IR 05000445/2022001

Integrated Inspection Report 05000445/2022001 and 05000446/2022001

ML22109A182
Person / Time
Site:	Comanche Peak
Issue date:	04/26/2022
From:	Greg Werner NRC/RGN-IV/DORS/PBB
To:	Peters K Vistra Operations Company
References
IR 2022001
Download: ML22109A182 (16)

Text

April 26, 2022

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2022001 AND 05000446/2022001

Dear Mr. Peters:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 7, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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 R esident 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 Projects Branch B Division of Operating Reactor Safety

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: 05000445/2022001 and 05000446/2022001

Enterprise Identifier: I-2022-001- 0006

Licensee: Vistra Operations Company, LLC

Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2

Location: Glen Rose, TX 76043

Inspection Dates: January 1, 2022, to March 31, 2022

Inspectors: N. Day, Resident Inspector J. Ellegood, Senior Resident Inspector D. Nani, Project Engineer D. Proulx, Senior Project Engineer A. Smallwood, Project Engineer H. Strittmatter, Project Engineer S. Hedger, Senior Emergency Preparedness Inspector

Approved By: Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety

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 FLEX Strategy Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.5] - 71152A Systems NCV 05000446,05000445/2022001- 01 Operating Open/Closed Experience The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.155,

Mitigation of Beyond Design Bases Events. Specifically, the licensee failed to maintain batteries associated with the steam generator fill pumps. This resulted in a failure to meet the minimum number of two pumps necessary to ensure sufficient capacity and capability to meet the FLEX strategy for a loss of normal heat sink.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000446/21001-01 Reactor Trip Due to Fault on 71153 Closed Main Transformer 2MT1

PLANT STATUS

Unit 1 operated at or near 100 percent power for the entire inspection period.

Unit 2 operated at or near 100 percent with two exceptions when the unit reduced power in response to grid congestion.

• On March 14, 2022, Unit 2 reduced power to approximately 85 percent. The unit returned to 100 percent on March 15, 2022.

• On March 29, 2022, Unit 2 reduced power to approximately 63 percent and returned to 100 percent later that day.

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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of cold temperatures.

• Feedwater on January 6.

• Ce StageksJanuary 21

- Equitlignment

Ptikdown Same (IPti) (5 Se

The ipectors evted systonfirions duritikdow ofling emtrains:

( Vtn January 2022

(, E mery D se G at 2-on February, 2022

(, turne driviliy pum ory 18, 2022

( Suel pooloolirn AMch 10, 2022

( Ut 1,ightng arrter system onarch 20

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, component cooling water pump Rooms 1-01 and 1-02, Fire Areas 27 and 33 on February 2, 2022

(2) Unit 2, centrifugal charging pump Rooms 2-01 and 2-02, Fire Areas 29 and 30, on February 2, 2022

(3) Unit 2, train B emergency diesel generator on March 7, 2022

(4) Unit 2, train A emergency diesel generator on March 8, 2022

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

(1) Centrifugal Charging Pump 2-01 lube oil cooler on February 15, 2022

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 component cooling water system realignment on March 9, 2022

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

(1) The inspectors observed and evaluated a scenario on February 7, 2022

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Partial)

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

(1) (Partial) Unit 2 neutron monitoring well ventilation

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2, elevated risk due to Emergency Diesel Generator 2-02 maintenance on February 2, 2022

(2) Unit 1, elevated risk due to component cooling water motor oil replacement on February 17, 2022

(3) Unit 2, elevated risk during Emergency Diesel Generator 2-02 ventilation maintenance on March 2, 2022

(4) Unit 1, storage of material and temporary equipment in containment at power on March 23, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) Radiation monitor 2-RE-5503 with periodic spikes

(2) Units 1 and 2, train B control room air conditioning with compressor X-03 not functional

(3) Condensate storage tank level indicators bias from nitrogen blanket

(4) Pressurizer power operated relief valve with loose fuse

(5) Offsite power following firewater spray on transformers auxiliary power source

71111.18 - Plant Modifications

Control Room heating, ventilation, and air conditioning system for the following:

• Like-for-like compressor change for control room air compressor X-03

• Configuration management of control room air compressor X-03 compressor change

• Technical specification bases revision to allow operability of a train with one control room air compressor unit inoperable

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

(1) Control room air conditioning from bases change and like-for-like compressor replacement

71111.19 - Post-Maintenance Testing

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

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

(1) Unit 1, Residual Heat Removal Pump 1-01 per Work Order 21-802016 on January 13, 2022

(2) Unit 1, train B containment spray pumps per Work Orders 6034550 and 6034618 on March 23, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) Unit 1, fuel transfer tube leakage rate testing per Work Order 5927472 on January 11, 2022

(2) Unit 2, Emergency Diesel Generator 2-02 surveillance on March 2, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Inservice test of Safety Injection Pump 1-02 on January 31, 2022

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The licensee submitted a summary of emergency plan changes in Emergency Action Level (EAL) Classification Matrix and EAL Technical Bases Document, Revision 3, to the NRC on January 13, 2022. The inspectors conducted an in-office review of the changes from January 16 to February 22, 2022. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

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

(1) Emergency planning drill on February 16,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) Unit 1 (January 1, 2021, through December 31, 2021)

(2) Unit 2 (January 1, 2021, through December 31, 2021)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 1 (January 1, 2021, through December 31, 2021)

(2) Unit 2 (January 1, 2021, through December 31, 2021)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 (January 1, 2021, through December 31, 2021)

(2) Unit 2 (January 1, 2021, through December 31, 2021)

===71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02)===

(1) Steam generator FLEX pump and meteorological tower diesel generators following battery failures

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample 1 Partial)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000446/2021-001-01, Reactor Trip Due to Fault on Main Transformer 2MT1 (ADAMS Accession No. MLML22060A103). The inspectors did not identify a violation of NRC requirements nor did the inspectors identify a performance deficiency.

(2) (Partial)

LER 05000445/2020- 001-00, Main Feedwater Pump Failure to Trip (ADAMS Accession No. ML21041A178): The licensee has not completed a cause determination for the failure of the main feed pump to trip since the evaluation requires an outage. Therefore, the inspectors cannot determine if a performance deficiency exists. The licensee plans on additional investigation during a planned outage in the second quarter of 2022. The inspectors have not identified any on-going safety concerns.

INSPECTION RESULTS

Failure to Maintain FLEX Strategy Cornerstone Significance Cross -Cutting Report Section Aspect Mitigating Systems Green [P 5] - Operating 71152A NCV 05000446,05000445/2022001- 01 Experience Open/Closed

The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.155, Mitigation of Beyond Design Bases Events. Specifically, the licensee failed to maintain batteries associated with the steam generator fill pumps. This resulted in a failure to meet the minimum number of two pumps necessary to ensure sufficient capacity and capability to meet the FLEX strategy for a loss of normal heat sink.

Description:

Comanche Peak has three steam generator auxiliary feedwater low pressure FLEX pumps, designated X-01, X-02, and X-03, intended to provide inventory to steam generators in the event of a beyond-design-bases event. On July 26, 2021, the licensee identified that the battery for FLEX pump X-03 was dead and replaced the battery.The licensee had just completed a quarterly test run of FLEX pumps X- 01 and X-02, thus establishing the current functionality of those pumps. On August 10, 2021, the site received, and entered into their tracking system operating experience from South Texas Project regarding a non-cited violation for failing to maintain batteries for FLEX diesel generators. The only action taken on this operating experience was informal benchmarking and that was not performed until January 2022. On September 29, 2021, the licensee started the yearly maintenance on the pumps.The first pump tested, FLEX pump XJ01Ileto a battery.oatherhanepl g the batty extiouslyoming tcheduled menanceting onhe otr twmI licenst testing, pendingFLEX pump X-01 battery replacement. The following provides a timeline of their actions:

• 09/29/2021 - Yearly inspection in accordance with Work Order 5977589 started for all three steam generator FLEX fill pumps with maintenance personnel identifying the battery for FLEX pump X-01 dead. Maintenance personnel emailed the FLEX engineer that the FLEX pump X-01 had a dead battery but no corrective action document was initiated.

• 10/04/2021 - Engineering performed a FLEX building walkdown and found the FLEX pump X-01 battery dead and the battery charger missing. Condition report CR-2021- 006325 and Work Order 21-772917 were created.

• 10/14/2021 - Maintenance satisfactorily tested FLEX pumps X- 01, X-02 and X-03 via quarterly Work Order 21-731086 and Preventive Maintenance 350678 tasks.

There was no record of FLEX pump X-01 battery replacement.

• 11/22/2021 - FLEX pump X-03 battery charger found not functioning. The licensee initiated corrective action document TR-2021- 008003 and Work Orders 21-873125 and 21-873126.

• 12/20/2021 - Maintenance, with the NRC resident observing, goes back out to complete yearly maintenance in accordance with Work Order 5977589.

The licensee initiated corrective action document TR-2021- 008547 and Work Order 6008784.

• 12/21/2021 - Maintenance replaced the battery for FLEX pump X-01 and successfully started the pump.

• 12/22/2021 - Maintenance found FLEX pump X-02 battery dead. The licensee initiated condition report CR-2021- 008575, replaced the battery, and successfully started FLEX pumps X-02 and X-03 later that day, completing the yearly maintenance (Work Order 5977589)..

The licensee adopted NRC endorsed NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, for FLEX implementation.Step 11.5, states in part, thatI "mtat that dirtlyfms a cibuitigation stregyor tor conttI orjto mancttiided inNml Am 913I bquitiabilityrsI toify unction.

qheenance program should ensure that the FLEX equipment reliability is being achieved." In this case, the pumps mitigate core damage by providing a water source to the steam generators which then removes heat from the reactor.The licensee failed to ensure FLEX equipment reliability in that two FLEX pumps used for loss of normal heat sink to fill the steam generators were non-functional at the same time due to dead batteries on FLEX pumps X-01 and X-02.

Corrective Actions: The licensee replaced the degraded batteries on December 22, 2021 and tested all thee FLEX pumps satisfactorily.

Crtivectie: J mfmancesssme :

Performance Deficiency: The licensee failed to maintain strategies to mitigate beyond-design basis external events. Specifically the licensee failed to ensure batteries for FLEX pumps remained functional.Internal and external operating experience provided indications that batteriesred meeplemento ense strategi fitigationd desi evtse mned.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using the mitigating systems cornerstone questions in Exhibit 2 of IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Per question number E2, a detail risk evaluation was needed to be performed. A senior reactor analyst performed a detailed risk evaluation of the performance deficiency, assuming the error existed from October 14, 2021 through December 21, 2021. The finding was determined to have a total delta core damage frequency of 3.1E-7/year, which is very low safety significance (Green).

Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The inspectors noted that the licensee neither evaluated nor assessed extent of condition from July 26, 2021, to December 22, 2021.Timely action in rto eli fl oro operating exri encernal externI would hav ensed the mitigatitregyemned viabl

Enforcement:

Title 10 CFR 50.155(b) requires, in part, that "licensee shall develop, implement, and maintain:

(1) Mitigation strategies for beyond-design basis external eventsStrategies and guidelines to mitigate beyond-design-basis external events from natural phenomena that are developed assuming a loss of all ac power concurrent with either a loss of normal access to the ultimate heat sink or, for passive reactor designs, a loss of normal access to the normal heat sink. These strategies and guidelines must be capable of being implemented site-wide..." In addition, 10 CFR 50.155(c)(1), requires in part, The equipment relied on for the mitigation strategies and guidelines required by paragraph (b)(1) of this section must have sufficient capacity and capability to perform the functions required by paragraph (b)(1) of this section. Contrary to these requirements, the licensee failed to maintain the equipment rel ied on for the mitigation strategies sometime between the October 14 test and the December 21, 2021 test.ppecally Iu J Jte to be stt due t batteri and trore could notriufficitity capabilityIch w mim ofwopsI necsyofm tunctions neededomentitigation strategy.

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 February 22, 2022, the inspectors presented the emergency action levels documentation in-office review inspection results to Mr. P. Allen, Manager, Emergency Preparedness, and other members of the licensee staff.

• On April 7, 2022, the inspectors presented the integrated inspection results to Thomas McCool, Vice President, and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed an Institute on Nuclear Power Operations report that was issued in the fourth quarter of 2021.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Procedures SOP-609B Diesel Generator System 18

71111.05 Procedures FPI-403 Auxiliary Building Elevation 810'-6" 5

71111.07A Corrective Action IR-2022-001140 Documenting thin black scale on CCP 2-01 and 2-02 lube oil

Documents cooler service water tubes

71111.07A Engineering EV-IR-2022-Past Operability for 2-02 CCP LO Cooler Gasket

Evaluations 000703-1

71111.07A Miscellaneous DBD-ME-233 Design Basis Document Station Service Water System

71111.07A Work Orders WO 5947040 Service Water Visual Inspection Form for CCP 2-01 Lube Oil 02/15/2022

Cooler

71111.11Q Miscellaneous LO47.B22.CLS Cycle 22-2 Cold Look 0

71111.13 Procedures STI-600.01 Protecting Plant Equipment and Sensitive Equipment 5

Controls

71111.15 Calculations MEB-240 Condensate Storage Tank Technical Specification Limit 4

71111.15 Calculations IC(B)097 Instrument Uncertainties and Indicator Loop Accuracy for 1

CST Level Instrumentation Loops 1-LI-2478A and 1-LI-

2479A

71111.15 Corrective Action CR-YYYY-NNNN 2017-10280, 2017-10346, 2017-10346, 2017-10346,

Documents 2021-008257, 2021-008257

71111.15 Drawings E1-0017 Common Turbine Control and Auxiliary BLDGs Normal 480v CP-44

MCC's One Line Drawing

71111.22 Procedures OPT-204A SI System 15

71114.04 Miscellaneous CP-202000209, Comanche Peak Nuclear Power Plant (CPNPP), Docket 05/21/2020

TXX-20020 Nos. 50-445 and 50- 446; License Amendment Request 20-

004 for Revision to the Emergency Plan - Changes to

Certain Emergency Action Levels

71114.04 Miscellaneous CP-202100113, Comanche Peak Nuclear Power Plant (CPNPP), Docket 02/24/2021

TXX-21058 Nos. 50-445 and 50- 446; Supplement to Request a Change

to the Implementation Date for License Amendment Request

20- 004 for Revision to the Emergency Plan - Changes to

Certain Emergency Action Levels

71114.04 Miscellaneous CP-202200020, Comanche Peak Nuclear Power Plant (CPNPP), Docket 01/13/2022

TXX-22005 Nos. 50-445, 50-446 and 72-74; Transmittal of Revised

Inspection Type Designation Description or Title Revision or

Procedure Date

Emergency Action Level (EAL) Classification Matrix and EAL

Bases Document

71114.04 Miscellaneous EPP-201, Tech Emergency Action Level Technical Bases Document 1, 2, 3

Bases

71114.04 Miscellaneous TR-2018-000626; Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 12/01/2021

TR-2021- 000145 Screening Evaluation Form, Correct Error on RCS Extended

Wide Range Device and RG1 References in Emergency

Action Levels (EAL) Technical Bases Document

71114.04 Miscellaneous TR-2019-002081, Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 12/10/2019

TR-2019- 006051 Screening Evaluation Form, Changes to the Comanche

Peak Nuclear Power Plant (CPNPP) Emergency Action

Levels (EALs)

71114.04 Miscellaneous TR-2019-002081, Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 12/10/2019

TR-2019- 006051 Effectiveness Evaluation Form, Changes to the Comanche

Peak Nuclear Power Plant (CPNPP) Emergency Action

Levels (EALs)

71114.04 Miscellaneous TR-2021-000145; Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 05/24/2021

TR-2021- 002480 Effectiveness Evaluation Form, Changes to the NRC

Emergency Telecommunications System

71114.04 Miscellaneous TR-2021-000145; Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 11/3/2021

TR-2021- 002938 Screening Evaluation Form, Adding Satellite Phones to List

of Communication Systems with Offsite and NRC

Organizations

71114.04 Miscellaneous TR-2021-000145; Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 11/3/2021

TR-2021- 002938 Effectiveness Evaluation Form, Adding Satellite Phones to

List of Communication Systems with Offsite and NRC

Organizations

71114.04 Miscellaneous TR-2021-002480; Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3) 05/24/2021

TR-2021- 000145 Screening Evaluation Form, Changes to the NRC

Emergency Telecommunications System

71114.04 Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 2

Emergency Plan Documentation

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.04 Procedures EPP-201 Assessment of Emergency Action Levels Emergency 13

Classification and Plan Activation

71153 Corrective Action CR-YYYY-NNNN 2020-7334,2021-3763

Documents

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