Comanche Peak Nuclear Power Plant, Units 3 & 4, Status of Regulatory Commitments … ·...

Rafael Flores Luminant PowerSenior Vice President & P 0 Box 1002Chief Nuclear Officer 6322 North FM 56

Lum inant [email protected] Glen Rose, TX 76043

T 254.897.5590F 254.897.6652C 817.559.0403

CP-201400353 Ref. # 10 CFR 52Log # TXNB-14006

March 24, 2014

U. S. Nuclear Regulatory CommissionDocument Control DeskWashington, DC 20555ATTN: Frank M. Akstulewicz, Director

Division of New Reactor Licensing

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 3 AND 4DOCKET NUMBERS 52-034 AND 52-035STATUS OF REGULATORY COMMITMENTS UPON SUSPENSION

Dear Sir:

Lumninant Generation Company LLC (Luminant) began a series of periodic reports to the NRC in April,2010 (ML101130045) describing the status of regulatory commitments made by Luminant incorrespondence to the NRC during the licensing process. This is the final status report until restart oflicensing activities, which remains unscheduled at this time.

Attachment 1 to this letter lists the commitments that have been completed and annotates thecompletion document for each. Attachment 2 lists the open commitments and addresses thesuspension status for each.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Don Woodlan (254-897-6887,[email protected]) or me.

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

Executed on March 24, 2014.

Sincerely,

Luminant Generation Company LLC

Rafael Flores

Attachments: 1. Completed Regulatory Commitments

2. Open Regulatory Commitments

U. S. Nuclear Regulatory CommissionCP-201400353TXNB-140063/24/2014

Electronic distribution w/attachments:

[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected] Licensing [email protected]@[email protected] Records Management (.pdf files only)

[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@[email protected]@nrc.gov


Attachment 1

Completed Regulatory Commitments


Id Source Description Close Doc Close Date Notified NRC4911 TXNB-08032 Luminant will revise the COL application to clarify which information on the affected pages of TXNB-13036 11/26/2013 TXNB-13036

Environmental Report Sections 3.8 and 9.3 should continue to be withheld from public disclosure.See also CTS-00571.

4921 TXNB-08024 In Subsection 5.2.1.4 of the ER, the water usage values for Somervell County are not the latest. TXNB-13036 11/26/2013 TXNB-13036Although the difference is minor and there is no impact on the conclusions, these estimates willbe updated.

4931 TXNB-08029 FSAR Subsection 2.4.13 will be changed in a future revision to reflect the summary information TXNB-13032 10/14/2013 TXNB-13032TXNB-08031 presented herein.

4941 TXNB-08029 Section 7.2.4 of the ER uses data from Tables 7.2-12, 7.2-13 and 7.2-14. A maximum dose risk TXNB-13026 8/1/2013 TXNB-13026in the text does not match the tables but the parameters of concern, the values provided for thehealth effects, are correct. The inconsistency will be corrected.

4951 TXNB-08027 Change FSAR Subsection 6.4.4 to reflect the response provided to Acceptance Review 6.4.4 TXNB-13026 8/1/2013 TXNB-13026Issue.

4961 UAP-HF-08259 Update Table 1.8-201 to reflect the changes made by UAP-HF-08259 sent to the NRC from MHI UAP-HF-13164 6/26/2013 TXNB-13021on Nov 7, 2008. Several COL Items were deleted and others were revised.

4971 TXNB-08024 In Subsection 3.5.4 of the ER, the cation demineralizer flow rate has an incorrect value (179 TXNB-13020 6/19/2013 TXNB-13020gpm). The correct value from the US-APWR DCD is 7 gpm. The COLA will be revised.

4981 TXNB-08028 Change FSAR Subsection 2.5.2.6 to include the information provided in response to Acceptance TXNB-12038 11/26/2012 TXNB-12038Review 2.5.2 Issue 2.

4991 TXNB-08028 Change FSAR Subsection 2.5.2.5 to include the information provided in response to Acceptance TXNB-12034 9/24/2012 TXNB-12034Review 2.5.2 Issue 1.

5001 TXNB-08028 Change FSAR Subsection 2.5.4.5.4 to include the information provided in the response to TXNB-12009 4/16/2012 TXNB-12009Acceptance Review 2.5.4 Issue 5 (Schedule Issue).

5011 TXNB-08027 Change FSAR Subsection 2.5.4.8 to reflect the response provided to Acceptance Review 2.5.4 TXNB-11086 12/8/2011 TXNB-11086Issue 3.

5021 TXNB-08024 Although it is obvious, ER Section 2.3.3.3.5 did not identify CPNPP Units 1 & 2 as TXNB-11086 12/8/2011 TXNB-11086hazardous waste generators (within a 6 mile radius). The section will be revised to reflect thisinformation.

5031 TXNB-08024 In the Environmental Report (ER), Sections 2.3 and 2.2.4 and a table, the terms "Max" and "Ave" TXNB-1 1075 11/7/2011 TXNB-1 1075are used interchangeably for water consumption. These terms will be properly used and the datamade consistent with projected Water Plan amendment.

5041 TXNB-08024 In several locations (primarily ER Chapter 10), the precise acreages for selected areas are not up TXNB-11070 10/27/2011 TXNB-1 1070to-date. These values were updated late in the COL application development and were notupdated in all locations. The differences are not significant and do not change any conclusions,but the ER needs to be revised to be the latest confirmed values.

Page 1 of 11


Id Source Description Close Doc Close Date Notified NRC5051 TXNB-08024 In the FSAR Section 12.5, the text incorrectly states that entry into the interim waste storage TXNB-11069 10/27/2011 TXNB-11069

building will require a radiation work permit. While this is generally true, there will be portions ofthe building that can be entered without such a permit.

5061 TXNB-08024 In the ER Section 10.1.3.2.1 under Air Emissions, the text incorrectly includes natural gas fueled TXNB-11070 10/27/2011 TXNB-11070generators (versus gas turbines) and fails to list the auxiliary boiler. The proper components arediscussed elsewhere in the COL application, but this section will be corrected.

5071 TXNB-08024 In the ER Table 1.3-2, some of the section titles do not match NUREG-1555. This does not TXNB-11070 10/27/2011 TXNB-11070impact the technical content of the COL application or any conclusions, but will be corrected.

5081 TXNB-08024 In the ER Section 10.1.2.1, the text states that the pipeline from Wheeler Branch would provide TXNB-11070 10/27/2011 TXNB-1107050 gpm for potable water, but does not state that the pipeline would also provide 250 gpm for de-mineralized water makeup and system flushing. This additional information will be added.

5091 TXNB-08024 The title for Figure 8.2-201 incorrectly implies that the figure includes the entire ONCOR System. TXNB-1 1072 10/27/2011 TXNB-1 1071The figure title will be clarified.

5101 TXNB-08024 The discussion of relative humidity monitoring in Section 6.7 of the ER was found to be potentiall TXNB-1 1070 10/27/2011 TXNB-1 1070inconsistent with the correct information which is in Section 6.4.1. Luminant will revise Section6.7.

5111 TXNB-08024 In the FSAR Section 2.4.11.5, the maximum expected Lake Granbury intake flow rate is identified TXNB-1 1070 10/27/2011 TXNB-1 1070as approximately 65,400 gpm. This is inconsistent with some other locations in the COLapplication that use 63,350 gpm. Luminant will identify the locations where this parameter isaddressed in the COL application and provide a consistent value or explain any differences.

5121 TXNB-08024 The NRC has issued a proposed supplement to the NRC staffs Proposed Interim Staff Guidance TXNB-11044 6/28/2011 TXNB-11044(ISG) on Limited Work Authorizations, COL/ESP-ISG-004, for use and comment. This guidanceaddresses the aspect of the Limited Work Authorization rule regarding environmental impacts ofpre-construction and construction activities. Pending clarification regarding how to address thisaspect of the rule (which applies to the CPNPP application even though we are not seeking anLWA), Luminant has not included this breakdown of the environmental impacts in the COLapplication. The COL application will be updated to properly address the requirements of therule. Luminant is working with NEI to identify appropriate actions and will revise the COLapplication when sufficient resolution has been attained.

5461 TXNB-09001 Re-write Part 1 to include the Financials of JV and to reflect the new organizational names. TXNB-1 1044 6/28/2011 TXNB-1 1044Expanded to include actions from NRC telecon 06/26/09.

6431 TXNB-09047; TXNB The response to Question 03.10-1 stated in part TXNB-11031 5/9/2011 TXNB-11051

"The plan for the CPNPP Units 3 and 4 seismic qualification program will be provided in MUAP-08015, Revision 1, by the end of October 2009."

Response the RAI 57 Question 3.9.6-1 delayed the submittal until "the end of 2009." Due date ofcommitment modified in TXNB-09058 to 12/31/09.

Page 2 of 11


Id Source Description Close Doc Close Date Notified NRC6461 TXNB-09048 Response to RAI 19-5 part (1) in TXNB-09048: TXNB-11032 5/6/2011 TXNB-11051

"The FSAR will be revised in the next COLA revision to indicate the basic events and RAWvalues of the site-specific events (i.e., failure of cooling tower fans) that are different from thereference US-APWR DCD."

6471 TXNB-09048 Response to RAI #29 Question 19-5 Part (2) in TXNB-09048: TXNB-11032 5/6/2011 TXNB-11051

"Site-specific key assumptions and design features will be described in the subsection thatreferences DCD Table 19.1-115. Design features and key assumptions that will be included inthe FSAR are: (list provided in response).

6481 TXNB-09048 Response to RAI #28 Question 19-5 Part (3) stated: TXNB-11013 3/14/2011 TXNB-11013

"Plant high confidence of low probability of failure (HCLPF) values for the plant-specific SSCs,such as cooling towers, will be confirmed with a calculation using EPRI TR-1 03959 methodologyafter completion of seismic design and stress analysis of the SSCs."

Superceded by #8256.

6491 TXNB-09048 Response to RAI #28 Question 19-5 Part (3) stated: TXNB-11013 3/14/2011 TXNB-11013

"When the seismic margin analysis for the design certification is available, we will confirm that theanalysis envelopes the plant-specific design."


6631 TXNB-09064 The response to RAI #93 Question 19-8 states: TXNB-11013 3/14/2011 TXNB-11013

With regard to the application of more recent guidance for probabilistic risk assessment - basedSMA methodology as applicable to the site-specific features of the COLA, Luminant plans torevise the COLA to incorporate the EPRI TR-1002988, "Seismic Fragility Application Guide," inresponse to the draft Interim Staff Guidance (ISG-20), which is expected to prescribe detaileditems that should be included in the FSAR. EPRI TR-1002989, "Seismic Probabilistic RiskAssessment Implementation Guide," may also be incorporated into the FSAR.


6641 TXNB-09064 The response to RAI #93 Question 19-8 states: TXNB-11013 3/14/2011 TXNB-11013

Luminant will revise the FSAR to include a description of the site-specific SMA results, includingmakeup water and seismically-driven common failure mode considerations for the UHSmechanical draft cooling towers, in response to ISG-20.


Page 3 of 11


Id Source Description Close Doc Close Date Notified NRC6661 TXNB-09064 The response to RAI #90 Question 16-2 stated: UAP-HF-1 1046 2/25/2011 TXNB-1 1028

The response to RAI No. 3698 (CP RAI #109) Question 09.02.01-1 will provide the calculation ofavailable NPSH and will provide changes to FSAR Subsection 9.2.5 regarding required ESWpump NPSH during the 30-day period following a LOCA.

6671 TXNB-09066 The response to RAI #78 Question 13.03-8 stated: UAP-HF-11030 2/21/2011 TXNB-11010

A Proposed License Condition will be included in a future revision to Part 10 of the CombinedLicense Application (COLA) [as described in Attachment 13.03-08 (the last phrase was deletedfrom the letter because there was no Attachment 13.03-08)]

6711 TXNB-09065 The response to RAI 79 Question 17.5-9 stated: See above 2/9/2011 TXNB-11010

RG 1.8, RG 1.28, and RG 1.33 have been added to Revision 1 of the QAPD, but the followingexceptions not listed in Revision 1 are to be taken by Luminant. These exceptions will beincorporated into an update of the CPNPP 3 and 4 QAPD.

6721 TXNB-09065 The response to RAI 83 Question 14.3.7-28 stated: TXNB-11008 2/7/2011 TXNB-11008

Although this response [to CP RAI #83 Question 14.03.07-28] addresses the question asked,Luminant commits to revise the ITAAC by December 10, 2009 to include a description for eachsystem in the COLA ITAAC to be consistent with DCD Tier 1 system descriptions.

6731 TXNB-09068 The response to RAI 118 Question 12.1-2 stated: UAP-HF-11017 1/27/2011 TXNB-1 1028

Once NEI 07-08 is approved by the NRC, FSAR Chapter 12 referenced sections will be revisedto reflect the approved version NEI 07-08A and all differences, if any, will be addressed.

6741 TXNB-09068 The response to RAI 118 Question 12.1-4 stated: UAP-HF-11007 1/18/2011 TXNB-11007

Once NEI 08-08 is approved by the NRC, FSAR Chapter 12 referenced sections will be revisedto reflect the approved version NEI 08-08A and all differences, if any, will be addressed.

6751 TXNB-09069 Proposed revisions to the ETE Report require review by State and local governments prior to MUAP-10006 RO 1/11/2011 TXNB-10054implementation. The revised ETE will be submitted to State and local governments for finalreview and certification, and will be submitted to the NRC following certification. Changes wereproposed via letter TXNB-09069 dated November 16, 2009 in response to questions posed byRAI No. 3183 (CP RAI #88) including Questions 13.03-18 through 13.03-27.

6761 TXNB-09072 The response to RAI #70 Question 13.03-1, Critical Element 2 stated: MUAP-10001 R1 1/11/2011 TXNB-10054

CPNPP EALs provided in Appendix 1 of the Emergency Plan will be updated to include currentUS-APWR design information and to indicate the differences and deviations (to NEI 99-01,Revision 5) currently known to Luminant.

6801 TXNB-09071 The response to RAI #109 Question 9.2.1-5 stated: MNES QPP 7.5 Rev 0 12/20/2010 TXNB-11007

FSAR Figure 9.5.1-201 will be revised to show the [fire protection water supply system] FSSinterface with ESWS.

Page 4 of 11


Id Source Description Close Doc Close Date Notified NRC6811 TXNB-09073 The response to RAI #60 Question 3.7.2-4 stated: TXNB-10089 12/16/2010 TXNB-11007

The COLA FSAR will be revised to incorporate as necessary the results of the MHI SSI analyses.

6821 TXNB-09073 The response to RAI #60 Question 3.7.2-8 stated: TXNB-10089 12/16/2010 TXNB-11007

The site-specific SSI analyses of the R/B will be revised to address the changes in the buildingbasement configuration and design enhancements. The FSAR will be revised in COLA Revision2 to include the SSI analyses that will provide SASSI calculated dynamic earth pressures fordirect comparison. FSAR Sections 3.7 and 3.8 and Appendix 3NN will be revised in the nextCOLA revision to address the basemat configuration and design embedments and to provideSASSI calculated dynamic earth pressures.

6831 TXNB-09073 The response to RAI #60 Question 3.7.2-9 stated: UAP-SGI-10003 Rev 1 11/22/2010 TXNB-11007

Because of the large ratio of the standard plant input motion versus the site-specific input motion,the assumptions for the standard plant design of the A/B and T/B were considered to envelopethe critical responses of the non-uniform site-specific soil column profiles, and were not validatedby performing site-specific SSI analyses. SSI analyses for A/B and T/B in generic standard soilinput will be performed by May 2010.

6871 TXNB-09078 The response to RAI #108 Question 3.8.4-5 states: TXNB-10080 11/8/2010 TXNB-10080

The response to RAI No. 3006 (CP RAI #122) Question 03.08.04-52, to be submitted no laterthan December 21, 2009, provides further discussion on the testing methods of the engineeredbackfill for CPNPP Units 3 and 4.

6881 TXNB-09078 The response to RAI #108 Question 3.8.4-15 states: TXNB-10076 10/29/2010 TXNB-10076

The description of this [equivalent time travel] method will be added to FSAR Sections 3NN.2 and3NN.3 in the response to RAI No. 3006 (CP RAI #122) Question 03.08.04-53 to be submitted tothe NRC no later than December 21, 2009.

6891 TXNB-09081 The response to RAI #123 Question 9.4.5-4 stated: UAP-HF-10283 10/22/2010 TXNB-1 1007

FSAR Figure 3.8-206 and related Chapter 3 figures will be revised in a future FSAR UpdateTracking Report as the detailed [ESW and transfer pump room] ventilation design and equipmentlayout progresses.

This is a two-step action: 1) determine when the design will be ready to include in a UTR, and 2)change the due date for this PAIL Item to reflect when the UTR will be submitted.

Page 5 of 11


Id Source Description Close Doc Close Date Notified NRC6901 TXNB-09081 The response to RAI #123 Question 9.4.5-5 stated: TXNB-10073 10/21/2010 TXNB-10073

The [ESW transfer pump room] flooding event evaluation will be described in a new FSARSubsection 3.4.1.5.3 and the details of the floor drain and sill design will be shown in FSARFigure 3.8-209 or related FSAR Section 3.8 figures in a future FSAR Update Tracking Report.FSAR Subsection 9.4.5.3.6 will also be revised to reflect the new flooding-related FSARinformation.

This is a two-step PAIL Item: 1) determine when the flood evaluation will be ready to include in aUTR, and 2) change the due date to reflect submission of the UTR.

7201 TXNB-10007 The supplemental information for RAI #10 Question 9.5.1-7 stated: TXNB-10070 10/11/2010 TXNB-10070

DCD Tier 2 Subsection 9.5.1.1 will be revised to address deviations from the NFPA codes andstandards as identified in RG 1.189 Regulatory Position 1.8.6 and FSAR Table 9.5.1-1R. Therevision will be provided in an upcoming DCD Update Tracking Report.

7211 TXNB-10013 TXNB-10013 stated: TXNB-10069 10/6/2010 NA

The responses for the two remaining [ER RAI #3] questions from the referenced letter[(ML093280707)], ALT-03 and SOC-33, will be provided by March 11, 2010 along withsupplemental information for questions GEN-03 and TE-04. The only commitment in this letter isstated above regarding the two remaining responses for the referenced letter.

7221 TXNB-10018 The response to RAI 135 Question12.3-12.4-11 in Attachment 1 of TXNB-10018 stated: TXNB-10065 9/20/2010 TXNB-10065

Site-specific design considerations for compliance with RG 4.21 will be added in FSAR Chapter12. This RAI response will be revised to incorporate the changes by the end of May 2010.

7231 TXNB-10018 The response to RAI 135 Question 12.3-12.4-11 in Attachment 1 of TXBN-10018 stated: UAP-HF-10225 8/2/2010 TXNB-10077

Subsection 12.3.1., "Minimization of Contamination and Radioactive Waste Generation," will beadded to the DCD to delineate the design features incorporated into the US-APWR. This sectionwill identify the design features discussed in RG 4.21 and where these features are specificallydiscussed in the DCD. The changes will be provided in Mitsubishi Heavy Industries, Ltd. letter tothe NRC by the end of May 2010.

7351 TXNB-10028 The response to RAI 150 Question 3.3.2-8 stated: TXNB-10052 7/16/2010 TXNB-10054

The first sentence in the third paragraph of DCD Subsection 3.3.2.3 will be corrected in the nextrevision of the DCD to delete "including loss of its siding" for the AC/B.

7381 TXNB-10031 TXNB-10031 stated that the proposed change [regarding re-opening Squaw Creek Reservoir and TXNB-10044 6/24/2010 TXNB-10044Park for fishing and boating] submitted in the letter would be included in the next formal revisionof the PSP.

Page 6 of 11


Id Source Description Close Doc Close Date Notified NRC7391 TXNB-10032 TXNB-10045 6/22/2010 TXNB-10054

The response to RAI No. 4310 (CP #143) Question 2.4.3-9 in TXNB-10032 states:

Calculation packages -011 and -012 are currently under revision in response to Questions 2.4.3-5, 2.4.3-7, 2.4.3-8, and 2.4.3-10. Calculation package -015 is currently under revision inresponse to RAI No. 4311 (CP #140) Questions 2.4.4-6 and 2.4.4-7. The revised calculationpackages will be submitted upon completion.

7501 TXNB-10043 The response to Question 2a from the March 9, 2010 RAI on COLA Part 1 stated: TXNB-10045 6/22/2010 TXNB-10054

The tables presenting this financial data will be updated in a future Update Tracking Report.

7511 TXNB-10043 The response to Question 5a from the March 9, 2010 RAI on COLA Part 1 stated: TXNB-10043 6/10/2010 TXNB-10043

These changes regarding the citizenship of the Representative Group members have beenincorporated in and a markup have been provided with the Update Tracking Report for theupdate to the tables in Part 1.

7531 TXNB-10047 UAP-SGI-08002 will be revised as stated in the response to Questions 13.06.01-25, -27, -28, -33, TXNB-10040 6/3/2010 TXNB-10054-34, and -35.

7541 TXNB-10047 (Question 13.06.01-35) - DCD Subsection 13.6.2.6 will be revised to provide consistency in the TXNB-10040 6/3/2010 TXNB-10054use of backup and standby power.

7561 TXNB-10047 The Security Plan will be revised as stated in the response to Questions 13.06.01-14, -15, -16, - MHI UAP-HF-10080 4/2/2010 TXNB-1003319, -20, -21, -22, -23, -26, -29, -30, -35, -36, -41, -45, -46, -47, -50, and -51.

7571 TXNB-10047 (Question 13.06.01-27) - UAP-SGI-10003, Rev. 0, will be revised to clearly indicate that the MHI UAP-HF-10089 3/31/2010 TXNB-10033waterbome threat is encompassed in the analysis.

7581 TXNB-10048 (RAI CP #164 Question 14.02-18): Similar changes to Table 1.9-201 will be made for other RGs TXNB-10023 3/19/2010 TXNB-10033not associated with Section 14.2 in a future FSAR update tracking report.

7761 TXNB-10069 The response to RAI 172 Question 06.04-9 stated "FSAR Subsection 6.4.4.2 will be revised to TXNB-10011 (ML100550203) 2/22/2010 TXNB-10011 (ML1001reflect the results of the new HABIT analyses by October 29, 2010."

7771 TXNB-10069 The response to RAI 172 Question 06.04-10 stated "The sensitivity analysis representing the TXNB-09082 (ML093570266) 12/21/2009 TXNB-10033most conservative set of conditions as described in Question 06.04-9 above will be included inthe amended calculation by October 29, 2010."

7781 TXNB-10063 This response [to Question 02.05.04-22] will be supplemented with figures to provide additional TXNB-09085 (ML093500123) 12/14/2009 TXNB-10033information regarding excavations, fills and slopes for Category I structures.

NRC requested on 9/23/2010 that all of the figures associated with this response be added to theFSAR. The NRC considers these figures to be SRI and will withhold them from publicdissemination. New commitment due date is 10/25/2010.

Page 7 of 11


Id Source Description Close Doc Close Date Notified NRC7801 TXNB-10065 The supplemental response to RAI 135 Question 12.3-12.4-11 stated: In the next revision of the TXNB-09085 (ML093500123) 12/14/2009 TXNB-10033

DCD currently scheduled for March 2011, Subsection 9.1.3.2.1.3 will be revised to include theoperating experience discussed in EPRI TR-1013470.

7811 TXNB-10066 The supplemental response to RAI #155 Question 2.3.1-6 stated: TXNB-09080 (ML093480067) 12/10/2009 TXNB-10033

"Luminant is determining if there are other necessary changes to the FSAR resulting from theresponse to this question. Any additional FSAR changes will be submitted as a supplement tothis response no later than October 29, 2010."

8131 TXNB-10073 TXNB-10073 stated: TXNB-09074 (COLA Rev 1) 11/20/2009 TXNB-10033

The supplemental information for the response to RAI No. 4841 impacts the response to RAI No.2818 and No. 2819 provided in the last quarter of 2009. Luminant will provide supplementalinformation for those responses by November 30, 2010.

8151 TXNB-10075 MNES will revise procedure QAP-GEN-7.5 to provide enhanced instructions to inform all affected TXNB-09071 (ML093280698) 11/20/2009 TXNB-10033organizations when a Supplier Deviation Report is issued and also to ensure timely correctiveaction. This will involve requirements to impose time restrictions and escalation methods forSupplier Deviation Reports.

8239 TXNB-10083 The same changes [that were made to CPNPP Units 3 and 4 Tech Spec 5.5.18 and 5.5.19 in TXNB-09074 (COLA Rev 1) 11/20/2009 TXNB-10033response to RAI No. 5164 (CP RAI #186) Question 16-20] will be made to US-APWR DCDChapter 16 in Revision 3.

8242 TXNB-10087 The response to Question 17.5-12 stated: TXNB-09074 (COLA Rev 1) 11/20/2009 TXNB-10033

Luminant has made the requested changes and will confirm that revision levels and dates for allthe references in Subsections 17.3.1 and 17.5.2 are consistent.

8245 TXNB-11006 The response to CP RAI #191 Question 19-01 states: TXNB-09072 (ML093240321) 11/18/2009 TXNB-10033

Figure 1 and Figure 2 [Figure 1, CPNPP Units 3 & 4 Protected Area Map and Figure 2, CPNPPUnits 3 & 4, Site Map] will be included in the next revision of the CPNPP MSR.

8254 TXNB-1 1009 The response to RAI #197 Question 17.04-6 stated: MUAP-08015 (ML093160512) 11/6/2009 TXNB-10033

MHI will submit marked-up DCD Table 17.4-1 Sheets 28, 29, 43, and 44 as part of an RAIresponse by the end of February 2011.

8256 TXNB-1 1013 Commitments 6481, 6491, 6631, and 6641 were consolidated into this commitment: TXNB-09038 (ML092520269) 8/31/2009 TXNB-10033

Luminant commits to complete the site-specific SMA and update Final Safety Analysis ReportChapter 19 accordingly within four months of completion of the US-APWR SMA. The site-specific SMA will include evaluation of the site-specific structures using the guidance of ISG-20.

Page 8 of 11


Id Source Description Close Doc Close Date Notified NRC8266 TXNB-11021 The response to CP RAI #209 Question 14.03-03-5 stated: TXNB-09026 (ML092090582) 7/24/2009 TXNB-10033

Also, to be consistent with ITAAC improvements made in DCD Revision 3, a number of additionalchanges will be made to COLA Part 10 in an Update Tracking Report in May 2011.

8268 TXNB-1 1025 The response to CP RAI #211 Question 14.03.12-2 states: TXNB-09026 (ML092090582) 7/24/2009 TXNB-10033

FSAR Subsections 14.3.4.12 and 14.3.7 have been revised to add a reference to "ComanchePeak Units 3 and 4 Physical Security Hardware ITAAC Abstracts." The Abstracts will be includedin COLA Part 11, Enclosures.

8272 TXNB-1 1029 The response to CP RAI #198 Question 6b states: TXNB-09011 (ML091460334) 5/14/2009 TXNB-10033

FSAR Table 1.9-220 has been revised to include compliance with NRC Bulletin 2005-01. Aresponse to this bulletin will be submitted in separate letter as it contains SGI. Anticipatedsubmittal is prior to December 31, 2011.

8273 TXNB-1 1029 The response to Question CP RAI #198 Question 5 states: TXNB-09007 (ML091130575) 4/16/2009 TXNB-10033

A separate SGI letter will be forthcoming that provides the SNM Physical Protection Programduring the time the requirements 10 CFR 73.67 are in effect. This description of the SNMPhysical Protection Program will be provided by December 31, 2011.

8279 TXNB-1 1040 The response to CP RAI #219 Question 2.5.1-22 states: TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033

Luminant will perform detailed geologic mapping of the excavations for the Comanche PeakNuclear Power Plant, Units 3 and 4 nuclear island structures; examine and evaluate geologicfeatures discovered in the excavations for safety-related structures other than those for the Units3 and 4 nuclear islands; and notify the Director of the Office of New Reactors, or the Director'sdesignee, once excavations for the Comanche Peak Nuclear Power Plant, Units 3 and 4 safety-related structures are open for examination by the NRC staff.

8290 TXNB-11054 Luminant has addressed the technical issues raised by the DNFSB letter through an initial TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033evaluation of the existing analyses results for the structures listed in the response to item 1, asdescribed further in item 3. The initial evaluation will be finalized and documented along with acomparison study which will be available in November 2011. The comparison study will be anSSI analysis sensitivity study for the embedded PSFSVs using three different SSI methods[Subtraction/FI-FSIN, Modified Subtraction/Flexible Interface - Excavated Volume BoundaryNodes (FI-EVBN), Direct/Flexible Volume (FV)].

8291 TXNB-11054 Luminant makes the following commitments to assess changes in the standard plant seismic TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033design:

- Identify subsections of the COL application, in particular FSAR Chapter 3 and relatedAppendices, which need to be updated to show new standard plant structures' configurationchanges and numerical results (such as ISRS). This assessment will be submitted to the NRC bythe end of October 2011.

Page 9 of 11


Id Source Description Close Doc Close Date Notified NRC8292 TXNB-1 1054 Luminant makes the following commitments to assess changes in the standard plant seismic TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033

design:

- Review the seismic design and identify updates to the COLA for any new analyses specificallyrequired as a result of the updated standard plant methodology (e.g. evaluation for selection, ifnecessary based on seismic stability evaluations, of a standard plant shear key design option).This assessment will be submitted to the NRC by the end of December 2011.

8293 TXNB-1 1054 Luminant makes the following commitments to assess changes in the standard plant seismic TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033design:

- Perform final confirmatory reviews of the seismic design. Provide a detailed mark-up of theCOLA where changes to standard plant configuration or numerical results occur (such as FSARAppendix 3NN) in an update tracking report (UTR) by the end of February 2012.

8294 TXNB-1 1054 Luminant makes the following commitments to assess potential change impacts on the site- TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033specific structures' design due to changes in standard plant design methodology:

- Identify subsections of the COLA, in particular FSAR Chapter 3 and related Appendices, whichmay be impacted by changes in standard plant design methodology. This assessment will besubmitted to the NRC by the end of October 2011.

8295 TXNB-1 1054 Luminant makes the following commitments to assess potential change impacts on the site- TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033specific structures' design due to changes in standard plant design methodology:

- Perform final confirmatory reviews of the seismic design, review and update the COLA ifrequired, including detailed mark-ups of any needed changes, which will be included in a UTR bythe end of February 2012.

8311 TXNB-1 1066 Calculations TXUT-001-FSAR 2.4.3-CALC-036, Rev.0 and TXUT-001-FSAR 2.4.3-CALC-037, TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033Rev.0, and their input files have been uploaded to the Luminant electronic reading room to allowthe NRC to start their review. Luminant will submit electronic copies of these files to the NRC byOctober 31, 2011.

8312 TXNB-1 1070 Luminant is incorporating these six commitments [#8290-#8295] into the ISCP, which will be TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033submitted to the NRC by January 31, 2012.

TXNB-1 2003 (1/25/12) extended the completion date to April 16, 2012 due to US-APWR seismicwork.

8327 TXNB-1 1085 Luminant will add to the CPNPP Units 3 and 4 licensing basis, as requested by the NRC, the TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033target set groups that were not selected in the standard plant portion of the HAE based onapplication of criteria greater than 8-hours to core damage. These three additional target setgroups and related scenarios to evaluate the capability to defend these target set groups will beincluded in Appendix A to the next revision of the HAE.

(Reference RAI 234)

Page 10 of 11


Id Source Description Close Doc Close Date Notified NRC8359 TXNB-12022 Parts 2 and 3 of CP RAI #254 Question 14.03.03-38 and Part 4 of CP RAI #257 Question 14.02- TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033

21 address freeze protection. Luminant is currently re-evaluating the freeze protectionrequirements for the ESWS and commits to provide a supplemental response to these RAIs byAugust 24, 2012.

8373 TXNB-12027 In the response to RAI 261-6527 Question 01.05-1, Luminant committed to submit a supplement TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033to the response describing the activities completed to address the updated EPRI guidance onearthquake sources in the CEUS.

8374 TXNB-12027 In the response to RAI 261-6527 Question 01.05-2, Luminant committed to provide a supplement TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033to the response and include necessary changes to the COLA describing implementation of theprocedure and training provisions of Recommendation 7.1 regarding new spent fuel poolinstrumentation.

8375 TXNB-12027 In the response to RAI 261-6527 Question 01.05-3, Luminant committed to provide the results of TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033an evaluation of the offsite communication equipment provisions in accordance with NEI 12-01,Revision 0 in a supplement to the response and include necessary changes to the COLA.

8377 TXNB-12027 In the response to RAI 261-6527 Question 01.05-3, Luminant committed that with respect to TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033Recommendation 9.3 item 3, offsite communications improvements identified by an evaluation ofthe offsite communications equipment provisions in accordance with NEI 12-01, Revision 0 thatare applicable to CPNPP Units 3 and 4 will be implemented.

8386 TXNB-12030 Figures 1.2-203, 1.2-209, 1.2-204, 1.2-210, 1.2-205, and 3.8-206 TXNB-09005 (ML091120280) 4/2/2009 TXNB-10033

8394 TXNB-12034 The capacity of the new unit heaters added to FSAR Table 9.4-202 has not been determined. TXNB-09002 (ML090490419) 2/20/2009 TXNB-10033These values and any associated impact on FSAR Chapter 8 will be provided by November 27,2012.

8410 TXNB-13001 Luminant intends to update the FSAR to describe how Luminant will address the regulatory- TXNB-13025 TXNB-10325required COL actions that result from the lessons learned from the great Tohoku earthquake andTsunami (Fukushima Required Actions). A portion of that update will address FukushimaRequired Actions that will not be required to be completed prior to the issuance of the CPNPPUnits 3 and 4 COL. These post-COL actions will be listed in a table in the FSAR update and willinclude an implementation schedule for each action listed. A single license condition will beproposed to control implementation of the actions.

8411 TXNB-13001 In response to Item 5 of Attachment 2 to Order EA-12-049, Luminant proposes to A) provide an TXNB-10069 NAFSAR table that will include an entry to submit a “Flex Integrated Plan” to the NRCthat will be consistent with the design of the US-APWR, the US-APWR Fukushima technicaldocument, and the guidance provided by JLD-ISG-2012-01 and NEI 12-06, at least six monthsprior to the initial full participation exercise for Unit 3, and B) to submit a final report to the NRCconfirming full compliance with the requirement prior to initial fuel load for Unit 3. The licensecondition will require that the actions listed in the table be completed per the implementationschedule in the table.

Page 11 of 11


Attachment 2

Open Regulatory Commitments


Id ACTION Description Discussion Source Suspension Status5751 Maintain the Electronic Reading Luminant hereby confirms that the conditions listed This is an ongoing commitment to the NRC. 2012-10, the TXNB-09012 The reading room will be available because the Unit 1/2

Room in accordance with NRC in the referenced [NRC] letter will be maintained room was upgraded and the room is accessed via the contract with CERTREC is being revised to continue torequirements throughout the duration of the CPNPP COL Certrec portal. support Unit 3/4 data. CERTREC is expected to

application review process for as long as the retain/provide the data in the reading room to Luminant.electronic room is available to NRC reviewers.

No ongoing action required.

Restart considerations: A new reading room may need tobe created or contact made with CERTREC to update theold reading room. It may be necessary to confirmacceptability of the new reading room with the NRC.

5761 Submit as-procured vessel material In order to enable timely NRC review of the TXNB-09010 Activity prior to suspension: None.properties pressurized thermal shock (PTS) evaluation using

the as-procured reactor vessel material properties, Suspension: None.the evaluation will be provided within 12 monthsafter acceptance of the reactor vessel. This Restart considerations: Execute commitment.commitment will be included as part of the proposedLicense Condition identified in Table 13.4-201, item5.

5851 Train on and implement LOLA event CPNPP 3&4 will establish LOLA event guidelines TXNB-09022 Activity prior to suspension: None.guidelines that will be implemented and trained on as part of

operational program prior to fuel load. Suspension: None.

Restart considerations: Execute commitment.

5861 Establish new EDMG CPNPP 3&4 will establish a new EDMG that TXNB-09022 Activity prior to suspension: None.describes command and control with arrivingsupport resources and integration with the on-site Suspension: None.equipment and personnel for significant stationevents. Restart considerations: Execute commitment.

5871 Revise existing MOUs to include 3 The MOUs in place will be revised to incorporate TXNB-09022 Activity prior to suspension: None.& 4 CPNPP 3 & 4 prior to fuel load.

Suspension: None.


5881 Provide updated training to LLEA CPNPP 3&4 will provide updated training to LLEA TXNB-09022 Activity prior to suspension: None.individuals and organizations that would respond toCPNPP 3&4. The LOLA (B.5.b) criteria has been Suspension: None.integrated into the training course and will beimplemented prior to operation. Restart considerations: Execute commitment.

5891 Establish and implement guidance Guidance on handling mass casualties for CPNPP TXNB-09022 Activity prior to suspension: None.on mass casualties 3&4 will be established and implemented prior to

operation. Suspension: None.


5901 Train fire brigade and offsite Training on accelerant-fed fires will be provided to TXNB-09022 Activity prior to suspension: None.departments on accelerant-fed fires the fire brigade for Units 3&4 and will be offered to

off-site fire departments that sign an MOU to support Suspension: None.CPNPP 3&4. As part of this training, off-site firedepartments will receive site familiarization training. Restart considerations: Execute commitment.Exercises or table-tops will be considered.

Page 1 of 10


Id ACTION Description Discussion Source Suspension Status5921 Include personnel dispersal in LOLA CPNPP 3&4 LOLA guidelines will include actions for TXNB-09022 Activity prior to suspension: None.

guidelines personnel dispersal upon notification of an imminentaircraft threat. Suspension: None.


5931 Include personnel positioning and Pre-defined positioning and dispersal of personnel TXNB-09022 Activity prior to suspension: None.dispersal in guidance are identified and will be included in the guidance

documents. Suspension: None.


5941 Finalize operational and The operational and programmatic elements of TXNB-09022 Activity prior to suspension: None.programmatic elements of LOLA responding to LOLA events will be finalized by

CPNPP 3&4 prior to fuel load. Suspension: None.


5951 Complete helicopter landing zones Potential landing zones for helicopters have been TXNB-09022 Activity prior to suspension: None.identified for outside support resources perEmergency Plan and LOLA (B.5.b) Guidelines and Suspension: None.will be completed prior to operation.


6101 Establish a turbine maintenance and The only commitment in this letter is on the attached TXNB-09023 Activity prior to suspension: None.inspection procedure prior to fuel revised page 10.2-1 of the Final Safety Analysisload Report, which states "A turbine maintenance and Suspension: None.

inspection procedure will be established prior to fuelload." Restart considerations: Execute commitment.

6231 Update PIT Limits The COL Holder will update the P/T limits prior to TXNB-09028 Activity prior to suspension: None.fuel loading using the PTLR methodologiesapproved in the US-APWR DCD and the plant Suspension: None.specific material properties and inform the NRC ofthe updated PIT limits as required by the CPNPP 3 Restart considerations: Execute commitment.and 4 Technical Specifications. (milestone - prior toinitial fuel load)

6241 Establish FAC monitoring program The flow accelerated corrosion (FAC) monitoring TXNB-09028 Activity prior to suspension: None.program will be established. (milestone - prior toinitial fuel load) Suspension: None.


6361 Implement the coatings program FSAR page 6.1-1 states: The commitment was made on marked-up FSAR page FSAR page 6.1-1 Activity prior to suspension: None.prior to procurement of coating 6.1-1 in response to RAt #16 included as Attachment 2 tomaterials. Coating program will be developed and TXNB-09033 (8/31/09). Suspension: None.

implemented prior to procurement phase.Restart considerations: Execute commitment.

Page 2 of 10


Id ACTION Description Discussion Source Suspension Status6451 Update PRA for RMTS and SFCP The response to Question 19-3 stated: Meeting held with NRC on 11/3/10. TXNB-09047 Activity prior to suspension: None.

Response provded to RAI 186.The PRA for RMTS and SFCP will be updated to Meeting held with NRC on 1/11/11. MNES working on Suspension: None.satisfy the PRA technical adequacy described in the updated draft package to facilitate further discussion withNEI guideline and will be available one year prior to the staff. Package will be sent to the NRC near the end of Restart considerations: Execute commitment.fuel load. See also TXNB-09051 dated 10/8/2009 Feb. Final package should be submitted during the(FSAR UTR # 6). summer 2011.

MNES provided updated draft package to Luminant on2/22 and 2/25. Next step is to schedule public meeting,prefered date is week of 3/28.Public meeting was held on 3/30. MNES to revise themethodology report and provide next draft to Luminant by5/2.NRC issued RAI 218 which asked for some case studiesto be evaluated for Inititiave 5b. Response scheduled forsubmittal by 7/15.PRA methodology document Draft A to be provided wk of

5/2. Final to be submitted in June. Tabletop meetingswith NEI and NRC were held on 6/1 for Initiative 4b and6/29 for Inititative 5b.Final RITS/PRA methodology was submitted on 6/29/11('X-NB-1 1045). NRC said they will review and provideany RAIs later this summer. This item has been movedout to 2013 to complete the rest of the commitment forupdating the PRA.

6521 Submit Procedure Generation The details of the requested information will be RAI #37 Question 13.5.2.1-4 response. Also in FSAR TXNB-09055 Activity prior to suspension: None.Package for EOPs to NRC submitted with the Procedure Generation Package Draft Rev 1 page 13.5-4.

(PGP) for the EOPs that will be submitted to the Suspension: None.NRC at least three months prior to the start of formaloperator training on the EOPs. The PGP will include Restart considerations: Execute commitment.detailed information on the following: (a) adescription of the process used to develop plant-specific technical guidelines (P-STGs) from the US-APWR generic technical guidelines, (b) identificationof (safety) significant deviations from the genericguidelines, including the identification of additionalequipment beyond that identified in the generictechnical guidelines, and engineering evaluations oranalyses as necessary to support the adequacy ofeach deviation, and (c) in accordance with thehuman factors program (FSAR Section 18.8), adescription of the process used to identify operatorinformation and control requirements.

Page 3 of 10


Id ACTION Description Discussion Source Suspension Status6531 Provide specific sample points in Specific sample points will be located during RAI #49 Question 11.2-10 TXNB-09055 Activity prior to suspension: None.

evaporation pond design detailed design and will ensure that representativesamples of the pond are taken before the contents The DCD Chapter 11 phase 2 review completion date is Suspension: None.are transferred to the Squaw Creek Reservoir via March 2010. The COLA phase 2 review is scheduled tothe CPNPP Units 1 and 2 circulating water return be complete in May 2010. This may show up as an Open Restart considerations: Incorporate this commitment intoline. Item on the COLA. We need to have a plan regarding the design of the pond.

when we will address.4/28/10 Update: MHI is confindent that this item will not

become an Open Item. In the response, it has stated thatsample is taken before the contents are transferred to theSquaw Creek Reservoir. This statement should beenough from licensing point of view because additionaldetail information is not required in RG and GDC.

6/30/10 Update: Based on MHI recommendation this willbe treated as a post COL item.

6541 Design interim radwaste storage The [interim radioactive waste] building will be RAt #39 Question 11.4-4. Luminant would like an update TXNB-09055 Activity prior to suspension: Nonebuilding designed in accordance with the applicable re how this will be done. We need some plans in case

regulatory requirements and NRC/industry guidance the NRC make this an open item. Suspension: None.referenced in FSAR Subsection 11.4.2.3

June 30, 2010 Update: We intend to treat this as a post Restart considerations: Incorporate this commitment intoCOL item unless the NRC asks a follow up question to the design procedures/processes for the rad wasteRAt 39 or creates an open item related to the interim building.raioacitive waste building.

6551 Develop Heavy Loads Handling A heavy load handling program, including Continued from Description field: TXNB-09057 Activity prior to suspension: None.Program associated procedural and administrative controls, Heavy load handling equipment maintenance manuals

will be established prior to fuel load and will address and procedures · Heavy load handling Suspension: None.the following attributes consistent with the standards equipment inspection and test plans· Heavyand regulatory guidance identified in revised FSAR load handling personnel qualifications, training, and Restart considerations: Execute commitment.Section 9.1.5. A listing of all heavy loads and heavy control programs· Quality assurance (QA)load handling equipment outside the scope of loads programs to monitor, implement, and ensure compliancedescribed in the referenced certified design and the with the heavy load handling program.associated heavy load attributes (load weight andtypical load path). Heavy load handling safe load TXNB-09057 RAI #52 Question 9.1.5-1. Luminant wouldpaths and routing plans including descriptions of like to understand on how this will be addressed sinceautomatic and manual interlocks and safety devices most of the plan is generic to the US-APWR.and procedures to assure safe load pathcompliance. (continued in Discussion field) 6/30 MNES talking to MHI. Luminant is looking for

confirmation that the movement of heavy loads is beingconsidered in the design. Otherwise we will spend a lotof extra money later on!

On 7/28 NPE provided the update (attached in the issuedoc field) to communicate MHIs work to incorporate theHeavy Loads Handling program into the design andlayout of the plant. Thus this has been moved out to postCOL issue timeframe.

Page 4 of 10


Id ACTION Description Discussion Source Suspension Status6561 Provide alternate methods for VPI, if Luminant confirms that alternate methods for TXNB-09058 RAI #57 Question 3.9.6-8 TXNB-09058 Activity prior to suspension: None.

necessary verification of valve position indicator operation, andthe justification, that are incorporated into the IST Suspension: None.program will be made available consistent with theimplementation schedule for the IST program to Restart considerations: Execute commitment.provide for timely review during NRC inspection ofthe IST program prior to plant operation. Alternatemethods for verification of valve position indicatoroperation, if necessary, will meet the requirementsof ASME OM Code ISTC-3700.

6571 Transition to the QAPD Luminant will transition the activities for the NuBuild TXNB-09058 RAI #59 Question 11.5-3 TXNB-09058 Activity prior to suspension: None.Project to the Quality Assurance Program Document(QAPD) based on NQA-1, RG 1.8, RG 1.28, and RG Operational procedure development Suspension: None.1.33 sometime during the construction of CPNPPUnits 3 and 4. The transition will be complete no Restart considerations: Execute commitment.later than 30 days before fuel load of CPNPP Unit 3.

6581 Develop Operating Procedures Site-specific operational procedures for CPNPP TXNB-09058 RAI #59 Question 11.5-3 TXNB-09058 Activity prior to suspension: None.during transition to QAPD Units 3 and 4 will be developed during the transition

as they are needed. In particular, [radiological] Suspension: None.procedures for radioactive effluents,analyticalprocedures, instrument calibration and regulated Restart considerations: Execute commitment.records will be developed before Unit 3 fuel loadwhich will comply with the CPNPP 3 and 4 QAPD,NQA-1, and relevant NRC RGs as discussed in theCOLA.

6601 Develop plan for sharing personnel The response to RAI No. 2837 (CP RAt #69) TXNB-09061 Activity prior to suspension: None.resources between all four units Question 13.1.2-13.1.3-4 states:

Suspension: None.Luminant does plan to share resources between theproposed CPNPP Units 3 and 4 and the existing Restart considerations: Execute commitment.CPNPP Units 1 and 2 at the Comanche Peak site.The plans for resource sharing are not yet matured,but will be provided to the NRC 18 months prior toUnit 3 fuel load. The plan will include sharing ofpersonnel between the units, a description of theirduties, and the proportion of their time that they mayroutinely be assigned between the units.

6611 Get training program accredidated The response to RAI No. 2836 (CP RAI #68) TXNB-09061 Activity prior to suspension: None.Question 13.1.1-3 stated in an FSAR 13.2.1.1 insert:

Suspension: None.In addition, the training program will be accreditedprior to fuel load or within the time frame established Restart considerations: Execute commitment.by INPO and the operating company seniormanagement using the guidance provided by ACAD08-001, "The Process for Initial Accreditation ofTraining in the Nuclear Power Industry."

Page 5 of 10


Id ACTION Description Discussion Source Suspension Status6651 Use ISG-8 option 3 with the TS The response to RAI #91 Question 16-16 states: Commitment due on Milestone listed. TXNB-09064 Activities prior to and during suspension: None

Markups with RAI #91 fully included ISG 8's option 3.In accordance with the changes to the DCD, The final action required to finish this commitment is to Restart considerations: Develop a plan to address item.Comanche Peak Units 3 and 4 Plant-specific correct all references to the NRC approved revision of theTechnical Specifications will use ISG option (3) as US-APWR Technical Report MUAP-09022 in theproposed in DC/COL-ISG-8, with the reference to Technical Specifications.the US-APWR Technical Report MUAP-09022 TR MUAP-09022 is under review at the NRC. TR status(NRC approved version). will continue to be tracked and when approved the COLA

will be updated. The NRC schedule has DCD Chapt 7review being completed on 7/2010.MAY 21 Update: MUAP-09022 was revised in April asdiscussed with the NRC. The review of the TR is stillscheduled to be completed with DCD Chapter 7.6/30 Update. NRC approval expected in January 2011.

TS can be updated to reference approved report at thattime.1/31 Update. The NRC date for the DCD Chapter 7 SER

has been delayed.4/29/11 Update: MUAP-09022 Rev 2 (Instrument

Setpoint Methodology) scheduled to be submitted5/31/11.Needs to be extended with the NRC. Update will be in

the first Part 4 UTR following NRC approval of MUAP-09022 Rev 2.TXNB-1 1044 (COLA Rev 2) rescheduled the commitmentto "Prior to Phase 6"

6681 Transition to the CPNPP 3 & 4 The response to RAI 79 Question 17.5-6 stated: TXNB-09065 Activity prior to suspension: None.QAPD

This transition [to the CPNPP 3 and 4 QAPD] will be Suspension: None.complete no later than 30 days before fuel load forCPNPP Unit 3. Restart considerations: Execute commitment.

6691 Include RG requirements in COLA The response to RAI 79 Question 17.5-4 stated: This is an ongoing commitment to the NRC. TXNB-09065 This is an ongoing commitment which remains valid duringcontracts the suspension and upon restart of the COLA review.

RG listed in COLA FSAR Table 1.9-201 that are notin the CPNPP 1 and 2 QAP will be included as partof contract requirements for companies performingCOLA work.

6771 Incorporate the fully developed site- The response to RAI #70 Question 13.03-1, Critical TXNB-09072 Activity prior to suspension: None.specific EAI scheme into EP App 1 Element 4 stated:

Suspension: None.As discussed in Critical Element 2, the fullydeveloped site-specific EAL scheme will be Restart considerations: Execute commitment.incorporated into Appendix 1 of the EmergencyPlan. Accordingly, future changes to the EALscheme will require an evaluation under 10 CFR50.54(q) to determine if these changes will reducethe effectiveness of the Emergency Plan.

6781 Modify existing EOF to include Units The response to RAI #78 Question 13.03-7, Part H- TXNB-09072 Activity prior to suspension: None.3 and 4 data displays 4.A stated:

Suspension: None.The existing EOF will be modified to include Units 3and 4 data displays described in the US-APWR Restart considerations: Execute commitment.DCD.

Page 6 of 10


Id ACTION Description Discussion Source Suspension Status7431 Implement underground cable The response to RAI #152 Question 8.2-28 states: TXNB-10037 Activity prior to suspension: None.

monitoring programPeriodic testing of cable insulation for underground Suspension: None.(including medium-voltage) cable within the scope ofthe maintenance rule (10 CFR 50.65) is conducted Restart considerations: Execute commitment.in accordance with established industry guidance todetect potential cable degradation from moistureintrusion. A cable monitoring program that includesmethods for cable selection, test methods, and testfrequencies will be implemented prior to fuel loadauthorization.

7551 Confirm 10 CFR 74.19 requirements (Question 13.06.01-4) - Luminant confirms that TXNB-10047 Activity prior to suspension: None.met 10CFR 74.19 recordkeeping requirements will be

fully implemented for the possession and storage of Suspension: None.Category Ill SNM prior to receipt of fuel onsite forCPNPP Units 3 and 4 in the protected area. Restart considerations: Execute commitment.

8191 Incorporate Units 3 & 4 into the Site procedures and guidelines address dosimetry TXNB-10078 Activity prior to suspension: None.offsite responder dosimetry for offsite responders, including estimates ofprocedures quantities, the process for distribution and the Suspension: None.

process for acquiring additional dosimetryresources. These procedures will be revised and Restart considerations: Execute commitment.updated to incorporate Units 3 & 4.

8201 Include Units 3 & 4 radios in Guidance for the number, location and process for TXNB-10078 Activity prior to suspension: None.guidance distribution of the radios is in site procedures and

will be updated to include an appropriate number of Suspension: None.radios for Units 3 & 4 using performance-basedevaluations. Restart considerations: Execute commitment.

8211 Maintain Units 3 & 4 radios in CPNPP 3 & 4 guidance will contain requirements to TXNB-10078 Activity prior to suspension: None.multiple locations maintain radios at multiple locations and have

sufficient chargers and batteries. Suspension: None.


8221 Include Units 3 & 4 in EP procedures These Emergency Plan procedures have been TXNB-10078 Activity prior to suspension: None.evaluated and found to be adequate for projectingdoses for offsite exposure for CPNPP 3 & 4 and will Suspension: None.be revised to explicitly include CPNPP 3 & 4.


8267 Establish admin controls for truck The response to CP RAI #210 Question 19-14 TXNB-1 1025 Activity prior to suspension: None.bay door when tornado in the area states:

Suspension: None.The truck bay entrance is designed to withstand adesign basis tornado when closed and an Restart considerations: Execute commitment.administrative control will be in place to ensure thatthe truck bay entrance is closed when a tornado isnearby or forecast for the immediate area.

Page 7 of 10


Id ACTION Description Discussion Source Suspension Status8271 Implement 10 CFR 73.55 for CAA The response to CP RAI #198 Question 5 states: TXNB-1 1029 Activity prior to suspension: None.

New fuel will be received and stored in the CAA,which is entirely encompassed by the boundary of Suspension: None.the proposed PA. Upon declaration of anoperational PA, the remaining requirements of 10 Restart considerations: Execute commitment.CFR 73.55 will be implemented, and the PA will beestablished and declared operational prior to fuelload.

8286 Include contamination monitoring in The supplemental information for the response to TXNB-1 1050 Activity prior to suspension: None.aux boiler procedures CP RAI #135 Question 12.03-12.04-11 S03 states:

Suspension: None.When the auxiliary boiler is used for HVAC heating,the condensate from the HVAC heaters is sampled Restart considerations: Execute commitment.and analyzed periodically to determine the level ofcontamination.

The condensate makeup piping from the auxiliarysteam drain tank inside the A/B to the auxiliaryboiler is sampled and analyzed periodically forlevels of contamination when the auxiliary boiler isbeing used. If contamination exceeds apredetermined set point, the steam supply line isisolated and appropriate actions are taken beforethe auxiliary boiler is restarted.

8300 Screen post-licensing-basis freeze Deferred Changes [after the licensing-basis freeze MNES Procedure LSP-LUM-04. "ISG-1 1 Evaluation of R- TXNB-1 1056 This is an ongoing commitment which remains valid duringpoint deferred changes point] will be screened in accordance with internal COLA Changes" was issued (effective 1/25/12). the suspension and upon restart of the COLA review.

guidance to confirm that the criteria of ISG-11 aremet. No changes are expected to be deferred during the

suspension as design changes are not expected to befinalized during the suspension.

Restart considerations: Confirm that there are no deferredchanges and if there are, ensure they are properlyscreened.

8301 Post-licensing basis freeze point Changes [after the licensing-basis freeze point] that MNES Procedure LSP-LUM-04, "ISG-11 Evaluation of R- TXNB-1 1056 This is an ongoing commitment which remains valid duringchanges that meet any of the criteria meet any of the stated criteria will not be deferred. COLA Changes," was issued (effective 1/25/12). the suspension and upon restart of the COLA review.will not be deferred. Luminant will notify the NRC in writing if Changes not meeting the identified screening criteria are

circumstances dictate any deviation from this to be discussed with Luminant, and if decision is to No changes are expected to be deferred during thelicensing-basis freeze point process. proceed, NRC will be notified of the freeze point suspension as design changes are not expected to be

deviation. finalized during the suspension.

Restart considerations: Confirm that there are no deferredchanges and if there are, ensure they are properlyscreened.

8376 Implement NTFF Rec 9.3 offsite In the response to RAI 261-6527 Question 01.05-3, TXNB-12027 Activity prior to suspension: None.communications improvements Luminant committed that with respect to

Recommendation 9.3 item 3, offsite communications Suspension: None.improvements identified by an evaluation of theoffsite communications equipment provisions in Restart considerations: Execute commitment.accordance with NEI 12-01, Revision 0 that areapplicable to CPNPP Units 3 and 4 will beimplemented.

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Id ACTION Description Discussion Source Suspension Status8445 Copy NRC on formal letters with Luminant is hereby committing to ensure the NRC is TXNB-13022 This is an ongoing commitment which must be sustained

gov't agencies that could impact included in the distribution of formal correspondence during the suspension. Although formal correspondence isFEIS with government agencies in the future that could not expected to be issued to government agencies during

impact the FEIS and is tracking this as Regulatory the suspension, it could occur.Commitment #8445. This is the only commitment inthis letter and it will be considered to be complete Restart considerations: Confirm that the commitment wasupon receipt of the combined license, met during the suspension and that responsibility is

assigned to maintain the commitment.

8472 Discuss ending the suspension with Luminant will contact the NRC staff to initiate TXNB-14002 Activity prior to suspension: None.the NRC discussions on how and when the suspension period

should end and COLA reviews resume. Suspension: Develop a communication plan to discussrestart with the NRC. Contact the NRC to initiate thediscussions. Continue discussions as necessary to createa plan for restart which is mutually acceptable.

Restart considerations: The commitment should becompleted prior to restart.

8473 Annual FSAR update during If the [FSAR annual update report] exemption is TXNB-14002 Activity prior to suspension: Submitted suspension request.suspension granted, Luminant will file FSAR Revision 5 within Update directions for caretaker based upon NRC

one year after the end of the suspension period. If response.the extension is not granted, Luminant will fileannual FSAR updates although the updates may Suspension: Comply with NRC response to exemptionstate during the suspension period, that the FSAR request.has not been revised since the last update.

Restart considerations: This will become a normalregulatory requirement and this commitment will not longerapply.

8474 Comply with regulatory Luminant has reviewed the active regulatory TXNB-14002 Activity prior to suspension: Nonecommitments during suspension commitments made regarding the COLA and will

comply with them [during suspension]. Suspension: This is an ongoing commitment and mayrequire action during suspension.

Restart considerations: This commitment will become partof the normal licensing process for keeping the applicationup-to-date. Consider taking action to delete commitment.

8475 Address non-generic Luminant will address non-generic correspondence TXNB-14002 Activity prior to suspension: None. Added to caretakercorrespondence during suspension specifically addressed to Luminant [during responsibilities.

suspension].Suspension: This is an ongoing commitment and willrequire action during suspension.


8476 Track generic correspondence Luminant will track generic correspondence to be TXNB-14002 Activity prior to suspension: Include in caretakerduring suspension addressed as part of the restart of the COLA review responsibilities.

[during suspension].Suspension: This is an ongoing commitment and willrequire action during suspension.


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Id ACTION Description Discussion Source Suspension Status8477 Notify NRC about change of Luminant will inform the NRC via separate TXNB-14002 Activity prior to suspension: None

ownership during suspension correspondence if there is any change in ownershipor in the list of applicants [during suspension]. Suspension: This is an ongoing commitment and may

require action during suspension.


8478 Notify NRC about contact changes The addresses and contact points for Luminant TXNB-14002 Activity prior to suspension: None. Add to caretakerduring suspension remain unchanged and Luminant will contact the responsibilities.

NRC staff if any changes occur [during suspension],Suspension: This is an ongoing commitment and may

require action during suspension.


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Date post:	23-Jul-2020
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