ML21222A033

NRR E-mail Capture - Comanche Peak Units 1 and 2 - License Amendment Request to Adopt TSTF-505 - Audit Plan and Setup of Online Document Access (L-2021-LLA-0085)

ML21222A033
Person / Time
Site:	Comanche Peak
Issue date:	08/09/2021
From:	Dennis Galvin NRC/NRR/DORL/LPL4
To:	Hicks J Vistra Operations Company
References
L-2021-LLA-0085
Download: ML21222A033 (6)

Text

From: Galvin, Dennis Sent: Monday, August 9, 2021 6:26 PM To: Jack Hicks (Jack.Hicks@luminant.com)

Cc: Struble, Garry

Subject:

Comanche Peak Units 1 and 2 - License Amendment Request to Adopt TSTF-505 - Audit Plan and Setup of Online Document Access (L-2021-LLA-0085)

Attachments: Comanche Peak - TSTF 505 -Audit Plan - Portal Request 2021-08-09.pdf

Dear Mr. Hicks,

By letter dated May 11, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML (ML21131A233) as supplemented by letter dated July 13, 2021 (ML21194A078), Vistra Operations Company, LLC (Vistra OpCo, the licensee) submitted a license amendment request (LAR) regarding Comanche Peak Nuclear Power Plant Units 1 and 2 (Comanche Peak). The proposed amendment would revise Technical Specification (TS) requirements to permit the use of risk informed completion times for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on TSs Task Force Traveler (TSTF) 505, Revision 2, Provide Risk Informed Extended Completion Times -

RITSTF Initiative 4b, dated July 2, 2018 (ADAMS Accession No. ML18183A493). The U.S.

NRC issued a final model safety evaluation (SE) approving TSTF 505, Revision 2, on November 21, 2018 (ADAMS Accession No. ML18269A041).

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit would support its review of the proposed license amendment. The audit will be conducted via online access to non-docketed information set up by the licensee and via webinar. The enclosed audit plan addresses the request for online access to documents. The audit plan for the webinar, including audit questions, will be provided separately. The licensee is requested to provide online access to specific NRC staff and to be read-only (i.e., to establish measures to prevent the downloading, copying, printing, or otherwise storing of any documents). The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket following the webinar portion of the audit.

If you have any questions, 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: 1310 Mail Envelope Properties (SA1PR09MB81118ED6702D62F16846C532FBF69)

Subject:

Comanche Peak Units 1 and 2 - License Amendment Request to Adopt TSTF-505 - Audit Plan and Setup of Online Document Access (L-2021-LLA-0085)

Sent Date: 8/9/2021 6:25:52 PM Received Date: 8/9/2021 6:25:00 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: SA1PR09MB8111.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2116 8/9/2021 6:25:00 PM Comanche Peak - TSTF 505 -Audit Plan - Portal Request 2021-08-09.pdf 120423 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

AUDIT PLAN LICENSE AMENDMENT REQUEST TO ADOPT RISK-INFORMED EXTENDED COMPLETION TIMES VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 I. BACKGROUND By letter dated May 11, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML (ML21131A233) as supplemented by letter dated July 13, 2021 (ML21194A078), Vistra Operations Company, LLC (Vistra OpCo, the licensee) submitted a license amendment request (LAR) regarding Comanche Peak Nuclear Power Plant Units 1 and 2 (Comanche Peak). The proposed amendment would revise Technical Specification (TS) requirements to permit the use of risk informed completion times for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on TSs Task Force Traveler (TSTF) 505, Revision 2, Provide Risk Informed Extended Completion Times -

RITSTF Initiative 4b, dated July 2, 2018 (ADAMS Accession No. ML18183A493). The U.S.

NRC issued a final model safety evaluation (SE) approving TSTF-505, Revision 2, on November 21, 2018 (ADAMS Accession No. ML18269A041).

The audit will be conducted via online access to non-docketed information set up by the licensee and via webinar. This audit plan addresses the request for online access to documents. The audit plan for the webinar, including audit questions, will be provided separately.

II. REGULATORY AUDIT BASES The basis of this remote audit is the licensees LAR for Comanche Peak, and the Standard Review Plan (SRP) Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance (ADAMS Accession No. ML071700658).

The remote audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274). An audit was determined to be the most efficient approach toward a timely resolution of issues associated with this LAR review, since the staff will have an opportunity to minimize the potential for multiple rounds of requests for additional information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination.

Enclosure

III. PURPOSE AND SCOPE The purpose of the audit is to gain a more detailed understanding of licensees Risk Informed Completion Time (RICT) program and its application to the TSs completion times as proposed in the LAR. This will support NRC staff preparation of questions to be addressed during the future audit interactions, anticipated to be conducted by webinar. The NRC staff will review internal events and fire PRA and the risk informed approach for establishing extended completion times.

The areas of focus for the regulatory audit are the information contained in the licensees submittal, the enclosed audit information needs, and all associated and relevant supporting documentations (e.g., methodology, process information, calculations, etc.). The relevant supporting documents are identified below.

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY REMOTE AUDIT The following documentation should be available to the audit team:

1. CN-RAM-13-038, Revision 3, Qualitative Screening, Quantitative Screening, Quantification, and Uncertainty Analysis for CPNPP Fire PRA, December 2019.

2. CN-RAM-20-003, Revision 0, Comanche Peak High Winds PRA Hazard Analysis, October 2020.

3. CN-RAM-20-016, Revision 0, Comanche Peak Nuclear Power Plant PRA Model Integration for TSTF-505, January 2021.

4. LTR-RAM-11-11-038, RG 1.200 PRA Peer Review Against the ASME/ANS PRA Standard Requirements for the Comanche Peak Nuclear Power Plant Probabilistic Risk Assessment, Westinghouse Electric Co.

5. LTR-RAM-15-48, Revision 0, Review of SRs not Met at Capability Category II and Resolution of Peer Review F&Os from the 2011 Internal Events and Internal Flooding PRA Peer Review for the Comanche Peak Nuclear Power Plant, Westinghouse Electric Co.

6. LTR-RAM-15-71, Revision 0, Independent Review and Resolution of Inconsistencies in the 2011 Internal Events and Internal Flooding PRA Peer Review Report for the Comanche Peak Nuclear Power Plant, Westinghouse Electric Co.

7. LTR-RAM-20-45, Revision 0, Seismic Hazard Analysis to Support Comanche Peak RICT LAR, May 2020.

8. LTR-RAM-20-99, Revision 0, High Wind Hazard Analysis to Support Comanche Peak RICT LAR, November 2020.

9. PWROG-14001-P-A, Revision 1, PRA Model for the Generation III Westinghouse Shutdown Seal, December 2017.

10. PWROG-15103-P, Revision 0, Peer Review of the Comanche Peak Internal Fire Probabilistic Risk Assessment, Pressurized Water Reactors Owners Group, June 2016.

11. PWROG-18060-P, Revision 0, Independent Assessment of Facts & Observations Closures of the Comanche Peak Probabilistic Risk Assessment, Pressurized Water Reactors Owners Group, January 2019.

12. R&R-PN-008A, Revision 5, Internal Initiating Events Data Analysis, Comanche Peak Nuclear Power Plant, November 2016.

13. R&R-PN-021, Revision 5, Internal Flooding Analysis, May 2019.

14. R&R-PN-022, Revision 5, Level 1 Internal Events Quantification, October 2016.

15. R&R-PN-035, Revision 5, Level 2 Internal Events Quantification, November 2016

16. R&R-PN-041, Revision 5, Sensitivity and Uncertainty, January 2019

17. R&R-PN-46, Revision 5, Configuration Risk Monitor for Risk-Informed Completion Times, January 2021.

18. R&R-PN-205, Revision 5, Screening and Conservative Analysis for Other External Hazards, October 2020.

19. STA-604, Configuration Risk Management and Work Scheduling

20. STA-762, Risk Informed Completion Time Implementation

21. STI-762.01, Risk-Informed Completion Time Implementation

22. STI-762.02, Risk-Informed Completion Times - PRA model Configuration Control

23. PRA Uncertainty Notebooks for internal events, internal flooding and fire

24. PRA success criteria Notebooks

25. Documentation supporting the example RICT calculations presented in LAR Enclosure 1 Table E1-2 V. AUDIT TEAM The members of the audit team are anticipated to be:

• Dennis Galvin, Project Manager, NRC (Dennis.Galvin@nrc.gov)

• Jigar Patel, APLA, NRC (Jigar.Patel@nrc.gov)

• Jeff Circle, APLA, NRC (Jeff.Circle@nrc.gov)

• Milton Valentin, APLC, NRC (Milton.Valentin@nrc.gov)

• Wesley Wu, APLC, NRC (De.Wu@nrc.gov)

• Steven Short, Contractor, PNNL (Steve.Short@pnnl.gov)

VI. SPECIAL REQUESTS The NRC staff would like online access to the documents listed above in Section IV that allows the NRC staff and contractors to access documents remotely. Additional documents may be identified as the review progresses. NRC staff and contractors online access should be terminated October 31, 2022.

Online access to documents is to be limited to specific NRC staff and contractors (e.g., based on NRC or contractor e-mail addresses or the use of passwords which will only be assigned to NRC or contractor staff directly involved in the LAR review on a need-to-know basis), and to be read-only (i.e., to establish measures to prevent the downloading, copying, printing, or otherwise storing of any documents). The conditions associated with the online access of documents must be maintained throughout the review process. The NRC staff who should be granted access to the portal are those listed in the Team Assignments section. All other communications should be coordinated with the NRC project manager.

VII. DELIVERABLES An audit summary, which will be public, will issued at the completion of the audit. If the NRC staff identifies information during the webinar portion of the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee after the completion of the webinar portion of the audit.