ML21132A089
| ML21132A089 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  (NPF-087, NPF-089) |
| Issue date: | 06/09/2021 |
| From: | Dennis Galvin Plant Licensing Branch IV |
| To: | Peters K Vistra Operations Company |
| Galvin D | |
| References | |
| EPID L-2020-LLA-0196 | |
| Download: ML21132A089 (27) | |
Text
June 9, 2021 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC Comanche Peak Nuclear Power Plant 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 -
ISSUANCE OF AMENDMENT NOS. 181 AND 181 REGARDING THE ADOPTION OF TSTF-567, REVISION 1, ADD CONTAINMENT SUMP TS TO ADDRESS GSI-191 ISSUES (EPID L-2020-LLA-0196)
Dear Mr. Peters:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 181 to Facility Operating License No. NPF-87 and Amendment No. 181 to Facility Operating License No. NPF-89 for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak), respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated August 31, 2020, as supplemented by "CP-202000585, (CPNPP) - Supplement to License Amendment Request (LAR)20-005, Revision to [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Containment Sump|letter dated January 27, 2021]].
The amendments revise the Comanche Peak TSs to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI [Generic Safety Issue]-191 Issues.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Dennis J. Galvin, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosures:
- 1. Amendment No. 181 to NPF-87
- 2. Amendment No. 181 to NPF-89
- 3. Safety Evaluation cc: Listserv
COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 181 License No. NPF-87
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Vistra Operations Company LLC (Vistra OpCo) dated August 31, 2020, as supplemented by "CP-202000585, (CPNPP) - Supplement to License Amendment Request (LAR)20-005, Revision to [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Containment Sump|letter dated January 27, 2021]], complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-87 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 181 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Vistra OpCo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License and Technical Specifications Date of Issuance: June 9, 2021 Samson S.
Lee Digitally signed by Samson S. Lee Date: 2021.06.09 15:23:29 -04'00'
COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 181 License No. NPF-89
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Vistra Operations Company LLC (Vistra OpCo) dated August 31, 2020, as supplemented by "CP-202000585, (CPNPP) - Supplement to License Amendment Request (LAR)20-005, Revision to [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Containment Sump|letter dated January 27, 2021]], complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-89 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 181 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Vistra OpCo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License and Technical Specifications Date of Issuance: June 9, 2021 Samson S.
Lee Digitally signed by Samson S. Lee Date: 2021.06.09 15:22:36 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 181 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 181 TO FACILITY OPERATING LICENSE NO. NPF-89 COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of Facility Operating License Nos. NPF-87 and NPF-89, and the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Operating License No. NPF-87 REMOVE INSERT 3
3 Facility Operating License No. NPF-89 REMOVE INSERT 3
3 Technical Specifications REMOVE INSERT 3.5-6 3.5-6 3.5-8 3.5-8 3.6-19 3.6-20 5.5-14 5.5-14
(3)
Vistra OpCo, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level Vistra OpCo is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal through Cycle 13 and 3612 megawatts thermal starting with Cycle 14 in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 181 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Vistra OpCo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
Unit 1 Amendment No. 181
(3)
Vistra OpCo, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time, special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, and described in the Final Safety Analysis Report, as supplemented and amended; (4)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use, at any time, any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source, and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)
Vistra OpCo, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level Vistra OpCo is authorized to operate the facility at reactor core power levels not in excess of 3458 megawatts thermal through Cycle 11 and 3612 megawatts thermal starting with Cycle 12 in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 181 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. Vistra OpCo shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions DELETED Unit 2 Amendment No. 181
SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.2.2 SR 3.5.2.3 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 Verify each ECCS manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
Verify ECCS piping is full of water.
Verify each ECCS pump's developed head at the test flow point is greater than or equal to the required developed head.
Verify each ECCS automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
Verify each ECCS pump starts automatically on an actual or simulated actuation signal.
Verify, for each ECCS throttle valve listed below, each mechanical position stop is in the correct position.
Valve Number 8810A 8810B 8810C 8810D 8816A 8816B 8816C 8816D 8822A 8822B 8822C 8822D ECCS -- Operating 3.5.2 In accordance with the Surveillance Frequency Control Program.
Prior to entry into MODE 3 In accordance with the INSERVICE TESTING PROGRAM In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program.
COMANCHE PEAK - UNITS 1 AND 2 3.5-6 Amendment No. 150, 156, 168, 181
ECCS -- Shutdown 3.5.3 SURVEILLANCE REQUIREMENTS SR 3.5.3.1 SURVEILLANCE FREQUENCY The following SRs are applicable for all equipment required In accordance with to be OPERABLE:
applicable SRs SR 3.5.2.1 SR 3.5.2.4 SR 3.5.2.7 COMANCHE PEAK - UNITS 1 AND 2 3.5-8 Amendment No. 150, 156, 181
3.6 CONTAINMENT SYSTEMS 3.6.8 Containment Sump Containment Sump 3.6.8 LCO 3.6.8 Two containment sumps shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4 ACTIONS CONDITION A. One or more containment sumps inoperable due to containment accident generated and transported debris exceeding the analyzed limits.
REQUIRED ACTION COMPLETION TIME A.1 Initiate action to mitigate containment Immediately accident generated and transported debris.
A.2 Perform SR 3.4.13.1.
Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND A.3 Restore the containment sumps to 90 days OPERABLE status.
COMANCHE PEAK - UNITS 1 AND 2 3.6-19 Amendment No. 181 AND
ACTIONS (continued)
CONDITION REQUIRED ACTION B. One or more containment 8.1 -------------------NOTES------------------
sumps inoperable for reasons other than Condition A.
Shutdown," for emergency core cooling trains made inoperable by the containment sumps.
- 2. Enter applicable Conditions and Required Actions of LCO 3.6.6, "Containment Spray System," for containment spray trains made inoperable by the containment sumps.
C. Required Action and C.1 Be in MODE 3.
associated Completion Time not met.
AND C.2 Be in MODE 5.
SURVEILLANCE REQUIREMENTS SURVEILLANCE Containment Sump 3.6.8 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> FREQUENCY SR 3.6.8.1 Verify, by visual inspection, the containment sumps do not show structural damage, abnormal corrosion, or debris blockage.
In accordance with the Surveillance Frequency Control Program.
COMANCHE PEAK - UNITS 1 AND 2 3.6-20 Amendment No. 181 Restore the containment sumps to OPERABLE status.
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 5.5.16 Safety Function Determination Program (SFDP) (continued) b.
A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:
1.
A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or 2.
A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or 3.
A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.
c.
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
Containment Leakage Rate Testing Program a.
A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"
Revision 3-A, dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2A, dated October 2008, as modified by the following exceptions:
1.
The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRG.
2.
The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRG.
COMANCHE PEAK - UNITS 1 AND 2 5.5-14 Amendment No. 150, 161, 165, 168, 173, 181
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 181 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 181 TO FACILITY OPERATING LICENSE NO. NPF-89 COMANCHE PEAK POWER COMPANY LLC AND VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-445 AND 50-446
1.0 INTRODUCTION
By application dated August 31, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20244A338), as supplemented by "CP-202000585, (CPNPP) - Supplement to License Amendment Request (LAR)20-005, Revision to [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Containment Sump|letter dated January 27, 2021]] (ADAMS Accession No. ML21027A249), Vistra Operations Company LLC (the licensee) submitted a license amendment request (LAR) for Comanche Peak Nuclear Power Plant, Units 1 and 2 (Comanche Peak).
The amendments would revise Comanche Peak Technical Specification (TS) 3.5.2, ECCS
[Emergency Core Cooling System] - Operating; TS 3.5.3, ECCS - Shutdown; and TS 5.5.15, Safety Function Determination Program (SFDP). The proposed changes would also add a new TS, Containment Sump, to Section 3.6, Containment Systems. The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI [Generic Safety Issue]-191 Issues, dated August 2, 2017 (ADAMS Accession No. ML17214A813). The U.S. Nuclear Regulatory Commission (NRC, the Commission) issued a final safety evaluation (SE) approving TSTF-567, Revision 1, on July 3, 2018 (ADAMS Accession No. ML18116A606).
The licensee proposed a variation in numbering from the TS changes described in TSTF-567, Revision 1. The variations are described in Section 2.2.5 and evaluated in Section 3.5 of this SE.
2.0 REGULATORY EVALUATION
2.1 System Description and TS Changes The TSs include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
Specified with each stated condition of the LCO are required action(s) and completion time(s) (CT) to meet TS requirements.
2.1.1 TS 3.5.2, ECCS - Operating The function of the ECCS is to provide core cooling and negative reactivity to ensure the reactor core is protected after any of the following accidents:
- a. loss-of-coolant accident (LOCA), coolant leakage greater than the capability of the normal charging system;
- b. rod ejection accident;
- c. loss of secondary coolant accident, including uncontrolled steam release or loss of feedwater; and
- d. steam generator tube rupture.
Comanche Peak TS 3.5.2 is applicable in Modes 1, 2, and 3 and requires that two independent ECCS trains be operable to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train.
TS 3.5.2 helps ensure the following acceptance criteria for ECCS, established by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors, will be met following a LOCA:
- a. Maximum fuel element cladding temperature is less than or equal to () 2200 degrees Fahrenheit.
- b. Maximum cladding oxidation is 0.17 times the total cladding thickness before oxidation.
- c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react.
- d. Core is maintained in a coolable geometry.
- e. Adequate long-term core cooling capability is maintained.
TS 3.5.2 also limits the potential for a post-trip return to power following a main steam line break event and ensures that containment temperature limits are met.
2.1.2 TS 3.5.3, ECCS - Shutdown Comanche Peak TS 3.5.3 is applicable in Mode 4 and requires one of the two independent (and redundant) ECCS trains to be operable to ensure that sufficient ECCS flow is available to the core following a design-basis accident.
2.1.3 TS 5.5.15, Safety Function Determination Program (SFDP)
Comanche Peak TS 5.5.15 establishes the SFDP, which implements the requirements of LCO 3.0.6. The SFDP ensures that loss of safety function is detected and that appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists. Additionally, other appropriate actions may be taken as a result of the support system inoperability and corresponding exception to entering a supported system(s) condition(s) and required action(s).
2.2 Proposed Changes to the TSs The proposed changes would revise Comanche Peak TSs 3.5.2, 3.5.3, and 5.5.15. The proposed changes would also add a new TS to Section 3.6. The proposed changes are described below.
2.2.1 Proposed Changes to TS 3.5.2, ECCS - Operating Comanche Peak TS 3.5.2 currently contains Surveillance Requirement (SR) 3.5.2.8, which requires the following at a frequency in accordance with the Surveillance Frequency Control Program (SFCP):
Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.
The licensee proposed to modify and move SR 3.5.2.8 from TS 3.5.2 and include it in the new containment sump TS.
This change is evaluated in Section 3.1 of this SE.
2.2.2 Proposed Changes to TS 3.5.3, ECCS - Shutdown Comanche Peak TS 3.5.3 currently contains SR 3.5.3.1, which refers to applicable SRs under TS 3.5.2. One of those referenced SRs is SR 3.5.2.8, as described in Section 2.2.1 of this SE.
Because the licensee proposed to modify and move SR 3.5.2.8 from TS 3.5.2 and include it in the new containment sump TS, the licensee also proposed to delete the reference to SR 3.5.2.8 in SR 3.5.3.1.
This change is evaluated in Section 3.2 of this SE.
2.2.3 Proposed Change to TS 5.5.15, Safety Function Determination Program (SFDP)
The licensee proposed to add the following sentence at the end of Comanche Peak TS 5.5.15:
When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
This change is evaluated in Section 3.3 of this SE.
2.2.4 Proposed Addition of a New Containment Sump TS The licensee proposed to add TS 3.6.8, which requires the containment sumps to be operable during Modes 1, 2, 3, and 4. Condition A specifies that if the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits, then the licensee is required to: (1) initiate action to mitigate the containment accident generated and transported debris immediately, (2) perform SR 3.4.13.1 once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and (3) restore the containment sump to OPERABLE status within 90 days (Required Actions A.1, A.2, and A.3, respectively).. Comanche Peak SR 3.4.13.1 requires verification that the reactor coolant system (RCS) operational leakage is within limits by performance of an RCS water inventory balance.
TS 3.6.8, Condition B, specifies that if the containment sumps are inoperable for reasons other than Condition A, then the licensee is required to restore the containment sumps to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Required Action B.1). Required Action B.1 is modified by two notes, which direct entering the applicable conditions and required actions of LCOs 3.5.2 and 3.5.3 for ECCS trains made inoperable by the containment sump and entering the applicable conditions and required actions of TS LCO 3.6.6, Containment Spray System, for containment spray and cooling system (CSS) trains made inoperable by the containment sump.
TS 3.6.8, Condition C, specifies that if required actions and associated CTs under Condition A and B are not met, then the licensee is required to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (Required Actions C.1 and C.2, respectively).
The licensee proposed to modify and move SR 3.5.2.8 currently located in TS 3.5.2. The new SR 3.6.8.1 requires the licensee to [v]erify, by visual inspection, the containment sumps do not show structural damage, abnormal corrosion, or debris blockage, in accordance with the SFCP.
Comanche Peaks containment sump design includes more than one containment sump. Each unit has two containment sumps. Each sump/strainer provides flow to the suction of a single safety train. The sumps provide suction for the residual heat removal and containment spray pumps. The sumps are considered part of a single support system because containment accident generated and transported debris issues that would render one sump inoperable would render all of the sumps inoperable. The new containment sump TS proposed in Traveler TSTF-567, Revision 1, is applicable to plants that have more than one containment sump.
This change is evaluated in Section 3.4 of this SE.
2.2.5 Variations from TSTF-567, Revision 1 The Comanche Peak TSs utilize different numbering than the Standard TSs on which TSTF-567, Revision 1, was based. Specifically, the proposed containment sump TS number from TSTF-567, Revision 1, is 3.6.19 while the proposed number for Comanche Peak is 3.6.8.
This difference is editorial and does not affect the applicability of TSTF-567, Revision 1, to the proposed LAR. The proposed new containment sump TS number (3.6.8) for the plant is used throughout this SE.
The Comanche Peak TSs contain a SFCP. Therefore, the frequency for SR 3.6.8.1 states, In accordance with the Surveillance Frequency Control Program.
2.3 Applicable Regulatory Requirements and Guidance 2.3.1 Regulatory Requirements The regulation at 10 CFR Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include proposed TSs in the application. That regulation also states, in part, that [a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.
The regulation at 10 CFR 50.36(b) requires:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.
The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation at 10 CFR 50.36(c)(2)(i) requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.
The regulation at 10 CFR 50.36(c)(3) requires TSs to include SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.
The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
2.3.2 Regulatory Guidance The guidance that the NRC staff considered in its review of this LAR included the following:
NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16.0, Technical Specifications, dated March 2010 (ADAMS Accession No. ML100351425),
provides guidance on review of TSs.
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
3.0 TECHNICAL EVALUATION
3.1 Proposed Changes to TS 3.5.2, ECCS - Operating The licensee proposed to modify and move SR 3.5.2.8 from Comanche Peak TS 3.5.2 to the new containment sump TS. Therefore, the licensee proposed deletion of SR 3.5.2.8.
The new SR 3.6.8.1 does not limit the visual inspection to the suction inlet, trash racks and screens as currently required by the TSs, but instead requires inspection of the entire containment sump system. The containment sump system consists of the containment drainage flow paths, any design features upstream of the containment sump that are credited in the containment debris analysis, the containment sump strainers (or screens), the pump suction trash racks, and the inlet to the ECCS and CSS piping.
The NRC staff concludes that the proposed change is acceptable because the existing requirements are either unchanged or expanded and continue to ensure the containment sump is unrestricted (i.e., unobstructed) and stays in proper operating condition. The proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides an SR to assure the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met.
3.2 Proposed Changes to TS 3.5.3, ECCS - Shutdown The licensee proposed to delete the reference to SR 3.5.2.8 in SR 3.5.3.1.
The NRC staff concludes that the proposed change is acceptable since SR 3.5.2.8 was modified and moved to the new containment sump TS. The existing SR on the containment sump is augmented (by requiring inspection of additional sump components) and moved to the new specification, and a duplicative requirement to perform the SR in TS 3.5.3 is removed. The new specification retains or expands the existing requirements on the containment sump and the actions to be taken when the containment sump is inoperable with the exception of adding new actions to be taken when the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits. The new action provides time to evaluate and correct the condition instead of requiring an immediate plant shutdown. The proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met.
3.3 Proposed Changes to TS 5.5.15, Safety Function Determination Program (SFDP)
Comanche Peak LCO 3.0.6 states:
When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, Safety Function Determination Program (SFDP). If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support systems Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
When a loss of safety function is determined to exist, the SFDP requires entry into the appropriate conditions and required actions of the LCO in which the loss of safety function exists. When a loss of function is solely due to a single TS support system, the appropriate LCO is the LCO for that support system. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported systems.
The licensee proposed to add the following sentence to Comanche Peak TS 5.5.15:
When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
The NRC staff finds that the proposed addition to TS 5.5.15 clarifies the intent of the allowance (not to enter the conditions and required actions) provided by LCO 3.0.6 and the SFDP for single-train support systems. The NRC staff concludes that the proposed change is acceptable since the actions for the support system LCO adequately address the inoperability of that system. Therefore, as required by 10 CFR 50.36(c)(5), the proposed change continues to provide adequate administrative controls to assure safe operation.
3.4 Proposed Addition of Containment Sump TS 3.4.1 Evaluation of the New TS The licensee proposed to add a new TS to address operability requirements of the containment sump. The numbering for this new TS is TS 3.6.8.
The containment sump supports the post-accident operation of the ECCS and CSS. However, only the current ECCS TSs contain SRs related to the containment sump and the TSs do not specify required actions that specifically address an inoperable containment sump. If the containment sump was found to be inoperable, as an ECCS and CSS support system, those respective LCOs would not be met. In order to address concerns related to containment sump
operability due to debris accumulation described in GSI-191, Assessment of Debris Accumulation on Pressurized-Water Reactor Sump Performance, the licensee proposed to add a new specification to address containment sump inoperability and create a condition for when the sump is inoperable due to analyzed containment accident generated and transported debris.
Based on the below evaluation, the NRC staff determined that the proposed TS 3.6.8 satisfies the requirements of 10 CFR 50.36(c)(2)(i) because the LCO specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public.
3.4.2 Evaluation of the Applicability The new Comanche Peak TS 3.6.8 requires the containment sump to be operable during Modes 1, 2, 3, and 4. The ECCS and CSS TS currently in the Comanche Peak TSs are applicable during Modes 1, 2, 3, and 4.
The NRC staff finds the proposed applicability is acceptable because the applicability is consistent with the applicability of the ECCS and CSS TS, which are the containment sump supported systems.
3.4.3 Evaluation of Condition A The licensee has analyzed the susceptibility of the ECCS and CSS to the adverse effects of post-accident debris blockage and operation with debris-laden fluids. The licensee has established limits on the allowable quantities of containment accident generated debris that could be transported to the containment sump based on its current plant configuration. In the current TSs, if unanalyzed debris sources are discovered inside containment, if errors are discovered in debris-related analyses, or if a previously unevaluated phenomenon that can affect containment sump performance is discovered, the containment sump and the supported ECCS and CSS may be inoperable, and the TSs would require a plant shutdown with no time provided to evaluate the condition.
In order to address this situation and to provide sufficient time to evaluate the condition, the licensee proposed Condition A, which is applicable when the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits.
Under Condition A, the operability of the containment sump with respect to debris is based on a quantity of debris evaluated and determined to be acceptable by the licensee. Conditions not evaluated under Condition A (containment accident generated and transported debris) and that affect the quantity of analyzed debris will be evaluated using a deterministic process.
Under Condition A, Required Action A.1 mandates immediate action to be initiated to mitigate the condition. The licensees proposed TS Bases for Required Action A.1 provided the following examples of mitigating actions:
Removing the debris source from containment or preventing the debris from being transported to the containment sumps; Evaluating the debris source against the assumptions in the analysis;
Deferring maintenance that would affect availability of the affected systems and other LOCA mitigating equipment; Deferring maintenance that would affect availability of primary defense-in-depth systems, such as containment coolers; Briefing operators on LOCA debris management actions; or Applying an alternative method to establish new limits.
The NRC staff finds the proposed Required Action A.1 and its CT are acceptable because they place urgency on the initiation of the appropriate actions that could mitigate or reduce the impact of the identified conditions.
Concurrently, Required Action A.2 mandates SR 3.4.13.1, the RCS water inventory balance to be performed at an increased frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump.
The NRC staff finds the proposed Required Action A.2 and its CT are acceptable because the more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.
In addition, Required Action A.3 requires the inoperable containment sump to be restored to operable status in 90 days.
The NRC staff finds the proposed Required Action A.3 and its CT are acceptable because they provide a reasonable amount of time to diagnose, plan and possibly reduce the severity of, or mitigate the unanalyzed debris condition and prevent a loss of ECCS and CSS safety function.
In addition, 90 days is adequate given the conservatisms in the containment debris analysis and the proposed compensatory actions required to be implemented immediately by Required Action A.1. Also, as discussed later in this SE section, the new SR will require visual inspection of the containment sump system (including the containment drainage flow paths, any design features upstream of the containment sump that are credited in the containment debris analysis, the containment sump strainers, the pump suction trash racks, and the inlet to the ECCS and CSS piping for evidence of structural degradation, potential for debris bypass, and presence of corrosion or debris blockage) to ensure no loose debris is present and there is no evidence of structural distress or abnormal corrosion.
For Condition A, a plant with multiple sumps is treated equivalently to a plant with a single sump, because multiple sumps are considered to be part of a single support system.
3.4.4 Evaluation of Condition B Condition B specifies the required actions for when the containment sump is inoperable for reasons other than containment accident generated and transported debris exceeding the analyzed limits.
Required Action B.1 requires restoring the containment sump to operable status and is modified by two notes. These two notes direct entry into the conditions and required actions for the
supported systems (ECCS and CSS) upon entering Required Action B.1. Since Required Action B.1 directs entry to the corresponding ECCS and CSS TSs, these notes retain the existing TS actions for ECCS or CSS trains made inoperable by an inoperable containment sump for reasons other than containment accident generated and transported debris exceeding the analyzed limits.
The proposed CT for Required Action B.1 is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This CT is consistent with the CT for a single inoperable ECCS train or CSS train so that the ECCS and CSS TS Actions control the licensees response.
The NRC staff finds that the proposed change is acceptable because it continues to provide remedial actions for when the containment sump is inoperable for reasons other than Condition A and ensures safe operation of the plant. In addition, the proposed CT is acceptable because it provides a reasonable time for repairs, and there is a low probability of an accident occurring during this period that would require the use of the containment sump.
3.4.5 Evaluation of Condition C If operators are unable to restore the affected containment sump to operable status under Condition A or B, Required Action C.1 requires the unit to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> followed by Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, as required by Required Action C.2.
The NRC staff finds that this proposed condition and its required actions are acceptable because the condition is consistent with the standard TSs and the required action requires the operators to place the unit in a condition in which the LCO no longer applies. In addition, the proposed CTs allow a reasonable amount of time to decrease from full power conditions to the required plant conditions in an orderly manner and without challenging plant systems.
3.4.6 Evaluation of the New SR 3.6.8.1 The licensee proposed a new SR 3.6.8.1 in the new containment sump TS. This SR was originally located in TS 3.5.2 and referred to in TS 3.5.3. The numbering for this new SR is SR 3.6.8.1. The frequency of the new SR is in accordance with the SFCP.
The proposed SR requires verification, by visual inspection, that the containment sump does not show structural damage, abnormal corrosion, or debris blockage.
The new SR is stated in generic terms and expands the scope of the required visual inspection to include the entire containment sump system. The entire containment sump system consists of the containment drainage flow paths, the containment sump strainers (or screens), the pump suction trash racks, and the inlet to the ECCS and CSS piping.
The NRC staff finds that the proposed new SR is acceptable because it expands the scope of inspection of the original SR. In addition, the proposed frequency is acceptable because it is the same as that currently required by the TSs. Therefore, the NRC staff finds that, as required by 10 CFR 50.36(c)(3), the necessary quality of systems will be maintained in accordance with the associated LCOs.
3.4.7 Evaluation of Changes to the TS Bases The licensee submitted TS Bases changes (that corresponded to the proposed TS changes) to provide the reasons for the proposed TSs. The licensee stated that the TS bases changes are consistent with the bases changes in the model application.
3.4.8 Conclusion Regarding Proposed Containment Sump TS The new containment sump TS retains and expands the existing TS requirements with the exception of the addition of Condition A. Condition A provides a condition for an inoperable containment sump due to containment accident generated and transported debris exceeding the analyzed limits.
The NRC staff reviewed the proposed changes against the regulations and concludes that the changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 50.36(c)(3) for the reasons discussed above, and therefore, provide reasonable assurance that adoption of these TSs will have the requisite requirements and controls to operate safely. Therefore, the NRC staff concludes that the proposed TS changes are acceptable.
3.5 Variations Section 2.2.5 of this SE describes a numbering difference between the Comanche Peak TS and TSTF-567, Revision 1. This difference is editorial and does not affect the applicability of TSTF-567 to the proposed LAR. Therefore, the NRC staff finds the TS numbering to be acceptable as proposed by the licensee in its LAR.
3.6 Technical Evaluation Conclusion
The NRC staff determined that the proposed TS changes meet the standards for TSs in 10 CFR 50.36 and are acceptable. As required by 10 CFR 50.36(c)(2), the LCOs specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The proposed changes to the SRs assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met, and satisfy 10 CFR 50.36(c)(3). In addition, the proposed changes to the administrative controls include provisions to assure safe operation of the facility as required by 10 CFR 50.36(c)(5).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments on May 11, 2021. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change SRs.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, as published in the Federal Register on
February 23, 2021 (86 FR 11014), and there has been no public comment on such finding.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: S. Smith, NRR Date: June 9, 2021
- via e-mail OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC*
NAME DGalvin PBlechman VCusumano DATE 5/18/2021 5/18/2021 4/8/2021 OFFICE OGC / NLO NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM NAME Turk JDixon-Herrity (SLee for)
DGalvin DATE 6/8/2021 6/9/2021 6/9/2021