Tubes with service-induced flaws located in the portion of the tube from the top of the tubesheet to 14.01 inches below the top of the tubesheet shall be plugged upon detection.
d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed . The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flawsof any type (e.g. , volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at thetube inlet to the tube-to-tubesheet weld at the tube outlet except for any portions of the tube that are exempt from inspection by alternate repair criteria, and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube . In addition to meeting the requirements below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection . A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need COMANCHE PEAK- UNITS 1 AND 2 5.5-5 Amendment No. 150, 161 , 168 to TXX-21107 Programs and Manuals Page 4 of 6 5.5 5.5 Programs and Man u als 5.5.9 Steam Generator (SG) Program (continued) to be employed and at what locations.
1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.
2. For the Unit 1 model Delta-76 SGs (Alloy 690 thermally treated) after the first refueling outage following SG installation , inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period .

For the Unit 2 model 05 SGs (Alloy 600 thermally treated) after the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 54 effective full power months, which defines the inspection period . If none of the SG tubes have ever experienced cracking other than in regions that are exempt from inspection by alternate repair criteria and the SG inspection was performed with enhanced probes, the inspection period may be extended to 72 effective full power months. Enhanced probes have a capability to detect flaws of any type equivalent to or better than array probe technology. The enhanced probes shall be used from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet except any portions of the tube that are exempt from inspection by alternate repair criteria. If there are regions where enhanced probes cannot be used, the tube inspection techniques shall be capable of detecting all forms of existing and potential degradation in that region.

If crack indications are found in any SG tube excluding any region that is exempt from inspection by alternate repair criteria, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indications shall be at the next refueling outage but for Unit 2, the next inspection may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2 If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing , or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary to secondary LEAKAGE .

COMANCHE PEAK- UNITS 1 AND 2 5.5-6 Amendment No. 150, 161 , 168, 173 to TXX-21107 Reporting Requirements Page 5 of 6 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

1. WCAP-14040-NP-A; "Methodology used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves ."
c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Not used 5.6.8 PAM Report When a report is required by the required actions of LCO 3.3 .3, "Post Accident Monitoring (PAM) Instrumentation ," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring , the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5 .5.9 , "Steam Generator (SG) Program." The report shall include:

a. The scope of inspections performed on each SG ;
b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;
c. For each degradation mechanism found:
1. The nondestructive examination techniques utilized ;
2. The location, orientation (if linear) , measured size (if available), and voltage response for each indication . For tube wear at support structures less than 20 percent through-wall , only the total number of indications needs to be reported ;
3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and
4. The number of tubes plugged during the inspection outage.

COMANCHE PEAK - UNITS 1 AND 2 5.6-5 Amendment No. 150, 154, 158, 161 to TXX-21107 Reporting Requirements Page 6 of 6 5.6 5.6 Reporting Requirements 5.6.9 Steam Generator Tube Inspection Report (continued)

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria , including the analysis methodology, inputs, and results;
e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG;
f. The results of any SG secondary side inspections; and
g. For Unit 2, the primary to secondary leakage rate observed in each SG (if it is not practical to assign the leakage to an individual SG, the entire primary to secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection which is the subject of the report; For Unit 2, the calculated accident induced leakage rate from the portion of the tubes below 14.01 inches from the top of the tubesheet for the most limiting accident in the most limiting SG. In addition , if the calculated accident induced leakage rate from the most limiting accident is less than 3.16 times the maximum operational primary to secondary leakage rate, the report should describe how it was determined; and For Unit 2, the results of monitoring for tube axial displacement (slippage) . If slippage is discovered, the implications of the discovery and corrective action shall be provided.

COMANCHE PEAK- UNITS 1 AND 2 5.6-6 Amendment No. 150, 154 , 158

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