ML21131A095: Difference between revisions

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{{#Wiki_filter:May 11, 2021
{{#Wiki_filter:May 11, 2021  
Mr. Ken Peters
Senior Vice President
   and Chief Nuclear Officer
VISTRA Operating Company, LLC
Mr. Ken Peters  
P.O. Box 1002
Senior Vice President
Glen Rose, TX 76043
   and Chief Nuclear Officer  
SUBJECT:       COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
VISTRA Operating Company, LLC  
                INTEGRATED INSPECTION REPORT 05000445/2021001 AND
P.O. Box 1002  
                05000446/2021001
Glen Rose, TX 76043  
Dear Mr. Peters:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
SUBJECT:  
at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 16, 2021, the NRC inspectors
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -  
discussed the results of this inspection with Mr. Thomas McCool and other members of your
INTEGRATED INSPECTION REPORT 05000445/2021001 AND  
staff. The results of this inspection are documented in the enclosed report.
05000446/2021001  
One finding of very low safety significance (Green) is documented in this report. This finding did
not involve a violation of NRC requirements.
Dear Mr. Peters:  
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
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection  
your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control
at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 16, 2021, the NRC inspectors  
Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and
discussed the results of this inspection with Mr. Thomas McCool and other members of your  
the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2.
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
K. Peters  
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,
                                              Cornelius F.        Digitally signed by
2  
                                                                  Cornelius F. O'Keefe
                                              O'Keefe            Date: 2021.05.11
This letter, its enclosure, and your response (if any) will be made available for public inspection  
                                                                  12:38:11 -05'00'
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document  
                                              Neil F. O'Keefe, Chief
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public  
                                              Reactor Projects Br B
Inspections, Exemptions, Requests for Withholding.  
                                              Division of Reactor Projects
Docket Nos. 05000445 and 05000446
Sincerely,  
License Nos. NPF-87 and NPF-89
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
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
  ML21131A095
                                Non-Sensitive                     Publicly Available
        SUNSI Review
SUNSI Review
                                Sensitive                          Non-Publicly Available
  OFFICE SRI:DRP/B       RI:DRP/B               TL:DRS/IPAT BC:DRS/EB1
  NAME     JEllegood JAE NDay NHD               AAgrawal ANA VGaddyvgg
Non-Sensitive  
  DATE     05/10/2021   04/28/2021             5/6/2021     05/06/2021
Sensitive
  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
Publicly Available  
  OFFICE SPE:DRP/B       BC:DRP/B
  NAME     DProulx DLP   NOKeefe nfo
Non-Publicly Available  
  DATE     5/10/2021     5/11/21
                                 
OFFICE SRI:DRP/B  
                          U.S. NUCLEAR REGULATORY COMMISSION
RI:DRP/B  
                                        Inspection Report
TL:DRS/IPAT  
Docket Numbers:        05000445 and 05000446
BC:DRS/EB1  
License Numbers:      NPF-87 and NPF-89
Report Numbers:        05000445/2021001 and 05000446/2021001
NAME  
Enterprise Identifier: I-2021-001-0095
JEllegood JAE  
Licensee:              VISTRA Operating Company, LLC
NDay NHD  
Facility:              Comanche Peak Nuclear Power Plant, Units 1 and 2
AAgrawal ANA  
Location:              Glen Rose, TX
VGaddyvgg  
Inspection Dates:      January 1, 2021 to March 31, 2021
Inspectors:            L. Brookhart, Senior Spent Fuel Storage Inspector
DATE  
                      N. Day, Resident Inspector
05/10/2021  
                      J. Drake, Senior Reactor Inspector
04/28/2021  
                      J. Ellegood, Senior Resident Inspector
5/6/2021  
                      S. Hedger, Emergency Preparedness Inspector
05/06/2021  
                      J. Melfi, Project Engineer
Approved By:          Neil F. O'Keefe, Jr., Chief
OFFICE BC:DRS/EB2  
                      Reactor Projects Br B
ABC:DRS/RCB  
                      Division of Reactor Projects
BC:DRS/OB  
                                                                        Enclosure
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  


                                              SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
Enclosure
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
U.S. NUCLEAR REGULATORY COMMISSION
Process is the NRCs program for overseeing the safe operation of commercial nuclear power
Inspection Report
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
Docket Numbers: 
  Cornerstone            Significance                                Cross-Cutting    Report
05000445 and 05000446
                                                                      Aspect          Section
  Mitigating            Green                                        None (NPP)      71111.12
  Systems                FIN 05000445/2021001-01
License Numbers: 
                        Open/Closed
NPF-87 and NPF-89
  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
Report Numbers: 
  valve was not the same model as the installed valve which resulted in premature failure of a
05000445/2021001 and 05000446/2021001
  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
Enterprise Identifier: I-2021-001-0095
  needed to verify it was appropriate for the application.
                                    Additional Tracking Items
None.
Licensee:
                                                  2
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 


PLANT STATUS
Units 1 began the inspection period at or near 100 percent power. On March 29, 2021, Unit 1
2
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
SUMMARY
percent power for the remainder of the inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
INSPECTION SCOPES
performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
Units 1 and 2, in accordance with the Reactor Oversight Process.  The Reactor Oversight
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
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-
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
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
complete when the IP requirements most appropriate to the inspection activity were met  
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection  
Program - Operations Phase. The inspectors reviewed selected procedures and records,
Program - Operations Phase. The inspectors reviewed selected procedures and records,  
observed activities, and interviewed personnel to assess licensee performance and compliance
observed activities, and interviewed personnel to assess licensee performance and compliance  
with Commission rules and regulations, license conditions, site procedures, and standards.
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),
Starting on March 20, 2020, in response to the National Emergency declared by the President  
resident inspectors were directed to begin telework and to remotely access licensee information
of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),  
using available technology. During this time, the resident inspectors performed periodic site
resident inspectors were directed to begin telework and to remotely access licensee information  
visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant
using available technology. During this time, the resident inspectors performed periodic site  
Status; observed risk-significant activities; and completed on-site portions of IPs. In addition,
visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant  
resident and regional baseline inspections were evaluated to determine if all or portions of the
Status; observed risk-significant activities; and completed on-site portions of IPs. In addition,  
objectives and requirements stated in the IP could be performed remotely. If the inspections
resident and regional baseline inspections were evaluated to determine if all or portions of the  
could be performed remotely, they were conducted per the applicable IP. In some cases,
objectives and requirements stated in the IP could be performed remotely. If the inspections  
portions of an IP were completed remotely and on-site. The inspections documented below met
could be performed remotely, they were conducted per the applicable IP. In some cases,  
the objectives and requirements for completion of the IP.
portions of an IP were completed remotely and on-site. The inspections documented below met  
REACTOR SAFETY
the objectives and requirements for completion of the IP.  
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
REACTOR SAFETY  
    (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
71111.01 - Adverse Weather Protection  
            Weather, for the following systems:
            Station Service Water
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)  
            Fire Water
            Emergency Diesel Generators
(1)  
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
On February 11, 2021, the inspectors evaluated readiness for seasonal extreme  
                                                  3
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)  


    (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,
4
          2021
71111.04 - Equipment Alignment
(1)  
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the adequacy of the overall preparations to protect  
    The inspectors evaluated system configurations during partial walkdowns of the following
risk-significant systems from impending severe weather for high winds on January 14,  
    systems/trains:
2021  
    (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
71111.04 - Equipment Alignment  
    (2)   Unit 1, residual heat removal system A following quarterly surveillance on March 11,
          2021
Partial Walkdown Sample (IP Section 03.01) (2 Samples)  
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following  
    The inspectors evaluated the implementation of the fire protection program by conducting a
systems/trains:  
    walkdown and performing a review to verify program compliance, equipment functionality,
    material condition, and operational readiness of the following fire areas:
(1)  
    (1)   Flex equipment storage building, area X-FX-2K19, on February 22, 2021
Systems, structures and components in service water and fire water for both units  
    (2)   Unit 1, main feedwater pumps, area TB, on March 12, 2021
that were vulnerable to freezing following extreme cold on February 20, 2021  
    (3)   Station service water intake structure, area WB, on March 22, 2021
(2)  
    (4)   Unit 1, safeguards building ventilation, area SK17a, on March 30, 2021
Unit 1, residual heat removal system A following quarterly surveillance on March 11,  
    (5)   Unit 1, main steam isolation and atmosphere relief valve room, area SK17c, on
2021  
          March 30, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
71111.05 - Fire Protection  
    (1)   The inspectors evaluated the onsite fire brigade training and performance during an
          unannounced fire drill on March 18, 2021
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)  
71111.06 - Flood Protection Measures
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated the implementation of the fire protection program by conducting a  
    The inspectors evaluated cable submergence protection in:
walkdown and performing a review to verify program compliance, equipment functionality,  
    (1)   Unit 1, station service water cable vault E1B2 on January 28, 2021.
material condition, and operational readiness of the following fire areas:  
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
(1)  
    The inspectors evaluated readiness and performance of:
Flex equipment storage building, area X-FX-2K19, on February 22, 2021  
    (1)   Unit 1, containment spray pump 1-01 and lube oil cooler 1-03
(2)  
                                                4
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  


71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
5
(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
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance  
          cooling water on January 27, 2021
71111.12 - Maintenance Effectiveness
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)  
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
(1 Sample)  
    The inspectors evaluated the effectiveness of maintenance to ensure the following
    structures, systems, and components (SSCs) remain capable of performing their intended
(1)  
    function:
The inspectors observed and evaluated licensed operator performance in the control  
    (1)   Unit 1, service water pump fouling on November 18, 2020
room during service water restoration on March 26, 2021  
    (2)   Failure of Unit 1 PT-0505, turbine first stage pressure transmitter, instrument line on
          November 6, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)  
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
(1)  
    The inspectors evaluated the accuracy and completeness of risk assessments for the
The inspectors observed and evaluated a simulated complete loss of component  
    following planned and emergent work activities to ensure configuration changes and
cooling water on January 27, 2021  
    appropriate work controls were addressed:
    (1)   Unit 2, simultaneous scheduling power range nuclear instrument calibrations for N-41
71111.12 - Maintenance Effectiveness  
          and N-42 on January 4, 2021
    (2)   Unit 1, unplanned inoperability train B auxiliary feedwater (AFW) pump on January 6,
Maintenance Effectiveness (IP Section 03.01) (2 Samples)  
          2021
    (3)   Recovery of breaker 1A1-1, normal offsite power to nonvital 6.9KVon January 20,
The inspectors evaluated the effectiveness of maintenance to ensure the following  
          2021
structures, systems, and components (SSCs) remain capable of performing their intended  
    (4)   Low temperatures and high grid load during the week of February 15, 2021
function:  
    (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
(1)  
71111.15 - Operability Determinations and Functionality Assessments
Unit 1, service water pump fouling on November 18, 2020
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
(2)  
                                                  5
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)  


    The inspectors evaluated the licensee's justifications and actions associated with the
    following operability determinations and functionality assessments:
6
    (1)   Unit 1, repair of B AFW pump flow transmitter
    (2)   Operability of 2-01 emergency diesel generator with unit trip light illuminated
The inspectors evaluated the licensee's justifications and actions associated with the  
    (3)   Offsite power with low frequency on February 15, 2021
following operability determinations and functionality assessments:  
    (4)   Service water pumps pursuant to Generic Letter 91-13.
    (5)   Circuit breaker 1EB3-3 due to missing overcurrent testing
(1)  
71111.18 - Plant Modifications
Unit 1, repair of B AFW pump flow transmitter  
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2)  
(1 Sample)
Operability of 2-01 emergency diesel generator with unit trip light illuminated  
    The inspectors evaluated the following permanent modification:
(3)  
    (1)   Unit 1, PT-0505 modification to improve vibration resilience
Offsite power with low frequency on February 15, 2021  
71111.19 - Post-Maintenance Testing
(4)  
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
Service water pumps pursuant to Generic Letter 91-13.  
    The inspectors evaluated the following post-maintenance test activities to verify system
(5)  
    operability and functionality:
Circuit breaker 1EB3-3 due to missing overcurrent testing  
    (1)   Unit 1, motor driven AFW flow transmitter 1-FT-2457 on
          January 12, 2021
71111.18 - Plant Modifications  
    (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
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)  
          February 25, 2021
(1 Sample)  
    (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
The inspectors evaluated the following permanent modification:  
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
(1)  
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
Unit 1, PT-0505 modification to improve vibration resilience  
    (1)   Unit 2, power range nuclear instrument on January 5, 2021
    (2)   Unit 2, reactor trip breaker B on January 25, 2021
71111.19 - Post-Maintenance Testing  
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)  
    (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
The inspectors evaluated the following post-maintenance test activities to verify system  
          changes from January 4 to 21, 2021. This evaluation does not constitute NRC
operability and functionality:  
          approval
                                                6
(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  


OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
7
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)
OTHER ACTIVITIES - BASELINE  
    (2)   Unit 2 (January 1, 2020, through December 31, 2020)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2
71151 - Performance Indicator Verification  
Samples)
    (1)   Unit 1 (January 1, 2020, through December 31, 2020)
The inspectors verified licensee performance indicators submittals listed below:  
    (2)   Unit 2 (January 1, 2020, through December 31, 2020)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)
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)
(1)  
71152 - Problem Identification and Resolution
Unit 1 (January 1, 2020, through December 31, 2020)
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
(2)  
    The inspectors reviewed the licensees implementation of its corrective action program
Unit 2 (January 1, 2020, through December 31, 2020)
    related to the following issues:
    (1)   Lack of engineering rigor on multiple engineering products
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2  
    (2)   Unit 1, main feed water pump A cause evaluation and corrective actions described in
Samples)  
          Condition Report 2020-07334
71153 - Followup of Events and Notices of Enforcement Discretion
(1)  
Event Followup (IP Section 03.01) (1 Sample)
Unit 1 (January 1, 2020, through December 31, 2020)
    (1)   The inspectors evaluated the Unit 1 main feedwater pump A trip and licensees
(2)  
          response on March 29, 2021
Unit 2 (January 1, 2020, through December 31, 2020)
    (2)   The inspectors evaluated the response to severe cold weather and grid frequency
          variations during the week of February 13
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)  
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of An Independent Spent Fuel Storage Installation (ISFSI)
(1)  
The inspectors performed a review of the licensees ISFSI activities to verify compliance with
Unit 1 (January 1, 2020, through December 31, 2020)
requirements of the Certificate of Compliance 72-1014, License Amendment 7, and the
(2)  
HI-STORM ISFSI Final Safety Analysis Report (FSAR), Revision 9. The inspectors reviewed
Unit 2 (January 1, 2020, through December 31, 2020)
selected procedures, corrective action reports, and records to verify ISFSI operations were
                                                7
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  


compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC
regulations
8
Operation Of An ISFSI (1 Sample)
  (1)   The inspectors evaluated the licensees dry cask storage operations, from March 22
compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC  
          through 26, 2021, during an on-site inspection. The Comanche Peak ISFSI is located
regulations  
          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)
Operation Of An ISFSI (1 Sample)  
          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
(1)  
          the routine loading inspection, the Comanche Peak ISFSI pad contained a total of 43
The inspectors evaluated the licensees dry cask storage operations, from March 22  
          HI-STORM 100S overpacks. The licensee was in the process of transporting the 44th
through 26, 2021, during an on-site inspection. The Comanche Peak ISFSI is located  
          cask to the ISFSI and loading/processing the 45th cask in the spent fuel building
approximately 2,900 feet southeast of the Unit 1 reactor building within a separate  
          During the on-site inspection, the inspectors evaluated and observed the following
protected area. The pad was designed to hold 84 HI-STORM 100S (Version B)  
          activities:
loaded with the Multi-Purpose Canisters, each with 32 spent fuel assemblies  
              * Walk-down of the ISFSI haul path
(MPC-32). The pad is designed to store the casks in a 6 by 14 array. At the time of  
              * Transportation of the 44th cask on the vertical cask transporter from the spent
the routine loading inspection, the Comanche Peak ISFSI pad contained a total of 43  
                  fuel building to the ISFSI
HI-STORM 100S overpacks. The licensee was in the process of transporting the 44th  
              * Fuel assembly selection and placement into the 45th canister
cask to the ISFSI and loading/processing the 45th cask in the spent fuel building  
              * 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
During the on-site inspection, the inspectors evaluated and observed the following  
                  area
activities:  
              * Welding and non-destructive testing of the lid-to-shell weld
*  
              * Processing of the spent nuclear fuel for storage, including bulk water removal,
Walk-down of the ISFSI haul path  
                  forced helium dehydration, and helium backfill operations
*  
              * Final sealing of the canister, including welding of the vent and port cover
Transportation of the 44th cask on the vertical cask transporter from the spent  
                  plates, non-destructive testing, and helium leak-testing
fuel building to the ISFSI
          The inspectors reviewed and evaluated the following documentation during the
*  
          inspection:
Fuel assembly selection and placement into the 45th canister  
              * Fuel selection evaluations for the canisters loaded since the last NRC ISFSI
*  
                  inspection, the inspectors reviewed the contents of casks 40-45 against the
Heavy load lifts using the cask handling crane to remove the transfer cask  
                  license's Technical Specifications for approved contents
with the loaded canister from the spent fuel pool to the canister processing  
              * Radiation surveys for dose at the owner-controlled boundary to verify
area  
                  compliance with the requirements of 10 CFR 72.104 for calendar years 2019
*  
                  and 2020
Welding and non-destructive testing of the lid-to-shell weld  
              * Selected ISFSI related condition reports (CRs) issued since the last NRC
*  
                  ISFSI inspection (October 2019)
Processing of the spent nuclear fuel for storage, including bulk water removal,  
              * Quality assurance (QA) program implementation, including recent QA audits,
forced helium dehydration, and helium backfill operations  
                  surveillances, receipt inspection, and quality control activities related to ISFSI
*  
                  operations
Final sealing of the canister, including welding of the vent and port cover  
              * Compliance to Technical Specifications for operational surveillance activities
plates, non-destructive testing, and helium leak-testing  
                  and FSAR required annual maintenance activities
              * Documentation of annual maintenance activities for the sites cask handling
The inspectors reviewed and evaluated the following documentation during the  
                  crane and special lifting devices
inspection:  
              * Selected licensee design changes and program changes to the ISFSI
*  
                  performed under the site's 10 CFR 72.48 program
Fuel selection evaluations for the canisters loaded since the last NRC ISFSI  
                                                  8
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  


                *   Changes made by the licensee in the site's 72.212 Evaluation Report from
                    Revisions 11 to 12
9
INSPECTION RESULTS
  Failure of Unit 1 Turbine First Stage Pressure Line
*  
  Cornerstone           Significance                             Cross-Cutting     Report
Changes made by the licensee in the site's 72.212 Evaluation Report from  
                                                                  Aspect            Section
Revisions 11 to 12  
  Mitigating             Green                                     None (NPP)        71111.12
  Systems                FIN 05000445/2021001-01
INSPECTION RESULTS  
                        Open/Closed
  The inspectors identified a finding of very low safety significance (Green) following the failure
Failure of Unit 1 Turbine First Stage Pressure Line  
  of a weld on the main turbine first stage pressure transmitter root valve 1-MS-0285.
Cornerstone  
  Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new
Significance  
  valve was not the same model as the installed valve which resulted in premature failure of a
Cross-Cutting  
  weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown
Aspect
  to make repairs. The licensee failed to properly control inventory in the supply system. As a
Report  
  result, the licensee installed a valve in the plant without doing the necessary part evaluations
Section  
  needed to verify it was appropriate for the application.
Mitigating  
  Description: The licensee replaced the main turbine first stage pressure transmitter root
Systems
  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
Green  
  transmitter 1-PT-0505 failed low. A parallel indicator continued to function correctly. A
FIN 05000445/2021001-01
  non-licensed operator investigated the condition and observed a steam plume from the inlet
Open/Closed  
  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.
None (NPP)
  In order to understand the failure, the licensee contracted for an analysis of the failed weld.
71111.12
  The lab performing the analysis determined the weld failed as a result of fatigue crack
The inspectors identified a finding of very low safety significance (Green) following the failure  
  initiation. Further analysis by the licensee determined the failure occurred as a result of
of a weld on the main turbine first stage pressure transmitter root valve 1-MS-0285.  
  vibration at resonant frequency. This resonance response resulted from installation of a
Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new  
  valve that weighed 2 pounds more than the previously installed valve, which altered the
valve was not the same model as the installed valve which resulted in premature failure of a  
  natural frequency of the section of piping.
weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown  
  The inspectors reviewed the licensee's work order associated with valve replacement as well
to make repairs. The licensee failed to properly control inventory in the supply system. As a  
  as procurement documents associated with the work. Supply chain documents revealed that
result, the licensee installed a valve in the plant without doing the necessary part evaluations  
  the replacement valve was transferred to Comanche Peak from coal plant. When it arrived,
needed to verify it was appropriate for the application.  
  the licensee accepted the valve into their inventory under the Texas Utility part number. At
Description: The licensee replaced the main turbine first stage pressure transmitter root  
  the time, Texas Utility was the corporate owner of Comanche Peak and numerous fossil
valve 1-MS-0285 during the fall 2020 refueling outage as a preventive maintenance  
  plants. The licensee correlated the valve to locations for other steam instrument isolation
activity. Shortly after unit start up, on November 6, 2020, main turbine first stage pressure  
  valves; however, the valve was not initially correlated to location 1-MS-0285. An update to a
transmitter 1-PT-0505 failed low. A parallel indicator continued to function correctly. A  
  logistics database in 1998 correlated the part number to the location for 1-MS-0285. In
non-licensed operator investigated the condition and observed a steam plume from the inlet  
  reviewing the procedure in effect in 1990, the inspectors determined that the procedure
side of the instrument root valve 1-MS-0285. Since the leak could not be isolated, the  
  required the site to verify the materiel description matched that in the database for the part. If
licensee shut the unit down and replaced the valve.  
  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
In order to understand the failure, the licensee contracted for an analysis of the failed weld.  
  new part number.
The lab performing the analysis determined the weld failed as a result of fatigue crack  
  PT-0505 provides indication of turbine first stage pressure as well as input to Anticipated
initiation. Further analysis by the licensee determined the failure occurred as a result of  
  Transient without Scram Mitigation System Actuation Circuitry (AMSAC) and the P-13
vibration at resonant frequency. This resonance response resulted from installation of a  
  permissive. The AMSAC input allows AMSAC to arm when power is above 40 percent.
valve that weighed 2 pounds more than the previously installed valve, which altered the  
                                                  9
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.


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
10
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.
Since the instrument failed low, AMSAC would not automatically actuate and operators would  
However, the licensee did not pursue the underlying cause that allowed an incorrect valve to
have needed to manually initiate AMSAC if the system was needed. The P-13 permissive is  
be installed. The inspectors discussed potential performance deficiencies with the licensee
associated with P-7 permissive which blocks certain trips when at low power.  
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.
During review of this issue, the licensee identified the technical cause of the weld failure.  
Corrective Actions: The licensee documented the condition in their Corrective Action
However, the licensee did not pursue the underlying cause that allowed an incorrect valve to  
Program (CAP) as CR-2020-8429 and replaced the valve with the correct valve.
be installed. The inspectors discussed potential performance deficiencies with the licensee  
Corrective Action References: CR-2020-8429
which prompted the licensee to understand how the valve was issued for installation. The  
Performance Assessment:
licensee plans to incorporate this event into training for supply chain staff.  
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
Corrective Actions: The licensee documented the condition in their Corrective Action  
part evaluations needed to verify it was appropriate for the application. Consequently, the
Program (CAP) as CR-2020-8429 and replaced the valve with the correct valve.  
natural frequency of a high-pressure steam pressure transmitter piping changed causing
premature failure. Repair of the leak required a plant shutdown.
Corrective Action References: CR-2020-8429  
Screening: The inspectors determined the performance deficiency was more than minor
Performance Assessment:  
because it was associated with the Design Control attribute of the Mitigating Systems
 
cornerstone and adversely affected the cornerstone objective to ensure the availability,
Performance Deficiency: The licensee failed to properly control inventory in the supply  
reliability, and capability of systems that respond to initiating events to prevent undesirable
system. As a result, the licensee installed a valve in the plant without doing the necessary  
consequences. The inspectors determined that the performance deficiency was more than
part evaluations needed to verify it was appropriate for the application. Consequently, the  
minor because it adversely affected the mitigating system cornerstone objective of ensuring
natural frequency of a high-pressure steam pressure transmitter piping changed causing  
the reliability of systems that respond to initiating events. The performance deficiency had a
premature failure. Repair of the leak required a plant shutdown.  
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
Screening: The inspectors determined the performance deficiency was more than minor  
input to the P-13 permissive as well as the AMSAC system.
because it was associated with the Design Control attribute of the Mitigating Systems  
Significance: The inspectors assessed the significance of the finding using Appendix A, The
cornerstone and adversely affected the cornerstone objective to ensure the availability,  
Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed
reliability, and capability of systems that respond to initiating events to prevent undesirable  
the finding in using Appendix A of IMC 0609. The inspectors answered no to all of the
consequences. The inspectors determined that the performance deficiency was more than  
questions in Exhibit 2, section A because the affected mitigating systems were only briefly
minor because it adversely affected the mitigating system cornerstone objective of ensuring  
non-functional; therefore, the finding screened as Green.
the reliability of systems that respond to initiating events. The performance deficiency had a  
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to
substantive impact on the equipment performance attribute because the failure of the weld as  
this finding because the inspectors determined the finding did not reflect present licensee
a result of the performance deficiency led to PT-0505 unavailability. This instrument provides  
performance. Specifically, the part designation error occurred in 1998.
input to the P-13 permissive as well as the AMSAC system.  
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
Significance: The inspectors assessed the significance of the finding using Appendix A, The  
Observation: Actions to address weaknesses in engineering rigor                         71152
Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed  
The inspectors noted several examples in 2019 and 2020 regarding weaknesses in
the finding in using Appendix A of IMC 0609. The inspectors answered no to all of the  
engineering technical rigor. These examples are documented as samples in reports:
questions in Exhibit 2, section A because the affected mitigating systems were only briefly  
05000445/2019004; 05000446/2019004 (ML20041D968)
non-functional; therefore, the finding screened as Green.  
05000445/2020002; 05000446/2020002 (ML20217L240)
                                                10
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)  


  05000445/2020004; 05000446/2020004 (ML21040A051)
  The inspectors searched the corrective action program and identified several examples of
11
  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
05000445/2020004; 05000446/2020004 (ML21040A051)  
  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
The inspectors searched the corrective action program and identified several examples of  
  training on this frequency would not result in sustainable improvement. Subsequently, the
where the site had attempted to improve engineering technical rigor, however, the inspectors  
  inspectors discussed actions in place to improve and sustain engineering technical rigor. The
concluded that the prior efforts had not been sustainable. The inspectors also reviewed a  
  licensee informed the inspectors that the site would have biennial training on engineering
presentation on engineering technical rigor provided to engineering staff. The Inspectors  
  technical rigor. In addition, engineering supervisors provide reinforcement of engineering
noted that the training had not been given in over 10 years. The inspectors concluded that  
  rigor during one on one discussions with engineers and in staff meetings. If the licensee
training on this frequency would not result in sustainable improvement. Subsequently, the  
  maintains initiatives to improve engineering rigor, the inspectors expect to see improvement
inspectors discussed actions in place to improve and sustain engineering technical rigor. The  
  in engineering products.
licensee informed the inspectors that the site would have biennial training on engineering  
  Observation: Licensee Response to Frigid Weather                                     71153
technical rigor. In addition, engineering supervisors provide reinforcement of engineering  
During the week of February 14, 2021, Comanche Peak experienced frigid weather
rigor during one on one discussions with engineers and in staff meetings. If the licensee  
conditions for multiple days. Prior to the onset of the cold weather, the licensee
maintains initiatives to improve engineering rigor, the inspectors expect to see improvement  
implemented their abnormal procedure to prepare for cold weather with supplemental
in engineering products.  
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
Observation: Licensee Response to Frigid Weather  
experienced a grid frequency drop on February 15, 2021. As part of the response, as
71153  
specified in ABN-601 Response to a 138/345 KV System Malfunction, the licensee started
During the week of February 14, 2021, Comanche Peak experienced frigid weather  
train A emergency diesel generators in both units and transferred the train A emergency
conditions for multiple days. Prior to the onset of the cold weather, the licensee  
busses to the diesel. Concurrently, the shift manager contacted the grid operator and
implemented their abnormal procedure to prepare for cold weather with supplemental  
requested the grid operator recover grid frequency to greater than 59.9 Hz. The grid
actions based on operating experience. The inspectors performed walkdowns of licensee  
operator reduced grid load and operators restored the plant to a normal electrical
actions using inspection procedure 71111.01. Following the onset of cold weather, the site  
configuration. The inspectors verified the licensee responded in accordance with approved
experienced a grid frequency drop on February 15, 2021. As part of the response, as  
procedures by discussion, log reviews, and computer trend reviews. The licensee
specified in ABN-601 Response to a 138/345 KV System Malfunction, the licensee started  
maintained the plant in a stable condition with limited work activities for the rest of the
train A emergency diesel generators in both units and transferred the train A emergency  
week. The inspectors continued to monitor plant parameters and activities using
busses to the diesel. Concurrently, the shift manager contacted the grid operator and  
procedures 71111.13 and 71111.15. After the cold weather subsided, on February 20,
requested the grid operator recover grid frequency to greater than 59.9 Hz. The grid  
2021, the inspectors used inspection procedure 71111.04 to inspect the condition of
operator reduced grid load and operators restored the plant to a normal electrical  
systems and components susceptible to freezing. The inspectors concluded site personnel
configuration. The inspectors verified the licensee responded in accordance with approved  
maintained the plant in a safe condition and the cold weather did not cause significant
procedures by discussion, log reviews, and computer trend reviews. The licensee  
damage to the plant.
maintained the plant in a stable condition with limited work activities for the rest of the  
EXIT MEETINGS AND DEBRIEFS
week. The inspectors continued to monitor plant parameters and activities using  
The inspectors verified no proprietary information was retained or documented in this report.
procedures 71111.13 and 71111.15. After the cold weather subsided, on February 20,  
    * On January 21, 2021, the inspectors presented the Emergency Plan Revision In-Office
2021, the inspectors used inspection procedure 71111.04 to inspect the condition of  
        Review Results inspection results to Mr. Patrick Allen, Manager, Emergency
systems and components susceptible to freezing. The inspectors concluded site personnel  
        Preparedness and other members of the licensee staff.
maintained the plant in a safe condition and the cold weather did not cause significant  
    * On March 25, 2021, the inspectors presented the routine ISFSI inspection results to
damage to the plant.  
        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
EXIT MEETINGS AND DEBRIEFS  
        Mr. Thomas McCool and other members of the licensee staff.
                                                11
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.  


DOCUMENTS REVIEWED
  Inspection Type             Designation   Description or Title                                   Revision or
12
Procedure                                                                                          Date
60855     Corrective Action CR-YYYY-NNNN 2019-009399, 2020-001626, 2020-008755, 2021-001243,
DOCUMENTS REVIEWED  
            Documents        TR-YYYY-NNNN  TR-2019-008506, TR-2019-009009, TR-2020-000102,
   
                                            TR-2020-005224
Inspection  
  60855     Engineering       EVAL-2019-009 Nuclear Oversight Core Performance Engineering and Fuel 03/11/2020
Procedure
            Evaluations                     Management QA Audit
Type  
60855      Engineering      NUC 212 Cask Cask Acceptability Report and Comprehensive Assembly   09/05/2019
Designation  
            Evaluations       40            Specifications Supplement
Description or Title  
60855      Engineering      NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly   09/05/2019
Revision or  
            Evaluations       41            Specifications Supplement
Date  
60855      Engineering      NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly   09/05/2019
60855  
            Evaluations       42            Specifications Supplement
Corrective Action  
60855      Engineering      NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly   02/24/2021
Documents 
            Evaluations       43            Specifications Supplement
CR-YYYY-NNNN  
60855      Engineering      NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly   02/24/2021
TR-YYYY-NNNN
            Evaluations       44            Specifications Supplement
2019-009399, 2020-001626, 2020-008755, 2021-001243,
60855      Engineering      NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly   02/24/2021
TR-2019-008506, TR-2019-009009, TR-2020-000102,
            Evaluations      45            Specifications Supplement
TR-2020-005224  
  60855      Miscellaneous    72.212 Report CPNPP 10CFR72.212 Evaluation Report                     12
   
60855     Procedures       DCS-201       Transporting Loaded and Unloaded HI-STORM               9
60855  
60855     Procedures       DCS-202       MPC Preparation for Loading                             9
Engineering  
60855     Procedures       DCS-203       MPC Handling and Fuel Loading Operations               12
Evaluations 
60855     Procedures       DCS-204       MPC Closure Operations (Sealing, Drying, Backfilling)   13
EVAL-2019-009  
60855     Procedures       DCS-205       Stack-up and Transfer of Loaded MPC                     10
Nuclear Oversight Core Performance Engineering and Fuel  
60855     Procedures       OPT-102A-1   Operations Shiftly Routine Tests                       15
Management QA Audit
71111.01   Work Orders                     5939919
03/11/2020  
  71111.04   Procedures       SOP-102A     Residual Heat Removal System                           22
60855
71111.04   Work Orders                     5820443
Engineering
  71111.05   Fire Plans       FPI-108A     Fire Preplan for UNIT 1 SAFEGUARDS BUILDING MAIN       4
Evaluations
                                            STEAM PENETRATION AREA 880'-6"
NUC 212 Cask  
71111.05   Fire Plans       FPI-2001     Fire Preplan for FLEX STORAGE BUILDING X-FX-2K19       1
40
71111.05   Fire Plans       FPI-302A     Fire Preplan for UNIT 1 & 2 TURBINE BUILDING           8
Cask Acceptability Report and Comprehensive Assembly  
                                            ELEVATION 803'-0"
Specifications Supplement
                                                      12
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


Inspection Type             Designation     Description or Title                                           Revision or
Procedure                                                                                                  Date
13
71111.05   Fire Plans       FPI-701         Fire Preplan for SERVICE WATER INTAKE STRUCTURE               4
                                            ELEV. 796'-0" & 810'-6"
Inspection  
71111.07A NDE Reports                       Containment Spray Pump 1-01 and 1-03 Visual Inspection         01/20/2021
Procedure
                                            Report
Type  
71111.12   Corrective Action CR-YYYY-NNNN   2020-7695, 2020-8429
Designation  
          Documents
Description or Title  
71111.12   Miscellaneous                     Service water system health report                             08/25/2020
Revision or  
71111.12   Miscellaneous                     Maintenance Rule Database for Main Steam
Date  
71111.12   Miscellaneous                     Maintenance Rule Database for Unit 1 Service Water
71111.05  
71111.12   Miscellaneous     6S832645       Material Transfer Form                                         05/01/1990
Fire Plans
71111.12   Miscellaneous     MDIR-98-000314-                                                               03/13/1998
FPI-701  
                            00-00
Fire Preplan for SERVICE WATER INTAKE STRUCTURE  
71111.12   Procedures       MMO-6.09       TSN Assignment and Transfer of Warehouse Material.             0
ELEV. 796'-0" & 810'-6"  
71111.13   Procedures       STI-600.01,     Protecting Plant Equipment and Sensitive Equipment             3
4
                                            Controls
71111.07A NDE Reports
71111.15   Corrective Action CR-YYYY-NNNN   2021-001393, 2021-1224, 2021-553
          Documents
Containment Spray Pump 1-01 and 1-03 Visual Inspection  
71111.15   Miscellaneous     PQE 208         Rosemont Pressure Transmitter Plant Qualification             12/23/2018
Report 
                                            Evaluation
01/20/2021  
71111.18   Engineering       FDA-2017-       Modify 1-PT-0505                                               2
71111.12  
          Changes          000020-01-01
Corrective Action  
71111.19   Procedures       OPT-205B       Containment Spray System Post Test for WO 5813767 and         18
Documents 
                                            5813740
CR-YYYY-NNNN  
71111.19   Work Orders                       5405494, 595445
2020-7695, 2020-8429  
71111.19   Work Orders                       5958368
71111.22   Work Orders                       5790214
71111.12  
71114.04   Miscellaneous                     Comanche Peak Nuclear Power Plant Emergency Plan,             43
Miscellaneous
                                            Units 1 and 2
71114.04   Miscellaneous     AI-TR-2020-     Use of Terms "Onsite," "Offsite," "Site," "Site Boundary," and 09/16/2020
Service water system health report  
                            000756-13      "Exclusion Area" in the Emergency Plan
08/25/2020  
71114.04   Miscellaneous     CP-20200627,   Comanche Peak Nuclear Power Plant (CPNPP), Docket             11/12/2020
71111.12  
                            TXX-20093      Nos. 50-445, 50-446; Transmittal of Revised Emergency
Miscellaneous
                                            Plan (Revision 44)
71114.04   Miscellaneous     EV-TR-2018-     Remove Letter of Agreement References from Comanche           08/18/2020
Maintenance Rule Database for Main Steam  
                                                      13
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  


Inspection Type             Designation Description or Title                                   Revision or
Procedure                                                                                        Date
14
                            005896-5     Peak Emergency Plan Appendix H
71114.04   Procedures       EPP-123     10 CFR 50.54(q) Screening and Evaluation of Changes to 2
Inspection  
                                          Emergency Plan Documentation
Procedure
71152     Corrective Action CR-YYYY-NNNN 2018-1550, 2018-2038, 2020-008417
Type  
          Documents
Designation  
71152     Corrective Action TR-YYYY-NNNN 2018-2038 ,2018-5898, 2020-5057, 2021-000414
Description or Title  
          Documents
Revision or  
                                                    14
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
}}
}}

Latest revision as of 09:02, 29 November 2024

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