CP-202000024, Response to NRC Request for Additional Information on Biennial Review of Procedures and Station Operations Review Committee Meetings

Response to NRC Request for Additional Information on Biennial Review of Procedures and Station Operations Review Committee Meetings

ML20016A318
Person / Time
Site:	Comanche Peak
Issue date:	01/14/2020
From:	Thomas McCool Luminant, TXU Energy, Vistra Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202000024, TXX-20004
Download: ML20016A318 (5)

Text

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Lumlffl:!nt Thomas P. McCool Site Vice President Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897 .6042 CP-202000024 TXX-20004 U. S. Nuclear Regulatory Commission Ref 10 CFR 50.54(a)(4)

ATTN: Document Control Desk Washington, DC 20555-0001 1/14/2020

SUBJECT:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Biennial Review of Procedures and Station Operations Review Committee Meetings Response to NRC Request for Additional Information

REFERENCES:

1. Letter TXX-19076 from Thomas P. McCool to the NRC, "Biennial Review of Procedures and Station Operations Review Committee Meetings," dated August 14, 2019 (ADAMS No. ML19228A086)

2. NRC Email from Dennis Galvin to Jack Hicks ."Comanche Peak RAls - Quality Assurance Program Reduction in Commitment (EPID L 2019-LLQ-0002)," dated December 11, 2019 In accordance with the requirements of 10 CFR 50.54(a)(4)(ii), Vistra Operations Company LLC (Vistra OpCo) requested approval iri Reference 1 to (1) eliminate the biennial reviews of Emergency Response Guidelines (ERGs), Functional Restoration Guidelines (FRGs), and Abnormal Plant Operating (ABNs) procedures and (2) to change the Station Operations Review Committee (SORC) meeting frequency, which are part of the previously accepted CPNPP quality assurance program as described In the Final Safety Analysis Report (FSAR). provides a response to an NRC Request for Additional Information (Reference 2). provides a 11st of updated regulatory commitments previously described in Attachment 4 of Reference 1.

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

TXX-20004 Page 2 of 2 Should you have any questions, please contact Carl B. Corbin at (254) 897-0121 or carl.corbln@lummant.com.

In accordance with 10 CFR 50.54(a)(4}(1v}, CPNPP plans to Implement these changes following receipt of an NRC letter indicating acceptance.

Sincerely, Th:dfol CPNPP Response to NRC Request for Additional Information List of Regulatory Commitments c- Scott A. Morris, Region IV Dennis Galvin, NRR Resident Inspectors, Comanche Peak to TXX-20004 CPNPP Response to NRC Request for Additional Information Page 1 of 2 NRC Question 1.

Crrterion V, Nlnstructwns, Procedures, and Drawings, N of Appendix 8 to 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,N states that NActlvlties affecting qua/Jty shall be prescnbed by documented instructions, procedures, or drawings, of a type appropnate to the circumstances and shall be accomplished In accordance with these Instructions, procedures, or drawings. Instructions, procedures, or drawings shall Include appropriate quantitative or qualitative acceptance criteria for determining that Important act1v1t1es have been satisfactorily accomplished. N Section 5.2 15, NRev1ew, Approval, and Control of Procedures, Hof ANSI N18.7-1976/ANS-3.2, states, ,n part, that "Plant procedures shall be reviewed by an individual knowledgeable ,n the area affected by the procedure and no less frequently than every two years to determine if changes are necessary or desirable."

Comanche Peak's proposed change to the FSAR to eliminate the biennial reviews of Emergency Response Guide/mes (ERGs), Functional Restoration Guidelines (FRGs), and Abnormal Plant Operating (ABNs) procedures and rely on Com_anche Peak's programmatic controls already in place represents a reduction in commitment from the previously accepted Comanche Peak QA program. It is unclear how Comanche Peak's current programmatic controls would ensure that ERGs, FRGs, and ABNs will be reviewed to determine if changes are necessary. Usage of these procedures is dictated by an event and their review is Important to determine the adequacy of current procedures and how the licensee would respond In case of an event. In addition, the NRC staff notes Comanche Peak did not identify a precedent for the proposed change.

The NRC staff requests Comanche Peak to provide additional clarifying Information to show how this proposed change will ensure the review of the ERGs, FRGs, and ABNs continue to satisfy Criterion Vof Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the NRC.

CPNPP Response to NRC Question 1:

The intent of the biennial reviews is accomplished by other Comanche Peak Nuclear Power Plant processes and programs, including initial license operator training and License Operator Requa1Jf1cation Training, 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.

All aspects of the ERGs, FRGs, and ABNs are reviewed as part of (1) the initial license operator training program (typically on a two year cycle) and {2) the License Operator Requal1ficatlon Training program (on a two-year cycle).

Both programs assure these procedures are reviewed by an individual knowledgeable 1n the area affected by the procedure and no less frequently than every two years to determine If changes are necessary or desirable. -

to TXX-20004 CPNPP Response to NRC Request for Additional Information Page 2 of 2 NRC Question 2.

Sub-section 4.3.2.2, NMeeting Frequency,"' of section 4.3.2, "Standing Committees Functioning as Independent Review Bodies,"' of ANSI N18. 7-1976/ANS-3.2 states, In part, that HOuring the period of /nit/al operation such meetings should be held no frequently than once per-cale-ndar quarter. Subsequently, the meeting frequency shall not be less than twice a year."

Comanche Peak's additional proposed change regarding the meeting frequency of the Station Operations Review Committee's (SORC) from Nonce 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, H represents a reduction in commitment from the previously accepted Comanche Peak's QA program. It is unclear how this change would ensure that the SORC meetings would be convened with sufficient frequency to ensure that It 1s able to adequately fulfill its safety responsibilities as listed in the FSAR. In addition, the NRC staff notes Comanche Peak did not Identify a precedent for the proposed change.

The NRC staff requests Comanche Peak to provide additional clanfying information to show how this proposed change wf/1 ensure that SORC meetings wlll continue to be convened at an acceptable frequency and therefore continue to satisfy the criteria of Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the NRC. .

CPNPP Response to NRC Question 2:

CPNPP has an "Operations Review Committee" (ORC) currently functioning as the independent review body. The ORC manual specifies a meeting frequency "The ORC shall meet not less than twice per year" which is consistent with ANSI N18.7-1976/ANS-3.2.

The Station Operations Review Committee (SOR() is not the independent review body within the context of Section 4.3.2.2 of ANSI N18.7-1976/ANS-3.2. SORC 1s comprised of in-line organizations from CPNPP.

The meeting frequency of SORC 1s administrative detail below that required in the QA program.

to TXX-20004 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 STAlUS 26823 Current:

The intent ofthe 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 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.

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, this commitment will be closed and-SORC meeting frequency will no longer be tracked as a regulatory commitment.