ML23226A007
| ML23226A007 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/11/2023 |
| From: | Dennis Galvin NRC/NRR/DORL/LPL4 |
| To: | Hicks J Vistra Operations Company |
| References | |
| L-2023-LLA-0057 | |
| Download: ML23226A007 (6) | |
Text
From: Dennis Galvin Sent: Friday, August 11, 2023 4:53 PM To: Jack Hicks (Jack.Hicks@luminant.com)
Cc: Nic Boehmisch (Nicholas.Boehmisch@luminant.com)
Subject:
Comanche Peak Units 1 and 2 - Audit Plan - License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors (EPID L-2023-LLA-0057)
Attachments: Comanche Peak 50.69 LAR Audit Plan - 2023-08-11.pdf
Dear Mr. Hicks,
By letter dated April 19, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23109A333), as supplemented by letter dated June 8, 2023 (ML23159A200), Vistra Operations Company LLC (Vista OpCo, the licensee) submitted a license amendment request (LAR) for Comanche Peak Nuclear Power Plant, Units 1 and 2. The licensee requested to adopt Title 10 of the Code of Federal Regulations, Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, into its licensing basis.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit would support its review of the proposed alternative. The audit will be conducted via online access to non-docketed information set up by the licensee and via webinar as described in the attached audit plan. 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 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: 2192 Mail Envelope Properties (SA1PR09MB81111642F616FCF1D9A9288BFB10A)
Subject:
Comanche Peak Units 1 and 2 - Audit Plan - License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors (EPID L-2023-LLA-0057)
Sent Date: 8/11/2023 4:53:00 PM Received Date: 8/11/2023 4:52:00 PM From: Dennis Galvin Created By: Dennis.Galvin@nrc.gov Recipients:
"Nic Boehmisch (Nicholas.Boehmisch@luminant.com)" <Nicholas.Boehmisch@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 1603 8/11/2023 4:52:00 PM Comanche Peak 50.69 LAR Audit Plan - 2023-08-11.pdf 290039 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO ADOPT THE REQUIREMENTS OF 10 CFR 50.69 RISK-INFORMED CATEGORIZATION OF SSCs VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446
1.0 BACKGROUND
By letter dated April 19, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23109A333), as supplemented by letter dated June 8, 2023 (ML23159A200), Vistra Operations Company LLC (Vista OpCo, the licensee) submitted a license amendment request (LAR) for Comanche Peak Nuclear Power Plant, Units 1 and 2.
The licensee requested to adopt Title 10 of the Code of Federal Regulations, Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, into its licensing basis.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal and determined that a regulatory audit of the information identified in the Information Request section below would assist in the timely completion of the subject LAR review process. The NRC staff is continuing to review other aspects of the licensees submittal and may identify the need for additional audit subjects by separate correspondence.
2.0. REGULATORY AUDIT BASES An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this LAR review. The NRC staff will have an opportunity to minimize the potential for request 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. The NRC staff is requesting an initial set of internal licensee information to be audited by the staff using an online reference portal. Upon completion of this audit, the NRC staff is expected to achieve the following.
- 1. Confirm internal licensee information that supports statements made in the LAR.
- 2. Determine whether the information included in the documents is necessary to be submitted to support a safety conclusion.
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.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The purpose of the remote audit is to gain a more detailed understanding of the licensees process to implement risk-informed categorization and treatment of structures, systems and components as proposed in the LAR. The NRC staff will audit internal events and fire probabilistic risk assessment (PRA) and the risk informed approach implementing 10 CFR 50.69.
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 documentation (e.g., methodology, process information, calculations, etc.) identified below.
The 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).
4.0 INFORMATION REQUESTS 1 The NRC staff requests that the following information be made available for audit:
- 1. Applicable peer review reports and closure reports for internal events, internal flooding and fire PRAs.
- 2. Available 10 CFR 50.69 structures, systems, and components categorization program procedures (i.e., Categorization review and adjustment process, decision criteria for Independent Decision-Making Panel (IDP), etc.).
- 3. Uncertainty notebooks for internal events, internal flooding, and fire PRAs related to PRA model assumptions and sources of uncertainty.
- 4. Documentation of review of PRA model assumptions and sources of uncertainty and identification of key assumptions and sources of uncertainty for the application identified in the LAR.
- 5. PRA notebooks for the modeling of Flexible and Diverse Coping Strategies (FLEX) equipment and FLEX human error probabilities, if credited in the PRA.
- 6. R&R PN-205
- 7. R&R PN-041
- 8. CN-RAM-13-038 5.0 AUDIT TEAM Key licensee personnel involved in the development of the LAR should be made available for interactions on a mutually agreeable schedule to respond to any questions from the NRC staff.
1 R&R PN-205, R&R PN-041 and CN-RAM-13-038 were cited in the June 8, 2023, supplement but no titles were provided.
Team Member Division Area of Responsibility Dennis Galvin NRR/DORL/LPL4 Project Management Dennis.Galvin@nrc.gov Ching Ng NRR/DRA/APLA Technical Review Ching.Ng@nrc.gov Mihaela Biro NRR/DRA/APLA Technical Review Mihaela.Biro@nrc.gov De (Wesley) Wu NRR/DRA/APLA Technical Review De.Wu@nrc.gov Stacey Rosenberg NRR/DRA/APLC Technical Review Stacey.Rosenberg@nrc.gov Steve Short Pacific Northwest National Technical Review Steve.Short@pnnl.com Laboratory To be determined Pacific Northwest National Technical Review Laboratory 6.0 LOGISTICS The virtual audit will be conducted from August 8, through December 31, 2023, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by the licensee.
The initial NRC staff desk audit will be conducted over several weeks. The NRC project manager will coordinate with the NRC staff and licensee for any webinars needed after the NRC staff has reviewed the documentation. The audit will include interactions (e.g., webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available. The audit teams access to the online portal may be terminated after completion of the virtual audit at a time established by the NRC project manager.
7.0 SPECIAL REQUESTS The audit team would like access to the documents listed in section 4.0 above through an online portal that allows the audit team to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff. The NRC staff who should be granted access to the portal are those listed in the Audit Team section of this document. All other communications should be coordinated with the NRC project manager.
8.0 DELIVERABLES An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee. Alternatively, the licensee can voluntarily submit a supplement to its licensing request to provide the NRC staff identified information need.