CP-201600986, Revised Completion Date for Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan

Revised Completion Date for Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan

ML16356A326
Person / Time
Site:	Comanche Peak
Issue date:	12/14/2016
From:	Thomas McCool Luminant Power, Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201600986, TXX-16112
Download: ML16356A326 (2)

Text

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Thomas P. McCool Luminant Power Site Vice President P 0 Box 1002 Thomas.McCool@Luminant.com 6322 North FM 56 Glen Rose, TX 76043 Luminant T 254 897 6042 c 817 776 0308 F 254 897 6652 CP-201600986 TXX-16112 December 14, 2016 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)

DOCKET NOS. 50-445 AND 50-446 REVISED COMPLETION DATE FOR THE COMANCHE PEAK MULTIPLE SPURIOUS OPERATION CIRCUIT INTERACTIONS RESOLUTION IMPLEMENTATION PLAN

REFERENCE:

Letter logged TXX-15049, dated April 7, 2015, "Revised Completion Date for the Comanche Peak Multiple Spurious Operation Circuit Interactions Resolution Implementation Plan," from Lurninant Power to the NRC

Dear Sir or Madam:

Vistra Operations Company LLC (Vistra OpCo) is implementing its plan to resolve multiple spurious operations (MSOs) issues at Comanche Peak, as documented in the referenced letter. This plan integrated resolution of operator manual actions (OMAs) with modifications to Comanche Peak to resolve fire protection potential circuit interactions.

All of the design for the plant modifications for these resolutions have been engineered and completed. The various designs included addition of new operable components, fire barrier circuit protection, cable reroute/relocation, and circuit redesign to either preclude spurious operation or allow manual operation post fire.

All of these modifications have been installed and completed in the plant prior to the end of 2016 as previously committed in the referenced letter with the exception of fire barrier installation for the Unit 2 Train B Power Operated Relief Valve (PORV) circuitry. Two Kapton conductors were found to have damage to their protective coating when the cable tray cover was removed to support Thermo-Lag installation in Unit 2 Elevation 852' .room 2-103. This was documented on Condition Report CR-2016-002892 and will be corrected in the next Unit 2 refueling outage scheduled for the spring of 2017.

These modifications made a substantial improvement in the plant response in the event of a fire. More components are directly operable from the control room. Reliance on operator manual actions in the immediate time following the initiation of a fire has been reduced. Unit differences in response to a fire have been removed. A substantial amount of components have had the control circuits hardened to

U. s. Nuclear Regulatory Commission TXX-16112 Page 2 of 2 12114/2016 decrease the amount of spuriously actuated components which will require action to mitigate or reposition. This will allow simplification of the actions to be taken in the event of a fire.

Follow on paperwork activities to update documentation and other records are ongoing. Revision of the Fire Safe Shutdown Analysis (FSSA) and update of Operations procedures will be completed in the fourth quarter of 2017.

This communication contains the following revised commitment which will be completed as noted:

Number Commitment Due Date 4510008 Luminant Power will complete the Comanche Peak OMA MSO 12-31-2017 Implementation Plan by the end of the Fourth Quarter of 2017.

The Commitment number is used by Luminant Power for the internal tracking of CPNPP commitments.

If you have any questions regarding this submittal, please contact Jack C. Hicks at (254) 897-6725 or jack.hicks@luminant.com.

Sincerely, Vistra Operations Company LLC Thomas P.McCool Site Vice President c-Kriss M. Kennedy, Region IV Margaret M. Watford, NRR Resident Inspectors, Comanche Peak