CP-202200454, (Cpnpp), Reply to a Notice of Violation Transmitted Via NRC Letter from Gregory Werner to Ken Peters Dated 11/01/2022, Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Inspection Report 05000445/2022003 .

(Cpnpp), Reply to a Notice of Violation Transmitted Via NRC Letter from Gregory Werner to Ken Peters Dated 11/01/2022, Comanche Peak Nuclear Power Plant, Units 1 and 2 Integrated Inspection Report 05000445/2022003 .

ML22335A518
Person / Time
Site:	Comanche Peak
Issue date:	12/01/2022
From:	Sewell S Luminant, Vistra Operating Co. (VistraOpCo)
To:	NRC Region 4, Document Control Desk
References
CP-202200454, TXX-22090, IR 2022003
Download: ML22335A518 (1)

Text

m Steven K. Sewell Senior Director, Engineering & Regulatory Affairs Comanche Peak Nuclear Power Plant (Vistra Operations Luminant Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose , TX 76043 T 254 .897.6113 CP-202200454 TXX-22090 December 1, 2022 U.S. Nuclear Regulatory Commission Ref 10CFR2.201 ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket No. 50-445 Reply To A Notice Of Violation

References:

1. NRC Letter from Gregory Werner to Ken Peters dated November 1, 2022, "Comanche Peak Nuclear Power Plant, Units 1 And 2 Integrated Inspection Report 05000445/2022003 And Notice Of Violation" (ADAMS Accession Number ML22299A056)

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 commitment regarding CPNPP Units 1 and 2:

Commitment No. Description 22-558339 A 10CFR50.59 evaluation will be performed and a license amendment will be submitted to address CPNPP' s commitments to NRC Regulatory Guide (RG) 1.81.

TXX-22090 Page 2 of 2 Should you have any questions, please contact Gary Merka at (254) 897-6613 or Gary.Merka@luminant.com.

Sincerely, Steven K. Sewell Attachment c (email) - Scott Morris, Region IV [Scott.Morris@nrc.gov]

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

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

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

Attachment to TXX-22090 Page 1 of 2 12/01/2022 NOTICE OF VIOLATION Vistra Operations Company, LLC Docket No. 50-445 Comanche Peak Nuclear Power Plant, Unit 1 License No. NPF-87 During an NRC inspection conducted from June 1 to September 30, 2022, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Title 10 of the Code of Federal Regulations (10 CFR) 50.59(c)(2) requires, in part, that a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important-to-safety previously evaluated in the final safety analysis report (as updated); or, create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated).

Contrary to the above, from February 13, 2019, to September 30, 2022, the licensee failed obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change that would: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important-to-safety previously evaluated in the final safety analysis report (as updated); or, create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated). Specifically, the licensee revised the Final Safety Analysis Report associated with the Unit 1 DC power system to change the facility's commitments to NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with General Design Criterion 5, without obtaining a license amendment.

This is a Severity Level IV violation (Enforcement Policy Section 6.1.d.4).

Attachment to TXX-22090 Page 2 of 2 12/01/2022 RESPONSE TO THE NOTICE OF VIOLATION Vistra OpCo agrees with the violation and the requested information follows:

1. Reason for the Violation This violation occurred because the Corrective Action Program documents that were addressing the violation (Condition Reports 2019-001711, 2019-004542, and 2019-006767) were all closed without performing a 10CFR50.59 evaluation or obtaining a license amendment. An action item was created in CR 2019-006767 to determine if a license amendment was required. However, this action item incorrectly concluded that a license amendment was not required and the Condition Report was subsequently closed.

2. Corrective Steps That Have Been Taken and the Results Achieved Sharing of common DC and UPS 118V AC power sources by Unit 1 specific loads was evaluated for conformance with GDC 5. The evaluation determined that XED1-1 and XED2-1 power source alignment to either Unit will provide an acceptable power source for Unit 1 components fed from the panels. However, the common DC panels are required to be normally aligned to Unit 1 power.

The evaluation determined that to preclude any adverse impact on Unit 1 safe shutdown capability, the UPS 118V AC power panels XEC1-1 & XEC2-1 are required to be aligned to a Unit 1 power source during Unit 1 Modes 1 thru 6 and only aligned to a Unit 2 power source when Unit 1 is in no Mode.

Sharing of common DC and UPS 118V AC power sources by Unit 1 specific loads, with the required lineup of the buses to a Unit 1 power source, does not significantly impair the ability of any structure, system, or component to perform their safety functions, including, in the event of an accident in one Unit, an orderly shutdown and cooldown of the other Unit. System Operating Procedures were revised to state that common DC distribution panels XED1-1 and XED2-1 should normally be aligned to Unit 1 power, and common UPS 118V AC panels XEC1-1 & XEC2-1 should be aligned to a Unit 1 power source during Unit 1 Modes 1 thru 6 and only aligned to a Unit 2 power source when Unit 1 is in no Mode.

3. Corrective Steps That Will Be Taken A 10CFR50.59 evaluation will be performed and a license amendment will be submitted to address CPNPPs commitments to NRC Regulatory Guide (RG) 1.81.

4. Date When Full Compliance Will be Achieved Vistra OpCo will be in full compliance by June 28, 2024.