ML17276B862

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Notification of NRC Design Bases Assurance Inspection (Programs)(05000445/2017007 and 05000446/2017007) and Initial Request for Information
ML17276B862
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/03/2017
From: Thomas Farnholtz
Region 4 Engineering Branch 1
To: Peters K
Vistra Operations Company
References
IR 2017007
Download: ML17276B862 (7)


See also: IR 05000445/2017007

Text

October 3, 2017

Mr. Ken J. Peters, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs

Vistra Operations Company LLC

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - NOTIFICATION OF NRC

DESIGN BASES ASSURANCE INSPECTION (PROGRAMS) (05000445/2017007

AND 05000446/2017007) AND INITIAL REQUEST FOR INFORMATION

Dear Mr. Peters:

On December 4, 2017, the NRC will begin an inspection at the Comanche Peak Nuclear

Power Plant. A three-person team will perform this inspection using NRC Inspection

Procedure 71111.21N, Design Bases Inspection (Programs), Attachment 1, Environmental

Qualification Under 10 CFR 50.49 Programs, Processes, and Procedures.

This inspection will evaluate the implementation of the environmental qualification of electrical

equipment program, as implemented by the Comanche Peak Nuclear Power Plant Operating

License. Additionally, the team will perform an inspection of the environmental qualification

documentation files to verify that electrical equipment important to safety meets the

requirements of 10 CFR 50.49. The team will select components that will be subjected to harsh

environments and are required to mitigate the consequences of a design basis accident.

The inspection will include an information gathering site visit by the team leader and two weeks

of on-site inspection by the team. The inspection team will consist of three NRC inspectors.

The current inspection schedule is as follows:

On-site Information Gathering Visit: November 6-8, 2017

Preparation Week: November 20, 2017

On-site Weeks: December 4-8, 2017, and December 11-15, 2017

The purpose of the information gathering visit is to meet with members of your staff to become

familiar with the Comanche Peak Nuclear Power Plant environmental qualification program.

The lead inspector will request a meeting with your personnel to discuss the site environmental

qualification program and procedures. Additionally, the lead inspector will request a discussion

with your staff to become familiar with the environmental qualification regulations and standards

to which the site is committed. Additional information and documentation needed to support the

inspection will be identified during the inspection, including interviews with engineering

managers and engineers.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

K. Peters

2

Our experience with these inspections has shown that they are 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. This information should be made available to the lead inspector by

November 1, 2017. Since the inspection will be concentrated on the environmental qualification

of the equipment, the equipment qualification master list should be available to review prior to

the information gathering visit to assist in our selection of components.

It is requested that this information be provided to the team leader as the information is

generated during the inspection. Additional requests by inspectors will be made during the

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 team leader for this inspection is Ronald A. Kopriva, Senior Reactor Inspector. We

understand that our licensing engineer contact for this inspection is Mr. Ken Vehstedt. If there

are any questions about the inspection or the requested materials, please contact the team

leader by telephone at 817-200-1104 or by e-mail at Ron.Kopriva@nrc.gov.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control

number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

K. Peters

3

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/

Thomas R. Farnholtz, Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 50-445 and 50-446

License Nos. NPF-87 and NPF-89

Enclosure:

Design Bases Inspection (Programs)

Environmental Qualification

Request for Information

cc: Electronic Distribution

Enclosure

Initial Request for Information

Design Bases Assurance Inspection (Programs), Environmental Qualification

Cooper Nuclear Station

Inspection Report: 05000445/2017007 and 05000446/2017007

Information Gathering Dates:

November 6-8, 2017

Inspection Dates:

December 4-8, 2017

December 11-15, 2017

Inspection Procedure:

IP 71111, Attachment 21N, Design Bases Assurance

Inspection (Programs)

Team Leader:

Ronald A. Kopriva, Senior Reactor Inspector

I.

Information Requested for Information Gathering Visit (November 6, 2017)

The following information should be provided to the lead inspector in hard copy or

electronic format (Certrec IMS preferred), to the attention of Ronald A. Kopriva, Senior

Reactor Inspector, by November 1, 2017, to facilitate the reduction in the items to be

selected for a final list of components. The inspection team will finalize the selected list

during the prep week using the documents requested in 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 boiling 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. List of components that are in equipment qualification master list. If the plant is

approved to categorize structures, systems, and component in accordance with

10 CFR 50.69, please provide the Risk Informed Safety Category of the component.

2. Listing of the equipment qualification master list components sorted by Birnbaum risk

importance.

3. List of all post-accident monitoring instrumentation components and locations.

4. Documents which show the environmental service conditions expected for areas in

which the environmentally qualified components are located.

5. Comanche Peak Nuclear Power Plant, word-searchable updated final safety analysis

report (UFSAR), license conditions, and technical specifications. Specifically identify

which UFSAR sections address environmental (including seismic) qualification.

2

6. NRC Safety Evaluation Report(s) associated with the Comanche Peak Nuclear

Power Plant environmental qualification program.

7. Identify the various environmental qualification standards (including year, edition, or

revision) that Comanche Peak Nuclear Power Plant is committed.

8. Identify whether Comanche Peak Nuclear Power Plant has entered its period of

extended operation (i.e., operation past the original 40-year license period).

9. Site (and corporate if applicable) procedures associated with the 10 CFR 50.49

environmental qualification program for electrical components. Additionally, please

provide similar procedures used to verify mechanical components meet their

10 CFR Part 50, Appendix A, Criterion 4, Environmental and Dynamic Effects

Design Bases. Include procedures for procurement of qualified equipment,

maintenance of qualified equipment, and modification to qualified equipment

(including equivalency or commercial grade dedication programs).

10. Site high energy line break analyses, including associated plant area drawings.

11. Procedures for material storage and shelf life controls.

12. List of commercial grade dedication evaluations performed, for which the dedicated

parts have been issued for installation on environmental qualification applications in

the plant, for the previous 5 years. Include description of the component the part

was issued to repair, work order, and date issued or installed.

13. List of condition reports related to the environmental qualification program or

environmental qualification of components (both electrical and mechanical) for the

previous 5 years.

14. Lists of modifications, repairs, or replacement of equipment qualification master list

components completed for the previous 5 years.

15. List of modifications, repairs, or replacements of containment penetrations for the

previous 5 years.

16. List of components removed from the environmental qualification program since

beginning of operation.

17. Any self-assessments and quality assurance assessments of the environmental

qualification program performed in the previous 5 years.

18. List of systems, system numbers/designators, and corresponding names.

II.

Discussions Requested during Information Gathering Visit

1. Interview with representative to discuss site environmental qualification service

condition analyses for plant areas, including plant drawings and assumptions. This

includes analysis for areas that are subject to high energy line breaks (HELB).

3

2. Interview with representative to discuss environmental qualification mandated

maintenance elements integrated into plant programs and procedures.

3. Interview with representative to discuss maintaining qualification for plant/equipment

that has entered its period of extended operation, if applicable.

III.

Information Requested for Inspection Preparation (November 17, 2017)

1. Equipment qualification documentation files, including test reports, for the electrical

components selected by the team leader listed from the equipment qualification

master list.

2. References associated with the electrical components equipment qualification

document files.

3. Vendor manuals and technical sheets associated with the selected electrical

components.

4. Tours of the rooms in which the selected electrical components are installed.

5. Tour of stored selected electrical components in the warehouse.

Inspector Contact Information:

Ronald A. Kopriva

Senior Reactor Inspector

817-200-1104

Ron.Kopriva@nrc.gov

Jonathan Braisted

Reactor Inspector

817-200-1194

Johathan.Braisted@nrc.gov

Chad Stott

Reactor Inspector

817-200-1526

Chad.Stott@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Ronald A. Kopriva

1600 East Lamar Blvd.

Arlington, TX 76011-4511

ML17276B862

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By: TFarnholtz

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

RI:EB1

C:EB1

NAME

RKopriva

TFarnholtz

SIGNATURE

/RA/

/RA/

DATE

9/22/17

10/3/17