ML22124A304
| ML22124A304 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/05/2022 |
| From: | Vincent Gaddy Region 4 Engineering Branch 1 |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2022003 | |
| Download: ML22124A304 (10) | |
See also: IR 05000445/2022003
Text
May 05, 2022
Mr. Ken Peters, Senior Vice President
and Chief Nuclear Officer
VISTRA Operating Company, LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
NOTIFICATION OF NRC TRIENNIAL HEAT EXCHANGER/SINK
PERFORMANCE INSPECTION (05000445/2022003 AND 05000446/2022003)
AND REQUEST FOR INFORMATION
Dear Mr. Peters:
The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff
will conduct the triennial portion of the heat exchanger/sink performance inspection at your
Comanche Peak Nuclear Power Plant, Units 1 and 2, from July 25 - 29, 2022. The onsite phase
of the inspection will consist of two reactor inspectors from the NRCs Region IV office for one
week. The inspection will be conducted in accordance with NRC Inspection Procedure (IP) 71111, Attachment 07, Heat Exchanger/Sink Performance, dated October 21, 2020.
The objectives of the inspection are to verify that: 1) any potential heat exchanger deficiencies
which could mask degraded performance are identified, 2) any potential common-cause heat
sink performance problems that have the potential to increase risk are identified, and 3) the
licensee has adequately identified and resolved heat sink performance problems that could
result in initiating events or affect multiple heat exchangers in mitigating systems and thereby
increase risk.
To minimize the impact the inspection has on the site and to ensure an efficient inspection, we
have enclosed a request for information needed for the inspection. It is important that these
requests are fulfilled as completely and accurately as possible to minimize any additional
requests during the preparation week or during the onsite inspection. The requests have been
divided into three groups.
The first group lists information necessary for our initial inspection scoping activities.
This information should be available to the lead inspector no later than June 6, 2022.
After reviewing the information, the lead inspector will communicate the selected 2-4 risk
significant or safety-related heat exchanger and/or heat sink samples as soon as
practical. The lead inspector will also communicate whether only a subset of the second
group information requests is required.
K. Peters 2
The second group of information requested includes those items needed to support our
in-office preparation activities. This set of documents should be available no later than
July 11, 2022. This information should be separated for each selected component.
Note that the inspector(s) may identify during the preparation week additional
information needed to support the inspection and will communicate those requests as
soon as practicable.
The third group of information requested includes the additional documentation identified
during in-office preparation activities as well as other resource requests necessary to
support our onsite inspection activities. The additional information or resources should
be available throughout the week of onsite inspection activities beginning on July 25,
2022.
If a request does not apply (or there are no responsive documents) for any heat exchanger/heat
sink sample, no response is necessary though a brief explanation is beneficial. Include all
attachments, addendums, enclosures, etc. to the requests as applicable. Please organize
responses in the manner presented in the enclosure.
We have discussed the schedule for this inspection with your staff and understand that our
regulatory contact for this inspection will be Gary Merka of your Regulatory Affairs organization.
If there are any questions about this inspection or the documents requested, please contact the
lead inspector, Jonathan Braisted, by telephone at 817-200-1469 or by e-mail at
Jonathan.Braisted@nrc.gov as soon as practicable.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office
of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and
Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor sponsor, and a person is not required to respond to, a request
for information or an information collection requirement unless the requesting document
displays a currently valid OMB control number.
K. Peters 3
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Signed by Gaddy, Vincent
on 05/05/22
Vincent G. Gaddy, Chief
Engineering Branch 1
Division of Reactor Safety
Docket No(s). 05000445 and 05000446
License No(s). NPF-87 and NPF-89
Enclosure:
Request for Information
Cc w/ encl: Distribution via LISTSERV
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JDB Yes No Publicly Available Sensitive NRC-002
OFFICE RI:DRS/EB1 BC:DRS/EB1
NAME JBraisted VGaddy
SIGNATURE /RA/ /RA/
DATE 5/4/2022 5/4/2022
Request for Information
Triennial Heat Exchanger/Sink Performance Inspection
Comanche Peak Nuclear Power Plant, Units 1 and 2
Inspection Report: 05000445/2022003 and 05000446/2022003
Inspection Dates: July 25 - 29, 2022
Inspection Procedure: IP 71111.07, Triennial Heat
Exchanger/Sink Performance
Lead Inspector: Jonathan Braisted, Reactor Inspector
I. Information Requested by June 6, 2022:
1. Copy of any heat exchanger/heat sink program documents including Generic Letter (GL) 89-13 programs or aging management programs (AMPs).
2. Copy of any original and/or supplemental responses to GL 89-13.
3. Copy of any current requirements and/or commitments related to GL 89-13 or AMPs.
4. Copy of any heat exchanger/heat sink program self-assessments, audits, etc. since last
NRC triennial heat exchanger/heat sink inspection.
5. Copy of the updated final safety analysis report, technical specifications, technical
requirements manual, preventive maintenance program, and inservice inspection
program. Include bases documents as applicable.
6. List of safety-related, risk-significant, or GL 89-13 program heat exchangers in order of
risk significance.
7. List of corrective action program documents with title and/or brief description related to
heat exchangers/heat sinks since last NRC triennial heat exchanger/heat sink
inspection.
II. Information Requested by July 11, 2022:
1. For the selected heat exchangers that are directly cooled by the service water (or open
water) system:
a. Documentation of performance testing (i.e., heat transfer, temperature
effectiveness, etc.) and/or monitoring methods (i.e., pressure loss, temperature
difference, etc.) such as technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
b. Documentation of as-found/as-left periodic flow testing and/or flow balancing
such as technical reports, complete work orders, implementing procedures, etc.
Limit response to last six of each.
Enclosure
c. Documentation of visual inspections, non-destructive examinations (i.e., eddy-
current, ultrasonic testing, etc.), and cleanings such as technical reports,
complete work orders, implementing procedures, etc. Limit response to last six
of each.
d. Documentation of biotic fouling and/or macrofouling treatment such as technical
reports, complete work orders, implementing procedures, etc. Limit response to
last six of each.
e. Copy of the tube plugging map, tube plugging criteria, and heat exchanger
margin if based upon tube plugging.
f. Copy of any relevant design basis calculations including any evaluations of the
potential for water hammer.
g. Copy of the applicable system health report, design basis document, and/or
system description.
h. Copy of any relevant system piping and instrumentation diagrams.
i. Copy of the heat exchanger design specification, heat exchanger data sheet, and
any relevant vendor manuals.
j. Copy of the heat exchanger (and motor/fan if an air-to-water heat exchanger)
preventive maintenance (PM) schedule including the frequency of those PM
activities and their bases.
k. Copy of documentation of completed PM activities if not already provided. Limit
response to last six of each.
2. For the selected heat exchangers that are directly cooled by a closed loop cooling water
system:
a. Documentation of performance testing (i.e., heat transfer, temperature
effectiveness, etc.) and/or monitoring methods (i.e., pressure loss, temperature
difference, etc.) such as technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
b. Documentation of as-found/as-left periodic flow testing and/or flow balancing
such as technical reports, complete work orders, implementing procedures, etc.
Limit response to last six of each.
c. Documentation of visual inspections, non-destructive examinations (i.e., visual,
eddy-current, ultrasonic testing, etc.), and cleanings such as technical reports,
complete work orders, implementing procedures, etc. Limit response to last six
of each.
d. Copy of the tube plugging map, tube plugging criteria, and heat exchanger
margin if based upon tube plugging
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e. Results from chemical treatments such as technical reports, complete work
orders, implementing procedures, etc. Limit response to last six of each.
f. Copy of any relevant design basis calculations including any evaluations of the
potential for water hammer.
g. Copy of the applicable system health report, design basis document, and/or
system description.
h. Copy of any relevant system piping and instrumentation diagrams.
i. Copy of the heat exchanger design specification, heat exchanger data sheet, and
any relevant vendor manuals.
j. Copy of the heat exchanger (and motor/fan if an air-to-water heat exchanger) PM
schedule including the frequency of those PM activities and their bases.
k. Copy of documentation of completed PM activities if not already provided. Limit
response to last six of each.
3. For the selected ultimate heat sink (UHS):
a. Forced draft cooling tower or spray pond UHS:
i. Copy of any calculations that demonstrate sufficient reservoir capacity.
ii. Documentation of periodic monitoring and trending of sediment such as
technical reports, complete work orders, implementing procedures, etc.
Limit response to last six of each.
iii. Documentation of any performance monitoring of heat transfer capability
such as technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
iv. Documentation of UHS structural integrity monitoring such as technical
reports, complete work orders, implementing procedures, etc. Limit
response to last six of each.
b. Operation of the service water system (SWS) and UHS:
i. List of modifications to the SWS and UHS.
ii. Copy of procedures for a loss of SWS or UHS.
iii. Copy of the applicable system health report, design basis document,
and/or system description.
iv. Documentation of biotic fouling and macrofouling treatments such as
technical reports, complete work orders, implementing procedures, etc.
Limit response to last six of each.
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v. Documentation of chemistry monitoring such as technical reports,
complete work orders, implementing procedures, etc. Limit response to
last six of each.
vi. Copy of any evaluation of strong-pump to weak-pump interactions.
c. Performance testing of the SWS and UHS:
i. Documentation of inservice testing of SWS/UHS pumps, valves, and fans
such as technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
ii. Documentation of SWS flow balance testing such as complete work
orders, implementing procedures, etc. Limit response to last six of each.
iii. Documentation of diagnostic testing for valves that interface with safety-
related service water and nonsafety-related or nonseismic piping systems
such as complete work orders, implementing procedures, etc. Limit
response to last six of each.
iv. Documentation of performance testing of risk-significant nonsafety-related
functions (or alignments) of the SWS such as complete work orders,
implementing procedures, etc. Limit response to last six of each.
d. Service water and/or closed cooling water system:
i. Documentation of inaccessible pipe testing, inspection (i.e., visual,
ultrasonic, etc.), and/or monitoring such as technical reports, complete
work orders, implementing procedures, etc. Limit response to last six of
each.
ii. Copy of any evaluations of active thru wall pipe leaks.
iii. Copy of any corrective action documents related to thru wall pipe leakage
including trend evaluations since last NRC triennial heat exchanger/heat
sink inspection.
iv. For closed cooling water systems, copy of any trend data on make-up to
the system since last NRC triennial heat exchanger/heat sink inspection.
v. Documentation of protective coatings inspections such as technical
reports, complete work orders, implementing procedures, etc. Limit
response to last six of each.
vi. For deep draft vertical pumps, documentation of diagnostic testing (or
equivalent method) such as, technical reports, complete work orders,
implementing procedures, etc. Limit response to last six of each.
e. Service water intake structure (SWIS):
i. Copy of the PM schedule for traveling screens and strainers the
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frequency of those PM activities and their bases.
ii. Copy of any corrective action documents related to traveling screens,
strainers, trash racks, etc. since last NRC triennial heat exchanger/heat
sink inspection.
iii. Copy of any SWS/UHS normal and abnormal operating procedures.
iv. Documentation of SWIS inspections regarding structural integrity and
silting such as technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
v. Copy of any service water pump bay water level instrument
documentation related to setpoints and calibrations such as calculations,
complete work orders, implementing procedures, etc. Limit response to
last six of each.
vi. Copy of any SWS/UHS water temperature instrumentation documentation
related to setpoints and calibrations such as calculations, complete work
orders, implementing procedures, etc. Limit response to last six of each.
vii. Copy of any evaluations of the potential for frazil ice formation.
viii. For underwater weir walls, copy of any evaluations of potential of silt
introduction.
4. UHS Containment Device or Dam
a. For an above-ground UHS encapsulated by embankments, weirs or excavated
side slopes:
i. Copy of weir or embankment design documentation, specification, etc.
ii. Copy of any licensee or third-party dam inspection documentation used to
monitor the integrity or performance of the heat sink. Limit response to
last six of each.
iii. Copy of any calculations for demonstrating sufficient reservoir capacity.
iv. Documentation of significant debris or sediment build-up monitoring in the
UHS such as any technical reports, complete work orders, implementing
procedures, etc. Limit response to last six of each.
v. Copy of any corrective action program documents related to debris,
structural integrity, seepage, settlement, rip rap, etc. since last NRC
triennial heat exchanger/heat sink inspection.
b. For underwater UHS weirs, structures, or excavations:
i. Copy of any underwater weirs, structures, or excavations design
documentation, specifications, etc.
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ii. Documentation of settlement or movement related to structural integrity
and/or capacity monitoring such as technical reports, complete work
orders, implementing procedures, etc. Limit response to last six of each.
iii. Documentation of sediment intrusion monitoring such as technical
reports, complete work orders, implementing procedures, etc. Limit
response to last six of each.
iv. Copy of any calculations for demonstrating sufficient capacity
v. Copy of any corrective action program documents related to settlement,
movement, structural integrity, sediment, etc. since last NRC triennial
heat exchanger/heat sink inspection.
III. Additional Requests During Inspection Activities Beginning July 25, 2022:
1. Supplemental requests identified during in-office preparation activities.
2. Additional requests identified during onsite inspection activities.
3. Discussions with relevant subject matter experts.
4. Walkdowns of selected heat exchanger/heat sink samples.
5. Corrective action program documents generated because of this inspection.
If the information requested above will not be available, please contact the lead inspector,
Jonathan Braisted, as soon as possible.
Inspector Contact Information:
Jonathan Braisted, Lead Ron Kopriva
Reactor Inspector Senior Reactor Inspector
817-200-1469 817-200-1104
Jonathan.Braisted@nrc.gov Ron.Kopriva@nrc.gov
Mailing Address:
U.S. NRC, Region IV
Attn: Jonathan Braisted
1600 East Lamar Blvd.
Arlington, TX 76011-4511
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