CP-202100251, (CPNPP) - Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections

From kanterella
(Redirected from ML21208A023)
Jump to navigation Jump to search

(CPNPP) - Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections
ML21208A023
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/27/2021
From: Thomas McCool
Luminant, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202100251, TXX-21083
Download: ML21208A023 (27)
v • d • e


Text

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

Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 .897.6042 CP-202100251 TXX-21083 July 27, 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 Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections"

Dear Sir or Madam:

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

Vistra OpCo requests adoption of TSTF-577-A, Revision 1, "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.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages. Attachment 2 provides the proposed TS changes. The intent is to replace what is currently in TS with the proposed changes given in Attachment 2. Attachment 3 provides the revised 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.

Should you have any questions, please contact Garry Struble at (254) 897-6628 or Garry.Struble@luminant.com.

TXX-21083 Page 2 of 2 I state under penalty of perjury that the foregoing is true and correct.

Executed on July 27, 2021.

ThonUP. McCool

Enclosure:

Description and Assessment Attachments: 1. Current Technical Specification Pages [TS 5.5.9 and 5.6.9]

2. Proposed Technical Specification Changes [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 Uohn.Ellegood@mc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@mc.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

Enclosure to TXX-21083 Page 1 of 5 Enclosure Description and Assessment

Enclosure to TXX-21083 Page 2 of 5 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

Vistra Operations Company LLC ("Vistra OpCo") requests adoption of TSTF-577-A, Revision 1 (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.

Enclosure to TXX-21083 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.

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.

Vistra OpCo has evaluated if a significant hazards consideration is involved with the proposed 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

Enclosure to TXX-21083 Page 4 of 5 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 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 UFSAR or the license.

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

Enclosure to TXX-21083 Page 5 of 5 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 environmental assessment need be prepared in connection with the proposed amendment.

to TXX-21083 Page 1 of 8 Attachment 1 Current Technical Specification Pages Technical Specifications 5.5.9 and 5.6.9 to TXX-21083 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 prog ram 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 A Steam Generator Program shall be established and implemented to ensure that SG tube integrity is maintained . In addition, the 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" 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. Performance criteria for SG tube integ rity. 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 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 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 integ rity, 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. 4-W, 168 to TXX-21083 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, the 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, 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 flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the 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 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 requ irements 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 COMANCHE PEAK - UNITS 1 AND 2 5.5-5 Amendment No . 150, 161 , 168 to TXX-21083 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) assessment, to determine which inspection methods need 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. 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 (Alloy 600 thermally treated) after the first refueling outage following SG installation, inspect each SG at least every 48 effective full power 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 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 with 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 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. After the first refueling outage following SG installation , inspect 100% of the tubes during the next 120 effective full power months. This constitutes the first inspection period;
b. During the next 96 effective full power months, inspect 100% of the tubes . This constitutes the second inspection period ; and COMANCHE PEAK - UNITS 1 AND 2 5.5-6 Amendment No. 150, 151 , 158, 161 , 168, 173 to TXX-21083 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)
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 effective full power months.

During the remaining life of the SGs, inspect 100% of the tubes every 72 effective ful l power months. This constitutes the third and 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 every 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 with 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 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. After the first refueling outage following SG installation , inspect 100% of the tubes during the next 144 effective full power months. This constitutes the first inspection period ;
b. During the next 120 effective full power months, inspect 100%

of the tubes. This constitutes the second inspection period ;

c. During the next 96 effective full power months, inspect 100% of the tubes. This constitutes the third inspection period ; and COMANCHE PEAK - UNITS 1 AND 2 5.5-7 Amendment No. 150, 154, 158, 161,168,173 to TXX-21083 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) Program (continued)
d. During the remaining life of the SGs , inspect 100% of the tubes every 72 effective full power months. This constitutes the fourth and subsequent inspection periods.
4. For Unit 1, if crack indications are found in any SG tube, 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) . For Unit 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.

5.5 .10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables ;
b. Identification of the procedures used to measure the values of the critical variables;
c. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;
d. Procedu res for the recording and management of data;
e. Procedures defining corrective actions for all off control point chemistry conditions; and COMANCHE PEAK - UNITS 1 AND 2 5.5-8 Amendment No. 150, 161 , 168, 173 to TXX-21083 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 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 Unit 1 Model D76 and Unit 2 Model 05 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 ,
c. Nondestructive examination techniques utilized fo r each degradation mechanism ,
d. Location , orientation (if linear) , and measured sizes (if available) of service induced indications,
e. Number of tubes plugged during the inspection outage for each degradation mechanism ,
f. The number and precentage of tubes plugged to date, and the effective plugging percentage in each steam generator,
g. The results of condition monitoring , including the results of tube pulls and in-situ testing ,
h. 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 COMANCHE PEAK- UNITS 1 AND 2 5.6-5 Amendment No. 4W, 154, 158, 161 to TXX-21083 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) secondary leakage should be conservatively assumed to be from one SG) during the cycle preceding the inspection which is the subject of the report,
i. 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
j. 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. 4W, 4§4,- 158 to TXX-21083 Page 1 of 6 Attachment 2 Proposed Technical Specification Changes Technical Specifications 5.5.9 and 5.6.9 to TXX-21083 Programs and Manuals Page 2 of 6 5.5 5.5 Programs and Manuals 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 surfacesof the removed flywheels may be conducted at 20 year intervals.

5.5.8 Deleted 5.5.9 Steam Generator (SG) Program A SG Program 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 a 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 in 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 power range, hot standby, and cool down), all anticipated transients included in 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 with 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 COMANCHE PEAK - UNITS 1 AND 2 5.5-4 Amendment No. ~ .

to TXX-21083 Programs and Manuals Page 3 of 6 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) 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 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 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 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 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 thermal 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 COMANCHE PEAK - UNITS 1 AND 2 5.5-5 Amendment No. 4-+J, to TXX-21083 Programs and Manuals Page 4 of 6 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) 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 .

3. 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 degradation mechanism that caused the crack indications shall be at the next refueling outage.

For Unit 2, the next inspection may be deferred to the following refueling outage if 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.

5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables;
b. Identification of the procedures used to measure the values of the critical variables;
c. Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;
d. Procedures for the record ing and management of data;
e. Procedures defining corrective actions for all off control point chemistry conditions; and COMANCHE PEAK - UNITS 1 AND 2 5.5-6 Amendment No. 4-+J.,

Attachment 2 to TXX-21083 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 , thecause 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;
4. The number of tubes plugged during the inspection outage; and
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; COMANCHE PEAK - UNITS 1 AND 2 5.6-5 Amendment No. 4M,

Attachment 2 to TXX-21083 Reporting Requirements Page 6 of 6 5.6 5.6 Reporting Requirements 5.6.9 Steam Generator Tube Inspection Report(continued)

f. The results of any SG secondary side inspections;
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,
h. 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
i. For Unit 2, the results of monitoring fo r 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. ~ .

to TXX-21083 Page 1 of 6 Attachment 3 Revised Technical Specification Pages Technical Specifications 5.5.9 and 5.6.9 to TXX-21083 Programs and Manuals Page 2 of 6 5.5 5.5 Programs and Manuals 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 Steam Generator (SG) Program A SG Program shall be established and implemented to ensu re 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 a 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 in 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 inducedleakage, 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 power range , hot standby, and cool down) , all anticipated transients included in 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 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 with 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 COMANCHE PEAK - UNITS 1 AND 2 5.5-4 Amendment No. 4-7-J, to TXX-21083 Programs and Manuals Page 3 of 6 5.5 5.5 Programs and Manuals 5.5 .9 Steam Generator (SG) Program (continued) 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 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 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 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 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 thermal 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 COMANCHE PEAK - UNITS 1 AND 2 5.5-5 Amendment No. ~ .

to TXX-21083 Programs and Manuals Page 4 of 6 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued) 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 .

3. 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 degradation mechanism that caused the crack indications shall be at the next refueling outage.

For Unit 2, the next inspection may be deferred to the following refueling outage if 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.

5.5.10 Secondary Water Chemistry Program Th is program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables ;
b. Identification of the procedures used to measure the values of the critical variables;
c. Identification of process sampling points , which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;
d. Procedures for the recording and management of data;
e. Procedures defining corrective actions for all off control point chemistry conditions; and COMANCHE PEAK- UNITS 1 AND 2 5.5-6 Amendment No . ~ .

Attachment 3 to TXX-21083 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;
4. The number of tubes plugged during the inspection outage ; and
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 ;

COMANCHE PEAK- UNITS 1 AND 2 5.6-5 Amendment No. 4e4,

Attachment 3 to TXX-21083 Reporting Requirements Page 6 of 6 5.6 5.6 Reporting Requirements 5.6.9 Steam Generator Tube Inspection Report(continued)

f. The results of any SG secondary side inspections;
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,
h. 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
i. 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. 4-M,

Retrieved from "https://kanterella.com/w/index.php?title=CP-202100251,_(CPNPP)_-_Application_to_Revise_Technical_Specifications_to_Adopt_TSTF_577,_Revised_Frequencies_for_Steam_Generator_Tube_Inspections&oldid=3407678"