Text

Integrated Inspection Report 05000445/2022003 and 05000446/2022003 and Notice of Violation
	ML22299A056
Person / Time
Site:	Comanche Peak
Issue date:	11/01/2022
From:	Greg Werner; NRC/RGN-IV/DORS/PBB
To:	Peters K; Vistra Operations Company
	Werner G
References
	IR 2022003
Preceding documents:	ML22346A086 (13 December 2022);
	Download: ML22299A056 (30)
	v • d • e

November 1, 2022

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 INTEGRATED INSPECTION REPORT 05000445/2022003 AND 05000446/2022003 AND NOTICE OF VIOLATION

Dear Mr. Peters:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 6, 2022, the NRC inspectors discussed the results of this inspection with Mr. A. Marzloff, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The enclosed report discusses a Severity Level IV violation. The NRC evaluated this violation in accordance with section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report (Enclosure 2). We determined that this violation did not meet the criteria to be treated as a non-cited violation (NCV) because your staff failed to restore compliance within a reasonable period after the violation was identified consistent with section 2.3.2 of the NRC Enforcement Policy. You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.

The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.

Additionally, 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 an NCV 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.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter, its enclosures, and your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

Sincerely, Signed by Werner, Gregory on 11/01/22 Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000445, 05000446 License Nos. NPF-87, NPF-89

Enclosures:

1. Notice of Violation 2. Inspection Report 05000445/2022003 and 05000446/2022003

Inspection Report

Docket Numbers: 05000445 and 05000446 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2022003 and 05000446/2022003 Enterprise Identifier: I-2022-003-0003 Licensee: Vistra Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, TX 76043 Inspection Dates: June 1 to September 30, 2022 Inspectors: R. Alexander, Regional State Liaison Officer J. Braisted, Senior Reactor Inspector D. Bryen, Reactor Inspector N. Day, Resident Inspector J. Ellegood, Senior Resident Inspector G. George, Senior Reactor Inspector R. Kopriva, Senior Reactor Inspector D. Reinert, Reactor Inspector H. Strittmatter, Emergency Preparedness Inspector Approved By: Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Enclosure 2

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 Restore Compliance for Non-Cited Violation 05000445/2019001-02 "Failure to Evaluate a Change to the Facility DC Power System" Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.17T NOV 05000445/2022003-01 Open The inspectors identified a Severity Level IV, notice of violation of 10 CFR 50.59, "Changes, tests, and experiments," for the failure to restore compliance of previously identified non-cited violation 05000445/2019001-02. The previous violation identified the licensee's failure to obtain a license amendment or perform a written evaluation demonstrating the basis for not obtaining a license amendment prior to making a change to the facility as described in the Final Safety Analysis Report. Specifically, the licensee revised the Final Safety Analysis Report to change the facility's commitments to NRC Regulatory Guide 1.81, which demonstrated compliance with General Design Criterion 5, without obtaining a license amendment.

Degraded Emergency Response Facility Communications Capabilities Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [P.3] - 71152A Preparedness NCV 05000445,05000446/2022003-02 Resolution Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.47(b)(6) when the licensee failed to ensure prompt communications among principal response organizations were available from the main control room. Specifically, on March 21, 2022, due to a loss of internet and degraded backup communication methods, there were no communication methods available from within the main control room to contact offsite response organizations.

Additional Tracking Items

None.

PLANT STATUS

On September 5, Unit 1 tripped due to a trip of the main turbine from 100 percent power. The licensee corrected the issue causing the trip and restarted Unit 1 on September 12, 2022. Unit 1 returned to 100 percent on September 15, 2022.

Unit 2 remained at or near rated thermal power for the entire assessment 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 performed activities described in IMC 2515, Appendix D, Plant Status, 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

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) High winds and drought conditions contributed to wildfires that came within three miles of the plant on July 19, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 1, diesel generators diesel and exhaust systems on July 20, 2022

(2) fire pumps on July 22, 2022

(3) independent spent fuel storage installation on July 30, 2022

(4) Unit 2, train A diesel generator starting air system on September 1, 2022

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 containment spray A system on August 4, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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, trains A and B component cooling water pumps on August 8, 2022

(2) Units 1 and 2, component cooling water heat exchanger room on August 8, 2022

(3) Unit 1, emergency diesel generator 1-01 room and fuel oil day tank 1-01 room on September 26, 2022

(4) Unit 1, emergency diesel generator 1-02 room and fuel oil day tank 1-02 room on September 26, 2022

(5) Unit 1, charging pump rooms on September 29, 2022

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

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on September 2, 2022.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 2, feedwater enclosures

(2) 25KV power cable vaults supplying independent spent fuel storage installation power

71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)

Main article: IP 71111.07

The inspectors evaluated heat exchanger performance on the following:

(1) component cooling water pump lube oil cooler 1-02

Heat Exchanger (Closed Loop) (IP Section 03.03) (2 Samples)

The inspectors evaluated heat exchanger performance on the following:

(1) motor driven auxiliary feedwater pump room fan cooler 1-07

(2) residual heat removal pump room fan cooler 2-01

Ultimate Heat Sink (IP Section 03.04) (1 Sample)

The inspectors evaluated the ultimate heat sink performance on the following:

(1) ultimate heat sink and service water system

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 plant cooldown to 205 degrees Fahrenheit on September 7, 2022.

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

(1) The inspectors observed and evaluated a simulated control room fire and plant shutdown on August 9, 2022.

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) Units 1 and 2, 6.9 kilovolt distribution system.

(2) Unit 2, turbine control system.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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 1, risk controls associated with feedwater heater outlet pressure transmitter 0508 card replacement on July 17, 2022

(2) Unit 1, operator actions to maintain availability of the turbine driven auxiliary feedwater pump 1-01 on August 4, 2022

(3) Unit 1, flooding, and operator response due to circulating water lube water pumps 1-01 and 1-02 flooding on August 9, 2022

(4) Unit 1, forced outage risk for the week of September 5, 2022

(5) Unit 1, startup risk on September 11 and 12, 2022

(6) Unit 1, risk during emergent motor driven feedwater pump 1-01 recirculation line leak on September 15, 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) Unit 2, pressurizer heaters per condition report 2022-5808

(2) Unit 1, pressurizer master controller 1-PK-455A per condition report 2022-005681

(3) Unit 1, turbine driven and motor driven feedwater pump 1-02 per condition report 22-006748

(4) Unit 1, emergency diesel generator 1-02 starting air receiver 1-03 leaking by valve 1DO-0041 per condition reports 21-008182 and 22-006804

(5) Unit 2, tornado door per tracking report 2022-006923.

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

Main article: IP 71111.17

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from [enter dates].

(1) EV-CR-2019-000901-2, Replace Units 1 and 2 Diesel Generator Starting Air Compressors

(2) EV-CR-2022-005805-8, Comp Action to Intermittently Isolate 1-HV-4393, Diesel Generator, Service Water Outlet Flow Valve

(3) EV-IR-2021-003710-1, Shift Manager Clearance SMP21-0016 STA-707 Review

(4) EV-TR-2019-001133-5, FDA-2019-000036-01 / TM 5735389

(5) EV-TR-2019-009096-1, Maintenance Clearance TR-2019-009096 Spent Fuel Pool X-02 Ventilation Exhaust Fan X-35 Motor

(6) EV-TR-2020-005137-11, Containment Building Polar Crane Use During Modes 3 Through 4

(7) EV-TR-2020-007888-3, Lubrication Recommendation Change to the Station Service Water Pump Motor 1-02 Lower Bearing Grease

(8) EV-TR-2021-002308-9, Plugging up to 65 Tubes in the Unit 1 & Unit 2 CCW HXs (CP1/2-CCAHHX-01/-02)

(9) EV-TR-2021-003204-1, Maintenance Clearance Greater Than 90 Days on CPX-WTPMWP-01 Water Treatment Waste Sump X-01

(10) EV-IR-2021-003254-1, Comp Action Evaluation for Monitoring RCP 1-03 Vibration

(11) EV-TR-2019-000777-6, VDRT 5775695, Westinghouse Calculation CN-PCSA-14-5, Revision 2

(12) EV-CR-2019-003377-8, Change Control Room A/C Units (CRAC) Compressor Suction Pressure Pumpdown Setpoint to greater than or equal to 45 psig

(13) EV-TR-2020-003698-5, Shift Manager Clearance Placed to Isolate 2-HV-4166 Leaking By

(14) EV-TR-2021-000607-1, Maintenance Clearance CP20-1066 Unit 2 Train A UPS Room Fan Coil Unit CP2-VAAUPR-01

(15) EV-TR-2019-06006-15, Application of WCAP-17627, Revision 1, to Unit 2 Reload Analyses, beginning with Unit 2 Cycle 19 and Subsequent Unit 1 and Unit 2 Reload Analyses (50.59 Safety Evaluation)

(16) EV-TR-2019-007450-4, Procedure Revision - Response to a Fire in the Control Room or Cable Spreading Room

(17) EV-CR-2020-009014-1, Unit 1 Turbine Shaft Displacement Channel 1 Defective Components

(18) EV-CR-2019-004542-5, Perform STA-707

(19) EV-CR-2020-005070-11, Compensatory Action: Manually Purging of Safety Chiller

(20) EV-CR-2021-002241-3, XEB4-2/1SS Motor Control Center Transfer Switch Maintained in Off Position

(21) EV-CR-2020-002810-9, Unit 2 Train B Core Exit Thermocouple Alternate Temperature Monitoring

(22) EV-TR-2020-002067-7, Manual Control Rod Drop Timing

(23) EV-TR-2019-008867-1, Degraded RCP Seal Standpipe Level Control Valve on Reactor Coolant Pumps 2-01 and 2-03

(24) EV-CR-2018-004605-4, Component Cooling Water Pump Shaft Bearing Diameter and Tolerance Changes

(25) 59SC-2017-000182-01, Increase Time Delay for Reactor Coolant Pump Vibration Alarm

(26) 59SC-2019-000025-01, Replace Alternate Power Diesel Generators

(27) 59SC-2019-000051-01, Motor Operated Valve Limit Switch Setting Modifications

71111.18 - Plant Modifications

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were updated in accordance with the pressurized water reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) Unit 1, pressure transmitter 0508 feedwater heater outlet header pressure transmitter following card replacement per work order 22-345906

(2) Unit 1, repairs to turbine shaft displacement probes between per work order 22-448268

(3) Unit 1, pressurizer heater control 1-PK-455A per work order 22-381599

(4) Unit 2, pressurizer heater control 2-PK-455A per work order 22-394264

(5) Unit 1, motor driven auxiliary feedwater pump 1-01 recirculation line leak repair per work order 22-457619

(6) Unit 1, main feedwater pump 1B following servo replacement per work orders 22-456325 and 22-456467

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated a forced outage between September 6 and 12, 2022 caused by a unit trip. The unit trip resulted from a turbine trip caused by a spurious shaft displacement indication.

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) (4 Samples)

(1) Unit 2, pressurizer heater per procedure IPO-001B on December 1, 2021

(2) Unit 1, pressurizer heaters per procedure IPO-001A on May 8, 2022

(3) Unit 2, condensate storage tank inspection on August 23, 2022

(4) Unit 1, scram breaker testing on September 12, 2022.

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Sample)

(1) The inspectors evaluated the biennial emergency plan exercise conducted on July 26 and 27, 2022. The exercise scenario simulated a greater than Operating Basis Earthquake seismic event resulting in several simulated in-plant failures requiring the rapid escalation to a Site Area Emergency declaration due the loss of all cooling water flow to the secondary heat sink. Though the scenario did not include a radiological release requiring issuance of protective action recommendations to the offsite authorities, it did include opportunities for the licensee emergency response organization to mitigate and repair additional simulated failures in electrical switchgear and respond to a simulated medical emergency. The licensee's exercise activities during the week also included a separate emergency scenario which required the licensee demonstrate of one of the station's extensive damage mitigation guideline strategies, per the requirements of 10 CFR 50.155(b)(2), in mitigating the loss of the spent fuel pool water inventory.

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.

ANS (Alert and Notification System) Design Report, revision 2, change 1 -effective March 11, 2021

On-Shift Staffing Analysis, revision 1 - effective June 24, 2021

Emergency Plan, revision 45 - effective June 15, 2022.

This evaluation does not constitute NRC approval.

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

(1) Unit 1 (July 1, 2021, through June 30, 2022)