1

PMComanchePeakPEm Resource

From: Conly, John [John.Conly@luminant.com]Sent: Wednesday, April 13, 2011 3:53 PMTo: 'Aitken, Diane'; Barrie, Ashley; 'Bell, Russ'; Bird, Bobby; 'Borsh, Gina'; Buschbaum, Denny;

'Bywater, Russell'; Caldwell, Jan; Carver, Ronald; 'Certrec'; Ciocco, Jeff; Clouser, Tim; Collins, Elmo; Conly, John; Cosentino, Carolyn; Degeyter, Brock; Evans, Todd; Flores, Rafael; 'Frantz, Steve'; 'Freitag, Al'; Hamzehee, Hossein; 'Hoshi, Masaya'; 'Ishida, Mutsumi'; Johnson, Michael; 'Kawanago, Shinji'; 'Keithline, Kimberley'; 'Kellenberger, Nick'; Koenig, Allan; Kramer, John; Lucas, Mitch; Madden, Fred; Matthews, David; 'Matthews, Tim'; 'McConaghy, Bill'; Monarque, Stephen; Moore, Bill; ComanchePeakCOL Resource; 'Onozuka, Masanori'; 'Paulson, Keith'; Plisco, Loren; Reible, Robert; 'Rund, Jon'; Simmons, Jeff; Singal, Balwant; 'Sirirat, Nan'; 'Sprengel, Ryan'; Takacs, Michael; 'Tapia, Joe'; Tindell, Brian; Turner, Bruce; Volkening, David; Vrahoretis, Susan; Williamson, Alicia; Willingham, Michael; Woodlan, Don

Cc: Hill, CraigSubject: Luminant Letters TXNB-11020 and TXNB-11022Attachments: TXNB-11020 RAI 135 Supp.pdf; TXNB-11022 RAI 201, 207, 208.pdf

Luminant has submitted the two attached letters to the NRC: TXNB-11020 Supplemental response to RAI 135 addressing design features to meet 10 CFR 20.1406 TXNB-11022 Response to RAIs 201, 207, and 208 addressing the evaporation pond effluent rad monitor and the MCR envelope heater sizing calculation If there are any questions regarding these submittals, please contact me or contact Don Woodlan (254-897-6887, Donald.Woodlan@luminant.com) Thanks,

John T. Conly COLA Project Manager (254) 897-5256 Confidentiality Notice: This email message, including any attachments, contains or may contain confidential information intended only for the addressee. If you are not an intended recipient of this message, be advised that any reading, dissemination, forwarding, printing, copying or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by reply message and delete this email message and any attachments from your system.

Hearing Identifier: ComanchePeak_COL_Public Email Number: 1324 Mail Envelope Properties (D7A32D47A61872409CE74F57B83C8B011C9A2AA1EE) Subject: Luminant Letters TXNB-11020 and TXNB-11022 Sent Date: 4/13/2011 3:52:31 PM Received Date: 4/13/2011 3:53:42 PM From: Conly, John Created By: John.Conly@luminant.com Recipients: "Hill, Craig" <James.Hill@luminant.com> Tracking Status: None "'Aitken, Diane'" <diane.aitken@dom.com> Tracking Status: None "Barrie, Ashley" <Ashley.Barrie@luminant.com> Tracking Status: None "'Bell, Russ'" <rjb@nei.org> Tracking Status: None "Bird, Bobby" <Robert.Bird@luminant.com> Tracking Status: None "'Borsh, Gina'" <regina.borsh@dom.com> Tracking Status: None "Buschbaum, Denny" <Dennis.Buschbaum@luminant.com> Tracking Status: None "'Bywater, Russell'" <russell_bywater@mnes-us.com> Tracking Status: None "Caldwell, Jan" <Janice.Caldwell@luminant.com> Tracking Status: None "Carver, Ronald" <Ronald.Carver@luminant.com> Tracking Status: None "'Certrec'" <cp34update@certrec.com> Tracking Status: None "Ciocco, Jeff" <Jeff.Ciocco@nrc.gov> Tracking Status: None "Clouser, Tim" <Timothy.Clouser@luminant.com> Tracking Status: None "Collins, Elmo" <Elmo.Collins@nrc.gov> Tracking Status: None "Conly, John" <John.Conly@luminant.com> Tracking Status: None "Cosentino, Carolyn" <Carolyn.Cosentino@luminant.com> Tracking Status: None "Degeyter, Brock" <Brock.Degeyter@energyfutureholdings.com> Tracking Status: None "Evans, Todd" <Eric.Evans@luminant.com> Tracking Status: None "Flores, Rafael" <Rafael.Flores@luminant.com> Tracking Status: None "'Frantz, Steve'" <sfrantz@morganlewis.com> Tracking Status: None "'Freitag, Al'" <al_freitag@mnes-us.com>

Tracking Status: None "Hamzehee, Hossein" <Hossein.Hamzehee@nrc.gov> Tracking Status: None "'Hoshi, Masaya'" <masaya_hoshi@mnes-us.com> Tracking Status: None "'Ishida, Mutsumi'" <mutsumi_ishida@mnes-us.com> Tracking Status: None "Johnson, Michael" <Michael.Johnson@nrc.gov> Tracking Status: None "'Kawanago, Shinji'" <shinji_kawanago@mnes-us.com> Tracking Status: None "'Keithline, Kimberley'" <kak@nei.org> Tracking Status: None "'Kellenberger, Nick'" <nicholas_kellenberger@mnes-us.com> Tracking Status: None "Koenig, Allan" <Allan.Koenig@luminant.com> Tracking Status: None "Kramer, John" <John.Kramer@nrc.gov> Tracking Status: None "Lucas, Mitch" <Mitchell.Lucas@luminant.com> Tracking Status: None "Madden, Fred" <Fred.Madden@luminant.com> Tracking Status: None "Matthews, David" <David.Matthews@nrc.gov> Tracking Status: None "'Matthews, Tim'" <tmatthews@morganlewis.com> Tracking Status: None "'McConaghy, Bill'" <william_mcconaghy@mnes-us.com> Tracking Status: None "Monarque, Stephen" <Stephen.Monarque@nrc.gov> Tracking Status: None "Moore, Bill" <Bill.Moore@luminant.com> Tracking Status: None "ComanchePeakCOL Resource" <ComanchePeakCOL.Resource@nrc.gov> Tracking Status: None "'Onozuka, Masanori'" <masanori_onozuka@mnes-us.com> Tracking Status: None "'Paulson, Keith'" <ck_paulson@mnes-us.com> Tracking Status: None "Plisco, Loren" <Loren.Plisco@nrc.gov> Tracking Status: None "Reible, Robert" <Robert.Reible@luminant.com> Tracking Status: None "'Rund, Jon'" <jrund@morganlewis.com> Tracking Status: None "Simmons, Jeff" <Jeffry.Simmons@luminant.com> Tracking Status: None "Singal, Balwant" <Balwant.Singal@nrc.gov> Tracking Status: None "'Sirirat, Nan'" <nan_sirirat@mnes-us.com> Tracking Status: None "'Sprengel, Ryan'" <ryan_sprengel@mnes-us.com> Tracking Status: None "Takacs, Michael" <Michael.Takacs@nrc.gov> Tracking Status: None "'Tapia, Joe'" <joseph_tapia@mnes-us.com>

Tracking Status: None "Tindell, Brian" <Brian.Tindell@nrc.gov> Tracking Status: None "Turner, Bruce" <Bruce.Turner@luminant.com> Tracking Status: None "Volkening, David" <David.Volkening@luminant.com> Tracking Status: None "Vrahoretis, Susan" <Susan.Vrahoretis@nrc.gov> Tracking Status: None "Williamson, Alicia" <Alicia.Williamson@nrc.gov> Tracking Status: None "Willingham, Michael" <Michael.Willingham@nrc.gov> Tracking Status: None "Woodlan, Don" <Donald.Woodlan@luminant.com> Tracking Status: None Post Office: MDCEXMB01.tceh.net Files Size Date & Time MESSAGE 1154 4/13/2011 3:53:42 PM TXNB-11020 RAI 135 Supp.pdf 486055 TXNB-11022 RAI 201, 207, 208.pdf 203131 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Page 2 of 2

Electronic distribution w/attachment:

Rafael.Flores@luminant.com shinji_kawanago@mnes-us.com mlucas3@luminant.com masanori_onozuka@mnes-us.com jeff.simmons@energyfutureholdings.com ck_paulson@mnes-us.com Bill.Moore@luminant.com joseph_tapia@mnes-us.com Brock.Degeyter@energyfutureholdings.com russell_bywater@mnes-us.com rbird1@luminant.com william_mcconaghy@mnes-us.com Allan.Koenig@luminant.com mutsumi_ishida@mnes-us.com Timothy.Clouser@luminant.com nan_sirirat@mnes-us.com Ronald.Carver@luminant.com nicholas_kellenberger@mnes-us.com David.Volkening@luminant.com ryan_sprengel@mnes-us.com Bruce.Turner@luminant.com al_freitag@mnes-us.com Eric.Evans@luminant.com masaya_hoshi@mnes-us.com Robert.Reible@luminant.com rjb@nei.org donald.woodlan@luminant.com kak@nei.org John.Conly@luminant.com michael.takacs@nrc.gov JCaldwell@luminant.com cp34update@certrec.com David.Beshear@txu.com michael.johnson@nrc.gov Ashley.Monts@luminant.com David.Matthews@nrc.gov Fred.Madden@luminant.com Balwant.Singal@nrc.gov Dennis.Buschbaum@luminant.com Hossein.Hamzehee@nrc.gov Carolyn.Cosentino@luminant.com Stephen.Monarque@nrc.gov NuBuild Licensing files jeff.ciocco@nrc.gov michael.willingham@nrc.gov john.kramer@nrc.gov Brian.Tindell@nrc.gov Alicia.Williamson@nrc.gov Elmo.Collins@nrc.gov Loren.Plisco@nrc.com Susan.Vrahoretis@nrc.gov ComanchePeakCOL.Resource@nrc.gov sfrantz@morganlewis.com jrund@morganlewis.com tmatthews@morganlewis.com regina.borsh@dom.com Luminant Records Management (.pdf files only) diane.aitken@dom.com

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Attachment Page 1 of 17

SUPPLEMENTAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Comanche Peak, Units 3 and 4

Luminant Generation Company LLC

Docket Nos. 52-034 and 52-035

RAI NO.: 4206 (CP RAI #135) SRP SECTION: 12.03-12.04 - Radiation Protection Design Features QUESTIONS for Health Physics Branch (CHPB) DATE OF RAI ISSUE: 1/29/2010

QUESTION NO.: 12.3-12.4-11 10 CFR 20.1406, NUREG-0800, 'Standard Review Plan,' Section 12.03-12.04, Regulatory Guide (RG) 1.206, RG 4.21, RG 8.8, IEB 80-10 By letter dated September 30, 2009, the NRC staff issued RAI No. 3511 (CP RAI # 99). In Question 12.03-12.04-1 (13765), the NRC staff requested the applicant provide information regarding the design features and program elements needed to meet the requirements of 10 CFR 20.1406 for the systems structures and components for which the COL applicant has responsibility. The applicant’s response, dated November 11, 2009, noted several design features and program elements were provided to minimize contamination of the facility and the environment consistent with the guidance in Regulatory Guide 4.21 “Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning” and Nuclear Energy Institute template NEI 08-08A “Generic FSAR Template Guidance for Life-Cycle Minimization of Contamination”. The NRC staff has reviewed the applicant's response and found the following examples of where question portions were not fully addressed by the applicant’s response. · The applicant was asked to describe the provisions for those portions cooling water systems, down

stream of the Liquid Waste Processing System (LWPS) connection points. While the applicant noted that evaporation pond piping would use leakage detection and inspection ports, neither this response, nor the response to RAI No. 2747 (CP RAI # 29), Question 11.02-2, dated September 24, 2009, noted this provision in the COL FSAR changes. This response also does not address the piping down stream of where the discharge piping from the evaporation pond connects to the cooling water discharge piping. The “Liquid Radioactive Release Lessons Learned Task Force Final Report” describes industry-operating experience involving inadvertent releases from cooling water piping or components located down stream of LWPS connections.

· COL FSAR COL 10.4(2) notes that with abnormal chemistry, the Steam Generator Blowdown

System (SGBDS) directs SGBDS water to Waste Water Management Pond C. However, this response does not describe the leakage prevention and leakage detection provisions for the piping to and from Waste Pond C and for the construction of Waste Pond C.

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Attachment Page 2 of 17

· The applicant was asked to describe leakage prevention and detection provisions for portions of the Steam and Condensate systems. The applicant’s response only discussed the radiation monitoring detector installed on the condenser air ejector, and not prevention or early detection of releases from PWR secondary system piping. This radiation monitor is not capable of detecting tritium contamination. Electric Power Research Institute (EPRI) Technical Report (TR) 1008219 "PWR Primary-to-Secondary Leak Guidelines-Revision 3", notes that even without primary to secondary leakage, radioactive tritium will be present in PWR secondary side systems due to hydrogen diffusion through the Steam Generator u-tubes. Operating Experience regarding PWR secondary system underground piping leakage is discussed in Indian Point Nuclear Generating Unit 2 - NRC Integrated Inspection Report 05000247/2009002, dated May 14, 2009 (ML091340445), and May 24, 2004, Event Number 40771 for Surry Power Station.

· The applicant was asked to describe provisions for leakage prevention and detection from systems

receiving water from the boron recycle system. The applicant’s response addressed leakage prevention provisions for valves, but did not discuss the leakage prevention and detection methods for piping containing recycled fluid, especially those portions of piping that originated in one building, and terminated in a separate building, such as the piping to and from the Primary Makeup Water Storage Tanks.

· The applicant’s response stated that heat exchangers separate radioactive fluid from non-

radioactive fluid by tube walls. As noted in the USAPWR Design Control Document FSAR Tier 2 Section 9.1.3.2.1.3, the CCW/SFP heat exchanger is a plate type heat exchanger. Operating Experience from EPRI TR 1013470 “Plant Support Engineering: Guidance for Replacing Heat Exchangers at Nuclear Power Plants with Plate Heat Exchangers”, notes that Plate Type heat exchanger gaskets are subject to leakage due to fouling of the gasket sealing surfaces during maintenance, and as a result of pressure spikes due to operational transients and events. The applicant did not discuss how the elements of the contamination minimization program will address operating experience showing the increased risk of leakage with Plate Type heat exchangers.

The examples provided are illustrative in nature, and do not portray an exhaustive review of the systems, structures and components, which should be considered during the 10 CFR 20.1406 review process. Please revise and update the COL FSAR to describe in Comanche Peak FSAR Chapter 12, the design features, and related maintenance and inspection requirements, to prevent or mitigate contamination of the environment from COL applicant provided systems, structures and components, which may contain radioactive material. Alternately, describe and justify the specific approaches employed to prevent contamination of the environment and facility from COL Applicant provided Systems, Structures or Components containing radioactive material.

SUPPLEMENTAL INFORMATION: 1. NRC Feedback: Drawing CPNPP 12.3-201 shows a line from the CST to the hotwell, however, there

is no discussion of the CST overflow line depicted on DCD Figure 9.2.6-1 Condensate Storage Facilities System Flow Diagram. Since overflowing of the CST is fairly common, clarification of where this line runs would be useful.

Response: The overflow from the CST is directed to the CST sump inside the dike area. The sump is equipped with an instrument to detect fluid level and initiate alarms in the MCR for operator action to stop condensate transfer and to investigate the extent of condition. After analysis for level of contamination, the contents inside the dike area can be trucked to the wastewater system (at CPNPP

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Attachment Page 3 of 17

Units 3 and 4, this is Waste Management Pond C) for disposal or to the LWMS for treatment and release. FSAR Subsection 9.2.6.2.4 has been revised to include this site-specific information. DCD Subsection 9.2.6.2.4, Figure 9.2.6-1, and Table 12.3-8 Sht 15 have been revised to include the overflow piping to the CST sump.

2. NRC Feedback: CPNPP Figure 12.3-201 shows the Auxiliary Boiler building, however, there is no discussion about the site-specific aspects of this building, or the site-provided piping and loads. Since this system can use the CST as a makeup water source, about the how potential contamination of loads is addressed. Also, since the Aux Boiler acts as a non-volatile contaminant concentrator, some discussion of the Aux Boiler blowdown lines may be warranted.

Response: DCD Subsection 10.4.11.2.1 includes a discussion of the Auxiliary Boiler Building and its piping. All the piping to and from the Auxiliary Boiler Building is above ground. The boiler blowdown connection has been added to DCD Subsection 10.4.11.2.1 and Table 12.3-8 Sht 60. DCD Subsection 10.4.11.2.1 was added as part of the response to DCD RAI 578 - 4483 (ML102240274), which has been included in DCD Revision 3. It is included here for completeness.

The ASSS supplies steam for plant system heating when main steam is not available. The auxiliary boiler takes condensate makeup from the auxiliary steam drain tank inside the A/B, or from the condensate storage tank (CST) in the yard. The auxiliary boiler is located in the yard near the plant area. The condensate piping from the ASSS drain tank is a single-walled carbon steel pipe run above ground in pipe chases from the A/B to the T/B, and is then connected to double-walled welded carbon steel piping through the T/B wall penetration to the auxiliary boiler. Since this is not a high traffic area, this segment of pipe is run above ground and is slightly sloped so that any leakage is collected in the outer pipe and drained to the auxiliary boiler building. At the auxiliary boiler building end, a leak detection instrument is provided to monitor leak. A drain pipe is provided to direct any drains to the building sump. The steam piping is jacketed with insulation and heat protection. The Auxiliary Boiler is designed with a blowdown connection from the boiler drum to the building sump. The boiler blowdown is drained directly into the sump for transfer into the Turbine Building sump. The T/B sump contents are then pumped to the Waste Holdup Tanks in the LWMS for processing. This design is supplemented by operational programs which includes periodic hydrostatic or pressure testing of pipe segments, instrument calibration, and when required, visual inspection and maintenance of piping, trench and instrument integrity. A discussion of the radiological aspects of the system leakage is contained in DCD Section 11.1. Design and system features addressing RG 4.21 are captured in Section 12.3.1.3 of the DCD.

The Auxiliary Boiler provides steam to the boric acid batching tank, boric acid evaporator, pre-heater, and non-safety related HVAC equipment. It also supplies steam to the turbine gland seal, deaerator seal, and deaerator heating when main steam is not available. The boric acid batching tank, the boric acid evaporator pre-heater and reboiler, and the air preheater for the HVAC equipment are located inside the Auxiliary Building. Floor drains are provided in the corresponding equipment areas. Any condensate leakage and/or contents is collected in the floor drain sump and is pumped to the waste holdup tank for processing. Turbine gland seal, deaerator seal, and deaerator heater are located in the Turbine Building. Any leakage is collected in the turbine

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Attachment Page 4 of 17

building drain sump. If contamination in the sump content is detected to be above a pre-determined setpoint, the sump contents are pumped to the waste holdup tank in the LWMS for processing.

3. NRC Feedback: While the response discussed testing of buried piping in several locations, it is not clear from the response that the systems will contain the necessary isolation mechanism (valves, blank flanges, pipe access ports etc.) to allow hydrostatic or other non-destructive testing.

Response: The effluent piping is divided into five segments as follows (refer to FSAR Figure 12.3-201):

• The first segment starts from the waste monitoring tank pumps located inside the Auxiliary Building (A/B) and extends through wall of the A/B into a pipe chase through the Power Supply Building (PS/B) and the Turbine Building (T/B) to the outside wall of the T/B. This segment of pipe is made of carbon steel with isolation valves provided for testing. The waste monitoring tank pumps are part of the Liquid Waste Management System discussed in DCD Subsection 11.2.2.

• The second segment extends from the outside wall of the T/B and runs through a concrete trench to the last manhole provided at the edge of the plant pavement (transition manhole). This segment of the pipe is either single-wall carbon steel or double-wall HDPE in a concrete trench. Isolation mechanisms (valves, blank flanges, pipe access ports etc.) are provided in the transition manhole to facilitate testing of this pipe segment.

• The third segment extends from the transition manhole to the radwaste evaporation pond. This segment is double-wall HDPE pipe buried underground. Two intermediate manholes are provided because of the distance to the pond. Isolation mechanisms (valves, blank flanges, pipe access ports etc.) are provided in the manholes for the underground piping segments to facilitate testing of buried piping.

• The fourth segment extends from the evaporation pond to the Unit 1 Flow Receiver and Head Box. This segment is also double-wall HDPE pipe buried underground. Two manholes are provided for this segment. Isolation mechanisms (valves, blank flanges, pipe access ports etc.) are provided in the manholes for the underground piping segments to facilitate testing of buried piping.

• The fifth segment extends from the transition manhole to the Unit 1 Flow Receiver and Head Box, which is a relatively short distance. This segment is also double-wall HDPE pipe buried underground. Since isolation mechanisms are provided in the transition manhole, no additional manhole is required. A flange connection is provided at the piping exit at the Unit 1 Flow Receiver and Head Box for isolation to facilitate testing.

The effluent piping from the startup SGBDS heat exchanger to waste management pond C is divided into four segments as follows:

• The first segment starts from the SGBDS heat exchanger outlet and extends to the outside wall of the Turbine Building (T/B). This segment of pipe is made of double-wall carbon steel and runs above ground.

• The second segment is single-wall carbon steel pipe extending through the wall of the T/B into pipe chases running through the T/B.

• The third segment runs through the T/B wall via a penetration into the concrete trench to the transition manhole provided at the edge of the plant pavement. This segment is single-wall carbon steel with isolation mechanisms (valves, blank flanges, pipe access ports etc.) provided in the transition manhole to facilitate testing of this pipe segment.

U. S. Nuclear Regulatory Commission CP-201100491 TXNB-11020 4/13/2011 Attachment Page 5 of 17

• The fourth segment extends from the transition manhole to waste management pond C. This segment is double walled HDPE pipe buried underground. Because of the short distance, no additional manhole is needed. A flange connection and a test connection are added at the end of the HDPE pipe for testing purpose.

The single-wall stainless steel piping from the condenser hotwell to the condensate storage tank (CST) has isolation mechanisms (valves, blank flanges, pipe access ports etc.) at the CST and at the hotwell to facilitate testing.

4. NRC Feedback: The Startup SGBD system appears to be located outside of a building; however,

there is no discussion of any provisions for containment of leakage from those components.

Response: FSAR Subsection 10.4.8.2.1 and Table 12.3-201 have been updated to include the requested information.

5. NRC Feedback: Section 2 of the RAI response indicates that there is no buried piping, and refers to

above ground piping. Section 4 also refers to above ground piping. These points do not appear to be clearly indicated in either the DCD markup or Figure 12.3-201.

Response: The piping inside the Turbine Building, Power Source Building, Reactor Building, and Auxiliary Building, and transiting between these buildings, is routed in aboveground pipe chases because these buildings are close to each other. This information has been added to DCD Subsection 10.4.8.2.1 and to FSAR Figure 12.3-201. The piping to and from the Primary Makeup Water Tanks is single-wall stainless steel that runs aboveground and penetrates the building wall directly next to the tank. DCD Subsection 9.2.6.2.6 was revised as part of the response to DCD RAI 578 - 4483 (ML102240274) to add this information, which was included in DCD Revision 3.

Impact on R-COLA

See marked-up FSAR Revision 1 pages 9.2-17, 9.2-18, 10.4-8, 10.4-9, and 12.3-6 and revised Figure 12.3-201.

Impact on DCD

See attached marked-up DCD Revision 3 pages 9.2-40, 9.2-109, 10.4-66, 10.4-124, 12.3-66, and 12.3-111 taken from MHI Letter UAP-HF-11091 dated April 6, 2011. The right margin notation on pages 12.3-66 and 12.3-111 is incorrect and will be corrected to read “RCOL2_12.03-12.04-11 S02” in a future DCD tracking report.

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 19.2-17

The inspection and testing provisions described above are subject to programmatic requirements and procedural controls as described in FSAR Section 13.5.

Manholes, handholes, inspection ports, ladder, and platforms are provided, as required, for periodic inspection of system components.

9.2.5.5 Instrumentation Requirements

Replace the sentence in DCD Subsection 9.2.5.5 with the following.

Water level in each of the basins is controlled by level instrumentation that opens or closes the automatic valves in the makeup lines.

Two level transmitters and associated signal processors are provided for each basin to indicate water level in the basin and annunciate in the MCR for both the high and low water levels in the basin.

A water level signal at six inches below the normal water level causes the makeup water control valve to open. A signal at normal water level then causes the makeup control valve to close. A low level alarm annunciates in the MCR whenever the water level falls one foot below the normal water level.

During accident condition, level indications from the operating basins are used to alert the MCR operator to start the UHS transfer pump to transfer water from the idle basin to the operating basins.

Blowdown rate is controlled manually. The blowdown control valves close automatically upon receipt of a low water level signal or emergency core cooling system actuation signal. The valve is designed to fail in the close position. Failure of the valve to close is indicated in the MCR.

The conductivity cells are provided at the ESW pump discharge line and conductivity are indicated in the MCR.

Temperature elements are provided in each basin and temperatures are indicated in the MCR.

Local flow rate and pressure indicators located in each UHS transfer pump discharge header are used for pump performance testing.

The cooling tower fan is equipped with vibration sensors that alarm in the control room in the event of high vibration.

9.2.6.2.4 Condensate Storage Tank

Replace the last sentence of the first paragraph in DCD Subsection 9.2.6.2.4 with the following.

RCOL2_09.02.05-12RCOL2_09.02.05-13

CP COL 9.2(24)

RCOL2_12.03-12.04-11 S02

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 19.2-18

After analysis for level of contamination, the content inside the dike area can be trucked to Waste Management Pond C for disposal; or to the LWMS for treatment and release.

9.2.7.2.1 Essential Chilled Water System

Replace the last paragraph in DCD Subsection 9.2.7.2.1 with the following.

The operating and maintenance procedures regarding water hammer are included in system operating procedures in Subsection 13.5.2.1. A milestone schedule for implementation of the procedures is also included in Subsection 13.5.2.1.

9.2.10 Combined License Information

Replace the content of DCD Subsection 9.2.10 with the following.

9.2(1) The evaluation of ESWP at the lowest probable water level of the UHS and the recovery procedures when UHS approaches low water level

This COL item is addressed in Subsection 9.2.1.3.

9.2(2) The protection against adverse environmental, operating and accident condition that can occur such as freezing, thermal over pressurization

This COL item is addressed in Subsection 9.2.1.3.

9.2(3) Source and location of the UHS

This COL item is addressed in Subsection 9.2.5.2.

9.2(4) The location and design of the ESW intake structure

This COL item is addressed in Subsection 9.2.5.2.

9.2(5) The location and the design of the discharge structure

This COL item is addressed in Subsection 9.2.5.2.

9.2(6) The ESWP design details – required total dynamic head, NPSH available, and the mode of cooling the pump motor.

This COL item is addressed in Subsection 9.2.1.2.2, 9.2.1.2.2.1, and Table 9.2.1-1R, and 9.4.5.1.1.6.

9.2(7) The design of ESWS related with the site specific UHS

This COL item is addressed in Subsections 9.2.1.2.1, 9.2.1.3, 9.2.1.5.4 and Figure 9.2.1-1R.

RCOL2_12.03-12.04-11 S02

STD COL 9.2(27)

CP COL9.2(1)

CP COL 9.2(2)

CP COL 9.2(3)

CP COL 9.2(4)

CP COL 9.2(5)

CP COL 9.2(6)STD COL 9.2(6)

RCOL2_09.02.01-4CTS-01140

CP COL 9.2(7)STD COL 9.2(7)

CTS-01140

RCOL2_09.02.01-4

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 110.4-8

Tanks (CST). This portion of the piping is in the same concrete trench as the condensate transfer piping to the CST. The concrete trench is sloped and has an epoxy coating to facilitate drainage. This design eliminates liquid accumulation in the trench and thus minimizes unintended release. Using single-wall carbon steel pipe in the trench facilitates additional radial cooling of the fluid and enables the use of High Density Polyethylene (HDPE) piping for underground burial;

5. From the transition manhole, the discharge piping is connected to a buried double-walled HDPE piping to an existing waste water management Pond C for discharge. A transition manhole is constructed near the plant pavement boundary. HDPE pipe has the property of good corrosion resistance in the soil environment;

6. The trench and the double-walled HDPE piping are both sloped towards the nearby manhole so that leakage can be collected at the manholes. This approach also facilitates the determination of the segment of pipe that is leaking. Analysis of samples of the liquid collected in the manholes can also differentiate whether the leakage is rain water, groundwater or condensate.

Additional manholes are provided for testing and inspection for the buried piping. Each manhole is equipped with drain collection basins and leak detection instruments. This design approach minimizes unintended releases and provides accessibility to facilitate periodic hydrostatic or pressure testing and visual inspection to maintain pipe integrity. This design feature is in compliance with the guidance of RG 4.21, provided in Subsection 12.3.1.3.1. A radiation monitor located downstream of the startup SG blowdown heat exchanger measures radioactive level in the blowdown water. When an abnormally high radiation level is detected, the blowdown lines are isolated and the blowdown water included in the SGBDS is transferred to waste holdup tank in the LWMS. The location and other technical details of the monitor (RMS-RE-110) is described in Subsection 11.5.2.5.3 and Table 11.5-201will be developed during the detail design phase.

With abnormal water chemistry, the flow of blowdown rate up to approximately 3 % of MSR at rated power is directed to the existing waste water management pond C via the startup SG blowdown flash tank for processing. In this mode, flashed vapor from the startup SG blowdown flash tank flows to the deaerator.

During normal operation, blowdown rate is approximately 0.5 to 1 % of MSR at rated power. At the 1% of MSR at rated power blowdown rate, both cooling trains are used.

The startup SGBDS is housed in a separate structure located outside the T/B consisting of a concrete foundation and pre-fabricated walls around the startup SGBD equipment. The surface of the startup SGBD housing foundation is slightly sloped to facilitate drainage to a pit with leak detection capabilities and to avoid unintended release to the environment. The concrete foundation, the walls, and the pit are coated with epoxy to facilitate decontamination. Leakage collected in

RCOL2_12.03-12.04-11

RCOL2_11.05-2

RCOL2_12.03-12.04-11 S02

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 110.4-9

the drainage pit is pumped back to the T/B sumps for collection and analysis. The T/B sump contents are pumped to the LWMS if a significant level of radioactive contamination is present.

Add the following text after last bullet of the seventeenth paragraph in DCD Subsection 10.4.8.2.1.

• High radiation signal from startup SG blowdown water radiation monitor

• High water level in the startup SG blowdown flash tank

• High pressure in the startup SG blowdown flash tank

10.4.8.2.2.4 Steam Generator Drain

Replace the first paragraph in DCD Subsections 10.4.8.2.2.4 with the following.

Pressurized nitrogen is used to send secondary side water in the steam generators under pressure to the existing waste water management Pond C or the condenser. An approximate 20 psig pressure is maintained. This pressure facilitates draining steam generators without using a pump. If the SG drain temperature exceeds the operating temperature limit of the existing waste water management Pond C prior to discharging to this Pond C, the SG drain is cooled in the Startup SG blowdown Heat Exchanger.

10.4.8.2.3 Component Description

Replace the first sentence of first paragraph in DCD Subsections 10.4.8.2.3 with the following.

Component design parameters are provided in Table 10.4.8-1R.

Add the following text after the last paragraph in DCD Subsection 10.4.8.2.3.

(9)Startup SG blowdown flash tank

The startup SG blowdown flash tank is located outdoors. During plant startup operation and abnormal secondary water chemistry conditions, up

RCOL2_12.03-12.04-11 S02

CPSTD COL 10.4(2)

CTS-01140

CP COL 10.4(5)

CPSTD COL 10.4(2)

CTS-01140

CP COL 10.4(2)

Rev

isio

n 1

12.3

-6

Com

anch

e Pe

ak N

ucle

ar P

ower

Pla

nt, U

nits

3 &

4C

OL

App

licat

ion

Part

2, F

SAR

Tabl

e12

.3-2

01R

egul

ator

y G

uide

4.2

1 D

esig

n O

bjec

tives

and

App

licab

le F

SAR

Sub

sect

ion

Info

rmat

ion

for

Min

imiz

ing

Con

tam

inat

ion

and

Gen

erat

ion

of R

adio

activ

e W

aste

(She

et 2

of 5

)

Stea

m G

ener

ator

Blo

wdo

wn

Syst

em(N

ote:

Thi

s ta

ble

addr

esse

s th

e si

te-s

peci

fic c

ompo

nent

s an

d m

ust b

e re

view

ed in

pa

ralle

l with

the

DC

D T

able

12.

3-8

for s

tand

ard

com

pone

nts.

The

“Sys

tem

Fea

ture

s” c

olum

n co

nsis

ts o

f exc

erpt

s fr

om th

e FS

AR

)

Obj

ectiv

eSy

stem

Fea

ture

sFS

AR

Ref

eren

ce2

5.Fr

om th

e tra

nsiti

on m

anho

le, t

he d

isch

arge

pip

ing

is c

onne

cted

to a

bu

ried

doub

le-w

alle

d H

DP

E p

ipin

g to

an

exis

ting

was

te w

ater

m

anag

emen

t Pon

d C

for d

isch

arge

. A tr

ansi

tion

man

hole

is c

onst

ruct

ed

near

the

plan

t pav

emen

t bou

ndar

y. H

DP

E p

ipe

has

the

prop

erty

of g

ood

corr

osio

n re

sist

ance

in th

e so

il en

viro

nmen

t;6.

The

trenc

h an

d th

e do

uble

-wal

led

HD

PE

pip

ing

are

both

slo

ped

tow

ards

the

near

by m

anho

le s

o th

at le

akag

e ca

n be

col

lect

ed a

t the

m

anho

les.

Thi

s ap

proa

ch a

lso

faci

litat

es th

e de

term

inat

ion

of th

e se

gmen

t of p

ipe

that

is le

akin

g. A

naly

sis

of s

ampl

es o

f the

liqu

id

colle

cted

in th

e m

anho

les

can

also

diff

eren

tiate

whe

ther

the

leak

age

is

rain

wat

er, g

roun

dwat

er o

r con

dens

ate.

Add

ition

al m

anho

les

are

prov

ided

for t

estin

g an

d in

spec

tion

for t

he b

urie

d pi

ping

. Eac

h m

anho

le is

equ

ippe

d w

ith d

rain

col

lect

ion

basi

ns a

nd le

ak

dete

ctio

n in

stru

men

ts. T

his

desi

gn a

ppro

ach

min

imiz

es u

nint

ende

d re

leas

es a

nd p

rovi

des

acce

ssib

ility

to fa

cilit

ate

perio

dic

hydr

osta

tic o

r pr

essu

re te

stin

g an

d vi

sual

insp

ectio

n to

mai

ntai

n pi

pe in

tegr

ity. T

his

desi

gn

feat

ure

is in

com

plia

nce

with

the

guid

ance

of R

G 4

.21.

The

star

tup

SG

BD

S is

hou

sed

in a

sep

arat

e st

ruct

ure

loca

ted

outs

ide

the

T/B

con

sist

ing

of a

con

cret

e fo

unda

tion

and

pre-

fabr

icat

ed w

alls

aro

und

the

star

tup

SG

BD

equ

ipm

ent.

The

surfa

ce o

f the

sta

rtup

SG

BD

hou

sing

fo

unda

tion

is s

light

ly s

lope

d to

faci

litat

e dr

aina

ge to

a p

it w

ith le

ak d

etec

tion

capa

bilit

ies

and

to a

void

uni

nten

ded

rele

ase

to th

e en

viro

nmen

t. Th

e co

ncre

te fo

unda

tion,

the

wal

ls, a

nd th

e pi

t are

coa

ted

with

epo

xy to

faci

litat

e de

cont

amin

atio

n. L

eaka

ge c

olle

cted

in th

e dr

aina

ge p

it is

pum

ped

back

to

the

T/B

sum

ps fo

r col

lect

ion

and

anal

ysis

. The

T/B

sum

p co

nten

ts a

re

pum

ped

to th

e LW

MS

if a

sig

nific

ant l

evel

of r

adio

activ

e co

ntam

inat

ion

is

pres

ent.

CP

CO

L 12

.3(1

0)R

CO

L2_1

2.0

3-12

.04-

11

RC

OL2

_12.

03-

12.0

4-11

S0

2

Revision 112.3-10

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Figure 12.3-201 Yard Piping Routing and Building Penetration Schematic(Not to scale)

RCOL2_12.03-12.04-11

RCOL2_12.03-12.04-11 S02

CP COL 12.3(10)RCOL2_12.03-12.04-11

Note: Piping to and from the PMWTs and is single-walledSS and runs above ground.Note: Isolation mechanisms (valves, blank flanges, pipe access ports etc.) are provided in the manholes to facilitate testing of buried piping.Note: All the pipings inside the containment, R/B, A/B and T/B and transiting between the buildings is routed above ground.

Revision 39.2-40

9. AUXILIARY SYSTEMS US-APWR Design Control Document

Tier 2

The primary makeup water system consists of two PMWTs, each of 140,000 gallon capacity, two 100% capacity primary makeup water pumps, and associated valves, piping, and instrumentation.

All system components meet design code requirements consistent with the component quality group and seismic design classification in provided in Section 3.2.

The DWST, CST, and the PMWTs are non-safety related and non-seismic (Section 3.2.). These tanks have no safety-related function and failure of their structural integrity would not impact the seismic category I SSCs or cause adverse system interaction. A dike is provided for the PMWTs and CST for mitigating the environmental effects of system leakage or storage tank failure.

The CSF system is shown schematically in Figures 9.2.6-1, 9.2.6-2 and 9.2.6-3.

9.2.6.2.1 Demineralized Water Storage Tank

The DWST is the normal source of demineralized water for supplying water CST, the secondary side chemical injection system, condensate polishing system and the emergency feedwater pits. It is also the normal source for supplying deaerated water to primary makeup water tanks and various primary system users, as shown in Figure 9.2.6-1. The DWST also supplies demineralized water to other users, as shown in Figure 9.2.6-2. Makeup to the CST is provided from the DWST.

Design parameters of the DWST are shown in Table 9.2.6-1.

9.2.6.2.2 Demineralized Water Transfer Pumps

Two 100% capacity demineralized water transfer pumps are provided. The demineralized water transfer pumps take suction from the DWST and discharge into a header that supplies demineralized water to various plant users, as shown in Figure 9.2.6-1. Design parameters of the demineralized water transfer pumps are shown in Table 9.2.6-1

9.2.6.2.3 Deaeration Package

The deaeration package reduces the oxygen concentration of the demineralized water.

9.2.6.2.4 Condensate Storage Tank

The CST is the normal source of water for make up to certain plant systems including the main condenser. The CST is a source of water for supply to various locations such as areas near equipment that need water for maintenance and drain tanks. Makeup to the CST is provided from the DWST. The CST overflow goes to a dike which is provided to control the release of chemicals and radioactive materials. This CST overflow is directed to the Condensate Storage Tank sump inside the dike area. The sump is equipped with a level instrument to detect fluid level and initiates alarms via representative alarm in the MCR for operator actions to stop condensate transfer and to investigate the extent of condition. After analysis for level of contamination, the content inside the dike area can be trucked to WWS for disposal; or to the LWMS for treatment and release.

RCOL2_12.03-12.04-11 S02

9.A

UXI

LIA

RY

SYST

EMS

Rev

isio

n 3

Tier

29.

2-10

9

US-

APW

R D

esig

n C

ontr

ol D

ocum

ent

Figu

re 9

.2.6

-1

Con

dens

ate

Stor

age

Faci

litie

s Sy

stem

Flo

w D

iagr

am

CST

MAK

EUP

REC

IRC

ULA

TIO

N

DEA

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ED W

ATER

DEM

INER

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LSL

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ND

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ATE

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DW

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EN

CY

TO C

DS

MAK

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M C

DS

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TCS

STAN

D P

IPE

FIG

UR

E 9

.2.6

-2

FIG

UR

E 9.

2.6-

3

SYS

TEM

CH

EM

ICA

L IN

JEC

TIO

NS

EC

ON

DAR

Y S

IDE

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ED

WA

TER

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NC

Y

AND

MIS

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R M

AIN

TEN

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E

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TEM

POLI

SH

ING

CO

ND

ENSA

TE

V

V

PI

PI

DEA

ER

ATT

ION

PAC

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EN

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AG

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NK

AUXI

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BOIL

ER

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ANK

VAR

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S D

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ER

ALIZ

ED

WA

TER

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MPSD

EM

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RA

LIZE

DW

ATE

R S

TOR

AG

ETA

NK

DE

MIN

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ALIZ

ED

WA

TER

TR

EA

TMEN

TP

LAN

T

RAW

WA

TER

SUP

PLY

THE

ARE

AS N

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RTH

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QU

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ENT

THA

TN

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ER

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RM

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TEN

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EC

9

EC

8

EC8

EC

8

PI

FT

FT

To C

ST s

ump

RC

OL2

_12.

03-

12.0

4-11

S

02

Revision 310.4-66

10. STEAM ANDPOWER CONVERSION SYSTEM

US-APWR Design Control Document

Tier 2

• Divert from the blowdown demineralizers to [[WWS]] or the condenser if the blowdown water temperature exceeds the predetermined temperature to protect demineralizers resin.

10.4.8.2 System Description

10.4.8.2.1 General Description

The SGBDS flow diagrams are shown in Figures 10.4.8-1 and 10.4.8-2. Classification of equipment and components in the SGBDS is provided in Section 3.2.

The SGBDS equipment and piping are located in the containment, the reactor building, the auxiliary building and the turbine building (T/B). The piping inside these buildings and transiting between buildings is all routed above ground.

The SGBDS consists of a flash tank, regenerative heat exchangers, non-regenerative coolers, filters, demineralizers, piping, valves and instrumentation. The flash tank, regenerative heat exchangers and non-regenerative coolers are provided to cool the blowdown water with heat recovery, while the filters and demineralizers are provided to purify the blowdown water.

One blowdown line per steam generator is provided. The blowdown from each steam generator flows independently to the flash tank. The blowdown water from the flash tank flows via one common line to regenerative heat exchangers and non regenerative coolers. Blowdown is split into two trains ahead of the heat exchangers. Common discharge from the coolers flows to the filters and demineralizers, where the flow is split into two trains. The purified water from the demineralizers flows to the condenser via a common discharge line.

The blowdown line from each steam generator is provided with two flow paths, a line for purifying blowdown water used during normal plant operation and a line for discharging the blowdown water to the [[WWS]] or the condenser used during startup and abnormal water chemistry conditions.

The US-APWR SG’s utilize a “peripheral” blowdown system arrangement. In this arrangement, blowdown holes are drilled from approximately 7 inches below the secondary surface of the tubesheet and intersect with the peripheral groove on the secondary face of the tubesheet. This arrangement is shown as Figure 10.4.8-3 and facilitates effective sludge removal from the tubesheet. The blowdown from each steam generator is depressurized by a throttle valve located downstream of the isolation valves. The throttle valves can be manually adjusted to control the blowdown rate.

The depressurized blowdown water flows to the flash tank, where water and flashing vapor are separated. The vapor is diverted to deaerator and the water is transferred to regenerative and non-regenerative heat exchangers for further cooling. When the pressure in the flash tank is low, the vapor is diverted to condenser. The condensate and feedwater system (CFS) provides the condensate in regenerative heat exchanger(s) to recover thermal energy.

RCOL2_12.03-12.04-11 S02

Revision 310.4-124

10. STEAM ANDPOWER CONVERSION SYSTEM

US-APWR Design Control Document

Tier 2

Condensed water from these components is collected in the auxiliary steam drain tank and then, by using the auxiliary steam drain pump, is transferred to the condenser during plant normal operation, or to the auxiliary boiler during the period in which the main steam is not available.

• Boric acid (B/A) evaporator

• B/A batching tank

• Non safety-related HVAC equipment

The ASSS supplies steam for plant system heating when main steam is not available. The auxiliary boiler takes condensate makeup from the auxiliary steam drain tank inside the A/B, or from the condensate storage tank (CST) in the yard. The auxiliary boiler is located in the yard near the plant area. The condensate piping from the ASSS drain tank is a single-walled carbon steel pipe run above ground in pipe chases from A/B to the T/B, and is then connected to double-walled welded carbon steel piping through the T/B wall penetration to the auxiliary boiler. Since this is not a high traffic area, this segment of pipe is run above ground and is slightly sloped so that any leakage is collected in the outer pipe and drained to the auxiliary boiler building. At the auxiliary boiler building end, a leak detection instrument is provided to monitor leak. A drain pipe is provided to direct any drains to the building sump. The steam piping is jacketed with insulation and heat protection. The Auxiliary Boiler is designed with a blowdown connection from the boiler drum to the building sump. The boiler blowdown is drained directly into the sump for transfer into the Turbine Building sump. The T/B sump contents are then pumped to the Waste Holdup Tanks in the LWMS for processing. This design is supplemented by operational programs which includes periodic hydrostatic or pressure testing of pipe segments, instrument calibration, and when required, visual inspection and maintenance of piping, trench and instrument integrity.

A discussion of the radiological aspects of the system leakage is contained in DCD Section 11.1. Design and system features addressing RG 4.21 are captured in Section 12.3.1.3 of the DCD.

Monitoring the leakage from the primary side of the evaporator, the radiation monitor is attached to the downstream of the auxiliary steam drain pump. The high alarm of the monitor isolates the pump discharge line and steam supply line from main steam and trips the pump.

Group II components served by the system are shown below. These components are supplied auxiliary steam from the auxiliary boiler during plant startup, shutdown or regular inspections due to unavailable of the main steam.

• Turbine gland seal

• Deaerator seal

• Deaerator heating

RCOL2_12.03-12.04-11 S02

Rev

isio

n 3

Tier

212

.3-6

6

12.R

AD

IATI

ON

PR

OTE

CTI

ON

US-

APW

R D

esig

n C

ontr

ol D

ocum

ent

Tabl

e 12

.3-8

R

egul

ator

y G

uide

4.2

1 D

esig

n O

bjec

tives

and

App

licab

le D

CD

Sub

sect

ion

Info

rmat

ion

for M

inim

izin

g C

onta

min

atio

n an

d G

ener

atio

n of

Rad

ioac

tive

Was

te (S

heet

15

of 6

1)

Wat

er S

yste

ms

Con

dens

ate

Stor

age

Faci

lity

(Not

e: T

he “

Syst

em F

eatu

res”

col

umn

cons

ists

of e

xcer

pts/

sum

mar

y fr

om th

e D

CD

)

Obj

ectiv

eSy

stem

Fea

ture

sD

CD

Ref

eren

ce

1M

inim

ize

leak

s an

d sp

ills

and

prov

ide

cont

ainm

ent i

n ar

eas

whe

re s

uch

even

ts m

ay o

ccur

.

The

CS

T ov

erflo

w is

dire

cted

to th

e C

onde

nsat

e St

orag

e Ta

nk s

ump

insi

de

the

dike

are

a. T

he s

ump

is e

quip

ped

with

a le

vel i

nstru

men

t to

dete

ct fl

uid

leve

l and

initi

ates

ala

rms

via

repr

esen

tativ

e al

arm

in th

e M

CR

for o

pera

tor

actio

ns to

sto

p co

nden

sate

tran

sfer

and

to in

vest

igat

e th

e ex

tent

of

cond

ition

. Afte

r ana

lysi

s fo

r lev

el c

onta

min

atio

n, th

e co

nten

t ins

ide

the

dike

ar

ea c

an b

e tru

cked

to W

WS

for d

ispo

sal;

or tw

o th

e LW

MS

for t

reat

men

t an

d re

leas

e.

9.2.

6.2.

4

The

trans

fer p

ipin

g ru

nnin

g be

twee

n th

e C

ST

and

the

hotw

ell i

s si

ngle

-wal

led

wel

ded

stai

nles

s st

eel p

ipin

g in

a c

oate

d tre

nch

with

re

mov

able

but

sea

led

cove

rs. T

his

desi

gn is

sup

plem

ente

d by

per

iodi

c hy

dros

tatic

or p

ress

ure

test

ing

of p

ipe

segm

ents

, ins

trum

ent c

alib

ratio

n, a

nd

whe

n re

quire

d, v

isua

l ins

pect

ion

and

mai

nten

ance

of p

ipin

g, tr

ench

and

in

stru

men

t int

egrit

y, in

com

plia

nce

with

the

guid

ance

of R

G 4

.21

and

indu

stry

ope

ratin

g ex

perie

nce.

9.2.

6.2.

4

2P

rovi

de fo

r ade

quat

e le

ak d

etec

tion

capa

bilit

y to

pro

vide

pro

mpt

de

tect

ion

of le

akag

e fo

r any

st

ruct

ure,

sys

tem

, or c

ompo

nent

w

hich

has

the

pote

ntia

l for

leak

age.

Pip

ing

in a

coa

ted

trenc

h w

ith re

mov

able

but

sea

led

cove

rs, t

his

desi

gn is

su

pple

men

ted

by p

erio

dic

hydr

osta

tic o

r pre

ssur

e te

stin

g of

pip

e se

gmen

ts,

inst

rum

ent c

alib

ratio

n, a

nd w

hen

requ

ired,

vis

ual i

nspe

ctio

n an

d m

aint

enan

ce o

f pip

ing,

tren

ch a

nd in

stru

men

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atio

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ched

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Leak

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10.4

.11.

2.3

RC

OL2

_12.

03-

12.0

4-72

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Page 2 of 2

Electronic distribution w/attachments:

Rafael.Flores@luminant.com shinji_kawanago@mnes-us.com mlucas3@luminant.com masanori_onozuka@mnes-us.com jeff.simmons@energyfutureholdings.com ck_paulson@mnes-us.com Bill.Moore@luminant.com joseph_tapia@mnes-us.com Brock.Degeyter@energyfutureholdings.com russell_bywater@mnes-us.com rbird1@luminant.com william_mcconaghy@mnes-us.com Allan.Koenig@luminant.com mutsumi_ishida@mnes-us.com Timothy.Clouser@luminant.com nan_sirirat@mnes-us.com Ronald.Carver@luminant.com nicholas_kellenberger@mnes-us.com David.Volkening@luminant.com ryan_sprengel@mnes-us.com Bruce.Turner@luminant.com al_freitag@mnes-us.com Eric.Evans@luminant.com masaya_hoshi@mnes-us.com Robert.Reible@luminant.com rjb@nei.org donald.woodlan@luminant.com kak@nei.org John.Conly@luminant.com michael.takacs@nrc.gov JCaldwell@luminant.com cp34update@certrec.com David.Beshear@txu.com michael.johnson@nrc.gov Ashley.Monts@luminant.com David.Matthews@nrc.gov Fred.Madden@luminant.com Balwant.Singal@nrc.gov Dennis.Buschbaum@luminant.com Hossein.Hamzehee@nrc.gov Carolyn.Cosentino@luminant.com Stephen.Monarque@nrc.gov NuBuild Licensing files jeff.ciocco@nrc.gov michael.willingham@nrc.gov john.kramer@nrc.gov Brian.Tindell@nrc.gov Alicia.Williamson@nrc.gov Elmo.Collins@nrc.gov Loren.Plisco@nrc.com Susan.Vrahoretis@nrc.gov ComanchePeakCOL.Resource@nrc.gov sfrantz@morganlewis.com jrund@morganlewis.com tmatthews@morganlewis.com regina.borsh@dom.com Luminant Records Management (.pdf files only) diane.aitken@dom.com

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 1 Page 1 of 5

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Comanche Peak, Units 3 and 4

Luminant Generation Company LLC

Docket Nos. 52-034 and 52-035

RAI NO.: 5377 (CP RAI #201) SRP SECTION: 11.05 - Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems QUESTIONS for Health Physics Branch (CHPB) DATE OF RAI ISSUE: 1/26/2011

QUESTION NO.: 11.05-4 The NRC Staff's review of COLA FSAR (Rev. 1), Updated Tracking Report (Rev. 4), and response to RAI 2747, Question 11.02-4 (RAI Letter Number 29) found the applicant did not fully describe information on process and effluent radiation monitor sensitivity for compliance with 10 CFR Part 50, Appendix A, GDC 60 and 64, and SRP Sections 11.2 and 11.5. In the response to RAI 2747, Question 11.02-4 (RAI Letter No. 29), item (3), it states a portion of the [liquid] flow will go through the radiation monitor in the unlikely event that the bypass valve (VLV-531) which is normally locked-closed and tagged is left open or partially open. The in-line process effluent radiation monitor (RE-035) is to initiate pump shutdown, valve closure, and operator actions when the monitor reaches the high setpoint, but can be bypassed along with discharge control valves (RCV-035A/B) to ensure the discharge operation is not interrupted by either failure of control valves and/or radiation monitor. Section 5.5 of ANSI/ANS-55.6-1993 (R2007), referenced in SRP Section 11.2, states that process and effluent radiation monitors shall have sensitivity sufficient to establish that discharges are within established limits and allow determination of the integrated quantity of radioactivity. Please provide a detailed analysis with the methodology, basis, and assumptions which demonstrates that the RE-035 radiation monitor has adequate sensitivity to meet its design objectives under this operation condition with reduced liquid discharge flow rates. Provide a mark-up of the proposed FSAR changes.

ANSWER: As discussed in the response to Question 11.02-4, bypass valve VLV-531 is administratively controlled and normally maintained in the locked-closed position. This valve can only be opened with a key controlled by CPNPP Operations and its position status is verified by two technically-qualified members of CPNPP Operations. Bypass valve VLV-531 is opened only during an outage of radiation monitor RE-035 and/or control valves RCV-035A/B. After maintenance is complete, the radiation monitor and/or control valves are reinstalled and tested as required. Following maintenance, the bypass valve VLV-531 is administratively controlled

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 1 Page 2 of 5 and maintained in the locked-closed position. The valve position is verified by at least two technically qualified members of the CPNPP Operations staff before discharge can start. With this verification, there is no anticipated flow path through bypass valve VLV-531. However, the overall radiation monitor sensitivity and the impact on monitoring performance for the conservative assumption that the valve is inadvertently left fully-open are discussed below. Flow from a waste monitor tank is monitored by radiation monitor RE-035. The continuous flow is stored in the sample chamber of the monitoring skid. There is no impact on monitoring sensitivity from a reduced flow rate because the sample chamber is always filled with liquid. However, there is an impact on monitor responsiveness from a reduced flow rate. When the bypass valve is closed, the monitor takes several seconds to respond. However, the monitor will take a few minutes to respond when the bypass valve is fully-opened. The design objective of RE-035 is to prevent a significant release of radionuclides from the liquid effluent. There is no significant difference between the two cases at normal operation, including anticipated operational occurrences, with respect to the design objective of RE-035. The average liquid effluent activity from a waste monitor tank is shown below. These average liquid effluent activities can be detected by RE-035 (lower range = 1E-07 �Ci/cm3); therefore, RE-035 has sufficient sensitivity to establish that discharges are within established limits and allow determination of the integrated quantity of radioactivity. There is no impact on the annual liquid release and the annual dose to the members of the public if the bypass valve is inadvertently left fully-open because RE-035 has sufficient sensitivity and the operator checks the tank water radioactivity concentration and water volume by sampling prior to the liquid effluent release.

Expected Effluent Release (Ci/y)(2)

Nuclide(1)

From Waste Monitor Tank

(WMT) via Holdup

Tank (HT)

(A1)

From Waste Monitor

Tank (WMT) via

Waste Holdup Tank

(WHT)

(A2)

Effluent Volume (gpd) (3)

(B)

Average Effluent Concentration (�Ci/cm3) (4)

(C)

Rb-88 0 0.00187 2.3E-07 Ru-106/Rh106 0.0001 0.00243 3.2E-07

Cs-136 0.0003 0.00112 1.8E-07 Cs-137/Ba-137m 0.00003 0.00008 1.4E-08

Ba-140 0.00001 0.00031 4.0E-08 La-140 0.00001 0.00051

From WMT via HT: 2785 gpd + 900 gpd From WMT via WHT: 2023 gpd

6.5E-08 Total 6.8E-03 (Ci/y) 8.02E+09 (cm3/y) 8.4E-07

Notes (1) The major gamma-emitter nuclides are selected. (2) See DCD Table 11.2-10 (“Shim Bleed” and “Misc. Wastes” columns). These effluent releases are derived from the ANSI/ANS-18.1-1999 (realistic source term) and MHI PWR-GALE code. “Shim bleed” effluent released from WMT via HT.

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 1 Page 3 of 5

“Misc. wastes” effluent released from the WMT via WHT. (3) See DCD Table 11.2-9 (“Shim Bleed Flow Rate,” “Coolant Drain Flow Rate,” and “Dirty Drainage Flow Rate” rows.) (4) Average Effluent concentration is calculated from the equation shown below:

C = (A1 + A2) x 1E+06 (�Ci/Ci) / (B x 365.25 (day/year) x 3.785412E+03 (cm3/gal))

Impact on R-COLA See attached marked-up FSAR Revision 1 pages 11.2-3 and 11.2-4. Impact on S-COLA None; this RAI is site-specific. Impact on DCD None.

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 111.2-3

evaporation pond effluents are commingled with various Unit 1 and 2 waste effluent streams. This Unit 1 circulating water flow path then goes to the Unit 1 condenser water box outlet, where it joins the Unit 2 condenser water box outlet flow. The joined flows from the Unit 1 and 3 condenser water boxes are then sent to the SCR via the Unit 1 and 2 discharge tunnel and outfall structure from all four units (see Figure 11.2-201 Sheet 10) for a visual representation of the above described flow path.

The header where the WMS intersects with the CWS is located within the Unit 1 Turbine building. The header contains two flow balancing valves (1CW-247 and 1CW-248) for Units 1 and 2. This arrangement ensures that there is always circulating cooling water flow for Unit 1 and/or Unit 2. The circulating water discharge piping then becomes progressively larger and flows freely (no valves) into the Unit 1 condenser water discharge box. This flow path also ensures there is less back pressure into the treated effluent flow. Based on the fact that the effluent piping flows freely into the box and that there is less back pressure, there is no need for a mixing orifice and backflow preventer, as the large circulating water return flow and length of pipe is sufficient to thoroughly mix the release.

The bypass valve, VLV-531, is located in the same area with the radiation monitor and the discharge control valves (RCV-035A and RCV-035B), which are inside the Auxiliary Building. All normal discharge is required to go through the discharge control valves. To ensure discharge operation is not interruptedprevented by the failure of the control valves at any time, a bypass valve is added around the radiation monitor and the discharge control valves. Plant procedures require that an operator verify the tank water radioactivity concentration by sampling and water volume by level indicator prior to a liquid effluent release via the bypass valve. The ODCM and supporting procedures ensure appropriate actions to prevent an unmonitored release.

Any leakage from the bypasspiping and the valves inside the buildings is collected in the floor drain sump, and is forwarded to the waste holdup tank for re-processing. It should be noted that the discharge control valves are downstream of the discharge isolation valve (AOV-522A and AOV-522B). During normal operations, the discharge is anticipated to occur once a week for approximately three hours for treated effluent, and one discharge (approximately an hour at 20 gpm) of detergent waste (filtered personnel showers and hand washes) daily. After each discharge, the line is flushed with demineralized water for decontamination.

The bypass valve is normally locked-closed and tagged. It requires an administrative approval key to open and the valve position is verified by at least two technically qualified members of the CPNPP Operations staff before discharge can start. Thus, a single operator error does not result in an unmonitored release. In the unlikely event that the valve is inadvertently left open, or partially open, the flow element detects flow and initiates an alarm for operator action. Also, at least a portion of the flow goes through the radiation monitor.Also, a portion of the flow continues to flow through the radiation monitor sample

RCOL2_11.02-17

RCOL2_11.02-17

RCOL2_12.03-12.04-11

RCOL2_11.02-17RCOL2_11.05-4

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 111.2-4

chamber. Because the monitor output depends on radionuclide concentration and not flow rate, there is no impact on radiation monitor sensitivity from reduced flow conditions. Prior to opening VLV-531 to establish the alternate flow path, the tanks (ATK-006A and ATK-006B) will be sampled and water volume verified by level indicator to confirm that the contents meet the discharge specifications. Therefore, there is no impact on the annual liquid release and the annual dose to the members of the public if the bypass valve is inadvertently left fully-open.

If the monitor reaches the high setpoint, it sends signals to initiate pump shutdown, valve closure and operator actions.

11.2.2.2.2 Tanks

Replace the second paragraph in DCD Subsection 11.2.2.2.2 with the following.

The tanks are equipped with overflows (at least as large as the largest inlet) into the appropriate sumps. The cells/cubicles housing tanks that contain significant quantities of radioactive material are coated with epoxy to a height that is sufficient to hold the tank contents in the event of tank failure. These coating are Service Level II as defined in RG 1.54 Revision 1, and are subject to the limited QA provisions, selection, qualification, application, testing, maintenance and inspection provisions of RG 1.54 and standards reference therein, as applicable to Service Level II coatings. Table 13.4-201 provides the milestone for decontaminable paints (epoxy coating implementation). Post-construction initial inspection is performed by personnel qualified using ASTM D 4537 (Reference 11.2-22) using the inspection plan guidance of ASTM D 5163 (Reference 11.2-23). Level detecting instrumentation measuring the current tank inventories is provided. High- and low-level alarms are provided. These alarms are annunciated in the radwaste control room located in the A/B and also in the MCR.

11.2.3.1 Radioactive Effluent Releases and Dose Calculation in Normal Operation

Replace the last fivesix paragraphs in DCD Subsection 11.2.3.1 with the following.

The detailed design information of release point is described in Subsection 11.2.2.

The annual average release of radionuclides is estimated by the PWR-GALE Code (Ref.11.2-13) with the reactor coolant activities that is described in Section 11.1. The version of the code is a proprietary modified version of the NRC

RCOL2_11.05-4RCOL2_11.02-17

RCOL2_11.02-14

CP COL 11.2(2)

CP COL 11.2(4)

MAP-11-201

RCOL2_11.03-4

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 2 Page 1 of 4

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Comanche Peak, Units 3 and 4

Luminant Generation Company LLC

Docket Nos. 52-034 and 52-035

RAI NO.: 5474 (CP RAI #208) SRP SECTION: 11.02 - Liquid Waste Management System QUESTIONS for Balance of Plant Branch 2 (SBPB) DATE OF RAI ISSUE: 3/10/2011

QUESTION NO.: 11.02-17 In response to RAI 11.2-4, Luminant provided information on the administrative controls regarding the bypass around the discharge radiation monitor in the liquid waste management system. However, the following additional information is needed in the COLA FSAR to confirm compliance with Part 50, Appendix A, General Design Criterion (GDC) 60: The RAI response states: “Prior to opening VLV-531 to establish the alternate flow path, the tanks (ATK-006A and ATK-006B) will be sampled and the contents confirmed to meet the discharge specifications.” This statement should be included in the FSAR to ensure that tank concentrations are less than the effluent concentration limits (ECLs) specified in 10 CFR 20, Appendix B prior to opening the bypass valve, in order to comply with Part 50, Appendix A GDC 60 and 64.

Provide additional information in the FSAR to confirm that an unmonitored release will not occur during the scenario where the unmonitored discharge bypass is being used for an offsite discharge and the monitor tank sample is not indicative of the actual radionuclide concentration of the tanks (for example due to human error, or analysis equipment error). Provide additional details in the FSAR to ensure that this unmonitored discharge effluent will be less than the effluent concentration limits specified in 10 CFR 20, Appendix B. NUREG-0800, Standard Review Plan (SRP) Section 11.2, “Review Procedures,” 3.F specifies that NRC guidance includes industry standards including ANS 55.6. ANS 55.6 Section 5.5 “Process and Effluent Radiation Monitoring” states: “The process and effluent radiation monitoring devices shall be designed to provide continuous monitoring and recording of information about radioactive liquids being released to the environment from the [Liquid Radwaste Processing Systems] (LRWPS). Effluent radiation monitors in the system shall automatically terminate the release of radioactive waste upon determination of high radiation (above a predetermined set point) in the discharge… All pathways of liquid radioactive releases to the environment shall be monitored.” The current design has a bypass around the radiation monitor, therefore creating a pathway of liquid radioactive release to the environment that is not monitored. In addition, the design has isolation provisions for the radiation monitor as well, so it cannot be relied upon for monitoring in bypass discharge configurations. Table 1.9 -212, “Comanche Peak Nuclear Power Plant Units 3 & 4 Conformance with Standard Review Plan Chapter 11 Radioactive Waste Management,” does not show this exception from SRP 11.2 guidance. Provide additional details in the FSAR either addressing how the

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 2 Page 2 of 4 design ensures the pathway of liquid radioactive release to the environment will always be monitored or specifically justify the exception from SRP 11.2 and ANS 55.6 in FSAR Section 11.2 and Table 1.9.-212.

ANSWER: As discussed in the response to RAI No. 5377 (CP RAI #201) Question 11.05-4 above, VLV-531, the bypass valve around radiation monitor RE-035, is administratively controlled and normally maintained in the locked-closed position. This valve can only be opened with a key controlled by CPNPP Operations and its position status is verified by two technically-qualified members of CPNPP Operations. Procedure compliance requires the operator to verify the tank water radioactivity concentration by sampling and verify water volume by level indicator prior to releasing effluent. Therefore, unmonitored effluent will not be discharged to the environment. The liquid effluent can be monitored even if RE-035 is inoperable and the bypass line is being used. The FSAR has been revised to include the procedural requirement to sample concentration and verify tank water volume before release. This is compliant with SRP 11.5 Acceptance Criteria regarding the monitoring of batch releases. As such, the CPNPP FSAR does not need to identify an exception to SRP 11.2 or ANS 55.6. Impact on R-COLA See attached marked-up FSAR pages 11.2-3 and 11.2-4. Impact on S-COLA None; this response is site-specific. Impact on DCD None.

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 111.2-3

evaporation pond effluents are commingled with various Unit 1 and 2 waste effluent streams. This Unit 1 circulating water flow path then goes to the Unit 1 condenser water box outlet, where it joins the Unit 2 condenser water box outlet flow. The joined flows from the Unit 1 and 3 condenser water boxes are then sent to the SCR via the Unit 1 and 2 discharge tunnel and outfall structure from all four units (see Figure 11.2-201 Sheet 10) for a visual representation of the above described flow path.

The header where the WMS intersects with the CWS is located within the Unit 1 Turbine building. The header contains two flow balancing valves (1CW-247 and 1CW-248) for Units 1 and 2. This arrangement ensures that there is always circulating cooling water flow for Unit 1 and/or Unit 2. The circulating water discharge piping then becomes progressively larger and flows freely (no valves) into the Unit 1 condenser water discharge box. This flow path also ensures there is less back pressure into the treated effluent flow. Based on the fact that the effluent piping flows freely into the box and that there is less back pressure, there is no need for a mixing orifice and backflow preventer, as the large circulating water return flow and length of pipe is sufficient to thoroughly mix the release.

The bypass valve, VLV-531, is located in the same area with the radiation monitor and the discharge control valves (RCV-035A and RCV-035B), which are inside the Auxiliary Building. All normal discharge is required to go through the discharge control valves. To ensure discharge operation is not interruptedprevented by the failure of the control valves at any time, a bypass valve is added around the radiation monitor and the discharge control valves. Plant procedures require that an operator verify the tank water radioactivity concentration by sampling and water volume by level indicator prior to a liquid effluent release via the bypass valve. The ODCM and supporting procedures ensure appropriate actions to prevent an unmonitored release.

Any leakage from the bypasspiping and the valves inside the buildings is collected in the floor drain sump, and is forwarded to the waste holdup tank for re-processing. It should be noted that the discharge control valves are downstream of the discharge isolation valve (AOV-522A and AOV-522B). During normal operations, the discharge is anticipated to occur once a week for approximately three hours for treated effluent, and one discharge (approximately an hour at 20 gpm) of detergent waste (filtered personnel showers and hand washes) daily. After each discharge, the line is flushed with demineralized water for decontamination.

The bypass valve is normally locked-closed and tagged. It requires an administrative approval key to open and the valve position is verified by at least two technically qualified members of the CPNPP Operations staff before discharge can start. Thus, a single operator error does not result in an unmonitored release. In the unlikely event that the valve is inadvertently left open, or partially open, the flow element detects flow and initiates an alarm for operator action. Also, at least a portion of the flow goes through the radiation monitor.Also, a portion of the flow continues to flow through the radiation monitor sample

RCOL2_11.02-17

RCOL2_11.02-17

RCOL2_12.03-12.04-11

RCOL2_11.02-17RCOL2_11.05-4

Comanche Peak Nuclear Power Plant, Units 3 & 4COL Application

Part 2, FSAR

Revision 111.2-4

chamber. Because the monitor output depends on radionuclide concentration and not flow rate, there is no impact on radiation monitor sensitivity from reduced flow conditions. Prior to opening VLV-531 to establish the alternate flow path, the tanks (ATK-006A and ATK-006B) will be sampled and water volume verified by level indicator to confirm that the contents meet the discharge specifications. Therefore, there is no impact on the annual liquid release and the annual dose to the members of the public if the bypass valve is inadvertently left fully-open.

If the monitor reaches the high setpoint, it sends signals to initiate pump shutdown, valve closure and operator actions.

11.2.2.2.2 Tanks

Replace the second paragraph in DCD Subsection 11.2.2.2.2 with the following.

The tanks are equipped with overflows (at least as large as the largest inlet) into the appropriate sumps. The cells/cubicles housing tanks that contain significant quantities of radioactive material are coated with epoxy to a height that is sufficient to hold the tank contents in the event of tank failure. These coating are Service Level II as defined in RG 1.54 Revision 1, and are subject to the limited QA provisions, selection, qualification, application, testing, maintenance and inspection provisions of RG 1.54 and standards reference therein, as applicable to Service Level II coatings. Table 13.4-201 provides the milestone for decontaminable paints (epoxy coating implementation). Post-construction initial inspection is performed by personnel qualified using ASTM D 4537 (Reference 11.2-22) using the inspection plan guidance of ASTM D 5163 (Reference 11.2-23). Level detecting instrumentation measuring the current tank inventories is provided. High- and low-level alarms are provided. These alarms are annunciated in the radwaste control room located in the A/B and also in the MCR.

11.2.3.1 Radioactive Effluent Releases and Dose Calculation in Normal Operation

Replace the last fivesix paragraphs in DCD Subsection 11.2.3.1 with the following.

The detailed design information of release point is described in Subsection 11.2.2.

The annual average release of radionuclides is estimated by the PWR-GALE Code (Ref.11.2-13) with the reactor coolant activities that is described in Section 11.1. The version of the code is a proprietary modified version of the NRC

RCOL2_11.05-4RCOL2_11.02-17

RCOL2_11.02-14

CP COL 11.2(2)

CP COL 11.2(4)

MAP-11-201

RCOL2_11.03-4

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 3 Page 1 of 2

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Comanche Peak, Units 3 and 4

Luminant Generation Company LLC

Docket Nos. 52-034 and 52-035

RAI NO.: 5598 (CP RAI #207) SRP SECTION: 09.04.01 - Control Room Area Ventilation System QUESTIONS for Containment and Ventilation Branch 1 (AP1000/EPR Projects) (SPCV) DATE OF RAI ISSUE: 3/10/2011

QUESTION NO.: 09.04.01-3 This is follow-up question to RAI No. 3219 (RAI Letter No 63), Question No. 09.04.01-1. The applicant provided its responses to RAI No 3219 on October 30, 2009 and October 29, 2010. (ADAMS Accession Numbers ML093090163 and ML103060043). The applicant, in its response dated October 23, 2009 (ML093090163) provided information on the basic equation used and the parameters used to derive the kilowatt sizing of each air handling unit (AHU) heater. The applicant based this calculation on an outside air temperature of -0.5ºF, based on the historical limit excluding 2 hour peaks from COLA FSAR Table 2.0-1R. The applicant amended this response on October 29, 2010 (ML103060043) with a recalculated heater size based on outside air temperature of -5ºF based on the more conservative 0% exceedance minimum value. This revision of FSAR Table 2.0-1R data was driven by the applicant’s response to RAI No. 4606 (RAI Letter No 155), Question No. 02.03.01-6, dated September 29, 2010 (ML102780284). The staff evaluated the information presented in the RAI responses and concluded that the methodology used to derive the kilowatt sizing of each AHU heater was reasonable. However it was not obvious or verifiable from the data presented in the RAI responses, that the resultant temperature from mixing the two air streams of 18,000 cfm returning from the control room with 1800 cfm of fresh outside air was accurate. Furthermore, the calculations, inputs (e.g. MCR heat loads) and assumptions used to determine the 75.1ºF return temperature of the air (i.e. 18,000 cfm) from the MCR were not part of the applicant’s response. The derivation of this parameter is a key in determining the integrity of the heater sizing calculations. Therefore, the NRC staff requests that the applicant make available to the staff, the calculations, assumptions and input parameters used in the derivation of the MCR air handling unit heaters. As an option, Luminant may place these calculations and supporting information in the Luminant’s Comanche Peak electronic reading room. Alternatively, the staff can perform a formal audit of the applicant’s engineering support calculations at the applicant’s business site. The staff also notes that the applicant, in its response to Question No. 09.04.01-1, did not amend FSAR section 9.4.1.2 to reflect the design basis of the heaters (i.e. change of outside air temperature from -0.5ºF to -5.0ºF). The staff requests that the applicant correct this FSAR deficiency as part of its response.

U. S. Nuclear Regulatory Commission CP-201100540 TXNB-11022 4/13/2011 Attachment 3 Page 2 of 2 ANSWER: As described in DCD Subsection 9.4.1.2.1, the Main Control Room (MCR) HVAC system provides 20,000 cfm of supply airflow to the MCR (and the other rooms in the MCR complex hereafter just referred to as the MCR) and the MCR Toilet/Kitchen Exhaust Fan transfers 1,800 cfm to the outside during normal operation mode. Therefore, the return airflow rate from the MCR is 18,200 cfm. The supply air temperature to the MCR (78ºF) is determined to maintain the maximum MCR temperature as described in DCD Table 9.4-1. Return air temperature from the MCR is derived from heat loss from the MCR, supply airflow to the MCR, and supply air temperature. The heat loss from the MCR (62,000 BTU/h) is through the concrete walls at -5ºF outside air temperature and is a design value. The return air temperature is calculated by the following equation and is determined by the following design condition.

tr = ts - q / ( � x Cp x Q x 60 ) = 78 - 62,000 / (0.075 x 0.24 x 20,000 x 60) = 75.13oF (use 75.1oF for conservatism)

where,

tr: Return air temperature (ºF) ts: Supply air temperature (78.0ºF) q: Heat loss from MCR (62,000 BTU/h) �: Density (0.075 lb/ft3) Cp: Specific heat (0.24 BTU/lb-F)

Q: Supply airflow rate across the heating coils (20,000 CFM with two AHU operating)

Entering air temperature of heating coil mixed with 1,800 cfm of outside air (makeup air) at -5ºF and 18,200 cfm of return air from the MCR at 75.1oF is:

67.8oF = ( ( - 5 × 1800 + 75.1 × 18200) / 20000 )

The full calculation package (4CS-CP34-20110004) has been placed in the electronic reading room for staff review.

Luminant revised the FSAR to use the 100-year return period minimum dry bulb temperatures for site calculations in a supplemental response to RAI No. 4606 (CP RAI #155) (ML102780284). In that submittal, Luminant committed to determine if there were other changes resulting from the use of the extreme temperatures. Those additional changes to both RAI responses and FSAR pages were submitted (ML103060043), including a revision to FSAR Table 9.4-201, which provided the design impact of using an outside air temperature of -5.0ºF instead of -0.5ºF.

Impact on R-COLA

None.

Impact on S-COLA

None; this response is site-specific.

Impact on DCD

None.