IR 05000445/2021002

Integrated Inspection Report 05000445/2021002 and 05000446/2021002

ML21222A101
Person / Time
Site:	Comanche Peak
Issue date:	08/10/2021
From:	O'Keefe C NRC/RGN-IV/DRP/RPB-B
To:	Peters K Vistra Operations Company
References
IR 2021002
Download: ML21222A101 (19)

Text

August 10, 2021

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2021002 AND 05000446/2021002

Dear Mr. Peters:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On July 15, 2021, the NRC inspectors discussed the results of this inspection with Mr. Brian St. Louis, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

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, Units 1 and 2.

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, Units 1 and 2. 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 Digitally signed by Cornelius F. O'Keefe F. O'Keefe Date: 2021.08.10 14:06:20 -05'00'

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: 05000445/2021002 and 05000446/2021002 Enterprise Identifier: I-2021-002-0038 Licensee: VISTRA Operating Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, TX 76043 Inspection Dates: April 1, 2021 to June 30, 2021 Inspectors: C. Alldredge, Health Physicist Ryan Alexander, Emergency Preparedness Inspector N. Day, Resident Inspector J. Ellegood, Senior Resident Inspector S. Hedger, Emergency Preparedness Inspector J. Melfi, Project Engineer J. O'Donnell, Senior Health Physicist H. Strittmatter, 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,

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

Failure to Maintain Emergency Response Data System Equipment in a Format Capable of Communication with the NRC Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.13] - 71152 Preparedness NCV 05000445,05000446/2021002-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50 Appendix E, Section VI.2.c when the licensee failed to maintain the emergency response data system (ERDS) so that it could generate data compatible with the NRC receiving system.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at 57 percent power. After restoring a tripped main feed pump, the licensee ascended to 100 percent power on April 2, 2021. Unit 1 operated at or near rated thermal power for the remainder of the inspection period.

Unit 2 began the inspection at or near rated thermal power. On June 7, 2021, Unit 2 tripped following a bushing failure and fire on the main transformer. On June 18, 2021, the licensee restarted the unit and reached 100 percent on the June 19, 2021. Unit 2 remained at or near 100 percent 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/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 a 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.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on June 3, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) Unit 2, motor driven auxiliary feedwater pumps prior to turbine driven auxiliary feedwater (TDAFW) pump work on April 7, 2021

(2) Unit 2, TDAFW pump following maintenance on June 23, 2021

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, yard area on June 7, 2021

(2) Units 1 and 2, train A battery rooms, Fire Area EH on June 23, 2021

(3) Units 1 and 2, train B battery rooms, Fire Area EC on June 23, 2021

(4) Fire water pump house, Fire Area FP on June 26, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during live fire training exercise on June 23, 2021.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the control room during restoration of Unit 1 main feedwater pump A on March 1, 2021.

(2) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 synchronization of the main generator to the grid on June 19, 2021.

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

(1) The inspectors observed and evaluated a licensed operator requalification examination in the control room simulator on May 11, 2021.

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 1, safety injection with maintenance rule (a)(1) status since September 2016

(2) Unit 1, low voltage electric power with maintenance rule (a)(1) status since August 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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, unplanned emergency diesel generator (EDG) 2-01 outage on May 13, 2021.

(2) Unit 2, main generator current transformer system elevated temperature on June 2, 2021.

(3) Unit 1, planned EDG 1-01 outage on June 30, 2021.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1, train B component cooling water with socket weld leak described in Condition Report 2021-2227

(2) Unit 2, train B uninterruptible power supply with tornado door impaired identified during and NRC walkdown.

(3) Independent spent fuel storage installation campaign Holtec Lift Yoke described in Condition Report 2021-002236.

(4) Unit 2, steam generator snubber low hydraulic fluid reservoir level described in Condition Report 2021-002873.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

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

(1) Unit 1, main feed pump A following pump trip on April 2 2021.

(2) Unit 2, main transformer 1 following bushing replacement on June 18, 2021.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) Unit 2, force outage due to main transformer bushing failure from June 7 to 19, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1, safety injection pump 1-02 by work order 6018854.

(2) Unit 2, safety injection pump 2-01 by work order 6016851.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, residual heat removal pump 2-02 by work order 6018783.

71114.06 - Drill Evaluation

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

(2 Samples)

(1) The green Emergency Response Organization team exercise May 12, 2021.

(2) License operator training with Drill/Exercise Performance opportunities on June 30,

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensees radiological work planning. The inspectors reviewed plans for the following activities:

(1) Radiation Work Permit (RWP) 2019-1607, 1RF20 Mechanical Stress Improvement Process (MSIP) Support Activities

(2) RWP 2020-1401, 1RF21 Reactor Coolant Pump Activities

(3) RWP 2020-2603, 2RF 18 Alloy 600/MSIP/Shim Gap

(4) RWP 2021-0601, Used Fuel Outage 7 (Dry Cask Storage 6 Casks)

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)

The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable planning documents:

(1) RWP 2019-1215, 1RF20 Scaffold Activities (Excludes Material Stress Improvement Program (MSIP))

(2) RWP 2020-2210, Lower and Upper Loop Rooms 1, 2, 3 & 4 (Allows Breach)

(3) RWP 2020-2217, 2RF18 Insulator Activities All Areas (Excluding Support of Room 2-153 Bare Metal Inspection)

(4) RWP 2020-2603, 2RF18 Alloy 600/MSIP/Shim Gap

(5) Additionally, the inspectors reviewed the following radiological outcome evaluations:

• RWP 2019-1606, 1RF20 MSIP Shim Gap Work

• RWP 2020-1401, 1RF21 Reactor Coolant Pump Activities

• RWP 2021-0601, Used Fuel Outage 7 (Dry Cask Storage 6 Casks)

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the internal dosimetry program implementation. The inspectors reviewed the following whole-body counts:

(1) 20190507 - Follow-up from Personnel Contamination Event (PCE) 19-0017 (CR 2019-004368)

(2) 20200508-10 - Investigation of Potential Intake PCE 20-0024 (TR-2020-003590)

(3) 20201026 - Investigation for Facial Contamination

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

(1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for three workers.

(2) Licensees implementation of requirements to manage radiation protection application of NRC-approved external dosimetry methods (i.e. EDEX) for three workers.

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 2020, through March 2021)

(2) Unit 2 (April 2020, through March 2021)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) Unit 1 (October 1, 2020, through March 31, 2021)

Unit 2 (October 1, 2020, through March 31, 2021)

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) Unit 1 (October 1, 2020, through March 31, 2021)

Unit 2 (October 1, 2020, through March 31, 2021)

EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) Unit 1 (October 1, 2020, through March 31, 2021)

Unit 2 (October 1, 2020, through March 31, 2021)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees system and program health reports for engineering for potential adverse trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1) Issues with the ERDS following January 2020 plant computer modification.

(2) Safety injection pump polarization index failure on September 26, 2021.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated the Unit 2 automatic reactor trip and fire on the Unit 2 main transformer 2MT1 and licensees response on June 7, 2021.

(2) The inspectors evaluated licensee actions to address frigid weather and grid instability during the week of February 14,

INSPECTION RESULTS

Failure to Maintain Emergency Response Data System Equipment in a Format Capable with the NRC Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.13] - 71152 Preparedness NCV 05000445,05000446/2021002-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50 Appendix E, Section VI.2.c when the licensee failed to maintain the emergency response data system (ERDS) plant equipment so that it could generate data compatible with the NRCs receiving system.

Description:

In January 2020, Comanche Peak Nuclear Plant installed a new plant computer. The plant computer provides plant information onsite. Some of the information can also be sent to ERDS allowing NRC staff to monitor plant conditions during events. Prior to the plant computer replacement, Comanche Peaks plant computer created 30 different data quality tags to describe data points. However, the NRCs receiving system is limited to eight specific quality tags. Therefore, the licensee used the Plant Interface (PI) server to translate the quality tags for data from the old plant computer into the acceptable eight quality tags.

The new plant computer system creates 26 different quality tags which do not necessarily match the old quality tags; however, the licensee failed to update the translation matrix to reflect the change. This caused most ERDS data sets to be displayed as BAD DATA on the NRCs receiving system. This problem was not recognized until April 21, 2021.

The NRC established requirements for ERDS following the accident at Three Mile Island when the lack of data regarding plant conditions inhibited the NRC's ability to assess the event. To accomplish its event response mission, NRC requires licensees to initiate ERDS within 60 minutes following declaration of an Alert. In addition, the NRC established format requirements to ensure NRC staff can view the required data. NUREG-1394, Emergency Response Data System (ERDS) Implementation, Appendix B, Revision 1 discusses the quality tags that will be accepted by the NRCs receiving system.Section II.B.2.g, states that all data must have quality tags using codes 0-7 to be understood by the NRC system. Use of quality tags outside this range result in BAD DATA or no value displayed on the ERDS viewer.

The inspectors reviewed the 10 CFR 50 Appendix E, Emergency Response Data System, statements of consideration published August 31, 1991 (Bluebook 21st ed. 56 Fed.

Reg. 40178 (1991), Tuesday, August 13, 1991, pages 38319 - 40218). Of note, in the staff response to public comment number 20 indicated that licensees can use any existing quality tags. However, a translation matrix is needed to convert the licensee tags to the form used by the NRC Operations Center. Variation of tags used by the licensee (without the translation matrix) could cause confusion to the NRC monitors.

On April 21, 2021, while performing a required quarterly ERDS communications test with the NRC, NRC personnel reported that most of the data being received indicated BAD DATA. In subsequent discussions between the inspectors and other NRC personnel, an NRC information technology staff member pointed out that the licensee must be sending data quality tags outside the limits of those used by the NRCs receiving system. In subsequent discussion with the licensee, the inspectors learned that no post-modification testing of the ERDS function was performed following replacement of the plant computer to ensure the data was successfully understood by the NRCs receiving system. Therefore, ERDS had been non-functional from January 2020 until May 11, 2021, when the licensee updated the translation matrix. Since the NRC informed Comanche Peak of the BAD DATA condition and identified that the data quality tags were not correctly set, this issue is being categorized as NRC identified.

The inspectors determined that while preparing the modification to replace the plant computer, the licensee had incorrectly concluded that the ERDS function would not be affected by the plant computer replacement; therefore, the licensee failed to inform the NRC of the change. The licensee did not include a comprehensive test of the ERDS interface in post-modification testing, so they did not recognize that the data being sent was not compatible. Although the licensee tested ERDS quarterly, the test used only validated ERDS transmission was being received at the computer center at NRC headquarters, as opposed to the Headquarters Operations Center where the data would be used. The inspectors learned that the people checking the transmission was received were computer technicians who did not have any reason to use ERDS, and they were not asked by the licensee whether good data was being displayed, so the test procedure was not effective in demonstrating that the system was really working. At the same time, the NRC did not specify what the quarterly test needed to check. Review of test data from January 2020 to April 2021 confirmed tests performed contained mainly bad data; however, NRC staff did not recognize this condition at the time. The inspectors noted that the licensee had previously replaced the plant computer, including successfully updating the translation matrix. Therefore, the inspectors concluded that the licensee was not using a consistent process in evaluating the scope of actions needed to support the modification.

Corrective Actions: This issue was corrected on May 11, 2021 under work order 6036106 which created a proper translation matrix evaluated in FDA-2021-000017-01.

Corrective Action References: This issue was entered into the corrective action program as Condition Report 2021-002743.

Performance Assessment:

Performance Deficiency: The licensees failure to maintain ERDS equipment capable of transmitting data in a format compatible with the NRCs receiving system was a performance deficiency. Specifically, Comanche Peak failed to correctly translate plant computer data quality tags created by the new plant computer into quality tags that could be recognized by the NRC. This caused ERDS data points to read as BAD DATA and were unusable by NRC staff.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. During events, the NRC is a principal response organization. For the NRC to effectively perform its regulatory function of event response, the NRC requires effective communication with licensee staff to include voice communications and data indicating key plant parameters. The Comanche Peak ERDS transmission to the NRC provides a real time update of 57 critical plant parameters without a time delay. This allows the NRC to assess plant conditions and advise multiple stake holders on mitigating actions. During an emergency event and a concurrent loss of ERDS capability, the NRCs ability of getting the same data would be significantly delayed and available to fewer responders than it would be using the backup method, which is via the Emergency Notification System Communicator telephone bridge.

Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. Using Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3 worksheets (effective date December 20, 2019);and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2 (issue date September 22, 2015). The performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The finding was not a loss of planning standard function because the licensee continued to have other emergency communication equipment available to implement its emergency plan.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Comanche Peak failed to follow a consistent process in evaluating the scope of actions needed to support the modification for updating the plant computer, when the process has previously been successful in determining the scope and should have included updating the translation matrix.

The plant computer was modified before without a ERDS transmission issue during a previous modification.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(6) requires, in part, that provisions exist for prompt communications among principal response organizations to emergency personnel and to the public. Further, 10 CFR 50, Appendix E, Section VI.2.c, regarding the ERDS, requires all link control and data transmission must be established in a format compatible with the NRC receiving system as configured at the time of licensee implementation.

Contrary to the above, from January 2020 until May 2021, Comanche Peak failed to maintain ERDS such that the data transmission was established in a format compatible with the NRC receiving system. Specifically, during a January 2020 plant computer replacement, the licensee failed to update a quality tag translation matrix, which made the ERDS transmission to the NRC monitors unusable in the event of an emergency.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: System Health and Program Health Trends 71152 The inspectors reviewed the site's system health reports and program health reports. For system health, the inspectors noted some systems had been in yellow health for multiple 6 month health reviews. There were also multiple examples of systems deteriorating from a white status to a yellow status between the fourth quarter of 2018 and fourth quarter of 2020.

For example:

• Unit 2 instrument air declined from white to yellow in the second half of 2020; Unit 1 was in yellow health from the second half of 2018 until the first half of 2020 but remains in white

• Radiation Monitoring system declined from white to yellow in 2018 and remains in yellow

• Unit 2 Safety injection has been Yellow since 2018; Unit 1 Safety injection declined to white over the same period.

• In addition, the program health for the Environmental Qualification Program has been yellow since the 4th quarter 2018.

The duration of systems and programs in a yellow status may indicate the licensees implementation of the system health program has not been effective in some cases in allocating resources to improve program and system health.

Observation: Licensee response to Frigid Weather 71153 During the week starting February 14, 2021, Comanche Peak experienced frigid weather conditions for multiple consecutive days. Prior to the onset of the cold weather, the licensee implemented their abnormal procedure to address cold weather with supplemental actions based on operating experience. The inspectors performed walkdowns of licensee action using inspection procedure 71111.01. Following the onset of cold weather, the site experienced a grid electrical frequency drop on February 14, 2021 caused by having more load on the grid than generation to support it. As part of the response, as specified in abnormal procedure titled "Response to A 138-345 KV System Malfunction, the licensee started all four emergency diesel generators and transferred the train A emergency busses to its respective diesel generator. Concurrently, the shift manager contacted the grid operator and requested that the grid operator recover grid frequency to at least 59.9 Hz. The grid operator reduced grid load and recovered electrical frequency within a few minutes, and plant operators restored the plant to a normal electrical configuration. The inspectors verified the licensee responded in accordance with approved procedures through discussions, log reviews, and computer trend reviews. The licensee maintained the plant in a stable condition with limited work activities for the rest of the period of severe cold weather. The inspectors continued to monitor plant parameters and activities using Inspection Procedures 71111.13 and 71111.15. After the cold weather, on February 20, 2021, the inspectors used inspection procedure 71111.04 to inspect the condition of systems and components susceptible to freezing looking for damage. The inspectors concluded site personnel maintained the plant in a safe condition and the cold weather did not cause significant damage to the plant.

EXIT MEETINGS AND DEBRIEFS

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

• On May 20, 2021, the inspectors presented the occupational radiation safety inspection results to Mr. Thomas P. McCool, Site Vice President, and other members of the licensee staff.

• On June 16, 2021, the inspectors presented the Emergency Preparedness Performance Indicator Verification inspection results to Mr. P. Allen, Manager, Emergency Preparedness, and other members of the licensee staff.

• On July 15, 2021, the inspectors presented the integrated inspection results to Mr. Brian St. Louis, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.05 Procedures FPI-510 Electrical Control Building Unit 1 and 2 Battery Rooms, 792 3

Elevation

71111.12 Corrective Action CR-YYYY-NNNN 2016-002742, 2018-007835

Documents TR-YYYY-NNNN 2016-7964, 2019-4155

Miscellaneous CPNPP System Electric Power Low Voltage 118, 240 V 4th Qtr FY20

Status

System 02/03/2021

Monitoring Plan

EPS (excel file)

Procedures MSE-S0-6303 Molded Case Circuit Breaker Test and Inspection 9

71111.13 Procedures STI-604.02 Maintenance Risk Assessment Revision 1

WMG-10 Work Week Coordinator Expectations Revision 3

71111.19 NDE Reports Unit 2 Main Transformers Thermography Measurements 06/19/2021

Order No. Sweep Frequency Response Analysis for Unit 2 Main 06/18/2021

4617028 Transformer.

71114.06 Miscellaneous Event Notification Forms for Drill/Exercise Performance

Opportunity during Licensed Operator Requalification on 30

June 2021.

71124.02 Corrective Action Tracking Reports 2019-007674, 2019-007986, 2019-008073, 2019-008081,

Documents (TR-) 2019-008161, 2019-008883, 2020-000449, 2020-000457,

20-000848, 2020-001010, 2020-002088, 2020-003452,

20-003474, 2020-003590, 2020-003728, 2020-003934,

20-004406, 2020-004540, 2020-004565, 2020-005176,

20-005496, 2020-006775, 2020-008584, 2021-001866,

21-001994

Procedures RPI-604 Radiological Control of Contamination 6

RPI-606 Radiation Work and General Access Permits 40

RPI-625 RP Job Coverage for High Integrity Container Closure and 4

Transfer

RPI-629 Radiological Risk Management 5

STA-651 ALARA Program 12

STA-656 Radiation Work Control 24

Inspection Type Designation Description or Title Revision or

Procedure Date

STA-657 ALARA Job Planning/Debriefing 21

Radiation Work 2019-1215 1RF20 Scaffold Activities (Excludes Mechanical Stress

Permits (RWPs) Improvement Process)

2019-1606 1RF20 Mechanical Stress Improvement Process Shim Gap

Work

2019-1607 1RF20 Mechanical Stress Improvement Process Support

Activities

20-1401 1RF21 Reactor Coolant Pump Activities

20-2210 Lower and Upper Loop Rooms 1, 2, 3 & 4 (Allows Breach)

20-2217 2RF18 Insulator Activities All Areas (Excluding Support of

Room 2-153 Bare Metal Inspection)

20-2603 2RF18 Alloy 600/Mechanical Stress Improvement

Process/Shim Gap

21-0601 Used Fuel Outage 7 (DCS 6 Casks)

Self-Assessments Five Year Dose Reduction Plan 2020-2024

71124.04 Corrective Action Condition Reports 2018-003290, 2019-003262, 2019-004368, 2019-004692,

Documents (CR-) 2020-003444

Tracking Reports 2019-004484, 2019-005455, 2019-008643, 2019-009439,

(TR-) 2020-000866, 2020-000968, 2020-001440, 2020-002350,

20-002971, 2020-003008, 2020-003590, 2020-005662,

20-005838, 2020-007409, 2021-001302, 2021-002846,

21-003354

Miscellaneous Declaration of Pregnancy (Start) 04/14/2020

Declaration of Pregnancy (Start) 09/14/2020

Declaration of Pregnancy (Start) 12/16/2020

Declaration of Pregnancy (End) 08/19/2019

100555-0 National Voluntary Laboratory Accreditation Program 07/01/2020

Certificate of Accreditation for through

Mirion Technologies (GDS), Inc., Irvine, CA 06/30/2021

1341 Whole Body Monitoring Worksheet 10/13/2020

1352 Multibadge Worksheet 01/20/2021

1352 Dose Evaluation Form 01/14/2021

1372 Whole Body Monitoring Worksheet 10/27/2020

1582 Whole Body Monitoring Worksheet 10/13/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

20-0024 Personnel Contamination Log Entry 06/02/2020

2018-2023 Five Year Dose Reduction Plan 06/01/2018

EV-TR-2016- Estimated Neutron Monitoring During Dry Cask Storage 11/14/2016

008283-2 Using the RadEye NL

IR-2016-8283 Implementation Testing of Thermo-Fischer RadEye NL 07/18/2018

Neutron Radiation Survey Meter and Mirion DMC3000

G3/Neutron Module Electronic Dosimeter (SRD)

IR-2016-8283 Determination of a Neutron Correction Factor for the Mirion 11/14/2016

DMC2000 GN and the DM3000 G3 with Neutron Detection

Module During Dry Cask Storage (DCS) Activities

Memorandum Data Verification 04/27/2021

TR-2019-005052 Annual Energy Calculation

Procedures RPI-105 Exposure Records 28

RPI-306 Personnel Contamination Monitoring 1

RPI-402 Personnel Contamination Event Documentation 37

RPI-500 Bioassay Program 16

RPI-509 Personnel Dosimetry Program 16

RPI-515 Neutron Dose Measurement and Recording 20

RPI-516 Dose Determination 35

RPI-521 General Area Monitoring Program 14

RPI-528 Multiple Dosimetry Badging 14

RPI-801 Operation of Portable Survey Instruments 22

STA-502 Routine Reporting 15

STA-650 General Health Physics Plan 9

STA-655 Exposure Monitoring Program 23

Radiation M-20190511-3 Unit 2 Safeguards 773 Train A Corridor 05/11/2019

Surveys

M-20210515-4 Aux 832 Piping Area 05/15/2021

71151 Corrective Action Condition Reports 2020-007714, 2020-009460, 2020-009553, 2020-009415,

Documents (CR-) 2021-000456

Corrective Action Issue Reports 2021-004018, 2021-004019

Documents (IR-)

Resulting from

Inspection Type Designation Description or Title Revision or

Procedure Date

Inspection

Miscellaneous Comanche Peak Nuclear Power Plant, Alert & Notification 2

System Design Report

CP-202100137 Alert & Notification System (ANS) Design Report, Revision 2, 3/11/2021

Change 1, Effective Date 3-11-2021 (Reference AI-TR-2017-

003895-1)

EPP-201, EAL Comanche Peak Nuclear Power Plant, Emergency Action 1

Tech Bases Level Technical Bases Document

FDA-2009- Replace the Unit 2 Plant Computer System (PCS) 7/31/2018

2875-13-00

FDA-2009- Replace the Unit 1 Plant Control System (PCS) 12/29/2019

2875-14-00

Procedures EPP-201 Assessment of Emergency Action Levels, Emergency 13

Classification and Plan Activation

Staff Guideline Alert and Notification System Surveillance 30

2

Staff Guideline NRC Performance Indicators 22

20

71152 Corrective Action CR-YYYY-NNNN 2020-7059

Documents

Miscellaneous Comprehensive System Health Report 4th Quarter FY 20

Environmental Qualification Program Health Scorecard February

21

16