ML25183A105
| ML25183A105 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/07/2025 |
| From: | Chris Speer NRC/RGN-IV/DORS |
| To: | Peters K Vistra Operations Company |
| Ramirez F | |
| References | |
| IR 2025010 | |
| Download: ML25183A105 (1) | |
Text
July 07, 2025 Ken Peters, Executive Vice President and Chief Nuclear Officer Vistra Operations Company, LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
NOTIFICATION OF BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION AND REQUEST FOR INFORMATION (05000445/2025010 AND 05000446/2025010)
Dear Ken Peters:
During the weeks of September 8 and September 22, 2025, the U.S. Nuclear Regulatory Commission (NRC) will conduct a Biennial Problem Identification and Resolution (PI&R) inspection at your facility. Four inspectors will perform this two-week inspection in accordance with NRC Inspection Procedure 71152, Problem Identification and Resolution. This inspection focuses on the corrective action program and its implementation to evaluate the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards. The team also evaluates the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. Finally, the team reviews the stations program to establish and maintain a safety-conscious work environment.
The schedule for the inspection is as follows:
Offsite Preparation Week:
September 2 to 5, 2025 Onsite Inspection Weeks:
September 8 to 12 and September 22 to 26, 2025 Note: The second week of inspection may be performed remotely in whole or in part as needed to complete the objectives of the inspection To minimize the inspection impact on the site and to ensure a productive inspection for both parties, we have enclosed a request for information. It is important that all these documents are up-to-date and complete to minimize the number of additional documents requested during the preparation and/or the on-site portions of the inspection. Please provide this information electronically to the lead inspector.
K. Peters 2
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 FOIA, Library and Information Collection Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, 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.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at https://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, Christopher Speer, Team Lead Generic Communications and Operating Experience Division of Reactor Oversight Docket No. 05000445, 05000446 License No. NPF-87, NPF-89
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Speer, Christopher on 07/07/25
SUNSI Review By: FCR
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE TL:DORS/IPAT TL:RSE/IOEB NAME FRamirez CSpeer SIGNATURE
/RA/
/RA/
DATE 07/03/25 07/07/25
Enclosure Information Request Biennial Problem Identification and Resolution Inspection Comanche Peak Nuclear Power Plant, Units 1 and 2 July 07, 2025 Inspection Report: 05000445/2025010 and 05000446/2025010 Onsite Inspection Dates: September 8 to 12, 2025, and September 22 to 26, 2025 Note: The second week of inspection may be performed remotely in whole or in part.
This inspection will cover the period from January 1, 2023, through September 26, 2025. All requested information is limited to this period or to the date of this request unless otherwise specified. To the extent possible, the requested information should be provided electronically in word-searchable Adobe PDF (preferred) or Microsoft Office format. To ensure appropriate handling, if you determine that any requested information is sensitive, the specific handling of this information should be discussed in advance between the NRC inspectors and the Comanche Peak representatives assigned to the Problem Identification and Resolution Inspection.
All requested documents should be provided electronically (e.g., Certrecs IMS) where possible. If an online inspection management system is used to provide the requested information, please ensure that all uploaded documents are searchable by title and identification number (for example, CR 1234567).
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable format. Please be prepared to provide any significant updates to this information by September 8, 2025, and as new information becomes available throughout the inspection. As used in this request, corrective action documents refers to condition reports, notifications, action requests, cause evaluations, and/or other similar documents, as applicable to Comanche Peak.
Please provide the following information no later than August 27, 2025:
1.
Document Lists Note: For these summary lists, please include the document/reference number, the document title, initiation date, current status, and long-text description of the issue. If there are fewer than 25 documents in the listing, the documents themselves may be provided rather than the listing if it is more convenient.
a.
Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period; b.
Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period
2 c.
Summary list of all condition reports related to non-conditions adverse to quality that were opened or closed during the period d.
Summary list of all apparent cause evaluations (or equivalent) performed during the period; e.
Summary list of all currently open corrective action documents associated with conditions first identified prior to the beginning of the inspection period; f.
Summary list of all corrective action documents that were upgraded or downgraded in priority/significance during the period (these may be limited to those downgraded from, or upgraded to, apparent cause level or higher);
g.
Summary list of all corrective action documents initiated during the period that identify an adverse or potentially adverse trend in safety-related or risk-significant equipment performance or in any aspect of the stations safety culture; h.
Summary lists of operator workarounds, operator burdens, temporary modifications, and control room deficiencies (1) currently open and (2) that were evaluated and/or closed during the period; this should include the date that each item was opened and/or closed; i.
Summary list of all prompt operability determinations or other engineering evaluations (or equivalent) to provide reasonable assurance of operability; j.
Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent) (sensitive information should be made available during the teams first weekdo not provide electronically) 2.
Full Documents with Attachments a.
All root cause evaluations completed during the period; include a list of any planned or in progress (if this information is fully included in item 1.a, it need not be provided separately) b.
Quality Assurance audits performed during the period c.
Audits/surveillances performed during the period on the Corrective Action Program, of individual corrective actions, or of cause evaluations d.
Functional area self-assessments and non-NRC third-party assessments (e.g.,
peer assessments performed as part of routine or focused station self-and independent assessment activities; do not include INPO assessments) that were performed or completed during the period; include a list of those that are currently in progress
3 e.
Any assessments of the safety conscious work environment at Comanche Peak including any safety culture survey results; if none performed during the inspection period, provide the most recent assessments and/or survey results f.
Corrective action documents generated during the period associated with the following:
i.
NRC findings and/or violations issued to Comanche Peak ii.
Licensee Event Reports issued by Comanche Peak Please provide a crosswalk or key tying corrective action documents to the specific finding, violation, or event report.
g.
Corrective action documents generated for the following, if they were determined to be applicable to Comanche Peak (for those that were evaluated but determined not to be applicable, provide a summary list;:
i.
NRC Information Notices, Bulletins, and Generic Letters issued or evaluated during the period ii.
Part 21 reports issued or evaluated during the period iii.
Vendor safety information letters (or equivalent) issued or evaluated during the period iv.
Other external events and/or operating experience evaluated for applicability during the period h.
Corrective action documents generated for the following:
i.
Maintenance preventable functional failures that occurred or were evaluated during the period ii.
Adverse trends in equipment, processes, procedures, or programs that were evaluated during the period iii.
Action items generated or addressed by offsite review committees during the period
- 3. Logs and Reports a.
Corrective action performance trending/tracking information generated during the period and broken down by functional organization (if this information is fully included in item 3.b, it need not be provided separately) b.
Current system health reports, Management Review Meeting packages, or similar information; provide past reports as necessary to include greater-than-or-equal to 12 months of metric/trending da
4 c.
Radiation protection event logs during the period d.
Security event logs and security incidents during the period (sensitive information should be made available during the teams first weekdo not provide electronically) - Handling of this item will need additional discussion e.
Employee Concerns Program (or equivalent) logs (sensitive information should be made available during the teams first week of inspectiondo not provide electronically) (if this information is fully included in item 1.j, it need not be provided separately) f.
List of training deficiencies, requests for training improvements, and simulator deficiencies for the period Note: For items 3.c and 3.d, if there is no log or report maintained separate from the corrective action program, please provide a summary list of corrective action program items for the category described.
4.
Procedures Note: For these procedures, please include all revisions that were in effect at any time during the period.
a.
Corrective action program procedures, to include initiation and evaluation procedures, operability determination procedures, cause evaluation procedures, and any other procedures that implement the corrective action program at the station, including applicable corporate procedures b.
Quality Assurance program procedures (specific audit procedures are not necessary) c.
Employee Concerns Program (or equivalent) procedures d.
Procedures that implement/maintain a Safety Conscious Work Environment e.
Conduct of Operations procedure (or equivalent) and any other procedures or policies governing control room conduct, operator burdens and workarounds, etc.
f.
Maintenance rule procedures and any procedures implementing any portion of the maintenance rule at the station g.
Operating experience program procedures and any other procedures or guidance documents that describe the sites use of operating experience information h.
Procedures associated with the 10 CFR Part 21 program
5 5.
Other a.
List of risk-significant components and systems, ranked by risk worth; if the list uses system designators, provide a list of the associated equipment/system names b.
List of structures, systems and components and/or functions that were in maintenance rule (a)(1) status or evaluated for (a)(1) status at any time during the inspection period; include dates and results of expert panel reviews and dates of status changes c.
Organization charts for plant staff and long-term/permanent contractors d.
Table showing the number of corrective action documents (or equivalent) initiated during each month of the inspection period, by screened significance e.
Table showing the number of anonymous corrective action documents (or equivalent) initiated during each month of the inspection period; f.
For each day the team is inspecting, provide the following:
i.
Planned work/maintenance schedule for the station (for onsite days only) ii.
Schedule of management, maintenance rule, corrective action related, or corrective action review meetings (e.g. operations focus meetings, condition report screening meetings, Corrective Action Review Boards, Management Review Meetings, challenge meetings for cause evaluations, etc.)
iii.
Agendas and materials for these meetings g.
Provide a copy of Comanche Peaks probabilistic risk assessment (PRA) summary document for the current internal events, external events (e.g., fire, flooding, seismic), and shutdown PRA models of record, as applicable.
6.
Focused System or Area Review(s) (system to be designed at a later date) a.
System design basis documents b.
Quarterly system health reports, maintenance rule determinations, 50.59 screens/evaluations, apparent and root cause evaluations c.
A listing of all condition reports associated with the system with a brief description of the condition and the significance/categorization in the corrective action program d.
A listing of work orders associated with the system, including their status as completed, pending, or cancelled
6 e.
Engineering walkdown schedule f.
Operating Procedures/Abnormal Operating Procedures/Emergency Operating Procedures g.
Work orders from system maintenance outages Additionally, please note that systems or areas for increased inspection focus may be identified in the coming weeks, and additional documentation may be requested. The inspection for the focused system will cover the period from September 8, 2020 to September 8, 2025
[going back 5 years].
Christopher Speer U.S. NRC Inspector, Reactor Systems Engineer Generic Communications and Operating Experience Branch Division of Reactor Oversight, NRC HQ 11555 Rockville Pike, Rockville, MD 20852 Chris.Speer@NRC.gov