IR 05000445/2019003

Integrated Inspection Report 05000445/2019003 and 05000446/2019003

ML19310D826
Person / Time
Site:	Comanche Peak
Issue date:	11/05/2019
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Peters K Vistra Operations Company
References
IR 2019003
Download: ML19310D826 (14)

Text

ber 5, 2019

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2019003 AND 05000446/2019003

Dear Mr. Peters:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 3, 2019, the NRC inspectors discussed the results of this inspection with Mr. T. McCool, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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/

Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000445 and 05000446 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2019003 and 05000446/2019003 Enterprise Identifier: I-2019-003-0011 Licensee: VISTRA Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, TX 76043 Inspection Dates: July 1, 2019 to September 30, 2019 Inspectors: M. Chambers, Senior Resident Inspector N. Day, Resident Inspector N. Greene, Senior Health Physicist B. Tharakan, Senior Project Engineer A. Athar, Acting Resident Inspector Approved By: Neil F. O'Keefe, Chief Reactor Projects Branch B 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.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

Units 1 and 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternating current (AC)power systems on July 9, 2019.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 turbine driven auxiliary feedwater pump and motor driven auxiliary feedwater pump on July 11, 2019

(2) Unit 1 containment spray pump A on July 20, 2019

(3) Unit 2 emergency diesel generator A and air start systems on August 7, 2019

(4) Unit 2 emergency diesel generator B on September 20, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 emergency diesel generator A on September 27, 2019.

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance during an announced fire drill in fuel handling building elevation 810 on September 5, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Zone EN64, Unit 1, cable spreading room on July 10, 2019

(2) Fire Zone EM63, Unit 2, cable spreading room on July 10, 2019

(3) Fire Zone 1SB4, Unit 1, containment spray chemical addition tank room on July 19, 2019

(4) Fire Zone 73, Units 1 and 2 control room air conditioning units room on July 24, 2019

(5) Fire Zone 161, Unit 2 equipment ventilation room on July 25, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1 emergency diesel generator B room on August 22, 2019.

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) Component cooling water heat exchanger thermal performance tests performed by Work Orders 5550736 and 5528056 on September 11, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated operator performance during plant conditions which required licensed operator credited actions for the auxiliary feedwater system on August 14, 2019.

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

(1) The inspectors observed and evaluated licensed operator performance in the simulator during scenario L044BBS005, plant response during a manual reactor trip due to elevated reactor coolant pump temperatures on September 5, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Maintenance Rule Program periodic evaluation per 50.65(a)(3) on August 15, 2019

(2) Ventilation chill water system on September 10, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Yellow risk due to Unit 2, train A 6.9 kV electrical system remote shutdown operability test on July 9, 2019

(2) Reliance on a dedicated operator action to maintain system availability during Unit 1, turbine driven auxiliary feedwater pump governor valve test on July 11, 2019

(3) Reliance on a dedicated operator action to maintain system availability during Unit 1 emergency diesel generator B on July 17, 2019

(4) Yellow risk due to Unit 2 emergency diesel generator A output breaker maintenance on September 4, 2019

(5) Emergent work on both Unit 1 instrument air compressors on September 10, 2019

(6) Yellow risk due to spent fuel pump X-01 mechanical seal replacement on September 25, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 reactor coolant pump 3 high vibrations described in TR-2019-005968 on July 19, 2019

(2) Unit 2 reactor pressurizer level control while centrifugal charging pump B was in service as described in IR-2019-005660 on August 1, 2019

(3) Unit 1 centrifugal charging pump motor B outboard bearing high temperatures described in CR-2019-006338 on August 1, 2019

(4) Common Unit - centrifugal charging pump lube oil filter acceptance limits described in CR-2019-006337 on August 8, 2019

(5) Unit 1 emergency diesel generator B pressure switch failure described in CR-2019-005953 on August 21, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Design change, DM 93-075, to implement a pressure bypass system on the control room air conditioning system on July 31, 2019

(2) Temporary modification T-Mod FDA-2016-000100-01-00, to implement a vibration setpoint change on the Unit 1 reactor coolant pump 3 on August 13, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Post work test for Unit 1, MSE-SE-0673A, Sequencer Under Voltage Relay, per Work Order 5572504 on July 10, 2019

(2) Post work test for Unit 2, indicator-7329B steam generator 3 narrow range, per Cal 2-2-0539 on August 5, 2019

(3) Post work test for 1-HV-4631B-A0, primary sample cooler component cooling water valve, per OPT-208A, "CCW System," on August 26, 2019

(4) Post work test for Unit 2 containment spray pump 3 following breaker maintenance per Work Order 5485145 on September 3, 2019

(5) Post work test for Unit 2 centrifugal charging pump A following motor, relief valve, and pump maintenance, per Work Order 5780021 on September 24, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) Unit 2, emergency diesel generator A monthly operability test per OPT-214B, "Diesel Generator Operability Test," on July 10, 2019

(2) Unit 2, turbine driven auxiliary feedwater pump quarterly operability test per OPT-206B, "AFW System," on August 29, 2019

(3) Unit 1, residual heat removal pump A quarterly operability test per Work Order 5781735 on September 24, 2019

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Quarterly remote shutdown panel auxiliary feedwater system valve test on September 20, 3019.

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Reactor coolant system boration FLEX pump X-01, FLEX 12 kW diesel generator, and reactor vessel level uninterruptable power supply on September 17, 2019.

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) Observed blue team drill on July 17,

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

The inspectors evaluated the licensees radiological work planning.

(1) The inspectors reviewed the following activities:

• RWP 2017-1400, "All Activities Associated with Primary Side Steam Generator," Revision 1

• RWP 2017-1405, "1RF19 reactor coolant pump (RCP) Motor 1-04 Swap,"

Revision 1

• RWP 2017-1600, "1RF19 Westinghouse (WEC) Refueling Activities,"

Revision 1

• RWP 2018-2215, "2RF17 Scaffold Activities," Revision 1

• RWP 2018-2400, "2RF17 Refueling Activities," Revision 1

• RWP 2018-2600, "2RF17 Westinghouse Primary Side Steam Generator Activities," Revision 1 Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

(1) The inspectors reviewed the following as low as reasonably achievable planning documents:

• 2017 Comanche Peak Annual ALARA Report, January 2018

• 2018 Comanche Peak Annual ALARA Report, January 2019 Additionally, the inspectors reviewed the following radiological outcome evaluations:

• 1RF19 CPNPP Radiation Protection Outage ALARA Report, January 16, 2018

71124.04 - Occupational Dose Assessment Source Term Categorization (IP Section 02.01)

(1) The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity.

External Dosimetry (IP Section 02.02) (1 Sample)

(1) The inspectors evaluated the external dosimetry program implementation.

Internal Dosimetry (IP Section 02.03) (1 Sample)

The inspectors evaluated the internal dosimetry program implementation.

(1) The inspectors reviewed the following:

Whole Body Counts

• The inspector reviewed whole body count assessments for eight individuals.

In-Vitro Internal Monitoring

• No exposures resulted in in-vitro internal monitoring. Thus, none were available during this inspection.

Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring

• None were available during this inspection

Special Dosimetric Situations (IP Section 02.04) (1 Sample)

The inspectors evaluated the following special dosimetric situation:

(1) Licensees implementation of requirements to manage radiation protection of three declared pregnant workers, application of NRC-approved external dosimetry methods (i.e., EDEX), shallow dose equivalent, and neutron dose assessments.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 1 from July 1, 2018, through June 30, 2019

(2) Unit 2 from July 1, 2018, through June 30, 2019 MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 from July 1, 2018, through June 30, 2019

(2) Unit 2 from July 1, 2018, through June 30, 2019

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 from July 1, 2018, through June 30, 2019

(2) Unit 2 from July 1, 2018, through June 30, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:

(1) Safeguard information container not properly secured as described in SFR# 0465-18, and IR# 2018-007207.

During inspection review of security event logs, this issue was identified and provided to the resident inspection team. The team gathered information surrounding the incident, interviewed security personnel, reviewed security procedures, and consulted with Regional security inspectors. The team determined that the licensee self-identified the issue through the Safeguard Patrol Program, entered the issue into the corrective action program, and evaluated and corrected the issue in accordance with station security and corrective action procedures.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On October 3, 2019, the inspectors presented the integrated inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

• On August 8, 2019, the inspectors presented the radiation safety inspection results inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05Q Procedures FPI-102A Unit 1 Safeguards Building Elevation 790'-0" 3

71111.05Q Procedures FPI-504 Electrical & Control Building Elevation 807'-0" Unit 2 Cable

Spread Room

71111.05Q Procedures FPI-505 Electrical & Control Building Unit 1 Cable Spread Room

Elevation 87'-0"

71111.07A Work Orders 5550736, 5528056

71111.13 Corrective Action IR-YYYY-NNNN 2019-6523, 2019-7088

Documents

71111.13 Procedures OPT-216B Remote Shutdown Operability Test 12

71111.13 Procedures STI-600.01 Protecting Plant Equipment and Sensitive Equipment 1

Controls

71111.13 Work Orders 5571958, 5731460, 5503928, 5795539, 5796560,

5806473

71111.15 Corrective Action CR-YYYY-NNNN 2019-006338, 2019-6337, 2019-005953

Documents

71111.15 Corrective Action IR-YYYY-NNNN 2019-005660

Documents

71111.15 Corrective Action TR-YYYY-NNNN 2019-005968

Documents

71111.19 Procedures OPT-201B Charging System 8

71111.19 Work Orders 5780021 09/24/2019

71111.22 Procedures OPT-214B Diesel Generator Operability Test 16

71111.22 Work Orders 5710954

71114.06 Procedures EPP-204 Activation and Operation of the Technical Support Center 16

71124.02 Corrective Action CR/TR-YYYY- CR-2018-008482, CR-2019-000208, TR-2018-008354,

Documents NNNN TR-2019-001117, TR-2019-001654, TR-2019-001896,

TR-2019-002489

71124.02 Miscellaneous CPNPP Five Year Dose Reduction Plan 2018-2023 06/2018

71124.02 Miscellaneous 2017 Comanche Peak Annual ALARA Report 01/2018

71124.02 Miscellaneous 2018 Comanche Peak Annual ALARA Report 01/2019

71124.02 Miscellaneous 1RF19 CPNPP Radiation Protection Outage ALARA Report 01/16/2018

71124.02 Procedures RPI-606 Radiation Work and General Access Permits 38

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.02 Procedures STA-650 General Health Physics Plan 8

71124.02 Procedures STA-651 ALARA Program 12

71124.02 Procedures STA-657 ALARA Job Planning/Debriefing 20

71124.02 Radiation M-20181211-31 U-2 SG 810' Pipe Pen Area Train B 2-077A 12/11/2018

Surveys

71124.02 Radiation M-20190503-19 Spent Fuel Bridge Shiftly 05/03/2019

Surveys

71124.02 Radiation M-20190713-5 U-1 SG 832' Corridor 07/13/2019

Surveys

71124.02 Radiation M-20190720-6 U-1 SG 790' Corridor 07/20/2019

Surveys

71124.02 Radiation Work RWP 2017-1400 All Activities Associated with Primary Side Steam Generator 1

Permits (RWPs)

71124.02 Radiation Work RWP 2017-1405 1RF19 RCP Motor 1-04 Swap 1

Permits (RWPs)

71124.02 Radiation Work RWP 2017-1600 1RF19 Westinghouse (WEC) Refueling Activities 1

Permits (RWPs)

71124.02 Radiation Work RWP 2018-2215 2RF17 Scaffold Activities 1

Permits (RWPs)

71124.02 Radiation Work RWP 2018-2400 2RF17 Refueling Activities 1

Permits (RWPs)

71124.02 Radiation Work RWP 2018-2600 2RF17 Westinghouse Primary Side Steam Generator 1

Permits (RWPs) Activities

71124.02 Self-Assessments EVAL-2018-0006 Work Management / Radiation Protection Audit 07/26/2018

71124.04 Corrective Action CR/TR-YYYY- CR-2018-002458, CR-2018-004881, CR-2018-006763,

Documents NNNN CR-2018-008373, CR-2018-008376, TR-2017-007389,

TR-2017-013292, TR-2018-000948, TR-2018-002735,

TR-2018-005685, TR-2019-001174, TR-2019-002331,

TR-2019-004527

71124.04 Miscellaneous Report: Site ED vs. TLD Results 2018

71124.04 Miscellaneous Shepherd Irradiation Exposure Method 09/21/2011

71124.04 Miscellaneous UFO 5 Individual Gamma and Neutron Exposure 2018

71124.04 Miscellaneous 2018-002196 Calculate Average Beta and Gamma Energy 2018

71124.04 Miscellaneous RPI-516-9 Dose Evaluation Forms 2017-2019

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.04 Procedures RPI-105 Exposure Records

71124.04 Procedures RPI-500 Bioassay Program 16

71124.04 Procedures RPI-506 Calculation and Tracking of Personnel Exposures to 11

Airborne Radioactive Material

71124.04 Procedures RPI-515 Neutron Dose Measurement and Recording 19

71124.04 Procedures RPI-516 Dose Determination 34

71124.04 Procedures RPI-528 Multiple Dosimetry Badging 14

71124.04 Procedures STA-655 Exposure Monitoring Program 22

71124.04 Self-Assessments TR-2018-001894 Strategic Self-Assessment of Radiation Protection 2018

Fundamentals

2