IR 05000445/2022004
| ML23025A098 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/26/2023 |
| From: | Greg Werner NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| Werner G | |
| References | |
| IR 2022004 | |
| Download: ML23025A098 (33) | |
Text
January 26, 2023
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000445/2022004 AND 05000446/2022004
Dear Ken Peters:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 18, 2023, 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 Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Gregory E. Werner, Chief Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000445, 05000446 License Nos. NPF-87, NPF-89
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000445 and 05000446
License Numbers:
Report Numbers:
05000445/2022004 and 05000446/2022004
Enterprise Identifier:
I-2022-004-0003
Licensee:
Vistra Operations Company, LLC
Facility:
Comanche Peak Nuclear Power Plant, Units 1 and 2
Location:
Glen Rose, Texas 76043
Inspection Dates:
October 1, 2022, to December 31, 2022
Inspectors:
D. Antonangeli, Health Physicist
B. Baca, Health Physicist
B. Bergeon, Senior Operations Engineer
N. Day, Resident Inspector
J. Ellegood, Senior Resident Inspector
N. Greene, Senior Health Physicist
S. Hedger, Senior Emergency Preparedness Inspector
G. Kolcum, Senior Resident Inspector
J. Melfi, Project Engineer
C. Osterholtz, Senior Operations Engineer
D. Proulx, Senior Project Engineer
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 Periodically Calibrate Radiation Monitors within their Frequency as Required by 10 CFR 20.1501(c)
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000445,05000446/2022004-01 Open/Closed
[H.5] - Work Management 71124.05 The inspectors identified a Green non-cited violation of 10 CFR 20.1501(c) for a failure to periodically calibrate radiation monitoring equipment used to perform quantitative radiation measurements within their required frequency. This monitoring equipment included effluent, process, area, and emergency protection related radiation monitors. The inspectors identified that required calibrations for 11 radiation monitors exceeded the specified frequency and the grace period.
Additional Tracking Items
Type Issue Number Title Report Section Status NOV 05000445,05000446/20 21011-05 Failure to Restore Compliance for Inadequate Voltage Calculations for the 120 VAC Buses 71111.21M Closed NOV 05000445,05000446/20 21011-06 Failure to Restore Compliance and Evaluate Inverter Fault Interrupting Capability During Design Basis Loss of Offsite Power and Seismic Conditions 71111.21M Closed
PLANT STATUS
Unit 1 operated at or near 100 percent power for the entire inspection period.
Unit 2 started the inspection period operating at 100 percent power. On October 19, 2022, Unit 2 was down powered to 90 percent power for main condenser maintenance. On October 22, 2022, Unit 2 returned to 100 percent power and operated at or near 100 percent power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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
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 seasonal cold temperatures for the following systems:
Unit 1, refueling water storage tank, fire water storage tanks and pump house, and exterior main feedwater piping on November 28, 2022.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on October 27, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)circulating water south pit dewatering pumps on November 15, 2022.
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Units 1 and 2 uninterruptible power supply systems on October 25, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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)electrical and control building elevation 840 on October 21, 2022 (2)circulating water intake structure on November 4, 2022 (3)service water intake structure on December 5, 2022 (4)flex building on December 13, 2022
- (5) Unit 1, control room air conditioning room on December 19, 2022
- (6) Unit 2, control room air conditioning room on December 19, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered from September 19 to October 28, 2022.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered from September 19, to October 28, 2022.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
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 a planned Unit 2 down power to remove circulating water pump 2-01 from service prior to isolating water box 2-A-4 for maintenance on October 19, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator annual examination simulator scenarios on October 18, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2, service water valve failure on October 23, 2022
- (2) Unit 1, reactor coolant system on November 29, 2022
- (3) Unit 2, reactor coolant system on November 29, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)safety chillers per strainer commercial grade dedication evaluation NEM11192018 and safety related applications requiring grease item ID 338097 per commercial grade dedication evaluation SAR 36001
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 2, circulating water realignment for condenser water box 2-A-4 isolation on October 20, 2022
- (2) Unit 1, turbine driven auxiliary water pump availability during quarterly testing on October 27, 2022 (3)circulating water intake water intrusion with temporary pumps and heavy rain with ODMI 2021-7593-9 on October 28, 2022.
- (4) Unit 2, repair of circulating water leak on November 12, 2022
- (5) Unit 1, primary water system leakage water return pump B replacement and trip risk on November 29, 2022 (6)tornado warning and emergent yellow risk on December 13, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)degraded fire barrier in the service water intake structure described in CR-2022-7333
- (2) Unit 1, turbine displacement per condition described in CR 2022-007076.
- (3) Unit 1, pressurizer control system per condition described in CR 2022-007329
- (4) Unit 2, circulating pumps from per condition described in CR 2022-007895
- (5) Unit 2, fuel oil transfer system with pump 2-03 not starting per CR-2022-008097
- (6) Unit 2 battery CP2-EPBTED-02 cell 53 cracked seal described in CR-2022-8479
- (7) Unit 1, degraded auxiliary feedwater pump flow indicator 1-FI-2465C per condition described in CR-2022-008473 (8)functionality of various heat trace systems per CR 2022-8668
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 1, modification of turbine thrust wear detector for failed probes on November 30, 2022
- (2) Units 1 and 2, leading edge flow meter system replacement on December 9, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
(1)emergency diesel generator 2-01 snoop leakage test and reset of the air start system following monthly test on October 26, 2022 (2)residual heat removal 2-01 quarterly surveillance following pump and breaker maintenance on October 27, 2022 (3)centrifugal charging pump 1-02 return to service test following motor maintenance on November 1, 2022 (4)emergency diesel generator 1-02 fuel oil booster pump 1-02 discharge relief valve replacement and return to service test on November 2, 2022 (5)emergency diesel generator 2-02 pre-lube oil pump 2-02 discharge relief valve replacement and return to service test on November 9, 2022 (6)circulating water discharge south vault pit manhole penetration clamp installation on November 12, 2022 (7)safety injection pump 1-01 quarterly surveillance following online motor analysis on November 22, 2022.
- (8) Unit 1, generator primary water system leakage pump B replacement return to service and vibration testing on November 29, 2022 (9)emergency diesel generator 2-01 return to service test following lube oil heater replacement on December 16, 2022
===71111.21M - Design Bases Assurance (DBA) Inspection The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)
The inspectors reviewed the licensees response to NOV 05000445/2021011-05 and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance will be achieved for this violation is adequately addressed and captured on the docket.
The inspectors reviewed the licensee's response to NOV 05000446/2021011-06 and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for this violation is adequately addressed and captured on the docket.
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)===
- (1) Unit 1, residual heat removal pump 1-01 on December 15, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2, safety injection pump 2-02 on October 3, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
(1)multipurpose Flex Pump X-01 per work order 22-20762 on December 12, 2022
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between September 29, 2020, and November 11, 2022.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization between September 29, 2020, and November 11, 2022. Inspectors also evaluated the licensee's ability to staff their emergency response facilities in accordance with emergency plan commitments.
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.
Emergency Plan, Revision 46 - effective September 1, 2022 This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between September 29, 2020, and November 11, 2022. The evaluation reviewed evidence of completing various emergency plant commitments, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency Response Organization red team drill on November 30, 2022.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)control room emergency filtration
- (2) Units 1 and 2 primary plant ventilation and exhaust
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)portable survey instruments, including friskers, RO-20 ion chambers, and telepoles stored ready for use in the laboratory (2)area radiation monitors in use within the auxiliary building (3)continuous air monitors in use within the auxiliary building
- (4) Canberra ARGOS personnel contamination monitors in use at the access to the radiologically controlled area (5)small article monitors in use at the access to the radiologically controlled area (6)liquid effluent radiation monitors in use at the plant (7)gaseous effluent radiation monitors in use at the plant
- (8) REM 500 neutron meter (HP-2213)
(9)survey friskers in use within the auxiliary building and the radwaste building
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Eberline AMS-4, HP-2171, November 2, 2022 (2)low volume air sampler, HP-2224, August 30, 2022
- (3) Ludlum Model 177 survey meter, HP-2403, September 26, 2022
- (4) Ludlum Model 3000 survey meter, HP-3165, May 23, 2022
- (5) Thermo Scientific RO-20 ion chamber, HP-4148, October 25, 2022
- (6) Mirion Technologies telepole, HP-5012, October 11, 2022
- (7) Canberra ARGOS - 5WBAB personnel contamination monitor, HP-0065, December 22, 2021
- (8) Canberra ARGOS - 5WBAB personnel contamination monitor, HP-0072, June 9, 2022
- (9) Canberra ARGOS - 5ABG personnel contamination monitor, HP-0060, May 24,
RADIATION SAFETY
- (10) Mirion Technologies telepole, HP-1966, August 23, 2022
- (11) AMP-100 radiation detector, HP-1846, August 31, 2022
- (12) Apex FSCAN whole body counter, April 28, 2022
- (13) Apex ASCAN whole body counter, September 14, 2021
- (14) Ludlum 54R-11 small article monitor, HP-0055, September 12, 2022 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)auxiliary building vent exhaust radiation monitor, X-RE-5701, WO 5371788, July 18, 2019 (2)south vent stack wide range gas monitor, X-RE-5570A, WO 5826291, June 24, 2021 (3)liquid waste processing discharge radiation detector, X-RE-5253, WO 5833378, March 9, 2021
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
(1)outage equipment located within warehouse C (2)interim low level radioactive waste storage facility located in the owner-controlled area
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Units 1 and 2, spent resin transfer system
- (2) Units 1 and 2, spent process filters system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) Unit 1, reactor coolant system filter - 2021
- (2) Unit 2, reactor coolant system - 2022
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the preparation of radioactive material shipment 20220044.
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a records review:
(1)shipment 2020044; one poly liner, LSA-II, Type A (2)shipment 2021017; one poly liner, LSA-II, Type A (3)shipment 2022024; one poly liner, LSA-II, Type A (4)shipment 2022056; one resin liner, LSA-II, Type A
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07)===
- (1) Unit 1 (July 1, 2021, through September 30, 2022)
- (2) Unit 2 (July 1, 2021, through September 30, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (October 1, 2021, through September 30, 2022)
- (2) Unit 2 (October 1, 2021, through September 30,.2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2021, through September 30, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 1, 2021, through September 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)failure of emergency diesel generator 1-01 rocker arm bolts (2)trip of Unit 1 due to failed cables for displacement probes (3)through wall leak on turbine driven AFW governor valve leak offline.
- (4) degraded Flex program batteries
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in operator workarounds and control room deficiencies that might be indicative of a more significant safety issue. In addition, the inspectors toured the safeguards building with the building operators on November 30, 2022, to verify that no undocumented operator workarounds/operator burdens existed outside of the licensee's tracking programs. The inspectors determined that the licensee was properly managing these backlogs and did not identify any adverse trends in operator workarounds or control room deficiencies.
INSPECTION RESULTS
Failure to Periodically Calibrate Radiation Monitors within their Frequency as Required by 10 CFR 20.1501(c)
Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000445,05000446/2022004-01 Open/Closed
[H.5] - Work Management 71124.05 The inspectors identified a Green non-cited violation of 10 CFR 20.1501(c) for a failure to periodically calibrate radiation monitoring equipment used to perform quantitative radiation measurements within their required frequency. This monitoring equipment included effluent, process, area, and emergency protection related radiation monitors. The inspectors identified that required calibrations for 11 radiation monitors exceeded the specified frequency and the grace period.
Description:
During a review of radiation monitor calibration data, as provided by the licensee, the inspectors noted that the licensee performed scheduled calibrations on a total of 93 radiation monitors/detectors. These radiation monitors/detectors supported effluents, process, area monitoring, and emergency preparedness monitoring programs. The calibration frequency of the radiation monitors subject to technical surveillance requirements (TSRs) is controlled by the surveillance frequency control program. This program is implemented by Technical Specification (TS) 5.5.21 and procedure STA-700, Surveillance Frequency Control Program. The calibration frequency of other radiation monitors, not subject to TSRs, is maintained within the preventive maintenance (PM) program, with established frequencies.
The licensee implements their PM-related radiation monitor calibrations via procedure STA-677, Preventive Maintenance Program, which maintains scheduling of their instrument calibrations using a work management database called Maximo.
The radiation monitors that are required by TSRs are allotted additional time to complete calibrations if an unplanned issue challenges the calibration completion by the original due date for the equipment to remain operable. This additional time for completing the calibration is commonly referred to as the grace period. The grace period is defined as an additional 25 percent of the scheduled calibration period to complete a required TSR calibration.
Surveillance Requirement (SR) 3.0.2 states, in part, The specified Frequency for reach SR is met if the Surveillance is performed within 1.25 times the interval specific in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. The grace period is applicable to liquid and gaseous effluent radiation monitoring equipment, which are required by the TSs and/or the Offsite Dose Calculation Manual. Of the 93 radiation monitors/detectors reviewed by the NRC, only thirteen
- (13) were effluent monitors. However, the licensee has implemented an approach that the grace period may be applied to any radiation monitor, coded as TU for a licensee commitment, providing some justification existed for not completing the calibration within its established frequency.
Per NRCs request, the licensee provided a chart of the established calibration frequency requirement for each of their radiation monitors/detectors. Of the 93 radiation monitors/detectors on the chart, the inspectors identified there were 78 (84 percent) in total that were not calibrated within their established calibration frequency. However, of those 78 radiation monitors/detectors, at least ten included TSR radiation monitors, which were allowed a grace period by SR 3.0.2, if needed. None of the ten radiation monitors related to TSRs exceeded their grace period, although most had inadequate justifications as to why the radiation monitor calibrations were not completed on time (within 550 days). The remaining 68 PM-related radiation monitors (73 percent) that were not controlled by the surveillance frequency control program exceeded their established calibration frequency failing to comply with NRC calibration requirements. Within a limited scope of calibration records reviewed, NRC identified that three of the subsequent calibrations for these radiation monitors had as-found conditions/parameters out-of-tolerance.
As a reference, the following chart summarizes 11 of the 68 radiation monitors that not only exceeded their specific radiation calibration frequency per the PM program, procedure STA-677, but were not calibrated until a significant time past their established period (greater than 1.25 times the calibration frequency - grace period):
Radiation Monitor/
Detector ID Calibration Frequency (days)
Calibration Completion Date Subsequent Calibration Due Date Previous Calibration Date Percent Past Calibration Date 2-RE-6292 1648 11/21/2019 05/14/2015 11/08/2010 100%
2-RE-6291A 1648 08/01/2022 07/17/2019 01/11/2015 67%
1-RE-6260B 1648 07/24/2020 08/17/2017 02/11/2013 65%
2-RE-6259A 1648 06/15/2022 08/15/2019 02/09/2015 63%
2-RE-6297 1648 05/10/2017 04/05/2015 09/30/2010 46%
1-RE-6296 1648 06/11/2021 10/12/2019 04/08/2015 37%
2-RE-5637 1648 05/19/2022 10/11/2020 04/07/2016 35%
1-RE-6292 732 01/16/2020 05/17/2019 05/15/2017 33%
2-RE-6253 1098 11/01/2021 04/19/2020 04/17/2017 51%
2-RE-6251 1098 10/25/2021 04/19/2020 04/17/2017 51%
X-RE-6275 1648 02/11/2021 07/14/2019 01/08/2015 35%
The inspectors reviewed a 2020 evaluation that the licensee documented in CR-2020-000814 that addressed a minor violation for not calibrating two installed radiation monitors (1-RE-6295 and 2-RE-6297) within their respective calibration frequency. According to CR-2020-000814, the licensee evaluated this issue and reviewed the surveillance frequencies of their radiation monitors. The evaluation stated, "Based on the current strategy for non-critical PMs, rescheduling of calibration work activities will continue to be as a result of parts issues, resource availability or ongoing critical work. To ensure this does not repeat, Maintenance have been coached to use the deferral process to extend or move calibration activities beyond their compliance dates into the grace period."
The inspectors reviewed this information and determined that the licensee used the grace period as a routine process to complete their calibrations. Comments provided by the licensee as a justification for not meeting the scheduled calibration date frequently used "no resources" or had no justification at all. Additionally, the licensee only documents a justification to extend their calibration frequency when they are entering the second half of the grace period (i.e., "violation time period"). NRC inspectors explained that this approach to completing calibrations often results in issues of concern because the frequent use of the grace period does not leave much room to complete calibrations in a timely manner to maintain their established calibration frequency. It was also discussed with the licensee that radiation monitors that are not required by their TSRs are not usually allotted a grace period. As stated above, in the TSs, the grace period or the calibration frequency factor of 1.25 is used for operational flexibility. Additionally, the licensee has established that you should not routinely use the grace period, as stated in TS Bases Surveillance Requirement (SR) Applicability SR 3.0.2, which in part states that, The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
With the significant number of missed calibration requirements, the failure to periodically calibrate radiation monitoring equipment within their established frequency is not an isolated occurrence and is deemed a programmatic breakdown of the licensee's radiation protection program barrier, rendering it ineffective in radiological surveys and monitoring. This is primarily due to the current way the licensee implements their program for radiation monitoring equipment calibrations via the surveillance frequency control program, the PM program, and their work management for frequently planning calibrations into the grace period without proper justification.
The inspectors reviewed the annual effluent release reports and determined the licensee did not fail to implement the effluent program nor had public doses greater than the 10 CFR 50, Appendix I, or 10 CFR 20.1301(e) annual public dose limits.
Corrective Actions: The licensee entered the issue into their corrective action program to evaluate the extent of conditions. The licensee also re-evaluated their corrective actions from CR-2020-000814.
Corrective Action References: CR-2022-008715
Performance Assessment:
Performance Deficiency: The failure to ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured, as required by 10 CFR 20.1501(c), is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the licensee failed to ensure they periodically calibrated their radiation monitors within their required frequency to maintain adequate quantitative radiation measurements.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because
- (1) it was not associated with ALARA planning and work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee failed to complete calibrations for most of their radiation monitors (84 percent)within their specific frequency.
The licensee mostly cited a lack of resources. This is a failure to properly plan and execute the calibration/PM tasks. The licensee has implemented a process of only documenting a PM basis/comment for exceeding the frequency period as the calibration enters the second half of the grace period. NRC asserts that planning for calibrations in the grace period challenges not meeting required calibration frequencies by providing less time to address unforeseen issues.
Enforcement:
Violation: Title 10 CFR 20.1501(c) requires, in part, that licensees ensure instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluents) are calibrated periodically for the radiation measured.
Procedure STA-677, is used to maintain the periodicity of calibration of instruments and equipment used for quantitative radiation measurements. Section 6.7.2 of STA-677, states, in part, PMs which are required by License Basis Documents coded as TU should be performed within the specified time interval of PM frequency plus 25% of the PM frequency (Grace Period).
Contrary to the above, from April 5, 2015, to August 1, 2022, the licensee failed to ensure that all radiation monitors were calibrated periodically for the radiation measured. Specifically, the licensee failed to ensure 11 of their radiation monitors were calibrated within their established calibration/PM frequency, plus 25 percent, as noted in the chart above, in accordance with procedure STA-677.
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 October 27, 2022, the inspectors presented the licensed operator requalification program and licensed operator performance inspection debrief results to C. Herring, Training Director, and other members of the licensee staff.
On November 3, 2022, the inspectors presented the licensed operator requalification program and licensed operator performance inspection exit results to J. Beaver, Training Manager, and other members of the licensee staff.
On November 17, 2022, the inspectors presented the emergency preparedness program inspection results to S. Sewell, Acting Site Vice President, and other members of the licensee staff.
On December 5, 2022, the inspectors presented the occupational radiation safety inspection results to S. Sewell, Acting Site Vice President, and other members of the licensee staff.
On December 13, 2022, the inspectors presented the public radiation safety inspection results to B. Pineda, Maintenance Director, and other members of the licensee staff.
On January 18, 2023, the inspectors presented the integrated inspection results to S. Sewell, Acting Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
CS-CA-0000-
4062
Flooding
Engineering
Evaluations
DBD-CS-071
Probable Maximum Flood
Procedures
ABN-907
Acts of Nature
Procedures
ABN-912
Heat Tracing and Freeze Protection System Malfunction
Procedures
EPP-201
Assessment of Emergency Action Levels
Procedures
ODA-308
LCO Tracking Program
Procedures
OWI-912
Cold Weather
Procedures
STA-696
Hazard Barrier Controls
Engineering
Evaluations
DBD-EE-043
118 VAC Uninterruptible Power Supply System
Engineering
Evaluations
DBD-EE-044
DC Power Systems
Miscellaneous
2nd QTR FY22
System Health
Report
Inverters System Health Report
10/19/2022
Miscellaneous
DC Distribution
2nd QTR FY22 System Health Report
10/19/2022
Procedures
ABN-603
Loss of Protection or Instrument Bus
Procedures
SOP 607A
118 VAC Distribution System and Inverters
Procedures
SOP-605A
25 VDC Switchgear and Distribution Systems, Batteries
and Battery Chargers
Procedures
SOP-605B
25 VDC Switchgear and Distribution Systems, Batteries
and Battery Chargers
Procedures
SOP-607B
118 VAC Distribution System and Inverters
Fire Plans
FPI-2001
Flex Storage Building X-FX-2K19
Fire Plans
FPI-507
Electrical and Control Building Elevation 840'6"
Fire Plans
FPI-508
Electrical and Control Building Elevation 854'-4" Fire Pre-
plan
Fire Plans
FPI-701
Service Water Intake Structure Elev. 796'-0" & 810'-6"
Fire Plans
FPI-801
Circulating Water Intake Structure Elevation 795'-0"
Corrective Action
Documents
CR 2022-001092
Licensed Operator Failure to Report a Medical Condition
2/15/2022
Corrective Action
Documents
CR-2021-001490
Time Critical Action Validation Failure
2/25/2021
Corrective Action
Documents
IR-2022-007530,
1-8811 CCP Miniflow Valve Switch Failed During
LO49F22E05 Scenario 2
Corrective Action
Documents
IR-2022-007531
Simulator Headset Communication Failure
Corrective Action
Documents
IR-2022-007933
22 LOR Examination Summary
11/03/2022
Corrective Action
Documents
Resulting from
Inspection
IR-2022-007715
Simulator Operability Test Data Collection Frequency
10/26/2022
Miscellaneous
Open Simulator Work Report
08/02/2022
Miscellaneous
Simulator Inspection Report
08/02/2022
Miscellaneous
Simulator Annual Performance Test Summary, 2021
21
Miscellaneous
Operations Crew 15 Training Records, June 2020 - August
22
Miscellaneous
LO49.D21.E06
21 LORT Operational Examination 6
05/12/2021
Miscellaneous
LO49.D21.JS6
21 LORT Senior Reactor Operator JPM Exam 6
05/12/2021
Miscellaneous
LO49.F22.E06
22 LORT Operational Exam 6
09/19/2022
Miscellaneous
LO49.F22.ER1
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ER2
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ER3
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ER4
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ER5
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ER6
22 LORT Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ES1
22 LORT Senior Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ES2
22 LORT Senior Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ES3
22 LORT Senior Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ES4
22 LORT Senior Reactor Operator Written Examination
10/4/2022
Miscellaneous
LO49.F22.ES5
22 LORT Senior Reactor Operator Written Examination
10/04/2022
Miscellaneous
LO49.F22.ES6
22 LORT Senior Reactor Operator Written Examination
10/04/2022
Miscellaneous
LO49.F22.JR6
22 LORT Reactor Operator JPM Exam 6
09/19/2022
Miscellaneous
LO49.F22.JS6
22 LORT Senior Reactor Operator JPM Exam 6
09/19/2022
Miscellaneous
LO49/D21.JR6
21 LORT Reactor Operator JPM Examination 6
05/12/2021
Procedures
ODA-315
Licensed Operator Maintenance Tracking
Procedures
SAPT-001
Steady State Performance Testing
Procedures
SAPT-002
Transient Performance Testing
Procedures
SAPT-003
Malfunctions Testing
Procedures
SAPT-004
Normal Operations Testing
Procedures
SAPT-005
Core Performance Test
Procedures
SOMI-09
Simulator Configuration Control
Procedures
SOMI-10
Simulator Testing Program
Procedures
TRA-204
Licensed Operator Requalification Training
Procedures
TRA-206
Operations Department Examination Control and
Implementation
Procedures
TRA-206-1
Examination Remedial Training Plan
Procedures
TRA-207
Simulator Configuration Management
Procedures
TRA-208
Simulator Training
Procedures
TRI-204.01
Licensed Operator Requalification Training Processes and
Program Reviews
Procedures
TRI-206-5
LORT Annual/Biennial Requalification Exam - Examinee
Security Agreement
Procedures
TRI-206.02
NRC Requalification Exam Development Process
Procedures
TRI-206.02-1
LORT Biennial Written Exam Checklist
Procedures
TRI-206.02-2
JPM Exam Development Process
Procedures
TRI-206.02-3
Simulator Scenario Review Checklist
Procedures
TRI-207.01
Simulator Maintenance
Procedures
TRI-208.02
Conduct of LORT Simulator Training
Corrective Action
Documents
CR-YYYY-NNNN
22-3605, 2022-6509, 2022-8156
Corrective Action
Documents
TR-YYYY-NNNN
22-7334
Miscellaneous
Reactor Coolant System Health Reports
Miscellaneous
Reactor Coolant System Maintenance Rule Database
Shipping Records
Unit 1 generator primary water system leakage pump B
replacement
10/29/2022
Work Orders
Unit 1 generator primary water system leakage pump B
replacement
10/29/2022
Corrective Action
Documents
CR-YYYY-NNNN
22-007333, 2017-10202, 2017-12716, 2021-7593,
22-8479, 2022-007076, 2022007329, 2022-007895,
22-008097, 2022-009473, 2022-8668
Corrective Action
Documents
TR-YYYY-NNNN
22-8822
Corrective Action
Documents
CR-YYYY-NNNN
22-006497, 2022-007076
Engineering
Changes
Final Design
Authorization
(FDA) -
2017-000141-01-01; 2017-000141-02-00- 2017-000141-03-
00; 2017-000141-04-00
Work Orders
22-295661, 2022-449574
Work Orders
22-486831, 2022-399034, 6017468, 5889486,
22-497829, 2022-495254, 6038099, 2022-536980,
22-448761, 6017179, 2022-520193, 2021-331956
22-541086
Work Orders
22-476174, 2022-370203
Miscellaneous
CP-202100256,
Comanche Peak Nuclear Power Plant (CPNPP) Docket
Nos. 50-445 and 50-44, Reply to A Notice of Violation.
NRC Letter from Vincent Gaddy to Ken Peters dated May 6,
21, "Comanche Peak Nuclear Power Plant, Units 1 And 2
- Design Basis Assurance Inspection (Teams) Inspection
Report 05000445/2021011 And 05000446/2021011 And
Notice of Violation" (ADAMS Accession Number
06/09/2021
Corrective Action
Documents
CR-YYYY-NNNN
20-007714, 2021-007470, 2021-007705, 2022-003197,
22-005482
Corrective Action
Documents
TR-YYYY-NNNN
21-004019, 2022-005642
Miscellaneous
Activity Number:
TR-2017-003895-
Comanche Peak Nuclear Power Plant, 10 CFR 50.54(q)(3)
Screening Evaluation Form - ANS Design Report
03/11/2021
Miscellaneous
CP-202100137
Alert & Notification System (ANS) Design Report, Revision
2, Change 1, Effective Date 3-11-2021
(Reference AI-TR-2017-003895-1)
03/11/2021
Procedures
SG-012
Alert and Notification System Surveillance
Procedures
STA-662
Administrative Control of the Siren System
Work Orders
Work Order
Number
5950180
Corrective Action
Documents
CR-YYYY-NNNN
20-009218
Corrective Action
Documents
TR-YYYY-NNNN
20-009209, 2021-001908
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
22-008425
Miscellaneous
1, Quarterly Augmentation Verification Results,
4th Quarter
2/15/2020
Miscellaneous
1, Quarterly Augmentation Verification Results,
1st Quarter
03/26/2021
Miscellaneous
1, Quarterly Augmentation Verification Results,
2nd Quarter
07/08/2021
Miscellaneous
1, Quarterly Augmentation Verification Results,
3rd Quarter
09/28/2021
Miscellaneous
1, Quarterly Augmentation Verification Results,
4th Quarter
2/28/2021
Miscellaneous
1, Quarterly Augmentation Verification Results,
1st Quarter
03/15/2022
Miscellaneous
1, Quarterly Augmentation Verification Results,
2nd Quarter
04/18/2022
Miscellaneous
1, Quarterly Augmentation Verification Results,
3rd Quarter
09/26/2022
Miscellaneous
Comanche Peak On-Shift Staffing Analysis
Procedures
SG-005
Quarterly Augmentation Verification of the Emergency
Response Organization (ERO)
Corrective Action
Documents
Resulting from
Inspection
IR-
22-008551
Miscellaneous
Screening and
Effectiveness
Evaluation Form
for ETE Update
CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness
Evaluation Form for ETE Update
08/15/2022
Procedures
EPP-123
CFR 50.54(q) Screening and Evaluation of Changes to
Emergency Plan Documentation
Corrective Action
Documents
CR-YYYY-NNNN
21-005014, 2022-007495, 2020-007181, 2020-007714,
20-008038, 2020-009537, 2021-005946, 2021-007705,
21-008154, 2022-001649, 2022-003197, 2022-005388,
22-005482, 2022-007002, 2022-007168, 2020-009415,
21-003239, 2021-003405, 2021-008501, 2021-008503,
22-003973, 2022-004837, 2020-007154
Corrective Action
Documents
TR-YYYY-NNNN
21-003554, 2021-005058, 2021-000198, 2021-008155,
22-001822, 2022-001892
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
22-008423, 2022-008464
Procedures
EPP-100
Maintaining Emergency Preparedness
Procedures
SG-24
Evacuation Time Estimate Annual Population Estimate and
Update Process
Procedures
SG-25
Evaluation and Critique of Exercises
Procedures
STA-153
Management of Contracts
Procedures
TRA-104
Fire Protection Training
Miscellaneous
Exercise Guide for November 30, 2022 emergency planning
drill
11/30/2022
Corrective Action
Documents
Tracking Report
(TR)
21-007015, 2021-007150, 2021-0072209, 2021-007307,
21-7670, 2021-007862, 2022-000408, 2022-000630,
22-001439, 2022-001797, 2022-002190, 2022-002364,
22-2408, 2022-002522, 2022-002567, 2022-002998,
22-003201, 2022-003215, 2022-003218, 2022-003620,
22-003638, 2022-003942, 2022-005442, 2022-005860,
22-006865, 2022-007169, 2022-008079
Miscellaneous
Final Source Term Assessment Letter Report for Comanche
Peak Station U2, 2021 Review
10/25/2021
Self-Assessments EV AL-2020-009
Nuclear Oversight Audit Report: Work Management,
Maintenance and Radiation Protection
04/07/2021
Corrective Action
Documents
TR-YYYY-NNNN
20-008943, 2020-009271, 2021-000896, 2021-001557,
21-005053, 2021-008354, 2022-007992
Corrective Action
Documents
Resulting from
Inspection
TR-YYYY-NNNN
22-008418, 2022-008420, 2022-008421, 2022-008470
Miscellaneous
Scott Authorized Service Center Certification ID: C007797-2
08/02/2020
Work Orders
5354557, 5358655, 5377734, 5382993, 5404601, 5410233,
5416926, 5431171, 5431297, 5558463, 556156, 5606050,
26932, 5651677, 5656809, 5661215, 5661217, 5677686,
5677756, 567787, 5714373, 5795600, 5815720, 5855701
Corrective Action
Documents
CR/TR-YYYY-
NNNN
CR-2020-000814, TR-2020-000838, TR-2020-002420,
TR-2021-001492, TR-2021-002846, TR-2021-005888,
TR-2021-008670, TR-2022-001797
Corrective Action
Documents
Resulting from
Inspection
CR/TR-YYYY-
NNNN
TR-2022-007842, TR-2022-007856, TR-2022-007897,
TR-2022-007898, TR-2022-007899, CR-2022-008715
Miscellaneous
CPNPP Offsite Dose Calculation Manual
Miscellaneous
Chapter 12 of the CPNPP Final Safety Analysis Report
104
Miscellaneous
Chapter 11 of the CPNPP Final Safety Analysis Report
111
Miscellaneous
2nd QTR FY22
CPNPP System Status: Radiation Monitoring
06/30/2022
Miscellaneous
4th QTR FY21
CPNPP System Status: Radiation Monitoring
2/31/2021
Miscellaneous
CP-202100152
20 Annual Radioactive Effluent Release Report
04/28/2021
Miscellaneous
CP-202100225
20 Annual Radiological Environmental Operating Report
04/29/2021
Miscellaneous
CP-202200145
21 Annual Radioactive Effluent Release Report
04/18/2022
Miscellaneous
CP-202200183
21 Annual Radiological Environmental Operating Report
04/28/2022
Miscellaneous
EV CR-2011-
2968
Evaluation of Changes to Eberline AMS-4 Procedure
2011
Procedures
ICI-4995X
Channel Calibration Plant Vent Stack Gas Channels: X-RE-
5567A & X-RE-5567B
Procedures
INC-4915X
Channel Calibration Auxiliary Building Vent Duct Exhaust
Gas Process Radiation Monitor Channel: X-RE-5701
Procedures
INC-7079
Channel Calibration Containment High Range Radiation
Monitor Channels: 1-RE-6290A/B and 2-Re-6290A/B
Procedures
INC-7082
Digital Channel Operational Test and Channel Calibration
Service Water System Effluent Liquid Process Radiation
Monitors Channels: 1-RE-4269, 1-RE-4270, 2-RE-4269, 2-
RE-4270
Procedures
INC-7090X
Digital Channel Operational Test Channel Operational Test
and Channel Calibration Plant Vent Stack Wide Range Gas
Monitor Channels: X-RE-5570A, X-RE-5570B
Procedures
RPI-301
Portable Survey Instruments
Procedures
RPI-800
Control of Radiation Protection Equipment
Procedures
RPI-802
Performance of Source Checks
Procedures
RPI-862
Calibration of the ARGOS SIRIUS Personnel Contamination
Monitor and GEM-5 Gamma Exit Monitor
Procedures
RPI-881
Calibration of Portable Dose Rate Instruments
Procedures
RPI-882
Calibration of Portable Count Rate Instruments
Procedures
RPI-889
Calibration of the Eberline AMS-4
Procedures
STA-619
Administrative Control of the Digital Radiation Monitoring
System
Procedures
STA-658
Radiation Protection Equipment Calibration Program
Procedures
STA-700
Surveillance Frequency Control Program
Self-Assessments
GEL Environmental Laboratory Quality Report: 2022 - First
Quarter
06/17/2022
Self-Assessments
GEL Environmental Laboratory Quality Report: 2022 -
Second Quarter
08/22/2022
Self-Assessments
GEL 2021 Annual Quality Assurance Report for the
Radiological Environmental Monitoring Program (REMP)
03/15/2022
Self-Assessments EVAL-2021-006
CPNPP Nuclear Oversight Audit Report: Chemistry,
Environmental, Effluent, and Radioactive Waste
03/31/2022
Work Orders
5371788
Auxiliary Building Vent Exhaust Radiation Monitor, X-RE-
5701
07/18/2019
Work Orders
26291
South Vent Stack Wide Range Gas Monitor, X-RE-5570A
06/24/2021
Work Orders
5833378
Liquid Waste Processing Discharge Radiation Monitor, X-
RE-5253
03/09/2021
Work Orders
5901918
Unit 2 Containment EL 905 High Range Radiation Monitor,
2-RE-6290A
10/23/2021
Work Orders
5946156
North Vent Stack Discharge Gas Radiation Detector, X-RE-
5567B
03/02/2022
Corrective Action
Documents
CR/TR-YYYY-
NNNN
TR-2021-004459, TR-2021-006713, TR-2021-007297,
TR-2021-008001, TR-2022-001442, CR-2022-001458
Corrective Action
Documents
Resulting from
Inspection
CR/TR-YYYY-
NNNN
TR-2022-007709, TR-2022-007934, CR-2022-008665
Miscellaneous
22 - Unit 2 waste characterization sample for reactor
coolant system
06/07/2022
Miscellaneous
21 - Unit 1 waste characterization sample of the reactor
coolant system filter
06/28/2021
Procedures
RPI-202
Receipt of Radioactive Material
Procedures
RPI-204
Radioactive Waste Handling
Procedures
RPI-212
Radioactive Source Control
Procedures
RPI-213
Survey and Release of Material
Procedures
RPI-215
Waste Stream Sampling
Procedures
RPI-232
Characterizing Radioactive Material for Shipment
Procedures
RPI-238
Radioactive Material/Waste Shipment Surveys
Procedures
RPI-240
Radioactive Waste Shipments
Procedures
RPI-242
Radioactive Waste Characterization and Classification
Procedures
RPI-243
Packaging Radioactive Waste for Shipment
Procedures
RPI-261
Operating Instructions for the Use of Filter Disposal
Containers
Procedures
RPI-271
Interim Storage of Low-Level Radioactive Waste
Procedures
RPI-273
Rad-Vault/Trailer Inspections and Movement
Procedures
RPI-274
CPNPP Transportation Security Plan
Procedures
RPI-304
Radiological Posting and Labeling
Procedures
STA-709
Radioactive Waste Management Program
Procedures
STA-713
Shipping Records
20044
Shipping package and associated documents for shipment
- 2020044
08/18/2020
Shipping Records
21017
Shipping package and associated documents for shipment
- 2021017
05/19/2021
Shipping Records
22024
Shipping package and associated documents for shipment
- 2022024
11/02/2022
Shipping Records
22056
Shipping package and associated documents for shipment
- 2022056
10/18/2022
71151
Corrective Action
Documents
CR-YYYY-NNNN
21-007878
71151
Corrective Action
Documents
TR-YYYY-NNNN
22-003934, 2022-004991
71151
Miscellaneous
21 Annual Radiological Effluents Release Report:
January 1, 2021 - December 31, 2021
04/09/2022
71151
Miscellaneous
22 Quarterly Air Doses Due to Gaseous Releases -
January through September
71151
Miscellaneous
22 Quarterly Doses to a member of the public due to
Liquid Releases - January through September
71151
Miscellaneous
22 Quarterly Doses due to Radioiodines, Tritium, and
Particulates in Gaseous Releases - January through
September
71151
Miscellaneous
MSPI Margin Report for Unit 2 Heat Removal System and
Cooling Water System
11/22/2022
71151
Miscellaneous
MSPI Margin Report for Unit 1 Heat Removal System and
Cooling Water System
11/22/2022
71151
Miscellaneous
Maximo Limiting Condition for Operation database for AFW,
Service Water, and Component Cooling Water
07/01/2021 -
09/30/2022
Calculations
RXE-TA-CPX/0-
2
Analysis of Proposed Auxiliary Feedwater Turbine Drain
System for CPSES
Corrective Action
Documents
CR-YYYY-NNNN
22-3593, 2022-6527, 2021-007070
Corrective Action
Documents
TR-YYYY-NNNN
22-4854, 2021-006947
Miscellaneous
Comanche Peak Unit 2 MSIP High Pressure Box Press
Failure Root Cause Analysis Report
04/2022
Miscellaneous
MRS-SSP-2592-
Comanche Peak Unit 1 Reactor Vessel Inlet Nozzle to Sale
End Weld Mechanical Stress Improvement Process Field
Service Procedure
Miscellaneous
MRS-SSP-3538
Comanche Peak Unit 2 (TCX) Reactor Vessel to Nozzle
Safe End Weld Mechanical Stress Improvement Process
Field Service Procedure
Miscellaneous
TCX-PP000-CN-
PX-000002
Comanche Peak Unit 2 Operability Assessment of the
Reactor Coolant Piping and Support System due to the
MSIP Tool Failures
Miscellaneous
TCX-PP000-TR-
PX-000001
Reactor Coolant Loop (RCL) Piping and Support System
Operability Assessment due to impact of the MSIP Tool
Failure at Comanche Peak Unit 2 by Westinghouse
Procedures
ECE-5.01
Design Control Program
Procedures
ECE-5.08
Standard Design Process
Procedures
ECE-5.09
Engineering Design Review Process
Procedures
NQA-3.14
Control Of Vendor Activities
Procedures
STA-206
Review Of Vendor Documents and Vendor Technical
Manuals
Procedures
STA-627
Control Of Planned Outages
Procedures
STI-604.04
Outage Safety Function Guide
Procedures
VISTRAOPCO
Comanche Peak Nuclear Power Plant Quality Assurance
Manual
24