ML15089A554

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Notification of NRC Component Design Bases Inspection (05000445/2015007 and 05000446/2015007) and Initial Request for Information
ML15089A554
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/30/2015
From: Ruesch E
Division of Reactor Safety IV
To: Flores R
Luminant Generation Co
References
IR 2015007
Download: ML15089A554 (8)


See also: IR 05000445/2015007

Text

March 30, 2015

Rafael Flores, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs

Luminant Generation Company LLC

Comanche Peak Nuclear Power Plant

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, -

NOTIFICATION OF NRC COMPONENT DESIGN BASES INSPECTION

(05000445/2015007 AND 05000446/2015007) AND INITIAL REQUEST FOR

INFORMATION

Dear Mr. Flores:

On June 1, 2015, the NRC will begin a triennial baseline Component Design Bases Inspection

at the Comanche Peak Nuclear Power Plant. A six-person team will perform this inspection

using NRC Inspection Procedure 71111.21, Component Design Bases Inspection.

The inspection focuses on components and operator actions that have high risk and low design

margins. The samples reviewed during this inspection will be identified during an information

gathering visit and during the subsequent in-office preparation week. In addition, a number of

operating experience issues will also be selected for review.

The inspection will include an information gathering site visit by the team leader and a senior

reactor analyst, and three weeks of on-site inspection by the team. The inspection will consist

of four NRC inspectors and two contractors, of which five will focus on engineering and one on

operations. The current inspection schedule is as follows:

On-site Information Gathering Visit: May 11 -14, 2015

Preparation Week(s): May 18, 2015; June 8, 2015; and June 22, 2015

On-site Week(s): June 1, 2015; June 15, 2015; and June 29, 2015

The purpose of the information gathering visit is to meet with members of your staff to identify

potential risk-significant components and operator actions. The lead inspector will also request

a tour of the plant with members of your operations staff and probabilistic safety assessment

staff. During the on-site weeks, several days of time will be needed on the plant-referenced

simulator in order to facilitate the development of operator action-based scenarios. Additional

information and documentation needed to support the inspection will be identified during the

inspection, including interviews with engineering managers, engineers, and probabilistic safety

assessment staff.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

R. Flores

- 2 -

Our experience with these inspections has shown that they are extremely resource intensive,

both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact

on the site and to ensure a productive inspection, we have enclosed a request for information

needed for the inspection. The request has been divided into three groups. The first group lists

information necessary for the information gathering visit and for general preparation. This

information should be available to the regional office no later than May 4, 2015. Insofar as

possible, this information should be provided electronically to the lead inspector. Since the

inspection will be concentrated on high risk/low margin components, calculations associated

with your list of high risk components should be available to review during the information

gathering visit to assist in our selection of components based on available design margin.

The second group of documents requested is those items that the team will need access to

during the preparation week in order to finalize the samples to be inspected. The third group

lists information necessary to aid the inspection team in tracking issues identified as a result of

the inspection. It is requested that this information be provided to the lead inspector as the

information is generated during the inspection. Additional requests by inspectors will be made

throughout all three on-site weeks for specific documents needed to complete the review of that

component/selection. It is important that all of these documents are up to date and complete in

order to minimize the number of additional documents requested during the preparation and/or

the on-site portions of the inspection. In order to facilitate the inspection, we request that a

contact individual be assigned to each inspector to ensure information requests, questions, and

concerns are addressed in a timely manner.

The lead inspector for this inspection is Ronald A. Kopriva. We understand that our licensing

engineer contact for this inspection is Gary Merka. If there are any questions about the

inspection or the requested materials, please contact the lead inspector by telephone at

817-200-1104 or by e-mail at Ron.Kopriva@nrc.gov.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be

made available electronically for public inspection in the NRC Public Document Room or from

the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Eric A. Ruesch, Acting Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 05000445 and 05000446

License Nos. NPF-87 and NPF-89

Enclosure:

Component Design Bases Inspection Request for Information

cc: Electronic Distribution for Comanche Peak Nuclear Power Plant

ML15089A554

SUNSI Review

By: RKopriva

ADAMS

Yes No

Publicly Available

Non-Publicly Available

Non-Sensitive

Sensitive

Keyword:

OFFICE

SRI:EB1

ABC:EB1

NAME

RKopriva/dch

ERuesch

SIGNATURE

/RA/

/RA/

DATE

3/25/15

3/30/15

Letter to Rafael Flores from Eric A. Ruesch, dated March 30, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, -

NOTIFICATION OF NRC COMPONENT DESIGN BASES INSPECTION

(05000445/2015007 AND 05000446/2015007) AND INITIAL REQUEST FOR

INFORMATION

Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Thomas.Farnholtz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (John.Kramer@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Rayomand.Kumana@nrc.gov)

Administrative Assistant (Rhonda.Smith@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Project Engineer, DRP/A (Thomas.Sullivan@nrc.gov)

Project Engineer, DRP/A (Margaret.Tobin@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Michael.Waters@nrc.gov)

- 1 -

Initial Request for Information

Component Design Bases Inspection

Comanche Peak Nuclear Power Plant

Inspection Report: 05000445/2015007, 05000446/2015007

Information Gathering Dates:

May 11 - 14, 2015

Inspection Dates:

June 1, 2015; June 15, 2015; and June 29, 2015

Inspection Procedure:

IP 71111.21, Component Design Bases Inspection

Lead Inspector:

Ron Kopriva, Senior Reactor Inspector

I.

Information Requested Prior to Information Gathering Visit (May 11, 2015)

The following information (Section I of this enclosure) should be sent to the Region IV

office in hard copy or electronic format (Certrec IMS preferred), to the attention of

Ronald Kopriva by May 4, 2015, to facilitate the reduction in the items to be selected.

The team leader will provide the licensee the selected components for Section II by

May 12, 2015. The inspection team will finalize the selected list during the week of

May 18, 2015 using the additional documents requested in Section II of this enclosure.

The specific items selected from the lists shall be available and ready for review on the

day indicated in this request. *Please provide requested documentation electronically in

pdf files, Excel, or other searchable formats, if possible. The information should

contain descriptive names, and be indexed and hyperlinked to facilitate ease of use.

Information in "lists" should contain enough information to be easily understood by

someone who has knowledge of pressurized water reactor technology. If requested

documents are large and only hard copy formats are available, please inform the

inspector(s), and provide subject documentation during the first day of the on-site

inspection.

1. An excel spreadsheet of equipment basic events (with definitions) including

importance measures sorted by risk achievement worth (RAW) and

Fussell-Vesely (FV) from your internal events probabilistic risk assessment (PRA).

Include basic events with RAW value of 1.3 or greater.

2. Provide a list of the top 500 cut-sets from your PRA.

3. Copies of PRA "system notebooks," and the latest PRA summary document.

4. An excel spreadsheet of PRA human action basic events or risk ranking of operator

actions from your site specific PSA sorted by RAW and FV. Provide copies of your

human reliability worksheets for these items.

5. List of procedures used to accomplish operator actions associated with the basic

event in your PRA.

- 2 -

6. A list of all time-critical operator actions in procedures.

7. If you have an external events or fire PSA model, provide the information requested

in items 1-4 for external events and fire.

8. Any pre-existing evaluation or list of components and associated calculations with

low design margins (i.e., pumps closest to the design limit for flow or pressure, diesel

generator close to design required output, heat exchangers close to rated design

heat removal, etc.).

9. List of high risk maintenance rule systems/components and functions; based on

engineering or expert panel judgment.

10. Structures, systems, and components in the Maintenance Rule (a)(1) category.

11. Site top 10 issues list.

12. A list of operating experience evaluations for the last 2 years.

13. A list of permanent and temporary modifications for the previous 3 years.

14. List of current "operator workarounds/burdens."

15. List of root cause evaluations associated with component failures or design issues

initiated/completed in the last 3 years.

16. List of any common-cause failures of components in the last 3 years.

17. Electrical one-line drawings for:

Off-site power/switchyard supplies

Normal AC power systems

Emergency AC/DC power systems including

120VAC power

125VDC/24VDC safety class systems

18. A copy of any self-assessments and associated corrective action documents

generated in preparation for the inspection.

19. A copy of engineering/operations-related audits completed in the last 2 years.

20. Current management and engineering organizational charts.

21. List of licensee contacts for the inspection team with phone numbers.

- 3 -

II.

Information Requested to be Available on First Day of Preparation Week

(May 18, 2015)

1. An electronic copy of the Design Bases Documents for the selected components.

2. An electronic copy of the System Health notebooks for the selected components.

3. List of condition reports (corrective action documents) associated with each of the

selected components for the last 5 years.

4. The corrective maintenance history associated with each of the selected components

for the last 3 years.

5. Copies of calculations associated with each of the selected components (if not

previously provided), excluding data files. Please review the calculations and also

provide copies of reference material (such as drawings, engineering requests, and

vendor letters).

6. Copies of operability evaluations associated with each of the selected components

and plans for restoring operability, if applicable.

7. Copies of selected operator workaround evaluations associated with each of the

selected components and plans for resolution, if applicable.

8. Copies of any open temporary modifications associated with each of the selected

components, if applicable.

9. Trend data on the selected electrical/mechanical components performance for last

3 years (for example, pumps performance including in-service testing, other

vibration monitoring, oil sample results, etc., as applicable).

10. List of motor-operated valves (MOVs) in the program, design margin and risk

ranking.

11. List of air operated valves (AOVs) in the valve program, design and risk ranking.

III.

Information Requested to be provided throughout the inspection

1. Copies of any corrective action documents generated as a result of the teams

questions or queries during this inspection.

2. Copies of the list of questions submitted by the team members and the

status/resolution of the information requested (provide daily during the inspection to

each team member).

3. Reference materials (available electronically and as needed during all on-site

weeks):

- 4 -

General set of plant drawings

IPE/PRA report

Procurement documents for components selected

Plant procedures (normal, abnormal, emergency, surveillance, etc.)

Technical Specifications

Updated Final Safety Analysis Report

Vendor manuals

Inspector Contact Information:

Ronald A. Kopriva

Senior Reactor Inspector

817-200-1104

Ron.Kopriva@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Ron Kopriva

1600 East Lamar Blvd.

Arlington, TX 76011-4511