CP-202100256, Reply to a Notice of Violation

Reply to a Notice of Violation

ML21154A186
Person / Time
Site:	Comanche Peak
Issue date:	06/03/2021
From:	Thomas McCool Luminant
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
CP-202100256, IR 2021011, TXX-21084
Download: ML21154A186 (5)

Text

II Luminant CP-202100256 TXX-21084 June 3, 2021 Thomas P. McCool Site Vice President Comanche Peak Nuclear Power Plant (Vlstra Operations CompanyLLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254.897.6042 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Ref 10CFR2.201

References:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Reply To A Notice Of Violation

1. NRC Letter from Vincent Gaddy to Ken Peters dated May 6, 2021, "Comanche Peak Nuclear Power Plant, Units 1 And 2-Design Basis Assurance Inspection (Teams)

Inspection Report 05000445/2021011 And 05000446/2021011 And Notice Of Violation" (ADAMS Accession Number ML21l?4A130)

Dear Sir or Madam:

Pursuant to 10CFR2.201, Vistra Operations Company LLC (Vistra OpCo) hereby responds to the Notice of Violation that was transmitted via Reference 1. This communication contains the following new licensing basis commitment regarding CPNPP Units 1 and 2:

Commitment No.

21-344702 Description In accordance with the CPNPP Corrective Action Program, non-1E loads on UPS panels will be reviewed by December 3, 2021, to determine if a basis can be provided that would assure the non-1E load circuit's integrity to withstand a DBE without a short or short to ground, and can remain to be fed from the panel and coordination of these circuits will not be a concern. If this review concludes that a basis cannot be provided, then a plant modification will be implemented by June 1, 2023.

TXX-21084 Page 2 of2 Should you have any questions, please contact Gary Merka at (254) 897-6613 or gary.merka@luminant.com.

Attachment c (email) -

Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

Thomas P. McCool John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

R4Enforcement@nrc.gov

Attachment to TXX-21084 Page 1 of 3 06/03/2021 NOTICE OF VIOLATION During an NRC inspection conducted from February 2, 2021 through March 25, 2021, two violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below:

A.

Title 10 CFR Part 50, Appendix B, Criterion III, requires, in part, that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from June 20, 2013, to March 25, 2021, the licensee did not assure that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the 125 VDC calculation did not account for the maximum inrush currents and actual accident loading, and the 120 V AC calculation did not properly account for low voltage when the buses are supplied from their alternate source.

This violation is associated with a Green SDP finding.

B.

Title 10 CFR Part 50, Appendix B, Criterion III requires in part, that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from June 18, 2015, to March 25, 2021, the licensee did not assure that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to verify or check the adequacy of the design by performing an analysis or test that demonstrated that the Class lE inverters would continue to operate reliably when subjected to the effects of electrical fau!ts that could be postulated to occur at non-Class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss-of-offsite power and seismic event.

This violation is associated with a Green SDP finding.

Attachment to TXX-21084 Page 2 of3 06/03/2021 RESPONSE TO NOTICE OF VIOLATION" A" Vistra OpCo agrees with the violation and the requested information follows:

1.

Reason for the Violation During the 2013 NRC Component Design Basis inspection at CPNPP, the inspectors identified that calculations did not take into account the maximum inrush currents and actual accident loading, and also did not properly account for low voltage when the buses were supplied from their alternate source. Condition Reports (CRs) 2013-006273, 2013-006396, and 2013-008394 were issued to address this Finding. CRs 2013-006273 and 2013-006396 were subsequently closed in April 2016, and some of the actions L'l CR 2013-008394 were also completed in 2016.

This violation occurred because CR 2013-008394 was not given a high enough priority for it to be completed in a timely manner.

2.

Corrective Steps That Have Been Taken and the Results Achieved An extent of condition review was completed. Calculations have been revised to account for the maximum inrush currents and actual accident loading. Calculations have also been revised to properly account for low voltage when the buses are supplied from their alternate source. A review of the 120 V AC system was completed to assess the adequacy of UPS bus voltages when they are supplied from the bypass source. The review shows that the bypass source will provide adequate voltage for loads fed from UPS buses.

3.

Corrective Steps That Will Be Taken The timeliness of addressing NRC violations is being addressed in the CPNPP corrective action program.

4.

Date When Full Compliance Will be Achieved Vistra OpCo is currently in full compliance.

Attachment to TXX-21084 Page 3 of3 06/03/2021 RESPONSE TO NOTICE OF VIOLATION "B" Vistra OpCo agrees with the violation and the requested information follows:

1.

Reason for the Violation During the 2015 NRC Component Design Basis inspection at CPNPP, the inspectors identified that CPNPP failed to verify or check the adequacy of the design by performing an analysis or test that demonstrated the Class 1E inverters would continue to operate reliably when subjected to the effects of electrical faults that could be postulated to occur at non-class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss of offsite power and seismic event. Condition Report (CR) 2015-005530 was issued to address this Finding. This violation occurred because CR 2015-005530 was not given a high enough priority for it to be completed in a timely manner.

2.

Corrective Steps That Have Been Taken and the Results Achieved An extent of condition review was completed. The affected UPS system panels with non-class 1E loads have been identified.

3.

Corrective Steps That Will Be Taken In accordance with the CPNPP Corrective Action Program, non-lE loads on UPS panels will be reviewed by December 3, 2021, to determine if a basis can be provided that would assure the non-lE load circuit's integrity to withstand a Design Basis Event without a short or short to ground, and can remain to be fed from the panel and coordination of these circuits will not be a concern. If this review concludes that a basis cannot be provided, then a plant modification will be implemented by June 1, 2023. The timeliness of addressing NRC violations is being addressed in the CPNPP corrective action program.

4.

Date When Full Compliance Will be Achieved Vistra OpCo will be in full compliance by June 1, 2023.