ML21259A140

Meeting Summary for Safety Pre Submittal Meeting for Initial License Renewal Application on September 21, 2021

ML21259A140
Person / Time
Site:	Comanche Peak
Issue date:	10/05/2021
From:	Lois James NRC/NRR/DNRL/NLRP
To:	Lauren Gibson NRC/NRR/DNRL/NLRP
James L,
References
EPID L-2020-RNW-0029
Download: ML21259A140 (7)

Text

October 5, 2021 MEMORANDUM TO: Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM: Lois M. James, Senior Project Manager /RA/

License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - MEETING

SUMMARY

FOR SAFETY PRE-SUBMITTAL MEETING FOR INITIAL LICENSE RENEWAL APPLICATION ON SEPTEMBER 21, 2021 (EPID NO. L-2020-RNW-0029)

On September 21, 2021, the U.S. Nuclear Regulatory Commission staff met with Luminant Generation Company, LLC for a safety pre-application discussion regarding Luminants future submittal of an initial license renewal application for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2. Enclosed is the meeting summary and the list of attendees.

If you have any questions or comments, please contact me via e-mail at Lois.James@nrc.gov.

Docket Nos.: 50-445 and 50-446

Enclosures:

1. Meeting Summary

2. List of Attendees cc w/enclosure:

See next page CONTACT: Lois M. James, NRR/DNRL 301-415-3306

ML21259A140 *via e-Concurrence OFFICE PM: NRR/DNRL/NLRP LA: NRR/DNRL/NRLB BC: NRR/DNRL/NLRP NAME LJames SGreen LGibson DATE 10/04/2021 10/04/2021 10/05/2021 OFFICE PM: NRR/DNRL/NLRP NAME LJames DATE 10/05/2021 U.S. Nuclear Regulatory Commission Public Meeting Summary

Title:

Pre-Submittal Meeting for License Renewal Application for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (CPNPP) - Safety Date of Meeting: September 21, 2021, 2:00 pm - 4:00 pm Location: Webinar Type of Meeting: This is an Observation Meeting. This is a meeting in which attendees will have an opportunity to observe the U.S. Nuclear Regulatory Commission (NRC) performing its regulatory function or discussing regulatory issues. Attendees will have an opportunity to ask questions of the NRC staff or make comments about the issues discussed following the business portion of the meeting; however, the NRC is not actively soliciting comments toward regulatory decisions at this meeting.

Purpose of the Meeting(s): NRC will meet with Vistra Operations Company LLC (Vistra OpCo) and Luminant Generating Company (Luminant) to discuss the preparation of the safety portion of the initial license renewal application for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (CPNPP)

General Details:

The NRC staff held a public, observational meeting with Vistra OpCo and Luminant to discuss the preparation of an initial license renewal application for CPNPP. The meeting began at 2:00 pm and ended at 3:30 pm. There were 28 NRC staff members, 17 applicant staff and contractor, and 19 members of the public. The meeting began with introductions of the NRC staff, Vistra OpCo staff, Luminant staff, and contractor support staff.

Summary of Meeting:

The NRC staff began their presentation by describing the license renewal process. There are two tracks - safety and environmental - that proceed in parallel. The environmental track includes a scoping period to receive comments on what should be included in the environmental impact statement; the staff review and audits; the development and issuance of a draft environmental impact statement; response to comments on the draft environmental impact statement; and issuance of a final environmental impact statement. The safety track includes staff reviews, audits, issuance of a safety evaluation report, and a review by the Advisory Committee on Reactor Safeguards (ACRS). The final environmental impact statement, the safety evaluation report, and the ACRS recommendation to the Commission are inputs to the NRC regulatory decision regarding the license renewal application.

Next, the staff discussed a tentative schedule assuming that the CPNPP license renewal application was submitted on September 30, 2022.

Activity Estimated Date Application Submission Date September 30, 2022 Acceptance Date (Project Start Date) November 21, 2022 In-Office Technical Review Audit December 2022 Enclosure 1

Activity Estimated Date On-Site Audit January 2023 Breakout Audit January/February 2023 Safety Evaluation Report October 2023 ACRS Full Committee Meeting December 2023 Licensing Decision May 2024 The staff emphasized that the schedule was based on a generic review and would be adjust to account for the actual submittal date and the application submitted.

Luminant began by explaining the licensee/operator information. The operator of CPNPP is Vistra Operations Company LLC (Vistra OpCo), commonly denoted by Luminant. The owner of CPNPP is Comanche Peak Power Company LLC (CP Power Co).

Luminant continue by providing a history of major activities at CPNPP and describing the CPNPP facility. Then Luminant explained their approach for scoping and screening and aging management review.

Luminant explained that at this point in the development from the license renewal application, they have identified 44 aging management programs (AMPs) (37 existing and 7 new) with several having exceptions:

• XI.M2 Water Chemistry

• XI.M17 Flow-Accelerated Corrosion

• XI.M19 Steam Generators (SGs)

• 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 have been identified at this time.

Luminant explained that CPNPP does have one unique material - fiberglass piping - and one unique exception - fuel oil storage tank - has extended the inspection frequency to 20 years.

Regarding time limited aging analysis (TLAA), Luminant does not anticipate any exemptions based on TLAAs. There will be three plant specific TLAAs:

• U2 SG tube corrosion allowance

• SG tube vibration wear projections

• Effect of radiation on containment coatings Luminant also described their approach to the operating experience review. The initial review period will be from January 1, 2011 through December 31, 2020. The actual cutoff date for the operating experience review will be December 31, 2021. No new aging effects have been identified as a result of the operating experience review.

Luminant identified three topics that would be of interest to the NRC:

• Environmentally Assisted-Fatigue (EAF) o NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components, sample set locations are being evaluated.

o Performing EAF screening consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2, AMP X.M1 to identify additional plant specific component locations that are more limiting than NUREG/CR-6260,Testing of dc-Powered Actuators for Motor-Operated Valves locations.

o Additional sentinel locations will be addressed prior to entering the period of extended operation.

• MRP-227, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines o CPNPP is the first 60-year application post issuance of MRP-227 Rev 1-A and as supplemented by Interim Staff Guidance (ISG) SLR-ISG-2021-01-PWRVI.

• End of life Fluence vs Capsule Fluence S

o Both Comanche Peak units have already withdrawn and tested a surveillance capsule intended to bound 60-year operation o Fluence values for these capsules are slightly below the peak 60-year reactor vessel fluence based on the latest projections Public Participation Themes:

No member of the public spoke on the webinar.

Action Items/Next Steps:

The NRC staff will prepare and issue a meeting summary.

Attachments:

Meeting description and agenda - ADAMS Accession No. ML21259A031 NRC slide presentation - ADAMS Accession No. ML21259A033 CPNPP slide presentation - ADAMS Accession No. ML21259A035

U.S. Nuclear Regulatory Commission Public Meeting - Attendees List September 21, 2021

Title:

Pre-Submittal Meeting for License Renewal Application for Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (CPNPP) - Safety Name Affiliation U.S. Nuclear Regulatory Commission (NRC)/Office of Nuclear Reactor Brian Allik Regulation (NRR)

Lydiana Alvardo NRC/NRR Steve Bloom NRC/NRR Bob Caldwell NRC/NRR Tony Gardner NRC/NRR Lauren Gibson NRC/NRR Allen Hiser NRC/NRR Lois James NRC/NRR Andrew Johnson NRC/NRR Nageswara Karipineni NRC/NRR Paul Klein NRC/NRR Brian Lee NRC/NRR Bryce Lehman NRC/NRR Chang Li NRC/NRR Gregory Makar NRC/NRR Melissa McGuffie NRC/NRR James Medoff NRC/NRR Seung Min NRC/NRR Duc Nguyen NRC/NRR David Pratt NRC/NRR Adam Rau NRC/NRR Hector Rodriguez-Luccioni NRC/NRR Angelo Stubbs NRC/NRR Leslie Terry NRC/NRR Vaugh Thomas NRC/NRR Brian Wittick NRC/NRR Matthew Yoder NRC/NRR Carl Corbin Luminant Generating Company (Luminant)

Todd Evans Luminant Ramiz Gilada Luminant Randy Harding Luminant Jack Hicks Luminant Amit Kalia Luminant Steven Sewell Luminant Taylor Smith Luminant Gary Adkins Enercon Enclosure 2

Stacy Burgess Enercon Burns Cunningham Enercon Zandra Garanzuay Enercon Mitch McFarland Enercon Brian Norman Enercon John Carlson Westinghouse Greg Imbrogno Westinghouse Thomas Zalewski Westinghouse Maria Delposen Public Mike Gallagher Public Jeff Gromatzky Public Dakota Huddleston Public Vivek A. Kannan Public Benjamin Mays Public L Smith (Guest) Public Garry G. Young Public Jane Public Veronica Public 5 additional call ins Public