ML20309A360
| ML20309A360 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/04/2020 |
| From: | Vincent Gaddy Region 4 Engineering Branch 1 |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2020011 | |
| Download: ML20309A360 (7) | |
See also: IR 05000445/2021011
Text
November 4, 2020
Mr. Ken Peters
Senior Vice President and
Chief Nuclear Officer
Attention: Regulatory Affairs
Vistra Operations Company LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
NOTIFICATION OF NRC DESIGN BASES ASSURANCE INSPECTION (TEAMS)
(INSPECTION REPORT 05000445/2021011 AND 05000446/2021011) AND
INITIAL REQUEST FOR INFORMATION
Dear Mr. Peters:
On February 8, 2021, the Nuclear Regulatory Commission (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,
Attachment 21M, Design Bases Assurance Inspection (Teams).
The inspection focuses on the maintenance of component design bases and modifications
made to structures, systems, and components. The samples reviewed during this inspection
will be identified during an information gathering visit and during the subsequent in-office
preparation week. In addition, operating experience issues will also be selected for review.
The inspection will include an information gathering site visit by the team leader and
two weeks of onsite inspection by the team. The inspection will consist of a team lead
inspector, two mechanical inspectors, two electrical inspectors, and an operations inspector.
The current inspection schedule is as follows:
Information Gathering Visit: January 4-8, 2021
Preparation Week: February 1-5, 2021
Onsite Weeks: February 8-12 and February 22-26, 2021
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 inspection, up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> will be needed on the plant-referenced simulator in
order to facilitate the development and inspection of operator action-based scenarios. It has not
yet been determined if the inspection will be onsite or conducted remotely. If the inspection is
performed remotely, we are requesting that, as a minimum, actual on-site time be made
available for 1-2 days to perform component and modification walkdowns. Simulator activities
K. Peters
2
would have to be performed on site. 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.
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 two 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 January 4, 2021, unless
otherwise stated. If possible, this information should be provided electronically to the lead
inspector. Since the inspection will be concentrated on high-risk/low-margin components and
modifications, calculations associated with your list of high-risk components and modifications
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 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. An additional request will be made by the team during the preparation week once
the specific components and modifications have been selected. Additional requests by
inspectors will also be made throughout the onsite weeks for specific documents needed to
complete the review. 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
onsite 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, Senior Reactor Inspector. 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. It is our
understanding that Mr. Gary Merka will be our licensing contact for the inspection.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office
of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and
Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor sponsor, and a person is not required to respond to, a request
for information or an information collection requirement unless the requesting document
displays a currently valid OMB control number.
K. Peters
3
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Vincent G. Gaddy, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos. 05000445 and 05000446
License Nos. NPF-87 and NPF-89
Enclosure:
Design Bases Assurance
Inspection (Teams) Request for
Information
cc w/ encl: Distribution via LISTSERV
Vincent G.
Gaddy
Digitally signed by Vincent
G. Gaddy
Date: 2020.11.04 10:53:56
-06'00'
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: RAK
Yes No
Publicly Available
Sensitive
OFFICE
SRI:EB1
C:EB1
NAME
RAKopriva
VGGaddy
SIGNATURE
/RA/
/RA/
DATE
11/04/2020
11/04/2020
Enclosure
Initial Request for Information
Design Bases Assurance Inspection (Teams)
Comanche Peak Nuclear Power Plant
Inspection Report: 05000445/2021011 and 05000446/2021011
EPID ID:
I-2021-011-0002
Information Gathering Date:
January 4-8, 2021
Inspection Dates:
February 8-12, 2021, and February 22-26, 2021
Inspection Procedure:
IP 71111, Attachment 21M, Design Bases Assurance
Inspection (Teams)
Lead Inspector:
Ronald A. Kopriva, Senior Reactor Inspector
I.
Information Requested Prior to Information Gathering Visit (January 4, 2021)
The following information (Section I of this enclosure) should be sent to the Region IV
office in hard copy or electronic format (electronic database preferred), to the
attention of Ronald A. Kopriva, Senior Reactor Inspector, by January 4, 2021, to
facilitate the reduction in the items to be selected for a final list. The inspection team
will finalize the selected list during the prep week 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 boiling water reactor technology. If requested documents are large and only hard
copy formats are available, please inform the inspector and provide subject
documentation during the first day of the onsite inspection.
1. An Excel spreadsheet of equipment basic events (with definitions), including
importance measures sorted by risk achievement worth and Fussell-Vesely
from your internal events probabilistic risk assessment. Include basic events
with risk achievement worth value of 1.3 or greater.
2. A list of the top 50 cut-sets from your PRA.
3. Copies of probabilistic risk assessment system notebooks and the
latest probabilistic risk assessment summary document.
4. An Excel spreadsheet of probabilistic risk assessment human action basic
events or risk ranking of operator actions from your site-specific PSA sorted by
risk achievement worth and Fussell-Vesely. Provide copies of your human
reliability worksheets for these items.
2
5. If you have an external events or fire PSA model, provide the information
requested in items 1-4 for external events and fire.
6. A list of high large early release frequency impact events and
associated components.
7. Structures, systems, and components in the Maintenance Rule (a)(1) Category.
8. A list of high risk maintenance rule systems/components and functions; based
on engineering or expert panel judgment.
9. Site top 10 issues list, if available.
10. Any pre-existing list of components and associated calculations with low
design margins.
11. A list of operating experience evaluations for the last 3 years.
12. A list of all time-critical operator actions in procedures.
13. A list of current operator work arounds/burdens.
14. Procedures, including emergency and abnormal, used to accomplish
operator actions associated with the basic events credited in your PRA.
15. Lists of permanent and temporary modifications performed in the past 5
years to structures, systems, and components sorted by component
identified in Item 1.
16. List of root cause evaluations associated with component failures or design
issues initiated/completed in the last 5 years.
17. A list of any common-cause failures of components in the last 3 years.
18. A copy of any internal/external self-assessments and associated corrective
action documents generated in preparation for this inspection.
19. A copy of engineering/operations-related audits completed in the last 2 years.
20. Electronic copies of the Technical Specifications, Technical Specifications
Bases, and the Final Safety Analysis Report, as updated.
21. A copy of the Individual Plant Examination of External Events, if
available electronically.
22. One-line drawings of emergency core cooling system, ultimate heat sink,
emergency feedwater, safety-related electrical systems.
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23. A copy of condition reports associated with inspection findings from the
previous NRC Inspection Procedure 71111.21 (or 71111.21 Attachment M
inspection).
24. A list of licensee contacts for the inspection team with phone numbers.
25. A copy of the current management and engineering organizational charts.
II.
Information Requested to be provided throughout the inspection.
1. Electronic copies of the design bases documents for selected components
and modifications.
2. Electronic copies of the system health notebooks for selected components
and modifications.
3. A list of the design calculations that provide the design margin information for
selected components. (Calculations for selected components should be
available during the information gathering visit.)
4. Calculations and drawings associated with selected components.
5. Modification documentation associated with modifications selected from
Item I.15, this includes:
a. Post-modification testing, including performance characteristics affected,
assumptions, and acceptance criteria associated with modifications
selected.
b. Updated maintenance and surveillance procedures associated with
modifications.
c. Updated operation procedures and training plans associated with the
modifications.
6. Copies of any corrective action documents generated as a result of the
teams questions or queries during this inspection.
7. 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).
Inspector Contact Information:
Ronald A. Kopriva
Senior Reactor Inspector
817-200-1104 - Work
Ron.Kopriva@nrc.gov
Mailing Address:
U.S. NRC, Region IV
ATTN: Ronald A. Kopriva
1600 East Lamar Blvd.
Arlington, TX 76011-4511