ML22228A094

Notification of Inspection (NRC Inspection Report 05000445/2022004 and 05000446/2022004) and Request for Information

ML22228A094
Person / Time
Site:	Comanche Peak
Issue date:	08/17/2022
From:	Heather Gepford NRC/RGN-IV/DORS/OB
To:	Peters K Vistra Operations Company
Bergeon B
References
IR 2022004
Download: ML22228A094 (8)

See also: IR 05000445/2022004

Text

August 17, 2022

Mr. Ken J. Peters

Senior Vice President and Chief Nuclear Officer

Attention: Regulatory Affairs

Vistra Operations Company LLC

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT - NOTIFICATION OF

INSPECTION (NRC INSPECTION REPORT 05000445/2022004 AND

05000446/2022004) AND REQUEST FOR INFORMATION

Dear Mr. Peters:

During the week of October 24, 2022, two inspectors from the U.S. Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline biennial requalification

inspection at Comanche Peak Nuclear Power Plant, using NRC Inspection

Procedure 71111.11B, Licensed Operator Requalification Program.

Experience has shown that this inspection is a resource intensive inspection both for the NRC

inspectors and your staff. In order to minimize the impact to your onsite resources and to

ensure a productive inspection, we have enclosed a request for documents needed for this

inspection. These documents have been divided into three groups:

The first group (Section A of the enclosure) identifies information to be provided prior to

the inspection to ensure that the inspectors are adequately prepared.

The second group (Section B of the enclosure) identifies the information the inspectors

will need upon arrival at the site.

The third group (Section C of this enclosure) identifies the items which are necessary to

close out the inspection and are usually sent a few weeks after the team has left the site.

It is important that all of these documents are up to date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Mr. Terry Jank of your training organization.

Our inspection dates are subject to change based on your updated schedule of examination

activities. If there are any questions about this inspection or the material requested, please

contact the lead inspector, Bryan Bergeon at (817) 200-1415 (Bryan.Bergeon@nrc.gov).

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 Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, 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.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter

and its enclosure 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 web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Signed by Gepford, Heather

on 08/17/22

Heather J. Gepford, Chief

Operations Branch

Division of Operating Reactor Safety

Docket No. 50-445; 50-446

License No. NPF-87; NPF-89

Enclosure:

Biennial Requalification Inspection

Request for Information

ML22228A094

OFFICE OE:OB C:OB

NAME BBergeon HGepford

SIGNATURE BAB HJG

DATE 08/16/2022 08/17/2022

Initial Request for Information

Biennial Requalification Inspection

Comanche Peak Nuclear Power Plant

Inspection Report: 5000445/2022004; 5000446/2022004

Inspection Dates: October 24, 2022 - October 28, 2022

Inspection Procedure: IP 71111.11B, Licensed Operator Requalification

Program

Lead Inspector: Bryan Bergeon, Operations Engineer

A. The following information is requested in order to support inspection preparation

activities. These items are listed by section as they appear in the inspection module

(i.e. 03.04a, 03.04b, etc.). Requested materials should be sent in an electronic format

on CD/DVD in order to arrive at the Region IV office no later than October 10, 2022;

OR uploaded to the NRCs secure Box application no later than October 10, 2022.

CD/DVD to: US Nuclear Regulatory Commission, Region IV

ATTN: Bryan Bergeon / Heather Gepford

1600 E. Lamar Blvd

Arlington, TX 76011

General Requests:

List of licensed operators (SRO & RO) by crew (operating & staff)

Training and Operations Department organization charts (with qualified LOR

evaluators identified)

Procedures that identify process for revising and maintaining LO continuing training

program up to date

List of outstanding LOR program changes

List of plant events and industry operating experience incorporated into LOR

program since last BRQ

Audits and/or self-assessment reports addressing the licensed operator

requalification training program

Last 2 years of simulator review committee (or equivalent) meeting minutes

Last 2 years of Curriculum Review Committee (or equivalent) meeting minutes

A summary report of all condition reports related to operator actions/errors in the

control room

Any revised requalification training that was based on licensed operator performance

issues

03.04a: Biennial Requalification Written Examinations

The current and approved biennial written examination schedule

The current requalification cycle written examination results for both SRO & RO that

have already been administered up to the week prior to the inspection team arrival

onsite.

All written examinations that have been approved for administration up to and

including the week before the inspection team is onsite. This will need to have

adequate password protection or double envelope protection if mailed via regular

mail per NUREG-1021.

The current requalification cycle examination methodology (sample plan)

03.04b: Annual Requalification Operating Tests

The schedule for the operating tests (JPMs & scenarios) to be given the week of

October 24, 2022

The operating tests (JPMs & scenarios) (password protected and provide separately

via telephone at later date) to be given the week of October 24, 2022

Current requalification cycle operating tests (SRO & RO) and results up to the week

prior to the inspection team arrival onsite

All 2021 NRC required annual operating tests

Current requalification cycle operating test methodology (sample plan)

03.04c: Administration of an Annual Requalification Operating Test

All procedures used to administer the annual operating test

All procedures used to assess operator performance

All procedures that describe conduct of simulator training

All procedures used to test, operate, and maintain the simulator

03.04d: Requalification Examination Security

Submit any tracking tools that you use as a means to prevent excessive overlap on

the written examinations and also meet the intent of sampling all required topics on a

periodic basis.

Submit any tracking tools that you use as a means to prevent excessive overlap on

the operating tests and also meet the intent of sampling all required malfunctions

(including major events, instrument/component malfunctions, TS calls, etc.) on a

periodic basis.

All procedures that describe examination security, including procedures used to

develop the examinations that include guidelines on overlap between examinations

in current exam cycle tests and prior year examinations

List of all condition reports since the last biennial requalification inspection related to

examination security and overlap

03.04e: Remedial Training and Re-Examinations

List of remedial training conducted or planned since last requalification exam

(includes training provided to operators to enable passing requalification exam and

training provided to correct generic or individual weaknesses observed during

previous requalification exam cycle)

Remediation plans (lesson plans, reference materials, and attendance

documentation)

03.04f: Operator License Conditions

All procedures and program documentation for maintaining active operator licenses,

tracking training attendance, and ensuring medical fitness of licensed operators

All procedures and associated documentation that supports reactivation of any

SRO/RO license (operating or staff crew) since the last biennial inspection

03.04g: Control Room Simulator

All simulator management and configuration procedures if not already provided

Simulator discrepancy report summary list for all open discrepancy reports and

summary list for those items closed between October 1, 2020 and October 10, 2022

Primary parameters tested in order to verify core physics parameters (such as

moderator temperature coefficient, integral rod worth)). The applicable reference

graphs from the plant physics data book (electronic or other means as available)

should also be included as well as the test procedures used and the acceptance

criteria with results.

All simulator modification packages that are on hold, delayed, or not completed in the

last 2 years

A list of simulator modification packages completed in the last two-year window

B. The following information is requested in order to support the onsite inspection

activities. Requested materials should be available to the inspection team, either

electronically or hardcopy, upon site arrival on October 24, 2022.

03.03: Requalification Exam Results / 03.04a and 03.04b: Biennial Requalification Written

Exam and Annual Requalification Operating Tests Quality

All operating tests (JPMs & scenarios) to be given in all subsequent weeks after

onsite week, if available

All results up to the day the team leaves the site

03.04f: Conformance with Operator License Conditions

Access to licensed operators records (operating and staff crews)

Access to licensed operators training attendance records

Access to licensed operators medical records

03.04g: Control Room Simulator Performance

Simulator discrepancies from October 1, 2020 to October 24, 2022. This should

include all open and closed simulator discrepancy reports, including the

documentation/justification for closure.

Acceptance test documentation, including hardware and software model revisions at

the time of acceptance (as available)

Documentation that validates current models, including the thermal-hydraulics and

neutronics models, to the actual plant

All current model deficiencies, including FSAR vs Design differences in the simulator

(any documentation on this)

Summary list of modifications from October 1, 2020 to October 24, 2022

Plant modifications (both hardware and software) completed on the simulator by due

date from October 1, 2020 to October 24, 2022

Simulator differences Lesson plan used in training (current to October 24, 2022)

The complete book of all simulator annual performance test packages (usually in a

single book but may be electronic or in single test packages), complete with all

transient tests, steady state tests, and malfunction tests. This should also include

the test procedures for each test, the acceptance criteria, and results. For each

transient test, the reference chart should be included or an equivalent subject matter

expert review versus the simulator results with a write-up for any differences beyond

the ANSI standard requirements.

All test packages used to verify core physics parameters (such as moderator

temperature coefficient and integral rod worth). The applicable reference graphs

from the plant physics data book (electronic or other means as available) should also

be included as well as the test procedures used and the acceptance criteria with

results.

All simulator tests, configuration management, and related documents available in

the room for inspectors to review. This includes training needs analysis packages,

simulator review committee meeting minutes, etc.

Current copy of ANSI 3.5 standard you are committed to for simulator testing

C. Comanche Peak Nuclear Power Plant is required to send the final results summary

(see Table 1 below) and any remaining exams and operating tests that have not been

reviewed to the regional office lead inspector for this inspection for final review and

comparison against the Significance Determination Tools in order to communicate

the exit results for the inspection.

TABLE 1: EXAMINATION RESULTS

1. Total number of licensed operators.

2. Number of licensed operators administered a requalification

examination required by 10 CFR 55.59(a).

3. Number of individual licensed operators who failed any portion of a

requalification examination (written, JPM, or individual simulator

scenario failures).

4. Divide line 3 by line 2 to obtain the individual requalification

examination failure rate. Line 3/Line 2.  %

5. Number of crews administered simulator scenarios as part of a

requalification examination required by 10 CFR 55.59(a).

6. Number of crews who performed unsatisfactorily on the

simulator scenarios.

7. Divide line 6 by line 5 to obtain the crew simulator scenario

failure rate. Line 6/Line 5.  %