IR 05000445/2020011
| ML22034A825 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/07/2022 |
| From: | Alexandra Siwy Division of Reactor Safety IV |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2020011 | |
| Preceding documents: |
|
| Download: ML22034A825 (17) | |
Text
February 7, 2022
SUBJECT:
AMENDED - COMANCHE PEAK NUCLEAR POWER PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000445/2020011 AND 05000446/2020011 AND NOTICE OF VIOLATION
Dear Mr. Peters:
The NRC is issuing this revision to the subject report to accurately reflect the number of samples that were performed under Inspection Procedure 71111.21N.05, Section 03.01 contained in NRC Inspection Report 05000445/2020011 AND 05000446/2020011, dated September 21, 2020 (ADAMS Accession No. ML20265A042). This section of the original report indicated that two partial samples and four complete samples were documented. This section has been amended to indicate that four partial and zero complete samples were documented.
On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant and 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.
Enclosure 2 discusses a violation associated with a finding of very low safety significance (Green). The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this violation did not meet the criteria to be treated as a non-cited violation because your staff did not restore compliance within a reasonable period of time after a violation was previously identified by the NRC as NCV 05000445/2017008-01; 05000446/2017008-01.
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in the inspection report (Enclosure 2). Therefore, you are not required to respond to this letter unless the record does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the Notice of Violation (Enclosure 1).
If you contest the violation or the significance or severity of the violation documented in this inspection report, 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 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; and the NRC Resident Inspector at Comanche Peak Nuclear Power Plant.
This letter, its enclosures, 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, Andrew D. Siwy, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89
Enclosures:
1. Notice of Violation 2. Inspection Report Signed by Siwy, Andrew on 02/07/22
ML22034A825 X SUNSI Review By: ADS ADAMS:
X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword NRC-002 OFFICE DRP:C/PBB DRS:C/EB2 NAME GEWerner ADSiwy SIGNATURE GEW ADS DATE 02/07/2022 2/7/2022
Enclosure 1 NOTICE OF VIOLATION Vistra Operations Company LLC Comanche Peak Nuclear Power Plant, Units 1 and 2 Docket Nos.: 05000445 and 05000446 License Nos.: NPF-87 and NPF-89 During an NRC inspection completed on August 27, 2020, a violation of NRC requirements was identified. In a
Inspection Report
Docket Numbers:
05000445 and 05000446
License Numbers:
Report Numbers:
05000445/2020011 and 05000446/2020011
Enterprise Identifier:
I-2020-011-0039
Licensee:
Vistra Operations Company LLC
Facility:
Comanche Peak Nuclear Power Plant
Location:
Glen Rose, Texas
Inspection Dates:
June 8, 2020 to August 27, 2020
Inspectors:
S. Alferink, Reactor Inspector
J. Drake, Senior Reactor Inspector
J. Mateychick, Senior Reactor Inspector
Approved By:
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection 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
Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000445;05000446/2020011-01 Opened/Closed H.8 - Procedure Adherence 71111.21N.
The team identified a Green violation of License Condition 2.G for the licensees failure to maintain adequate procedures for the inspection of penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the licensee implemented a revision to Fire Protection Procedure FIR-310, Penetration Seal Inspection, in 2020 to provide corrective actions for an NCV issued in 2017 due to the procedure not ensuring that all penetrations seals would be inspected during the required 15-year cycle.
However, the revised procedure incorrectly excluded from the inspection schedule all penetration seals in the auxiliary building.
Additional Tracking Items
None
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.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection (FPTI) SSC Credited for Fire Prevention, Detection, Suppression, or Post-Fire SSD Review (IP Section 03.01) (4 Partial Samples)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA). All sections of 03.01 were completed for the following samples except subsections b and e.
Subsection b states Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA. Subsection e states Perform a walkdown inspection to identify equipment alignment discrepancies. Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation. Due to conditions related to COVID19 in the area of the licensee, onsite inspector walkdowns of procedures with licensee operations personnel could not be performed at this time. An inspector will visit the licensees site to perform this activity at a later date. The results of the additional inspection will be documented in a resident inspectors quarterly report.
(1)
(Partial)
The auxiliary feedwater system and the steam generator power-operated relief valves.
(2)
(Partial)
The fire water system including the fire water tanks, fire pumps, and yard loop distribution piping system.
(3)
(Partial)
The fire detection systems and fire suppression systems installed in Fire Area EN, Unit 1 Cable Spreading Room.
(4)
(Partial)
The fire detection systems and fire suppression systems installed in Fire Area EM, Unit 2 Cable Spreading Room.
Fire Protection Program Administrative Controls (IP Section 03.02)===
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees fire protection program contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) The inspectors reviewed the licensees administrative controls of hot work, transient combustibles, and fire impairments.
- (2) The inspectors reviewed the licensees fire brigade training program.
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
- (1) The inspectors reviewed changes to the approved fire protection program concerning the inspection of fire rated penetration sealing devices.
- (2) The inspectors reviewed the changes to the approved fire protection program incorporated into the Comanche Peak Nuclear Power Plant Fire Protection Report Units 1 and 2, Revision
INSPECTION RESULTS
Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000445; 05000446/2020011-Opened/Closed H.8 - Procedure Adherence 71111.21N.0 The team identified a Green violation of License Condition 2.G for the licensees failure to maintain adequate procedures for the inspection of penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the licensee implemented a revision to Fire Protection Procedure FIR-310, Penetration Seal Inspection, in 2020 to provide corrective actions for an NCV issued in 2017 due to the procedure not ensuring that all penetrations seals would be inspected during the required 15-year cycle.
However, the revised procedure incorrectly excluded from the inspection schedule all penetration seal devices in the auxiliary building.
Description:
During the 2017 triennial fire protection inspection, the NRC identified a Green non-cited violation for the failure to maintain adequate procedures for the inspection of fire penetration seals. As part of this violation, the NRC noted that the licensee used an automated random sampling process for selection of penetration seals for inspection and this process failed to ensure that all required penetration seals were inspected within their 15-year sampling plan interval.
The team documented this violation as NCV 05000445/2017008-01; 05000446/2017008-01, Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices, on July 31, 2017. The licensee documented this issue in the corrective action program in Condition Report CR-2017-007746.
In response to this violation, the licensee generated a list of over 16,000 fire penetration seals that required inspection. The licensee divided this list into different groups based on the penetration seal location. The licensee associated these groups with 15 repetitive preventive maintenance tasks. The licensee then updated Procedure FIR-310, Penetration Seal Inspection, to require the inspection of penetration seals using one of these 15 preventive maintenance tasks each year over a 15-year period, thereby ensuring that each penetration seal would be inspected once during the 15-year period. The licensee revised this procedure on February 6, 2020.
During the current inspection, the team reviewed the revised inspection procedure and the repetitive preventive maintenance tasks. The team identified that the fire penetration seal group associated with the auxiliary building was not included in any of the 15 repetitive preventive maintenance tasks. This group contained 1,956 penetration seals. Since this group was not included in any of the 15 preventive maintenance tasks, the team determined that these 1,956 penetration seals were not scheduled to be inspected during the current 15-year period.
In response to the teams questions, the licensee reviewed the previous fire penetration seal inspections for the penetration seals associated with the auxiliary building. The licensee identified that 1,192 of the penetration seals were inspected and 764 of the penetration seals were not inspected during the previous 15-year period. Of the penetration seals that were inspected, the licensee determined that only two of them failed the inspection.
Corrective Actions: There was no immediate safety concern since the licensee had observed a very low failure rate of penetration seals during the previous 15-year cycle. The licensee entered this issue into the corrective action program for resolution and incorporated the auxiliary building penetration seals into eight of the preventive maintenance tasks required by procedure FIR-310. The licensee restored compliance with the approved fire protection program on June 25, 2020 and performed an Organizational Effectiveness Investigation to determine the cause of the violation. The licensee identified a lack of attention to detail and verbatim compliance with Procedure STA-422, Corrective Action Program, as causes. The verification of the lists of penetration seals to be inspected was not completed and was transferred to future actions. This was not in compliance with Procedure STA-442, Section 6.6, Condition Report Closure to Future Actions, which states that when the condition report documents a Licensing Basis Deviation the condition report may not close to future actions. The licensee provided coaching for the personnel involved.
Corrective Action References: Condition Report CR-2020-004473
Performance Assessment:
Performance Deficiency: The failure to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The team assigned the fire confinement category to the finding since it involved fire rated penetration seals. The team noted that the licensee observed a very low failure rate of the auxiliary building penetration seals during the past 15 years.
The team discussed the finding with a senior reactor analyst because the finding involved multiple fire areas. In consultation with the senior reactor analyst, the team assigned a low degradation rating to the finding because of the very low failure rate and the fact that a majority of the auxiliary building penetration seals have been previously inspected.
The team determined the finding was of very low risk significance (Green) in Step 1.3 since the finding was assigned a low degradation rating.
H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions.
Specifically, the licensee failed to complete required verifications of corrective actions to assure adequacy.
Enforcement:
Violation: License Condition 2.G for Unit 1 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 78 and as approved in the Safety Evaluation Report and its supplements through Supplement 24.
License Condition 2.G for Unit 2 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 Fire Protection Report was included as part of the licensees approved fire protection program for both units, and states, in part, that administrative control of the fire protection program is provided through station procedures to assure that the fire protection equipment and systems are operable and properly maintained. This includes periodic tests and inspections, compensatory measures concerning items which may be inoperable, and quality assurance audits. Section IV-2.1.c.1 of the Fire Protection Report required, in part, that the required fire rated assemblies and penetration sealing devices are confirmed operable by visually inspecting the exposed surfaces using a site approved sampling plan every 18 months.
Contrary to this requirement, from 2009 to June 25, 2020, the licensee failed to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan every 18 months. Specifically, Procedure FIR-310, Penetration Seal Inspection, revised in response to NCV 05000445/2017008-01; 05000446/2017008-01, Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices, did not ensure that all required penetration sealing devices would be inspected within the licensees sampling plan interval. Consequently, the licensee failed to restore compliance to the previous NCV since the revised procedure did not ensure the fire rated penetration seals in the auxiliary building were included in the maintenance list so they would be scheduled for inspection.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance after the violation was previously identified consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 25, 2020, the inspectors presented the triennial fire protection inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff in a debrief meeting.
On August 27, 2020, the inspectors presented the triennial fire protection inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff in an exit meeting.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
210-063-0031
Unit 1 and Common Hydraulic Calculation Verification
Calculations
2-FP-0006
Determination of the Pressure and Flow at the Fire Pump
Discharge
Calculations
DBD-ME-003
71111.21N.05
Calculations
DBD-ME-027
Radiological Accident Analysis
71111.21N.05
Corrective Action
Documents
CR-2010-004331 CR-2013-001933 CR-2015-004590
CR-2016-002210 CR-2017-001410 CR-2017-001552
CR-2017-002011 CR-2017-002035 CR-2017-003949
CR-2017-004235 CR-2017-004324 CR-2017-004560
CR-2017-004691 CR-2017-007536 CR-2017-007745
CR-2017-007746 CR-2017-008728 CR-2017-008890
CR-2017-008961 CR-2018-006426 CR-2018-007079
CR-2018-007442 CR-2018-008405 CR-2019-003625
CR-2019-005334 CR-2019-009310 CR-2020-000558
CR-2020-000864 CR-2020-001701 CR-2020-002817
CR-2020-003204 TR-2014-010354 TR-2014-010370
TR-2014-012160 TR-2016-003548 TR-2017-003590
TR-2017-008741 TR-2017-012520 TR-2018-006427
TR-2019-003269 TR-2020-000040 TR-2020-001999
TR-2020-004586 TR-2917-009888
71111.21N.05
Corrective Action
Documents
Resulting from
Inspection
CR-2020-004397 CR-2020-004473 IR-2020-004760
Fire Plans
FPI - 504
Electrical & Control Building Elevation 807-0
Unit 2 Cable Spreading Room
71111.21N.05
Fire Plans
FPI - 505
Electrical & Control Building
Unit 1 Cable Spreading Room Elevation 807-0
Miscellaneous
Comanche Peak Nuclear Power Plant Fire Protection
Report Unit 1 and Unit 2
& 33
71111.21N.05
Miscellaneous
Comanche Peak Fire PRA Summary
Miscellaneous
AO5407
Response to Fire in the Control Room or Cable Spreading
2/21/03
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Room, Perform AO #1 Actions
Miscellaneous
20023
Transient Combustible Permit
Miscellaneous
20060
Transient Combustible Permit
Miscellaneous
20079
Transient Combustible Permit
Miscellaneous
20085
Transient Combustible Permit
Miscellaneous
20088
Transient Combustible Permit
Miscellaneous
23-AS-18
Specification Hollow Metal Doors and Frames
Miscellaneous
27599
Fire Permit
Miscellaneous
5563972
Fire Permit
Miscellaneous
5595567
Fire Permit
Miscellaneous
5611222
Fire Permit
Miscellaneous
5832506
Fire Permit
Miscellaneous
AO6413
Response to fire in Control Room or Cable spreading
room
Miscellaneous
AO6414
Response to a fire in the Control Room or Cable
Spreading Room opening pressurizer PORV MOV 8000A
2/19/01
Miscellaneous
AO6415
Align Alternate Auxiliary Feedwater Supply from Station
Miscellaneous
DBD-ME-001
CPSES Fire Protection Program Design Basis Document
Miscellaneous
DBD-ME-225
Fire Suppression System
Miscellaneous
FB44.FBR.193
FBR - 2019 Live Fire Requal Training
Miscellaneous
FB44FBR196
FBR - 2020 Live Fire Requal Training
Miscellaneous
FBD2FBI103
Portable Fire Extinguishers 1
Miscellaneous
FBD2FBI107
Fire Hose
Miscellaneous
FBD2FBI108
Fire Streams and Nozzles
Miscellaneous
FBD2FBI109
Hoselines and Master Streams
Miscellaneous
FBD2FBI201
Personal Protective Equipment (Fire Brigade)
Miscellaneous
FBD2FBI204
Search and Rescue
Miscellaneous
FBD2FBI207
Handling Hoselines
Miscellaneous
FBD2FBI208
Foam Operations (Fire Brigade)
Miscellaneous
FBDSFBI102
Combustion and Fire Behavior
Miscellaneous
Final Safety
Analysis Report
Emergency Planning
Amendment
No. 109
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Section 13.3
Miscellaneous
Final Safety
Analysis Report
Section 9.5.1
Amendment
No. 109
Miscellaneous
OER-2017-
007276
IER L4-17-6 Fire Event Trend and Causes
06/13/17
Miscellaneous
OER-2017-
009751
NRC IN-2917-04 High Energy Arching Faults In Electrical
Equipment Containing Aluminum Components
08/29/17
Miscellaneous
OER-2018-
006316
NRC Information Notice 2018-09; Electrical Arc Flash
Caused by Foreign Material Damages Fire Door
09/20/18
Miscellaneous
RO4406
Respond To Fire In Control Room Or Cable Spread Room
08/31/08
Procedures
ABN-803A
Response To A Fire In The Control Room Or Cable
Spreading Room
Procedures
ABN-803B
Response To A Fire In The Control Room Or Cable
Spreading Room
Procedures
ABN-804A
Response To Fire In The Safeguards Building
Procedures
ABN-804B
Response To Fire In The Safeguards Building
Procedures
ABN-805A
Response To Fire In The Auxiliary Building Or The Fuel
Building
Procedures
ABN-805B
Response To Fire In The Auxiliary Building Or The Fuel
Building
Procedures
ABN-806A
Response To Fire In The Electrical And Control Building
Procedures
ABN-806B
Response To Fire In The Electrical And Control Building
Procedures
ABN-807A
Response To Fire In The Containment Building
Procedures
ABN-807B
Response To Fire In The Containment Building
Procedures
ABN-808A
Response To Fire In Service Water Intake Structure
Procedures
ABN-808B
Response To Fire In Service Water Intake Structure
Procedures
ABN-809A
Response To Oil Leak Or Fire In The Turbine Building
Procedures
ABN-809B
Response To Oil Leak Or Fire In The Turbine Building
Procedures
ABN-901
Fire Protection System Alarms or Malfunctions
Procedures
FBD2FBI104
Portable Fire Extinguishers 2
Procedures
FBD2ICS111
Incident Management
71111.21N.05
Procedures
FIR-201
Preparation, Control, Review and Use of Fire Preplan
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Instructions
Procedures
FIR-302
Fire Door Tests and Inspections
Procedures
FIR-308
Fire Brigade Equipment
Procedures
FIR-310
Penetration Seal Inspection
Procedures
FIR-PX-3200
Fire Suppression Loop Flow Test
Procedures
FIR-PX-3801
Electric Driven Fire Protection Pump CPX-FPAPFP-04
Operability Test
Procedures
FIR-PX-3802
Diesel Driven Fire Protection Pump CPX-FPAPFP-05
Operability Test
Procedures
FIR-PX-3803
Diesel Driven Fire Protection Pump CPX-FPAPFP-06
Operability Test
Procedures
INC-3020
Maintenance and Rework of Plant Doors
Procedures
OPT-220
Fire Suppression Water System Operability Test
Procedures
STA-202
Nuclear Generation Procedure Change Process
Procedures
STA-421
Control of Issue Reports
Procedures
STA-422
Corrective Action Program
Procedures
STA-602
Temporary Modifications and Transient Equipment
Placements
Procedures
STA-716
Modification Process
Procedures
STA-722
Procedures
STA-723
Fire Protection Systems/Equipment Requirements
Procedures
STA-724
Fire Reporting and Response
Procedures
STA-727
Fire Brigade
Procedures
STA-729
Control of Transient Combustibles, Ignition Sources and
Fire Watches
Procedures
STA-738
Fire Protection Systems/Equipment Impairments
Procedures
STI-422.03
Performing Coaching and Investigations
Procedures
STI-422.04
Processing of Condition Reports
Procedures
STI-423.01
Processing Tracking Reports
Procedures
TRA-104
Fire Protection Training
71111.21N.05
Self-
Assessments
EVAL-2018-010
2/15/18
Self-
IR-2019-005207
Fire Protection Self-Assessment Report
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Assessments
71111.21N.05
Work Orders
209230, 5329355, 5511184, 5557316, 5558257,
5578521, 5655850, 5668385, 5747089, 5749736,
5757975, 5821733, 5840282, 5841173, 5856117,
5861142, 5920545