IR 05000445/2022003
| 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: |
|
| Download: ML22299A056 (30) | |
Text
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, 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:
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
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 Aspect Report Section Not Applicable Severity Level IV NOV 05000445/2022003-01 Open Not Applicable 71111.17T 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 Aspect Report Section Emergency Preparedness Green NCV 05000445,05000446/2022003-02 Open/Closed
[P.3] -
Resolution 71152A 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)
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)
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)===
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) April 1, 2021, through June 30, 2022 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2021, through June 30, 2022 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) April 1, 2021, through June 30, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) loss of internet in the main control room and the impact on Emergency Plan communication equipment
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated a Unit 1 trip and licensees response on September 5 and 6,
INSPECTION RESULTS
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 Aspect Report Section Not Applicable Severity Level IV NOV 05000445/2022003-01 Open Not Applicable 71111.17T The inspectors identified a Severity Level IV, notice of violation (NOV) of 10 CFR 50.59, "Changes, tests, and experiments," for the failure to restore compliance of previously identified non-cited violation (NCV)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 Comanche Peak Final Safety Analysis Report (FSAR) to change the facility's commitments to NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with General Design Criterion 5, without obtaining a license amendment.
Description:
The inspectors reviewed corrective actions associated with NCV 05000445/2019001-02. Through review of the associated condition reports (CR) 2019-001711 and CR-2019-004542, the inspectors identified that the licensee did not restore compliance with the requirements of 10 CFR 50.59, Change, tests, and experiments. Specifically, the licensee failed to correct the NCV when they closed corrective actions for the violation without obtaining a license amendment.
In January 2000, the licensee discovered electrical power panels that shared safety-related alternating current and direct current electrical power between Units 1 and 2, contrary to what was described in the Comanche Peak FSAR and NUREG-0797, Safety Evaluation Report related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, Docket Nos. 50-445 and 50-446, Supplement 22. The licensee took corrective action to modify the plant and revise the FSAR description of their original commitments to NRC RG 1.81, Shared Emergency and Shutdown Electric Systems for Multi-Unit Nuclear Power Plants.
RG 1.81 was used by the licensee to comply with General Design criterion 5, Sharing of structures, systems, and components.
In April 2002, the licensee issued 10 CFR 50.59 screening document 59SC-2000-000142-02-02 which changed the description of RG 1.81 commitments in the FSAR. The licensee was originally committed to positions C.1 and C.3 of RG 1.81, which describes that there was no sharing of emergency power sources between units. The 10 CFR 50.59 screening document changed the description of the licensees commitment to position C.2 of RG 1.81, which allowed sharing of emergency power sources given specific conditions. Specifically, position C.2 applied only to plants under construction permits issued before June 1, 1973, and the position was NRC reviewed on an individual case basis. The change was screened-out of the 10 CFR 10.59 process and no license amendment was submitted.
The inspectors determined that the licensee inappropriately applied position C.2 of RG 1.81 because the Comanche Peak construction permit was issued after June 1, 1973, and Comanche Peak was originally evaluated against position C.3 of RG 1.81. The inspectors determined these were changes to commitments that were used to meet General Design Criteria 5. Additionally, the unit specific loads on the common unit panels could result in new failure modes for previously evaluated accidents.
The inspectors reviewed 10 CFR 50.59 guidance as documented in NEI 96-07, revision 1, Guidelines for 10 CFR 50.59 Implementation, as endorsed by NRC RG 1.187, revision 3, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments." Based on this determination, the inspectors determined that the 10 CFR 50.59 screening document should have screened to a 10 CFR 50.59 evaluation. Further, the 10 CFR 50.59 safety evaluation would have determined that the licensee was required to submit a license amendment for the change because the change resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the final safety analysis report. Additionally, the change created a possibility for a malfunction of a structure, system, or component important to safety with a different result than any previously evaluated in the final safety analysis report.
Corrective Actions: The licensee entered the issue into the corrective action program. There are no operability concerns because the licensee corrected the technical aspects of the issue in previous corrective actions.
Corrective Action References: CR 2019-001711, CR-2019-003684, CR-2019-004542, CR-2019-006767, CR-2022-006915, CR-2022-006916
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency.
Enforcement:
The reactor oversight processes significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: The violation was determined to be Severity Level IV using Section 6.1.d.4 of the NRC Enforcement Policy, dated January 14, 2022. Specifically, it was a violation of 10 CFR 50.59 because the change required prior Commission review and approval, and the violation was determined to be associated with a minor performance deficiency.
Violation: Title 10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change would: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important-to-safety previously evaluated in the final safety analysis report (as updated); or, create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated).
Contrary to the above, from February 13, 2019, to September 30, 2022, the licensee failed obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the change that would: result in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important-to-safety previously evaluated in the final safety analysis report (as updated); or, create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated). Specifically, the licensee revised the Final Safety Analysis Report associated with the Unit 1 DC power system to change the facility's commitments to NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with General Design Criterion 5, without obtaining a license amendment.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period after the violation was identified consistent with section 2.3.2 of the Enforcement Policy.
Degraded Emergency Response Facility Communications Capabilities Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000445,05000446/2022003-02 Open/Closed
[P.3] -
Resolution 71152A 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.
Description:
On March 21, 2022, Comanche Peak experienced a loss of internet at the site.
This loss created degradation of communications in multiple emergency response facilities, especially the main control room. The main control room has multiple methods of communication available to communicate to various onsite, offsite, stakeholders, and the NRC as described in section 4.0 of the Emergency Plan. Since many of the methods rely on internet (e.g., voice over internet protocol (VOIP)) technology, the dependent communication methods that relied upon internet were rendered non-functional. Table 4.1 in the Emergency Plan illustrates the communication interfaces from Comanche Peak's facilities to the other onsite/offsite facilities and response organizations with the different communication methods available. The inspectors discussed available communications methods with licensee staff and were informed that no communications methods were available in the control room without breaching the control room envelope.
The unplanned loss of internet on March 21, 2022, lasted approximately one hour. The inspectors noted that from March 10 through April 18, 2022, there were a total of five instances of the loss of all internets at the site ranging from one hour to seventeen hours; however, aside from the March 21, 2022, instance, some form of emergency communications was available from within the control room. Furthermore, the inspectors noted there were multiple loss of internet occurrences in 2021. However, the loss of internet occurrence on March 21, 2022, was the most significant due to the contributing factors affecting the other methods of communication concurrent with that loss. Specifically, the following methods were affected; all commercial telephones due to their reliance on VOIP, the emergency notification number due to its reliance on VOIP, the black start satellite phone (which is antenna wired capable for control room use) due to inadequate instructions, VESTA online notification program (notifies state/local authorities) due to its reliance on internet, and the land line telephone system (copper based redundant telephone lines) due to degraded connection and static. The individuals in the control room were left with no methods to make phone calls from the control room envelope; however, the black start satellite phone could receive calls.
On March 21, 2022, Comanche Peak did have handheld satellite phones available; however, for those phones to function, the antenna needed to be deployed outside of the control room envelope. Although there is a door to the turbine building roof from the main control room, the door forms part of the control room envelope and routing through the door violates the control room envelope. While cell phones can normally be used via Wi-Fi, the internet loss precluded main control room use of cell phones on March 21, 2022. The inspectors assessed this situation to see if a viable compensatory method of communications among principal response organizations was provided for in the event of a radiological emergency. To ensure assumptions about the maximum radiological dose to control room emergency workers were provided for their protection, the ventilation envelope could not be breached to set up the antenna. Therefore, there was no viable compensatory measure in place..
Comanche Peak updated the dedicated copper lines federal telephone system to VOIP emergency notification system using RIS 2000-11 in the spring 2021 due to reliability concerns of the copper circuitry. The inspectors noted that the licensee's modification to VOIP protocols failed to account for the introduction of single point vulnerabilities.
Specifically, the connection to the sites internal network by the internet service provider included only one line. Internet outages created by damage or degradation of a single line occur on occasion; therefore, they are reasonably within the licensee's ability to foresee. In addition, numerous losses occurred in 2021 providing the licensee with sufficient information to recognize the vulnerability and take interim actions to ensure communications capability until redundancy in the internet connection could be implemented. The inspectors note that there was overall improvement in line clarity with the upgrade to emergency notification system, but the station remained vulnerable to communications degradation due to the known single point vulnerability.
The inspectors previously reviewed emergency preparedness communication issues in 2021.
No more than minor performance deficiencies were identified during that review. This inspection was documented in the 71152 Inspection in the 2021004 (ADAMS Accession No.
ML22019A304 https://www.nrc.gov/docs/ML2201/ML22019A304.pdf).
Corrective Actions: For completed corrective actions, Comanche Peak has updated the black start satellite telephone dialing protocol procedure and added a second internet line with a diverse method (microwave vs. local area network). Planned corrective action included adding a third internet line with a diverse switch which eliminates an existing single point vulnerability in the currently installed internet lines. Additional actions are I documented in CR-2022-1892.
Corrective Action References: Comanche Peak entered the loss of internet events into the corrective action program under CR-2021-7895, tracking report (TR) 2022-1822, TR-2022-1892, TR-2022-1886, CR-2021-3239, TR-2021-7938, CR-2021-6637, TR-2021-5058, CR-2021-5014, TR 2021-1209, TR-2022-1688, TR-2021-5017, CR-2022-1894, TR-2022-1823, TR-2022-1848, CR-2021-2796, TR-2021-7588.
Performance Assessment:
Performance Deficiency: The failure to ensure reliable emergency communication methods were available from the control room was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee can implement adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, on March 21, 2022, the unplanned loss of internet impacted emergency communication methods to offsite response organizations, which effects public health and safety in the event of a radiological emergency.
Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609, Significance Determination Process, attachment 4 (effective date December 13, 2019), and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, table 5.6-1. The performance deficiency was determined have very low safety significance (Green) because it was a failure to comply with NRC requirements, was a degraded planning standard function, and the deficiency lasted less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of discovery and there were no compensatory measures implemented.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Comanche Peak modified the site's telecommunication infrastructure with the intent to improve the reliability of control room communication by transitioning from degraded copper circuitry to VOIP technology. However, the site experienced multiple outages the year following the modification but failed to implement timely corrective actions prior to more significant communications equipment outages.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(6) requires, in part, that provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
Contrary to the above, on March 21, 2022, the licensee failed follow and maintain the effectiveness of an emergency plan which meets the requirements of appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Specifically, the license failed to meet the planning standard in 10 CFR 50.47(b)(6) due to a loss of internet event and degraded backups resulting in no communication methods available from within the main control room to offsite response organizations.
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 July 28, 2022, the inspectors presented the triennial heat exchanger and heat sink performance inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On August 25, 2022, the inspectors presented the emergency plan exercise inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On September 22, 2022, the inspectors presented the evaluations of changes, tests, and experiments inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On October 6, 2022, the inspectors presented the integrated inspection results to Mr. A. Marzloff, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
SOP-204B
Containment Spray System
Procedures
SOP-809A
Diesel Generator Ventilation System
Procedures
SOP-904
Fire Protection Main Water Supply and Fire Pumps System
Procedures
SOP-908B
Diesel Generator System
Fire Plans
FPI-104A
Unit 1 Train A Diesel Generator and Equipment Elevation
810 and Fuel Oil Day Tank Room Elevation 844
Fire Plans
FPI-105A
Unit 1 Train B Diesel Generator and Equipment Elevation
810 and Fuel Oil Day Tank Room Elevation 844
Fire Plans
FPI-401
Auxiliary Building Elevation 790'-6"
Fire Plans
FPI-403
Auxiliary Building Elevation 810'-6"
Miscellaneous
Drill No 22-12-03
Fire Drill Scenario: Train A Centrifugal Charging Pump
09/02/2022
Calculations
2-NU-0059
Unit 2 Safeguards Building Flooding Analysis
Corrective Action
Documents
TR-YYYY-NNNN
TR-2022-000683
Corrective Action
Documents
CR-YYYY-NNNN
2015-000079
Calculations
1-EB-302-04
Auxiliary Feedwater Pump Rooms - Unit 1
Calculations
1-EB-302-05
RHR Pump Rooms Unit 1
Calculations
1-EB-303-01
Centrifugal Charging Pump Rooms -Unit 1
Calculations
1-EB-311-01
ESF Local Cooler Areas Summary Spare Heat Gains and
Maximum Temperatures (LOCA with LOOP)
Calculations
1-EB-311-08
Safety Chilled Water Pump Evaluation
Calculations
1-EB-311-12
Evaluation of Safety Chiller Capacities at Reduced CCW
Flow Rates - Unit 1
Calculations
1-EB-311-3
ESF Local Cooler Areas Summary - Space Heat Gains and
Maximum Temperatures (LOCA w/OPA) - Unit 1
Calculations
16345-ME(B)-088
Station Service Water System Steady State Hydraulic
Calculations
Calculations
16345-ME(B)-183
SSI Heat Loads
Calculations
X-SC-04-04
SSW Travelling Screen 02 Differential Pressure X-L-4289A
Corrective Action
Documents
CR-YYYY-NNNN
2019-007485, 2020-004666, 2020-004864, 2020-006675,
20-009296, 2021-002257, 2021-002716, 2021-005490,
22-002640, 2022-003351, 2022-004955
Corrective Action
Documents
TR-YYYY-NNNN
21-005163
Corrective Action
Documents
Resulting from
Inspection
Issue Report (IR)
22-005606, 2022-005664
Drawings
M1-0229
Flow Diagram Component Cooling Water System
Drawings
M1-0311
Flow Diagram Ventilation Safety Chilled Water System
Miscellaneous
Open Cooling Water Plant Specific Guidelines
Miscellaneous
CCP 1-02 Lube
Oil Cooler
Unit 1 Service Water Visual Inspection Form
03/03/2021
Miscellaneous
CCP 1-02 Lube
Oil Cooler
Unit 1 Service Water Visual Inspection Form
03/26/2019
Miscellaneous
Centrifugal Charging Pumps and Motors
Miscellaneous
Air Handling Units
Miscellaneous
CPNPP System
Status
Safety Chilled Water
2nd Quarter,
22
Miscellaneous
DBD-CS-096
Safe Shutdown Impoundment/Dam
Miscellaneous
DBD-ME-229
Comanche Peak Nuclear Power Plant Units 1 and 2, Design
Basis Document, Component Cooling Water System
Miscellaneous
DBD-ME-233
Comanche Peak Nuclear Power Plant Units 1 and 2 Design
Basis Document, Station Service Water System
Miscellaneous
DBD-ME-311
Comanche Peak Nuclear Power Plant Units 1 and 2, Design
Basis Document, Safety Chilled Water System
Miscellaneous
NALCO Water
Letter
Quarterly Closed Loop Analysis - 2022 Q1
06/15/2022
Procedures
ABN-501
Station Service Water Malfunction
Procedures
ABN-907
Acts of Nature
Procedures
COP-501
Chemistry Operating Procedures, Station Service Water
Procedures
COP-502A
Unit 1 Chemistry Operating Procedures Manual, Component
Cooling Water
Procedures
COP-814
Unit 1 Chemistry Operating Procedure Manual, Ventilation
Chilled Water
Procedures
COP-815A
Unit 1 Chemistry Operating Procedures Manual, Safety
Chilled Water
Procedures
MSE-G0-4003
Motor Insulation Resistance Testing
Procedures
OPT-201A
Charging System
Procedures
OPT-207A
Service Water System
Procedures
OPT-209A
Surveillance Test, Safety Chilled Water System
Procedures
OPT-209B
Surveillance Test, Safety Chilled Water System
Procedures
PPT-SX-7517
Safe Shutdown Impoundment Inspection
Procedures
STA-734
Service Water System Fouling Monitoring Program
Procedures
TDM-901A
Systems Data, Throttled Valves/Flow Rates
Procedures
TSP-509
Predictive Maintenance Thermographic Analysis Program
Work Orders
Work Orders
(WO)
3667839, 3868301, 3953450, 3975749, 4260995, 4434930,
4765986, 4813602, 4941796, 5135252, 5282413, 5326811,
5370719, 5436260, 5532319, 5535113, 5671623, 5685144,
5695618, 5779054, 5794744, 5813178, 5814385, 5823278,
24058, 5926668, 5927760, 5928617, 5951210, 5955001,
5958222, 5968810, 5972626, 5974285, 5980342, 6006826,
20235, 6024697, 21-776632, 21-940915, 21-941868, 22-
103231, 22-14288, 22-183905, 22-70886, 22-79326
Corrective Action
Documents
CR-YYYY-NNNN
2019-7903, 2022-1492
Miscellaneous
System Health Report AC Distribution 6.9KV Switchgear
4th quarter
21
Miscellaneous
Maintenance Rule
Database for Unit
Program Reports
Miscellaneous
System Health
Report for Unit 2
Corrective Action
Documents
TR-YYYY-NNNN
22-004908
Miscellaneous
SORC 22-010
Unit 1 Forced Outage Start up Meeting Package
09/11/2022
Calculations
ME-CA-0229-
CCW Parameters for Fouling Monitoring
29
Corrective Action
Documents
CR-YYYY-NNNN
2019-001271, 2019-001317, 2019-001428, 2019-001430,
2019-001711, 2019-004542, 2019-003684, 2019-006767,
22-005805
Corrective Action
Documents
TR-YYYY-NNNN
2019-001133, 2019-009096, 2020-005137, 2020-007888,
21-002308, 2021-003710, 2022-000031, 2022-004593
Corrective Action
Documents
Resulting from
Inspection
Issue Report (IR-)
22-006839, 2022-006874, 2022-006886, 2022-006890,
22-006915, 2022-006916
Drawings
554
Starting Air Receivers Delaval Part No. 76001-125
Drawings
M1-0215
Flow Diagram Starting Air Piping CP1-MEDGEE-01
Engineering
Changes
FDA-2017-
000092-01
Replace the Unit 1 and Unit 2 Emergency Diesel Generator
Starting Air Compressors
Miscellaneous
DBD-ME-006
Control of Heavy Loads at Nuclear Plants
Miscellaneous
DBD-ME-011
Diesel Generator Sets
Miscellaneous
DBD-ME-303-01
Fuel Building Ventilation System
Procedures
CPNPP 50.59 Resource Manual
Procedures
ABN-712
Rod Control System Malfunction
Procedures
INC-3027
Control Rod Drop Timing
Procedures
IPO-010B
Reactor Coolant System Reduced Inventory Operations
Procedures
MDA-304
Control of Heavy Loads and Critical Lifts
Procedures
MSG-2013
Polar Crane/Telescoping Jib Crane Operating Instructions
and Restrictions
Procedures
NUC-114
Core Performance Engineering Periodic Duties
Procedures
NUC-206
Control Rod Drop Timing
Procedures
SOP-608A
20, 208, 208/120, and 120/240 VAC Distribution System
Procedures
SOP-608B
20, 208, 208/210, and 120/240 VAC Distribution System
Procedures
STA-707
10CFR50.59 and 10CFR72.48 Reviews
Procedures
STI-707.01
10CFR50.59 Screens
Procedures
STI-707.04
10CFR50.59 and 10CFR72.48 Reviews Applicability
Determinations
Corrective Action
Documents
TR-YYYY-NNNN
2018-3643, 2022-1952, 2022-1407
Procedures
SAG-1.0
Control Room Severe Accident Initial Response
Procedures
SAG-9.0
Technical Severe Accident Response Mitigate Fission
Product Release
Procedures
STI-203.02
Preparation of Sever Accident Management Guidance
Procedures
STI-203.02
Preparation of Severe Accident Management Guidance
Corrective Action
Documents
TR-YYYY-NNNN
22-4908
Procedures
IPO-002A
Plant Startup from Hot Standby
Corrective Action
Documents
CR-YYYY-NNNN
TR-YYYY-NNNN
CR-2017-009505, CR-2019-008751, CR-2019-008766,
CR-2019-008787, CR-2019-008798, CR-2019-008800,
CR-2020-001364, CR-2020-001368, CR-2020-002313,
CR-2020-004960, CR-2020-006058, CR-2020-006768,
CR-2020-007289, CR-2021-008503, CR-2021-008514,
CR-2022-000174, CR-2022-001649, CR-2022-004837,
CR-2022-005181, CR-2022-005234, CR-2022-006005,
CR-2022-006006, CR-2022-006007, CR-2022-006008,
CR-2022-006052, CR-2022-006061, CR-2022-006063,
CR-2022-006064, TR-2017-009355, TR-2017-009418,
TR-2017-009419, TR-2017-009430, TR-2017-009436,
TR-2017-009487, TR-2017-009491, TR-2017-009492,
TR-2017-009506, TR-2017-009508, TR-2017-009509,
TR-2017-009511, TR-2019-008671, TR-2019-008770,
TR-2019-008799, TR-2021-008177, TR-2022-005307,
TR-2022-0060062
Corrective Action
Documents
Resulting from
Inspection
Issue Reports
IR-2022-006242
Miscellaneous
Management Challenge Presentation: 07/27/2022 Green
Team Exercise Summary
08/15/2022
Miscellaneous
Control Room Simulator Exercise Participant Logs
07/27/2022
Miscellaneous
Exercise Report, Red Team November 06, 2019
07/12/2022
Miscellaneous
Exercise Report, Gold Team, August 16,2017
10/15/2017
Miscellaneous
Green Team, Exercise Report, June 24, 2020
07/12/2022
Miscellaneous
Technical Support Center Exercise Participant Logs
07/27/2022
Miscellaneous
Technical Support Center Focused Drill Participant Logs
07/26/2022
Miscellaneous
Operations Support Center Exercise Participant Logs
07/27/2022
Miscellaneous
Operations Support Center Focused Drill Participant Logs
07/26/2022
Miscellaneous
Emergency Operations Facility Exercise Participant Logs
07/27/2022
Miscellaneous
Joint Information Center Exercise Participant Logs
07/27/2022
Miscellaneous
Miscellaneous
Management Challenge Presentation: 7/26/2022 Green
Team Exercise Summary (Focused Area Drill TSC and OSC
Only)
08/15/2022
Procedures
ABN-907
Acts of Nature
Procedures
ABN-909
Spent Fuel Pool/Refueling Cavity Malfunction
Procedures
BSI-3.0
Spent Fuel Cooling Safety Function Restoration
Procedures
EPP-116
Emergency Repair & Damage Control and Immediate Entries
Procedures
EPP-201
Assessment of Emergency Action Levels Emergency
Classification and Plan Activation
Procedures
EPP-201
Technical Bases
Emergency Action Level Technical Bases Document
Procedures
EPP-203
Notifications
Procedures
EPP-205
Activation and Operation of the Operations Support
Center (OSC)
Procedures
EPP-206
Activation and Operation of the Emergency Operations
Facility (EOF)
Procedures
EPP-303
Operation of Computer Based, Emergency Dose
Assessment System
Procedures
EPP-304
Protective Action Recommendations
Procedures
EPP-309
Onsite/In-Plant Radiological Surveys and Offsite Radiological
Monitoring
Procedures
FRH-0.1A
Response to Loss of Secondary Heat Sink
Procedures
SAG-1.0
Control Room Severe Accident Initial Response
Procedures
SAG-10.0
TSC Severe Accident response Control SFP Level
Procedures
SOP-506
Spent Fuel Pool Cooling and Cleanup System
Miscellaneous
CPNPP 10 CFR 50.54(q)(3) Screening Evaluation Form for
ANS Design Report Change
03/11/2021
Miscellaneous
CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness
Evaluation Forms for OSSA Change
06/23/2021
Procedures
CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness
Evaluation Form for Emergency Plan Revision 45
05/24/2021
Procedures
Procedures
Procedures
EPP-123
CFR 50.54(q) Screening and Evaluation of Changes to
Emergency Plan Documentation
71151
Miscellaneous
NucIQ data on reactor coolant system for Units 1 and 2 for
June, 2022
71151
Miscellaneous
Control room log leak rate readings July 1, 2021, through
June 30, 2022.
71151
Miscellaneous
MSPI Margin Reports
PRA Living Model Report
71151
Miscellaneous
ANS Test Report Data 2021Q2-2022Q2
71151
Miscellaneous
Quarterly Key ERO Member Drill Participation
Trackers 2021Q2-2022Q2
71151
Miscellaneous
71151
Procedures
SG-012
Alert and Notification System Surveillance
71151
Procedures
SG-020
NRC Performance Indicators
71151
Procedures
STA-662
Administrative Control of the Siren System
Procedures
STI-433.02
Emergency Response Facility Functionality Evaluation
2