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| {{#Wiki_filter:May 11, 2021 | | {{#Wiki_filter: |
| Mr. Ken Peters
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| Senior Vice President
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| and Chief Nuclear Officer
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| VISTRA Operating Company, LLC
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| P.O. Box 1002
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| Glen Rose, TX 76043
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| SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
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| INTEGRATED INSPECTION REPORT 05000445/2021001 AND
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| 05000446/2021001
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| Dear Mr. Peters:
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| On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
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| at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 16, 2021, the NRC inspectors
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| discussed the results of this inspection with Mr. Thomas McCool and other members of your
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| staff. The results of this inspection are documented in the enclosed report.
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| One finding of very low safety significance (Green) is documented in this report. This finding did
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| not involve a violation of NRC requirements.
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| If you disagree with a finding not associated with a regulatory requirement in this report, you
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| should provide a response within 30 days of the date of this inspection report, with the basis for
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| your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control
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| Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and
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| the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2.
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| | |
| K. Peters 2
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| This letter, its enclosure, and your response (if any) will be made available for public inspection
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| and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
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| Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
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| Inspections, Exemptions, Requests for Withholding.
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| Sincerely,
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| Cornelius F. Digitally signed by
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| Cornelius F. O'Keefe
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| O'Keefe Date: 2021.05.11
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| 12:38:11 -05'00'
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| Neil F. O'Keefe, Chief
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| Reactor Projects Br B
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| Division of Reactor Projects
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| Docket Nos. 05000445 and 05000446
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| License Nos. NPF-87 and NPF-89
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| Enclosure:
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| As stated
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| cc w/ encl: Distribution via LISTSERV
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| | |
| | |
| ML21131A095
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| Non-Sensitive Publicly Available
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| 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
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| DATE 05/10/2021 04/28/2021 5/6/2021 05/06/2021
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| OFFICE BC:DRS/EB2 ABC:DRS/RCB BC:DRS/OB ABC:DNMS/RxIB
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| NAME NTaylor NHT JRollins JMR HGepford hjg NGreene / NAG
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| DATE 5/6/2021 5/10/2021 5/10/2021 05/06/2021
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| OFFICE SPE:DRP/B BC:DRP/B
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| NAME DProulx DLP NOKeefe nfo
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| DATE 5/10/2021 5/11/21
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|
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| U.S. NUCLEAR REGULATORY COMMISSION
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| Inspection Report
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| Docket Numbers: 05000445 and 05000446
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| License Numbers: NPF-87 and NPF-89
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| Report Numbers: 05000445/2021001 and 05000446/2021001
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| Enterprise Identifier: I-2021-001-0095
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| Licensee: VISTRA Operating Company, LLC
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| Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2
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| Location: Glen Rose, TX
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| Inspection Dates: January 1, 2021 to March 31, 2021
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| Inspectors: L. Brookhart, Senior Spent Fuel Storage Inspector
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| N. Day, Resident Inspector
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| J. Drake, Senior Reactor Inspector
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| J. Ellegood, Senior Resident Inspector
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| S. Hedger, Emergency Preparedness Inspector
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| J. Melfi, Project Engineer
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| Approved By: Neil F. O'Keefe, Jr., Chief
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| Reactor Projects Br B
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| Division of Reactor Projects
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| Enclosure
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| | |
| SUMMARY
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| The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
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| performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,
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| Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight
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| Process is the NRCs program for overseeing the safe operation of commercial nuclear power
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| reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
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| List of Findings and Violations
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| Failure of Unit 1 Turbine First Stage Pressure Line
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| Cornerstone Significance Cross-Cutting Report
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| Aspect Section
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| Mitigating Green None (NPP) 71111.12
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| Systems FIN 05000445/2021001-01
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| Open/Closed
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| The inspectors identified a finding of very low safety significance, Green, following the failure
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| of a weld on the root valve for the main turbine first stage pressure transmitter 1-PT-0505.
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| Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new
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| valve was not the same model as the installed valve which resulted in premature failure of a
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| weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown
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| to make repairs. The licensee failed to properly control inventory in the supply system. As a
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| result, the licensee installed a valve in the plant without doing the necessary part evaluations
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| needed to verify it was appropriate for the application.
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| Additional Tracking Items
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| None.
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| 2
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| | |
| PLANT STATUS
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| Units 1 began the inspection period at or near 100 percent power. On March 29, 2021, Unit 1
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| main feedwater pump A tripped. An automatic runback occurred in response to the main
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| feedwater pump trip which reduced power to about 57 percent. Unit 1 remained at about 57
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| percent power for the remainder of the inspection period.
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| Unit 2 operated at or near rated thermal power for the entire inspection period.
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| INSPECTION SCOPES
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| Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
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| effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
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| their attached revision histories are located on the public website at http://www.nrc.gov/reading-
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| rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
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| complete when the IP requirements most appropriate to the inspection activity were met
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| consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
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| Program - Operations Phase. The inspectors reviewed selected procedures and records,
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| observed activities, and interviewed personnel to assess licensee performance and compliance
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| with Commission rules and regulations, license conditions, site procedures, and standards.
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| Starting on March 20, 2020, in response to the National Emergency declared by the President
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| of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),
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| resident inspectors were directed to begin telework and to remotely access licensee information
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| using available technology. During this time, the resident inspectors performed periodic site
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| visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant
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| Status; observed risk-significant activities; and completed on-site portions of IPs. In addition,
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| resident and regional baseline inspections were evaluated to determine if all or portions of the
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| objectives and requirements stated in the IP could be performed remotely. If the inspections
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| could be performed remotely, they were conducted per the applicable IP. In some cases,
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| portions of an IP were completed remotely and on-site. The inspections documented below met
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| the objectives and requirements for completion of the IP.
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| REACTOR SAFETY
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| 71111.01 - Adverse Weather Protection
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| Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
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| (1) On February 11, 2021, the inspectors evaluated readiness for seasonal extreme
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| weather conditions prior to the onset of cold weather per procedure OWI-912, Cold
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| Weather, for the following systems:
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| Station Service Water
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| Fire Water
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| Emergency Diesel Generators
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| Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
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| 3
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| | |
| (1) The inspectors evaluated the adequacy of the overall preparations to protect
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| risk-significant systems from impending severe weather for high winds on January 14,
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| 2021
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| 71111.04 - Equipment Alignment
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| Partial Walkdown Sample (IP Section 03.01) (2 Samples)
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| The inspectors evaluated system configurations during partial walkdowns of the following
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| systems/trains:
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| (1) Systems, structures and components in service water and fire water for both units
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| that were vulnerable to freezing following extreme cold on February 20, 2021
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| (2) Unit 1, residual heat removal system A following quarterly surveillance on March 11,
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| 2021
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| 71111.05 - Fire Protection
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| Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
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| The inspectors evaluated the implementation of the fire protection program by conducting a
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| walkdown and performing a review to verify program compliance, equipment functionality,
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| material condition, and operational readiness of the following fire areas:
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| (1) Flex equipment storage building, area X-FX-2K19, on February 22, 2021
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| (2) Unit 1, main feedwater pumps, area TB, on March 12, 2021
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| (3) Station service water intake structure, area WB, on March 22, 2021
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| (4) Unit 1, safeguards building ventilation, area SK17a, on March 30, 2021
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| (5) Unit 1, main steam isolation and atmosphere relief valve room, area SK17c, on
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| March 30, 2021
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| Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
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| (1) The inspectors evaluated the onsite fire brigade training and performance during an
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| unannounced fire drill on March 18, 2021
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| 71111.06 - Flood Protection Measures
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| Cable Degradation (IP Section 03.02) (1 Sample)
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| The inspectors evaluated cable submergence protection in:
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| (1) Unit 1, station service water cable vault E1B2 on January 28, 2021.
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| 71111.07A - Heat Sink Performance
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| Annual Review (IP Section 03.01) (1 Sample)
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| The inspectors evaluated readiness and performance of:
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| (1) Unit 1, containment spray pump 1-01 and lube oil cooler 1-03
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| 4
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| | |
| 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
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| Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
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| (1 Sample)
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| (1) The inspectors observed and evaluated licensed operator performance in the control
| |
| room during service water restoration on March 26, 2021
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| Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
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| (1) The inspectors observed and evaluated a simulated complete loss of component
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| cooling water on January 27, 2021
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| 71111.12 - Maintenance Effectiveness
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| Maintenance Effectiveness (IP Section 03.01) (2 Samples)
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| The inspectors evaluated the effectiveness of maintenance to ensure the following
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| structures, systems, and components (SSCs) remain capable of performing their intended
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| function:
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| (1) Unit 1, service water pump fouling on November 18, 2020
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| (2) Failure of Unit 1 PT-0505, turbine first stage pressure transmitter, instrument line on
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| November 6, 2020
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| 71111.13 - Maintenance Risk Assessments and Emergent Work Control
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| Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
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| The inspectors evaluated the accuracy and completeness of risk assessments for the
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| following planned and emergent work activities to ensure configuration changes and
| |
| appropriate work controls were addressed:
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| (1) Unit 2, simultaneous scheduling power range nuclear instrument calibrations for N-41
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| and N-42 on January 4, 2021
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| (2) Unit 1, unplanned inoperability train B auxiliary feedwater (AFW) pump on January 6,
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| 2021
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| (3) Recovery of breaker 1A1-1, normal offsite power to nonvital 6.9KVon January 20,
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| 2021
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| (4) Low temperatures and high grid load during the week of February 15, 2021
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| (5) Extended service water pump 2-02 outage during the week of March 22, 2021
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| (6) Unit 1, repairs to main feed pump A during the week of March 29, 2021
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| 71111.15 - Operability Determinations and Functionality Assessments
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| Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
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| 5
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| The inspectors evaluated the licensee's justifications and actions associated with the
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| following operability determinations and functionality assessments:
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| (1) Unit 1, repair of B AFW pump flow transmitter
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| (2) Operability of 2-01 emergency diesel generator with unit trip light illuminated
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| (3) Offsite power with low frequency on February 15, 2021
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| (4) Service water pumps pursuant to Generic Letter 91-13.
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| (5) Circuit breaker 1EB3-3 due to missing overcurrent testing
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| 71111.18 - Plant Modifications
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| Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
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| (1 Sample)
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| The inspectors evaluated the following permanent modification:
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| (1) Unit 1, PT-0505 modification to improve vibration resilience
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| 71111.19 - Post-Maintenance Testing
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| Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
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| The inspectors evaluated the following post-maintenance test activities to verify system
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| operability and functionality:
| |
| (1) Unit 1, motor driven AFW flow transmitter 1-FT-2457 on
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| January 12, 2021
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| (2) Component cooling water pump 1-02 breaker replacement on February 4, 20201.
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| (3) Unit 2, main steam isolation valve 2-03 following pressure gauge root valve leak on
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| February 25, 2021
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| (4) Unit 2, replacement of train A accident sequencer optical isolator on March 16, 2021
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| (5) Service water pump 2-02 following replacement on March 27, 2021
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| 71111.22 - Surveillance Testing
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| The inspectors evaluated the following surveillance tests:
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| Surveillance Tests (other) (IP Section 03.01) (2 Samples)
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| (1) Unit 2, power range nuclear instrument on January 5, 2021
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| (2) Unit 2, reactor trip breaker B on January 25, 2021
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| 71114.04 - Emergency Action Level and Emergency Plan Changes
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| Inspection Review (IP Section 02.01-02.03) (1 Sample)
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| (1) The licensee submitted a summary of emergency plan changes (Revision 44) to the
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| 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
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| approval
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| 6
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| OTHER ACTIVITIES - BASELINE
| |
| 71151 - Performance Indicator Verification
| |
| The inspectors verified licensee performance indicators submittals listed below:
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| IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)
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| (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)
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| (2) Unit 2 (January 1, 2020, through December 31, 2020)
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| 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
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| 71153 - Followup of Events and Notices of Enforcement Discretion
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| 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
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| (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
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| HI-STORM ISFSI Final Safety Analysis Report (FSAR), Revision 9. The inspectors reviewed
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| selected procedures, corrective action reports, and records to verify ISFSI operations were
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| 7
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| | |
| compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC
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| regulations
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| Operation Of An ISFSI (1 Sample)
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| (1) The inspectors evaluated the licensees dry cask storage operations, from March 22
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| 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
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| (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
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| with the loaded canister from the spent fuel pool to the canister processing
| |
| area
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| * Welding and non-destructive testing of the lid-to-shell weld
| |
| * Processing of the spent nuclear fuel for storage, including bulk water removal,
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| 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
| |
| 8
| |
| | |
| * Changes made by the licensee in the site's 72.212 Evaluation Report from
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| Revisions 11 to 12
| |
| INSPECTION RESULTS
| |
| Failure of Unit 1 Turbine First Stage Pressure Line
| |
| Cornerstone Significance Cross-Cutting Report
| |
| Aspect Section
| |
| Mitigating Green None (NPP) 71111.12
| |
| Systems FIN 05000445/2021001-01
| |
| Open/Closed
| |
| 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.
| |
| 9
| |
| | |
| 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)
| |
| 10
| |
| | |
| 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.
| |
| 11
| |
| | |
| DOCUMENTS REVIEWED
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 60855 Corrective Action CR-YYYY-NNNN 2019-009399, 2020-001626, 2020-008755, 2021-001243,
| |
| Documents TR-YYYY-NNNN TR-2019-008506, TR-2019-009009, TR-2020-000102,
| |
| TR-2020-005224
| |
| 60855 Engineering EVAL-2019-009 Nuclear Oversight Core Performance Engineering and Fuel 03/11/2020
| |
| Evaluations Management QA Audit
| |
| 60855 Engineering NUC 212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
| |
| Evaluations 40 Specifications Supplement
| |
| 60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
| |
| Evaluations 41 Specifications Supplement
| |
| 60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
| |
| Evaluations 42 Specifications Supplement
| |
| 60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
| |
| Evaluations 43 Specifications Supplement
| |
| 60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
| |
| Evaluations 44 Specifications Supplement
| |
| 60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
| |
| Evaluations 45 Specifications Supplement
| |
| 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 4
| |
| STEAM PENETRATION AREA 880'-6"
| |
| 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 8
| |
| ELEVATION 803'-0"
| |
| 12
| |
| | |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 71111.05 Fire Plans FPI-701 Fire Preplan for SERVICE WATER INTAKE STRUCTURE 4
| |
| ELEV. 796'-0" & 810'-6"
| |
| 71111.07A NDE Reports Containment Spray Pump 1-01 and 1-03 Visual Inspection 01/20/2021
| |
| Report
| |
| 71111.12 Corrective Action CR-YYYY-NNNN 2020-7695, 2020-8429
| |
| Documents
| |
| 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- 03/13/1998
| |
| 00-00
| |
| 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 3
| |
| Controls
| |
| 71111.15 Corrective Action CR-YYYY-NNNN 2021-001393, 2021-1224, 2021-553
| |
| Documents
| |
| 71111.15 Miscellaneous PQE 208 Rosemont Pressure Transmitter Plant Qualification 12/23/2018
| |
| Evaluation
| |
| 71111.18 Engineering FDA-2017- Modify 1-PT-0505 2
| |
| Changes 000020-01-01
| |
| 71111.19 Procedures OPT-205B Containment Spray System Post Test for WO 5813767 and 18
| |
| 5813740
| |
| 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, 43
| |
| Units 1 and 2
| |
| 71114.04 Miscellaneous AI-TR-2020- Use of Terms "Onsite," "Offsite," "Site," "Site Boundary," and 09/16/2020
| |
| 000756-13 "Exclusion Area" in the Emergency Plan
| |
| 71114.04 Miscellaneous CP-20200627, Comanche Peak Nuclear Power Plant (CPNPP), Docket 11/12/2020
| |
| TXX-20093 Nos. 50-445, 50-446; Transmittal of Revised Emergency
| |
| Plan (Revision 44)
| |
| 71114.04 Miscellaneous EV-TR-2018- Remove Letter of Agreement References from Comanche 08/18/2020
| |
| 13
| |
| | |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 005896-5 Peak Emergency Plan Appendix H
| |
| 71114.04 Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 2
| |
| Emergency Plan Documentation
| |
| 71152 Corrective Action CR-YYYY-NNNN 2018-1550, 2018-2038, 2020-008417
| |
| Documents
| |
| 71152 Corrective Action TR-YYYY-NNNN 2018-2038 ,2018-5898, 2020-5057, 2021-000414
| |
| Documents
| |
| 14
| |
| }} | | }} |
