ML22304A191

– Aging Management Audit Plan Regarding the License Renewal Application Review

ML22304A191
Person / Time
Site:	Comanche Peak
Issue date:	11/23/2022
From:	Lauren Gibson NRC/NRR/DNRL/NLRP
To:	Peters K Comanche Peak Nuclear Power Co
References
Download: ML22304A191 (10)

Text

November 23, 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, UNITS 1 AND 2 - AGI NG MANAGEMENT AUDIT PLAN REGARDING THE LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Peters:

By letter dated October 3, 2022, (Agencywide Documents Access a nd Management System (ADAMS) Accession No. ML22276A082), V istra Operations Company L LC (Vistra or the applicant) submitted an application for license renewal of Faci lity Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Un its 1 and 2, to the U.S.

Nuclear Regulatory Commission (NRC or staff). Vistra submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requireme nts for Renewal of Operating Licenses for Nuclear Power Plants, for license renewal.

The NRC plans to conduct an Aging Management Audit from Decembe r 12, 2022 -

March 27, 2023, in accordance with the enclosed regulatory audi t plan. The Aging Management Audit will be conducted at NRC Headquarters and CPNP P site, as appropriate. If you have any questions, please contact Emmanuel Sayoc at 301-41 5-4048 or by e-mail at emmanuel.sayoc@nrc.gov.

Sincerely,

/RA/

Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses OfficeofNuc lear Reactor Regulation

Docket Nos. 50-445 and 50-446

Enclosure:

Aging Management Audit Plan cc: w/encl.: ListServ

ML22304A191 *via email NRR-106 OFFICE PM/NLRP/DNRL LA/NLRP/DNRL NAME ESayoc YEdmonds DATE 10/31/2022 11/7/2022 OFFICE PM/NLRP/DNRL BC/NLRP/DNRL NAME ESayoc LGibson DATE 11/16/2022 11/23/2022 Audit Plan

Comanche Peak Nuclear Power Plant, Units 1 and 2 License Renewal Application Aging Management Regulatory Audit

December 12, 2022 - March 27, 2023

Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Enclosure Audit Plan Comanche Peak Nuclear Power Plant, Units 1 and 2 License Renewal Application Aging Management Regulatory Audit

1. Background

By letter dated October 3, 2022, (Agencywide Documents Access a nd Management System (ADAMS) Accession No. ML22276A082), Vistra Operations Co mpany LLC (Vistra or the applicant) submitted an application for license renewal of Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (C PNPP), Units 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC or staff).

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, Requirements for Renewal of Operating Licenses for Nu clear Power Plants, NRC staff will perform an aging management regulatory audit to gain a better understanding of (1) the applicants methodology to identify the systems, struct ures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR), and (2) the applicants aging management programs (AMPs), AMR items, time-limited aging analyses (TLAAs), and associated bases and d ocumentation as applicable.

2. Regulatory Audit Bases

License renewal requirements are specified in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Guidance is provi ded in NUREG-1800, Rev. 2, Standard Review Plan for Review of License Renewal Application s for Nuclear Power Plants (SRP-LR), dated December 2010, and NUREG-1801, Rev. 2, Generic Aging Lessons Learned (GALL) Report, dated December 2010.

3. Regulatory Audit Scope of Review

Operating Experience Review

The scope of this license renewal regulatory audit of CPNPP is the staffs independent review of plant specific operating experience (OE). The review is perfor med to identify pertinent examples of age-related degradation, as documented in the appli cants corrective action program database. The results of the audit will be used to sup port the staffs further review of aging management programs (AMP), time limited aging analyses (T LAAs) and aging management review line items to provide a basis for the staffs conclusions on the ability of the applicants proposed AMP and TLAAs to manage the effects of agi ng in the period of extended operation.

The staff will use risk insights to focus the breadth and depth of its review of plant specific operating experience. However, the staffs review is not limit ed to risk significant systems and components because 10 CFR Part 54 is a deterministic rule. The staff must conclude that there is reasonable assurance that activities will continue to be con ducted in accordance with the current licensing basis and the effects of aging will be manage d during the period of extended operation for all structures and components within the scope of 10 CFR Part 54.

Scoping and Screening Review

The purpose of the scoping and screening review is to evaluate the applicants scoping and screening methodology used to identify SSCs within the scope of license renewal and subject to AMR, and the results of the implementation of the methodology. The review is performed by evaluating the scoping and screening process and results, as do cumented in the license renewal application (LRA), implementing procedures, reports, an d drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SS Cs within the scope of license renewal and to identify the structures and component s subject to an AMR; and

• Has sufficient docketed information to allow the NRC staff to r each a conclusion on the adequacy of the scoping and screening methodology results, as documented in the LRA.

AMP, AMR, and TLAA Review

The scope of the AMP, AMR, and TLAA review is to: (a) examine t he applicants AMPs, AMR items, and TLAAs; (b) verify the applicants claims of consiste ncy with the corresponding GALL-SLR Report AMPs, and AMR items; and (c) assess the adequac y of the TLAAs.

Enhancements and exceptions will be evaluated on a case-by-case basis with the results documented in the safety evaluation.

The NRC staff will audit Program Elements 1 - 10 (scope, preven tive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrat ive controls, and operating experience (OE)) of the AMPs against the elements of the associ ated AMP described in the GALL-SLR Report. In addition, the NRC staff will verify that t he conditions at the plant are bounded by the conditions for which the GALL-SLR Report program was evaluated.

The NRC staff will also examine the applicants program bases d ocuments and related references for AMPs, AMR items, and TLAAs, and interview applic ant representatives to obtain additional clarification.

The NRC staff will use risk insights to inform the prioritizati on of its review of documentation associated with AMPs, AMR items, and TLAAs and to focus the bre adth and depth of its review of plant specific operating procedures and OE. However, the NRC staffs review is not limited to risk-significant systems and components because 10 C FR Part 54 is a deterministic rule and the NRC staff must conclude that there is reasonable a ssurance that activities will continue to be conducted in accordance with the current licensi ng basis and the effects of aging will be managed during the period of extended operation f or all structures and components within the scope of 10 CFR Part 54.

The NRC staff has reviewed the list of risk-significant systems and components provided by the applicant to inform the establishment of priorities for the performance of the scoping and screening review.

4. Audit Activities

Throughout the Aging Management Audit technical staff will cond uct a technical review of the LRA, as supplemented and revised, the AMP basis documents, lice nse renewal drawings, and other CPNPP supporting documents, as appropriate and requested, on the applicants electronic portal (ePortal). The project team requires continu ed CPNPP document review capability via the ePortal throughout the audit process. Docum ent requests for upload to the ePortal shall be made as needed via the NRC safety project mana ger to the appropriate applicant licensing manager.

The Aging Management Audit will consist of four parts, schedule d, and coordinated between the NRC staff and the applicant. Each audit part allows the applic ant to provide context on the ePortals contents and configuration, the methods used to devel op the LRA, the corresponding results, and any areas unique to the CPNPP LRA. The staff will have the opportunity to have discipline-specific discussions with the applicant to discuss t he approaches used for evaluation and development of AMPs, TLAAs, AMR items, with the considerati on of OE. In addition, the staff may identify specific technical areas where the staff wou ld benefit from a presentation or discussion to provide additional context to support the staffs review. The staff is to review the information needed to perform the safety review and use the inf ormation, to the extent possible, to begin developing draft input for the SER (resulting in an S ER with open items).

At the conclusion of the staffs technical review, the staff wi ll identify any areas requiring inclusion in appropriate formal audit parts outlined below. Th e four Aging Management Audit parts include:

• Part 1: In-Office Operating Experience Audit

The staff will review:

(1) Applicants Process to Identify OE Used in Development of A MPs. The staff requests that the applicant provides a presentation on the proc ess used to identify and evaluate the pertinent OE that was used to inform the developme nt of the AMPs as discussed in the LRA and basis documentation.

(2) Use of OE Contained in AMP Report-Out Documents. The staff requests that the applicant discuss how the OE contained in the AMP report-out do cuments (e.g., reports of inspections, assessments, AMP effectiveness reviews) is in a lignment with information contained in the corrective action program (CAP) da tabase and how the process described in (1) along with the use of the report-out i nformation would include any pertinent OE otherwise contained in the CAP database. The applicant should demonstrate that OE identified by the process or included in th e report-out documents is bounding of OE that should be considered for developing the LRA. Additionally, the applicant should provide examples of the report-out documents a nd corresponding corrective action reports.

(3) Staffs Review of Age-Related OE Contained in the CAP Datab ase. Following the applicants presentations on the process to identify and evalua te OE as well as the information included in the report-out documents, the staff sho uld determine if there are any specific areas of OE that have not been sufficiently addres sed or if there is a need to sample the information discussed by the applicant to verify the applicants results. If the staff identifies such a need, the staff will have an opportunit y to perform an independent

review of age-related OE contained in the CAP database, as nece ssary, to provide reasonable assurance that the applicant has adequately identifi ed and evaluated pertinent OE in the development of the LRA in Part 2 of the Agi ng Management Audit.

• Part 2: On-Site Scoping and Screening Audit

The applicant presents on references, tools, procedures and rep orts, and approach to scoping and screening methodology developed and applied to meet the requirements of 10 CFR 54.4(a) and 10 CFR 54.21. The presentation includes tec hnical references used for scoping and screening - updated final safety analysis report (UFSAR),

equipment database, Maintenance Rule information, program tools used for License Renewal Application development (database), implementing proced ures, guidance documents and reports, and the plant structural layout.

The staff, with the assistance of the applicant, will conduct a detailed review of scoping and screening methodology for mechanical, electrical, and struc tural systems and components (SCs). As applicable, the review will include imple menting procedures; source information; electronic databases; definition of safety-related; design bases events consideration; identification of SSCs within scope; iden tification of intended functions; scoping/screening boundaries; license renewal drawin gs; identification of SCs subject to AMR; exceptions taken to Nuclear Energy Institute 95 -10, Appendix F, and scoping and screening reports. The review may also include dis cussions of commodities, consumables, insul ation, overhead handling systems, abandoned equipment, and staged equipment, as applicable.

As necessary, the Staff will conduct walkdowns of SCs within th e scope of license renewal in accordance with 10 CFR 54.4(a). The walkdown includ es a review of areas, rooms or structures containing a combination of SCs within the scope of license renewal.

• Part 3: On-Site Audit

The purpose of the On-Site Audit is to make visual observations of areas, equipment conditions, and configurations, and will be performed by an int egrated review team. The On-Site Audit will target specific areas, equipment, and system s, and the staff shall provide the applicant with the audit scope prior to the On-Site Audit to ensure access and to verify that licensee support is available.

Part 4: In-Office Breakout Sessions

During the In-Office Breakout Sessions, the NRC staff will have the opportunity to discuss various basis documents, license renewal drawings, refe rences, condition/corrective action reports, and to obtain additional c larification related to the LRA safety review with the applicant.

The NRC staff will hold breakout se ssions, via electronic means, of communication with NRC staff and CPNPP subject matter experts to discuss various b asis documents, references, condition/corrective action reports, and interview CPNPP representatives to obtain additional clarification related to the license renewal review. Breakout sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC staff and CPNPP representatives. NRC staf f will provide discussion topics and technical requests and questions to the N RC safety project

manager, who will then relay the information to the CPNPP licen sing manager. Any information requests transmitted to the applicant will be inclu ded in the audit report. All breakout sessions will be coordinated via the NRC safety projec t manager and the CPNPP licensing manager.

Each of the four parts of the Aging Management Audit will provi de the staff the opportunity to have technical discussions with the applicant to gain clarity a nd information regarding the LRA.

The audit is coordinated to support the development of the revi ewers reasonable assurance for the safety finding to be documented in the SER. The staff may require additional information from the applicant for some technical areas, while finding that information on the ePortal is sufficient for other technical areas. Accordingly, some techni cal areas may not require inclusion in Part #3, the On-Site Audit. The NLRP safety project manager will coordinate all communications with the applicant. Staff requests for communic ation with the applicant will require approval of their respective technical branch chief and the NLRP branch chief.

5. Information and Other Material Necessary for the Regulatory Aud it

Throughout the Aging Management Audit, the staff will review th e LRA, as supplemented and revised, the AMP basis documents and other app licant supporting documents as appropriate and requested, which have been uploade d to the ePortal.

The staff may request additional applicant documents to be adde d to the ePortal during the course of the audit. The staff requests for ePortal additions shall be made, as needed, to the safety project manager, who will provide the requests to the ap plicant.

All documents used as the basis for the staffs review will be documented in the audit report.

6. Team Members

Team Member Branch/Division License Renewal Projects Branch (NLRP)/Division of New and Emmanuel Sayoc Renewed Licenses (DNRL)

Lauren Gibson NLRP/DNRL Billy Rogers NLRP/DNRL Jessica Hammock NLRP/DNRL Allen Hiser Jr DNRL John Wise DNRL Steven Bloom Corrosion and Steam Generator Branch (NCSG)/DNRL Andrew Johnson NCSG/DNRL Brian Allik NCSG/DNRL Gregory Makar NCSG/DNRL Joel Jenkins NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado Guilloty NCSG/DNRL Matthew Yoder NCSG/DNRL Paul Klein NCSG/DNRL Reena Boruk NCSG/DNRL Tony Gardner NCSG/DNRL

James Gavula NCSG/DNRL Matthew Mitchell Piping and Head Penetrations Branch (NPHP)/DNRL Ali Rezai NPHP/DNRL Bart Fu NPHP/DNRL Karen Sida NPHP/DNRL Mat Burton NPHP/DNRL Varoujan Kalikian NPHP/DNRL Seung Min NPHP/DNRL Jay Collins NPHP/DNRL Angela Buford Vessels and Internals Branch (NVIB)/DNRL Carol Moyer NVIB/DNRL Carolyn Fairbanks NVIB/DNRL Cory Parker NVIB/DNRL David Dijamco NVIB/DNRL Emma Haywood NVIB/DNRL James Medoff NVIB/DNRL John Tsao NVIB/DNRL Michael Benson NVIB/DNRL On Yee NVIB/DNRL Electrical Engineering Branch (EEEB)/Division of Engineering and Wendell Morton, Wendell External Hazards (DEX)

Adakou Foli EEEB/DEX Jason Paige, Jason Long Term Operations and Modernization Branch (ELTB)/DEX Liliana Ramadan ELTB/DEX Matthew McConnell ELTB/DEX Gurcharan Matharu ELTB/DEX Jorge Cintron-Rivera ELTB/DEX Bryce Lehman Structural, Civil, Geotech Engineering Branch (ESEB)/DEX George Wang ESEB/DEX Zuhan Xi ESEB/DEX Ata Istar ESEB/DEX Andrew Prinaris ESEB/DEX George Thomas ESEB/DEX Jen Whitman PRA Licensing B (APLB)/Division of Risk Assessment (DRA)

Naeem Iqbal APLB/DRA Thinh Dinh APLB/DRA Containment and Plant Systems (SCPB)/Division of Safety Systems Brian Wittick, Brian (DSS)

Brian Lee SCPB/DSS Chang Li SCPB/DSS Nageswara Karipineni SCPB/DSS Angelo Stubbs SCPB/DSS Diana Woodyatt Nuclear Systems Performance Branch (SNSB)/DSS Christopher Jackson SNSB/DSS Adam Rau SNSB/DSS

7. Logistics

The Aging Management Audit will be c onducted primarily via electronic means. Entrance and exit briefings will be held at the beginning and end of each au dit.

On-Site Audits will be done at CPNPP and portions of the audit shall be done with electronic means, as needed, to allow NRC staff to participate remotely. The Audits schedules, which were coordinated with the NRC staff and the applicant are follo ws:

In-Office Operating Experience Audit: December 12 - 16, 2022

On-Site Scoping and Screening Audit: January 9-13, 2023

On-Site Audit: January 30, 2023 - February 20, 2023

In-Office Breakout Sessions: February 27, 2023 - March 27, 202 3

8. Special Requests

The NRC staff requests the applicant to make available the lice nse renewal application program basis documentation and drawings, and other documents a s requested.

9. Deliverables

An audit report should be issued to the applicant within 90 day s from the end of the Aging Management Audit.