IR 05000445/2019003
| 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
November 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:
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
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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness Sample (IP Section 03.01) (1 Sample)
- (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) (4 Samples)
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 Sample)
- (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 Sample)
- (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) (5 Samples)
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.) (1 Sample)
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) (1 Sample)
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 Sample)
- (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) (2 Samples)
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) (6 Samples)
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) (5 Samples)
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) (2 Samples)
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) (5 Samples)
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 Sample)
- (1) Observed blue team drill on July 17,
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 02.01) (1 Sample)
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:
71124.04 - Occupational Dose Assessment
Source Term Categorization (IP Section 02.01) (1 Sample)
- (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) (1 Sample)
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
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.05Q Procedures
FPI-102A
Unit 1 Safeguards Building Elevation 790'-0"
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"
Work Orders
5550736, 5528056
Corrective Action
Documents
IR-YYYY-NNNN
2019-6523, 2019-7088
Procedures
OPT-216B
Remote Shutdown Operability Test
Procedures
STI-600.01
Protecting Plant Equipment and Sensitive Equipment
Controls
Work Orders
5571958, 5731460, 5503928, 5795539, 5796560,
5806473
Corrective Action
Documents
CR-YYYY-NNNN
2019-006338, 2019-6337, 2019-005953
Corrective Action
Documents
IR-YYYY-NNNN
2019-005660
Corrective Action
Documents
TR-YYYY-NNNN
2019-005968
Procedures
OPT-201B
Charging System
Work Orders
5780021
09/24/2019
Procedures
OPT-214B
Diesel Generator Operability Test
Work Orders
5710954
Procedures
EPP-204
Activation and Operation of the Technical Support Center
Corrective Action
Documents
CR/TR-YYYY-
NNNN
CR-2018-008482, CR-2019-000208, TR-2018-008354,
TR-2019-001117, TR-2019-001654, TR-2019-001896,
TR-2019-002489
Miscellaneous
CPNPP Five Year Dose Reduction Plan 2018-2023
06/2018
Miscellaneous
2017 Comanche Peak Annual ALARA Report
01/2018
Miscellaneous
2018 Comanche Peak Annual ALARA Report
01/2019
Miscellaneous
1RF19 CPNPP Radiation Protection Outage ALARA Report
01/16/2018
Procedures
RPI-606
Radiation Work and General Access Permits
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
STA-650
General Health Physics Plan
Procedures
STA-651
ALARA Program
Procedures
STA-657
ALARA Job Planning/Debriefing
Radiation
Surveys
M-20181211-31
U-2 SG 810' Pipe Pen Area Train B 2-077A
2/11/2018
Radiation
Surveys
M-20190503-19
Spent Fuel Bridge Shiftly
05/03/2019
Radiation
Surveys
M-20190713-5
U-1 SG 832' Corridor
07/13/2019
Radiation
Surveys
M-20190720-6
U-1 SG 790' Corridor
07/20/2019
Radiation Work
Permits (RWPs)
RWP 2017-1400
All Activities Associated with Primary Side Steam Generator
Radiation Work
Permits (RWPs)
RWP 2017-1405
1RF19 RCP Motor 1-04 Swap
Radiation Work
Permits (RWPs)
RWP 2017-1600
1RF19 Westinghouse (WEC) Refueling Activities
Radiation Work
Permits (RWPs)
RWP 2018-2215
2RF17 Scaffold Activities
Radiation Work
Permits (RWPs)
RWP 2018-2400
2RF17 Refueling Activities
Radiation Work
Permits (RWPs)
RWP 2018-2600
2RF17 Westinghouse Primary Side Steam Generator
Activities
Self-Assessments EVAL-2018-0006
Work Management / Radiation Protection Audit
07/26/2018
Corrective Action
Documents
CR/TR-YYYY-
NNNN
CR-2018-002458, CR-2018-004881, CR-2018-006763,
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
Miscellaneous
Report: Site ED vs. TLD Results
2018
Miscellaneous
Shepherd Irradiation Exposure Method
09/21/2011
Miscellaneous
UFO 5 Individual Gamma and Neutron Exposure
2018
Miscellaneous
2018-002196
Calculate Average Beta and Gamma Energy
2018
Miscellaneous
RPI-516-9
Dose Evaluation Forms
2017-2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
RPI-105
Exposure Records
Procedures
RPI-500
Bioassay Program
Procedures
RPI-506
Calculation and Tracking of Personnel Exposures to
Airborne Radioactive Material
Procedures
RPI-515
Neutron Dose Measurement and Recording
Procedures
RPI-516
Dose Determination
Procedures
RPI-528
Multiple Dosimetry Badging
Procedures
STA-655
Exposure Monitoring Program
Self-Assessments TR-2018-001894
Strategic Self-Assessment of Radiation Protection
Fundamentals
2018