ML24018A107

– Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information

ML24018A107
Person / Time
Site:	Comanche Peak
Issue date:	01/18/2024
From:	Vincent Gaddy NRC/RGN-IV/DORS/EB1
To:	Peters K Vistra Operations Company
References
IR 2024012
Download: ML24018A107 (9)

See also: IR 05000445/2024012

Text

January 18, 2024

Ken Peters

Senior Vice President and Chief Nuclear Officer

Vistra Operations Company

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT - NOTIFICATION OF

COMMERCIAL GRADE DEDICATION INSPECTION (05000445/2024012 AND

05000446/2024012) AND REQUEST FOR INFORMATION

Dear Ken Peters:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff

will conduct the commercial grade dedication baseline inspection at Comanche Peak Nuclear

Power Plant, Units 1 and 2, beginning on April 29, 2024. The inspection team will be composed

of three personnel from the NRC Region IV office. The inspection will be conducted in

accordance with NRC inspection procedure (IP) 71111.21N.03, Commercial Grade

Dedication, dated February 16, 2023.

The inspection will evaluate the implementation of Comanche Peak Nuclear Power Plants

process for dedicating commercial grade items, as required in applicable portions of Appendix B

to Title 10 of the Code of Federal Regulations Part 50, to ensure reasonable assurance is

provided that these items will perform their intended safety function. Additionally, this inspection

will evaluate implementation of Comanche Peak Nuclear Power Plants procurement process for

safety-related structures, systems, and components, as required in Appendix B.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

• Onsite Information Gathering Visit: February 26-29, 2024

• Offsite Preparation Week: April 22-25, 2024

• Onsite Inspection Weeks: April 29 - May 2, 2024 and May 13-16, 2024

The purpose of the information gathering visit is to meet with your staff to become familiar with

the process for dedicating commercial grade items and the process for procuring safety-related

structures, systems, and components at Comanche Peak Nuclear Power Plant. A high-level

presentation of site-specific commercial grade dedication and safety-related procurement

activities would be beneficial. This visit may include a tour of onsite commercial grade item

dedication facilities, receipt inspection facilities, storage facilities, and installed plant

components associated with potential inspection samples. During the visit, the team lead will

also review the information provided in the initial information request to select a list of potential

K. Peters 2

inspection samples. The team lead may also identify other information needed to support the

inspection during this visit.

To minimize the impact on your staff and to ensure an effective and efficient inspection, we

have enclosed two separate requests for information needed prior to the onsite information

gathering visit and offsite inspection preparation week. The first request (Enclosure 1) is

generally for information that will be used to choose the inspection samples or information that

will be applicable to all inspection samples throughout the inspection. This information should

be made available to the team lead prior to the information gathering visit. The second request

(Enclosure 2) is for information that is specific to an individual sample and should be made

available prior to the offsite preparation week.

Additional information requests, interviews with your staff, and/or walkdowns of facilities or

installed plant components will be made by the team throughout the inspection to complete their

review of the selected inspection samples. It is important that all documentation provided to the

team is complete and upto-date to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection. Additionally, to facilitate an

efficient 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.

We understand that Mr. Ryan Sexton from your Regulatory Affairs organization is our contact

for this inspection. If there are any questions about the inspection or the information requested,

please contact the team lead, Mr. Wes Cullum, by telephone at 817-200-1563 or by email at

wes.cullum@nrc.gov. Enclosure 3 contains additional contact information for the inspection

team.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, under Control Number

3150-0011. The NRC may not conduct or 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 Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC rules and practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC public document

room or from the publicly available records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC website.

Sincerely,

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

Signed by Gaddy, Vincent

on 01/18/24

K. Peters 3

Docket No.05000445, 05000446

License No. NPF-87, NPF-89

Enclosures:

1. Documents Requested Prior to

Information Gathering Visit

2. Documents Requested Prior to

Inspection Preparation Week

3. Inspection Team Contact Information

cc w/ encl: Distribution via LISTSERV

ML24018A107

X Non-Sensitive X Publicly Available

X SUNSI Review

Sensitive Non-Publicly Available

OFFICE BC:DORS/EB1 SRI:DORS/EB1

NAME VGaddy WCullum

SIGNATURE /RA/ /RA/

DATE 01/18/24 01/18/24

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both onsite and offsite during the information gathering visit.

Electronic format is the preferred media. If electronic media is made available via an internet

based remote document management system, then the remote document access must allow

inspectors to download, save, and print the documents in the NRC's regional office. Electronic

media on compact disc or paper records (hardcopy) are acceptable. At the end of the

inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by February 19, 2024:

1. Copy of procedures for dedicating commercial grade items/services, procuring

safety-related structures, systems, and components (SSCs), performing receipt

inspections, controlling counterfeit, fraudulent, and suspect items, and 10 CFR Part

21 evaluations and reporting.

2. Sortable list of commercial grade items/services that completed the dedication

process within the past six years. These items/services may have been dedicated

by Comanche Peak Nuclear Power Plant or by a vendor (or other licensee) and

procured by Comanche Peak Nuclear Power Plant. Include, as applicable, relevant

information such as the item/services material/catalog identification number and

description, parent/host equipment identification number and description, purchase

order number, installation work order/job number, and date of issue/installation.

3. Sortable list of SSCs that were procured as safety-related within the past six years.

Include, as applicable, relevant information such as the SSCs material/catalog

identification number and description, parent/host equipment identification number

and description, purchase order number, installation work order/job number, date of

issue/installation, and end-use safety classification.

4. Sortable list of dedicated commercial grade items/services or procured safety-related

SSCs that were placed on hold within the past six years because of concerns

identified during receipt, dedication, or from operating experience or the corrective

action program as applicable.

5. Sortable list of dedicated commercial grade items/services or procured safety-related

SSCs, with a brief description, where dedication/procurement activities were

expedited within the past six years.

6. Sortable list of dedicated commercial grade-items/services or procured safety-related

SSCs that failed after completing dedication/procurement activities or required

corrective maintenance within the past six years.

Enclosure 1

7. Sortable list of corrective action program documents, with a brief description, related

to commercial grade item/service dedication, safety-related SSC procurement,

receipt inspection, and storage activities within the past six years.

8. Copy of any self-assessments or audits of commercial grade item/service dedication

and/or safety-related SSC procurement activities performed within the past six years.

9. Copy of the updated final safety analysis report, operational quality assurance

program description, technical specifications, and technical requirements manual,

including applicable bases documents.

10. Sortable list of systems, including identifying designators and corresponding names.

11. List of individuals who will be supporting the inspection and their contact information.

2

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both onsite and

offsite during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hardcopy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested by April 15, 2024:

1. Complete commercial grade item dedication package including relevant

documentation such as the following, as applicable: description of item/service,

identification of safety functions and safety classifications of item/parent component,

like-for-like or equivalency evaluations, credible failure modes/failure modes and

effects analysis, critical characteristics and acceptance criteria, identification of the

suppliers commercial quality assurance program or other documented controls.

2. Complete purchase order including relevant documentation such as the following, as

applicable: purchase requisition, catalog specifications, item product data

sheets/vendor manuals, shelf-life information, service/qualified life information,

certificates of conformance/compliance/quality, vendor test and inspection reports,

third-party or sub vendor test and inspection results, vendor dedication or partial

dedication information, material receiving reports, packing list/invoices or other

shipping documents, and other pertinent vendor/licensee correspondence.

3. Receipt inspection reports and any related test reports, documents noting any

deviations from design, material, and performance characteristics relevant to the

safety function (nonconformance dispositions).

4. Documents showing objective evidence of special test and inspection procedures

used to verify technical and quality requirements have been met, commercial grade

survey reports, or source verification reports; any other documents to trace the item

from the time it was dedicated to the time it was installed, tested, and accepted.

5. Completed installation work orders and stock or material issue forms; completed

post-installation test procedures and results.

Enclosure 2

6. Design basis information of the inspection sample or parent/host component such

as: normal/accident service environment, normal/accident performance

requirements, design basis document/system description, relevant UFSAR/technical

specification sections, calculation/drawing/procedure updates, etc.

7. 10 CFR 50.59 documentation, if required.

8. Sortable list of corrective action program documents, with a brief description,

associated with the inspection sample or parent/host equipment.

2

Enclosure 3

Inspection Team Contact Information

Wes Cullum (Lead) Rayo Kumana Fabian Thomas

Senior Reactor Inspector Senior Reactor Inspector Reactor Inspector

817-200-1563 817-200-1426 817-200-1126

Wes.cullum@nrc.gov Rayo.kumana@nrc.gov Fabian.thomas@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Wes Cullum

1600 East Lamar Blvd.

Arlington, TX 76011-4511

Enclosure 3