ML22152A041
| ML22152A041 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/10/2022 |
| From: | Dennis Galvin Plant Licensing Branch IV |
| To: | Peters K Vistra Operations Company |
| Galvin D | |
| References | |
| EPID L-2021-LLA-0085 | |
| Download: ML22152A041 (9) | |
Text
June 10, 2022 Mr. Ken J. Peters Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Vistra Operations Company LLC Comanche Peak Nuclear Power Plant 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 -
SUMMARY
OF REGULATORY AUDIT REGARDING A LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B (EPID L-2021-LLA-0085)
Dear Mr. Peters:
By application dated May 11, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21131A233), as supplemented letters dated July 13, 2021; February 17, 2022; March 29, 2022; and May 12, 2022 (ML21194A078, ML22048B490, ML22088A299, and ML22132A119, respectively); Vistra Operations Company, LLC (the licensee) submitted a license amendment request (LAR) for Comanche Peak Nuclear Power Plant Unit Nos. 1 and 2. The amendments would revise technical specification 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 Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision2, Provide Risk Informed Extended Completion Times - RITSTF [Risk Informed TSTF] Initiative4b, dated July 2, 2018 (ML18183A493). The U.S. Nuclear Regulatory Commission (NRC) issued a final model safety evaluation approving TSTF 505, Revision 2, dated November 21, 2018 (ML18269A041).
To support its review, the NRC staff conducted a regulatory audit via the use of an online reference portal set up by the licensee, and a webinar. The NRC staff reviewed documents and held discussions with the licensees staff concerning the LAR. The audit summary is enclosed.
If you have any questions, please contact me at 301-415-6256 or via email at Dennis.Galvin@nrc.gov.
Sincerely,
/RA/
Dennis J. Galvin, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
Audit Summary cc: Listserv
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT
SUMMARY
IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505 VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446
1.0 BACKGROUND
By application dated May 11, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21131A233), as supplemented letters dated July 13, 2021; February 17, 2022; March 29, 2022; and May 12, 2022 (ML21194A078, ML22048B490, ML22088A299, and ML22132A119, respectively); Vistra Operations Company, LLC (the licensee) submitted a license amendment request (LAR) for Comanche Peak Nuclear Power Plant Unit Nos. 1 and 2 (Comanche Peak). The amendments 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 TS Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b, dated July 2, 2018 (ML18183A493). The U.S. Nuclear Regulatory Commission (NRC) issued a final model safety evaluation approving TSTF-505, Revision 2, dated November 21, 2018 (ML18269A041).
The NRC staff reviewed the licensees submittal and determined that a regulatory audit would support its review of the proposed license amendment. The audit was conducted in accordance with the audit plan dated August 9, 2021 (ML21222A033), as supplemented by email dated October 27, 2021 (ML21300A134).
2.0 AUDIT ACTIVITIES The purpose of the audit was to review the documentation related to the subject of its application (e.g., calculations and reports) that were not submitted on the Comanche Peak docket, to acquire additional understanding about the amendment request, and to determine whether additional information is needed to be docketed to complete the NRC staffs safety evaluation.
The audit was conducted via the use of an online reference portal set up by the licensee and webinars. Through the online reference portal, the NRC staff reviewed the licensees documents made available in response to section IV of the August 9, 2021, audit plan. The NRC staff also reviewed the licensees responses to the audit questions contained in the October 27, 2021, supplement to the audit plan. The licensee also included responses to the audit questions in the February 17, 2022, supplement to the LAR.
The NRC staff and the licensee conducted webinars on November 30 and December 1 and 6 -
8, 2021. The webinar discussions were focused on the following major technical areas:
probabilistic risk assessment, external hazards, fire protection, TSs, electrical engineering, and instrumentation and controls. The NRC staff and the licensee discussed each of the audit questions and proposed responses and identified if and how the responses could be modified to address the audit questions and the aspects of the responses to the audit questions that should be submitted on the docket. The discussions facilitated the NRC staff understanding of the request and identified information that should be provided on the docket. The list of non-docketed documents made available by the licensee during the audit is attached to this audit summary. There were no deviations from the audit plan beyond minor schedule changes and finishing a day early each week.
On December 1 and 8, the NRC staff and licensee held closing sessions to summarize the disposition of each audit question covered that week and the information that should submitted on the docket, either through a licensee supplement or in response to requests for additional information (RAIs). The NRC staff informed the licensee that the RAIs would essentially be the portion of the audit questions that required a supplement. As part of the closing of the December 8 webinar, the licensee informed the NRC staff that it would supplement the LAR to provide documentation of certain audit discussion points on the docket. The licensee also indicated that the supplement would include the responses to audit questions for information purposes and provide pointers to where LAR sections were supplemented. The NRC staff agreed with this closure path to the audit questions and did not identify any open items beyond providing a supplement.
3.0 RESULTS OF THE AUDIT The audit identified information to be provided on the docket, which the licensee agreed to provide through a supplement to the LAR. The licensee provided the supplement on February 17, 2022. As agreed to at the audit, the supplement provided responses to each of the audit questions and supplemented certain LAR sections as discussed in the audit. Thus, those details are not included in this audit summary.
4.0 AUDIT PARTICIPANTS NRC Jeff Circle Fred Forsaty Dennis Galvin Daniel Ju Ming Li Khoi Nguyen Robert Pascarelli Jigar Patel Milton Valentin Robert Vettori Khadijah West Wesley Wu Steve Wyman Pacific Northwest National Laboratory Steve Short Comanche Peak Kris Brigman Jack Hicks Garry Struble Westinghouse Electric Company, LLC James Boatwright Matt Degonish Kyle Hope Andrea Maioli Michele Reed Steven Satter Dan Tirsun Carroll Trull
Attachment:
List of Documents Reviewed During Audit
Attachment List of Documents Reviewed During Audit The licensee provided an extensive list of supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) on the Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak or CPNPP), document portal available during the audit period. The list of documents available on the portal is provided below.
CN-RAM-13-031, Revision 3, Plant Response Model for Comanche Peak Nuclear Power Plant Fire PRA [Probabilistic Risk Assessment]
CN-RAM-13-032, Revision 3, Ignition Frequencies for Comanche Peak Nuclear Power Plant Fire PRA CN-RAM-13-034, Revision 3, Fire Scenario Selection from the Comanche Peak Nuclear Power Plant Fire PRA CN-RAM-13-035, Revision 1, Main Control Room Analysis for the Comanche Peak Nuclear Power Plant Fire PRA CN-RAM-13-036, Revision 4, Human Reliability Analysis for Comanche Peak Nuclear Power Plant Fire PRA CN-RAM-13-038, Revision 3, Qualitative Screening, Quantitative Screening, Quantification, and Uncertainty Analysis for CPNPP Fire PRA, December 2019.
CN-RAM-17-011, Revision 1, Quantitative Uncertainty Evaluation for Fire PRA CN-RAM-20-002, Revision 0, Comanche Peak High Winds PRA Hazard Analysis CN-RAM-20-003, Revision 0, Comanche Peak High Winds PRA Hazard Analysis, October 2020.
CN-RAM-20-016, Revision 0, Comanche Peak Nuclear Power Plant PRA Model Integration for TSTF-505 [Technical Specifications Task Force-505], January 2021.
LTR-RAM-II-11-038, RG [Regulatory Guide] 1.200 PRA Peer Review Against the ASME/ANS [American Society of Mechanical Engineers/American Nuclear Society] PRA Standard Requirements for the Comanche Peak Nuclear Power Plant Probabilistic Risk Assessment, Westinghouse Electric Co., April 2011 LTR-RAM-15-48, Revision 0, Review of SRs [Supporting Requirements] not Met at Capability Category II and Resolution of Peer Review F&Os [Facts and Observations]
from the 2011 Internal Events and Internal Flooding PRA Peer Review for the Comanche Peak Nuclear Power Plant, Westinghouse Electric Co., September 2015 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., February 2016 LTR-RAM-20-45, Revision 0, Seismic Hazard Analysis to Support Comanche Peak RICT [Risk-Informed Completion Times] LAR [License Amendment Request],
May 2020.
LTR-RAM-20-99, Revision 0, High Wind Hazard Analysis to Support Comanche Peak RICT LAR, November 2020.
PWROG-14001-P-A, Revision 1, PRA Model for the Generation III Westinghouse Shutdown Seal, December 2017.
PWROG-15103-P, Revision 0, Peer Review of the Comanche Peak Internal Fire Probabilistic Risk Assessment, Pressurized Water Reactors Owners Group (PWROG),
June 2016.
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.
R&R-PN-008A, Revision 5, Internal Initiating Events Data Analysis, Comanche Peak Nuclear Power Plant, November 2016.
R&R-PN-020, Revision 5, Human Reliability Analysis, October 2016 R&R-PN-021, Revision 5, Internal Flooding Analysis, May 2019.
R&R-PN-022, Revision 5, Level 1 Internal Events Quantification, October 2016.
R&R-PN-035, Revision 5, Level 2 Internal Events Quantification, November 2016 R&R-PN-041, Revision 5, Sensitivity and Uncertainty, January 2019 R&R-PN-46, Revision 5, Configuration Risk Monitor for Risk-Informed Completion Time (RICT), February 2021.
R&R-PN-205, Revision 5, Screening and Conservative Analysis for Other External Hazards, October 2020.
R&R-PN-027, Revision 5, RCP [Reactor Coolant Pump] Seal LOCA [Loss-of-Coolant Accident] Model, October 2016 STA-604.01, Revision 6, Integrated Risk Management, May 20, 2021 STA-604.02, Revision 1, Maintenance Risk Assessment, December 17, 2019 STA-604.03, Revision 9, Weekly Surveillances / Work Scheduling, May 20, 2021 STA-604.04, Revision 2, Outage Safety Function Guide, September 4, 2019 STA-604.05, Revision 0, On-line Fire Risk Management, March 2, 2017 STA-604, Revision 12, Configuration Risk Management and Work Scheduling, May 10, 2021 STA-762, Revision 0, Risk Informed Completion Time Program STI-762.01, Revision 0, Risk-Informed Completion Time Implementation STI-762.02, Revision 0, Risk-Informed Completion Times - PRA model Configuration Control RXE-LA-CPX/0-104, Revision 0, Core Uncovery Times for the WOG [Westinghouse Owners Group] 2000 Reactor Coolant Pump Seal LOCA Leak Rates for CPNPP RXE-LA-CPX/0-103, Revision 1, Thermal-hydraulic Bases for the Success Criteria &
Accident Sequence Event Tree for the CPNPP PRA R&R-PN-013, Revision 5, Accident Sequences and Success Criteria EV-TR-2019-006419-6, Revision 0, CPNPP Plant Response to an Open Phase Condition, October 2019 AI-TR-2021-000006-35, CPNPP RICT Calculation Summary
ML22152A041 OFFICE NRR/DORL/LPLIV/PM NRR/DORL/LPLIV/LA NRR/DRA/APLA/BC NAME DGalvin PBlechman RPascarelli DATE 6/1/2022 6/1/2022 6/2/2022 OFFICE NRR/DRA/APLB/BC NRR/DRA/APLC/BC(A)
NRR/DEX/EICB/BC NAME JWhitman SVasavada MWaters DATE 6/8/2022 6/2/2022 6/10/2022 OFFICE NRR/DEX/EEEB/BC NRR/DSS/SNSB/BC NRR/DSS/STSB/BC NAME WMorton SKrepel VCusumano DATE 6/2/2022 6/1/2022 6/8/2022 OFFICE NRR/DORL/LPLIV/BC NRR/DORL/LPLIV/PM NAME JDixon-Herrity DGalvin DATE 6/10/2022 6/10/2022