IR 05000445/2021004
| ML22019A304 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/25/2022 |
| From: | Greg Werner NRC/RGN-IV/DRP |
| To: | Peters K Vistra Operating Co. (VistraOpCo) |
| References | |
| IR 2021004 | |
| Download: ML22019A304 (25) | |
Text
January 25, 2022
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000445/2021004 AND 05000446/2021004
Dear Mr. Peters:
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 6, 2022, the NRC inspectors discussed the results of this inspection with Mr. S. Sewell, Senior Director Engineering and Regulatory Affairs, 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.
Two licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as NCVs consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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, 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:
Report Numbers:
05000445/2021004 and 05000446/2021004
Enterprise Identifier:
I-2021-004-0118
Licensee:
VISTRA Operating Company, LLC
Facility:
Comanche Peak Nuclear Power Plant, Units 1 and 2
Location:
Glen Rose, TX 76043
Inspection Dates:
October 1, 2021 to December 31, 2021
Inspectors:
B. Baca, Health Physicist
N. Day, Resident Inspector
J. Drake, Senior Reactor Inspector
J. Ellegood, Senior Resident Inspector
S. Graves, Senior Reactor Inspector
E. Simpson, Health Physicist
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.
Licensee-identified non-cited violations are documented in report sections: 71111.15 and 71111.2
List of Findings and Violations
Failure to follow Radiation Work Permit requirement Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000445,05000446/2021004-01 Open/Closed
[H.12] - Avoid Complacency 71124.01 The inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to follow written procedures for worker behavior inside a high radiation area. Specifically, a licensee contract worker failed to follow radiation work permit 2021-2605, Task 31, Unit 2 Refueling Outage 19 Interference Removal and Installation, Revision 00, which required that with any dose alarm, the worker leave the work area and contact radiation protection immediately.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power.
Unit 2 began the inspection period at rated thermal power. On October 3, the licensee shut Unit 2 down for a planned refueling outage. Unit 2 remained shut down until November 14, 2021. The licensee synchronized Unit 2 to the grid on November 15, 2021, and ascended in power. On November 17, 2021, Unit 2 reached rated thermal power.
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 performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, component cooling water on October 16, 2021
- (2) Unit 2, steam generator nozzle dams on October 30, 2021
- (3) Unit 2, containment penetrations on November 2, 2021
- (4) Mid loop level indication system on November 7, 2021
- (5) Unit 2, demineralized water to ensure isolation per tagout 2RF19-374 on November 9, 2021
- (6) Cyber security equipment per Job Aid 11/02/2021B on November 22, 2021
Complete Walkdown Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 turbine driven auxiliary feedwater system on November 30, 2021.
- (2) The inspectors evaluated system configurations during a complete walkdown of the 345kV system on December 2, 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, turbine building on October 15, 2021
- (2) Unit 2, containment on October 20, 2021
- (3) Unit 1, train A residual heat removal (RHR), containment spray and RHR pump rooms on November 19, 2021
- (4) Unit 1, train B RHR, containment spray and RHR pump rooms on November 19, 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) Units 1 and 2, emergency core cooling system pump rooms trains A and B.
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 October 18, to November 10, 2021:
03.01.a - Nondestructive Examination and Welding Activities.
Ultrasonic examination of the pressurizer surge nozzle pipe to safe end weld overlay, component ID TCX-1-4500-5OL
Liquid penetrant examination of socket weld on the safety injection replacement drain valve, component ID 2SI-0125
Work Order 5540274, socket weld for replacement of safety injection drain valve, component ID2SI-0125 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
Bare metal visual examinations of reactor vessel head 78 penetrations and head vent 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
Work Order 21-400126; boric acid leak on 2WP-0016, liquid processing system reactor coolant drain tank Pump 2-02 discharge drain valve
Work Order 21-400150; boric acid leak on 2SI-8970C, Coolant Charging Pump 2-01/2-02 to Flow Element 0926 high pressure test connect valve Work Order 21-768572; boric acid leak on safety injection pump 2SI-8829B, to Cold Leg 2-04 Flow Element 0983 low pressure test connect valve
Work Order 21-768572; boric acid leak on safety injection pump 2SI-8827A, to Cold Leg 2-02 Flow Element 0981 high pressure test connect valve 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
Eddy current testing of 11052 tubes in steam generator SG 1, 10919 tubes in steam generator SG 2, 11422 tubes in steam generator SG 3 and 11454 tubes in steam generator SG 4 The inspectors reviewed one condition report associated with inservice inspection activities and concluded that nondestructive examination/inservice inspection related issues and operating experience are put into the corrective action program system at low levels to ensure conditions and problems are identified. No findings or violations of more than minor significance were identified.
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 shutdown of the reactor on October 3, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance during time critical operator action scenario LO44A22TCA on December 6, 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, instrument air compressor failure on June 29, 2021
- (2) Unit 1, primary plant ventilation on December 18, 2021
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Commercial Grade Dedication Packages NEE07522019, SAR 28981, SAR 41689, NEI03272019 and NEI03302020 for tape, capacitors, and hinges
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) Yellow risk due to refueling outage during the week of October 3, 2021
- (2) Elevated risk during adverse weather on October 12, 2021
- (3) Unit 2, elevated risk during heavy lift of the high-pressure turbine shaft assembly on October 18, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Emergency preparedness following loss of telephone and internet on October 11, 2021
- (2) Unit 1, service water with 1EB4-3/2E/breaker open
- (3) Unit 2, power range nuclear instruments with operation past approved fluence levels
- (4) Unit 2, train B containment spray and RHR with flood tight door unsecured
- (5) Unit 2, reactor coolant and support systems following failure of the mechanical stress improvement process (MSIP) tool
- (6) Steam generator power operated relief valves with filters past specified life
- (7) Unit 2, service water pump B broken seismic support
- (8) Unit 2, containment temperatures due to high differential pressure alarms on neutron well cooling Units 2-9 and 2-10 on December 28, 2021 in condition report CR-2021-
===008621
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary or permanent modifications:
- (1) Temporary modification of nuclear instrument 2-N50B to eliminate noise
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (14 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2, Loop 2 hot leg MSIP completion following failure of the MSIP tool during compression evolution on October 20, 2021
- (2) Unit 2, Loop 1 cold leg MSIP completion following failure of the MSIP tool during compression evolution on October 23, 2021
- (3) Hot and cold leg nozzle penetration enclosures following MSIP tool failures on October 25, 2021
- (4) Unit 2, Emergency Diesel Generator 2-02 per Work Order 5922931 on November 1, 2021
- (5) Reactor vessel foreign object search and retrieval on November 1 and 2, 2021
- (6) Unit 2, digital rod position indication replacement per Work Order 5918899 on November 5, 2021
- (7) Unit 2, Centrifugal Charging Pump 2-02 per Work Order 307396 on November 5, 2021
- (8) Steam Generator 4 bowl closeout inspection on November 8, 2021
- (9) Core verification testing on November 14, 2021
- (10) Unit 2, station service water to auxiliary feedwater pump supply valve per Work Order 5881360 on November 22, 2021
- (11) Unit 1, containment spray chemical addition tank level transmitter 1-LT-4752 Work Order 6040905 on December 1, 2021
- (12) Unit 1, containment spray chemical addition tank level transmitter 1-LT-4753 Work Order 6040884 on December 1, 2021
- (13) Unit 1, main feedwater pump 1B control power fuse replacement per Work Order 21-933901 on December 16, 2021
- (14) Unit 1, 1-CI-104 power supply per Work Order 21-951071 on December 22, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 2RF19 activities from October 3 to November 17, 2021.
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
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 in the fire hazards analysis or safe shutdown analysis.
(1)
(Partial)
Walkdowns of the fire water system including the fire water tanks, fire pumps and yard loop distribution piping system on September 8, 2021. The inspectors completed Sections 03.01.b and 03.01.e. This completes on site sample associated with the 2020 triennial fire protection inspection documented in report 05000445/2020011 and
===05000446/202011.
(2)
(Partial)
Unit 1, cable spreading room on September 8, 2021. The inspectors completed Sections 03.01.b and 03.01.e. This completes on site sample associated with the 2020 triennial fire protection inspection documented in report 05000445/2020011 and 05000446/202011.
(3)
(Partial)
Unit 2, cable spreading room on September 8, 2021. The inspectors completed Sections 03.01.b and 03.01.e. This completes on site sample associated with the 2020 triennial fire protection inspection documented in report 05000445/2020011 and 05000446/202011.
(4)
(Partial)
Unit 2, time critical operator actions associated with auxiliary feedwater system and the steam generator power operated relief valves on September 8, 2021. The inspectors completed Sections 03.01.b and 03.01.e. This completes on site sample associated with the 2020 triennial fire protection inspection documented in report 05000445/2020011 and 05000446/202011.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 1, post-accident instrumentation channel check per procedure OPT-112A, "Post Accident Monitoring Channel Checks," on October 20, 2021
- (2) Unit 1, monthly rod exercise and repositioning per Work Order 776590 on October 28, 2021
- (3) Unit 2, trains A and B sump inspections on November 27, 2021 Inservice Testing (IP Section 03.01)===
- (1) Unit 2, reactor head vent valve testing by Work Order 5901912 on November 11, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) Local leak rate testing per Work Order 5900151 accepted on November 12, 2021
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Steam generator FLEX pumps X-01, X-02 and X-03 per Work Order 5977589 on December 22,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated instructions to workers including radiation work permits (RWPs) used to access high radiation areas (HRAs):
Radiation Work Packages
RWP 2021-2400, "Unit 2 Refueling Outage 19 (2RF19) Westinghouse Primary Side Steam Generator," Revision 0
RWP 20212604, 2RF19 Mechanical Stress Improvement Process (MSIP)
Westinghouse NuVision, Revision 0
RWP 20212605, 2RF19 Interference Removal, Revision 0; and
RWP 20212607, 2RF19 MSIP Support Activities, Revision 0 Electronic Alarming Dosimeter Alarms
One dose rate alarm - a contract employee received an unanticipated dose rate alarm of 231 mrem per hour on a RWP set-point of 120 mrem per hour.
The higher-than-expected dose rates were due to the reactor internals being lifted higher out of the water than previous evolutions and a shorter than usual (half the usual length) tag line being used by workers (TR-2021-006574).
One accumulated dose alarm - a contract employee received an accumulated dose alarm of 44 mrem on a RWP set-point of 40 mrem while moving the Unit 2 reactor upper internals. The higher-than-expected dose rates were due to the internals being lifted higher out of the water than previous evolutions, causing higher dose rates in the area the individual was required to stand (TR-2021-006570).
One accumulated dose alarm - a contract employee received an accumulated dose alarm of 72 mrem on a RWP set-point of 70 mrem while performing tie-rod measurements connected to reactor coolant pump Loop 2. The individual believed they could complete final measurements without exceeding dose limits (TR-2021-006743).
Pre-job Briefings and Labeling of Containers
Pre-job briefing for the sandbox areas, 860-foot elevation, cleanup of residual interferences in support of MSIP work on October 18, 2021, for RWP
===20212604, Tasks 31 and 32 and RWP 20212605, Task 31
High Radiation Area pre-job briefing for sandbox activities on October 18, 2021, for RWP 2605, Task 31
Seven radioactive source containers (HP60171-XSS, HP-60193-XSS, HP-60194-XSS, HP-60249-XSS, HP-60250-XSS, HP-60265-XSS, and HP-60703-XSS).
One 55-gallon barrel of radioactive material/trash from the MSIP activities on the Unit 2 refuel floor
Multiple radioactive contaminated outage equipment containers in the outage radioactive material storage yard; and
Locked high radiation area steam generator Loop 1 and Loop 4 insert/diaphragm containers Contamination and Radioactive Material Control (IP Section 03.03)===
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Observed radiation protection technicians surveying potentially contaminated personnel and materials exiting the radiological controlled area.
- (2) Observed worker and radiation protection technician control of radioactive materials during and exiting the cavity for MSIP activities and steam generator Loop 1 and Loop 4 manway and insert/diaphragm removal.
- (3) Observed workers and radiation protection technicians exiting and releasing materials from the Unit 2 containment contamination area.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the following in-plant radiological conditions during facility walkdowns and observation of radiological work activities:
- (1) RWP 2021-2400, "2RF19 Westinghouse Primary Side Steam Generator," Revision 0
- (2) RWP 2021-2600, "2RF19 Westinghouse Refueling Activities," Revision 0 and RWP 2021-2601, "2RF19 Refueling Support Activities," Revision 0
- (3) RWP 2021-2601, "2RF19 Fuel Building Refueling Activities," Revision 0
- (4) RWP 2021-2604, "2RF19 MSIP Westinghouse NuVision," Revision 0; RWP 2021-2605, "Interference Removal," Revision 0; and RWP 2021-2607, "2RF19 MSIP Support Activities," Revision 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:
- (1) Unit 1 Safeguards Building: Floor Drain Tank Room (1-SG-773-061), Letdown Heat Exchanger Valve Room (1-SG-810-080), Letdown Heat Exchanger Room (1-SG-810-081), and Volume Control Tank Room (1-SG-832-089)
- (2) Unit 2 Reactor Building: Reactor Cavity (2-RB-860-155M/157), Regeneration Heat Exchanger Room (2-RB-832-155C), Steam Generator Loop 1 and Loop 4 inserts (2-RB-812)
- (3) Unit 2 Safeguards Building: Letdown Heat Exchanger Room (2-SG-810-081) and Volume Control Tank Room (2-SG-832-089)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (3 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls for the following activities:
- (1) RWP 2021-2400, "2RF19 Westinghouse Primary Side Steam Generator," Revision 0
- (2) RWP 2021-2600, "2RF19 Westinghouse Refueling Activities," Revision 0 and RWP 2021-2601, "2RF19 Refueling Support Activities," Revision 0
- (3) RWP 2021-2604, "2RF19 MSIP-Westinghouse NuVision," Revision 0; RWP 2021-2605, "Interference Removal," Revision 0; and RWP 2021-2607, "2RF19 MSIP Support Activities," Revision 0
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during the following activities:
(1
RWP 2021-2400, Task 31, "Manway/Diaphragm Removal," Revision 0
RWP 2021-2604, Task 31, "MSIP Activities including Quality Assurance/Quality Control," Revision 0, and Task 32, "Install tools, Wall Anchor Jibs, and Demobilize," Revision 0
RWP 2021-2605, Task 30, "Work in cavity associated with setup/removal of equipment," Revision 0 and Task 31, "Interference removal and installation,"
Revision 0
RWP 2021-2607, Task 1, "Confined space and firewatch, no sandbox entry,"
Revision 0; Task 30,"Radiation Protection," Revision 0; and Task 31,"Decon support," Revision
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS10: Cooling Water Support Systems (IP Section 02.09)===
- (1) Unit 1 (October 1, 2020, through September 30, 2021)
- (2) Unit 2 (October 1, 2020, through September 30, 2021)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) November 1, 2020 through September 30, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) November 1, 2020 through September 30, 2021
71152 - Problem Identification and Resolution (PI&R)
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in field use of procedures that might be indicative of a more significant safety issue. The inspectors observed an issue during installation of a rod position indication panel during which workers improperly used the lift rig. Further investigation revealed the work order was in a different location and the human performance tool of "circle slash" was not used as described in licensee procedures. In addition, the inspectors noted the use of a reference use work order during the replacement of level transmitters was used, however, a field copy would have been another resource/barrier against human performance errors. During the months of November and December, the inspectors observed work in progress as part of routine tours and other inspection activities and checked that procedures were in use and human performance error reduction tools were in use.
Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) The licensee's identification and resolution of control room and in the field deficiencies, burdens, and work arounds.
- (2) Evaluation of the corrective action effectiveness by sampling issues identified during and after the cyber security full implementation inspection completed on June 1, 2020 (ML20153A465)
- (3) The inspectors reviewed the licensee's maintenance of equipment used for communications as part of the emergency plan. In 2021, the inspectors recognized multiple conditions that challenged functionality of emergency plan equipment including the loss of emergency response data system equipment following a plant computer modification (corrected by translation modification documented in integrated inspection report 05000445/2021002 and 05000446/2021002, ML21222A101), the loss of the emergency notification system phone line due to degraded infrastructure (corrected by upgrade to voice over internet protocol technology), loss of network which impacted voice over internet protocol technology, and site Gaitronics equipment degradation (condition reports 2021-003884, 2021-005014, 2021-005058, 2021-005937 and 2021-007256). For the issues reviewed, the licensee was able to implement their emergency plan. The inspectors are continuing to monitor the licensee's corrective actions of restoring redundancy of communication methods to verify they are addressed in accordance with safety and regulatory significance.
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III requires, in part, that "Measures shall also be established for the selection of and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety related functions of the structures, systems and components."
Contrary to the above, in 2013, Comanche Peak failed to review for suitability the power range neutron instrumentation (PRNI) extension of service life. At the time, Westinghouse vendor document WCAP-8687 concluded that the PRNI were suitable for operation to a fluence of 4.59x10^17 nvt; however, the licensee subsequently exceeded this fluence. After further evaluation incorporating additional Westinghouse information, the PRNI were determined to be operable at all times.
Significance/Severity: Green. The inspectors determined the finding was more than minor because it adversely affected the mitigating system cornerstone objective to ensure the capability of system that respond to initiating events with respect to the design control attribute. In addition, the inspectors concluded the issue was similar to Inspection Manual Chapter 0612 Appendix E, Example 3a, in that the issue resulted in reasonable doubt regarding the operability of the PRNI and an additional calculation was required revision to establish operability.
Corrective Action References: Comanche Peak entered this issue into the corrective action program as condition report CR-2021-007137.
Licensee-Identified Non-Cited Violation 71111.20 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 3.a of Regulatory Guide 1.33, Revision 2, Appendix A, February 1978 describes and requires, in part, instructions for changing modes of operation of the chemical volume control system (CVCS).
Contrary to the above, on October 5, 2021, Comanche Peak failed to implement a procedure for changing modes of operation of the Unit 1 CVCS. Specifically, an auxiliary operator operated a Unit 2 CVCS system valve instead of the Unit 1 valve, which resulted in a partial depressurization of the Unit 2 reactor coolant system while in solid plant operations.
Significance/Severity: Green. The inspectors determined this issue adversely impacted the initiating events cornerstone objective of limiting the likelihood of events that upset performance with respect to the human performance attribute. The inspectors concluded using IMC 0609 Appendix G, Attachment 1, that the issue increased the likelihood of a shutdown initiating event-i.e. a loss of inventory event. The inspectors discussed the issue with a regional Senior Risk Analyst. The Senior Risk Analyst determined the issues was of very low safety significance-i.e. Green.
Corrective Action References: Comanche Peak entered this issue into the corrective action program as condition report CR-2021-006372.
Failure to follow Radiation Work Permit requirement Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000445,05000446/2021004-01 Open/Closed
[H.12] - Avoid Complacency 71124.01 The inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to follow written procedures for worker behavior inside a High Radiation Area. Specifically, a licensee contract worker failed to follow radiation work permit (RWP) 2021-2605, Task 31, Unit 2 Refueling Outage 19 Interference Removal and Installation, Revision 00, which required that with any dose alarm, the worker leave the work area and contact radiation protection (RP) immediately.
Description:
On October 18, 2021, a contract worker received an accumulated dose alarm while cutting out interferences in the reactor vessel cold leg No. 3 sandbox area. The worker did not leave the work area or contact RP upon receipt of the accumulated dose alarm as required by RWP 2021-2605, Task 31. The worker had a dosimeter accumulated dose set point of 300 millirem and exited the area with a total accumulated dose of 367 millirem on his electronic dosimeter. The worker was wearing a multi-badge pack, the alarm occurred on the worker's back dosimeter, and the dosimeter was in an alarm state for approximately 16 minutes before the worker was instructed by an RP technician to leave the reactor cavity.
Prior to making the entry into the radiologically controlled area, the workers cutting out the interferences were informed of the work area radiological conditions during an RP high radiation area brief. The brief also instructed the workers to exit the area immediately upon any accumulated dose alarm per the RWP requirements. The RWP setpoints assigned to the self-reading dosimeters were 300 millirem accumulated dose and a 300 millirem per hour dose rate. The highest dose rate received on the worker's back dosimeter was 432 millirem per hour and follow up surveys of the work area were consistent with the maximum rate seen by the self-reading dosimeter. The inspectors concluded that the contract worker did not follow the instructions provided by RP during the per-job briefing or the requirements of the RWP when they did not stop work and leave the work area upon receiving the accumulated dose alarm.
Corrective Actions: The licensee assessed this issue and implemented multiple immediate corrective actions. Some of the actions taken included:
Discussion with the individual to clear up knowledge gaps regarding dose versus dose rate alarms and multi-badge dosimetry
RP technician positioned in the cavity to provide additional support and telemetry monitoring at the 860 refuel control point
Increased the dose rate alarm setpoints in reactor vessel cold leg No. 3 sandbox, based on work to be performed
Stand down for both day and night shifts to cover lessons learned Corrective Action References: The licensee entered the contract workers failure to properly respond to a self-reading dosimeter accumulated dose alarm as required by RWP 2021-2605, Task 31 into their corrective action program as condition report CR-2021-006894.
Performance Assessment:
Performance Deficiency: The failure to follow an RWP requirement was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to follow requirements involving radiological controls had the potential to increase the workers dose. The failure to follow procedural requirements to exit the work area upon an accumulated dose alarm resulted in a 67 millirem increase to worker exposure above the RWP assigned maximum total accumulated dose of 300 millirem.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because
- (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because the worker failed to implement the following human performance (error reduction) tools while in the high radiation area: Questioning Attitude and Self/Peer Checking. In regard to the Questioning Attitude aspect, when multiple dose rate alarms were received, a proper questioning attitude would have caused the worker to exit the high radiation area and contact RP. In regard to the Self/Peer Checking aspect, while the worker may not have been able to see the accumulated dose on the back dosimeter, the workers should have worked as a team where a peer check could have been made to assess how close the back dosimeter's accumulated dose was from the accumulated dose alarm. Neither of these human performance actions took place
[H.12].
Enforcement:
Violation: Technical Specification 5.4.1.a, requires, in part, that written procedures shall be established, implemented, and maintained covering
- (a) the applicable procedures recommended in NRC Regulatory Guide 1.33, Rev. 2, Appendix A, February 1978. Appendix A, Section 7.e.1 requires procedures for Access Control to Radiation Areas Including a Radiation Work Permit (RWP) System. The licensee established RWP 2021-2605, Task 31, Interference Removal and Installation, Revision 0, which requires that with any dose alarm,
[the worker] leave [the] area and contact RP immediately.
Contrary to the above, on October 18, 2021, a contract employee received an accumulated dose alarm while cutting out interferences in the reactor vessel cold leg No. 3 sandbox and the employee did not leave the work area or contact RP immediately as required by RWP 2021-2605, Task 31. The cavity worker had been in an alarm state for approximately 16 minutes before the individual was directed by RP to leave the reactor cavity.
Enforcement Action: This violation is being treated as a non-cited violation, 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 December 2, 2021, the inspectors presented the fire protection samples to complete 2020 triennial inspection, onsite portion not completed due to COVID 19. inspection results to Mr. A. Marzloff, Plant Manager, and other members of the licensee staff.
On December 9, 2021, the inspectors presented the inservice inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On January 6, 2022, the inspectors presented the integrated inspection results to Mr. S. Sewell, Senior Director Engineering and Regulatory Affairs, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
21-788872
Containment Penetration Verification for
Calculations
CPE-SI-CA-662
rev 8
Corrective
Action
Documents
CR-2017-011512
Concrete from Ceiling of the SWIS had
fallen onto Walkway
2/26/2020
Engineering
Evaluations
SG-CDMP-21-16
Comanche Peak 2RF19 SG Inspection
NDE Reports
211010
Detailed Borescope Report
10/12/2021
NDE Reports
FW-8 2SI-0125
PT Examination Report
10/19/2021
NDE Reports
TCX-1-4500-OL
UT of Pressurizer Surge Nozzle
10/28/2021
Operability
Evaluations
CR-2021-006299
U2 Containment Boric Acid Inspection
10/03/2021
Procedures
NDE 2.01
Liquid Penetrant Examination
Procedures
TX-ISI-302
Ultrasonic Examination of Austenitic Piping
Procedures
TX-ISI-305
Appendix 1 PDI-UT-5
Procedures
WPS CP-301-1
Welding Procedure P8 to P8
Work Orders
5540274
Replace Valve 2SI-0125
10/19/2021
Corrective
Action
Documents
CR-YYYY-NNNN
21-004279
Engineering
Evaluations
EV-TR-2019-004073-2
Evaluate Instrument Air Maintenance Rule
Function
06/30/2021
Miscellaneous
Maintenance Rule Manager database for
Unit 1 Instrument Air on December 7,2021
Corrective
Action
Documents
CR-YYYY-NNNN
2013-5928, 2021-6783, 2021-7137
Corrective
Action
Documents
CR-YYYY-NNNN
2002-000038-01
Engineering
FDA-2021-000061-02-00
Provide Temporary Modification to Neutron
Revision 0
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Changes
Flux Monitoring System
Engineering
Evaluations
59SC-2021-000061-02
50.59 Screen for PRNI temporary
Modification
Corrective
Action
Documents
TR-YYYY-NNNN
21-007807
Miscellaneous
FOSAR Bottom of Vessel Video
11/01/2021
Miscellaneous
FOSAR Nozzle Closeout Video
11/01/2021
Miscellaneous
FOSAR Lower Support Ledge Video
11/01/2021
Miscellaneous
FOSAR Flange Surfaces Video
11/01/2021
Procedures
NUC-301
Low Power Physics Testing
11/14/2021
Procedures
RFO-210
Reactor Vessel and Upper Internals FOSAR
Activities
11/01/2021
Miscellaneous
Work hour records and key card records for
sample of covered workers.
71111.21N.05
Procedures
AO*5407
Response to Fire in the Control Room or
Cable Spreading Room, Perform AO #1
Actions
2/21/2003
71111.21N.05
Procedures
AO*5407A
In Response to a Fire in the Control Room
or Cable Spreading Room, Perform PEO #1
Actions to Achieve Hot Shutdown
01/20/2006
71111.21N.05
Procedures
AO5407C
Title: Response to Fire in the Control Room
or Cable Spreading Room, NEO #1 Actions
(Outside RCA)
71111.21N.05
Procedures
AO6413
Title: Response to fire in Control
Room or Cable spreading room,
NEO #2 actions
Response to fire in Control Room or Cable
spreading room, NEO #2 actions
71111.21N.05
Procedures
RO4406B
Respond to Fire in the Control Room or
Cable Spreading Room
71111.21N.05
Procedures
RO4406C
Respond to a Fire in the Control Room
Procedures
OPT-830B
Appendix J Leakrate Test of Penetration 2-
MIV0001(b)
Work Orders
Calculate Total Containment Leakrate
11/03/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective
Action
Documents
TR-YYYY-NNNN
2019-007674, 2019-007684, 2019-007986,
2019-008073, 2019-008161, 2019-008424,
2019-008440, 2019-009225, 2019-009321,
20-002947, 2020-003633, 2020-004002,
20-008104, 2021-000975, 2021-001889,
21-001994, 2021-002065, 2021-002555,
21-005459, 2021-006570, 2021-006574,
21-006730, 2021-006743, 2021-006894
Miscellaneous
Spent Fuel Pool Contents, Units-1 and -2
09/29/2021
Miscellaneous
Weekly High Radiation Area/Locked High
Radiation Area/Very High Radiation Area
Checks
10/05/2021
Procedures
RPI-212
Radioactive Source Control
Procedures
RPI-304
Radiological Posting and Labeling
Procedures
RPI-305
Access Controls for High Radiation Areas
Procedures
RPI-509
Personnel Dosimetry Program
Procedures
RPI-602
Radiological Surveillance
Procedures
RPI-606
Radiation Work and General Access Permits
Procedures
RPI-700
Sealed Source Leak Testing
Procedures
STA-422
Corrective Action Program
Procedures
STA-650
General Health Physics Plan
Procedures
STA-652
Radioactive Material Control
Procedures
STA-655
Exposure Monitoring Program
Procedures
STA-656
Radiation Work Control
Procedures
STI-421.02
Issue Report Reviews
Procedures
STI-422.01
Operability Determination and Functionality
Assessment Program
Procedures
STI-422.01
Initiation of Issue Reports
Procedures
STI-422.03
Performing Coaching and Investigations
Procedures
STI-422.05
Conditional Release
Radiation Work
Permits (RWPs)
21-2400
Unit 2 Refuel 19, Westinghouse Primary
Side Steam Generator Activities
Radiation Work
Permits (RWPs)
21-2401
Unit 2 Refuel 19, Reactor Coolant Pump
Activities
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Work
Permits (RWPs)
21-2600
Unit 2 Refuel 19, Westinghouse Refueling
Activities
Radiation Work
Permits (RWPs)
21-2601
Unit 2 Refuel 19, Refueling Support
Activities
Radiation Work
Permits (RWPs)
21-2604
Unit 2 Refuel 19, Mechanical Stress
Improvement Process Westinghouse
NuVision
Radiation Work
Permits (RWPs)
21-2605
Unit 2 Refuel 19, Interference Removal
Radiation Work
Permits (RWPs)
21-2607
Mechanical Stress Improvement Process
Support Activities
ALARA Plans
RWP 2021-2400
2RF19 Westinghouse Primary Steam
Generator Work
08/10/21
ALARA Plans
RWP 2021-2600
2RF19 Westinghouse (WEC) Refueling
Activities
07/26/2021
ALARA Plans
RWP 2021-2601
2RF19 Refuel Support Activities
09/15/2021
ALARA Plans
RWP 2021-2602
2RF19 Fuel Building Refuel Activities
06/14/2021
ALARA Plans
RWP 2021-2604
2RF19 Mechanical Stress Improvement
Process (MSIP) Westinghouse NuVision
09/08/2021
ALARA Plans
RWP 2021-2605
2RF19 Interference Removal
09/20/21
ALARA Plans
RWP 2021-2607
2RF19 Mechanical Stress Improvement
Process (MSIP) Support Activities
09/23/2021
Corrective
Action
Documents
TR-YYYY-NNNN
21-004040, 2021-004147, 2021-004251,
21-005091, 2021-005602, 2021-005857,
21-005954
Procedures
RPI-606
Radiation Work and General Access Permits
Procedures
RPI-629
Radiological Risk Management
Procedures
STA-651
ALARA Program
Procedures
STA-657
ALARA Job Planning/Debriefing
Radiation
Surveys
M-20211018-23
Steam Generator Channel Head Survey
Points - Steam Generator #1
10/21/2021
Radiation
Surveys
M-20211018-26
Steam Generator Channel Head Survey
Points - Steam Generator #4
10/21/2021
Radiation
M-20211022-5
Steam Generator Platform #4
10/22/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Surveys
Radiation
Surveys
M-20211022-6
Steam Generator Platform #1
10/21/2021
Radiation
Surveys
M-YYYY-XXXX-X
Unit 2 Sandbox Surveys: M-20211018-6, M-
211018-14, M-20211018-12, M-
211018-13, M-20211018-8, M-20211018-
10, M-20211018-7, M-20211018-15
71151
Miscellaneous
MSPI Indicator Margin Report for Cooling
Water Systems, Units 1 and 2
2/08/2021
Corrective
Action
Documents
CR-YYYY-NNNN
20-001086, 2020-001149, 2020-001154,
20-001412, 2020-001429
Corrective
Action
Documents
TR-YYYY-NNNN
20-001410
Drawings
NEI0809R6ITSECLAN950SAOV-
001
Schematic Architecture Overview for
LAN950 and Interconnections
Miscellaneous
Time Server Delta Check Tracking Table
08/24/2021
Miscellaneous
Comanche Peak Nuclear Power Plant Unit 1
and 2 Cyber Security Plan
Miscellaneous
CSI-006
Security Computer System IPS Functionality
Test Logs (March, 2020 - September 2021)
Miscellaneous
TSST - NEI044
Audit Log Correlation Document - System
Time Servers
Procedures
CSI-103
Control of Portable Devices and Mobile
Computing Devices
Procedures
CSI-302-1-AUA-
Audit and Accountability Controls
Compliance Checklist - Direct CDAs
Procedures
CSI-318
Cyber Security Ongoing Monitoring and
Assessment of Direct CDAs
Procedures
CSI-318-1-OMP-
Ongoing Monitoring - Program Level
Controls
Procedures
CSI-318-2-OMC-
Ongoing Monitoring - CDA Level Controls -
Direct CDAs
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
CSI-322
Cyber Security CDA, Insecure and Rogue
Devices/Wireless Connections Monitoring
1