IR 05000445/2020002
| ML20217L240 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/04/2020 |
| From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2020002 | |
| Preceding documents: |
|
| Download: ML20217L240 (13) | |
Text
August 4, 2020
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000445/2020002 AND 05000446/2020002
Dear Mr. Peters:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On July 9, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/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: 05000445/2020002 and 05000446/2020002 Enterprise Identifier: I-2020-002-0010 Licensee: VISTRA Operating Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, TX 76043 Inspection Dates: April 1, 2020 to June 30, 2020 Inspectors: I. Anchondo-Lopez, Reactor Inspector N. Day, Resident Inspector J. Ellegood, Senior 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
Type Issue Number Title Report Section Status LER 05000446/2020-001-00 LER 2020-001-00 for 71153 Closed Comanche Peak, Manual Reactor Trip Due to Trip of Both Main Feedwater Pumps
PLANT STATUS
Unit 1 began the inspection period at rated thermal power and remained at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On April 19, 2020, Unit 2 was shut down for a planned refueling outage. On May 12, the licensee restarted the unit and entered Mode 1. The licensee then ascended in power reaching near rated thermal power on rated thermal power on May 16. Unit 2 remained at or near rated thermal power 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/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal summer operations for the following systems:
138 KV offsite power and switch yard components 345 KV offsite power and switch yard component
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, auxiliary feedwater system following valve maintenance on April 8, 2020
- (2) Unit 1, Class 1E electrical distribution on May 21, 2020
- (3) Unit 1, Containment spray chemical addition tank on June 12, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, main turbine, Fire Area TB, due to oil leak on May 22, 2020
- (2) Circulating water pumps and auxiliaries, Fire Area CWI, on May 22, 2020
- (3) Unit 1, component cooling water pump rooms, Fire Area AF, on June 23, 2020
- (4) Unit 2, component cooling water pump rooms, Fire Area AE, on June 23, 2020
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2, CCW heat exchanger 2-01
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from May 19, 2020, to May 29, 2020:
03.01.a - Nondestructive Examination and Welding Activities.
The inspectors reviewed records of the following Nondestructive activities:
1. Ultrasonic Examination a. Weld TCX-1-4200-8, Report Number UT-2018-043, Elbow-to-Pipe in Reactor Coolant System b. Weld TCX-1-4201-4, Report Number UT-2018-054, Pipe-to-Elbow in Reactor Coolant System c. Weld TCX-1-4201-5, Report Number UT-2018-055, Elbow-to-Pipe in Reactor Coolant System d. Weld TCX-1-4201-6, Report Number UT-2018-056, Pipe-to-Elbow in Reactor Coolant System e. Weld TCX-1-4203-11, Report Number UT-2018-038, Pipe-to-Elbow in Reactor Coolant System 2. Visual Examination a. Rector Pressure Vessel Nozzle Cold Leg Loop 1 b. Rector Pressure Vessel Nozzle Cold Leg Loop 2 c. Rector Pressure Vessel Nozzle Cold Leg Loop 3 d. Rector Pressure Vessel Nozzle Cold Leg Loop 4 e. Rector Pressure Vessel Nozzle Hot Leg Loop 1 f. Rector Pressure Vessel Nozzle Hot Leg Loop 2 g. Rector Pressure Vessel Nozzle Hot Leg Loop 3 h. Rector Pressure Vessel Nozzle Hot Leg Loop 4 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities Comanche Peak received verbal authorization on April 9, 2020 (ML20106F235) to implement an alternative to the inspection of the control rod drive mechanism (CRDM) nozzle penetrations and delay the required inspection for 18 months due to the hardship caused by potential spread of the Coronavirus Disease 2019 (COVID-19) virus. The licensee performed a boric acid examination of the head by observing the flange area and inspecting underneath the CRDM cooling shroud support ring gap, looking for signs of boric acid leakage. The inspectors reviewed the results of this inspection under work order 5713483.
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
The inspector reviewed eight boric acid corrosion evaluations and associated corrective actions contained in condition report 2020-02733.
03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
On April 17, 2020, the NRC approved an amendment that allowed the licensee to defer the Comanche Peak Unit 2 steam generator inspections from the spring 2020 refueling outage (RFO) to the fall 2021 RFO (ADAMS Accession No. ML20108E878).
The licensee requested the amendment in response to social distancing recommendations provided by the United States Center for Disease Control, which have been issued as a defensive measure against the spread of the COVID-19 virus.
Problem Identification and Resolution of Problems:
The inspector reviewed 19 notifications that dealt with inservice inspections issues and found that items were entered into the corrective action program at the appropriate level and addressed appropriately.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during synchronization of the main generator to the grid on May 12, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated Just in Time operator training for reactor shutdown via video recorded on April 14 and 15, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2, safety chilled water system
- (2) Units 1 and 2, instrument air system
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2, the inspectors reviewed the outage risk assessment for refueling outage 2RFO18
- (2) Unit 2, elevated risk during a planned refueling outage during the week of April 20, 2020
- (3) Unit 1, risk associated with steam leak repair and main feedwater cooler realignment on May 28 and June 1, 2020
- (4) Unit 1, risk associated with Unit 1 nuclear steam supply system cabinet 5 power supply replacement on June 11, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2, centrifugal charging pump B motor breaker, due to the failure to close during a degraded voltage test as described in Condition Report CR-2020-00822 on April 2, 2020
- (2) Unit 2, NI-0032B source range neutron flux monitor channel 2 for instrumentation spiking as described in Condition Report CR-2020-03105 on April 28, 2020
- (3) Unit 2, containment sump filters due to irretrievable debris as described in Condition Report CR-2020-003599 on May 11, 2020
- (4) Unit 2, safety injection accumulator due to water in-leakage as described in Condition Report CR-2020-003692 on May 27, 2020
- (5) Unit 2, motor-driven auxiliary feedwater pump A room cooler due to high fan vibrations as described in Condition Report CR-2020-004550 on June 16, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) The inspectors reviewed FDA-2020-000020-01-01, a temporary modification to gag Unit 1 heater drain pump discharge valve in place.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Unit 2, containment refueling machine position limit switch repairs, per Work Order 5441053 on April 27, 2020
- (2) Unit, 2 lower core plate and upper internals inspections prior to reassembly on April 30, 2020
- (3) Unit 2, emergency diesel generator 2B following a maintenance window on May 5, 2020
- (4) Unit 2, low power physics testing to confirm core design on May 11, 2020
- (5) Unit 1, feedwater heater 3A steam leak repair per Work Order 5744907 on June 1, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 2RFO 18 activities from April 19 to May 12, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1, turbine driven auxiliary feedwater system discharge valve position limit switch test per Work Order 5630193 on April 16, 2020
- (2) Unit 2, OPT-408B, refueling containment penetration verification on April 24, 2020
- (3) Unit 2, MSM-C2-9901 reactor vessel head removal and installation and Work Order 5441053, containment polar crane maintenance on April 24, 2020
- (4) Unit 2, OPT-435B-1, train B safety injection with loss of offsite power on April 26, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, motor-driven auxiliary feedwater pump B inservice test per Work Order 5872174 on May 28, 2020.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Green team drill on June 24,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1, April 1, 2019, through March 31, 2020
- (2) Unit 2, April 1, 2019, through March 31, 2020 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1, April 1, 2019, through March 31, 2020
- (2) Unit 2, April 1, 2019, through March 31, 2020
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1, April 1, 2019, through March 31, 2020
- (2) Unit 2, April 1, 2019, through March-31, 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in engineering and maintenance that might be indicative of a more significant safety issue. The inspectors noted several licensee indicators revealed backlogs in maintenance-related activities. For example, the licensee has a large number of control room deficiencies and many preventive maintenance actions in the second half of the allowed grace period. The inspectors believe a better understanding of the underlying factors may be necessary to achieve sustainable improvement in maintenance-related backlogs.
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) The planned and completed correction actions for the Unit 2 emergency diesel generator A automatic voltage regulator fiber optic cable connection failure described in CR-2020-000542.
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) Licensee Event Report 05000446/2020-001-00, Manual Reactor Trip Due to Trip of Both Main Feedwater Pumps, on January 1, 2020 (ADAMS Accession No.
ML20070H633). The circumstances surrounding this LER are documented in Comanche Peak Nuclear Power Plant, Units 1 and 2, Integrated Inspection Report 05000445/2020001 and 05000446/2020001, Section 71153, Inspection Results.
That report also documented NCV 05000446/2020001-01 that addressed the performance deficiency that caused the plant trip.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 2, 2020, the inspectors presented the Inservice Inspection results to Mr. Steven Sewell, Senior Director, Engineering and Regulatory Affairs and other members of the licensee staff.
- On July 9, 2020, the inspectors presented the integrated inspection results to Mr. Ken Peters, Senior Vice-President and Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures OPT-215 Class 1E Electrical Systems Operability 15
SOP-204A-CT- Chem Add Tank Valve Lineup 1
V03
71111.05 Fire Plans FPI-403 Auxiliary Building 810'-6" 5
FPI-801 Circulating Water Intake Structure 795-0 3
FPI-303A Unit 1 and 2 Turbine Building 830-0 7
71111.07A Calculations 16345-ME-259 Verification of CCW HX Tube Plugging Analysis 11/11/1987
2-ME-0265 Component Cooling Water Heat Exchanger Tube Plugging 0
Analysis
CP2-CAHX-01- Following Factor Calculation for CP2=CCAHHX-01 01/08/2020
01-08-2020
ME-CA-0229- Component Cooling Water Heater Exchanger Fouling Factor 8
2188 Analysis
Miscellaneous CP2-2RF18- Eddy Current Inspection Results for CP2-CCAHHX-01 05/04/2020
5703970
71111.08P Corrective Action CR-YYYY-NNNN 2018-08536, 2019-03722, 2019-07170, 2019-04101,
Documents 2019-07476, 2020-07982, 2020-02270, 2018-08440,
2019-00542, 2020-02735, 2020-02913, 2019-06855,
2019-06858, 2019-07695, 2019-09530, 2020-01272,
20-02733,
TR-2018-09202, TR-2019-06693, TR-2018-07810,
TR-2019-06596
Procedures EPG-725 Pressure Testing 5
NDE 4.02 ASME Section XI Visual Examination VT-2 11
STI-737.01 Boric Acid Corrosion Detection and Evaluation 1
TX-ISI-214 7
TX-ISI-302 Ultrasonic Examination of Austenitic Piping Welds 5
TX-OPS-101 Preservice and Inservice Examination Documentation for 14
Work Orders 5414198, 5713347, 5713483, 5713525, 5590643, 5599508,
5617373, 5649392
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.12 Corrective Action CR-YYYY-NNNN 2020-4252, 2018-6900, 2019-5986, 2020-5256
Documents
71111.13 Procedures ABN-302 Feedwater, Condensate, Heater Drain System Malfunction 14
SOP-302A Feedwater System 19
71111.15 Miscellaneous Operations Department Troubleshooting Plan for SI 05/25/2020
Accumulator 2-01 (CR-2020-003692
Work Orders 5908190
5908190 CR-2020-003692 Troubleshoot In-Leakage 05/27/2020
71111.19 Miscellaneous Video of Upper internals and vessel internals taken April 30,
20
2RF18 FOSAR Package 04/30/2020
Unit 2 Cycle 19 Reactivity Computer Generated Form 05/11/2020
Procedures NUC-301 Low Power Physics Testing 24
RFO-401, RFO-
2, RFO-501,
RFO-502, RFO-
2
Work Orders 5744907
71111.20 Calculations RXE-TA-CPX/0- Cycle-Independent RCS Time to Boil Analysis 03/16/2016
101
Procedures OPT-408B Refueling Containment Penetration Verification 6
71111.22 Work Orders 6872174 05/28/2020
71151 Miscellaneous Unit 2 Dose equivalent iodine activity spreadsheet, April 1
2019 to March 31 2020
Unit 1 Dose equivalent iodine activity spreadsheet, April 1
2019 to March 31 2020
Unit 2 RCS leakage spreadsheet, April 1 2019 to March 31
20
Unit 1 RCS leakage spreadsheet, April 1 2019 to March 31
20
71152 Corrective Action TR-2019-004978 Work Order Backlogs Have Continued to Increase 06/07/2019
Documents TR-2020-000901 Potential Trend Identified with the Modification Process 05/05/2020
11