ML20309A360

Notification of NRC Design Bases Assurance Inspection (Teams) (Inspection Report 05000445/2021011 and 05000446/2021011) and Initial Request for Information

ML20309A360
Person / Time
Site:	Comanche Peak
Issue date:	11/04/2020
From:	Vincent Gaddy Region 4 Engineering Branch 1
To:	Peters K Vistra Operations Company
References
IR 2020011
Download: ML20309A360 (7)

See also: IR 05000445/2021011

Text

November 4, 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: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

NOTIFICATION OF NRC DESIGN BASES ASSURANCE INSPECTION (TEAMS)

(INSPECTION REPORT 05000445/2021011 AND 05000446/2021011) AND

INITIAL REQUEST FOR INFORMATION

Dear Mr. Peters:

On February 8, 2021, the Nuclear Regulatory Commission (NRC) will begin a triennial

baseline component design bases inspection at the Comanche Peak Nuclear Power Plant.

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, operating experience issues will also be selected for review.

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

two weeks of onsite inspection by the team. The inspection will consist of a team lead

inspector, two mechanical inspectors, two electrical inspectors, and an operations inspector.

The current inspection schedule is as follows:

Information Gathering Visit: January 4-8, 2021

Preparation Week: February 1-5, 2021

Onsite Weeks: February 8-12 and February 22-26, 2021

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 inspection, up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> will be needed on the plant-referenced simulator in

order to facilitate the development and inspection of operator action-based scenarios. It has not

yet been determined if the inspection will be onsite or conducted remotely. If the inspection is

performed remotely, we are requesting that, as a minimum, actual on-site time be made

available for 1-2 days to perform component and modification walkdowns. Simulator activities

K. Peters 2

would have to be performed on site. 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.

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 January 4, 2021, 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 onsite 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

onsite 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 Ronald A. Kopriva, Senior Reactor Inspector. If there

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

inspector by telephone at 817-200-1104 or by e-mail at Ron.Kopriva@nrc.gov. It is our

understanding that Mr. Gary Merka will be our licensing contact for the inspection.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct nor 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 OMB control number.

K. Peters 3

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Vincent G. Digitally signed by Vincent

G. Gaddy

Gaddy Date: 2020.11.04 10:53:56

-06'00'

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 05000445 and 05000446

License Nos. NPF-87 and NPF-89

Enclosure:

Design Bases Assurance

Inspection (Teams) Request for

Information

cc w/ encl: Distribution via LISTSERV

ML20309A360

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: RAK Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:EB1 C:EB1

NAME RAKopriva VGGaddy

SIGNATURE /RA/ /RA/

DATE 11/04/2020 11/04/2020

Initial Request for Information

Design Bases Assurance Inspection (Teams)

Comanche Peak Nuclear Power Plant

Inspection Report: 05000445/2021011 and 05000446/2021011

EPID ID: I-2021-011-0002

Information Gathering Date: January 4-8, 2021

Inspection Dates: February 8-12, 2021, and February 22-26, 2021

Inspection Procedure: IP 71111, Attachment 21M, Design Bases Assurance

Inspection (Teams)

Lead Inspector: Ronald A. Kopriva, Senior Reactor Inspector

I. Information Requested Prior to Information Gathering Visit (January 4, 2021)

The following information (Section I of this enclosure) should be sent to the Region IV

office in hard copy or electronic format (electronic database preferred), to the

attention of Ronald A. Kopriva, Senior Reactor Inspector, by January 4, 2021, to

facilitate the reduction in the items to be selected for a final list. 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 boiling 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 onsite 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 PRA.

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.

Enclosure

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 PRA.

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.

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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.

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: Mailing Address:

Ronald A. Kopriva U.S. NRC, Region IV

Senior Reactor Inspector ATTN: Ronald A. Kopriva

817-200-1104 - Work 1600 East Lamar Blvd.

Ron.Kopriva@nrc.gov Arlington, TX 76011-4511

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