ML20196L829

Relief Request 1A3-2, Inservice Inspection (ISI)

ML20196L829
Person / Time
Site:	Comanche Peak
Issue date:	07/14/2020
From:	Barnette J Vistra Operating Co. (VistraOpCo)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20196L875	List: ML20196L824 ML20196L829
References
Download: ML20196L829 (10)

Text

Attachment 001 to CPNPP ISI Relief Request Relief Request Application for ISI Relief Request

1. Title of Project RELIEF REQUEST - INSERVICE INSPECTION (ISI)

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 227551

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) ISI

13. Proposed Alternative Number or Identifier:

1A3-2

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

ASME Section XI, 2007 Edition through the 2008 Addenda, Rules for Inservice Inspection of Nuclear Power Plant Components. (Ref. 1)

Page 1 of 10 01 to CPNPP ISI Relief Request

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

CPNPP Unit 1 entered its Third ISI Interval on August 13, 2010. CPNPP Unit 1 has utilized the interval extension of as much as one year allowed by IWA-2430 and Code Case N-765. The original end date for the Third Interval for CPNPP Unit 1 was August 12, 2020. By utilizing the one-year extension the end date for the Third Interval for CPNPP Unit 1 was moved to on or before August 12, 2021. As allowed by IWA-2430 and Code Case N-765, the start date of the Fourth Interval for CPNPP Unit 1 is to be maintained at August 13, 2020. During the 1RF21 outage, examinations were scheduled to be performed to satisfy the requirements of both the Third ISI Interval and Fourth ISI Interval for CPNPP Unit 1. However, examinations performed to satisfy requirements of either the Third Interval or Fourth Interval were not to be credited to both intervals.

Completion of the 1RF21 Section XI examinations and tests listed in Table 1 is required to complete the Third Interval. Because the Third ISI Inspection Interval now ends on or before August 12, 2021, 1RF21, currently scheduled for October 18, 2020, is the last scheduled opportunity to perform Section XI examinations and tests within the interval.

ASME Section XI, 2007 Edition through the 2008 Addenda, subparagraph IWA-2430(c)(1) allows interval extensions and states:

(c) For components inspected under the Inspection Program, the following shall apply:

(1) Each inspection interval may be reduced or extended by as much as 1 year. Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals. If an inspection interval is extended, neither the start and end dates nor the inservice inspection program for the successive interval need be revised.

After 1RF21 the next scheduled refueling outage for CPNPP Unit 1 is 1RF22 which is currently scheduled for April 17, 2022. Therefore, the 1-year extension in IWA-2430(c)(1) does not provide CPNPP the flexibility it needs to defer the required Third Interval Section XI examinations and tests from 1RF21 to 1RF22.

16. ASME Code Class ASME Class 1 and 2

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

See Table 1

18. Describe the Applicable Code Requirements:

The Code of Federal Regulations, Title 10, Part 50, Section 55a (Ref. 2) requires United States Nuclear plants to follow the requirements of ASME BPV Code. This requirement is mandated in paragraph (b),

which states in part:

Use and conditions on the use of standards. Systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements of the ASME BPV Code and the ASME OM Code as specified in this paragraph (b).

ASME Section XI, 2007 Edition through the 2008 Addenda, subparagraph IWA-2430(c)(1), which states:

(c) For components inspected under the Inspection Program, the following shall apply:

Page 2 of 10 01 to CPNPP ISI Relief Request (1) Each inspection interval may be reduced or extended by as much as 1 year. Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals. If an inspection interval is extended, neither the start and end dates nor the inservice inspection program for the successive interval need be revised.

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 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 Page 3 of 10 01 to CPNPP ISI Relief Request 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.

CPNPP Unit 1 entered its Third ISI Interval on August 13, 2010. CPNPP Unit 1 has utilized the interval extension of as much as one year allowed by IWA-2430 and Code Case N-765. The original end date for the Third Interval for CPNPP Unit 1 was August 12, 2020. By utilizing the one-year extension the end date for the Third Interval for CPNPP Unit 1 was moved to on or before August 12, 2021. As allowed by IWA-2430 and Code Case N-765, the start date of the Fourth Interval for CPNPP Unit 1 is to be maintained at August 13, 2020. During the 1RF21 outage, examinations were scheduled to be performed to satisfy the requirements of both the Third ISI Interval and Fourth ISI Interval for CPNPP Unit 1. However, examinations performed to satisfy requirements of either the Third Interval or Fourth Interval were not to be credited to both intervals.

Completion of the 1RF21 Section XI examinations and tests listed in Table 1 is required to complete the Third Interval. Because the Third ISI Inspection Interval now ends on or before August 12, 2021, 1RF21, currently scheduled for October 18, 2020, is the last scheduled opportunity to perform Section XI examinations and tests within the interval.

ASME Section XI, 2007 Edition through the 2008 Addenda, subparagraph IWA-2430(c)(1) allows interval extensions and states:

(c) For components inspected under the Inspection Program, the following shall apply:

(1) Each inspection interval may be reduced or extended by as much as 1 year. Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern of intervals. If an inspection interval is extended, neither the start and end dates nor the inservice inspection program for the successive interval need be revised.

After 1RF21 the next scheduled refueling outage for CPNPP Unit 1 is 1RF22 which is currently scheduled for April 17, 2022. Therefore, the 1-year extension in IWA-2430(c)(1) does not provide CPNPP the flexibility it needs to defer the required Third Interval Section XI examinations and tests from 1RF21 to 1RF22.

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

Vistra OpCo is requesting 1 year inspection interval extension as allowed by IWA-2430(c)(1) be increased in accordance with 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 COVID-19 outbreak. As an alternative, Luminant is proposing that the extension allowed by IWA-2430(c)(1) be increased to 24 months due to the hardship caused by the COVID-19 Pandemic.

21. Full Description of the Proposed Alternative:

Proposed Alternative Due to the hardship caused by potential spread of COVID-19 to CPNPP personnel and the surrounding community as well as the travel restrictions and quarantine requirements affecting outside contractors, Luminant is proposing that the one-year inspection interval extension as allowed by IWA-2430(c)(1) be increased in accordance with 10 CFR 50.55a(z)(2). As an alternative, Luminant is proposing that the extension allowed by IWA-2430(c)(1) be increased to 24 months due the hardship caused by the COVID-19 Pandemic.

Page 4 of 10 01 to CPNPP ISI Relief Request Basis for Use As verified by the Inservice Inspection Program at CPNPP Unit 1 there were no significant flaws identified during the previous examination of the items listed in Table 1 that exceeded the applicable acceptance standards or that were outside of allowable evaluation requirements of ASME Section XI. In addition, there have been no known major indications in any ASME Section XI Safety Systems or Components during any ISI examination that had an adverse effect on the safe operation of CPNPP Unit 1. Most recently, this history is supported by the Luminant submittal to the NRC of CPNPP Unit 1 Third Interval OAR-1 Forms for Outages 1RF15, 1RF16, 1RF17, 1RF18, 1RF19 and 1RF20. OAR-1 Forms are Owners Activity Reports prepared in accordance with ASME Code Case N-532-4; this Code Case is an alternative to Section XI reporting requirements and is approved for use by the NRC in Regulatory Guide 1.147.

Prior to the COVID-19 Pandemic, the Third Interval for CPNPP Unit 1 was on track to be completed within the allowable extension timeframe of IWA-2430(c)(1) as required by ASME Section XI. As a result of the COVID-19 circumstances, extension of the Third Interval beyond that allowed by Section XI is necessary.

The impact of extending the CPNPP Unit 1 Third Interval is detailed below.

All examinations and tests required to be completed by ASME Section XI within the Third ISI Inspection Interval will be completed prior to the end of the extended Interval. With the approval of this Proposed Alternative, all applicable ASME Section XI period completion percentages will be maintained, including the following requirements:

ASME Section XI, 2007 Edition through the 2008 Addenda, subparagraph IWA-2430(c)(2) states:

(c) For components inspected under the Inspection Program, the following shall apply:

(2) Examinations may be performed to satisfy the requirements of the extended period or interval in conjunction with examinations performed to satisfy the requirements of the successive period or interval. However, an examination performed to satisfy requirements of either the extended period or interval or the successive period or interval shall not be credited to both periods and intervals.

Therefore, if this Proposed Alternative were to be approved, examinations and tests for both the Third ISI Interval and Fourth ISI Interval could be completed concurrently during 1RF22 if any given examination is not credited to both Intervals.

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

23. Description of the Basis for Use:

Operations Monitoring Technical Specifications (TS) 3.4.13, RCS Operational LEAKAGE, for each Unit, limits system operation in the presence of leakage from Reactor Coolant System (RCS) components to leakage amounts that do not compromise safety. Surveillance Requirement (SR) 3.4.13.1 requires the performance of RCS water inventory balance to verify RCS leakage is within limits to ensure that the integrity of the Reactor Coolant Pressure Boundary (RCPB) is maintained.

Per LCO 3.4.13 RCS operational LEAKAGE shall be limited to no pressure boundary LEAKAGE and 1 gpm unidentified LEAKAGE.

Page 5 of 10 01 to CPNPP ISI Relief Request Procedure OPT-303, Reactor Coolant System Water Inventory, Attachment 10.2, RCS Live Leakrate Action Levels and Response Guidelines, provides the steps that would be taken to satisfy TS SR 3.4.13.1 by performance of an RCS water inventory balance. A summary of the steps is seen below in A through E:

A. Action Levels based on Absolute Value of Unidentified RCS Inventory Balance (From Surveillance Data)

Entrance Criteria ACTION LEVEL One seven (7) day rolling average of LEVEL 1 Unidentified RCS Inventory Balance values >

0.1 gpm Two consecutive Unidentified RCS Inventory LEVEL 2 values > 0.15 gpm One Unidentified RCS Inventory Balance value LEVEL 3

> 0.3 gpm B. Action Levels based on Deviation from the Baseline Mean:

Entrance Criteria ACTION LEVEL Nine (9) consecutive Unidentified RCS LEVEL 1 Inventory Balance values > baseline mean []

Two (2) of three (3) consecutive Unidentified LEVEL 2 RCS Inventory Balance Values > [ + 2],

where is the baseline standard deviation One (1) Unidentified RCS Inventory Balance > LEVEL 3

[ + 3]

C. Exit Criteria following Action Level Entry:

Exit Criteria x Location of RCS leak has been identified AND Leak terminated (isolated or stopped) - confirmed by RCS leak rate and VCT level trends OR x A minimum of 2 daily leak rates with indicated leakage less than the applicable Action Level AND Ops Department and Engineering staff recommend exiting the applicable Action Level D. For any ACTION LEVEL response:

1) Run confirmatory leak rate calculation

2) Confirm indication

3) Evaluate trend of affected parameters

4) Check for abnormal trend of other leakage indicators Page 6 of 10 01 to CPNPP ISI Relief Request E. IF confirmed:

1) Increase monitoring of leakage indicators

2) Initiate a Condition Report to document investigation and results in an EVAL

3) Commence a leak investigation x IF ACTION LEVEL 1, search for sources as resources allow x IF ACTION LEVEL 2, search for sources, continue 24 hour/day, 7 days/week until cause determined x IF ACTION LEVEL 3, search for sources, continue 24 hour/day, 7 days/week until cause determined. At 0.50 gpm sustained leakage, the Shift Manager should consult with the Duty Manager to consider an orderly shutdown to Mode 3.

x Initiate logbook detailing all systems and rooms inspected for leakage with findings. All rooms should be inspected with a thermographic camera (Fire Brigade or Engineering camera).

x Track all inspections on copies of system drawings, denoting piping and valves inspected.

x Review recent plant evolutions to determine any suspect source(s).

x Check any components or flow paths recently changed or placed in service, shutdown, vented, drained, filled, etc.

x Check any maintenance activity that may have resulted in increasing leakage.

x Check RCS and seal injection filter seals, vents, and drains for leakage (most common source of leakage).

x Check any filters recently alternated or changed for leakage from their vents or drains, inspect filter housings for gasket leaks, check seal injection filters and reactor coolant filters for signs of leakage.

x Scrutinize sump pump run times, sample trends, and rad monitor readings.

x Divide the primary plant into several large groups for investigation. (e.g. Leakage to atmosphere inside containment, S/G primary to secondary leakage, leakage to atmosphere outside containment, inter system leakage) x Scrutinize tank levels and trends (eg., RHUT, RCDT, PRT and SRST), utilizing temporary indication if necessary.

x Check SI and RHR check valves for small leaks.

x Initiate outside Containment walk-downs of various portions of potentially affected systems.

x Notify System Engineer to obtain input/assistance.

4) IF increased leak rate is indicated inside Containment, THEN:

x Begin planning for Containment entry while carrying out other actions; obtain proper approval for Containment entry.

x Obtain a Containment Sump sample (during pump out) and analyze for activity, a larger than expected boric acid concentration and other unexpected chemicals.

x Evaluate other systems for indications of leakage.

x Obtain a Containment atmosphere sample for indications of RCS leakage.

x Perform a Containment entry to search for signs of leakage.

x If necessary, utilize robot to perform loop room inspections.

5) Identify the source of the increase in leakage.

6) Quantify the leakage.

7) Initiate plan to correct the leak.

Page 7 of 10 01 to CPNPP ISI Relief Request

8) Monitor Containment airborne radiation levels as well as area radiation monitors and sample Containment atmosphere for indications of RCS leakage.

9) Monitor other Containment parameters (temperature, pressure, humidity, etc.).

10) If the leak source is found and isolated or stopped, re-perform RCS leak rate calculation.

In addition to surveillance required monitoring, Operations continually monitors the RCS leak rate through control board metering and trend graphing capability. Instrumentation such as pressurizer level, sump levels, containment pressure and humidity instruments, and many others are monitored on a continuous basis and are logged and reviewed each shift.

Administrative controls Administrative procedures require monitoring of RCS leakage under the Boric Acid Corrosion Control Program (BACCP) on a per cycle basis. The program also addresses abnormal trends in RCS primary system leakage indicators, which may provide indication of leaks much smaller than TS and RCS leakage levels.

CPNPP monitors the following containment building/system parameters during the operating cycle to determine any potential leakage from borated or radioactive systems containing boric acid:

Unidentified Reactor Coolant System Leakage:

This parameter monitors unidentified reactor coolant system leakage both inside and outside of containment. The purpose is to review the data graph for trends in leakage and assess if any increases are indication of borated system leakage in Unit 1 containment.

Containment Air Particulate and Gaseous Concentration:

Radiochemistry analysis are performed of the containment atmosphere for each vent process. The vent process is performed approximately every three days and can identify changes in containment activity.

The isotope for detecting increase leakage is noble gas Argon-41. Argon-41 is a short-lived isotope that can be readily monitored to detect small increases or upward trends in leakage. From this parameter, an increase in borated system leakage in the Unit 1 containment can be detected.

Containment Air Cooler Condensate Flow and Containment Sump Level/Pump Rates:

The containment air cooler condensate flow is not separately measured but flows to the containment sumps. Therefore, the reported sump flow rates include the containment air cooler condensate flows.

Review of monthly Unit 2 sump pump volumes for this operating cycle are performed to determine if any upward trend in daily pump volume rates are observed. An increased pump rate could indicate leakage from borated systems in Unit 1 containment.

Containment Humidity/Dew Point Temperatures:

The Unit 1 containment has five area dew point temperature sensors at containment elevations 832, 860, and 905, as well as the Control Rod Drive Mechanism shroud and the reactor coolant pipe penetrations.

Weekly dew point temperature measurements during plant operation are performed to monitor changes in temperature that could be indicative of leakage from borated systems in containment. Minor changes in temperature, both up and down, are gradual and are considered to be normal due to seasonal variations.

Page 8 of 10 01 to CPNPP ISI Relief Request Continued monitoring of these parameters will provide early indication of any abnormal unidentified leakage during the upcoming cycle following 1RF21.

Other Considerations Visual examinations of borated systems will be performed by the Boric Acid Corrosion Control Program (BACCP) during 1RF21.

The ISI Pressure Testing Program will implement the Class 1 System Leakage Test required by ASME Section XI Examination Category B-P, Item Number B15.10 at NOP/NOT during heatup from 1RF21; VT-2 Visual Examination will be performed during the test.

Operations looks for leakage during their shiftly tours which includes ASME Section XI piping/components located outside of containment.

Any gross leakage (i.e. water, boric acid, insulation deformation) or structural deformities would be identified during the above examinations/activities and captured in the Corrective Action Program.

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 the majority of U.S. states reporting community spread of COVID-19. Currently CPNPP is operating in accordance 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 examinations and testing for the ISI and IST programs. Due to the potential spread of COVID-19 to CPNPP personnel, Vistra OpCo has identified performance of these examinations and 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 to delay the inspections for one refueling cycle from fall 2020 (1RF21) to spring 2022 (1RF22).

These examinations in the Unit 1 ISI program are delineated by American Society of Mechanical Engineers (ASME) section IWA-2430(c)(1).

26. Proposed duration of the alternative:

If approved, the proposed alternative will be implemented at CPNPP Unit 1 starting from the existing Third Interval end date of August 12, 2020 to the end of the approved 24-month extension.

27. Include any additional information, as necessary:

Page 9 of 10 01 to CPNPP ISI Relief Request

28. Precedents (optional):

Relief Request, 2A3-2, was submitted by Vistra Operations Company, LLC for deferral of Section XI requirements at Comanche Peak Nuclear Power Plant, Unit 2 due to COVID-19 issues, see Accession Nos.

ML20099D059 and ML20101L082 and Verbal Authorization per Accession No. ML20104A001.

29.

References:

1. American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section Xl, 2007 Edition through 2008 Addenda

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

30. Do you have attachments?

Yes x Full text of the CPNPP ISI Relief Request x 1RF21 ISI Relief Request 1A3-2 Table 1 Page 10 of 10