CP-201900467, (CPNPP) - Biennial Review of Procedures and Station Operations Review Committee Meetings

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(CPNPP) - Biennial Review of Procedures and Station Operations Review Committee Meetings
ML19228A086
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/14/2019
From: Thomas McCool
Luminant, TXU Energy, Vistra Operations Company
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201900467, TXX-19076
Download: ML19228A086 (12)
v • d • e


Text

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I Luminant Thomas P. McCool Site Vice President Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897.6042 CP-201900467 TXX-19076 U.S. Nuclear Regulatory Commission Ref 10 CFR 50.54(a)(4)

ATIN: Document Control Desk Washington, DC 20555-0001 8/14/2019

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Biennial Review of Procedures and Station Operations Review Committee Meetings In accordance with the requirements of 10 CFR 50.54(a)(4)(ii), Vistra Operations Company LLC (Vistra OpCo) requests approval of the attached revision to the FSAR description of (1) the biennial reviews of Emergency Response Guidelines (ERGs), Functional Restoration Guidelines (FRGs), and Abnormal Plant Operating (ABNs) procedures and (2) Station Operations Review Committee (SORC} meeting frequency, which are part of the previously accepted CPNPP quality assurance program. Since these changes may be considered a reduction in quality assurance commitment, NRC approval is required prior to implementation of the changes. Vistra OpCo believes these changes do not reduce the effectiveness of the Quality Assurance Program.

The intent of the biennial reviews is accomplished by other Comanche Peak Nuclear Power Plant processes and programs which make the biennial reviews redundant and as such the biennial reviews represent an unnecessary expenditure of CPNPP management and staff resources which does not produce an overall safety benefit.

6555 SIERRA DRIVE IRVING, TEXAS 75039 0214-812-4600 VISTRAENERGY.COM

TXX-19076 Page 2 of 2 The SORC meeting frequency is changed from "at least once per calendar month and as convened by the SORC Chairman or his designated alternate" to "periodically as determined by the SORC Chairman or his designated alternate." Currently, special SORC meetings are called as needed by the SORC Chairman (this is not changing).

NRC Regulatory Guide 1.33, Revision 2, "Quality Assurance Program (Operations)," discusses the need for an onsite independent review committee (i.e., SORC) but does not prescribe meeting frequency. The change to SORC meeting frequency does not reduce the effectiveness of the SORC oversight function. provides a mark-up of the affected FSAR pages. Attachment 2 (Biennial Reviews) and Attachment 3 (SORC Meeting Frequency) provide a description of the changes, the reason for the changes, and the basis for concluding that the revised program continues to satisfy the quality assurance program commitments previously accepted by the NRC. Attachment 4 provides a list of updated regulatory commitments described in this submittal.

Should you have any questions, please contact Carl B. Corbin at (254) 897-0121 or carl.corbin@luminant.com.

In accordance with 10 CFR 50.54(a)(4)(iv), CPNPP plans to implement these changes following receipt of an NRC letter indicating acceptance or 60 days after the date of the submittal.

Sincerely, Thomas-1:McCool FSAR marked up pages Description and Basis for Change - Biennial Reviews Description and Basis for Change - SORC Meeting Frequency List of Regulatory Commitments c- Scott A. Morris, Region IV Natreon Jordan, NRR Resident Inspectors, Comanche Peak to TXX-19076 Page 1 of 5 CPNPP/FSAR jFor Information Only

2. The recommendations of Revision 1 (6/73) or Revision 2 (5/77) of this regulatory guide are used .
3. The exception described in Subsection 6.1B.1.1.4.

Also refer to Appendix 1A(N).

Regulatory Guide 1.32 Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants Discussion The CPNPP design complies with the requirements of Revision 2 (2/77) of this regulatory guide.

For details see Section 8.3 .

Regulatory Guide 1.33 Quality Assurance Program (Operation)

Discussion The quality assurance requirements for the operations phase of CPNPP are in compliance with Revision 2 (2/78) of this regulatory guide as implemented by ANSI N18.7-1976 , "Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants", with the following exceptions:

1. Biennial Reviews of Plant Procedures The quality assurance program has specified alternatives to the program area audit frequencies stated in Regulatory Position C.4. The quality assurance program schedules the audits provided for in Regulatory Position C.4 at 24 month frequencies. The audit schedu le is performance-based and additional audits may be scheduled based upon program or functional area performance or other factors that indicate the need for increased assessment.

The intent of the biennial review is accomplished by CPNPP programmatic controls already in place. The following controls assure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, regulatory requirements ,

industry experience and other conditions that may impact plant procedures.

  • Site Modification Process Corrective Action Program Off-Normal Occurrence User Feedback and Procedure Compliance Operating Experience Review 1A(B)-9 Amendment No. 109 to TXX-19076 Page 2 of 5 CPNPP/FSAR Vendor Technical Information Licensed Document Change/50 .59 Evaluation Commitment Tracking System (CTS)

Trending Activities Infrequently Performed Evolutions Control Delete

  • Requalification Training Quality Assurance Activities In addition, biennial reviews are performed of non-routine procedures (Emergency Response guidelines (ERGs), Functional Restoration Guidelines (FRGs) and Abnormal Plant Operating Procedures (ABNs)).

Note: 10CFR50.59 has been revised and the terminology in Section 4.3.4 of ANSI N18.7-1976 is no longer current. Section 17.2 has been updated to reflect the revision to 10CFR50.59.

2. Identification of QA Program Requirements in Procurement Documents Quality Assurance program requirements consistent with 10CFR50 Appendix B or ANSI N45.2 are not imposed in procurement documents for commercial grade calibration services from a National Voluntary Laboratory Accreditation Program (NVLAP) or American Association for Laboratory Accreditation (A2LA) accredited calibration laboratory evaluated in accordance with Section 17.2.7.

Regulatory Guide 1.34 Control of Electroslag Weld Properties Discussion Refer to Appendix 1A(N).

Regulatory Guide 1.35 lnservice Inspection of Ungrouted Tendons in prestressed Concrete Containment Structures Discussion This regulatory guide is not applicable to the CPNPP which has a steel-lined, reinforced concrete containment structure.

Regulatory Guide 1.36 Nonmetallic Thermal Insulation for Austenitic Stainless Steel 1A(B)-10 Amendment No. 109 to TXX-19076 Page 3 of 5 CPNPP/FSAR !For Information Only

2. Technical and administrative direction of the Director, Nuclear Training.
3. Operational and technical support of CPNPP.
4. Techn ical and administrative direction for the implementation of quality assurance requirements and controls at CPNPP.
5. Technical and administrative direction of Plant Manager and assumes duties if the position is not occupied.

17.2.1.1.3 Plant Manager The Plant Manager is responsible to the Site Vice President for plant operations at CPNPP .

Specific duties and responsibilities of the Plant Manager include the following :

1. Technical and administrative direction of the Director, Operations .
2. Technical and administrative direction of the Director, Maintenance.
3. Technical and administrative direction of the Manager, Radiation Protection.
4. Operational and maintenance support of CPNPP .
5. Manager of all operations activities at CPNPP.
6. Chai rmanship of the Station Operations Review Committee (SORC).
7. Membership on the Operations Review Committee upon appointment by the Senior Vice President & Chief Nuclear Officer.

17.2.1.1.3.1 Station Operations Review Committee (SORC)

The SORC shall function to advise the Plant Manager on all matters related to nuclear safety.

The SORC shall as a minimum be composed of the Chairman and six individuals who collectively have experience and expertise in the areas listed below and meet the requirements of Regu latory Guide (RG) 1.8, Rev. 2 for required experience .

Operations Maintenance Instrumentation and Controls Technical Support Radiation Protection Quality Assurance 17.2-2 Amendment No. 109 to TXX-19076 Page 4 of 5 CPNPP/FSAR The Plant Manager shall serve as the chairman of SORC. A senior health physicist is acceptable for the Radiation Protection representative on SORC. The SORC members shall be designated, in writing, by the Plant Manager.

All alternate members shall be appointed in writing by the Plant Manager to serve on a temporary basis; however, no more that two alternates shall participate as votin members in SORC activities at any one time. periodically as determined The SORC shall meet by the SORC Chairman or his desig The quorum of the SORC necessary for the performance of the SORC responsibility and authority shall consist of the Chairman or his designated alternate and a majority of the regular members (or their alternates).

The SORC shall be responsible for:

1. Review of applicable administrative procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
2. Review of: (1) procedures, (2) change to procedures, equipment, systems or facilities ,

and (3) tests or experiments where nuclear safety is adversely affected ;

3. Review of proposed procedures and changes to procedures , equipment, systems or facilities which require an amendment to the operating license;
4. Review of proposed test or experiments which require an amendment to the operating license ;
5. Review of proposed changes to Technical Specifications or the Operating License :
6. Investigation of all violations of the Technical Specifications requiring a written report to the NRC, including the forwarding of reports covering evaluation and recommendations to prevent recurrence to the Senior Vice President & Chief Nuclear Officer and to the ORC:
7. Review of reports or operating abnormalities, deviations from expected performance of plant equipment and of unanticipated deficiencies in the design or operation of structures ,

systems or components that affect nuclear safety;

8. Review of all events submitted pursuant to 10CFR50.73. Other non routine reports may be reviewed at the discretion of the SORC Chairman or the responsible manager.
9. Review of changes to the PROCESS CONTROL PROGRAM , the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems ;
10. Review of any accidental , unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation , recommendations , and dispositions of the corrective action to prevent recurrence and the forwarding of these reports to the Senior Vice President & Chief Nuclear Officer and to the ORC; 17.2-3 Amendment No. 109 to TXX-19076 Page 5 of 5 CPNPP/FSAR

!For Information Only

11. Review of Unit operations to detect potential hazards to nuclear safety;
12. Investigations or analysis of special subjects as requested by the Chairman of the ORC or the Plant Manager.
13. Review of the Fire Protection Report and implementing procedures and submittal of recommended Fire Protection Report changes to the ORC; and
14. Review of the Technical Requirements Manual and revision thereto.

17.2.1.1.3.1.1 The SORC shall:

1. Recommend in writing to the designated manager (see Section 17.2.1.6) approval or disapproval of items considered under items 1 through 5 above. prior to their implementation ; and
2. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Vice President & Chief Nuclear Officer, and the Operations Review Committee of disagreement between the SORC and the designated manager (see Section 17.2.1.6) however, the Plant Manager shall have responsibility for resolution of such disagreements pursuant to Technical Specification 5.1.1 .

The SORC shall maintain written minutes of each SORC meeting that, at a minimum , document the results of all SORC activities performed under the responsibility provisions above. Copies shall be provided to the Senior Vice President & Chief Nuclear Officer and the Operations Review Committee.

Any changes in the conduct of operation of the SORC will be made with the approval of the Plant Manager. Changes in the organization of the SORC will be made with the approval of the Plant Manager.

17.2.1.1.4 Director, Nuclear Oversight The Director, Nuclear Oversight reports directly to the Senior Vice President & Chief Nuclear Officer and is responsible for assuring effective implementation of the Quality Assurance Program. This reporting relationship assures that the Director, Nuclear Oversight has sufficient authority, organizational freedom , and independence from undue influence from, or responsibility for, costs and schedules such that the Director, Nuclear Oversight can effectively assure implementation of and compliance with the CPNPP operations quality assurance requirements and controls.

The Director, Nuclear Oversight communicates directly with the Nuclear Generation Group supervisory and management personnel and with appropriate management levels in consultant and contractor quality assurance organizations to identify quality problems; initiate, recommend or provide solutions; and to verify implementation of solutions to quality problems. The Director, Nuclear Oversight also has authority to "stop work" during the operations phase .

Specific duties and responsibilities of the Director, Nuclear Oversight include the following:

17.2-4 Amendment No. 109 to TXX-19076 Page 1 of 2 Description and Basis for Change - Biennial Reviews Description of Change:

Comanche Peak Nuclear Power Plant's (CPNPP) FSAR (Reference 1) is committed to NRC Regulatory Guide

{RG) 1.33, Revision 2, "Quality Assurance Program Requirements (Operation)" (Reference 2). Reference 2 endorses ANSI N18.7-1976 / ANS-3.2, "Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants" (Reference 3), which contains a requirement that safety related procedures be reviewed no less frequently that every two years.

In accordance with 10 CFR 50.54{a)(4)(ii) [previously 10 CFR 50.54{a)(3)(ii)], on May 31, 1984, CPNPP requested approval to replace the biennial review of safety related procedures with reliance on CPNPP programs and processes (Reference 4). The change was subsequently implemented in accordance with the provisions of 10 CFR 50.54{a)(4)(iv) [previously 10 CFR 50.54(a)(3)(iv)].

Reference 4 also indicated that biennial reviews would continue to be performed for non-routine procedures (Emergency Response guidelines {ERGs), Functional Restoration Guidelines (FRGs) and Abnormal Plant Operating Procedures (ABNs)) based on the requirements of 10 CFR 50.54(t) (emergency preparedness program procedures) and 10 CFR 50.54{p) (safeguards contingency plan procedures). The ERGs, FRGs, and ABNs are not implementing procedures for either (1) the emergency preparedness program nor (2) the safeguards contingency plan. Therefore, biennial reviews for ERGs, FRGs, and ABNs are not required in accordance with 10 CFR 50.54{p) and 10 CFR 50.54(t).

CPNPP requests approval to replace the biennial reviews of ERGs, FRGs, and ABNs with reliance on CPNPP programs and processes. Since this revision may be considered a reduction in the quality assurance commitment, NRC approval is required prior to implementation in accordance with 10 CFR 50.54(a)(4)(ii)

/ (a)(4)(iv). Attachment 1 to TXX-19076 provides a markup of affected FSAR pages. Attachment 4 to TXX-19076 provides the updated regulatory commitment 26823.

Reason for Change:

The intent of the biennial review is accomplished by CPNPP programmatic controls already in place. The following controls assure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, regulatory requirements, industry experience and other conditions that may impact plant procedures.

  • Site Modification Process
  • Corrective Action Program
  • Off-Normal Occurrence
  • User Feedback and Procedure Compliance
  • Operating Experience Review
  • Vendor Technical Information
  • Licensed Document Change/50.59 Evaluation
  • Commitment Tracking System (CTS)
  • Trending Activities
  • Infrequently Performed Evolutions Control
  • Requalification Training
  • Quality Assurance Activities to TXX-19076 Page 2 of 2 Basis for Conclusion that revised program incorporating this Change continues to satisfy the criteria of Appendix B of this part [i.e., 10 CFR SO] and the Safety Analysis Report quality assurance program:

Section 5.2.15, "Review, Approval and Control of Procedures," of Reference 2 prescribes a biennial review of safety related procedures "determine if changes are necessary or desirable."

When NRC RG 1.33 R2 (Reference 2) and ANSI N18.7-February 1976 ANS-3.2 (Reference 3) were developed in the 1970s the nuclear industry was relatively new. The original biennial procedure reviews were used to compensate for the lack of operational experience for a plant transitioning from construction to operation.

In addition to the programs and processes described above, over the last 25 years the nuclear industry and CPNPP have matured and include the following items:

  • New rule 10 CFR 50.155 Mitigation of Beyond Design Basis Events with associated training requirements Emergency Response Guidelines (ERGs), Functional Restoration Guidelines (FRGs), and Abnormal Plant Operating Procedures (ABNs) are essentially "routine" procedures based on the frequent licensed operator's requalification training within a two year cycle.

Replacement of the biennial procedure reviews for ERGs, FRGs, and ABNs with current programs/

process preserves compliance with the original intent of NRC RG 1.33 Rev 2 / ANSI N18.7-1976/ANS-3.2.

This change continues to satisfy the criteria of 10 CFR 50 appendix Band the Safety Analysis Report quality assurance program previously accepted by the NRC.

References:

1. CPNPP Final Safety Analysis Report (FSAR) Appendix lA(B), "Discussion of Regulatory Guides/

Regulatory Guide 1.33 Quality Assurance Program (Operation)"

2. NRC RG 1.33 Rev 2, Quality Assurance Program Requirements (Operation)
3. ANSI N18.7-February 1976 ANS-3.2 Administrative Controls and QA for Operational Phase of Nuclear Power Plants
4. TXX-94081, dated May 31, 1994, from W. Cahill to NRC regarding biennial procedure reviews (Accession Number 9406070169) to TXX-19076 Page 1 of 2 Description and Basis for Change - SORC Meeting Frequency Description of Change:

CPNPP FSAR Section 17.2.1.1.3.1, "Station Operations Review Committee (SORC)," (Reference 1.1) currently indicates a meeting frequency of "at least once per calendar month and as convened by the SORC Chairman or his designated alternate."

CPNPP requests approval to change SORC meeting frequency from "at least once per calendar month and as convened by the SORC Chairman or his designated alternate" to "periodically as determined by the SORC Chairman or his designated alternate." Since this revision may be considered a reduction in the quality assurance commitment, NRC approval is required prior to implementation in accordance with 10 CFR 50.54(a)(4)(ii) / (a)(4)(iv). Attachment 1 to TXX-19076 provides a markup of the affected FSAR pages.

Attachment 4 to TXX-19076 provides the updated regulatory commitment 03010.

As described below, CPNPP also believes that SORC meeting frequency is below the level of detail required by underlying requirement (i.e., NRC RG 1.33, R2), and will close commitment 03010 and no longer track SORC meeting frequency as a regulatory commitment.

Reason for Change:

A SORC meeting frequency of "at least monthly" is too prescriptive and results in unnecessary use of CPNPP's resources.

Basis for Conclusion that revised program incorporating this Change continues to satisfy the criteria of Appendix B of this part [i.e., 10 CFR 50] and the Safety Analysis Report quality assurance program:

Comanche Peak Nuclear Power Plant's (CPNPP) FSAR Appendix 1A(B) "Discussion of Regulatory Guides/

Regulatory Guide 1.33 Quality Assurance Program (Operation)" (Reference 1.2) is committed to NRC Regulatory Guide (RG) 1.33, Revision 2, "Quality Assurance Program Requirements (Operation)"

(Reference 2). Reference 2 endorses ANSI N18.7-1976 / ANS-3.2, "Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants" (Reference 3).

References 2 and 3 are silent with respect to meeting frequency of onsite review committees such as SORC.

The meeting frequency of "at least once per calendar month" was initially identified as part of a response to how proposed uses of radioactive material would be evaluated (Reference 4) (during the construction phase at CPNPP). The response included a "snapshot" of an FSAR description of the Station Operations Review Committee. The description stated in part "Meetings of the SORC will be held on a routinely scheduled basis at intervals of at least once per calendar month." The SORC meeting frequency was subsequently internally identified as regulatory commitment 03010.

A meeting frequency of periodically as determined by the SORC chairman or his designated alternate will continue to assure that nuclear safety issues are addressed. This change continues to satisfy the criteria of 10 CFR 50 appendix Band the Safety Analysis Report quality assurance program previously accepted by the NRC.

to TXX-19076 Page 2 of 2

References:

1. CPNPP Final Safety Analysis Report (FSAR) 11 1.1. Section 17.2.1.1.3.1, Station Operations Review Committee (SORC)"

11 1.2. Appendix lA(B) Discussion of Regulatory Guides/ Regulatory Guide 1.33 Quality Assurance Program (Operation)"

2. NRC RG 1.33 Rev 2, Quality Assurance Program Requirements (Operation)
3. ANSI Nl8.7-February 1976 ANS-3.2 Administrative Controls and QA for Operational Phase of Nuclear Power Plants
4. TXX-4097, dated January 17, 1984, from Texas Utilities Generating Company to the NRC regarding a response to a request for information related to the byproduct material license application (Docket 030-20267, Control No. 60099).
  • . . to TXX-19076 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to in this document by Vistra Operations Company LLC (Vistra OpCo) for Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 and Unit 2. Any other statements in this submittal are provided for informational purposes and are not considered to be regulatory commitments.

NUMBER COMMITMENT STATUS 26823 Current:

The intent of the biennial review is accomplished by CPNPP Incorporated programmatic controls already in place. The following controls assure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, regulatory requirements, industry experience and other conditions that may impact plant procedures.

In addition, biennial reviews are performed of non-routine procedures (Emergency Response guidelines (ERGs),

Functional Restoration Guidelines (FRGs) and Abnormal Plant Operating Procedures (ABNs)).

Revised:

The intent of the biennial review is accomplished by CPNPP To be incorporated upon receipt programmatic controls already in place. The following controls of NRC acceptance letter or 60 assure that procedures are appropriately reviewed and revised days after submittal ofTXX-19076 to incorporate information based on plant operations, design changes, regulatory requirements, industry experience and other conditions that may impact plant procedures.

03010 Current:

The SORC shall meet at least once per calendar month and as Incorporated convened by the SORC chairman or his designated alternate.

Revised:

The SORC shall meet periodically as determined by the SORC Upon receipt of NRC acceptance chairman or his designated alternate. letter or 60 days after submittal ofTXX-19076, this commitment will be closed and SORC meeting frequency will no longer be tracked as a regulatory commitment.

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