CP-202200075, Third Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections

Third Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections

ML22046A198
Person / Time
Site:	Comanche Peak
Issue date:	02/15/2022
From:	Thomas McCool Luminant, Vistra Operating Co. (VistraOpCo)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202200075, TSTF-577, TXX-22020
Download: ML22046A198 (7)

Text

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

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6042 CP-202200075 TXX-22020 February 15, 2022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Ref 10 CFR 50.90 10 CFR 50.91

References:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Third Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections"

1. Letter to NRC from Thomas P. McCool, Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" dated July 29, 2021 [ADAMS Accession No. ML21208A023]

2. Letter to NRC from Thomas P. McCool, Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" dated August 31, 2021 [ADAMS Accession No. ML21243A232]

3. Request for Additional Information regarding the CPNPP Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" from the NRC to Jack C. Hicks dated October 13, 2021 [ADAMS Accession No. ML21286A791]

4. Email regarding the CPNPP Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" from the NRC to Garry Struble dated January 12, 2022.

5. Letter to NRC from Thomas P. McCool, Second Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" dated January 25, 2022 [ADAMS Accession No. ML22025A412]

6. Email regarding the CPNPP Application to Revise Technical Specifications to Adopt TSTF 577, "Revised Frequencies for Steam Generator Tube Inspections" from the NRC to Garry Struble dated February 8, 2022.

TXX-22020 Page 2 of 3

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Vistra Operations Company LLC ("Vistra OpCo") is submitting a third supplement to an amendment to the Technical Specifications (TS) for Comanche Peak, Units 1 and 2 made by References 1, 2, 3, 4, 5, and 6.

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 TS. The TS related to steam generator (SG) tube inspections and reporting are revised based on operating history. provides the updated markup TS pages. Attachment 2 provides the updated proposed TS page. Attachment 3 provides the updated revised (clean) TS page. These pages contained editorial errors that have been corrected. 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.

I state under penalty of perjury that the foregoing is true and correct.

Executed on February 15, 2022.

Sincerely, Attachments:

1.

Markup Technical Specification Page [TS 5.5.9, Pages 5.5-6 and 5.5-8]

2.

Proposed Technical Specification Pages [TS 5.5.9, Page 5.5-6]

3.

Revised Technical Specification Pages [TS 5.5.9, Page 5.5-6]

c (email) -

Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

TXX-22020 Page 3 of 3 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 to T:XX-22020 Page 1 of 2 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (continued) to be employed and at what locations.

1.

2.

2 Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.

For the Unit 1 model 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.

Implement a one time ohange to TS 5.5.Q.d.2, for Unit 2 Cyole 1Q only, to inspeot eaoh SG at least every 54 effeotive full po*Ner months.

For the Unit 2 model D5 steam generators SGs (Alloy 600 thermally 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 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. after the first refueling outage follmNing SG installation, inspect eaoh SG at least every 4 8 effeotive full po*Ner months or at least every other refueling outage (whiohever results in more frequent inspeotions). In addition, the minimum number of tubes inspeoted at eaoh soheduled inspeotion shall be the number of tubes in all SGs di*.*ided by the number of SG inspeotion outages soheduled in eaoh inspeotion period as defined in a, b, and o belo'>*J. If a degradation assessment indioates the potential for a type of degradation to ooour at a looation not pre11iously inspeoted with a technique oapable of detesting this type of degradation at this looation and that may satisfy the applioable tube plugging oriteria, the minimum number of looations inspeoted with suoh a oapable inspeotion teohnique during the remainder of the inspeotion period may be prorated. The fraotion of locations to be inspeoted for this potential type of degradation at this looation at the end of the inspeotion period shall be no less than the ratio of the number of times the SG is soheduled to be inspeoted in the inspeotion period after the determination that a new form of degradation oould potentially be ooourring at this looation di'41ided by COMANCHE PEAK-UNITS 1 AND 2 5.5-6 Amendment No. 150,154, 158,161,168, 173 to TXX-22020 Page 2 of 2 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (continued)

a.

b.

C.

d.

34.

After the first refueling outage follo1Ning SG installation, inspect100%

of the tubes during the next 14 4 effective full power rnonths. This constitutes the first inspection period; During the next 120 effectii.*e full power months, inspect 100%of the tubes. This constitutes the second inspection period; During the next 96 effective full po1Ner rnonths, inspect 100% ofthe tubes. This constitutes the third inspection period; and During the rernaining life of the SGs, inspect 100% of the tubese1.*ery 72 effective full po1.-.,er rnonths. This constitutes the fourth and subsequent inspection periods.

FOF Unit 1, ilf 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 the degradation mechanism that caused the crack indications shall -Aet-be at the next e~meed 24 effective full po*Ner rnonths or one refueling outage (1.t,1hiche1.ier results in rnore frequent inspections), but for Unit 2, the next inspection may be deferred to the following refueling outage if the 100% inspection of all SGs was performed with enhanced probes as described in paragraph d.2. i-f crack indications are found in any SG tube frorn 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 rnechanisrn that caused the crack indications shall not e~meed 24 effective full poi.11er rnonths or one refueling outage (1Nhichever results in rnore 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.

COMANCHE PEAK - UNITS 1 AND 2 5.5-8 Amendment No. 150, 161, 168, 173 to TXX-22020 Page 1 of 1 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued)

1.

Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.

2.

For the Unit 1 model 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 thermally 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 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 the degradation mechanism that caused the crack indications shall be at the next refueling outage, but for Unit 2, the next inspection may be deferred to the following refueling outage if the 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.

COMANCHE PEAK - UNITS 1 AND 2 5.5-6 Amendment No. 4-73, 182 to TXX-22020 Page 1 of 1 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Steam Generator (SG) Program (continued)

1.

Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.

2.

For the Unit 1 model 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 thermally 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 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 the degradation mechanism that caused the crack indications shall be at the next refueling outage, but for Unit 2, the next inspection may be deferred to the following refueling outage if the 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.

COMANCHE PEAK - UNITS 1 AND 2 5.5-6 Amendment No. ~. 182