IR 05000445/2015007

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IR 05000445/2015007 and 05000446/2015007), June 1, 2015 Through August 3, 2015, Comanche Peak, Units 1 and 2, NRC Component Design Bases
ML15245A507
Person / Time
Site: Comanche Peak  
Issue date: 09/02/2015
From: Thomas Farnholtz
Region 4 Engineering Branch 1
To: Flores R
Luminant Generation Co
R. Kopriva
References
IR 2015007
Download: ML15245A507 (54)


Text

September 2, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC COMPONENT DESIGN BASES INSPECTION (05000445/2015007 AND 05000446/2015007)

Dear Mr. Flores:

July 2, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, -

NOTIFICATION OF NRC COMPONENT DESIGN BASES INSPECTION (05000445/2015007 AND 05000446/2015007) AND INITIAL REQUEST FOR INFORMATION

Dear Mr. Flores:

On June 1, 2015, the NRC will begin a triennial baseline Component Design Bases Inspection at the Comanche Peak Nuclear Power Plant. A six-person team will perform this inspection using NRC Inspection Procedure 71111.21, Component Design Bases Inspection.

The inspection focuses on components and operator actions that have high risk and low design margins. The samples reviewed during this inspection will be identified during an information gathering visit and during the subsequent in-office preparation week. In addition, a number of operating experience issues will also be selected for review.

The inspection will include an information gathering site visit by the team leader and a senior reactor analyst, and three weeks of on-site inspection by the team. The inspection will consist of four NRC inspectors and two contractors, of which five will focus on engineering and one on operations. The current inspection schedule is as follows:

On-site Information Gathering Visit: May 11 -14, 2015 Preparation Week(s): May 18, 2015; June 8, 2015; and June 22, 2015 On-site Week(s): June 1, 2015; June 15, 2015; and June 29, 2015

The purpose of the information gathering visit is to meet with members of your staff to identify potential risk-significant components and operator actions. The lead inspector will also request a tour of the plant with members of your operations staff and probabilistic safety assessment staff. During the on-site weeks, several days of time will be needed on the plant-referenced simulator in order to facilitate the development of operator action-based scenarios. Additional information and documentation needed to support the inspection will be identified during the inspection, including interviews with engineering managers, engineers, and probabilistic safety assessment staff.

Our experience with these inspections has shown that they are extremely resource intensive, both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact on the site and to ensure a productive inspection, we have enclosed a request for information needed for the inspection. The request has been divided into three groups. The first group lists A2-2

information necessary for the information gathering visit and for general preparation. This information should be available to the regional office no later than May 4, 2015. Insofar as possible, this information should be provided electronically to the lead inspector. Since the inspection will be concentrated on high risk/low margin components, calculations associated with your list of high risk components should be available to review during the information gathering visit to assist in our selection of components based on available design margin.

The second group of documents requested is those items that the team will need access to during the preparation week in order to finalize the samples to be inspected. The third group lists information necessary to aid the inspection team in tracking issues identified as a result of the inspection. It is requested that this information be provided to the lead inspector as the information is generated during the inspection. Additional requests by inspectors will be made throughout all three on-site weeks for specific documents needed to complete the review of that component/selection. It is important that all of these documents are up to date and complete in order to minimize the number of additional documents requested during the preparation and/or the on-site portions of the inspection. In order to facilitate the inspection, we request that a contact individual be assigned to each inspector to ensure information requests, questions, and concerns are addressed in a timely manner.

The lead inspector for this inspection is Ronald A. Kopriva. We understand that our licensing engineer contact for this inspection is Gary Merka. If there are any questions about the inspection or the requested materials, please contact the lead inspector by telephone at 817-200-1104 or by e-mail at Ron.Kopriva@nrc.gov.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric A. Ruesch, Acting Chief Engineering Branch 1 Division of Reactor Safety

Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

Component Design Bases Inspection Request for Information

cc: Electronic Distribution for Comanche Peak Nuclear Power Plant

ML15089A554 SUNSI Review By: RKopriva ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive Keyword:

OFFICE SRI:EB1 ABC:EB1

NAME RKopriva/dch ERuesch

SIGNATURE

/RA/

/RA/

DATE 3/25/15 3/30/15

A2-4 Letter to Rafael Flores from Eric A. Ruesch, dated March 30, 2015

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, -

NOTIFICATION OF NRC COMPONENT DESIGN BASES INSPECTION (05000445/2015007 AND 05000446/2015007) AND INITIAL REQUEST FOR INFORMATION

Electronic distribution by RIV:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

Acting DRP Deputy Director (Thomas.Farnholtz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (John.Kramer@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Rayomand.Kumana@nrc.gov)

Administrative Assistant (Rhonda.Smith@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Project Engineer, DRP/A (Thomas.Sullivan@nrc.gov)

Project Engineer, DRP/A (Margaret.Tobin@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Michael.Waters@nrc.gov)

A3-1 Attachment 3 Initial Request for Information Component Design Bases Inspection Comanche Peak Nuclear Power Plant

Inspection Report:

05000445/2015007, 05000446/2015007

Information Gathering Dates:

May 11 - 14, 2015

Inspection Dates:

June 1, 2015; June 15, 2015; and June 29, 2015

Inspection Procedure:

IP 71111.21, Component Design Bases Inspection

Lead Inspector:

Ron Kopriva, Senior Reactor Inspector

I.

Information Requested Prior to Information Gathering Visit (May 11, 2015)

The following information (Section I of this enclosure) should be sent to the Region IV office in hard copy or electronic format (Certrec IMS preferred), to the attention of Ronald Kopriva by May 4, 2015, to facilitate the reduction in the items to be selected.

The team leader will provide the licensee the selected components for Section II by May 12, 2015. The inspection team will finalize the selected list during the week of May 18, 2015 using the additional documents requested in Section II of this enclosure.

The specific items selected from the lists shall be available and ready for review on the day indicated in this request. *Please provide requested documentation electronically in pdf files, Excel, or other searchable formats, if possible. The information should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use.

Information in "lists" should contain enough information to be easily understood by someone who has knowledge of pressurized water reactor technology. If requested documents are large and only hard copy formats are available, please inform the inspector(s), and provide subject documentation during the first day of the on-site inspection.

1. An excel spreadsheet of equipment basic events (with definitions) including importance measures sorted by risk achievement worth (RAW) and Fussell-Vesely (FV) from your internal events probabilistic risk assessment (PRA).

Include basic events with RAW value of 1.3 or greater.

2. Provide a list of the top 500 cut-sets from your PRA.

3. Copies of PRA "system notebooks," and the latest PRA summary document.

4. An excel spreadsheet of PRA human action basic events or risk ranking of operator actions from your site specific PSA sorted by RAW and FV. Provide copies of your human reliability worksheets for these items.

5. List of procedures used to accomplish operator actions associated with the basic event in your PRA.

A3-2 6. A list of all time-critical operator actions in procedures.

7. If you have an external events or fire PSA model, provide the information requested in items 1-4 for external events and fire.

8. Any pre-existing evaluation or list of components and associated calculations with low design margins (i.e., pumps closest to the design limit for flow or pressure, diesel generator close to design required output, heat exchangers close to rated design heat removal, etc.).

9. List of high risk maintenance rule systems/components and functions; based on engineering or expert panel judgment.

10. Structures, systems, and components in the Maintenance Rule (a)(1) category.

11. Site top 10 issues list.

12. A list of operating experience evaluations for the last 2 years.

13. A list of permanent and temporary modifications for the previous 3 years.

14. List of current "operator workarounds/burdens."

15. List of root cause evaluations associated with component failures or design issues initiated/completed in the last 3 years.

16. List of any common-cause failures of components in the last 3 years.

17. Electrical one-line drawings for:

  • Offsite power/switchyard supplies

Normal AC power systems

Emergency AC/DC power systems including

120VAC power

125VDC/24VDC safety class systems

18. A copy of any self-assessments and associated corrective action documents generated in preparation for the inspection.

19. A copy of engineering/operations-related audits completed in the last 2 years.

20. Current management and engineering organizational charts.

21. List of licensee contacts for the inspection team with phone numbers.

II.

Information Requested to be Available on First Day of Preparation Week (May 18, 2015)

A3-3 1. An electronic copy of the Design Bases Documents for the selected components.

2. An electronic copy of the System Health notebooks for the selected components.

3. List of condition reports (corrective action documents) associated with each of the selected components for the last 5 years.

4. The corrective maintenance history associated with each of the selected components for the last 3 years.

5. Copies of calculations associated with each of the selected components (if not previously provided), excluding data files. Please review the calculations and also provide copies of reference material (such as drawings, engineering requests, and vendor letters).

6. Copies of operability evaluations associated with each of the selected components and plans for restoring operability, if applicable.

7. Copies of selected operator workaround evaluations associated with each of the selected components and plans for resolution, if applicable.

8. Copies of any open temporary modifications associated with each of the selected components, if applicable.

9. Trend data on the selected electrical/mechanical components performance for last 3 years (for example, pumps performance including in-service testing, other vibration monitoring, oil sample results, etc., as applicable).

10. List of motor-operated valves (MOVs) in the program, design margin and risk ranking.

11. List of air operated valves (AOVs) in the valve program, design and risk ranking.

III.

Information Requested to be provided throughout the inspection

1. Copies of any corrective action documents generated as a result of the teams questions or queries during this inspection.

2. Copies of the list of questions submitted by the team members and the status/resolution of the information requested (provide daily during the inspection to each team member).

3. Reference materials (available electronically and as needed during all on-site weeks):

  • General set of plant drawings

IPE/PRA report

Procurement documents for components selected

A3-4

Plant procedures (normal, abnormal, emergency, surveillance, etc.)

  • Technical Specifications

Updated Final Safety Analysis Report

Vendor manuals

Inspector Contact Information:

Ronald A. Kopriva

Senior Reactor Inspector

817-200-1104

Ron.Kopriva@nrc.gov

Mailing Address:

U.S. NRC, Region IV Attn: Ron Kopriva 1600 East Lamar Blvd.

Arlington, TX 76011-4511

ML15245A507 SUNSI Review By: RAK ADAMS:

Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE SRI/EB1/RIV:

RI/EB1/RIV:

RI/EB1/RIV:

SRTI/TTC:

C:EB1 NAME RKopriva/tk CSmith JWatkins APalmer TFarnholtz SIGNATURE

/RA/

/RA/

/RA/

/RA/email

/RA/

DATE 8/31/15 8/6/15 8/7/15 8/13/15 9/2/15

Letter to Rafael Flores from Thomas Farnholtz, dated September 2, 2015

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC COMPONENT DESIGN BASES INSPECTION (05000445/2015007 AND 05000446/2015007)

Distribution Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Jeffrey.Josey@nrc.gov)

Resident Inspector (Rayomand.Kumana@nrc.gov)

Administrative Assistant (Rhonda.Smith@nrc.gov)

Acting Branch Chief, DRP/A (Thomas.Hipschman@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Project Engineer, DRP/A (Thomas.Sullivan@nrc.gov)

Project Engineer, DRP/A (Mathew.Kirk@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Acting Team Leader, DRS/TSS (Eric.Ruesch@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)