ML22140A108

(CPNPP) First License Renewal (60 Years) Application Pre-Application Submittal Meeting 2, Meeting Slides

ML22140A108
Person / Time
Site:	Comanche Peak
Issue date:	05/31/2022
From:	Luminant
To:	NRC/NRR/DNRL/NLRP
Sayoc E
References
Download: ML22140A108 (22)

Text

Comanche Peak Nuclear Power Plant (CPNPP)

First License Renewal (60 years) Application:

Pre-Application Submittal Meeting #2

May 2022 Opening Remarks and Introductions

Speakers Steven Sewell (Luminant)

Todd Evans (Luminant)

Taylor Smith (Luminant)

Amit Kalia (Luminant)

Participants Ramiz Gilada (Luminant)

Burns Cunningham (ENERCON)

Mitch McFarland (ENERCON)

Gary Adkins (ENERCON)

Tyler Bro (Westinghouse)

Jen Meneely (Westinghouse)

2 CPNPP Site

3 Agenda

Update of Information Provided September 2021 Aging Management Programs (AMPs)

Ti m e-Limited Aging Analysis (TLAA)

Use of SLR Operating Experience for First LR General Topics and Future Activities

4 Aging Management Programs - Overview

Total Existing AMPs AMPs New AMPs 43 32 11

Consistent with Includes Includes Includes GALL (no Exception(s) Exception(s) and Enhancement(s) exceptions or Only Enhancement(s) Only enhancements) 5 1 10 16

Plant-Specific AMPs None

5 Aging Management Programs - Exceptions

Water Chemistry, Flow-Accelerated Corrosion, and Closed Treated Water - Exceptions to use later revisions of standards which have been included in GALL-SLR Steam Generators Exception for Unit 2 model D5 tube-to -tube sheet weld inspections, NRC approved TS Amendment which exempted welds from inspection and monitoring due to design (welds are not pressure boundary). Rolled tubes are the pressure boundary.

Exceptions to use later revisions of EPRI standards Fire Water - Exception to not perform trip testing on specific deluge valves in order to protect the charcoal filter units; instead, perform periodic visual inspection Buried Piping and Tanks - Exception to continue Emergency Diesel Generator Fuel Oil Storage Tank inspections at a 20-yr frequency as opposed to the GALL 10-yr frequency. Inspection frequency evaluations have been implemented based on internal operating experience.

Fuel Oil Chemistry Exception to perform bottom-level sampling instead of multi -level sampling in the horizontal EDG fuel oil storage tanks.

The exception above for the Buried Piping and Tanks AMP is also within the Fuel Oil Chemistry AMP.

6 Aging Management Programs - Exceptions (cont )

Reactor Vessel Surveillance - Exception to not submit the U1 and U2 capsule schedule changes with LRA. Appropriate outage has not been determined. Schedule will be submitted in accordance with 10 CFR Part 50 Appendix H at least 6 months prior to PEO, or no later than the last refueling outage prior to the PEO.

Reactor Head Closure Stud Bolting - Exception to allow high strength closure studs to remain in service and spares already acquired to be placed in service.

ASME Section XI, Subsection IWF - IWF AMP requirements for examination and testing of ASME Class CC and MC components and Class MC component supports are included in separate AMPs (IWE, Overhead Heavy Load, and Structures Monitoring).

Internal Coatings - Exceptions are to:

Perform opportunistic inspections of buried cement-lined fire protection piping consistent with SLR-ISG -2021-02-MECHANICAL.

Manage coatings in an indoor air environment (the EDG intercoolers), consistent with SLR-ISG -2021-02-MECHANICAL.

Credit periodic oil sampling by the Lubricating Oil Analysis AMP instead of performing periodic inspections of internal coatings in the Safety Injection pump lubricating oil reservoirs.

Non-destructively tap test coatings surrounding a blister as an alternative to destructive adhesion testing.

7 Aging Management Programs -

NUREG-1801 AMPs Not Applicable to CPNPP

Containment Tendon - CPNPP does not have pre-stressed tendon containment design Boraflex Monitoring - CPNPP does not use boraflex in spent fuel pool Fuse Holders - Fuse holders were screened out because they are included in the EQ Program or due to their location in a larger active device or assembly, consistent with the screening guidance in NUREG-1801,Section XI.E5.

Aboveground Metallic Tanks - the CSTs, RWSTs, and RMWSTs are concrete tanks with stainless steel liners and managed by Structures Monitoring, Water Chemistry, One-Time Inspection and Internal Surfaces AMPs.

Additional tanks:

Fire Water Storage Tanks managed by Fire Water AMP.

Recycle Hold Up Tanks do not have a 54.4(a)(2) function due to their location in watertight compartments.

8 A M P - Reactor Vessel Internals

CPNPP will be implementing MRP-227 Rev 1A SLR-ISG-2021 -01 -PWRVI gap analysis Not required for 1st LR Technical Bases for SLR-ISG-2021 -01 -PWRVI CPNPP requests staff to provide a status update MRP-227-A A/LAI 1 for Inspection and Evaluation Guidelines for RVI BFB degradation addressed in AMP OE section as applicable MRP-227-A A/LAI 8 plant -specific inspection plan required previously for rev 0A will not be included in a separate Appendix C section

9 TLAA - Steam Generators

TLAA Applicable Unit(s) Category Disposition TLAA?

SG Flow-Induced 10 CFR Vibration and Tube Wear 1 and 2 54.21(c)(1)(i)

Evaluations

SG U-Bend Tube Vibration SG tube Ye s and Fatigue Assessment 2 10 CFR vibration wear 54.21(c)(1)(i) projections

SG Tube Wear Rates and Wear Projections for AVB 2 10 CFR 54.21(c)(1)(ii) and TSP Wear

SG Tubes Metal Corrosion U2 SG 10 CFR Allowance 2tube corrosion 54.21(c)(1)(i) Ye s allowance

10 TLAA - Irradiation of Service Level I Coatings

Identified as a TLAA Coatings qualified for 3x108 Rads and required to resist environmental radiation for the life of the plant Total Integrated Dose (TID) through end of PEO (60 years) remains below 3x108 Rads Dispositioned as 10 CFR 54.21(c)(1)(i), remains valid for the PEO Service Level I Coatings will continue to be managed for aging effects, other than irradiation, by the NUREG-1801 Section XI.S8 Protective Coating Monitoring and Maintenance AMP

11 TLAA - Environmentally Assisted Fatigue NUREG/CR-6260 sample set locations (newer vintage Westinghouse plant) have been evaluated:

Reactor vessel shell and lower head Reactor vessel inlet and outlet nozzles RCS charging system nozzle RCS safety injection (SI) nozzle Residual Heat Removal (RHR) system Class 1 piping - Sentinel location is RCS cold leg accumulator nozzle Pressurizer surge line (including hot leg and pressurizer nozzles) -

Sentinel location is RCS Hot Leg Surge Nozzle Environmental fatigue penalty factors taken from NUREG/CR-6909 Rev. 1 Evaluation methods include refined analyses (i.e. finite element modeling),

consideration of 60-year projected cycles, etc.

All NUREG/CR-6260 locations environmental fatigue usage results meet ASME Code fatigue usage requirements (< 1.0)

12 TLAA - Environmentally Assisted Fatigue (cont.)

EAF screening has been completed consistent with GALL Revision 2, X.M1 to identify additional plant-specific component locations that are more limiting than NUREG/CR-6260 locations EAF screening methodology utilized is as described in Section 4 of the Electric Power Research Institute (EPRI) report 3002018262 Utilizes the Section III fatigue analyses in the current licensing basis Class 1, wetted surface, pressure boundary locations Environmental fatigue penalty factors taken from NUREG/CR-6909 Rev. 1 Considers transient sections for fatigue usage results subject to similar loadings Compares fatigue usage results based on level of technical rigor in-addition to the published fatigue usage result Determines a sentinel location for each material type (i.e. low-alloy, carbon steel, stainless steel, nickel alloy) for all transient sections Additional sentinel locations will be addressed prior to entering the PEO 13 TLAA - Leak Before Break Analysis & Alloy 82/182 Welds Reactor Coolant Loop Analysis LBB considers the PWSCC effects due to alloy 82/182 welds at RPV inlet and outlet nozzles Unit 1 - Mitigated via Mechanical Stress Improvement Process (MSIP), evaluation included within the LBB analysis Unit 2 - Partial implementation of MSIP (Loop 2 Hot Leg, Loop 4 Cold Leg Nozzle), evaluation included within the LBB analysis Pressurizer Surge Line Unit 1 and Unit 2 Alloy 82/182 location at the Pressurizer Nozzle to safe end weld has been mitigated by a structural weld overlay (SWOL)

SWOL has been included within the LBB analysis

14 TLAA - Environmental Qualification

Environmental Qualification is evaluated as a TLAA in LRA Chapter 4 and Appendix A, and evaluated as an AMP in Appendices A and B Mechanical Environmental Qualification Program is currently incorporated in the CLB Mechanical Environmental Qualification Program will be removed from the CLB prior to LRA submittal in accordance with 10 CFR 50.59.

15 Use of SLR Operating Experience - Examples

Opportunistic inspections of the internal cement lining applied to buried fire protection ductile iron piping Guidance incorporated from SLR-ISG-2021 -02 -MECHANICAL in the Internal Coatings/Linings AMP Later revisions of EPRI standards endorsed by GALL-SLR Guidance incorporated in Water Chemistry AMP Guidance incorporated in Flow-Accelerated Corrosion AMP PWR Vessel Internals AMP written to SLR-ISG-2021 -01 -PWRVI requirements, which completely supersedes previous revisions of GALL

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

Additional ISGs Lessons Learned from current SLR application reviews Process changes Portal (e-room) plan Two portals - one for Westinghouse proprietary documents and one for all other documents Luminant propose file structure; NRC PM and staff provide feedback Luminant conduct an overview (virtual meeting) towards later part of sufficiency review Portal to be made available upon completion of sufficiency review

17 General Topics and Future Activities (cont)

Luminant to offer "information sessions" on the following topics:

Operating Experience Portal / e-room Audit support logistics OE and Portal information sessions towards later part of sufficiency review Audit support logistics prior to "on-site" audit Would like NRC perspective on GEIS activities

18 Questions?

Additional Information General Information Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2 Four Loop Westinghouse PWRs that are nearly identical Located in north Texas, southwest of Dallas-Fort Worth Unit 1 40 year license expires February 8, 2030 Unit 2 40 year license expires February 2, 2033 LRA written to NUREG-1801 Rev. 2 and LR-ISGs LRA submittal planned for Oct-Dec 2022 Industry Peer Review to be conducted prior to submittal Major Modifications Unit 1 SG and RVCH replacements, alternate access cut into containment (returned to original specification)

Stretch Power Uprate in 2007 Material Stress Improvement Process (MSIP) for Reactor Vessel Nozzles complete in Unit 1 and partially complete in Unit 2 Structural Weld Overlay (SWOL) for Pressurizer Nozzles

21 General Information (cont )

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

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

Vistra OpCo owned by Vistra Corp. (through an intermediary)

Project structure (Luminant, ENERCON, and WEC)

Luminant Project Team Luminant staff Subject Matter Experts ENERCON Chapters 1, 2, 3 and appendices Environmental Report (Appendix E)

Overall application assembly Westinghouse Chapter 4 TLAA Consultant review of selected documents 22