ML20139A145

Notification of NRC Design Bases Assurance Inspection (Programs) (05000445/2020010 and 05000446/2020010) and Initial Request for Information

ML20139A145
Person / Time
Site:	Comanche Peak
Issue date:	05/18/2020
From:	Vincent Gaddy Region 4 Engineering Branch 1
To:	Peters K Vistra Operations Company
References
IR 2020010
Download: ML20139A145 (9)

See also: IR 05000445/2020010

Text

May 18, 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

(PROGRAMS) (05000445/2020010 AND 05000446/2020010) AND INITIAL

REQUEST FOR INFORMATION

Dear Mr. Peters:

On August 10, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an onsite

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

inspection using NRC Inspection Procedure 71111.21N.02, Design Bases Inspection

(Programs), Attachment 2, Design-Basis Capability of Power-Operated Valves Under

Title 10 of the Code of Federal Regulations (10 CFR) 50.55a Requirements.

This inspection will evaluate the reliability, functional capability, and design basis of

risk-important power-operated valves as required by 10 CFR 50.55a and applicable

10 CFR Part 50, Appendix A and Appendix B, requirements, and as required by the Comanche

Peak Nuclear Power Plant Operating License. Additionally, the team will perform an inspection

of the documentation files to verify that the plant activities associated with safety-related

motor-operated valves meet your commitments to Generic Letter (GL) 89-10, Safety-Related

Motor-Operated Valve Testing and Surveillance, and GL 96-05, "Periodic Verification of

Design-Basis Capability of Safety-Related Motor-Operated Valves." In conducting this

inspection, the team will select power-operated valves used to prevent and mitigate the

consequences of a design basis accident.

The inspection will include an information gathering site visit by the team leader and 2 weeks of

onsite inspection by the team. The inspection will consist of three NRC inspectors. The current

inspection schedule is as follows:

Onsite Information Gathering Visit: July 28-29, 2020

Preparation Weeks: August 3-7, 2020, and August 17 - 21, 2020

Onsite Weeks: August10-14, 2020, and August 24 - 28, 2020

K. Peters 2

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

familiar with the power-operated valve activities at the Comanche Peak Nuclear Power Plant.

The lead inspector will request a meeting with your personnel to discuss the site power-

operated valve procedures. Additionally, the lead inspector will request a discussion with your

staff to become familiar with the regulations and standards applicable to power-operated valves

at the site. Additional information and documentation needed to support the inspection will be

identified during the inspection, including interviews with engineering managers and engineers.

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. This information should be

made available to the lead inspector during the July 28-29, 2020, visit. Since the inspection will

be concentrated on safety-related and risk-significant power-operated valves, a list of such

power-operated valves should be available to review during and following the information

gathering visit to assist in our selection of appropriate power-operated valves to review.

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 during the

onsite weeks for specific documents needed to complete the review of specific power-operated

valves and associated activities. 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 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 Wayne C. Sifre. We understand that our licensing

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

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

at 817-200-1193 or by e-mail at Wayne.Sifre@nrc.gov.

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.

The burden to the public for these voluntary information collections is estimated to average

2,250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per examination, including the time for reviewing instructions, searching existing

data sources, gathering and maintaining the data needed, and completing and reviewing the

information collection. You may submit comments on any aspect of the information collection,

including suggestions for reducing the burden, to the FOIA, Privacy and Information Collections

Branch (T-5 F53), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by

electronic mail to INFOCOLLECTS.RESOURCE@NRC.GOV; and to the Desk Officer, Office of

Information and Regulatory Affairs, NEOB-10202, (3150-0018), Office of Management and

Budget, Washington, DC 20503.

K. Peters 3

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.

This letter 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 10 CFR 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

(Programs) Power-Operated Valve

Initial Request for Information

w/Attachment: Comanche Peak

Valves of Interest

cc w/ encl: Distribution via LISTSERV

ML20139A145

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: WCS Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:EB1 C:EB1

NAME WSifre VGaddy

SIGNATURE /RA/ /RA/

DATE 05/18/2020 05/18/2020

Initial Request for Information

Design Bases Assurance Inspection (Programs), Power-Operated Valves

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2

Inspection Report: 05000445/2020010 AND 05000446/2020010

Information Gathering Dates: July 28-29, 2020

Inspection Dates: August 10-14, 2020 and August 24-28, 2020

Inspection Procedure: IP 71111, Attachment 21N.02, Design Bases Assurance

Inspection (Programs) Attachment 2, Design-Basis

Capability of Power-Operated Valves Under

10 CFR 50.55a Requirements

Lead Inspector: Wayne C. Sifre, Senior Reactor Inspector

Inspectors: Gerond George, Senior Reactor Inspector

Wes Cullum, Reactor Inspector

I. Information Requested for Information Gathering Visit (July 28, 2020)

The following information should be provided to the lead inspector in hard copy or

electronic format to the attention of Wayne Sifre by July 20, 2020, to facilitate the

reduction in the items to be selected for a final list of components. The inspection team

will finalize the selected list during the prep week using the documents requested in 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 inspectors and provide subject documentation during the first day of

the onsite inspection.

1. Provide the valve characteristics for the valves listed in the attached list as described

in Appendix C of NRC Inspection Procedure 71111.21N.02, Design Bases

Inspection (Programs), Attachment 2, Design-Basis Capability of Power-Operated

Valves Under 10 CFR 50.55a Requirements.

2. List of power-operated valves (POVs) important to safety for the Comanche Peak

Nuclear Power Plant. The list should include (a) component identification number;

(b) applicable plant system; (c) American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (BPVC) Class; (d) safety-related or non-safety

related classification; (e) valve type, size and manufacturer; and (f) actuator type,

size, and manufacturer. If the NRC has granted a license amendment to categorize

structures, systems, and component in accordance with 10 CFR 50.69, please

provide the risk-informed safety category of the component.

Enclosure

3. Listing of the POVs sorted by risk importance, including external risk considerations.

4. Comanche Peak Nuclear Power Plant word-searchable updated final safety analysis

report (UFSAR), License Conditions, Technical Specifications, and most recent

Inservice Testing (IST) program plan. Specifically identify which UFSAR sections

address environmental, seismic, and functional qualification of POVs.

5. NRC Safety Evaluation Report(s) associated with the Comanche Peak Nuclear

Power Plant IST program and relief and alternative requests submitted in

accordance with 10 CFR 50.55a for POVs.

6. Identify the edition of the ASME Operation and Maintenance of Nuclear Power Plants

(OM Code) that is the Code of Record for the current 10-year IST Program interval,

as well as any standards to which the Comanche Peak Nuclear Power Plant has

committed with respect to POV capability and testing.

7. Comanche Peak Nuclear Power Plant Power Operated Valve Program Documents.

8. List of systems, system numbers/designators and corresponding names.

9. List of site contacts that will be associated with the inspection.

II. Discussions Requested

1. Interview with a Comanche Peak Nuclear Power Plant representative to discuss site

POV capability analyses, including plant drawings and assumptions. This includes

analysis for accident conditions.

2. Interview with a Comanche Peak Nuclear Power Plant representative to discuss

POV maintenance elements as integrated into plant programs and procedures.

3. Interview with a Comanche Peak Nuclear Power Plant representative to discuss

maintaining the design-basis capability of POVs if they have entered a period of

extended operation, if applicable.

III. Information Requested for Inspection Preparation (August 3, 2020)

1. Documentation files, including test reports, for the electrical and mechanical

components associated with the POVs selected by the lead inspector (10 specific

valves will be identified and communicated to you prior to August 3, 2020).

2. References associated with the electrical and mechanical components document

files.

3. Vendor manuals and technical sheets associated with the selected POVs.

4. Tours of the rooms in which the selected POVs are installed.

2

Inspector Contact Information:

Wayne C. Sifre Gerond George Wes Cullum

Senior Reactor Inspector Senior Reactor Inspector Reactor Inspector

817-200-1193 817-200- 1562 817-200- 1563

Wayne.Sifre@nrc.gov Gerond.George@nrc.gov Wes.Cullum@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Wayne Sifre

1600 East Lamar Blvd.

Arlington, TX 76011-4

3

Comanche Peak Valves of Interest

No. ACT Size Valve System Utility ID Selection

(in) Type Basis

1. MOV 8 Gate Unit 1 - AFW - AFW Pump 1-HV-2482 Risk

Emergency Supply Flowpath

2. MOV 8 Gate Unit 1 - CVCS - ECCS 1-LCV-0112E Risk

Injection Flowpath &

Boration

3. AOV 10 Butterfly Unit 1 - CCW - Flowpath 1-FV-4537 Risk

Boundary

4. AOV 3 Ball Unit 1 - CCW - Safety 1-PV-4553

Chilled Water Condenser

Cooling

5. AOV 3 Diaphragm Containment Isolation 1-LCV-1003 LERF

6. AOV 18 Globe Unit 1 - Feedwater Isolation 1-FCV-0540

7. HOV 18 Gate Unit 1 - Feedwater Isolation 1-HV-2134 LERF

& Containment Isolation

8. AOV 3 Globe Unit 1 - RCS - Post Accident 1-PCV-0455A Risk

Vent Path/Vent Path

Isolation

9. MOV 12 Gate Unit 1 - RHR - 1-8701B Risk

Flowpath/Containment

Isolation

10. MOV 8 Gate Unit 1 - SI - ECCS 1-8804B Risk

Recirculation

Flowpath/Passive Pipe

Break Isolation

11. MOV 4 Gate Unit 1 - SI - ECCS to Cold 1-8835 Risk

Legs Flowpath/ECCS to Hot

Legs Flowpath

12. MOV 10 Gate Unit 1 - SI - ECCS to Cold 1-8809B Risk

Legs Flowpath/ECCS to Hot

Legs Flowpath

13. MOV 10 Gate Unit 1 - SI - ECCS to Hot 1-8840 Risk

Legs Flowpath/ECCS to

Cold Legs

14. MOV 24 Butterfly Unit 1 - Service Water 1-HV-4287 Risk

Flowpath/Throttling

15. MOV 4 Gate Unit 2 - Containment 2-HV-2492B Risk

Isolation & AFW to Faulted

SG Flow

16. MOV 2 Globe Unit 2 - CVCS - ECCS 2-8110 Risk

Flowpath Boundary

17. AOV 10 Butterfly Unit 2 - CCW Flowpath 2-FV-4536 Risk

Boundary

18. MOV 18 Butterfly Unit 2 - CCW - RHR Heat 2-HV-4572 Risk

Exchanger Cooling Flowpath

Attachment

No. ACT Size Valve System Utility ID Selection

(in) Type Basis

19. AOV 3 Ball CCW - - Safety Chilled 2-PV-4552 Risk

Water Condenser Cooling

20. AOV 18 Globe Feedwater Isolation 2-FCV-0520 Risk

21. HOV 18 Gate Feedwater Isolation & 2-HV-2137 Risk

Containment Isolation

22. HOV 2 Globe Unit 2 - FW - Feedwater 2-HV-2137 Risk

Isolation & Containment

Isolation

23. HOV 2 Globe Unit 2 - MS - Steam Line 2-HV-2333A Risk

Isolation & Containment

Isolation

24. MOV 3 Gate Unit 2 - RCS - Post Accident 2-8000A Risk

Vent Path/Vent Path

Isolation

25. MOV 6 Gate Unit 2 - SI - ECCS Flowpath 2-8806 Risk

Boundary (during

Recirculation)

26. MOV 14 Gate Unit 2 - SI - ECCS 2-8811A Risk

Recirculation

Flowpath/Containment

Isolation

27, MOV 10 Gate Unit 2 - SI - ECCS to Cold 2-8809A Risk

Legs Flowpath/ECCS to Hot

Legs Flowpath

28. MOV 4 Gate Unit 2 - SI - - ECCS to Hot 2-8802B Risk

Legs Flowpath/ECCS to

Cold Legs

29. MOV 6 Gate Unit 2 - SI - Passive Pipe 2-8923B Risk

Break Isolation

A-2