ML21131A095

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CP2021001-RP-JE, Comanche Peak Nuclear Power Plant, Units 1 and 2 - Integrated Inspection Report 05000445/2021001 and 05000446/2021001
ML21131A095
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/11/2021
From: O'Keefe N
NRC/RGN-IV/DRP
To: Peters K
Vistra Operating Co. (VistraOpCo)
References
IR 2021001
Download: ML21131A095 (17)


See also: IR 05000445/2021001

Text

May 11, 2021

Mr. Ken Peters

Senior Vice President

and Chief Nuclear Officer

VISTRA Operating Company, LLC

P.O. Box 1002

Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2021001 AND

05000446/2021001

Dear Mr. Peters:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 16, 2021, the NRC inspectors

discussed the results of this inspection with Mr. Thomas McCool and other members of your

staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding did

not involve a violation of NRC requirements.

If you disagree with a finding not associated with a regulatory requirement in this report, you

should provide a response within 30 days of the date of this inspection report, with the basis for

your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control

Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and

the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2.

K. Peters

2

This letter, its enclosure, and your response (if any) will be made available for public inspection

and copying at http://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,

Neil F. O'Keefe, Chief

Reactor Projects Br B

Division of Reactor Projects

Docket Nos. 05000445 and 05000446

License Nos. NPF-87 and NPF-89

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

Cornelius F.

O'Keefe

Digitally signed by

Cornelius F. O'Keefe

Date: 2021.05.11

12:38:11 -05'00'

ML21131A095

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE SRI:DRP/B

RI:DRP/B

TL:DRS/IPAT

BC:DRS/EB1

NAME

JEllegood JAE

NDay NHD

AAgrawal ANA

VGaddyvgg

DATE

05/10/2021

04/28/2021

5/6/2021

05/06/2021

OFFICE BC:DRS/EB2

ABC:DRS/RCB

BC:DRS/OB

ABC:DNMS/RxIB

NAME

NTaylor NHT

JRollins JMR

HGepford hjg

NGreene / NAG

DATE

5/6/2021

5/10/2021

5/10/2021

05/06/2021

OFFICE SPE:DRP/B

BC:DRP/B

NAME

DProulx DLP

NOKeefe nfo

DATE

5/10/2021

5/11/21

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers:

05000445 and 05000446

License Numbers:

NPF-87 and NPF-89

Report Numbers:

05000445/2021001 and 05000446/2021001

Enterprise Identifier: I-2021-001-0095

Licensee:

VISTRA Operating Company, LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, TX

Inspection Dates:

January 1, 2021 to March 31, 2021

Inspectors:

L. Brookhart, Senior Spent Fuel Storage Inspector

N. Day, Resident Inspector

J. Drake, Senior Reactor Inspector

J. Ellegood, Senior Resident Inspector

S. Hedger, Emergency Preparedness Inspector

J. Melfi, Project Engineer

Approved By:

Neil F. O'Keefe, Jr., Chief

Reactor Projects Br B

Division of Reactor Projects

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,

Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight

Process is the NRCs program for overseeing the safe operation of commercial nuclear power

reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure of Unit 1 Turbine First Stage Pressure Line

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Mitigating

Systems

Green

FIN 05000445/2021001-01

Open/Closed

None (NPP)

71111.12

The inspectors identified a finding of very low safety significance, Green, following the failure

of a weld on the root valve for the main turbine first stage pressure transmitter 1-PT-0505.

Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new

valve was not the same model as the installed valve which resulted in premature failure of a

weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown

to make repairs. The licensee failed to properly control inventory in the supply system. As a

result, the licensee installed a valve in the plant without doing the necessary part evaluations

needed to verify it was appropriate for the application.

Additional Tracking Items

None.

3

PLANT STATUS

Units 1 began the inspection period at or near 100 percent power. On March 29, 2021, Unit 1

main feedwater pump A tripped. An automatic runback occurred in response to the main

feedwater pump trip which reduced power to about 57 percent. Unit 1 remained at about 57

percent power for the remainder of the inspection period.

Unit 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President

of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),

resident inspectors were directed to begin telework and to remotely access licensee information

using available technology. During this time, the resident inspectors performed periodic site

visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant

Status; observed risk-significant activities; and completed on-site portions of IPs. In addition,

resident and regional baseline inspections were evaluated to determine if all or portions of the

objectives and requirements stated in the IP could be performed remotely. If the inspections

could be performed remotely, they were conducted per the applicable IP. In some cases,

portions of an IP were completed remotely and on-site. The inspections documented below met

the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1)

On February 11, 2021, the inspectors evaluated readiness for seasonal extreme

weather conditions prior to the onset of cold weather per procedure OWI-912, Cold

Weather, for the following systems:

Station Service Water

Fire Water

Emergency Diesel Generators

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

4

(1)

The inspectors evaluated the adequacy of the overall preparations to protect

risk-significant systems from impending severe weather for high winds on January 14,

2021

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1)

Systems, structures and components in service water and fire water for both units

that were vulnerable to freezing following extreme cold on February 20, 2021

(2)

Unit 1, residual heat removal system A following quarterly surveillance on March 11,

2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a

walkdown and performing a review to verify program compliance, equipment functionality,

material condition, and operational readiness of the following fire areas:

(1)

Flex equipment storage building, area X-FX-2K19, on February 22, 2021

(2)

Unit 1, main feedwater pumps, area TB, on March 12, 2021

(3)

Station service water intake structure, area WB, on March 22, 2021

(4)

Unit 1, safeguards building ventilation, area SK17a, on March 30, 2021

(5)

Unit 1, main steam isolation and atmosphere relief valve room, area SK17c, on

March 30, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1)

The inspectors evaluated the onsite fire brigade training and performance during an

unannounced fire drill on March 18, 2021

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1)

Unit 1, station service water cable vault E1B2 on January 28, 2021.

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1)

Unit 1, containment spray pump 1-01 and lube oil cooler 1-03

5

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1)

The inspectors observed and evaluated licensed operator performance in the control

room during service water restoration on March 26, 2021

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1)

The inspectors observed and evaluated a simulated complete loss of component

cooling water on January 27, 2021

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following

structures, systems, and components (SSCs) remain capable of performing their intended

function:

(1)

Unit 1, service water pump fouling on November 18, 2020

(2)

Failure of Unit 1 PT-0505, turbine first stage pressure transmitter, instrument line on

November 6, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the

following planned and emergent work activities to ensure configuration changes and

appropriate work controls were addressed:

(1)

Unit 2, simultaneous scheduling power range nuclear instrument calibrations for N-41

and N-42 on January 4, 2021

(2)

Unit 1, unplanned inoperability train B auxiliary feedwater (AFW) pump on January 6,

2021

(3)

Recovery of breaker 1A1-1, normal offsite power to nonvital 6.9KVon January 20,

2021

(4)

Low temperatures and high grid load during the week of February 15, 2021

(5)

Extended service water pump 2-02 outage during the week of March 22, 2021

(6)

Unit 1, repairs to main feed pump A during the week of March 29, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

6

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1)

Unit 1, repair of B AFW pump flow transmitter

(2)

Operability of 2-01 emergency diesel generator with unit trip light illuminated

(3)

Offsite power with low frequency on February 15, 2021

(4)

Service water pumps pursuant to Generic Letter 91-13.

(5)

Circuit breaker 1EB3-3 due to missing overcurrent testing

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following permanent modification:

(1)

Unit 1, PT-0505 modification to improve vibration resilience

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system

operability and functionality:

(1)

Unit 1, motor driven AFW flow transmitter 1-FT-2457 on

January 12, 2021

(2)

Component cooling water pump 1-02 breaker replacement on February 4, 20201.

(3)

Unit 2, main steam isolation valve 2-03 following pressure gauge root valve leak on

February 25, 2021

(4)

Unit 2, replacement of train A accident sequencer optical isolator on March 16, 2021

(5)

Service water pump 2-02 following replacement on March 27, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1)

Unit 2, power range nuclear instrument on January 5, 2021

(2)

Unit 2, reactor trip breaker B on January 25, 2021

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1)

The licensee submitted a summary of emergency plan changes (Revision 44) to the

NRC on November 12, 2020. The inspectors conducted an in-office review of the

changes from January 4 to 21, 2021. This evaluation does not constitute NRC

approval

7

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)

(1)

Unit 1 (January 1, 2020, through December 31, 2020)

(2)

Unit 2 (January 1, 2020, through December 31, 2020)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2

Samples)

(1)

Unit 1 (January 1, 2020, through December 31, 2020)

(2)

Unit 2 (January 1, 2020, through December 31, 2020)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)

(1)

Unit 1 (January 1, 2020, through December 31, 2020)

(2)

Unit 2 (January 1, 2020, through December 31, 2020)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1)

Lack of engineering rigor on multiple engineering products

(2)

Unit 1, main feed water pump A cause evaluation and corrective actions described in

Condition Report 2020-07334

71153 - Followup of Events and Notices of Enforcement Discretion

Event Followup (IP Section 03.01) (1 Sample)

(1)

The inspectors evaluated the Unit 1 main feedwater pump A trip and licensees

response on March 29, 2021

(2)

The inspectors evaluated the response to severe cold weather and grid frequency

variations during the week of February 13

OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of An Independent Spent Fuel Storage Installation (ISFSI)

The inspectors performed a review of the licensees ISFSI activities to verify compliance with

requirements of the Certificate of Compliance 72-1014, License Amendment 7, and the

HI-STORM ISFSI Final Safety Analysis Report (FSAR), Revision 9. The inspectors reviewed

selected procedures, corrective action reports, and records to verify ISFSI operations were

8

compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC

regulations

Operation Of An ISFSI (1 Sample)

(1)

The inspectors evaluated the licensees dry cask storage operations, from March 22

through 26, 2021, during an on-site inspection. The Comanche Peak ISFSI is located

approximately 2,900 feet southeast of the Unit 1 reactor building within a separate

protected area. The pad was designed to hold 84 HI-STORM 100S (Version B)

loaded with the Multi-Purpose Canisters, each with 32 spent fuel assemblies

(MPC-32). The pad is designed to store the casks in a 6 by 14 array. At the time of

the routine loading inspection, the Comanche Peak ISFSI pad contained a total of 43

HI-STORM 100S overpacks. The licensee was in the process of transporting the 44th

cask to the ISFSI and loading/processing the 45th cask in the spent fuel building

During the on-site inspection, the inspectors evaluated and observed the following

activities:

Walk-down of the ISFSI haul path

Transportation of the 44th cask on the vertical cask transporter from the spent

fuel building to the ISFSI

Fuel assembly selection and placement into the 45th canister

Heavy load lifts using the cask handling crane to remove the transfer cask

with the loaded canister from the spent fuel pool to the canister processing

area

Welding and non-destructive testing of the lid-to-shell weld

Processing of the spent nuclear fuel for storage, including bulk water removal,

forced helium dehydration, and helium backfill operations

Final sealing of the canister, including welding of the vent and port cover

plates, non-destructive testing, and helium leak-testing

The inspectors reviewed and evaluated the following documentation during the

inspection:

Fuel selection evaluations for the canisters loaded since the last NRC ISFSI

inspection, the inspectors reviewed the contents of casks 40-45 against the

license's Technical Specifications for approved contents

Radiation surveys for dose at the owner-controlled boundary to verify

compliance with the requirements of 10 CFR 72.104 for calendar years 2019

and 2020

Selected ISFSI related condition reports (CRs) issued since the last NRC

ISFSI inspection (October 2019)

Quality assurance (QA) program implementation, including recent QA audits,

surveillances, receipt inspection, and quality control activities related to ISFSI

operations

Compliance to Technical Specifications for operational surveillance activities

and FSAR required annual maintenance activities

Documentation of annual maintenance activities for the sites cask handling

crane and special lifting devices

Selected licensee design changes and program changes to the ISFSI

performed under the site's 10 CFR 72.48 program

9

Changes made by the licensee in the site's 72.212 Evaluation Report from

Revisions 11 to 12

INSPECTION RESULTS

Failure of Unit 1 Turbine First Stage Pressure Line

Cornerstone

Significance

Cross-Cutting

Aspect

Report

Section

Mitigating

Systems

Green

FIN 05000445/2021001-01

Open/Closed

None (NPP)

71111.12

The inspectors identified a finding of very low safety significance (Green) following the failure

of a weld on the main turbine first stage pressure transmitter root valve 1-MS-0285.

Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new

valve was not the same model as the installed valve which resulted in premature failure of a

weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown

to make repairs. The licensee failed to properly control inventory in the supply system. As a

result, the licensee installed a valve in the plant without doing the necessary part evaluations

needed to verify it was appropriate for the application.

Description: The licensee replaced the main turbine first stage pressure transmitter root

valve 1-MS-0285 during the fall 2020 refueling outage as a preventive maintenance

activity. Shortly after unit start up, on November 6, 2020, main turbine first stage pressure

transmitter 1-PT-0505 failed low. A parallel indicator continued to function correctly. A

non-licensed operator investigated the condition and observed a steam plume from the inlet

side of the instrument root valve 1-MS-0285. Since the leak could not be isolated, the

licensee shut the unit down and replaced the valve.

In order to understand the failure, the licensee contracted for an analysis of the failed weld.

The lab performing the analysis determined the weld failed as a result of fatigue crack

initiation. Further analysis by the licensee determined the failure occurred as a result of

vibration at resonant frequency. This resonance response resulted from installation of a

valve that weighed 2 pounds more than the previously installed valve, which altered the

natural frequency of the section of piping.

The inspectors reviewed the licensee's work order associated with valve replacement as well

as procurement documents associated with the work. Supply chain documents revealed that

the replacement valve was transferred to Comanche Peak from coal plant. When it arrived,

the licensee accepted the valve into their inventory under the Texas Utility part number. At

the time, Texas Utility was the corporate owner of Comanche Peak and numerous fossil

plants. The licensee correlated the valve to locations for other steam instrument isolation

valves; however, the valve was not initially correlated to location 1-MS-0285. An update to a

logistics database in 1998 correlated the part number to the location for 1-MS-0285. In

reviewing the procedure in effect in 1990, the inspectors determined that the procedure

required the site to verify the materiel description matched that in the database for the part. If

it did not, a new part number was required. In this case, the replacement valve did not match

any valves with an existing part number; however, the licensee failed to assign the valve a

new part number.

PT-0505 provides indication of turbine first stage pressure as well as input to Anticipated

Transient without Scram Mitigation System Actuation Circuitry (AMSAC) and the P-13

permissive. The AMSAC input allows AMSAC to arm when power is above 40 percent.

10

Since the instrument failed low, AMSAC would not automatically actuate and operators would

have needed to manually initiate AMSAC if the system was needed. The P-13 permissive is

associated with P-7 permissive which blocks certain trips when at low power.

During review of this issue, the licensee identified the technical cause of the weld failure.

However, the licensee did not pursue the underlying cause that allowed an incorrect valve to

be installed. The inspectors discussed potential performance deficiencies with the licensee

which prompted the licensee to understand how the valve was issued for installation. The

licensee plans to incorporate this event into training for supply chain staff.

Corrective Actions: The licensee documented the condition in their Corrective Action

Program (CAP) as CR-2020-8429 and replaced the valve with the correct valve.

Corrective Action References: CR-2020-8429

Performance Assessment:

Performance Deficiency: The licensee failed to properly control inventory in the supply

system. As a result, the licensee installed a valve in the plant without doing the necessary

part evaluations needed to verify it was appropriate for the application. Consequently, the

natural frequency of a high-pressure steam pressure transmitter piping changed causing

premature failure. Repair of the leak required a plant shutdown.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Design Control attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. The inspectors determined that the performance deficiency was more than

minor because it adversely affected the mitigating system cornerstone objective of ensuring

the reliability of systems that respond to initiating events. The performance deficiency had a

substantive impact on the equipment performance attribute because the failure of the weld as

a result of the performance deficiency led to PT-0505 unavailability. This instrument provides

input to the P-13 permissive as well as the AMSAC system.

Significance: The inspectors assessed the significance of the finding using Appendix A, The

Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed

the finding in using Appendix A of IMC 0609. The inspectors answered no to all of the

questions in Exhibit 2, section A because the affected mitigating systems were only briefly

non-functional; therefore, the finding screened as Green.

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to

this finding because the inspectors determined the finding did not reflect present licensee

performance. Specifically, the part designation error occurred in 1998.

Enforcement: Inspectors did not identify a violation of regulatory requirements associated

with this finding.

Observation: Actions to address weaknesses in engineering rigor

71152

The inspectors noted several examples in 2019 and 2020 regarding weaknesses in

engineering technical rigor. These examples are documented as samples in reports:

05000445/2019004; 05000446/2019004 (ML20041D968)

05000445/2020002; 05000446/2020002 (ML20217L240)

11

05000445/2020004; 05000446/2020004 (ML21040A051)

The inspectors searched the corrective action program and identified several examples of

where the site had attempted to improve engineering technical rigor, however, the inspectors

concluded that the prior efforts had not been sustainable. The inspectors also reviewed a

presentation on engineering technical rigor provided to engineering staff. The Inspectors

noted that the training had not been given in over 10 years. The inspectors concluded that

training on this frequency would not result in sustainable improvement. Subsequently, the

inspectors discussed actions in place to improve and sustain engineering technical rigor. The

licensee informed the inspectors that the site would have biennial training on engineering

technical rigor. In addition, engineering supervisors provide reinforcement of engineering

rigor during one on one discussions with engineers and in staff meetings. If the licensee

maintains initiatives to improve engineering rigor, the inspectors expect to see improvement

in engineering products.

Observation: Licensee Response to Frigid Weather

71153

During the week of February 14, 2021, Comanche Peak experienced frigid weather

conditions for multiple days. Prior to the onset of the cold weather, the licensee

implemented their abnormal procedure to prepare for cold weather with supplemental

actions based on operating experience. The inspectors performed walkdowns of licensee

actions using inspection procedure 71111.01. Following the onset of cold weather, the site

experienced a grid frequency drop on February 15, 2021. As part of the response, as

specified in ABN-601 Response to a 138/345 KV System Malfunction, the licensee started

train A emergency diesel generators in both units and transferred the train A emergency

busses to the diesel. Concurrently, the shift manager contacted the grid operator and

requested the grid operator recover grid frequency to greater than 59.9 Hz. The grid

operator reduced grid load and operators restored the plant to a normal electrical

configuration. The inspectors verified the licensee responded in accordance with approved

procedures by discussion, log reviews, and computer trend reviews. The licensee

maintained the plant in a stable condition with limited work activities for the rest of the

week. The inspectors continued to monitor plant parameters and activities using

procedures 71111.13 and 71111.15. After the cold weather subsided, on February 20,

2021, the inspectors used inspection procedure 71111.04 to inspect the condition of

systems and components susceptible to freezing. The inspectors concluded site personnel

maintained the plant in a safe condition and the cold weather did not cause significant

damage to the plant.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 21, 2021, the inspectors presented the Emergency Plan Revision In-Office

Review Results inspection results to Mr. Patrick Allen, Manager, Emergency

Preparedness and other members of the licensee staff.

On March 25, 2021, the inspectors presented the routine ISFSI inspection results to

Mr. Thomas McCool, Site Vice President, and other members of the licensee staff.

On April 16, 2021, the inspectors presented the integrated inspection results to

Mr. Thomas McCool and other members of the licensee staff.

12

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

60855

Corrective Action

Documents

CR-YYYY-NNNN

TR-YYYY-NNNN

2019-009399, 2020-001626, 2020-008755, 2021-001243,

TR-2019-008506, TR-2019-009009, TR-2020-000102,

TR-2020-005224

60855

Engineering

Evaluations

EVAL-2019-009

Nuclear Oversight Core Performance Engineering and Fuel

Management QA Audit

03/11/2020

60855

Engineering

Evaluations

NUC 212 Cask

40

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

09/05/2019

60855

Engineering

Evaluations

NUC-212 Cask

41

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

09/05/2019

60855

Engineering

Evaluations

NUC-212 Cask

42

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

09/05/2019

60855

Engineering

Evaluations

NUC-212 Cask

43

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

02/24/2021

60855

Engineering

Evaluations

NUC-212 Cask

44

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

02/24/2021

60855

Engineering

Evaluations

NUC-212 Cask

45

Cask Acceptability Report and Comprehensive Assembly

Specifications Supplement

02/24/2021

60855

Miscellaneous

72.212 Report

CPNPP 10CFR72.212 Evaluation Report

12

60855

Procedures

DCS-201

Transporting Loaded and Unloaded HI-STORM

9

60855

Procedures

DCS-202

MPC Preparation for Loading

9

60855

Procedures

DCS-203

MPC Handling and Fuel Loading Operations

12

60855

Procedures

DCS-204

MPC Closure Operations (Sealing, Drying, Backfilling)

13

60855

Procedures

DCS-205

Stack-up and Transfer of Loaded MPC

10

60855

Procedures

OPT-102A-1

Operations Shiftly Routine Tests

15

71111.01

Work Orders

5939919

71111.04

Procedures

SOP-102A

Residual Heat Removal System

22

71111.04

Work Orders

5820443

71111.05

Fire Plans

FPI-108A

Fire Preplan for UNIT 1 SAFEGUARDS BUILDING MAIN

STEAM PENETRATION AREA 880'-6"

4

71111.05

Fire Plans

FPI-2001

Fire Preplan for FLEX STORAGE BUILDING X-FX-2K19

1

71111.05

Fire Plans

FPI-302A

Fire Preplan for UNIT 1 & 2 TURBINE BUILDING

ELEVATION 803'-0"

8

13

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.05

Fire Plans

FPI-701

Fire Preplan for SERVICE WATER INTAKE STRUCTURE

ELEV. 796'-0" & 810'-6"

4

71111.07A NDE Reports

Containment Spray Pump 1-01 and 1-03 Visual Inspection

Report

01/20/2021

71111.12

Corrective Action

Documents

CR-YYYY-NNNN

2020-7695, 2020-8429

71111.12

Miscellaneous

Service water system health report

08/25/2020

71111.12

Miscellaneous

Maintenance Rule Database for Main Steam

71111.12

Miscellaneous

Maintenance Rule Database for Unit 1 Service Water

71111.12

Miscellaneous

6S832645

Material Transfer Form

05/01/1990

71111.12

Miscellaneous

MDIR-98-000314-

00-00

03/13/1998

71111.12

Procedures

MMO-6.09

TSN Assignment and Transfer of Warehouse Material.

0

71111.13

Procedures

STI-600.01,

Protecting Plant Equipment and Sensitive Equipment

Controls

3

71111.15

Corrective Action

Documents

CR-YYYY-NNNN

2021-001393, 2021-1224, 2021-553

71111.15

Miscellaneous

PQE 208

Rosemont Pressure Transmitter Plant Qualification

Evaluation

12/23/2018

71111.18

Engineering

Changes

FDA-2017-

000020-01-01

Modify 1-PT-0505

2

71111.19

Procedures

OPT-205B

Containment Spray System Post Test for WO 5813767 and

5813740

18

71111.19

Work Orders

5405494, 595445

71111.19

Work Orders

5958368

71111.22

Work Orders

5790214

71114.04

Miscellaneous

Comanche Peak Nuclear Power Plant Emergency Plan,

Units 1 and 2

43

71114.04

Miscellaneous

AI-TR-2020-

000756-13

Use of Terms "Onsite," "Offsite," "Site," "Site Boundary," and

"Exclusion Area" in the Emergency Plan

09/16/2020

71114.04

Miscellaneous

CP-20200627,

TXX-20093

Comanche Peak Nuclear Power Plant (CPNPP), Docket

Nos. 50-445, 50-446; Transmittal of Revised Emergency

Plan (Revision 44)

11/12/2020

71114.04

Miscellaneous

EV-TR-2018-

Remove Letter of Agreement References from Comanche

08/18/2020

14

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

005896-5

Peak Emergency Plan Appendix H

71114.04

Procedures

EPP-123

10 CFR 50.54(q) Screening and Evaluation of Changes to

Emergency Plan Documentation

2

71152

Corrective Action

Documents

CR-YYYY-NNNN

2018-1550, 2018-2038, 2020-008417

71152

Corrective Action

Documents

TR-YYYY-NNNN

2018-2038 ,2018-5898, 2020-5057, 2021-000414