ML19319A543

NRR E-mail Capture - Draft Comanche Peak RAIs - Quality Assurance Program Reduction in Commitment

ML19319A543
Person / Time
Site:	Comanche Peak
Issue date:	11/14/2019
From:	Dennis Galvin NRC/NRR/DORL/LPL4
To:	Hicks J Luminant Generation Co
References
L 2019-LLQ-0002
Download: ML19319A543 (4)

Text

From: Galvin, Dennis Sent: Thursday, November 14, 2019 2:48 PM To: Jack Hicks (Jack.Hicks@luminant.com)

Cc: Struble, Garry

Subject:

Draft Comanche Peak RAIs - Quality Assurance Program Reduction in Commitment (EPID L 2019-LLQ-0002)

Attachments: Comanche Peak QAPD Change Draft RAI L-2019-LLQ-0002 2019-11-14 .pdf Mr. Hicks, By letter dated August 14, 2019 (Agencywide Documents Access and Management System Accession No. ML19228A086), Vistra Operations Company LLC, (the licensee) submitted a request to reduce quality assurance program commitments for Comanche Peak Nuclear Power Plant Units 1 and 2 (Comanche Peak). The request would revise the final safety analysis report description of (1) the biennial reviews of Emergency Response Guidelines, Functional Restoration Guidelines, and Abnormal Plant Operating procedures and (2) the Station Operations Review Committee meeting frequency, which are part of the previously accepted Comanche Peak quality assurance program.

To complete its review, the NRC staff has prepared the attached requests for additional information (RAIs) in DRAFT form. To arrange a clarification call for the attached draft RAIs and to discuss the due date for the RAI responses, please contact me at (301) 415-6256.

Respectfully, Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256 Docket No. 50-445, 50-446

Hearing Identifier: NRR_DRMA Email Number: 311 Mail Envelope Properties (CH2PR09MB39571D13BBF3AACBB4DB92A1FB710)

Subject:

Draft Comanche Peak RAIs - Quality Assurance Program Reduction in Commitment (EPID L 2019-LLQ-0002)

Sent Date: 11/14/2019 2:48:29 PM Received Date: 11/14/2019 2:48:00 PM From: Galvin, Dennis Created By: Dennis.Galvin@nrc.gov Recipients:

"Struble, Garry" <Garry.Struble@luminant.com>

Tracking Status: None "Jack Hicks (Jack.Hicks@luminant.com)" <Jack.Hicks@luminant.com>

Tracking Status: None Post Office: CH2PR09MB3957.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1188 11/14/2019 2:48:00 PM Comanche Peak QAPD Change Draft RAI L-2019-LLQ-0002 2019-11-14 .pdf 111673 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST TO REDUCE QUALITY ASSURANCE PROGRAM COMMITMENTS COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 By letter dated August 14, 2019 (Agencywide Documents Access and Management System Accession No. ML19228A086), Vistra Operations Company LLC, (the licensee) submitted a request to reduce quality assurance program commitments for Comanche Peak Nuclear Power Plant Units 1 and 2 (Comanche Peak). The request would revise the final safety analysis report description of (1) the biennial reviews of Emergency Response Guidelines, Functional Restoration Guidelines, and Abnormal Plant Operating procedures and (2) the Station Operations Review Committee meeting frequency, which are part of the previously accepted Comanche Peak quality assurance program.

Chapter 17 of the Comanche Peak Nuclear Power Plant (Comanche Peak) Final Safety Analysis Report (FSAR) (ADAMS Accession No. ML17226A054) describes the Comanche Peak QA program and includes a commitment to Revision 2 of Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation). RG 1.33 endorses ANSI N18.7-1976/ANS-3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.

Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a)(4) requires licensees to submit changes to the quality assurance (QA) program description that represent a reduction in commitment. Subsequently, 10 CFR 50.54(a)(4)(ii) requires that the submittal of a change to the Safety Analysis Report QA program description must include all pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the revised program incorporating the change continues to satisfy the criteria of Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the U.S. Nuclear Regulatory Commission (NRC).

Question 1 Criterion V, Instructions, Procedures, and Drawings, of Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, states that Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Section 5.2.15, Review, Approval, and Control of Procedures, of ANSI N18.7-1976/ANS-3.2, states, in part, that Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure and no less frequently than every two years to determine if changes are necessary or desirable.

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Comanche Peaks proposed change to the FSAR to eliminate the biennial reviews of Emergency Response Guidelines (ERGs), Functional Restoration Guidelines (FRGs), and Abnormal Plant Operating (ABNs) procedures and rely on Comanche Peaks programmatic controls already in place represents a reduction in commitment from the previously accepted Comanche Peak QA program. It is unclear how Comanche Peaks current programmatic controls would ensure that ERGs, FRGs, and ABNs will be reviewed to determine if changes are necessary. Usage of these procedures is dictated by an event and their review is important to determine the adequacy of current procedures and how the licensee would respond in case of an event. In addition, the NRC staff notes Comanche Peak did not identify a precedent for the proposed change.

The NRC staff requests Comanche Peak to provide additional clarifying information to show how this proposed change will ensure the review of the ERGs, FRGs, and ABNs continue to satisfy Criterion V of Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the NRC.

Question 2 Sub-section 4.3.2.2, Meeting Frequency, of section 4.3.2, Standing Committees Functioning as Independent Review Bodies, of ANSI N18.7-1976/ANS-3.2 states, in part, that During the period of initial operation such meetings should be held no frequently than once per calendar quarter. Subsequently, the meeting frequency shall not be less than twice a year.

Comanche Peaks additional proposed change regarding the meeting frequency of the Station Operations Review Committees (SORC) from once per calendar month and as convened by the SORC Chairman or his designated alternate, to periodically as determined by the SORC Chairman or his designated alternate, represents a reduction in commitment from the previously accepted Comanche Peaks QA program. It is unclear how this change would ensure that the SORC meetings would be convened with sufficient frequency to ensure that it is able to adequately fulfill its safety responsibilities as listed in the FSAR. In addition, the NRC staff notes Comanche Peak did not identify a precedent for the proposed change.

The NRC staff requests Comanche Peak to provide additional clarifying information to show how this proposed change will ensure that SORC meetings will continue to be convened at an acceptable frequency and therefore continue to satisfy the criteria of Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the NRC.

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