IR 05000445/2017009
| ML17192A436 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/09/2017 |
| From: | Alexander R D, Haire M S NRC/RGN-IV/DRP/RPB-A |
| To: | Peters K J Vistra Operations Company |
| Haire M S | |
| References | |
| 05000445/2017009, 05000446/2017009, IR 2017009 | |
| Download: ML17192A436 (14) | |
Text
July 9, 2017
Ken J. 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 - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS, AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000445/2017009 AND 05000446/2017009
Dear Mr. Peters:
On May 19, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of the inspection at the Comanche Peak Nuclear Power Plant, Units 1 and 2. On June 26, 2017, the NRC inspectors discussed the results of this inspection with Mr. Tom McCool, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel. The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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/ Mark S. Haire, Chief Project Branch A Division of Reactor Projects Docket Nos. 50-445 and 50-446 License Nos. NPF-87 and NPF-89
Enclosure:
Inspection Report 05000445/2017009 and 05000446/2017009 w/
Attachment:
Supplemental Information cc w/ encl: Electronic Distribution 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000445, 05000446 License: NPF-87, NPF-89 Report: 05000445/2017009 and 05000446/2017009 Licensee: Vistra Operations Company LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: 6322 N. FM-56, Glen Rose, Texas Dates: May 15 - June 26, 2017 Inspectors: R. Alexander, Sr. Project Engineer (Team Leader) E. Uribe, Project Engineer T. Sullivan, Project Engineer Approved By: Mark S. Haire Chief, Project Branch A Division of Reactor Projects 2
SUMMARY
IR 05000445/2017009 and 05000446/2017009; 05/15/2017 - 06/26/2017; Comanche Peak Nuclear Power Plant; Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015. The inspection covered a one week inspection by three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5.
A. NRC-Identified and Self-Revealing Findings
None
B. Licensee-Identified Violations
None 3
REPORT DETAILS
4. Other Activities
4OA5 Other Activities (TI 2515/191) The objective of Temporary Instruction (TI) 2515/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency
Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans" is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No. ML16214A251) and the NRC's plant safety evaluation (ADAMS Accession No. ML16334A173) and to verify that the licensees installed reliable water-level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site-specific submittals and NRC safety assessments, including multi-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event. The inspection verified that plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012 request for information letter and multi-unit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262). The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections. 1. Mitigation Strategies for Beyond-Design-Basis External Events
a. Inspection Scope
The team examined the licensee's established guidelines and implementing procedures for the beyond-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off-normal and Emergency Operating Procedures with the newly developed mitigation strategies. The team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios. The team verified that a preventive maintenance program had been established for the Diverse and Flexible Coping Strategies (FLEX) portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and Security staffs most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel. b. Assessment Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-049. The inspectors verified that the licensee satisfactorily: Developed and issued FLEX Support Guidelines (FSGs, called FLEX Support Instructions (FSI) at Comanche Peak) to implement the FLEX strategies for postulated external events; Integrated their FSIs into their existing plant procedures such that entry into and departure from the FSIs are clear when using existing plant procedures; Protected FLEX equipment from site-specific hazards; Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and Developed means to ensure that the necessary off-site FLEX equipment will be available from off-site locations. The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified. 2. Spent Fuel Pool (SFP) Instrumentation
a. Inspection Scope
The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment. b. Assessment Based on samples selected for review, the inspectors determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA-12-051. The inspectors verified that the licensee satisfactorily: Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation; Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.
The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified. 3. Staffing and Communication Request for Information
a. Inspection Scope
Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment and facilities to support an Extended Loss of All AC Power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from SFPs) capability using the licensee's site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment. b. Assessment The inspectors reviewed information provided in the licensee's multi-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.
The inspectors verified the following: Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario; Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario; and Implemented dose assessment capabilities (including releases from SFPs) using the licensee's site-specific dose assessment software and approach.
The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.
c. Findings
No findings identified.
4OA6 Exit Exit Meeting Summary On May 19, 2017, the inspectors presented the on-site inspection results in a management debrief to Mr. T. McCool, Site Vice President, and other members of the site staff.
The inspectors confirmed that proprietary information examined during the inspection had been returned. The inspectors completed an exit meeting with Mr. T. McCool, Site Vice President, and other members of the site staff, via telephone on June 26, 2017, to discuss the final results of the inspection. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Bryan, Unit Supervisor, Emergency Preparedness
- B. Clark, Sr. Reactor Operator, Operations
- C. Corbin, Principal Engineer, Regulatory Affairs
- R. Deppi, Director, Engineering Projects
- J. Dreyfus, Plant Manager
- B. Henley, Engineer, Engineering
- J. Hull, Manager, Emergency Preparedness
- T. McCool, Site Vice President
- M. McNally, Manager, Security
- M. Reeves, Director, Maintenance
- R. Reible, Sr. Project Engineer/FLEX Project Manager, Engineering Projects
- B. St. Louis, Director, Operations
- J. Taylor, Director, Site Engineering
- L. Wandall, Engineer, Engineering
NRC Personnel
- J. Josey, Senior Resident Inspector
- S. Janicki, Acting Resident Inspector
- N. Sanfilippo, Branch Chief, Office of Nuclear Reactor Regulation, Japan Lessons Learned Div.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed 2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans, issued December 23, 2015
LIST OF DOCUMENTS REVIEWED
Section 4OA5: Other Activities Corrective Action Documents
- CR-2013-002652
- CR-2014-012443
- CR-2014-012945
- CR-2015-000369
- CR-2015-001503
- CR-2015-002099
- CR-2015-003153
- CR-2015-003907
- CR-2015-003994
- CR-2015-004831
- CR-2015-006167
- CR-2015-007415
- CR-2015-008963
- CR-2015-010749
- CR-2016-010177
- EV-CR-2015-003153-1
- CR-2017-006551*
- CR-2017-006568*
- CR-2017-006529*
- CR-2017-006501*
- CR-2017-006488*
- CR-2017-006462*
- CR-2017-006470*
- CR-2017-006432*
- CR-2017-007796*
- IR-2017-005822
- IR-2017-006370
- IR-2017-006372
- IR-2017-006373
- IR-2017-006566
- IR-2017-006594*
- TR-2015-000369
- TR-2016-010177
- TR-2017-000369
- TR-2017-002586
- TR-2017-004075
- TR-2017-005777
- TR-2017-005787
- TR-2017-005822
- TR-2017-006291 * - indicates corrective action document written by the licensee as a result of the NRC inspection
Drawings
- Number Title Revision E1-0007-A Safeguard and Auxiliary Buildings Safeguard 480V MCC's One Line Diagram
- CP-11 M1-0225-06 Flow Diagram Fire Protection System Main Loop
- CP-34 M1-0225 Flow Diagram Fuel Building Fire Protection
- CP-16 E1-0024-01A Diagram
Procedures
Procedures
- Number Title Revision
- ABN-601 Response to a 138/345kV System Malfunction 13
- ABN-907 Acts of Nature 15
- ECA-0.0A/B Loss of All AC Power 9
- ECE-5.08 Design Change Process 2
- FSI-1.0A/B Long Term Inventory Control 0
- FSI-10.0A/B Accumulator Venting 0
- FSI-11.0 Alternate SFP Makeup 0
- FSI-20.0A/B Loss of All AC Power While on Shutdown Cooling 0
- FSI-21.0A/B Shutdown RCS Makeup 0
- FSI-22.0A/B Shutdown SG Makeup 0
- FSI-24.0A/B Mode 5/6 DC Bus Load Management and Phase 2 480 VAC Generator Alignment 0
- FSI-3.0A/B Alternate AFW Pump Operation 0
- FSI-30.0 Phase 3 Equipment Operation 0
- FSI-30.501 Phase 3 Alternate SSW System Restoration 0
- FSI-30.502 Phase 3 CCW System Restoration 0
- FSI-30.506 Phase 3 Spent Fuel Pool Cooling System Restoration 0
- FSI-30.507 Phase 3 Reactor Makeup Water System Restoration 0
- FSI-30.509 Phase 3 Instrument Air System Restoration 0
- FSI-30.802 Phase 3 Control Room Ventilation System Restoration 0
- FSI-30.814 Phase 3 Ventilation Chilled Water System Restoration 0
- FSI-30.815 Phase 3 Safety Chilled Water System Restoration 0
- FSI-30.816 Phase 3 Primary Plant Ventilation System Restoration 0
- FSI-4.0A/B DC Bus Load Management and Phase 2 480 VAC Generator Alignment 0
- FSI-5.0 Initial Assessment and FLEX Equipment Staging 0
- FSI-6.0 Alternate CST Makeup 0
- FSI-7.0A/B Loss of Vital Instrumentation or Control Power 0
- FSI-8.0A/B Alternate RCS Boration 0
- IPO-003A Power Operations 30
- IPO-005A Plant Cooldown from Hot Standby to Cold Shutdown 26
Procedures
- Number Title Revision
- SOP-907A Containment Personnel Airlocks 16
- STA-634 Extreme Temperature Equipment Protection Program 6
- STA-677 Preventive Maintenance 11
- STI-140.01 Station Non-Accredited Training 2
- STI-204.01 FSI Rules of Usage 0
- STI-204.01-6 FLEX 12KW Generator Local Job Aid 0
- STI-204.01-7 FLEX Phase 2 480 VAC Generator 0
- STI-250.02-11 FLEX Emergency Plan Equipment Inspection and Inventory 2
- STI-716.06 Impact Assessments Reviews 0
- Parent/Model Work Orders Number Title Revision / Date
- 5370628 FLEX Bobcat Compact Track Loader {No Date}
- 5377309 Multipurpose High Flow FLEX Pump {No Date}
- 5383629 FLEX Fuel Caddy Trailer {No Date}
- 5405326 Phase 2 480
- VAC 500 KW Diesel Generator {No Date}
- 5410242 FLEX Portable 12 KW Diesel Generator 120/240 {No Date}
- 5428642 FLEX Equipment Storage Building {No Date}
Calculations
- FDA 2013-000008-28-01
Miscellaneous
- Documents/Reports Number Title Revision / Date
- Comanche Peak Nuclear Power Plant Units 1 and 2 Safety Evaluation December 14, 2016
- FLEX Validation Integrated Review - Comanche Peak November 6, 2015
- Training Program Curriculum - LORT Requal 2017-2018 March 23, 2017
- Training Program Curriculum - NEO Requal 2017-2018 March 23, 2017
- DBD-ME-012 Beyond Design Basis Events 2
- ER-ME-133 Beyond-Design-Basis External Event Mitigation Strategies 1 IC25SYSSF1 Training Material/Lab Guide - Spent Fuel Pool Level Instrumentation April 28, 2015 LGC13555 CPNPP FLEX Equipment Storage Building Geotechnical Investigation Report January 2014 LO44.FLX.01 Simulator Exercise Guide - Loss of All AC - FLEX July 22, 2015 MD31.ADM.FLS Lesson Plan - FLEX System Mods November 6, 2014
- OPD1.ADM.FLD FLEX Delta Training October 22, 2015
- OPD1.ADM.FLX Lesson Plan - FLEX Intro March 4, 2014
- TXX-13081 Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuant to 10
- CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights April 30, 2013
- TXX-16002 Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 And 50-446, Submittal of Updated Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing) (TAC NOS. ME8686 and ME8687) January 20, 2016
- TXX-16051 Comanche Peak Nuclear Power Plant Final Integrated Plan July 28, 20160 VDRT
- 4889620 Specification for 4160 VAC - 6900 VAC Three Phase Step Up Transformer February 28, 2014 PO S08098296D6 Purchase Order for ABB Power 4160-to-6900 VAC Transformers May 6, 2015 Requisition 611-6R
- 429687 Purchase Order for ABB Power 4160-to-6900 VAC Transformer January 6, 2015
- K. Peters
- 3
- COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS, AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS - INSPECTION REPORT 05000445/2017009
- AND 05000446/2017009 - DATED JULY 9, 2017