ML18121A311
| ML18121A311 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/30/2018 |
| From: | Thomas Farnholtz Region 4 Engineering Branch 1 |
| To: | Peters K Vistra Operations Company |
| Farnholtz T | |
| References | |
| IR 2018010 | |
| Download: ML18121A311 (7) | |
See also: IR 05000445/2018010
Text
April 30, 2018
Ken J. Peters, Senior Vice President
and Chief Nuclear Officer
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 (TEAMS) (05000445/2018010 and
05000446/2018010) AND INITIAL REQUEST FOR INFORMATION
Dear Mr. Peters:
On June 5, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial baseline
design bases assurance inspection at the Comanche Peak Nuclear Power Plant, Units 1 and 2.
A six-person team will perform this inspection using NRC Inspection Procedure 71111,
Attachment 21M, Design Bases Assurance Inspection (Teams).
The inspection focuses on the maintenance of component design bases and modifications
made to structures, systems, and components. 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 2 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: June 5 - 6, 2018
Preparation Weeks: June 18 - 22, 2018, and July 2 - 6, 2018
On-site Weeks: June 25 - 29, 2018, and July 9 - 13, 2018
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 and administration 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.
K. Peters
2
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 two groups. The first group lists
information necessary for the information gathering visit and for general preparation. This
information should be available to the Regional office no later than June 5, 2018, unless
otherwise stated. If possible, this information should be provided electronically to the lead
inspector. Since the inspection will be concentrated on high risk/low margin components and
modifications, calculations associated with your list of high risk components and modifications
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 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. An additional request will be made by the team during the preparation week once
the specific components and modifications have been selected. Additional requests by
inspectors will also be made throughout the on-site weeks for specific documents needed to
complete the review. 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
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 Jonathan Braisted. 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
817-200-1194 or by e-mail at Jonathan.Braisted@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.
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
K. Peters
3
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 Assurance
Inspection (Teams) Initial Request for Information
Enclosure
Initial Request for Information
Design Bases Assurance Inspection (Teams)
Comanche Peak Nuclear Power Plant
Inspection Report: 05000445/2018010,
EPID ID:
I-2018-010-0042
Information Gathering Dates:
June 5 - 6, 2018
Inspection Dates:
June 25 - 29, 2018
July 9 - 13, 2018
Inspection Procedure:
IP 71111, Attachment 21M, Design Bases Assurance
Inspection (Teams)
Lead Inspector:
Jonathan Braisted, Reactor Inspector
I.
Information Requested Prior to Information Gathering Visit.
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
Jonathan Braisted by June 5, 2018, to facilitate the reduction in the items to be selected
for a final list during the preparation week June 18, 2018. The inspection team will
finalize the selected list during the prep week 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 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 and Fussell-Vesely from
your internal events probabilistic risk assessment. Include basic events with risk
achievement worth value of 1.3 or greater.
2. A list of the top 50 cut-sets from your probabilistic risk assessment.
3. Copies of probabilistic risk assessment system notebooks and the latest
probabilistic risk assessment summary document.
4. An Excel spreadsheet of probabilistic risk assessment human action basic events or
risk ranking of operator actions from your site-specific PSA sorted by risk
achievement worth and Fussell-Vesely. Provide copies of your human reliability
worksheets for these items.
2
5. If you have an external events or fire PSA model, provide the information requested
in items 1-4 for external events and fire.
6. A list of high large early release frequency impact events and associated
components.
7. Structures, systems, and components in the Maintenance Rule (a)(1) category.
8. A list of high risk maintenance rule systems/components and functions; based on
engineering or expert panel judgment.
9. Site top 10 issues list, if available.
10. Any pre-existing list of components and associated calculations with low design
margins.
11. A list of operating experience evaluations for the last 3 years.
12. A list of all time-critical operator actions in procedures.
13. A list of current operator work arounds/burdens.
14. Procedures, including emergency and abnormal, used to accomplish operator
actions associated with the basic events credited in your probabilistic risk
assessment.
15. Lists of permanent and temporary modifications performed in the past 5 years to
structures, systems, and components sorted by component identified in Item 1.
16. List of root cause evaluations associated with component failures or design issues
initiated/completed in the last 5 years.
17. A list of any common-cause failures of components in the last 3 years.
18. A copy of any internal/external self-assessments and associated corrective action
documents generated in preparation for this inspection.
19. A copy of engineering/operations-related audits completed in the last 2 years.
20. Electronic copies of the Technical Specifications, Technical Specifications Bases,
and the Final Safety Analysis Report, as updated.
21. A copy of the Individual Plant Examination of External Events, if available
electronically.
22. One-line drawings of emergency core cooling system, ultimate heat sink, emergency
feedwater, safety-related electrical systems.
23. A copy of condition reports associated with inspection findings from the previous
NRC Inspection Procedure 71111.21 (or 71111.21 Attachment M inspection).
24. A list of licensee contacts for the inspection team with phone numbers.
3
25. A copy of the current management and engineering organizational charts.
II.
Information Requested to be provided throughout the inspection.
1. Electronic copies of the design bases documents for selected components and
modifications.
2. Electronic copies of the system health notebooks for selected components and
modifications.
3. A list of the design calculations that provide the design margin information for
selected components. (Calculations for selected components should be available
during the information gathering visit.)
4. Calculations and drawings associated with selected components.
5. Modification documentation associated with modifications selected from Item I.15,
this includes:
a. Post-modification testing, including performance characteristics affected,
assumptions, and acceptance criteria associated with modifications selected
b. Updated maintenance and surveillance procedures associated with
modifications
c. Updated operation procedures and training plans associated with the
modifications
6. Copies of any corrective action documents generated as a result of the teams
questions or queries during this inspection.
7. 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).
Inspector Contact Information:
Reactor Inspector
Reactor Inspector
Emergency Response Specialist
817-200-1174
817-200-1565
817-200-1544
Peter.Jayroe@nrc.gov
Brian.Correll@nrc.gov
Michael.Bloodgood@nrc.gov
Mailing Address:
U.S. NRC, Region IV
Attn: Jonathan Braisted
1600 East Lamar Blvd.
Arlington, TX 76011-4511
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: JDB
Yes No
Publicly Available
Sensitive
OFFICE
RI:EB1
C:EB1
NAME
JBraisted
TFarnholtz
SIGNATURE
/RA/
/RA/
DATE
4/26/2018
4/30/2018