ML20055E105

CP2019006 Annual Assessment Letter

ML20055E105
Person / Time
Site:	Comanche Peak
Issue date:	03/03/2020
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Peters K Vistra Operations Company
References
IR 20192006
Download: ML20055E105 (5)

Text

March 3, 2020 Mr. Ken Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

ANNUAL ASSESSMENT LETTER FOR COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 (REPORT 05000445/2019006 AND 05000446/2019006)

Dear Mr. Peters:

The U.S. Nuclear Regulatory Commission (NRC) has completed its end-of-cycle performance assessment of Comanche Peak Nuclear Power Plant, Units 1 and 2, reviewing performance indicators, inspection results, and enforcement actions from January 1, 2019 through December 31, 2019. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility. The NRC concluded that overall performance at your facility preserved public health and safety.

The NRC determined the performance at Comanche Peak Nuclear Power Plant, Units 1 and 2, during the most recent quarter was within the Licensee Response Column, the highest performance category of the NRCs Reactor Oversight Process (ROP) Action Matrix, because all inspection findings had very low safety significance (i.e., Green) and all performance indicators were within the expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.

For the 12-month period ending August 8, 2019, the NRC issued three severity level IV traditional enforcement violations associated with impeding the regulatory process. However, despite having met the entry criteria, the NRC has decided not to conduct Inspection Procedure 92723, Follow-up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period to follow up on these violations because two of the violations occurred in the distant past and are not indicative of current performance. The NRC will continue to assess the remaining violation and any future traditional enforcement violations against the entry criteria for this supplemental inspection procedure.

Additionally, during this period the NRC will schedule an additional inspection per a revised version of Temporary Instruction (TI) 2515/194, Inspection of the Licensees Implementation of Industry Initiative Associated with the Open Phase Condition Design Vulnerability in Electrical Power Systems (NRC Bulletin 2012-01) for any sites who elect to implement the guidance of the Industry Initiative on Open Phase Condition, Revision 3 (Agency Documents Access and

K. Peters 2 Management System (ADAMS) Accession ML19163A176), which included an option for relying on annunciation and operator manual actions instead of automatic protective features to isolate a power supply affected by an open phase condition. Licensees will be individually notified when the NRC schedules these inspections.

The enclosed inspection plan lists the inspections scheduled through December 31, 2021.

This updated inspection plan now includes security inspections which were formerly transmitted under separate correspondence. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. Routine inspections performed by resident inspectors are not included in the inspection plan. You should be aware that the agency is pursuing potential changes to the ROP, including changes to engineering inspections (SECY-18-0113, Recommendations for Modifying the Reactor Oversight Process Engineering Inspections), and other changes to the baseline inspection program described in SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process. Should these changes to the ROP be implemented, the engineering and other region-based inspections are subject to change in scope, as well as schedule. The inspections listed during the last 12 months of the inspection plan are tentative and may be revised. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.

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

Please contact me at (817) 200-1141 with any questions you have regarding this letter.

Sincerely,

/RA/

Neil F. OKeefe, Chief Project Branch B Division of Reactor Projects Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

Inspection Plan cc w/ encl: Distribution via LISTSERV

IP 22 Inspection Activity Plan Report Comanche Peak 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count RS567 Radiation Safety PS Team 3 1, 2 01/27/2020 01/31/2020 IP 71124.05 000729 Radiation Monitoring Instrumentation 1, 2 01/27/2020 01/31/2020 IP 71124.06 000730 Radioactive Gaseous and Liquid Effluent Treatment 1, 2 01/27/2020 01/31/2020 IP 71124.07 000731 Radiological Environmental Monitoring Program Cyber Security Inspection - CP 4 1, 2 02/10/2020 02/14/2020 IP 71130.10P 000741 Cyber Security 1, 2 02/24/2020 02/28/2020 IP 71130.10P 000741 Cyber Security Inservice Inspection 2RF18 - CP 1 2 04/27/2020 05/08/2020 IP 71111.08P 000702 Inservice Inspection Activities (PWR)

RS13PI Radiation Safety 2 1, 2 04/27/2020 05/01/2020 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2 04/27/2020 05/01/2020 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation Fire Protection Inspection - CP 3 1, 2 06/08/2020 06/20/2020 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI) 1, 2 06/22/2020 07/04/2020 IP 71111.21N.05 001646 Fire Protection Team Inspection (FPTI)

Comanche Peak 1, 2 - Powered Operated Valve Inspection 3 1, 2 08/10/2020 08/14/2020 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements 1, 2 08/24/2020 08/28/2020 IP 71111.21N.02 001645 Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements Security Access Control .02 1 1, 2 08/24/2020 08/28/2020 IP 71130.02 000734 Access Control 1, 2 08/24/2020 08/28/2020 IP 71151 001338 Performance Indicator Verification CPSES 2020 BRQ 2 1, 2 09/27/2020 10/03/2020 IP 71111.11B 000704 Licensed Operator Requalification Program and Licensed Operator Performance EP Program Inspection 1 1, 2 10/05/2020 10/09/2020 IP 71114.02 000717 Alert and Notification System Testing 1, 2 10/05/2020 10/09/2020 IP 71114.03 000718 Emergency Response Organization Staffing and Augmentation System 1, 2 10/05/2020 10/09/2020 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes 1, 2 10/05/2020 10/09/2020 IP 71114.05 000720 Maintenance of Emergency Preparedness This report does not include INPO and OUTAGE activities. Page 1 of 3 This report shows only on-site and announced inspection procedures.

2/19/2020 11:29:49 AM

IP 22 Inspection Activity Plan Report Comanche Peak 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count EP Program Inspection 1 1, 2 10/05/2020 10/09/2020 IP 71151 001397 Performance Indicator Verification Inservice Inspection 1RF21 - CP 1 1 10/12/2020 10/23/2020 IP 71111.08P 000702 Inservice Inspection Activities (PWR)

RS8 1 1, 2 11/02/2020 11/06/2020 IP 71124.08 000732 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Design Bases Assurance (Team) 21M - Comanche Peak 6 1, 2 02/08/2021 02/26/2021 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)

Security FFD .08 1 1, 2 02/22/2021 02/26/2021 IP 71130.08 000740 Fitness For Duty Program EP Exercise and PI Inspection 4 1, 2 03/29/2021 04/02/2021 IP 71114.01 000716 Exercise Evaluation 1, 2 03/29/2021 04/02/2021 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes 1, 2 03/29/2021 04/02/2021 IP 71151 001397 Performance Indicator Verification Security Protective Strategy .05 w/Exercise 2 1, 2 05/03/2021 05/07/2021 IP 71130.05 000737 Protective Strategy Evaluation CPSES 2021 INITIAL EXAM 4 1, 2 05/09/2021 05/15/2021 OV 000956 VALIDATION OF INITIAL LICENSE EXAMINATION (OV) 1, 2 06/13/2021 06/19/2021 EXAD 000500 LICENSE EXAM ADMINISTRATION (EXAD)

RP 2,4 2 1, 2 05/17/2021 05/21/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls 1, 2 05/17/2021 05/21/2021 IP 71124.04 000728 Occupational Dose Assessment MCA - Material Control & Accounting 1 1, 2 05/17/2021 05/21/2021 IP 71130.11 000742 Material Control and Accounting (MC&A)

Security Access Authorization .01 and Access Control .02 w/PIV 2 1, 2 07/26/2021 07/30/2021 IP 71130.01 000733 Access Authorization This report does not include INPO and OUTAGE activities. Page 2 of 3 This report shows only on-site and announced inspection procedures.

2/19/2020 11:29:49 AM

IP 22 Inspection Activity Plan Report Comanche Peak 01/01/2020 - 12/31/2021 Unit Start End Activity CAC Title Staff Count Security Access Authorization .01 and Access Control .02 w/PIV 2 1, 2 07/26/2021 07/30/2021 IP 71130.02 000734 Access Control 1, 2 07/26/2021 07/30/2021 IP 71151 001338 Performance Indicator Verification Biennial PI&R Inspection 4 1, 2 09/13/2021 09/17/2021 IP 71152B 000747 Problem Identification and Resolution 1, 2 09/27/2021 10/01/2021 IP 71152B 000747 Problem Identification and Resolution Inservice Inspection 2RF19 - CP 1 2 10/11/2021 10/22/2021 IP 71111.08P 000702 Inservice Inspection Activities (PWR)

RP 1,2,PI 2 1, 2 10/18/2021 10/22/2021 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2 10/18/2021 10/22/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls This report does not include INPO and OUTAGE activities. Page 3 of 3 This report shows only on-site and announced inspection procedures.

2/19/2020 11:29:49 AM