ML11192A046

Response to Comanche Peak Letter Requesting Reconsideration of Cross-Cutting Aspect Associated with Non-Cited Violation 05000445/2011007-02; 00500446/2011007 02

ML11192A046
Person / Time
Site:	Comanche Peak
Issue date:	07/08/2011
From:	O'Keefe N NRC/RGN-IV/DRS/EB-2
To:	Flores R Luminant Generation Co
References
IR-11-007
Download: ML11192A046 (3)

See also: IR 05000445/2011007

Text

UNITED STATES

NUC LE AR RE G ULATO RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

July 8, 2011

Rafael Flores, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs

Luminant Generation Company LLC

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: RESPONSE TO COMANCHE PEAK LETTER REQUESTING

RECONSIDERATION OF CROSS-CUTTING ASPECT ASSOCIATED WITH

NON-CITED VIOLATION 05000445/2011007-02; 00500446/2011007-02

Dear Mr. Flores,

Your letter CP-201100851/TXX-11078 dated June 16, 2011, discussed noncited violation 05000445/2011007-02; 00500446/2011007-02. While you agree to modify the plants to

address the safety issue described in the violation, you requested that we review the cross-

cutting aspect that was documented with this finding. This letter responds to your request.

Noncited violation 05000445/2011007-02; 00500446/2011007-02 was issued for a failure to

implement and maintain in effect all provisions of the approved fire protection program.

Specifically, you failed to recognize that electrical cables for the pressurizer power-operated

relief valves and associated block valves were installed in many of the same cable trays, leaving

the plant susceptible to fire damage that could spuriously open the power-operated relief valve

and prevent the ability to shut the block valve. Your fire safe shutdown strategies at the time of

the inspection did not provide effective mitigation for this situation; however, you implemented

prompt compensatory measures in response to this finding.

A cross-cutting aspect of P.1.a was assigned in the area of problem identification and resolution

associated with the corrective action component (P.1.a). The inspection report stated that the

expert panel reviewing potential spurious operation scenarios for applicability to Comanche

Peak Units 1 and 2 did not identify the technical issue documented in the finding completely,

accurately, and in a timely manner when the specific scenario was reviewed.

Your letter and a telephone conference with Mr. F. Madden and Mr. J. Hicks conducted on

July 6, 2011, provided additional information related to the causal factors associated with the

performance deficiency. In particular, your letter and your staff explained that the expert panel

was given written guidance that the scope of their reviews did not need to address high-to-low

pressure interface valves because NRC Supplemental Safety Evaluation Report 12 had

accepted your conclusions that opening associated circuit breakers would prevent the spurious

operation of these valves.

Luminant Generation Company LLC -2-

Our inspection identified that opening breakers in this manner would not prevent spurious

operation of the power-operated relief valves in certain cases. However, this situation was

identified after the expert panel had completed their review. While it appears that the guidance

provided to your expert panel in this instance was not in keeping with the guidance provided in

NEI 00-01, Section 4.4, to systematically and completely review all spurious and multiple

spurious operation scenarios, we also recognize that this review was a voluntary effort.

Based on the information that you have provided, we have concluded that the expert panel was

given guidance that precluded them from identifying the plant susceptibility described in the

violation. Therefore, cross-cutting aspect P.1.a does not apply. We further reviewed the issue

and concluded that no other cross-cutting aspect applies to this finding. Accordingly, the finding

will be revised in the plant issues matrix to remove the cross-cutting aspect, and this will be

documented in the next quarterly inspection report.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of the

NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Neil OKeefe, Chief

Engineering Branch 2

Division of Reactor Safety

Dockets: 50-445; 50-446

Licenses: NPF-87; NPF-89

Distribution by ListServ for Comanche Peak

Luminant Generation Company LLC -3-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

Acting DRS Deputy Director (Robert.Caldwell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director Jeff.Clark@nrc.gov

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

Resident Inspector (Brian.Tindell@nrc.gov)

Senior Project Engineer (David. Proulx@nrc.gov)

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

CP Site Secretary (Sue.Sanner@nrc.gov)

Branch Chief, DRS/TSB (Dale.Powers@nrc.gov)

OEDO RIV Coordinador (John.McHale@nrc.gov)

R:\_REACTORS\CP Crosscutting Aspect ltr-NFO ADAMS ML

ADAMS: No  ; Yes ;NFOSUNSI Review Complete Reviewer Initials: NFO

Publicly Available  ; Non-Sensitive

Category Non-publicly Available Sensitive

KEYWORD:

EB 2 C:EB2

S. Graves N. O'Keefe

/RA/ /RA/

7/8 /2011 7/8 /2011

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax