IR 05000445/2020003

Integrated Inspection Report 05000445/2020003 and 05000446/2020003

ML20315A321
Person / Time
Site:	Comanche Peak
Issue date:	11/10/2020
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Peters K Vistra Operations Company
References
IR 2020003
Download: ML20315A321 (10)

Text

November 10, 2020

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000445/2020003 AND 05000446/2020003

Dear Mr. Peters:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant. On October 1, 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, Cornelius F. Digitally signed by Cornelius F. O'Keefe O'Keefe Date: 2020.11.10 14:28:58-06'00'

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: 05000445/2020003 and 05000446/2020003 Enterprise Identifier: I-2020-003-0010 Licensee: VISTRA Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant Location: Glen Rose, TX 76043 Inspection Dates: July 1, 2020 to September 30, 2020 Inspectors: N. Brown, Project Engineer N. Day, Resident Inspector J. Ellegood, Senior Resident Inspector S. Hedger, Emergency Preparedness Inspector J. Melfi, Project Engineer 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, 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

Unit 1 began the inspection period at rated thermal power and remained at or near rated thermal power until September 29, 2020. From September 29, 2020, until the end of the inspection period, Unit 1 was in maximum achievable coast down operations for their upcoming refueling outage.

Unit 2 began the inspection period at rated thermal power and remained 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 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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors 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 portion 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.

71111.04 - 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 1, train B motor-driven auxiliary feedwater pump on July 6, 2020

(2) Unit 2, train B safety injection on July 28, 2020

(3) Unit 1, train A instrument air dryer on August 13, 2020

(4) Unit 2, train B safety chiller on September 14, 2020 Complete Walkdown Sample (IP Section 03.02)

Ultimate Heat Sink

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 2, safety chillers area 2AA on September 11, 2020

(2) Unit 2, safety bus 2EA1 area 2SD on September 25, 2020

(3) Unit 2, safety bus 2EA2 area 2SE on September 25, 2020

(4) Unit 1, safety chillers area 1AA on September 30, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Units 1 and 2, uninterruptable power supply rooms

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) Unit 2, licensed operator performance during motor-driven auxiliary feedwater post maintenance testing per Work Order 5717924 on September 23, 2020

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

(1) The inspectors observed and evaluated a licensed operator exam in the simulator on September 2, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample 1 Partial)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) (Partial)-Electronic power supplies for safety-related systems on Units 1 and 2

(2) Overall maintenance effectiveness of Unit 1 auxiliary feedwater

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 1, elevated risk due to fire main leak and Unit 1 main generator thyristor AC unit failure during the week of August 31, 2020

(2) Unit 2, elevated risk due to safety chiller 2-06 maintenance outage from September 8 through 13, 2020

(3) Unit 1, elevated risk due to main generator thyristor voltage regulator failure on September 9, 2020.

(4) Unit 1, auxiliary feedwater pump availability while crediting a dedicated operator actions on July 7, 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) Safety chiller 1-06 operability based on small Freon leak on July 25, 2020

(2) Safety injection pump 2-01 following inability to meet test conditions on July 28, 2020

(3) Containment radiation monitor with incorrect setpoint on August 31, 2020

(4) Fire suppression system with X-06 diesel fire pump not functional on September 15, 2020

(5) Component cooling water system due to piping indication in Condition Report CR-2020-006675 on September 22, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Unit 2, safety chiller 2-05 repairs on July 23, 2020

(2) Diesel fire pump X-06 on September 10, 2020

(3) Emergency diesel generator 2-02 on September 16, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Safe shutdown impoundment silt measurement on August 25, 2020

(2) Unit 2, safety injection pump A on September 29, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The licensee submitted a summary of emergency plan changes (Revision 43) to the NRC on May 12, 2020. The inspectors conducted an in-office review of the changes from July 1 to September 23, 2020. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) Tabletop emergency preparedness drill on August 3,

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, July 1, 2019, through June 30, 2020

(2) Unit 2, July 1, 2019, through June 30, 2020

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1, July 1, 2019, through June 30, 2020

(2) Unit 2, July 1, 2019, through June 30, 2020

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

(1) Unit 1, July 1, 2019, through June 30, 2020

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

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On September 23, 2020, the inspectors presented the Emergency Plan In-Office Review Exit Meeting inspection results to Mr. J. Dreyfuss, Director of Organizational Effectiveness, and other members of the licensee staff.

• On October 1, 2020, the inspectors presented the integrated inspection results to Ken Peters, Senior Vice President and Chief Nuclear Office, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action IR-2020-006659

Documents

Miscellaneous CP20-0739 Instrument Air Dryer Clearance 08/11/2020

DBD-ME-225 Fire Suppression System 27

TX04912 Safe Shutdown Impoundment Inspection Report September,

20

Procedures ODA-403 Operations Department Locked Component Control 8

SOP-201B-SI- Safeguards Bldg Train B Valve Lineup 1

V09

SOP-304B-AF- Train B MDAFW Pump Lineup 3

V02

SOP-509A Instrument Air System 22

Work Orders 5772340, 5805115, 5834490, 5863391

71111.05 Fire Plans FPI-103B Unit 2 Safeguards Building 810'-6" Radiation Pen Area and 3

Electrical Equipment Room

FPI-107B Unit 2 Safeguards Elevation 852' Electrical Equipment Area 4

and Feedwater Penetration Area

FPI-510 Electrical and Control Building Chiller Pump Rooms 3

Elevation 778'-0"

71111.06 Calculations SI-CA-0803-3381 UPS Room Flooding Analysis 1

71111.11Q Miscellaneous LO49C20E02 Scenario Event Description for Licensed Operator 09/02/2020

Examination

71111.12 Corrective Action TR-2019-8503, TR-2020-005887

Documents

Work Orders 5849486 Power Supply CP1-ECPRCB-08 2/6/2020

71111.13 Miscellaneous Guarded Equipment Posting Management Sign Posting Log 09/07/2020

for Safety Chiller 2-06 Outage

71111.15 Corrective Action TR-2020-005621

Documents CR-YYYY-NNNN 2020-6366, 2020-005556

71111.19 Procedures MSM-PX-4702 Fire Pump Diesel Engine Preventive Maintenance

71111.22 Miscellaneous Safe Shutdown Impoundment Inspection August 2020

71114.04 Corrective Action CR-YYYY-NNNN 2020-005975

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

Miscellaneous Activity Numbers Removing Section 6.7 (Laboratory Facilities in EOF-NOSF) 2/26/2020

EV-CR-2019-

008831-4; EV-IR-

20-000756-1

CP-201800662 Comanche Peak Nuclear Power Plant, Docket Nos. 50-445, 10/31/2018

50-446, and 72-74; License Amendment Request 18-002 for

Revision of the Emergency Plan

CP-201900152 Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 3/28/2019

and 50-446; Response to Request for Additional Information

Regarding License Amendment Request (LAR)18-002 for

Revision of the Emergency Plan and Supplement to LAR 18-

2

CP-201900354 Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 6/3/2019

and 50-446; Response to Supplemental Request for

Additional Information Regarding License Amendment

Request (LAR)18-002 for Revision of the Emergency Plan

and Supplement to LAR 18-002

CP-202000312 Comanche Peak Nuclear Power Plant (CPNPP), Docket 5/12/2020

Nos. 50-445, 50-446; Transmittal of Revised Emergency

Plan (Revision 43)

Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 2

Emergency Plan Documentation

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

(TSC)

71114.06 Miscellaneous Drill scenario for table top drill conducted August 3, 2020

71151 Miscellaneous U1 MSPI Margin Report 6/30/2020

U2 MSPI Margin Reports 6/30/2020

MAY20 MSPI WANO spreadsheet 5/31/2020

APR20 MSPI WANO spreadsheet 4/30/2020

JUN20 MSPI WANO spreadsheet 6/30/2020

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