ML21259A031

Initial License Renewal Pre-Application Submittal Meeting Sept 2021 - Safety

ML21259A031
Person / Time
Site:	Comanche Peak
Issue date:	09/30/2021
From:	Luminant Generation Co
To:	Office of Nuclear Reactor Regulation
James L, NRR/DNRL/NRLP, 301-415-3306
References
EPID L-2020-RNW-0029
Download: ML21259A031 (20)

Text

Comanche Peak Nuclear Power Plant (CPNPP)

First License Renewal (60 years) Application:

Safety Pre-Application Submittal Meeting September 2021

Opening Remarks and Introductions Speakers Steven Sewell (Luminant)

Todd Evans (Luminant)

Taylor Smith (Luminant)

Amit Kalia (Luminant)

Participants Ramiz Gilada (Luminant)

Carl Corbin (Luminant)

Burns Cunningham (ENERCON)

Mitch McFarland (ENERCON)

Gary Adkins (ENERCON)

Tom Zalewski (Westinghouse) 2

AGENDA General Information Application Preparation Approach Scoping and Screening Aging Management Review Aging Management Programs TLAA and Exemption Identification Operating Experience Topics of Interest Environmentally Assisted Fatigue MRP-227 EOL Fluence and Capsule Fluence Discussion, Future Activities and Q&A 3

General Information Project Team Experience Luminant engaged in NEI Working Groups (LRA and LRI) and extensive benchmarking since 2017 Luminant conducted extensive LR Feasibility Study in 2019 Luminant attends LR related public meetings Experienced Luminant technical personnel Engaged resources with extensive LR experience

• ENERCON & Westinghouse Consultant review of selected documents Building a high-quality application Review and address recent applicant RCIs, RAIs and Supplements (Byron-Braidwood, Waterford, Turkey Point, Peach Bottom, Surry)

Monitoring on-going applicant processes Industry Peer Review to be conducted prior to submittal 4

General Information (cont.)

Licensee information Operator - Vistra Operations Company LLC (Vistra OpCo)

• Luminant commonly used to denote CPNPP operator Owner - Comanche Peak Power Company LLC (CP Power Co)

Vistra OpCo is indirect, wholly owned subsidiary of Vistra Corp 5

General Information (cont.)

CPNPP Units 1 and 2 Four Loop Westinghouse PWRs that are nearly identical Located in north Texas, southwest of Dallas-Fort Worth CPNPP Upgrade History Unit 1 Unit 2 Initial License, 3411 MWt 1990 1993 Leading Edge Flow Meter Technology, 3458 MWt 2001 1999 / 2001 Stretch Power Uprate, 3612 MWt 2008 2008 SG & RVCH Replacements* 2008 N/A Mechanical Stress Improvement Process 2019 2021 Structural Weld Overly for Pressurizer Nozzles 2007 2008 Current License Expiration Date 2/8/2030 2/2/2033

• Included Alternate Containment Access - -

LRA written to NUREG-1801 Rev. 2 and LR-ISGs LRA submittal planned for Oct-Dec 2022 6

General Information (cont.)

12 11 1

2 8 3 9 4

5 6

7 10 7

Application Approach to Scoping and Screening Nuclear Safety Related, 10 CFR 54.4(a)(1)

Regulated Events 10 CFR 54.4(a)(3)

Fire Protection 10 CFR 50.48 Environmental Qualification 10 CFR 50.49 Pressurized Thermal Shock 10 CFR 50.61 Anticipated Transient Without Scram 10 CFR 50.62 Station Black Out 10 CFR 50.63 SSC Intended Functions System Intended Function Sources: FSAR, DBDs, TS, TRMs, FPR, Docketed Correspondence Component Intended Functions consistent with NEI 95-10 Rev. 6 8

Application Approach to Scoping and Screening (cont)

Non-Safety Affecting Safety, 10 CFR 54.4(a)(2)

Spaces Approach Consistent with NEI 95-10, App. F ANSI B31.1 piping attached to ASME Class (1, 2 or 3) Piping Other ANSI B31.1 piping inside Seismic Category I Buildings (Spatial)

Protection Design Features for Flooding, Missiles, Tornadoes, Pipe Whip, and Jet Impingement 9

Application Approach to Aging Management Review System/Structure AMR (9-column) Tables Generic Notes

• Majority are Note A through E - consistent with GALL Plant-Specific Notes

• Majority are to cite NUREG-2191 line items considered as applicable operating experience Unique Materials

• Fiberglass piping (Equipment and Floor Drain system) and pump casings (Chemical Transfer Condensate Deox Pumps) 10

Application Approach to Aging Management Programs 44 AMPs 37 Existing 7 New AMPs with Exceptions (Preliminary)

XI.M2 Water Chemistry XI.M17 Flow-Accelerated Corrosion XI.M19 Steam Generators XI.M21A Closed Treated Water Systems XI.M27 Fire Water System XI.M30 Fuel Oil Chemistry XI.M41 Buried and Underground Piping and Tanks XI.M42 Internal Coatings/Linings XI.S3 ASME Section XI, Subsection IWF No plant specific AMPs 11

Application Approach to TLAA and Exemptions Identification Search Methods Keyword Searches of CPNPP plant records, plant licensing documents, and OEM document management system

• TLAA search and screening performed against requirements in 10 CFR 54.21 and Section 54.3 No Exemptions based on TLLAs are anticipated Plant Specific TLAAs for CPNPP U2 SG tube corrosion allowance SG tube vibration wear projections Effect of radiation on containment coatings 12

Application Approach to Operating Experience Initial Review Period: 1/1/2011 through 12/31/2020 Formal OE cutoff date will be 12/31/2021 (2021 OE to be reflected in application)

CPNPP CAP Database is ActionWay Keyword Searches

~200 Keywords Developed From Recent SLR OE Audits

~51,000 Results (IRs, CRs, TRs, OERs)

~5,500 relevant to LR Lessons learned from recent RAIs/RCIs and supplements are incorporated in AMPs and AMRs GALL-SLR and SLR-ISGs are considered as Operating Experience No New Aging Effects Identified 13

Topics of Interest Environmentally Assisted Fatigue NUREG/CR-6260 sample set locations are being evaluated Performing EAF screening consistent with GALL Revision 2, X.M1 to identify additional plant-specific component locations that are more limiting than NUREG/CR-6260 locations Additional sentinel locations will be addressed prior to entering the PEO 14

Topics of Interest (cont.)

MRP-227 CPNPP is the first 60 year application post issuance of MRP-227 Rev 1-A and as supplemented by SLR-ISG-2021-01-PWRVI The MRP provides Aging Management guidelines for 60 years of operation CPNPP LR Application, including the RVI AMP, will reference the MRP and will be consistent with the ISG CPNPP RVI AMP will be implemented prior to the PEO 15

Topics of Interest (cont.)

EOL Fluence vs Capsule Fluence Both Comanche Peak units have already withdrawn and tested a surveillance capsule intended to bound 60-year operation Fluence values for these capsules are slightly below the peak 60-year reactor vessel fluence based on the latest projections Luminant intends to re-insert one previously withdrawn surveillance capsule at each unit in order to obtain higher fluence data which bounds the PEO These capsules are intended to be removed and tested prior to the end of the PEO and after reaching a fluence value equivalent to the 80-year reactor vessel fluence Capsule will be removed with a fluence that is between once and twice the peak RV fluence consistent with ASTM E185-82 and GALL Revision 2 16

Discussion and Future Activities Luminant would like the NRCs perspective on any currently developing topics that the NRC is aware whose timing could impact Luminants application or the NRCs review of the application, e.g.

Additional guidance, e.g. additional ISGs Good practices from current LR application reviews Process changes Continue quarterly check-ins Plan Pre-Application Submittal meeting ~6 months prior to submittal Some potential topics

• Use of RCIs and Supplements

• OE Searches by NRC

• Sufficiency Review

• Audits

• Portal 17

Closing Remarks CPNPP application will be consistent with industry practices and lessons learned from recent LRs/SLRs and meet NRC requirements Luminant will submit a high-quality application that can support an 18 month staff review CPNPP application is on track to be submitted to the NRC in October to December 2022 18

Additional Information 19

Aging Management Review - LRBD Example 20