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Integrated Inspection Report 05000445/2021003 and 05000446/2021003
	ML21307A154
Person / Time
Site:	Comanche Peak
Issue date:	11/03/2021
From:	Greg Werner; NRC/RGN-IV/DRP/RPB-B
To:	Peters K; Vistra Operating Co. (VistraOpCo)
References
	IR 2021003
	Download: ML21307A154 (11)
	v • d • e

November 03, 2021

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2021003 AND 05000446/2021003

Dear Mr. Peters:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 14, 2021, the NRC inspectors discussed the results of this inspection with Mr. Thomas McCool 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, Gregory E. Werner, 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:

05000445/2021003 and 05000446/2021003

Enterprise Identifier: I-2021-003-0107

Licensee:

VISTRA Operating Company, LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, TX

Inspection Dates:

July 1, 2021 to September 30, 2021

Inspectors:

N. Day, Resident Inspector

J. Ellegood, Senior Resident Inspector

D. Proulx, Senior Project Engineer

H. Strittmatter, Project Engineer

B. Bergeon, Examiner

Approved By:

Gregory E. Werner, Chief

Reactor Projects Branch B

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,

Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Units 1 and 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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 on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP

===71152, Problem Identification and Resolution, 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.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01)===

Main article: IP 71152

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

(1) Unit 2, motor driven auxiliary feedwater pump A on July 7, 2021

(2) Unit 1, 1B2-1 electrical lineup on July 21, 2021

(3) Unit 1, chemical addition system on July 28, 2021

(4) Unit 1, train B containment spray system on August 18, 2021

(5) Unit 2, train B safety injection system on August 31, 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 1, train A safeguards building switchgear room on August 19, 2021

(2) Unit 1, safeguards building electrical equipment room on August 23, 2021

(3) Unit 1, train B safeguards building switchgear room on August 25, 2021

(4) Unit 2, train B safeguards building switchgear room on August 26, 2021

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) Standby service water pumphouse on August 25-26, 2021

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from April 21, 2021, through May 21, 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) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 service water A quarterly system testing on September 22, 2021.

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

(1) The inspectors observed and evaluated licensed operator requalification training scenario LO44.A22.TCA on September 10, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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 plant computer on September 8, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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, station transformer outage on July 8 2021

(2) Unit 1, solid state protection system power supply replacement on August 18, 2021

(3) Unit 1, channel A N-16 monitor failure and replacement on August 27, 2021

(4) Unit 2, outage risk profile for Refueling Outage 19 which begins October 3, 2021

(5) Risk profile issues discussed in IR-2021-005614 and TR-2021-005609 due to new Phoenix software on September 9, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

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

(1) Electrical Bus 1EA1 undervoltage protection circuit PB-3B/1EA1 and PB-4B/1EA1 when depressed did not light

(2) Component Cooling Water Heat Exchanger 1-02 fouling as reported on August 4, 2021

(3) Spiking of source range nuclear instrument start up rate while deenergized

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) Unit 1, temporary lube oil purification skid for the main feed pump A

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (1 Sample)

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

(1) Unit 1, safety injection pump breaker replacement on July 13, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22

(1) Unit 1, lube oil analysis for component cooling water pumps analyzed July 20, 2021

(2) Diesel Generator 1-01 monthly operability test on August 26, 2021

(3) Unit 1, Turbine Driven Auxiliary Feedwater Pump 1-01 per Work Order 538334 on September 2, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Unit 1, Station Service Water System 1-01 operability test per Work Order 582265

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Emergency response organization drill conducted on August 4,

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)===

Main article: IP 71151