CP-202300433, License Renewal Application Annual Update 1
| ML23290A273 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/17/2023 |
| From: | John Lloyd Luminant, Vistra Operating Co. (VistraOpCo) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CP-202300433, TXX-23070 | |
| Download: ML23290A273 (1) | |
Text
Jay Lloyd Senior Director, Engineering
& Regulatory Affairs Comanche Peak Nuclear Power Plant (Vistra Operations Company LLC)
P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.5337 Ref 10 CFR 54 CP-202300433 TXX-23070 October 17, 2023 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-445 AND 50-446 FACILITY OPERATING LICENSE NUMBERS NPF-87 and NPF-89 LICENSE RENEWAL APPLICATION ANNUAL UPDATE 1
REFERENCES:
1.
Letter TXX-22077, from Steven K. Sewell to the NRC, submitting Comanche Peak Nuclear Power Plant License Renewal Application, October 3, 2022 (ADAMS Accession No. ML22276A082) 2.
Letter TXX-23012, from Jay Lloyd to the NRC, submitting Comanche Peak Nuclear Power Plant License Renewal Application Revision 0, Supplement 1, April 6, 2023 (ADAMS Accession No. ML23096A302) 3.
Letter TXX-23022, from Jay Lloyd to the NRC, submitting Comanche Peak Nuclear Power Plant License Renewal Application Revision 0, Supplement 2, April 24, 2023 (ADAMS Accession No. ML23114A377) 4.
NRC Order, from Robert F. Kuntz (NRC) to Ken J. Peters (Vistra OpCo) and David B. Hamilton (Energy Harbor Nuclear Corp.), Order Approving Transfer of Licenses and Draft Conforming License Amendments, September 28, 2023 (ADAMS Accession Nos. ML23237B422, ML23237B427, ML23237B428, and ML23237B430)
Dear Sir or Madam:
In Reference 1, as supplemented by References2 and 3, Vistra Operations Company LLC (Vistra OpCo) submitted a license renewal application (LRA) for the Facility Operating Licenses for Comanche Peak Nuclear Power Plant (CPNPP) Units 1 and 2.
The License Renewal Rule, 10 CFR 54.21(b), requires Vistra OpCo to report changes to the Current Licensing Basis (CLB) that materially affect the contents of the LRA, including the Final Safety Analysis Report (FSAR) Supplement. These changes are required to be submitted each year following submittal of the license renewal application and at least 3 months before scheduled completion of the NRC review.
In accordance with the License Renewal Rule, Vistra OpCo has performed the annual review of CPNPP Units 1 and 2 CLB changes since LRA submittal to determine whether any sections of the LRA were materially affected by these changes. As a result of this review, Vistra OpCo has identified three material changes to the LRA due to CLB changes. These material changes are described in Attachments A through C.
TXX-23070 Page 2 of 3 Vistra OpCo has identified one clarification to the CPNPP Units 1 and 2 LRA, as described in Attachment D. Updates to the CPNPP LR Environmental Report are described in Attachment E.
For ease of reference, the index of attached information is provided on page 3 of this letter. Attachments A through D include associated revisions to the LRA. For clarity, revisions to the LRA are provided with deleted text by strikethroughs and inserted text by bold red underline. Previous LRA revisions are denoted by bold black text. Revisions to LRA tables are shown by providing excerpts from each affected table.
In Reference 4, the U.S. Nuclear Regulatory Commission approved the license transfers resulting from a proposed transaction between Vistra OpCo and Energy Harbor Corp. This reference provides information relative to Chapter 1 of the LRA.
This communication contains no new commitments regarding CPNPP Units 1 and 2.
Should you have any questions, please contact Todd Evans at (254) 897-8987 or Todd.Evans@luminant.com.
I state under penalty of perjury that the foregoing is true and correct.
Executed on October 17, 2023 Sincerely, Jay Lloyd Attachments c:
(email) w / o Attachments Mahesh Chawla, NRR, DORL [Mahesh.Chawla@mc.gov]
Dominic Antonangeli, RGN IV, CPNPP [Dominic.Antonangeli@mc.gov]
Victor Dricks, RGN IV /OPA [Victor.Dricks@mc.gov]
John Ellegood, RGN IV, CPNPP [John.Ellegood@mc.gov]
Dennis Galvin, NRR [Dennis.Galvin@mc.gov]
Lauren Gibson, NRR/DNRL [Lauren.Gibson.me.gov]
Jessica Hammock, NRR, DNRL Uessica.Hammock@mc.gov]
Jim Melfi, RGN IV [Jim.Melfi@mc.gov]
Robert Lewis, RGN IV [Robert.Lewis@mc.gov]
Greg Pick RGN IV [Greg.Pick@mc.gov]
David Proulx, NRR/RGN IV [David.Proulx@mc.gov]
Mark Yoo, NRR/DNRL [Mark.Yoo@mc.gov]
Chris Smith, RGN IV [Chris.Smith@mc.gov]
Theodore Smith, NMSS/REFS [Theodore.Smith@mc.gov]
Tam Tran, NMSS/REFS [Tam.Tran@mc.gov]
Nick Taylor, RGN IV [Nick.Taylor@mc.gov]
Greg Werner, RGN IV [Greg.Werner@mc.gov]
TXX-23070 Page 3 of 3 Attachment Index Attachment CPNPP LRA Update Topics A
Operating Experience - Calcium Build-Up B
Structures Monitoring Updates C
Projected OBE Cycle Updates D
Editorial Clarifications E
Environmental Report Clarifications
Attachment A:
Operating Experience - Calcium Build-Up 5 pages follow TXX-23070
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment A Page 1 of 5 Operating Experience - Calcium Build-Up Affected LRA Sections: 3.5.2.2.2.1 Item 4, 3.5.2.2.2.3 Item 3, Table 3.5-1 Item 3.5-1, 047 LRA Page Numbers: 3.5-30, 3.5-34, 3.5-51 Description of Change:
During a walkdown in September 2023, signs of calcium build-up were observed in concrete located near the roof of the Auxiliary Building. The build-up is limited to the surface level of the concrete. An engineering evaluation was performed and defined the degradation as non-structural surface indications in accordance with site specification. Calcium build-up may indicate that leaching of calcium hydroxide and carbonation is occurring. Increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation is an aging effect requiring management for concrete (which is exposed to the water-flowing environment in the form of rainwater) and is managed by the CPNPP Structures Monitoring AMP.
Discussions in the LRA (ML22276A082), as updated in Supplement 2 (ML23114A377), state that a review of operating experience did not find evidence of leaching of calcium hydroxide or carbonation at CPNPP. These discussions are updated to reflect this recent operating experience.
References:
None.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment A Page 2 of 5 LRA Section 3.5.2.2.2.1 Item 4 (page 3.5-30), is revised as follows:
4.
Increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide and carbonation could occur in below grade inaccessible concrete areas of Groups 1-5 and 7-9 structures. The GALL Report recommends further evaluation if leaching is observed in accessible areas that impact intended functions.
Groups 1, and 3 through 7 structures at CPNPP are designed in accordance with ACI 318 71 and constructed in accordance with ACI 301 72 using ingredients/materials conforming to ACI and ASTM standards. Concrete aggregates conform to the requirements of ASTM C-33-74 (fine and coarse aggregate). Materials for concrete used in CPNPP concrete structures and components were specifically investigated, tested, and examined in accordance with pertinent ASTM standards. Concrete structures and CC are constructed of a dense, well-cured concrete with an amount of cement suitable for strength development and achievement of a water-to-cement ratio that is characteristic of concrete having low permeability.
As summarized in item 3.5-1, 047, the ECB, SGBs, and TBs are the buildings in the scope of LR whose foundation extends below the water table and are exposed to groundwater that is more than absorbed surface or perched water. Recent monitoring of the groundwater chemistry at CPNPP has revealed that the groundwater is not aggressive (Chloride <500 ppm, Sulfates
<1500 ppm, and Ph >5.5) with respect to chlorides, pH, or sulphates. Therefore, below-grade inaccessible concrete for the ECB, SGBs, and TBs are exposed to conditions that may result in increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide or carbonation. Conversely, the below grade portions of the AB, DGBs, FB, switchgear buildings, yard structures, and switchyard structures are located above the water table and leaching is not expected to occur.
Leaching of calcium hydroxide is commonly applicable for a flowing water environment.
Consistent with NUREG-1801, water-flowing can include rainwater or groundwater. However, aA review of operating experience for CPNPP has not found evidence ofthat leaching of calcium hydroxide or carbonation may have occurred for accessible concrete at CPNPP.
Accessible external concrete locations near the roof of the Auxiliary Building are showing signs of calcium build-up. These instances have been entered into the Corrective Action Program and an engineering evaluation in accordance with site specification determined that these are surface-level non-structural indications and that there was no loss of intended function. ThereforeFurthermore, increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide or carbonation is not expected but could occur in the future for exterior above-grade concrete due to water-flowing from heavy rains and for below-grade portions of the ECB, SGBs, and TBs as leading indicators. However, tThe Structures Monitoring (B.2.3.34) AMP continues to inspect and monitor concrete structures within the scope of LR. CPNPP also examines exposed portions of below-grade (inaccessible) concrete, when excavated for any reason, in accordance with the Structures Monitoring (B.2.3.34) AMP. As such, the absence of an increase in porosity and permeability and loss of strength, due to leaching of calcium hydroxide or carbonation, is managed will be confirmed by the Structures Monitoring (B.2.3.34) AMP and a plant-specific AMP is not required.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment A Page 3 of 5 LRA Section 3.5.2.2.2.3 Item 3, page 3.5-34, is revised as follows (text from LRA page 3.5-33 included for clarity):
3.
Increase in porosity and permeability and loss of strength due to leaching of calcium hydroxide and carbonation could occur in inaccessible areas of concrete elements of Group 6 structures. The GALL Report recommends further evaluation if leaching is observed in accessible areas that impact intended functions. Acceptance criteria are described in Branch Technical Position RLSB 1 (Appendix A.1 of this SRP LR).
As summarized in item 3.5-1, 051, structures at CPNPP including Group 6 structures are designed in accordance with ACI 318-71 and constructed in accordance with ACI 301-72 using ingredients/materials conforming to ACI and ASTM standards. Concrete aggregates conform to the requirements of ASTM C-33-74 (fine and coarse aggregate). Materials for concrete used in CPNPP concrete structures and components were specifically investigated, tested, and examined in accordance with pertinent ASTM standards. Cracking is controlled through proper arrangement and distribution of reinforcing steel. Concrete structures are constructed of a dense, well cured concrete with an amount of cement suitable for strength development and achievement of a water to cement ratio that is characteristic of concrete having low permeability.
This is consistent with the recommendations and guidance provided by ACI 201.2R. A review of operating experience for CPNPP has not found evidence thatof leaching of calcium hydroxide or carbonation may have occurred for accessible concrete structures.
Accessible external concrete locations near the roof of the Auxiliary Building are showing signs of calcium build-up. These instances have been entered into the Corrective Action Program and an engineering evaluation in accordance with site specification determined that these are surface-level non-structural indications and that there was no loss of intended function. However, tThe below grade surfaces of the SWIS are exposed to raw water and groundwater below the water table, both of which are considered water-flowing for LR.
Therefore, a change in material properties (described as increase in porosity and permeability, and loss of strength) due to leaching of calcium hydroxide and carbonation in inaccessible areas of below grade concrete may be an aging effect for the CPNPP SWIS. Therefore, the Structures Monitoring (B.2.3.34) AMP will manage the aging effect for inaccessible concrete areas. Condition of below grade inaccessible structures is based on evaluation of inspection results from accessible areas. In addition, the Structures Monitoring AMP (B.2.3.34) includes opportunistic inspections of inaccessible concrete if exposed due to excavations for other reasons. As such, the absence of an increase in porosity and permeability and loss of strength, due to leaching of calcium hydroxide or carbonation, is managed will be confirmed by the Structures Monitoring (B.2.3.34) AMP and a plant-specific AMP is not required.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment A Page 4 of 5 LRA Table 3.5-1, page 3.5-51, is revised as follows:
Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Commodities Item Number Component Aging Effect Requiring Management Aging Management Program Further Evaluation Recommended Discussion 3.5-1, 047 Groups 1-5, 7-9:
concrete (inaccessible):
exterior above-and below-grade; foundation Increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation Further evaluation is required to determine if a plant-specific aging management program is needed.
Yes, if leaching is observed in accessible areas that impact intended function (See SRP subsection 3.5.2.2.2.1.4)
Consistent with the OE reflected in SLR-ISG-2021-03-STRUCTURES, a plant-specific AMP is not required for inaccessible concrete areas of Group 1, and 3 through 5, and 7 structures with foundations exposed to groundwater. A review of operating experience for CPNPP has not found evidence of any leaching of calcium hydroxide or carbonation in inaccessible above or below grade concrete. However, evidence has been found that leaching of calcium hydroxide or carbonation may have occurred in accessible above grade concrete. Accessible external concrete locations near the roof of the Auxiliary Building are showing signs of calcium build up on the surface level.
Group 2 and 9 structures are not present at CPNPP. No concrete foundations were evaluated with Group 8 (metallic) structures at CPNPP. The FWST foundation is a Yard Structure (Group 3).
For LR, groundwater (other than seepage from the surface) and rainwater are is considered to be flowing water where leaching or carbonation could occur.
The Structures Monitoring (B.2.3.34) AMP includes opportunistic inspection of inaccessible concrete surfaces, when excavated for other reasons, and will include evaluation of impact to inaccessible areas if leaching or carbonation is observed in accessible areas.
Further evaluation is documented in subsection 3.5.2.2.2.1, item 4.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment A Page 5 of 5 LRA Table 3.5-1, page 3.5-54, is revised as follows:
Table 3.5-1 Summary of Aging Management Programs for Containments, Structures and Commodities Item Number Component Aging Effect Requiring Management Aging Management Program Further Evaluation Recommended Discussion 3.5-1, 051 Groups 6 - concrete (inaccessible): exterior above-and below-grade; foundation; interior slab Increase in porosity and permeability; loss of strength due to leaching of calcium hydroxide and carbonation Further evaluation is required to determine if a plant-specific aging management program is needed.
Yes, if leaching is observed in accessible areas that impact intended function (See SRP subsection 3.5.2.2.2.3.3)
Consistent with the OE reflected in SLR-ISG-2021-03-STRUCTURES, a plant-specific AMP is not required for the inaccessible areas of the CPNPP SWIS (Group
- 6) structure. A review of operating experience for CPNPP has not found evidence of any leaching of calcium hydroxide or carbonation in inaccessible above or below grade concrete. However, evidence has been found that leaching of calcium hydroxide or carbonation may have occurred in accessible above grade concrete. Accessible external concrete locations near the roof of the Auxiliary Building are showing signs of calcium build up on the surface level.
The Structures Monitoring (B.2.3.34) AMP will be credited to manage increase in porosity and permeability and loss of strength of inaccessible concrete surfaces of the SWIS (intake bay) exposed to a flowing water environment (squaw creek reservoir water or groundwater), based on the conditions in accessible areas.
In addition, accessible areas of the SWIS exposed to water - flowing are addressed in item 3.5-1, 061.
Further evaluation is documented in subsection 3.5.2.2.2.3, item 3.
Attachment B:
Structures Monitoring Updates 5 pages follow
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-20230433 Annual Update, Attachment B Page 1 of 5 Structures Monitoring Updates Affected LRA Sections: Table A-3 item 36, and Section B.2.3.34 LRA Page Numbers: A-84, B-193 Description of Change:
Visual inspections of buildings every five years, per the structures monitoring procedure, would record degradation of component supports and process it through the corrective action program, if any is identified. A separate, focused inspection of a sample of component supports is presently conducted every ten years.
Relative to the inspection of component supports through the Structures Monitoring Program for license renewal, an enhancement is added to reduce the interval of component support inspections to five years and ensure they are included in the inspections, to be consistent with the guidance in NUREG-1801 Rev. 2 AMP XI.S6.
References:
- 1. Letter TXX-23022, from Jay Lloyd to the NRC, submitting Comanche Peak Nuclear Power Plant License Renewal Application Revision 0, Supplement 2, April 24, 2023 (ADAMS Accession No. ML23114A377)
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-20230433 Annual Update, Attachment B Page 2 of 5 LRA Table A-3, item 36 (page A-84), is revised as follows:
No.
Aging Management Program or Activity (Section)
NUREG-1801 Section Commitment Implementation Schedule 36 Structures Monitoring (A.2.2.34)
XI.S6 Continue the existing Structures Monitoring AMP, including enhancements to:
a)
Include the Diesel Generator Buildings, Switchgear Buildings, Transmission Towers associated with Startup Transformers (XST1, XST2), Alternate Start-up Transformers (XST1A, XST2A),
Firewater Valve Houses, Seismic Category I Manholes, Handholes, and Duct Banks, and Plant Effluent Holdup and Monitor Tanks and pipe encasement in the scope of the Structures Monitoring AMP.
b)
Perform periodic sampling and testing of groundwater chemistry at a frequency once every 5 years to determine the quality of groundwater.
c)
Inspect structural members of crane supports, high energy line break (HELB) and spray shields, stairs, and platforms, industrial and HELB doors.
d)
Include exposed steel embedments in the Steel Structural Elements group e)
Inspect concrete structures for increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.
f)
Visually inspect concrete structures for unique cracking such as "craze", "mapping" or "patterned" cracking to determine the presence of alkali-silica gel.
g)
Provide guidance for documenting significant findings of the inspection, consistent with ACI 349.3R Section 3.5.5 to monitor and trend the extent of degradation.
h)
Provide guidance for documentation and archival requirements in accordance with ACI 349.3R Section 3.4.
No later than 6 months prior to the PEO, i.e.:
U1: 08/08/2029 U2: 08/02/2032, or no later than the last refueling outage prior to the PEO.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-20230433 Annual Update, Attachment B Page 3 of 5 No.
Aging Management Program or Activity (Section)
NUREG-1801 Section Commitment Implementation Schedule i)
Provide guidance for inspection reports to be completed in accordance with ACI 349.3R Section 3.5.5.
j)
Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
k)
Specify the qualification requirements for inspection of structures and components as well as the requirements for the reviewer to match the ACI 349.3R current code requirements.
l)
Specify that the selection of bolting material, lubricants, and installation torque or tension are in accordance with the guidelines of EPRI NP-5769, NP-5067, EPRI TR-104213, and the additional recommendations of NUREG-1339 to prevent or mitigate degradation and failure of structural bolting.
m) Specify the use of preventive actions for storage, lubricants, and SCC potential in Section 2 of Research Council for Structural Connections publication, Specification for Structural Joints Using ASTM A325 or A490 Bolts, for structural bolting consisting of ASTM A325, or A490, and equivalent bolts.
n)
Prohibit the use of molybdenum disulfide (MoS2) or other sulfur containing lubricants for structural bolts.
o)
Monitor structural sealants for cracking, loss of material, and hardening.
p)
Specify that the condition of structural sealants is acceptable if observed loss of material, cracking, and hardening will not result in loss of sealing.
q)
Require engineering evaluation, more frequent inspections, or destructive testing of affected concrete (to validate properties) if ground water leakage is identified. When leakage volumes allow, assessments may include analysis
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-20230433 Annual Update, Attachment B Page 4 of 5 No.
Aging Management Program or Activity (Section)
NUREG-1801 Section Commitment Implementation Schedule of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.
r)
Ensure component supports are included in the inspections every 5 years.
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-20230433 Annual Update, Attachment B Page 5 of 5 LRA Section B.2.3.34 (page B-193) is revised as follows:
Element Affected Enhancement
- 4. Detection of Aging Effects
Ensure component supports are included in the inspections every 5 years.
Evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
Update the qualification requirements for inspection of structures and components as well as requirements for the reviewer to match ACI 349.3R current code requirements.
Require engineering evaluation, more frequent inspections, or destructive testing of affected concrete (to validate properties) if ground water leakage is identified. When leakage volumes allow, assessments may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.
- 5. Monitoring and Trending Provide guidance for documenting significant findings of the inspection, consistent with ACI 349.3R Section 3.5.5 to monitor and trend the extent of degradation.
Attachment C: Projected OBE Cycle Updates 4 pages follow
Westinghouse Non-Proprietary Class 3 Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment C Page 1 of 4 Updates to Table 4.3.1-2 and 4.3.1-4 and Section 4.3.3 Projected Cycles for Operational Basis Earthquake Affected LRA Sections: Sections 4.3.1 and 4.3.3 LRA Page Numbers: Pages 4.3-5, 4.3-8, and 4.3-10 Description of Change:
This supplement provides updates to Sections 4.3.1 and 4.3.3 of the LRA. The number of projected cycles for the Operational Basis Earthquake transient should be updated from 2 to 20 cycles, representing 2 events with 10 cycles per event, in LRA Table 4.3.1-2. As a result, the number of projected cycles should be updated for the non-Class 1 systems and piping in LRA Table 4.3.1-4 and LRA Section 4.3.3.
References:
None
Westinghouse Non-Proprietary Class 3 Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment C Page 2 of 4 LRA Table 4.3.1-2 in Section 4.3.1 (page 4.3-5) is revised as follows:
Operational Basis Earthquake 2 20(f) 2 20(f) 200 The notes in LRA Table 4.3.1-2 in Section 4.3.1 (page 4.3-6) are revised as follows:
Notes:
(a) This transient is insignificant to fatigue and was excluded from the 60-year projections.
(b) The CPNPP units are not licensed to operate with a loop shutdown. Therefore, no cycles of this transient have occurred, and none are projected.
(c) This transient is only applicable to Unit 2.
(d) Transients with no margin are test, emergency, or faulted condition transients for which 60-year projected values were not calculated, but instead the design value was applied to 60-years.
(e) This transient only applicable to Unit 1.
(f) The Operational Basis Earthquake projected cycles are based on 2 events with 10 cycles per event.
Westinghouse Non-Proprietary Class 3 Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment C Page 3 of 4 LRA Table 4.3.1-4 in Section 4.3.1 (page 4.3-8), as modified by Supplement W7 (ML23096A302) and Luminants response to NRC RAI 4.3.3-1 (ML23208A193), is revised as follows:
Table 4.3.1-4 CPNPP 60-year Projected Transient Cycle Totals for Non-Class 1 Systems and Piping Piping Line/System CPNPP Projected Cycles Cycle Limit Unit 1
Unit 2
RHR Hot Leg Loops 1 and 4 4001 4019 4167 4185 7000 ECCS/BIT Cold Legs 1, 2, 3, and 4 3961 3979 4116 4134 7000 Accumulator Cold Legs 1, 2, 3, and 4, SI/RHR Return, and SIS Connection to Accumulator 3959 3977 4114 4132 7000 RCP Seal Water Injection Line 4055 4073 4225 4243 7000 Normal and Alternate Charging and Letdown Branch Line 4228 4246 4341 4359 7000 Normal Letdown and Excess Letdown Branch Line 3940 3958 4094 4112 7000 Pressurizer Auxiliary Spray Line 3928 3946 4083 4101 7000 Pressurizer Safety and Relief Valve Inlet Line 3993 4011 4153 4171 7000 Feed Water Piping 897 676 7000 Main Steam Line - Piping Upstream of MISVs 3926 3944 4081 4099 7000 Main Steam Line - Piping Downstream of MSIVs 477 271 7000 Main Steam Line - Admitted for Operation of the Turbine Drive Auxiliary Feed Water Pump 3225 4759 7000 Process Sampling - Hot Leg Isolation 4756 3890 7000 Process Sampling - Pressurizer Liquid Sample Isolation 5183 5195 7000 Liquid Waste Processing 710 690 7000 Steam Generator Blowdown and Heater Drains 5613 5631 5635 5653 7000 Auxiliary Steam 2947 2863 7000
Westinghouse Non-Proprietary Class 3 Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment C Page 4 of 4 LRA Section 4.3.3, TLAA Evaluation (page 4.3-10) is revised as follows:
For CPNPP Unit 1, the RCS total 60-year projected transients cycles are: 3926 3944.
For CPNPP Unit 2, the RCS total 60-year projected transients cycles are: 4081 4099.
Attachment D:
Editorial Clarifications 2 pages follow
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment D Page 1 of 2 LRA Editorial Corrections Affected LRA Sections: A.3.6.9 LRA Page Numbers: A-47 Description of Change:
A LRA section is updated to resolve an editorial error.
The editorial correction is to LRA Section A.3.6.9, which is currently titled, Steam Generator U-Bend Tube Variation and Fatigue Assessment.
The word Variation should be Vibration, and LRA Section A.3.6.9 is revised as such. Note that other LRA sections do not contain this error.
References:
None
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP-202300433 Annual Update, Attachment D Page 2 of 2 LRA Section A.3.6.9 (page A-47), is revised as follows:
A.3.6.9.
Steam Generator U-Bend Tube Variation Vibration and Fatigue Assessment In some models of steam generators, particular consideration is given to the potential for high cycle fatigue of U-bend tubes. This mechanism has been observed in tubes with carbon steel support plates where denting or a fixed tube support condition has been observed in the uppermost plate and anomalous conditions existed in the AVB insertion depths or AVB support structure that could lead to unsupported tubes. The aging effects/mechanisms of the SG nickel alloy tubes include cumulative fatigue damage due to fatigue and the loss of material due to fretting and wear which can be caused by the FIV of U-bend tubes with anomalous support conditions leading to high cycle fatigue and subsequent tube failure.
Due to fabrication advancements and controls used to ensure proper anti-vibration bar insertion depths for the CPNPP Unit 1 Delta 76 RSGs, the SG tubing is not affected by the U-bend FIV and fatigue mechanism.
For CPNPP Unit 2, the U-bend tube vibration and fatigue assessment already considers 60 years of operation. The assessment assumes SG operating life is from the time of initial plant start-up to the anticipated 60-year plant operating license expiration date. Therefore, the conclusions of the assessment are applicable through the PEO in accordance with 10 CFR 54.21(c)(1)(i).
Attachment E: Environmental Report Clarifications 2 pages follow
CPNPP NATURAL GAS PIPELINE IMPACTS EVALUATION AND LR ER PERMIT UPDATES In August 2023, Vistra Operations Company, LLC (Vistra OpCo) evaluated potential impacts to the Comanche Peak Nuclear Power Plant (CPNPP) license renewal (LR) environmental report (ER) from the installation of the Worsham Steed Wolf Hollow natural gas pipeline crossing a portion of the CPNPP site (Figure 1). This evaluation of the 24-inch pipeline, routed under the Squaw Creek Reservoir, included Cultural Resources, Ecology (threatened and endangered species, aquatic resources, and wetlands), Land Use, and Cumulative Impacts. These evaluations found that there were no significant impacts (i.e., greater than SMALL) to any of the environmental resources listed above. Based on these evaluations, Vistra OpCo determined that a supplement to the CPNPP LR ER is not required regarding the installation of the natural gas pipeline project.
Figure 1 - Worsham Steed Wolf Hollow Natural Gas Pipeline Route within CPNPP Site Boundary Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP202300433 Annual Update, Attachment E Page 1 of 2
In addition, since the transmittal of the CPNPP LR ER in October 2022, three permits have been updated and are listed in Table 1 below.
Table 1 - Updated Environmental Permits for Current CPNPP Operations Agency Authority Requirement Number Expiration Date Authorized Activity DOT
[49 CFR Part 107, Subpart G];
49 USC 5108 Registration Registration ID:
060923550304F US DOT #:
2051403 Issued: 7/1/2023 Expires:
6/30/2024 Renewed Annually Hazardous material shipments.
TCEQ 30 TAC 335 Industrial and hazardous solid waste generators registration EPA ID #:
TXD020332078 Solid Waste Registration #:
33306 Permit #: 50356 Initial Registration:
2/14/1986 Last Amendment:
11/29/2022 Registration currently active Industrial waste and hazardous waste generators state registration.
TCEQ Section 402 CWA; Texas Water Code Section 26.050 Construction stormwater general permit TXR150000 Effective:
3/5/2023 Expires: 3/5/2028 General permit under the TPDES for stormwater discharges associated with construction.
References:
DOT (US Department of Transportation). 2023. PHMSA Hazmat Certificate of Registration.
Retrieved from
<https://portal.phmsa.dot.gov/HazmatRegistrationSearch/certificate?regId=060923550304F&ye arRange=2324> (accessed September 15, 2023).
TCEQ (Texas Commission on Environmental Quality). 2023a. Central Registry Query -
Regulated Entity Search. Retrieved from
<https://www15.tceq.texas.gov/crpub/index.cfm?fuseaction=regent.showSingleRN&re_id=1455 30862003087> (accessed September 15, 2023).
TCEQ. 2023b. General Permit to Discharge under the Texas Pollutant Discharge Elimination System. Retrieved from
<https://www.tceq.texas.gov/downloads/permitting/stormwater/general/construction/2023-cgp-txr150000.pdf> (accessed September 15, 2023).
Comanche Peak Nuclear Power Plant Units 1 and 2 Dockets 50-445 and 50-446 TXX-23070 and CP202300433 Annual Update, Attachment E Page 2 of 2