ML21286A791

NRR E-mail Capture - Comanche Peak - Request for Additional Information - Request to Adopt TSTF-577 Revision 1

ML21286A791
Person / Time
Site:	Comanche Peak
Issue date:	10/13/2021
From:	Dennis Galvin NRC/NRR/DORL/LPL4
To:	Hicks J Vistra Operations Company
References
L 2020-LLA-0134
Download: ML21286A791 (4)

Text

From: Galvin, Dennis Sent: Wednesday, October 13, 2021 11:51 AM To: Jack Hicks (Jack.Hicks@luminant.com)

Cc: Dixon-Herrity, Jennifer; Struble, Garry

Subject:

Comanche Peak - Request for Additional Information - Request to Adopt TSTF-577 Revision 1 (EPID: L 2020-LLA-0134)

Attachments: Comanche Peak TSTF-577 LAR - RAIs 2021-10-13.pdf

Dear Mr. Hicks,

By letter dated July 27, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21208A023), as supplemented by letter dated August 31, 2021 (ADAMS Accession No. ML21243A232), Vistra Operations Company LLC (the licensee) submitted a license amendment request (LAR) for Nuclear Regulatory Commission (NRC) approval for an amendment to the facility operating license for the Comanche Peak Nuclear Power Plant, Units 1 and 2 (Comanche Peak). The licensee requested that the NRC process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program and the Unit 1 Model D76 and Unit 2 Model D5 Steam Generator Tube Inspection Report technical specifications (TSs) based on Technical Specifications Task Force (TSTF) Traveler TSTF 577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections (TSTF 577) (ADAMS Accession No. ML21060B434), and the associated NRC staff safety evaluation (SE) TSTF 577 (ADAMS Accession No. ML21098A188).

The NRC staff has determined that additional information is needed to complete its review. The requests for additional information (RAIs) were transmitted to the licensee in draft form on October 12, 2021. Garry Struble of your staff on October 13, 2021, indicated that no clarification call was needed, and the licensee agreed to provide responses to the RAls by November 12, 2021. The NRC staff agreed with this date.

If you have any questions, please contact me at (301) 415-6256 or Dennis.Galvin@nrc.gov.

Respectfully,

Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256

Hearing Identifier: NRR_DRMA Email Number: 1379

Mail Envelope Properties (SA1PR09MB8111FEA5FEC296D6435D120DFBB79)

Subject:

Comanche Peak - Request for Additional Information - Request to Adopt TSTF-577 Revision 1 (EPID: L 2020-LLA-0134)

Sent Date: 10/13/2021 11:51:29 AM Received Date: 10/13/2021 11:51:00 AM From: Galvin, Dennis

Created By: Dennis.Galvin@nrc.gov

Recipients:

"Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>

Tracking Status: None "Struble, Garry" <Garry.Struble@luminant.com>

Tracking Status: None "Jack Hicks (Jack.Hicks@luminant.com)" <Jack.Hicks@luminant.com>

Tracking Status: None

Post Office: SA1PR09MB8111.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 1886 10/13/2021 11:51:00 AM Comanche Peak TSTF-577 LAR - RAIs 2021-10-13.pdf 69203

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION

LICENSE AMENDMENT REQUEST

VISTRA OPERATIONS COMPANY LLC

COMANCHE PEAK UNIT 1 AND 2

DOCKET NOS. 50-445 AND 50-446

By letter dated July 27, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21208A023), as supplemented by letter dated August 31, 2021 (ADAMS Accession No. ML21243A232), Vistra Operations Company LLC (the licensee) submitted a license amendment request (LAR) for Nuclear Regulatory Commission (NRC) approval for an amendment to the facility operating license for the Comanche Peak Nuclear Power Plant, Units 1 and 2 (Comanche Peak). The licensee requested that the NRC process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the Unit 1 Mode l D76 and Unit 2 Model D5 Steam Generator (SG) Program and the Unit 1 Model D76 and Unit 2 Model D5 Steam Generator Tube Inspection Report technical specifications (TSs) based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections (TSTF-577) (ADAMS Accessi on No. ML21060B434), and the associated NRC staff safety evaluation (SE) TSTF-577 (ADAMS Accession No. ML21098A188).

The tubes within an SG function as an integral part of the reactor coolant pressure boundary and, in addition, isolate fission products in the primary coolant from the secondary coolant and the environment. SG tube integrity means that the tubes are capable of performing this safety function in accordance with the plant design and licensing basis.

Comanche Peak has two Units. The Unit 1 SGs have Alloy 690 thermally treated (Alloy 690TT) tubes. The Unit 2 SGs have Alloy 600 thermally treated (Alloy 600TT) tubes.

The NRC staff has determined that additional information is needed to complete its review, as described below.

Regulatory Basis

The regulation in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(5),

Administrative Controls, states in part, that [ a]dministrative controls 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. All pressurized water reactors have TSs according to 10 CFR 50.36 that include a SG Program with specific criteria for the structural and leakage integrity, repair, and inspection of SG tubes. At Comanche Peak, programs established by the licensee, including the SG Program, are listed in the administrative controls section of the TS to operate the facility in a safe manner.

=

Background===

As noted above, on July 27, 2021, the licensee submitted the subject application described above. On August 31, 2021, the licensee supplemented its application to address several items

to include consistency with TSTF-577. Based on the supplement, the NRC identified a few more issues that are not consistent with TSTF-577 adoption. It appears that these inconsistencies are formatting related errors and the NRC staff requests the licensee to evaluate.

Request for Additional Information

To complete its evaluation of whether the proposed TS changes meet the SG Program requirements described above, the NRC staff requests the following information:

1. The licensee letter dated August 31, 2021, contains three attachments: Attachment 1, Markup Technical Specification Pages; Attachment 2, Proposed Technical Specification Pages; and Attachment 3, Revised Technical Specification Pages. These attachments contain changes to the TSs, but in a few instances where they should agree, they do not agree. In addition, in a few instances where all three attachments agree, it appears that numbered lists are formatted incorrectly. Specifically:

a. In Attachment 1, there is a TS 5.5.9 paragraph d.3, but in Attachments 2 and 3, the paragraph that appears to be paragraph d.3 in TS 5.5.9 is not numbered.

b. In Attachment 1, within TS 5.5.9 paragraph d.3, there is a comma after the first use of the phrase refueling outage but this comma does not appear in Attachments 2 and 3.

c. In Attachment 1, within TS 5.5.9 paragraph d.3, there is a period after the phrase paragraph d.2 but this period does not show up in Attachments 2 and 3. In addition, it appears that paragraph d.3 should be reviewed for proper spacing between the sentence ending with paragraph d.2 and the next sentence beginning with If definitive information.

d. In all three attachments, there is a TS 5.5.9, paragraph e, that does not appear to have the proper list indentation distance (indented too far to the right).

e. In all three attachments, there is a TS 5.6.9, Steam Generator Tube Inspection Report, that removes numbering for items h, i, and j and combines them into new item g with no change in technical content. Current items h, i, and j contain distinct reporting requirements and because of their independence, it appears they merit being identified by a unique number. Please justify why the numbering for these independent items was combined into new item g or reestablish individual numbering for each independent item.

For all corrections, please provide new Attach ments for the affected TS pages for the NRC staff to review.