IR 05000445/2018004
| ML19042A345 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/11/2019 |
| From: | Mark Haire NRC/RGN-IV/DRP/RPB-A |
| To: | Peters K Vistra Operating Co. (VistraOpCo) |
| References | |
| IR 2018004 | |
| Download: ML19042A345 (52) | |
Text
ary 11, 2019
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2018004 and 05000446/2018004
Dear Mr. Peters:
On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 31, 2019, the NRC inspectors discussed the results of this inspection with Tom McCool, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented four findings of very low safety significance (Green) in this report.
All of these findings involved violations of NRC requirements; one of these violations was determined to be Severity Level IV under the traditional enforcement process. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment 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; the Director, Office of Enforcement; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Mark S. Haire, Chief Project Branch A Division of Reactor Projects Docket Nos. 50-445 and 50-446 License Nos. NPF-87 and NPF-89 Enclosure:
Inspection Report 05000445/2018004 and 05000446/2018004 w/ Attachments:
1. Documents Reviewed 2. Request for Information 3. Request for Information
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000445, 05000446 License Numbers: NPF-87, NPF-89 Report Numbers: 05000445/2018004 and 05000446/2018004 Enterprise Identifier: I-2018-004-0011 Licensee: Vistra Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, Texas Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: J. Josey, Senior Resident Inspector R. Kumana, Resident Inspector S. Hedger, Emergency Preparedness Inspector L. Carson II, Senior Health Physicist N. Green, PhD. Senior Health Physicist J. Drake, Senior Reactor Inspector Approved By: Mark S. Haire Chief, Project Branch A Division of Reactor Projects Enclosure
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.
NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.
List of Findings and Violations Programmatic Failures Related to Procedures for the Control Transient Combustibles Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.2 - Field 71111.05AQ Systems NCV 05000446/2018004-01 Presence Fire Closed Protection The inspectors identified a Green, non-cited violation of Operating License NPF-89, License Condition 2.G, "Fire Protection Program," for the failure to control transient combustibles in accordance with the station's Fire Protection Report. The licensee entered this issue into the corrective action program as Condition Report (CR) 2018-008405.
Inadequate Procedure for Alignment of Priority Panels Normally Aligned to Class 1E Power Cornerstone Cornerstone Cross-cutting Inspection Aspect Procedure Mitigating Green None 71111.15 Systems Severity Level IV Operability NCV 05000445;05000446/2018004-02 Determinations Closed and Functionality Assessments The inspectors identified a Green, Severity Level IV, non-cited violation of Technical Specification 5.4.1.a associated with the failure to establish, implement, and maintain procedures for operation and maintenance of electrical systems, which are recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. The licensee entered this issue into the corrective action program as CR-2018-006180 and CR-2019-001052.
Failure to Correct a Condition Adverse to Quality Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.5 - 71111.15 Systems NCV 05000445;05000446/2018004-03 Work Operability Closed Management Determinations and Functionality Assessments The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, for the licensees failure to take corrective actions for condition adverse to quality. Specifically, a failure of a 1E power supply resulted in technical specification equipment being powered from non-1E power and the licensee closed all corrective actions and work orders without correcting the adverse condition. The licensee entered this issue into the corrective action program as CR-2018-007972.
Failure to Perform Evaluations of State and Local Government Interface Based on Licensee Performance Indicators Cornerstone Significance Cross-cutting Inspection Aspect Procedure Emergency Green None 71114.05 Preparedness NCV 05000445;05000446/2018004-04 Maintenance Closed of Emergency Preparedness The inspectors identified a Green, non-cited violation of 10 CFR 50.54(t) for failure to evaluate the adequacy of interfaces with State and local governments based on assessment against performance indicators. Specifically, the licensee failed to develop and use performance indicators assessing the quality of the interface between licensee and State and local agencies in support of a 24-month review frequency for this aspect of the emergency preparedness program. The licensee entered the issue in the corrective action program in document CR-2018-008140.
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On December 3, 2018, the unit was down powered to 95 percent due to an unplanned loss of the 138kV switchyard and actuation of auxiliary feedwater. The unit was returned to rated thermal power on the same day. On December 8, 2018, the unit was shut down to commence a refueling outage. The unit remained shutdown for the remainder of the 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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
REACTOR SAFETY
71111.01 Adverse Weather Protection Seasonal Extreme Weather
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of cold weather on December 8, 2018.
71111.04 Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Common transformer XST2A after placement in service on November 7, 2018
- (2) Unit 1 train A battery during cell replacement on November 9, 2018
- (3) Unit 2 uninterruptable power supply (UPS) cooling during core offload on December 26, 2018
71111.05AQ Fire Protection Annual/Quarterly Quarterly Inspection
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Fire zone EC49 and EH56, Unit 1 battery room on November 8, 2018
- (2) Yard fire area, Transformer XST2A on November 9, 2018
- (3) Fire zone 2SK17A, Unit 2 feed injection room on November 28, 2018
- (4) Fire zone 2SD9, Unit 2 train A switchgear room on December 20, 2018
Annual Inspection (1 Sample)
The inspectors evaluated fire brigade performance on November 14, 2018.
71111.07 Heat Sink Performance Heat Sink
The inspectors evaluated UPS chillers performance on December 19, 2018.
71111.08 Inservice Inspection Activities
The inspectors evaluated non-destructive testing by observing and reviewing the following activities:
- (1) Visual Testing 1 a) SW-2-AB-005-H3-WA, Station Service Water Hangar
- (2) Visual Testing 3 a) SW-2-AB-005-H3, Station Service Water Hangar b) TCX-1-4202-H4, Safety Injection Hangar c) TCX-1-4205-H25, Safety Injection Hangar
- (3) Ultrasonic Testing a) TCX-1-4306-1, Reactor Coolant System T-to-Pipe Weld b) TCX-1-4306-1, Reactor Coolant System Reducer-to-Pipe Weld
- (4) Penetrant Testing a) TCX-2-2533-H6-WA, Safety Injection System Lugs b) TCX-2-3100-1-1WS, Residual Heat Removal Pump 1 Lug The inspectors evaluated the licensees boric acid control program performance.
The inspectors evaluated the results of the licensees bare metal visual inspection of the reactor vessel upper head penetrations. The inspectors also reviewed whether the required inspection coverage was achieved and whether limitations were properly recorded. The inspectors reviewed whether the personnel performing the inspection were certified examiners to their respective nondestructive examination method.
The inspectors evaluated the steam generator tube eddy current examination scope and criteria to determine whether it met technical specification requirements, Electric Power Research Institute guidelines, and commitments made to the NRC. The inspectors verified that the number and sizes of steam generator tube flaws/degradation identified was consistent with the licensees previous outage operational assessment predictions. The inspectors confirmed that no repairs were required at the time of the inspection.
The inspectors verified that no new degradation mechanism was identified during the eddy current examinations.
The inspectors evaluated a sample of condition and issue reports associated with inservice inspection activities.
71111.11 Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated a crew during an evaluated simulator scenario on
===October 23, 2018.
Operator Performance (1 Sample)===
The inspectors observed and evaluated operator performance during the following activities:
- (1) Unit 1 control room operators during a loss of 25KV power on October 15, 2018
- (2) Unit 2 control room operators during reactor shutdown on December 8, 2018
- (3) Unit 2 control room operators during core alterations on December 27, 2018
71111.12 Maintenance Effectiveness Routine Maintenance Effectiveness
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety-significant functions:
- (1) Unit 1 battery chargers on November 20, 2018
- (2) Unit 1 diesel generator jacket water on December 21, 2018
71111.13 Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1 compensatory measures while replacing diesel generator 1-02 annunciator system power supply 1-EQ-3418 on October 16, 2018
- (2) Risk management actions during swap of transformer XST2 to XST2A on October 26, 2018
- (3) Unit 2 elevated risk during performance of diesel generator fuel transfer pump test on October 30, 2018
- (4) Unit 2 elevated risk during lithium flush using residual heat removal pump 2-01 on November 7, 2018
- (5) Risk management actions during Unit 1 battery cell replacement on November 9, 2018
- (6) Unit 1 elevated risk during turbine driven auxiliary feedwater valve stroke on November 29, 2018
- (7) Risk management for refueling outage 2RF17 defense in depth on December 7, 2018
- (8) Risk management actions during turbine stator lift on December 17, 2018
71111.15 Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 1, replacement of diesel generator 1-02 annunciator system power supply on October 16, 2018
- (2) Unit 1, excessive battery charger ripple voltage on October 19, 2018
- (3) Unit 2, steam generator 2-01 low snubber oil reservoir level on October 24, 2018
- (4) Unit 2, component cooling water heat exchanger outlet temperature loop instrument calibration frequency on October 25, 2018
- (5) Unit 2, failure of transfer switch for bus XEC1 on November 27, 2018
71111.18 Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) Installation of transformer XST1A on November 27, 2018
- (2) Addition of battery cells to Unit 1 batteries on December 13, 2018
71111.19 Post Maintenance Testing
The inspectors evaluated the following post-maintenance tests:
- (1) Unit 1, containment air lock following relief valve replacement on October 17, 2018
- (2) Unit 1, battery 1-02 following cell replacement on November 19, 2018
- (3) Unit 1, turbine driven auxiliary feedwater isolation valve following repair on December 3, 2018
- (4) Unit 2, battery 2-01 following cell addition on December 18, 2018
===71111.20 Refueling and Other Outage Activities (Partial Sample)
The inspectors evaluated refueling outage 2RF17 activities from December 8, 2018, to December 31, 2018. The inspectors completed inspection Procedure 71111.20 Sections 03.01.a through c.
71111.22 Surveillance Testing The inspectors evaluated the following surveillance tests:
Routine ===
- (1) Unit 2, containment sump inspection on December 26, 2018
Containment Isolation Valve (1 Sample)
- (1) Unit 2, safety injection check valves 2-8956A and 2-8956B on November 13, 2018
71114.02 Alert and Notification System Testing
The inspectors evaluated the maintenance and testing of the alert and notification system between March 1, 2016, and October 12, 2018.
71114.03 Emergency Response Organization Staffing and Augmentation System
The inspectors evaluated the readiness of the Emergency Response Organization between March 1, 2016, and October 12, 2018. The inspectors also evaluated the licensees ability to staff their emergency response facilities in accordance with emergency plan commitments.
71114.04 Emergency Action Level and Emergency Plan Changes
The inspectors evaluated Emergency Plan, Revision 42, submitted on August 9, 2018. In addition, the inspector evaluated the 10 CFR 50.54(q) emergency plan change process and practices between March 1, 2016, and October 12, 2018. The evaluation reviewed screenings and evaluations documenting the implementation of this process. The reviews of the change process documentation and the Emergency Plan change do not constitute NRC approval.
71114.05 Maintenance of Emergency Preparedness
The inspectors evaluated the maintenance of the emergency preparedness program between March 1, 2016, and October 12, 2018. The evaluation reviewed activations of the emergency plan, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.
RADIATION SAFETY
71124.01 Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
71124.02 Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Implementation of ALARA and Radiological Work Controls
The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:
- (2) RWP 2018-2102, Locked High Radiation Area (LHRA) RP Balance of Plant (BOP)
- (3) RWP 2018-2214, Reactor Vessel Annulus, Seal Table Activities, Eddy Current Test
- (4) RWP 2018-2215, 2RF17 Scaffold Activities
- (5) RWP 2018-2601, Maintenance Activities
Radiation Worker Performance (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance.
OTHER ACTIVITIES - BASELINE
71151 Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
- (1) MS09: MSPI Residual Heat Removal Systems (10/01/2017-09/30/2018)
- (2) MS10: MSPI Cooling Water Support Systems (10/01/2017-09/30/2018)
- (3) EP01: Drill/Exercise Performance (DEP) Sample (07/01/2017 - 09/30/2018)
- (4) EP02: Emergency Response Organization (ERO) Drill Participation Sample (07/01/2017
- 09/30/2018)
- (5) EP03: Alert and Notification System (ANS) Reliability Sample (07/01/2017 -
09/30/2018)
- (6) OR01: Occupational Exposure Control Effectiveness Sample (04/01/2017 - 09/30/2018)
- (7) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (04/01/2017 - 09/30/2018)
71152 Problem Identification and Resolution Semiannual Trend Review
The inspectors reviewed the licensees corrective action program for trends associated with the failure to follow the requirements of station Procedure STA-206, Review of Vendor Documents and Vendor Technical Manuals, that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Post-accident-monitoring system unavailable for greater than 30 days on December 20, 2018
- (2) Non-conservative calculation for steam generator water level limits on November 21, 2018
71153 Follow-up of Events and Notices of Enforcement Discretion Personnel Performance
The inspectors evaluated loss of 138kV and actuation of Unit 2 AFW and the licensees performance on December 2,
INSPECTION RESULTS
Programmatic Failures Related to Procedures for the Control Transient Combustibles Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.2 - Field 71111.05AQ Systems NCV 05000446/2018004-01 Presence Fire Closed Protection The inspectors identified a Green, non-cited violation of Operating License NPF-89, License Condition 2.G, "Fire Protection Program," for the failure to control transient combustibles in accordance with the station's Fire Protection Report.
Description:
From December 10-20, 2018, the inspectors performed walkdowns of the plant.
During these walkdowns, the inspectors observed the following conditions:
1. Quantities of plastic, oily rags, and cardboard that remained in the plant after end of shift. The initial response provided when the issue was brought to licensee personnel was that the work was still in progress; therefore, the material could be stored in the various locations.
2. Three cans of combustible liquids and a quantity of flammable aerosols not in flammable liquid storage lockers or under the control of individuals. The initial response from the licensee was that per STA-728, Storage And Handling Of Flammable/
Combustible Material and Compressed/Cryogenic Gases, Revision 5, Section 6.1.9, flammable/combustible liquids which are incidental to an activity and kept in an area do not have to be kept in an approved storage area or cabinet if the on-hand amount is:
a. 10 Gallons or less of flammable/combustible liquids in the original manufacturers container and/or in safety cans; or b. 25 Gallons or less of flammable/combustible liquids in safety cans. If the on-hand quantity of flammable/combustible liquids exceeds these quantities, the materials should be kept in an approved storage area in accordance with Section 6.2.
The inspectors reviewed Station Procedure STA-728, Storage of Combustible and Flammable Liquids, and STA-729, Control of Transient Combustibles, Ignition Sources and Fire Watches, Revision 11, which are the procedures used by the licensee to control transient combustibles in the plant. The inspectors noted that these procedures contained the following definitions and requirements:
- STA-729, Section 6.1.5, states, in part, that, Debris and waste such as flammable liquids, plastics, HEPA filters, Bituminous filter medium, oily rags, and other combustible supplies resulting from work activities shall be removed from plant areas at the end of each work activity or at the end of each shift, whichever is sooner. Plastic materials should only be used when alternate non-combustible materials are not available.
Contrary to this requirement, the licensee allowed quantities of plastic, oily rags, and cardboard to remain in the plant after end of shift.
- Procedure STA-729, Section 4.21, defines Incidental transient combustible material, in part, as hand carried items directly under an individuals control and that are attended by an individual at all times while within the power block. However, Procedure STA-728, Section 6.1.9, states that flammable/combustible liquids which are incidental to an activity and kept in an area do not have to be kept in an approved storage area or cabinet.
- Procedure STA-728 provides the following definitions:
o 4.5 Combustible Liquid - Any liquid with a flash point at or above 100 degrees F.
o 4.10 Flammable Liquid - A liquid having a flash point of not more than 93 degrees C. (199.4 degrees F).
This definition for flammable liquid implies that a combustible liquid is a greater hazard than a flammable liquid and is in conflict with the definition provided in STA 729.
Procedure STA-729 contains the following definition for flammable liquid:
o 4.12 Flammable Liquid - Any liquid with a flash point below 100 degrees F and a vapor pressure that does not exceed 40 psia at 100 degrees F (i.e., acetone, alcohols, gasoline, etc.).
Inspectors determined that the definition contained in STA-729 aligned with the definition contained in NFPA-30 which is the standard identified in the stations approved Fire Protection Report, and that the STA-728 definition aligns with an OSHA definition which is not part of the stations approved Fire Protection Report. Therefore, the inspectors determined that the information in STA-728 was contrary to the stations approved licensing basis.
Inspectors also noted that STA-728 delineates the following responsibilities:
- 5.1 Department managers/supervisors are responsible for the safe handling and storage of all flammable/combustible materials and compressed gases assigned to or in use by their departments.
- 5.3 Fire protection maintenance supervisor is responsible for the inspection and authorization of all flammable/combustible material and compressed gas storage areas.
Based on these observations, and review of two of the fire protection procedures, the inspectors determined that the licensee had failed to implement the requirements of the station's approved Fire Protection Program when storing and controlling combustible materials.
Corrective Action(s): The licensee removed the combustible materials from the impacted areas, and/or established appropriate compensatory measures in accordance with the Fire Protection Program and entered the procedure conflicts and discrepancies into the corrective action program.
Corrective Action Reference: Document CR-2018-008405
Performance Assessment:
Performance Deficiency: The licensees failure to control transient combustible material in accordance with the approved Fire Protection Program is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against the external factors attribute of the Mitigating System 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. Specifically, the failure of licensee personnel to implement proper control of transient combustible materials decreased the external event mitigation for fire prevention. Furthermore, the inspectors determined that this was a programmatic issue since multiple departments and multiple levels of management were responsible for the inappropriate control of combustible materials in the plant and the conflicting information in Procedures STA-728 and STA-729.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination Process," May 02, 2018, and determined that the finding was of very low safety significance (Green) because the identified fire prevention and administrative controls issues would not prevent the reactor from reaching and maintaining a safe shutdown condition because none of the examples impacted both trains of safe shutdown equipment.
Cross-Cutting Aspect: The finding has a cross-cutting aspect in the area of human performance, field presence, because leaders failed to reinforce standards and expectations
[H.2].
Enforcement:
Violation: Comanche Peak Unit 2, Operating License NPF-89, Condition 2.G, "Fire Protection," requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27.
The stations approved fire protection program includes Fire Protection Report, Revision 29, which is implemented by Procedures STA-728, Storage of Combustible and Flammable Liquids, and STA-729, Control of Transient Combustibles, Ignition Sources and Fire Watches, to control transient and other combustible/flammable materials.
Contrary to the above, between December 10 and December 20, 2018, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27. Specifically, the licensee allowed storage of combustible materials contrary to the requirements of Procedures STA-728, Storage of Combustible and Flammable Liquids, and STA-729, Control of Transient Combustibles, Ignition Sources and Fire Watches.
Enforcement Action(s): This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Procedure for Alignment of Priority Panels Normally Aligned to Class 1E Power Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green None 71111.15 Systems Severity Level IV Operability NCV 05000445;05000446/2018004-02 Determinations Closed and Functionality Assessments The inspectors identified a Green, Severity Level IV, non-cited violation of Technical Specification 5.4.1.a associated with the failure to establish, implement, and maintain procedures for operation and maintenance of electrical systems, which are recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Description:
The inspectors found that the licensee had a common 120 V power panel, panel XEC1, aligned to its off-normal non-Class-1E power source. The panel is normally powered from Class-1E 480 V panel XEB3-2, but is capable of being aligned to non-Class-1E panel XB2-2 using Procedure SOP-608A, 120, 208, 208/120 and 120/240 VAC Distribution System. Panel XB2-2 is, in turn, normally powered by Unit 1 non-Class-1E bus 1B2. In August 2016, after performing maintenance with XEC1 aligned to the non-Class-1E power source (XB2-2), the licensee was unable to restore XEC1 to its normal Class-1E source due to a failure of its transfer switch. The licensee left the panel aligned to XB2-2 and entered the failure into the corrective action program.
When the licensee reviewed the condition for its impact to operability and functionality on September 2, 2016, the licensee determined that the supported equipment was operable because XEC1 was energized from its maintenance bypass power source which is allowed per SOP-608A. The inspectors reviewed Procedure SOP-608A and concluded that the procedure was inadequate because, in establishing the procedural guidance to align XEC1 to a non-Class-1E alternate source, the licensee did not consider the impact of the alignment to the non-Class-1E power source on the current licensing basis of the safety-related and important-to-safety equipment supported by XEC1, and did not identify that compensatory measures were needed to support a determination of operability and functionality of the supported equipment.
The inspectors determined that the procedure section for alignment of XEC1 contained guidance for maintenance that can affect the performance of safety-related equipment, and that it was required by Regulatory Guide 1.33, Revision 2, Appendix A, Section 9. The procedure contained no guidance for ensuring that safety-related and important-to-safety equipment maintained their operability and functionality during the non-Class-1E power alignment.
The inspectors identified several safety-related and important-to-safety systems, structures and components (SSCs) that were affected by aligning XEC1 to non-Class-1E power. Some of the affected SSCs required the implementation of compensatory measures to ensure operability and functionality, but the licensee had not identified and implemented these compensatory measures when SOP-608A was implemented to align XEC1 to non-Class-1E power.
- The solid state protection system (SSPS) relay that actuates the containment vent isolation (CVI) system for Unit 1 is powered by XEC1. During the time that XEC1 was aligned to non-Class-1E power, a failure of non-Class-1E power to XB2-2 would cause a failure of a protection system required to be operable by Technical Specification 3.3.6, Containment Ventilation Isolation Instrumentation. The containment pressure relief system is a system required during normal operations to maintain containment pressure within the limits of Technical Specification 3.6.4, and compensatory measures are required to maintain operability while XEC1 is aligned to non-Class-1E power.
- Several radiation monitors required to be operable by the Offsite Dose Calculation Manual are powered by XEC1. While XEC1 is powered from non-Class-1E power, compensatory measures are required to maintain the operability of these monitors.
o The Unit 2 station service water liquid effluent monitors 2-RUK-4269 and 2-RUK-4270 are required to be operable by ODCM Technical Specification (TS) 3.3.3.4, Radioactive Liquid Effluent Instrumentation. If either of them were to be inoperable, the ODCM required the licensee to monitor the component cooling water liquid effluent monitors. However, all three of those monitors are also powered by XEC1. This resulted in a condition where the only way to comply with the ODCM in the event of a loss of non-safety power to XB2-2 would be to perform manual samples as compensatory measures.
o The liquid effluent monitors for the Unit 1 turbine building sump and the auxiliary building discharge are powered from XEC1 and required to be operable by ODCM TS 3.3.3.4. A loss of power to these monitors would require manual compensatory measures.
- Several radiation monitors used as inputs to emergency action level declarations are powered from XEC1. While XEC1 is powered from non-Class-1E power, compensatory measures are required to maintain the functionality of these inputs to the emergency plan.
o The gross failed fuel monitor is powered from XEC1 and is used to classify an unusual event, or an alert for a loss of the fuel cladding barrier.
o The Unit 2 station service water liquid effluent monitors 2-RUK-4269 and 2-RUK-4270 are used to classify an unusual event. The component cooling water radiation monitors would normally be used as a backup; however, they are also powered by XEC1.
- Several radiation monitors required to function post-accident by 10 CFR 50, Appendix A, Criteria 13 and 64, and designated as Category 2 in accordance with Regulatory Guide 1.97, Revision 2, are powered by XEC1, and are required to be powered by a highly reliable power source. While XEC1 is powered from non-Class-1E, these monitors do not meet the power supply requirements. These monitors include the Unit 1 condenser off-gas monitor, the Unit 2 steam generator blowdown line monitor, the auxiliary building discharge monitor, and the Unit 1 turbine building sump monitor. Compensatory actions would be required to monitor these Category 2 variables during an accident.
- Several fire detection panels receive power from XEC1. In addition, the control panel for halon actuation is powered from XEC1. Compensatory measures would be required upon loss of power to XEC1.
- The solid state isolation cabinets 1-CR-07, 1-CR-16, and 2-CR-07 receive AC power from XEC1. These cabinets are safety-related and require Class 1E power.
- The control room ventilation communication isolation devices X-RY-5895A-2 and X-RY-5895B are powered by XEC1. These devices are safety-related and require Class 1E power.
- The loose parts monitoring system is powered from XEC1 and is required to be operable by the Technical Requirements Manual.
The inspectors reviewed the 50.59 screen performed to evaluate the change to the procedure allowing alignment to non-Class-1E maintenance bypass power. The inspectors found that the screen simply stated that it was being done to incorporate modification DM 95-097, Maintenance Bypass Transformer TXEC1/2, and that the changes done for the modification governed energizing, de-energizing and transferring operations. Inspectors then reviewed the 50.59 performed for DM 95-097 and determined that the licensee had failed to identify the impact to Unit 1 technical specifications associated with the SSPS relay since power panel XB2-2 could be powered from Unit 2. Specifically, this allowed lineup creates the possibility of a cross-unit interaction where a failure of non-safety power on Unit 2 would cause a failure of the Unit 1 protection system required to be operable by Technical Specification 3.3.6, Containment Ventilation Isolation Instrumentation. Inspectors determined that this potential for cross-unit interaction represented a change to technical specifications that was not recognized by the licensee.
Additionally, the inspectors determined that the licensee had failed to fully consider the licensing basis impact to the important-to-safety equipment affected by changing power supplies. The licensee failed to consider the impact to technical specifications and on the current licensing basis for all of the above functions and failed to recognize that compensatory measures for many of these functions were required while panel XEC1 was aligned to its alternate non-Class-1E power source.
Corrective Action(s): The licensee subsequently reevaluated operability and identified necessary compensatory measures to maintain a reasonable assurance of operability and functionality of the impacted systems.
Corrective Action References: Document CR-2018-006180 and CR-2019-001052
Performance Assessment:
Performance Deficiency: The licensees failure to maintain a procedure recommended by Regulatory Guide 1.33, Revision 2, Appendix A and implement the requirements of 10 CFR 50.59 to adequately evaluate changes to determine if prior NRC approval is required was a performance deficiency.
Screening: The inspectors identified that multiple cornerstones were affected by this performance deficiency. Since the emergency preparedness cornerstone is not used if another cornerstone is impacted, the inspectors determined that mitigating systems was the appropriate cornerstone because the spurious actuations, failed equipment, and additional compensatory actions would most likely affect the ability of operators to mitigate an event. The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance 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 (i.e., core damage). Specifically, the procedure inadequacies resulted in a non-conforming condition affecting safety-related and important-to-safety equipment going unrecognized for 2 years without identifying the need for compensatory measures.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating System Screening Questions, and determined the finding was of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating SSCs, but the SSCs maintained their operability or functionality.
Cross-cutting Aspect: The finding was not assigned a cross-cutting aspect because the finding was not indicative of present performance.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
The inspectors assessed the severity level in accordance with the NRC Enforcement Policy, dated May 15, 2018, and determined that the violation was Severity Level IV because it was a violation of 10 CFR 50.59 that resulted in conditions evaluated as having very low safety significance (Green) by the significance determination process.
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, Section 9, recommends procedures for activities involving maintenance that can affect the performance of safety-related equipment.
Title 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), states, in part, that a licensee may make changes in the facility as described in the Updated Safety Analysis Report without obtaining a license amendment pursuant to 10 CFR 50.90 only if a change to the technical specifications incorporated in the license is not required.
Contrary to the above, from November 1997 to December 2018, the licensee failed to: 1)adequately maintain a written procedure for maintenance that can affect the performance of safety-related equipment and 2) obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in a change to the technical specifications incorporated in the license. Specifically, the licensee failed to include adequate guidance in Procedure SOP-608A to implement appropriate compensatory measures for supported equipment when aligning alternate power to XEC1 in support of maintenance and failed to recognize the change in technical specifications resulting from the cross-unit interaction created by powering XEC1 from Unit-2 non-Class-1E power.
Enforcement Action(s): This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Correct a Condition Adverse to Quality Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green H.5 - 71111.15 Systems NCV 05000445;05000446/2018004-03 Work Operability Closed Management Determinations and Functionality Assessments The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to take corrective actions for a condition adverse to quality. Specifically, a failure of a Class-1E power supply resulted in technical specification equipment being powered from non-Class-1E power and the licensee closed all corrective actions and work orders without correcting the adverse condition.
Description:
The inspectors found that the licensee had a common 120 V power panel, panel XEC1, aligned to its off-normal non-Class-1E power source. The panel is normally powered from Class-1E 480 V panel XEB3-2, but is capable of being aligned to non-Class-1E panel XB2-2 using Procedure SOP-608A, 120, 208, 208/120 and 120/240 VAC Distribution System. Panel XB2-2 is, in turn, normally powered by Unit 1 non-Class-1E bus 1B2. In August 2016, after performing maintenance with XEC1 aligned to the alternate non-Class-1E power source, the licensee was unable to restore XEC1 to its normal Class-1E source due to a failure of its transfer switch. The licensee left the panel aligned to XB2-2 and entered the failure into their corrective action program as CR-2016-007907. The inspectors noted that while the transfer switch is not quality related, panel XEC1 provides power to some loads that are quality related and required to be powered by Class-1E power. Therefore, the inspectors concluded that being unable to power these loads from Class-1E power was a condition adverse to quality.
The licensee generated a work order to troubleshoot and repair the transfer switch for XEC1, Work Order 5331282, and then closed the condition report. Work Order 5331282 was then voided to Work Order 5220567. However, Work Order 5220567 was a work order to troubleshoot the transfer switch for XEC2. As a result, no condition reports, corrective actions, or work orders remain open to correct the XEC1 transfer switch failure.
Corrective Action(s): The licensee revised Work Order 5220567 to include actions to correct the failure of the transfer switch for XEC1.
Corrective Action Reference(s): Document CR-2018-007972
Performance Assessment:
Performance Deficiency: The licensees failure to take corrective actions to correct a condition adverse to quality was a performance deficiency.
Screening: The inspectors identified that multiple cornerstones were affected by this performance deficiency. Since the emergency preparedness cornerstone is not used if another cornerstone is impacted, the inspectors determined that mitigating systems was the appropriate cornerstone because the spurious actuations, failed equipment, and additional compensatory actions would most likely affect the ability of operators to mitigate an event. The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance 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 (i.e., core damage). Specifically, the failure to correct the condition resulted in a non-conforming condition affecting safety-related and important-to-safety equipment going uncorrected for 2 years.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating System Screening Questions, and determined the finding was of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating SSCs, but the SSCs maintained their operability or functionality.
Cross-cutting Aspect: The finding was assigned a cross-cutting aspect of work management because the licensee failed to plan, control, and execute work activities such that nuclear safety was the overriding priority [H.5].
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from August 2016 until December 2018, a condition adverse to quality was not promptly corrected. Specifically, the alignment of a support system for quality related equipment to non-Class-1E power, a non-conforming condition, existed for 2 years with no planned or completed corrective actions.
Enforcement Action(s): This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Perform Evaluations of State and Local Government Interfaces Based on Licensee Performance Indicators Cornerstone Significance Cross-cutting Report Aspect Section Emergency Green None 71114.05 Preparedness NCV 05000445,05000446/2018004-04 Maintenance Closed of Emergency Preparedness The inspectors identified a Green, non-cited violation of 10 CFR 50.54(t) for failure to evaluate the adequacy of interfaces with State and local governments based on assessment against performance indicators. Specifically, the licensee failed to develop and use performance indicators assessing the quality of the interface between licensee and State and local agencies in support of a 24 month review frequency for this aspect of the emergency preparedness program.
Description:
Title 10 CFR 50.54(t) requires each reactor licensee to provide a periodic independent review of their emergency preparedness program. It requires the independent review at a default periodicity of 12 months, including adequacy reviews of the interfaces with State and local governments and licensee drills, exercises, capabilities, and procedures.
The regulation was revised on March 29, 1999, to provide licensees the option to change the frequency of independent evaluations of their emergency preparedness programs (64 FR 14814). The amendment allowed licensees to conduct reviews at intervals not to exceed 24 months, based on an assessment of the program against performance indicators and after changes that could adversely affect the emergency preparedness program.
The inspectors reviewed a sample of the licensees audit reports. It was observed that the evaluation conducted in 2017, documented in EVAL-2017-003 (dated April 18, 2017), only addressed specific corrective action documents, procedures, and training issues, which represented only a portion of the emergency preparedness program elements. Similar audits conducted in 2016 and 2018 addressed all emergency preparedness program elements.
The inspectors asked why the review scope in 2017 was different. The licensee stated that the scope was based on an audit scope evaluation performed in association with action tracking document TR-2016-010885. Specifically, the scope was based on a review of performance indicators as specified in 10 CFR 50.54(t)(1)(ii); the inspector determined the licensee used the NRC Reactor Oversight Program (ROP) emergency preparedness performance indicators.
The inspectors noted that the NRC ROP emergency preparedness performance indicators were developed after the revision to 10 CFR 50.54(t) and had been designed for a purpose other than the audit program. Consequently, the ROP emergency preparedness performance indicators do not address all of the required evaluation elements; further, they provide no means of assessing the sites performance with regards to maintaining appropriate State/local government communications and interactions. The inspector concluded that extending the audit frequency for evaluating the sites interface with State and local agencies to 24 months without basis (supported by performance indicators) could lead to issues in this area not being discovered and corrected in a timely manner.
The inspectors found that the licensee decided to implement the 24-month review option in 2000. To support this, the licensee decided to use the NRC ROP emergency preparedness performance indicators to make their scope of evaluation decisions as documented in assessment EVAL-2001-042 (October 12, 2001). There was no indication that the licensee developed any performance indicators to monitor this State/local interface program element.
The inspectors concluded that the licensee did not have a basis for extending the review to 24 months because of the lack of an appropriate performance indicator assessing the adequacy of interfaces with State and local governments. In addition, the licensee failed to provide offsite response organizations the opportunity to provide comments or concerns about the quality of the interface between licensee staff and offsite responders in odd numbered years between 2001 and 2017.
Corrective Action(s): The licensee entered these issues into the corrective action program.
Corrective Action Reference(s): CR-2018-008140
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to develop and use performance indicators assessing the quality of the interface between licensee and State and local agencies in support of a 24-month independent review frequency was a performance deficiency.
Screening: The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the offsite emergency preparedness attribute of the Emergency Preparedness Cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if communication and coordination problems between the licensee and offsite agencies are not detected and corrected.
Significance: Using Manual Chapter 0609, Significance Determination Process, 4, Tables 1, 2, and 3 worksheets (effective date October 7, 2016); and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, 2 (issue date September 22, 2015); the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk-significant planning standard function.
Cross-Cutting Aspect: As the licensee developed the audit performance indicators in 2001, no cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50.54(t)(1) requires, in part, that the licensee shall ensure that all emergency preparedness program elements are reviewed at intervals not to exceed 12 months or, as necessary, based on an assessment against performance indicators, at least once every 24 months. Title 10 CFR 50.54(t)(2) requires, in part, the review must include an evaluation for adequacy of interfaces with State and local governments.
Contrary to the above, from October 12, 2001, to April 18, 2017, the licensees periodic emergency preparedness review failed to include an evaluation for adequacy of interfaces with State and local governments at an interval not exceeding 12 months or against performance indicators at least once every 24 months. Specifically, evaluations conducted in odd numbered years did not evaluate State and local agency interface and the licensee had not developed a performance indicator designed to measure the licensees performance in that area to support extending the periodicity of this elements review to 24 months.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 19, 2018, the inspectors provided a debrief for the emergency preparedness program inspection to Mr. K. Peters, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. On December 6, 2018, the inspectors communicated the inspection results telephonically to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On December 14, 2018, the inspectors presented the baseline radiation safety inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On December 20, 2018, the inspectors presented the inservice inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On January 31, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
The inspectors verified that no proprietary information was retained or documented in this report.
DOCUMENTS REVIEWED
71111.05AQ Fire Protection Annual/Quarterly
Condition Reports
CR-2018-008405 CR-2017-009039 TR-2018-001479
Procedures
Number Title n
STA-728 Storage of Combustible and Flammable Liquids 12
STA-729 Control of Transient Combustibles, Ignition Sources and 11
Fire Watches
Miscellaneous
Documents
Number Title
Transient Combustible Permit 16673
Transient Combustible Permit 15617
Transient Combustible Permit 15481
71111.08 Inservice Inspection Activities (Unit 2)
Condition Reports (CR)
CR-2016-001706 CR-2016-010133 CR-2017-009039 CR-2017-010906 CR-2017-011526
CR-2017-011619 CR-2017-011968 CR-2017-012371 CR-2017-012392 CR-2017-012859
CR-2018-000500 CR-2018-003983 CR-2018-008319
Work Orders
5305016 5433695 5479235 5479236 5580729 5258912
Procedures
Number Title Revision
STA-729 Control Of Transient Combustibles, Ignition Sources, and 12
Fire Watches
CP-201 Comanche Peak Steam Electric Station Welding 10
Procedure Specification
CP-301 Comanche Peak Steam Electric Station Welding
Procedure Specification
CP-315 Comanche Peak Steam Electric Station Welding 6
Procedure Specification
CP-325 Comanche Peak Steam Electric Station Welding 0
Procedure Specification
TX-ISI-IWL Concrete Structure Visual Examination 6
TX-ISI-IWE Metal Containment Visual Examination 5
TX-ISI-305 Straight Beam Ultrasonic Examination of Studs and Bolts 2
in Accordance with PDI-UT-5
TX-ISI-302 Ultrasonic Examination of Austenitic Piping Welds 5
TX-ISI-301 Ultrasonic Examination of Ferritic Piping Welds 5
TX-ISI-88 Underwater Remote Visual Examination of Reactor Vessel 4
and Internals
TX-ISI-8 VT-1 and VT-3 Visual Examination Procedure 10
TX-ISI-11 Liquid Penetrant Examination for Comanche Peak Nuclear 17
Power Plant
STA-737 Boric Acid Corrosion Detection And Evaluation 8
STI-737.01 Boric Acid Corrosion Detection And Evaluation 0
71111.15 Operability Determinations and Functionality Assessments
Condition Reports
CR-2016-007907 CR-2018-006180 TR-2016-002742 CR-2015-008236
CR-2018-007972 TR-2016-008960 TR-2017-000169
Work Orders
5144575 5220567 5331282 5347463 5377428
Procedures
Number Title Revision
STI-422.01 Operability Determination and Functionality Assessment 4
Program
SOP-608A 120, 208, 208/120 and 120/240 VAC Distribution System 11
Drawings
Number Title Revision
E1-0018-01 208/120V AC One Line Diagram CP-51
E1-0018-01A 208/120V AC One Line Diagram CP-17
Miscellaneous
Documents
Number Title Date
DM 95-097 Maintenance Bypass Transformer TXEC1/2 Jan. 28, 1998
71114.02 Alert and Notification System Testing
Condition Reports
CR-2018-001905 TR-2018-008103
Procedures
Number Title Revisions
SG-012 Alert and Notification System Surveillance 24, 25
EPP-100 Maintaining Emergency Preparedness 11
Miscellaneous
Documents
Number Title Revision
Comanche Peak Nuclear Power Plant, Alert and 2
Notification System Design Report
71114.03 Emergency Response Organization Staffing and Augmentation System
Condition Reports (TR)
TR-2018-007163
Procedures
Number Title Revision
SG-005 Quarterly Augmentation Verification of the Emergency 14
Response Organization (ERO)
Miscellaneous
Documents
Number Title Date
SG-005, Attachment 1 Quarterly Augmentation Verification Results March 30, 2016
SG-005, Attachment 1 Quarterly Augmentation Verification Results July 6, 2016
SG-005, Attachment 1 Quarterly Augmentation Verification Results September 22,
2016
SG-005, Attachment 1 Quarterly Augmentation Verification Results January 10,
2017
SG-005, Attachment 1 Quarterly Augmentation Verification Results March 13, 2017
SG-005, Attachment 1 Quarterly Augmentation Verification Results June 22, 2017
SG-005, Attachment 1 Quarterly Augmentation Verification Results September 6,
2017
SG-005, Attachment 1 Quarterly Augmentation Verification Results December 14,
2017
SG-005, Attachment 1 Quarterly Augmentation Verification Results March 12, 2018
SG-005, Attachment 1 Quarterly Augmentation Verification Results September 10,
2018
71114.04 Emergency Action Level and Emergency Plan Changes
Procedures
Numbers Title Revisions
EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes 1, 2
to Emergency Plan Documentation
Miscellaneous
Documents Revision
Number Title or Date
CP-201800479 Comanche Peak Nuclear Power Plant, Docket August 9,
Nos. 50-455, 50-446 and 72-74; Transmittal of 2018
Revised Emergency Plan
2016-00283-1 Comanche Peak Nuclear Power Plant 10 CFR November 17,
50.54(q)(3) Screening Evaluation Form, Condition 2016
Report No.: CR-2016-000283; Activity No. AI-CR-
2016-000283-1
2016-00283-10 Comanche Peak Nuclear Power Plant 10 CFR November 17,
50.54(q)(3) Screening Evaluation Form, Condition 2016
Report Nos.: CR-2014-012646, CR-2016-000283;
Activity Nos. EV-2014-0012646-9 and
AI-2016-000283-10
2016-000283-1 Comanche Peak Nuclear Power Plant 10 CFR November 17,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2016
Report Nos.: CR-2015-005680, CR-2016-000283;
Activity No.: AI-CR-2015-005680-3, AI-CR-2016-
000283-1
2018-001581-10 Comanche Peak Nuclear Power Plant 10 CFR April 26, 2018
50.54(q)(3) Screening Evaluation Form, Condition
Report No.: 2018-001581; Activity No. 2018-001581-
2018-001581-11 Comanche Peak Nuclear Power Plant 10 CFR June 14, 2018
50.54(q)(3) Screening Evaluation Form, Condition
Report No.: 2018-001581; Activity No. IR-2018-
001581-11
2018-001581-10 Comanche Peak Nuclear Power Plant 10 CFR June 14, 2018
50.54(q)(3) Effectiveness Evaluation Form, Condition
Report No.: 2018-001581; Activity No. 2018-001581-
2018-001581-11 Comanche Peak Nuclear Power Plant 10 CFR June 14, 2018
50.54(q)(3) Effectiveness Evaluation Form, Condition
Report No.: 2018-001581; Activity No. 2018-001581-
2016-001187-1 Comanche Peak Nuclear Power Plant 10 CFR December 5,
50.54(q)(3) Screening Evaluation Form, Condition 2016
Report Nos.: 2016-001187; TR-2016-000283
2016-001187-1 Comanche Peak Nuclear Power Plant 10 CFR December 5,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2016
Report Nos.: 2016-001187; TR-2016-000283
2016-001102-1 Comanche Peak Nuclear Power Plant 10 CFR February 18,
50.54(q)(3) Screening Evaluation Form, Condition 2016
Report Nos.: 2016-001102; 2015-000362
2016-001102-1 Comanche Peak Nuclear Power Plant 10 CFR February 18,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2016
Report Nos.: 2016-001102; 2015-000362
2018-001581-2 Comanche Peak Nuclear Power Plant 10 CFR March 20,
50.54(q)(3) Screening Evaluation Form, Condition 2018
Report Nos.: TR-2016-004376; TR-2018-001581
2018-001581-2 Comanche Peak Nuclear Power Plant 10 CFR March 20,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2018
Report Nos.: TR-2016-004376; TR-2018-001581
2018-001581-6 Comanche Peak Nuclear Power Plant 10 CFR March 15,
50.54(q)(3) Screening Evaluation Form, Condition 2018
Report Nos.: CR-2017-009505; TR-2018-001001,
TR-2018-001581
2018-001581-6 Comanche Peak Nuclear Power Plant 10 CFR March 15,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2018
Report Nos.: CR-2017-009505; TR-2018-001001,
TR-2018-001581
2018-001581-7 Comanche Peak Nuclear Power Plant 10 CFR March 20,
50.54(q)(3) Screening Evaluation Form, Condition 2018
Report Nos.: TR-2017-002079; TR-2017-009380,
TR-2018-001581
2018-001581-7 Comanche Peak Nuclear Power Plant 10 CFR March 20,
50.54(q)(3) Effectiveness Evaluation Form, Condition 2018
Report Nos.: TR-2017-002079; TR-2017-009380,
TR-2018-001581
Comanche Peak Nuclear Power Plant Emergency 11, 27, 28, 41,
Plan, Units 1 and 2 42
Condition Reports (CR)
CR-2014-005874 CR-2015-012024 CR-2016-001187 CR-2016-002478
CR-2016-002704 CR-2016-003377 CR-2016-003467 CR-2016-006983
CR-2018-001386 CR-2018-002654 CR-2018-007026 CR-2018-008058
CR-2018-008104 TR-2016-002987 TR-2016-010466 TR-2016-010508
TR-2016-010590 TR-2016-010885 TR-2017-000900 TR-2017-002380
TR-2017-003677 TR-2017-008391 TR-2017-009345 TR-2017-009809
TR-2018-000045 TR-2018-000239 TR-2018-001919 TR-2018-005711
CR-2018-007019 CR-2018-008140
Work Orders
270670 5356319 5357278 5468669
5487099 5569255 5626062
Procedures
Numbers Title Revision
STA-421 Control of Issue Reports 21
STA-422 Corrective Action Program 34
NQA-3.02 Internal Audit and Surveillance Programs 14
EPP-204 Activation and Operation of the Technical Support Center 16
(TSC)
Miscellaneous
Documents Revision
Number Title or Dates
EVAL-2016-004 Emergency Preparedness March 29,
2016
EVAL-2017-003 Emergency Preparedness April 18, 2017
EVAL-2018-004 Emergency Preparedness April 11, 2018
NOS 2016-1 Nuclear Oversight Performance Assessment
Triannual Report 2016-1 (September 2015 -
December 2015)
NOS 2016-2 Nuclear Oversight Performance Assessment
Triannual Report 2016-2 (January 2016-May 2016)
KLD TR-589 Comanche Peak Nuclear Power Plant, 1
Development of Evacuation Time Estimates
EV-CR-2016-006983-2 Apparent Cause Evaluation (Low Tier) for August 25,
CR-2016-006983, ERO Call-out System Activation 2016
Emergency Preparedness Gold Team Exercise, October 27,
September 28, 2016, Final Report 2016
Green Team Exercise (WANO), July 26, 2016, Final September 27,
Report 2016
Emergency Preparedness, Red Team Exercise, June 2 2016
April 12, 2016, Final Report
Comanche Peak Nuclear Power Plant Emergency April 21, 2017
Response Organization, Exercise Report, Blue
Team - February 15, 2017
Comanche Peak Nuclear Power Plant Emergency October 15,
Response Organization, Exercise Report, Gold 2017
Team - August 16, 2017
Comanche Peak Nuclear Power Plant Emergency October 18,
Response Organization, Exercise Report, Gold 2017
Team - July 12, 2017
Comanche Peak Nuclear Power Plant Emergency February 7,
Response Organization, Exercise Report, Green 2017
Team - January 11, 2017
Comanche Peak Nuclear Power Plant Emergency July 27, 2017
Response Organization, Exercise Report, Red
Team - June 28, 2017
Comanche Peak Nuclear Power Plant Emergency August 28,
Response Organization, Exercise Report, Gold 2018
Team - February 18, 2018
Comanche Peak Nuclear Power Plant Emergency August 28,
Response Organization, Exercise Report, Blue 2018
Team - April 4, 2018
Comanche Peak Nuclear Power Plant Emergency August 28,
Response Organization, Exercise Report, Green 2018
Team - July 11, 2018
Comanche Peak Nuclear Power Plant After Action November 16,
Report/Improvement Plan, Drill Date - October 11, 2016
2016, Radiological Emergency Preparedness (REP)
Program
CP-201601153 To. Emergency Planning E07, RE: 2016 Annual December 15,
Review of CPNPP Evacuation Time Estimate 2016
CP-201701008 To: Emergency Planning E07, RE: 2017 Annual December 18,
Review of CPNPP Evacuation Time Estimate 2017 (says
2018)
Communications Drill Summary, March 29, 2016 July 6, 2016
Communications Drill Summary, June 28, 2016 August 10,
2016
Communications Drill Summary, September 28, December 12,
2016 2016
Communications Drill Summary, October 31, 2016 November 2,
2016
Communications Drill Summary, December 20, January 15,
2017 2018
Communications Drill Summary, August 16, 2017 October 3,
2017
Communications Drill Summary, February 15 2017 October 3,
2017
Communications Drill Summary, January 16, 2018 April 26, 2018
Communications Drill Summary, June 6, 2018 August
28,2018
Miscellaneous
Documents Revision
Number Title or Dates
Communications Drill Summary, August 23, August 28,
2018 2018
Health Physics Drill, Semi Annual, September 12,
(EP37PA1XY1), July 26, 2016 2016
Health Physics Drill, Semi Annual, December 1,
(EP37PA1XY1), September 28, 2016 2016
Health Physics Drill, Semi Annual, May 16, 2017
(EP37PA1XY1), February 15, 2017
Health Physics Drill, Semi Annual, October 3,
(EP37PA1XY1), July 12, 2017 2017
Health Physics Drill, Semi Annual, October 15,
(EP37PA1XY1), July 11, 2018, Summary/After 2018
Action
Offsite Radiological Drill Report September 12,
(EP37ORSRJ1), June 29, 2016 - July 27, 2016
2016
Offsite Radiological Drill Report
(EP37ORSRJ1), May 2017 - June 2017
Offsite Radiological Drill Report October 15,
(EP37ORSRJ1), August 20, 2018 - 2018
September 23, 2018
IS47.ECA.HCI Medical Drill - Handling a Contaminated October 31,
Injured Individual 2016; January
11, 2018
RP37.ECA.HCI Handling Contaminated Injured Personnel - June 30, 2016
Continuing
IS21.ECA.HCI Medical Drill - Handling a Contaminated January 12,
Injured Individual 2017
Comanche Peak Nuclear Power Plant Media December
Guide 2016;
November
2017
Plan of Instruction for Training of Local May 9, 2017
Officials for Fixed Nuclear Facility Accident
Response, May 9, 2017
CP-201601034 Comanche Peak Nuclear Power Plant October 27,
(CPNPP) Transmittal of the Offsite Portion of 2016
the 2016 Emergency Preparedness
Independent Review
Emergency Planning MRM - Front, July-2018 August 14,
2018
EVAL-2001-042 NOD Quarterly Report and Assessment for October 12,
the Third Quarter of 2001 2001
71124.01 Radiological Hazard Assessment and Exposure Controls
Condition Reports (CR)
CR-2017-05996 CR-2017-06658 CR-2017-09983 CR-2017-10105 CR-2017-11747
CR-2018-01895 CR-2018-04549 CR-2018-04822 CR-2018-04881 CR-2018-08373
CR-2018-08400 TR-2017-03384 TR-2017-5436 TR-2017-06678 TR-2017-08189
TR-2017-10351 TR-2017-13251 TR-2017-13314 TR-2018-02651 TR-2018-04234
TR-2018-05087 TR-2018-05692 TR-2018-05702
Procedures
Number Title Revision
RPI-212 Radioactive Source Control 13
RPI-302 Radiation and Contamination Surveys 00
RPI-304 Radiological Posting and Labeling 00
RPI-305 Access Controls for High Radiation Areas 03
RPI-418 Operation of the Tri-Nuc Underwater Filter Equipment 07
RPI-700 Sealed Source Leak Testing 13
RPI-802 Performance of Source Checks 28
RPI-895 Calibration of the NE Technology SAM - Small Articles 06
Monitor
STA-650 General Health Physics Plan 08
STA-652 Radioactive Material Control 21
STA-656 Radiation Work Control 22
STA-660 Control of High Radiation Areas 18
Audits and Self-Assessments
Number Title Date
TR-2017-007881 Self-Assessment: Radiation Protection (RP) July 24, 2017
Supplemental Worker Qualification Program
EVAL-2017-008 CPNPP Nuclear Oversight: Work Management/RP Audit July 31, 2017
TR-2017-008189 Self-Assessment: RP Fundamentals March 8, 2018
2018 CPNPP Mid-Cycle Assessment Report March 14, 2018
Radiation Work Permits
Number Title Revision
20171400 1RF19 Primary Side Steam Generator Activities 01
20171600 1RF19 Westinghouse (WEC) Refueling Activities 01
20182100 2RF17 RP Support in Containment 00
20182108 2RF17 NRC and Management Walk-Downs 01
20182205 2RF17 Scaffold Activities 01
20182300 2RF17 Steam Generator Secondary Side Activities 01
20182600 2RF17 Westinghouse (WEC) Refueling Activities 00
Radiological Surveys
Number Title Date
M-20181208-42 U-2 RB 905 Corridor 2-160A December 8, 2018
M-20181208-20 U-2 RB 808 Corridor 2-154A-D December 8, 2018
M-20181208-22 U-2 RB 860 Corridor 2-155L-N December 8, 2018
M-20181209-14 U-2 RB 832 Corridor 2-155D-G December 8, 2018
M-20181211-92 AUX 832 Piping Area X-213 December 11, 2018
M-20181212-43 AUX 790 Waste Monitor Tank Pumps December 12, 2018
Miscellaneous
Documents
Number Title Dates
NRC Form 748 2018 NSTS Confirmation of Annual Inventory January 10, 2018
Reconciliation
WO 449008 Comanche Peak Part 61 Analytical Results May 29, 2018
WO 5545076 Sealed Source Leak Testing June 14, 2018
WO 454340 Comanche Peak Part 61 Analytical Results August 14, 2018
Spent Fuel Pool Non-Fuel Stored Items October 29, 2018
WO 5615291 Sealed Source Leak Testing November 20,
2018
LHRA/VHRA Key Log December 11-13,
2018
71124.02 Occupational ALARA Planning and Controls
Condition Reports (CR)
CR-2018-05831 TR-2018-05436 TR-2018-05807 TR-2018-05436 TR-2017-05436
Procedures
Number Title Revision
CHM-170 Liquid and Gaseous Effluents Program 04
RPI-213 Survey and Release of Material 27
RPI-602 Radiological Surveillance 61
RPI-620 Crud Burst Trending & Radiological Transients 18
STA-650 General Health Physics Plan 09
STA-651 ALARA Program 12
STA-652 Radioactive Material Control 21
STA-656 Radiation Work Control 22
STA-657 ALARA Job Planning/Debriefing 20
STA-660 Control of High Radiation Areas 18
Audits and Self-Assessments
Number Title Date
TR-2017-007881 Self-Assessment: RP Supplemental Worker Qualification July 24, 2017
Program
EVAL-2017-008 CPNPP Nuclear Oversight: Work Management/Radiation July 31, 2017
Protection Audit
TR-2017-008189 Self-Assessment: RP Fundamentals March 8, 2018
2018 CPNPP Mid-Cycle Assessment Report March 8, 2018
EVAL-2018-006 CPNPP Nuclear Oversight: Work Management/RP Audit July 27, 2018
Radiation Work Permits
Number Title Revision
RWP 2018-2100 2RF17 RP Support in Containment 00
RWP 2018-2102 Locked High Radiation Area (LHRA) RP Balance of Plant 00
RWP 2018-2214 Reactor Vessel Annulus, Seal Table Activities, Eddy 00
Current Test
RWP 2018-2215 2RF17 Scaffold Activities 01
RWP 2018-2601 Maintenance Activities 00
ALARA Planning, In-Progress Reviews, and Post-Job Reviews
Number Title Revision
RWP 2018-2100 2RF17 RP Support in Containment 00
RWP 2018-2215 2RF17 Scaffold Activities 01
RWP 2018-2601 Maintenance Activities 00
Radiation Surveys
Number Title Date
M-20181209-4 Unit-2 RB 905 Pressurizer Compartment December 10.
2018
M-20181210-19 Unit-2 2-153 Under Vessel Bare Metal December 12.
2018
M-20181210-43 2-156B Deconner Seal Table Wipe Down December 10.
2018
M-20181210-51 2RF17 Post Crud Burst 2-154L Lower Loop December 10.
2018
M-20181210-51 2-155 Post Crud Burst Upper Loop December 10.
2018
Miscellaneous
Documents
Number Title Date
2018-2002 Shielding Request: Pressurizer Lines Northeast Wall December 12.
2018
Radwaste Water/Gas Management Plan December 8,
2018
Unit-2 Containment Radioactive Release RF17 Outage December 10,
2018
2RF17 Crud burst Cleanup Projection December 11,
2018
71151 Performance Indicator Verification
Condition Reports
TR-2017-011425
Procedures
Number Title Revisions
SG-012 Alert and Notification System Surveillance 24, 25
EPP-100 Maintaining Emergency Preparedness 11
EPP-201 Emergency Action Level Technical Bases Document 1
Miscellaneous
Documents Revision
Number Title or Date
LO44.BBS.011 ATWT, Simulator Exercise Guide May 3, 2017
LO44.CPE.003 CPE Scenario, Simulator Exercise Guide 1
LO47.D17.CLS Cold Look Cycle 17-4, Simulator Exercise Guide September 18,
2017
EP37.TEX.XY1 EP Exercise, February 2018 February 5,
2018
LO44.BBS.022 Faulted-Ruptured Steam Generator, Simulator Exercise April 11, 2018
Guide
LO44.BBS.027 Conservative Decision Making SOER 94-1, Simulator June 7, 2018
Exercise Guide
71152 Problem Identification and Resolution
Condition Reports
CR-2018-004648 CR-2018-007165
Procedures
Number Title Revision
STI-421.01 Control of Timed Operator Actions 1
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
requirements were approved by the Office of Management and Budget, Control Number
31500011. The NRC may not conduct or sponsor, and a person is not required to respond to, a
request for information or an information collection requirement unless the requesting document
displays a currently valid Office of Management and Budget control number.
This letter and its enclosure 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 10 CFR 2.390, Public Inspections, Exemptions, and Requests for
Withholding.
Information Request
September 17, 2018
Notification of Inspection and Request for Information
Comanche Peak Unit 2
NRC Inspection Report 05000446/2018004
INSERVICE INSPECTION DOCUMENT REQUEST
Inspection Dates: November 26 to December 7, 2018
Inspector: Jim Drake, Senior Reactor Inspector
A. Information Requested for the In-Office Preparation Week
The following information should be sent to the Region IV office in hard copy or
electronic format (ims.certrec.com preferred), in care of Jim Drake, by November 2,
2018, to facilitate the selection of specific items that will be reviewed during the onsite
inspection week. The inspector will select specific items from the information requested
below and then request from your staff additional documents needed during the onsite
inspection week Please provide requested documentation electronically if possible. If
requested documents are large and only hard copy formats are available, please inform
the inspector(s), and provide subject documentation during the first day of the onsite
inspection.
If you have any questions regarding this information request, please call the inspector as
soon as possible.
On November 26, 2018, a reactor inspector from the Nuclear Regulatory Commissions
(NRC) Region IV office will perform the baseline inservice inspection at Comanche Peak
Unit 2, using NRC Inspection Procedure 71111.08, "Inservice Inspection Activities.
Experience has shown that this inspection is a resource intensive inspection both for the
NRC inspector and your staff. The date of this inspection may change dependent on the
outage schedule you provide. In order to minimize the impact to your onsite resources
and to ensure a productive inspection, we have enclosed a request for documents
needed for this inspection. The information identified on this request (Section A) is to be
provided prior to the inspection to ensure that the inspector(s) are adequately prepared.
The section identified as Documents Upon Request is intended to provide guidance to
the type of information an inspector(s) will be requesting to complete the inspection. It is
important that all of these documents are up to date and complete in order to minimize
the number of additional documents requested during the preparation and/or the onsite
portions of the inspection (i.e., condition reports with attachments).
We have discussed the schedule for these inspection activities with your staff and
understand that our regulatory contact for this inspection will be Mr. James Barnette of
your licensing organization. The tentative inspection schedule is as follows:
Preparation week: November 13 - 16, 2018
Onsite weeks: November 26 - December 7, 2018
Our inspection dates are subject to change based on your updated schedule of outage
activities. If there are any questions about this inspection or the material requested,
please contact Jim Drake at (817) 200-1558 (email to: James.Drake@nrc.gov).
A.1 ISI/Welding Programs and Schedule Information
1. A detailed schedule (including preliminary dates) of:
1.1. Nondestructive examinations planned for ASME Code Class Components performed as
part of your ASME Section XI, risk informed (if applicable), and augmented inservice
inspection programs during the upcoming outage.
1.2. Examinations planned for Alloy 82/182/600 components that are not included in the
Section XI scope (If applicable)
1.3. Examinations planned as part of your boric acid corrosion control program (Mode 3
walkdowns, bolted connection walkdowns, etc.)
1.4. Welding activities that are scheduled to be completed during the upcoming outage
(ASME Class 1, 2, or 3 structures, systems, or components)
2. A copy of ASME Section XI Code Relief Requests and associated NRC safety
evaluations applicable to the examinations identified above.
2.1. A list of ASME Code Cases currently being used to include the system and/or
component the Code Case is being applied to.
3. A list of nondestructive examination reports which have identified recordable or
rejectable indications on any ASME Code Class components since the beginning of the
last refueling outage. This should include the previousSection XI pressure test(s)
conducted during start up and any evaluations associated with the results of the
pressure tests.
4. A list including a brief description (e.g., system, code class, weld category,
nondestructive examination performed) associated with the repair/replacement activities
of any ASME Code Class component since the beginning of the last outage and/or
planned this refueling outage.
5. If reactor vessel weld examinations required by the ASME Code are scheduled to occur
during the upcoming outage, provide a detailed description of the welds to be examined
and the extent of the planned examination. Please also provide reference numbers for
applicable procedures that will be used to conduct these examinations.
6. Copy of any 10 CFR Part 21 reports applicable to structures, systems, or components
within the scope of Section XI of the ASME Code that have been identified since the
beginning of the last refueling outage.
7. A list of any temporary non-code repairs in service (e.g., pinhole leaks).
8. A copy of (or ready access to) most current revision of the inservice inspection program
manual and plan for the current interval.
9. Copy of NDE procedures for NDE that will be used during the outage.
10. Copy of overarching site procedure for welding.
11. Provide evaluation of operating experience associated with CRDM thermal sleeve wear
issue.
A.2 Reactor Pressure Vessel Head
1. Provide a detailed scope of the planned bare metal visual examinations (e.g., volume
coverage, limitations, etc.) of the vessel upper head penetrations and/or any nonvisual
nondestructive examination of the reactor vessel head including the examination
procedures to be used.
1.1. Provide the records recording the extent of inspection for each penetration nozzle
including documents which resolved interference or masking issues that confirm that the
extent of examination meets 10 CFR 50.55a(g)(6)(ii)(D).
1.2. Provide records that demonstrate that a volumetric or surface leakage path examination
assessment was performed.
2. Copy of current calculations for EDY, and RIY as defined in Code Case N-729-1 that
establish the volumetric and visual inspection frequency for the reactor vessel head and
J-groove welds.
A.3 Boric Acid Corrosion Control Program
1. Copy of the procedures that govern the scope, equipment and implementation of the
inspections required to identify boric acid leakage and the procedures for boric acid
leakage/corrosion evaluation.
2. Please provide a list of leaks (including code class of the components) that have been
identified since the last refueling outage and associated corrective action documentation.
If during the last cycle, the unit was shutdown, please provide documentation of
containment walkdown inspections performed as part of the boric acid corrosion control
program.
A.4 Steam Generator Tube Inspections
1. A detailed schedule of:
- Steam generator tube inspection, data analyses, and repair activities for the upcoming
outage.
- Steam generator secondary side inspection activities for the upcoming outage.
2. Copy of steam generator history documentation given to vendors performing eddy
current (ET) testing of the steam generators during the upcoming outage.
3. Copy of steam generator condition monitoring and operational assessment of previous
cycle. Also include a copy of the following documents as they become available for the
current cycle:
- Degradation assessment
- Condition monitoring assessment
4. Define the planned steam generator ET scope (e.g., 100 percent of unrepaired tubes
with bobbin probe and 20 percent sample of hot leg expansion transition regions with
rotating probe) and identify the scope expansion criteria, which will be applied.
5. Identify and quantify any steam generator tube leakage experienced during the previous
operating cycle. Also provide documentation identifying which steam generator was
leaking and corrective actions completed and planned for this condition.
6. Copy of steam generator eddy current data analyst guidelines and site validated eddy
current technique specification sheets. Additionally, please provide a copy of EPRI
Appendix H, Examination Technique Specification Sheets, qualification records.
7. Copy of the guidance to be followed if a loose part or foreign material is identified in the
8. Provide past history of the condition and issues pertaining to the secondary side of the
steam generators (including items such as loose parts, fouling, top of tube sheet
condition, crud removal amounts, etc.).
Indicate where the primary, secondary, and resolution analyses are scheduled to take place.
A.5 Additional Information Related to all Inservice Inspection Activities
1. A list with a brief description of inservice inspection, and boric acid corrosion control
program related issues (e.g., CR) entered into your corrective action program since the
beginning of the last refueling outage. For example, a list based upon data base
searches using key words related to piping such as: inservice inspection, ASME Code,
Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric acid, or errors in
piping examinations.
2. Provide training (e.g., scaffolding, fall protection, foreign material exclusion, confined
space) if they are required for the activities described in A.1 through A.3.
3. Please provide names and phone numbers for the following program leads:
Inservice inspection (examination, planning)
Containment exams
Snubbers and supports
Repair and replacement program
Licensing
Site welding engineer
Boric acid corrosion control program
Steam generator inspection activities (site lead and vendor contact)
DOCUMENTS UPON REQUEST
Inservice Inspection / Welding Programs and Schedule Information
1. Updated schedules for inservice inspection/nondestructive examination activities,
including planned welding activities, and schedule showing contingency repair plans,
if available.
2. For ASME Code Class welds selected by the inspector please provide copies of the
following documentation (as applicable) for each subject weld:
- Weld data sheet (traveler).
- Weld configuration and system location.
- Applicable welding procedures used to fabricate the welds.
- Copies of procedure qualification records (PQRs).
- Welders performance qualification records (WPQ).
- Nonconformance reports for the selected welds (If applicable).
- Radiographs of the selected welds and access to equipment to allow viewing
radiographs (if radiographic testing was performed).
- Preservice and inservice examination records for the selected welds.
- Readily accessible copies of nondestructive examination personnel qualifications
records for reviewing.
3. For ultrasonic examination procedures qualified in accordance with ASME Code,
Section XI, Appendix VIII, provide documentation supporting the procedure qualification
(e.g., the EPRI performance demonstration qualification summary sheets). Also, include
qualification documentation of the specific equipment to be used (e.g., ultrasonic unit,
cables, and transducers including serial numbers) and nondestructive examination
personnel qualification records.
Boric Acid Corrosion Control Program
1. Boric acid walk down inspection results, an updated list of boric acid leaks identified so
far this outage, associated corrective action documentation, and overall status of
planned boric acid inspections.
2. List of boric acid evaluation and corrective action documents associated with the
leakage.
Steam Generator Tube Inspections
1. Examination technique specification sheets and associated justification for any revisions.
2. Copy of the eddy current testing procedures used to perform the steam generator tube
inspections (specifically calibration and flaw characterization/sizing procedures, etc.).
3. Procedures with guidance/instructions for identifying (e.g., physically locating the tubes
that require plugging) and plugging steam generator tubes.
4. List of corrective action documents generated by the vendor and/or site with respect to
steam generator inspection activities.
Codes and Standards
1. Ready access to (i.e., copies provided to the inspector(s) for use during the inspection at
the onsite inspection location, or room number and location where available):
- Applicable editions of the ASME Code (Sections V, IX, and XI) for the inservice
inspection program and the repair/replacement program.
2. Copy of the performance demonstration initiative (PDI) generic procedures with the
latest applicable revisions that support site qualified ultrasonic examinations of piping
welds and components (e.g., PDI-UT-1, PDI-UT-2, PDI-UT-3, PDI-UT-10, etc.).
3. Boric Acid Corrosion Guidebook Revision 1 - EPRI Technical Report 1000975.
The following items are requested for the
Occupational Radiation Safety Inspection
at Comanche Peak
Dates of Inspection: 12/10/2018 to 12/14/2018
Integrated Report 2018004
Inspection areas are listed in the attachments below.
Please provide the requested information on or before Monday, October 29, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at 817-200-1221 or via e-
mail at Louis.Carson@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection: April 10, 2017
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
B. Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
- C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection
date, related to this inspection area
D. Procedure indexes for the radiation protection procedures and other related disciplines.
E. Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
9. Fuel Pool Inventory Access and Control
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G. Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) since the last inspection date.
1. Initiated by the radiation protection organization
2. Assigned to the radiation protection organization
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
H. List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.) Please include the radiological risk assigned to each
activity.
I. Provide a summary of any changes to plant operation that have resulted or could result
in a significant new radiological hazard. For each change, please provide the
assessment conducted on the potential impact and any monitoring done to evaluate it.
J. List of active radiation work permits and those specifically planned for the on-site
inspection week.
K. Please provide a list of air samples taken to verify engineering controls and a separate
list for breathing air samples in airborne radiation areas or high contamination work
areas. Please include the RWP the breathing air sampling supports.
- L. Please provide the current radioactive source inventory, listing all radioactive sources
that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,
Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and
current activity (w/assay date), and storage location for each applicable source.
M. The last two leak test results for all required/applicable radioactive sources that have
failed its leak test within the last two years. Provide any applicable condition reports.
- N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate
dose rates (Contact / @ 30cm)
inspection date. The list should include the date of entry, some form of worker
identification, the radiation work permit used by the worker, dose accrued by the worker,
and the electronic dosimeter dose alarm set-point used during the entry (for
Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).
P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.
Include their current status, locations, and control measures.
Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally
closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay
doors). Include any CRs associated with this monitoring or instrumentation.
2. Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection: December 4, 2017
Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell
numbers are appropriate, then please include them as well.
B. Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
- C. Copies of audits, self-assessments, LARs, and LERs, written since the date of last
inspection, focusing on ALARA
D. Procedure index for ALARA Program procedures and other related disciplines.
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
2. ALARA Planning
3. ALARA Reviews
4. ALARA Committee
5. Radiation Work Permit Preparation
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G. Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of last inspection, related to the ALARA
program, including exceeding RWP Dose Estimates.
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspectors can ascertain the regulatory impact, the significance
level assigned to the condition, the status of the action (e.g., open, working,
closed, etc.) and the search criteria used. Please provide in document formats
which are sortable and searchable so that inspectors can quickly and
efficiently determine appropriate sampling and perform word searches, as
needed. (Excel spreadsheets are the preferred format.) If codes are used,
please provide a legend for each column where a code is used.
- H. List of work activities (RWPs) greater than 1 rem, since date of last inspection,
including the original dose estimates and actual doses accrued. (Excel format
preferred). Please provide all revisions/changes, as well as any related RWPs that
support the work activity.
dose and dose rate settings, and if available, the planned dose. Include planning
documents and surveys. Include radiological risk assessments and proposed control
measures.
J. Site dose totals for the past 3 years (based on dose of record). Also provide the current
year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide
another document that separates the online and outage doses for the past 3 years.
- K. Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides
and alpha hazards. Include a list of new and historical exposure issues (radiological
source term or high exposure areas/activities).
- L. If available, provide a copy of the lessons learned from the most recently completed
outage for each unit. Include a summary list of any associated corrective action
documents and the current status of any corrective actions assigned.
M. Please provide the methods/reports that are in your process to meet the requirements of
CFR 20.1101(c) for periodic review of your RP program.
N. Current exposure trends (BRAC dose rates and/or source term information).
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JJosey Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:DRP/A RI:DRP/A SPE:DRP/A BC:EB1 BC:EB2 BC:OB
NAME JJosey RKumana RAlexander VGaddy JDrake GWerner
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 01/31/19 01/18/19 01/29/19 01/22/19 01/18/19 01/20/19
OFFICE BC:PSB2 TL-IPAT BC:DRP/A
NAME HGepford RKellar MHaire
SIGNATURE /RA/ /RA/ via E /RA/
DATE 01/31/19 01/23/19 2/11/19