IR 05000445/2022004

Integrated Inspection Report 05000445/2022004 and 05000446/2022004

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, Signed by Werner, Gregory on 01/26/23 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: NPF-87 and NPF-89 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 Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,

Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Periodically Calibrate Radiation Monitors within their Frequency as Required by 10 CFR 20.1501(c)

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.5] - Work 71124.05 Radiation Safety NCV 05000445,05000446/2022004-01 Management Open/Closed 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 Failure to Restore 71111.21M Closed 21011-05 Compliance for Inadequate Voltage Calculations for the 120 VAC Buses NOV 05000445,05000446/20 Failure to Restore 71111.21M Closed 21011-06 Compliance and Evaluate Inverter Fault Interrupting Capability During Design Basis Loss of Offsite Power and Seismic Conditions

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.

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,

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, 2022

(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 Report Aspect Section Occupational Green [H.5] - Work 71124.05 Radiation Safety NCV 05000445,05000446/2022004-01 Management Open/Closed 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 Calibration Calibration Subsequent Previous Percent Past Monitor/ Frequency Completion Calibration Calibration Calibration Detector ID (days) Date Due Date Date 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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Calculations CS-CA-0000- Flooding 0

4062

71111.01 Engineering DBD-CS-071 Probable Maximum Flood 13

Evaluations

71111.01 Procedures ABN-907 Acts of Nature 17

71111.01 Procedures ABN-912 Heat Tracing and Freeze Protection System Malfunction 10

71111.01 Procedures EPP-201 Assessment of Emergency Action Levels 13

71111.01 Procedures ODA-308 LCO Tracking Program 21

71111.01 Procedures OWI-912 Cold Weather 5

71111.01 Procedures STA-696 Hazard Barrier Controls 4

71111.04 Engineering DBD-EE-043 118 VAC Uninterruptible Power Supply System 15

Evaluations

71111.04 Engineering DBD-EE-044 DC Power Systems 29

Evaluations

71111.04 Miscellaneous 2nd QTR FY22 Inverters System Health Report 10/19/2022

System Health

Report

71111.04 Miscellaneous DC Distribution 2nd QTR FY22 System Health Report 10/19/2022

71111.04 Procedures ABN-603 Loss of Protection or Instrument Bus 8

71111.04 Procedures SOP 607A 118 VAC Distribution System and Inverters 25

71111.04 Procedures SOP-605A 125 VDC Switchgear and Distribution Systems, Batteries 13

and Battery Chargers

71111.04 Procedures SOP-605B 125 VDC Switchgear and Distribution Systems, Batteries 6

and Battery Chargers

71111.04 Procedures SOP-607B 118 VAC Distribution System and Inverters 18

71111.05 Fire Plans FPI-2001 Flex Storage Building X-FX-2K19 1

71111.05 Fire Plans FPI-507 Electrical and Control Building Elevation 840'6" 3

71111.05 Fire Plans FPI-508 Electrical and Control Building Elevation 854'-4" Fire Pre- 4

plan

71111.05 Fire Plans FPI-701 Service Water Intake Structure Elev. 796'-0" & 810'-6" 4

71111.05 Fire Plans FPI-801 Circulating Water Intake Structure Elevation 795'-0" 3

71111.11B Corrective Action CR 2022-001092 Licensed Operator Failure to Report a Medical Condition 02/15/2022

Documents

71111.11B Corrective Action CR-2021-001490 Time Critical Action Validation Failure 02/25/2021

Documents

71111.11B Corrective Action IR-2022-007530, 1-8811 CCP Miniflow Valve Switch Failed During

Documents LO49F22E05 Scenario 2

71111.11B Corrective Action IR-2022-007531 Simulator Headset Communication Failure

Documents

71111.11B Corrective Action IR-2022-007933 2022 LOR Examination Summary 11/03/2022

Documents

71111.11B Corrective Action IR-2022-007715 Simulator Operability Test Data Collection Frequency 10/26/2022

Documents

Resulting from

Inspection

71111.11B Miscellaneous Open Simulator Work Report 08/02/2022

71111.11B Miscellaneous Simulator Inspection Report 08/02/2022

71111.11B Miscellaneous Simulator Annual Performance Test Summary, 2021 2021

71111.11B Miscellaneous Operations Crew 15 Training Records, June 2020 - August

22

71111.11B Miscellaneous LO49.D21.E06 2021 LORT Operational Examination 6 05/12/2021

71111.11B Miscellaneous LO49.D21.JS6 2021 LORT Senior Reactor Operator JPM Exam 6 05/12/2021

71111.11B Miscellaneous LO49.F22.E06 2022 LORT Operational Exam 6 09/19/2022

71111.11B Miscellaneous LO49.F22.ER1 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ER2 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ER3 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ER4 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ER5 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ER6 2022 LORT Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ES1 2022 LORT Senior Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ES2 2022 LORT Senior Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ES3 2022 LORT Senior Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ES4 2022 LORT Senior Reactor Operator Written Examination 10/4/2022

71111.11B Miscellaneous LO49.F22.ES5 2022 LORT Senior Reactor Operator Written Examination 10/04/2022

71111.11B Miscellaneous LO49.F22.ES6 2022 LORT Senior Reactor Operator Written Examination 10/04/2022

71111.11B Miscellaneous LO49.F22.JR6 2022 LORT Reactor Operator JPM Exam 6 09/19/2022

71111.11B Miscellaneous LO49.F22.JS6 2022 LORT Senior Reactor Operator JPM Exam 6 09/19/2022

71111.11B Miscellaneous LO49/D21.JR6 2021 LORT Reactor Operator JPM Examination 6 05/12/2021

71111.11B Procedures ODA-315 Licensed Operator Maintenance Tracking 8

71111.11B Procedures SAPT-001 Steady State Performance Testing 1

71111.11B Procedures SAPT-002 Transient Performance Testing 1

71111.11B Procedures SAPT-003 Malfunctions Testing 1

71111.11B Procedures SAPT-004 Normal Operations Testing 3

71111.11B Procedures SAPT-005 Core Performance Test 0

71111.11B Procedures SOMI-09 Simulator Configuration Control 13

71111.11B Procedures SOMI-10 Simulator Testing Program 18

71111.11B Procedures TRA-204 Licensed Operator Requalification Training 20

71111.11B Procedures TRA-206 Operations Department Examination Control and 5

Implementation

71111.11B Procedures TRA-206-1 Examination Remedial Training Plan 1

71111.11B Procedures TRA-207 Simulator Configuration Management 3

71111.11B Procedures TRA-208 Simulator Training 3

71111.11B Procedures TRI-204.01 Licensed Operator Requalification Training Processes and 2

Program Reviews

71111.11B Procedures TRI-206-5 LORT Annual/Biennial Requalification Exam - Examinee 1

Security Agreement

71111.11B Procedures TRI-206.02 NRC Requalification Exam Development Process 2

71111.11B Procedures TRI-206.02-1 LORT Biennial Written Exam Checklist 2

71111.11B Procedures TRI-206.02-2 JPM Exam Development Process 1

71111.11B Procedures TRI-206.02-3 Simulator Scenario Review Checklist 1

71111.11B Procedures TRI-207.01 Simulator Maintenance 1

71111.11B Procedures TRI-208.02 Conduct of LORT Simulator Training 5

71111.12 Corrective Action CR-YYYY-NNNN 2022-3605, 2022-6509, 2022-8156

Documents

71111.12 Corrective Action TR-YYYY-NNNN 2022-7334

Documents

71111.12 Miscellaneous Reactor Coolant System Health Reports

71111.12 Miscellaneous Reactor Coolant System Maintenance Rule Database

71111.13 Shipping Records WO 21-331956 Unit 1 generator primary water system leakage pump B 10/29/2022

replacement

71111.13 Work Orders WO 22-541086 Unit 1 generator primary water system leakage pump B 10/29/2022

replacement

71111.15 Corrective Action CR-YYYY-NNNN 2022-007333, 2017-10202, 2017-12716, 2021-7593,

Documents 2022-8479, 2022-007076, 2022007329, 2022-007895,

22-008097, 2022-009473, 2022-8668

71111.15 Corrective Action TR-YYYY-NNNN 2022-8822

Documents

71111.18 Corrective Action CR-YYYY-NNNN 2022-006497, 2022-007076

Documents

71111.18 Engineering Final Design 2017-000141-01-01; 2017-000141-02-00- 2017-000141-03-

Changes Authorization 00; 2017-000141-04-00

(FDA) -

71111.18 Work Orders 2022-295661, 2022-449574

71111.19 Work Orders 2022-486831, 2022-399034, 6017468, 5889486,

22-497829, 2022-495254, 6038099, 2022-536980,

22-448761, 6017179, 2022-520193, 2021-331956

22-541086

71111.20 Work Orders 2022-476174, 2022-370203

71111.21M Miscellaneous CP-202100256, Comanche Peak Nuclear Power Plant (CPNPP) Docket 06/09/2021

TXX-21084 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

ML21124A130)

71114.02 Corrective Action CR-YYYY-NNNN 2020-007714, 2021-007470, 2021-007705, 2022-003197,

Documents 2022-005482

71114.02 Corrective Action TR-YYYY-NNNN 2021-004019, 2022-005642

Documents

71114.02 Miscellaneous Activity Number: Comanche Peak Nuclear Power Plant, 10 CFR 50.54(q)(3) 03/11/2021

TR-2017-003895- Screening Evaluation Form - ANS Design Report

71114.02 Miscellaneous CP-202100137 Alert & Notification System (ANS) Design Report, Revision 03/11/2021

2, Change 1, Effective Date 3-11-2021

(Reference AI-TR-2017-003895-1)

71114.02 Procedures SG-012 Alert and Notification System Surveillance 31

71114.02 Procedures STA-662 Administrative Control of the Siren System 1

71114.02 Work Orders Work Order 5950180

Number

71114.03 Corrective Action CR-YYYY-NNNN 2020-009218

Documents

71114.03 Corrective Action TR-YYYY-NNNN 2020-009209, 2021-001908

Documents

71114.03 Corrective Action CR-YYYY-NNNN 2022-008425

Documents

Resulting from

Inspection

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 12/15/2020

4th Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 03/26/2021

1st Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 07/08/2021

2nd Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 09/28/2021

3rd Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 12/28/2021

4th Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 03/15/2022

1st Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 04/18/2022

2nd Quarter

71114.03 Miscellaneous Attachment 1, Quarterly Augmentation Verification Results, 09/26/2022

3rd Quarter

71114.03 Miscellaneous Comanche Peak On-Shift Staffing Analysis 1

71114.03 Procedures SG-005 Quarterly Augmentation Verification of the Emergency 19

Response Organization (ERO)

71114.04 Corrective Action IR- 2022-008551

Documents

Resulting from

Inspection

71114.04 Miscellaneous CPNPP 10 CFR CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness 08/15/2022

50.54(q)(3) Evaluation Form for ETE Update

Screening and

Effectiveness

Evaluation Form

for ETE Update

71114.04 Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 3

Emergency Plan Documentation

71114.05 Corrective Action CR-YYYY-NNNN 2021-005014, 2022-007495, 2020-007181, 2020-007714,

Documents 2020-008038, 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

71114.05 Corrective Action TR-YYYY-NNNN 2021-003554, 2021-005058, 2021-000198, 2021-008155,

Documents 2022-001822, 2022-001892

71114.05 Corrective Action CR-YYYY-NNNN 2022-008423, 2022-008464

Documents

Resulting from

Inspection

71114.05 Procedures EPP-100 Maintaining Emergency Preparedness 11

71114.05 Procedures SG-24 Evacuation Time Estimate Annual Population Estimate and 1

Update Process

71114.05 Procedures SG-25 Evaluation and Critique of Exercises 0

71114.05 Procedures STA-153 Management of Contracts 13

71114.05 Procedures TRA-104 Fire Protection Training 19

71114.06 Miscellaneous Exercise Guide for November 30, 2022 emergency planning 11/30/2022

drill

71124.01 Corrective Action Tracking Report 2021-007015, 2021-007150, 2021-0072209, 2021-007307,

Documents (TR) 2021-7670, 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

71124.01 Miscellaneous Final Source Term Assessment Letter Report for Comanche 10/25/2021

Peak Station U2, 2021 Review

71124.01 Self-Assessments EV AL-2020-009 Nuclear Oversight Audit Report: Work Management, 04/07/2021

Maintenance and Radiation Protection

71124.03 Corrective Action TR-YYYY-NNNN 2020-008943, 2020-009271, 2021-000896, 2021-001557,

Documents 2021-005053, 2021-008354, 2022-007992

71124.03 Corrective Action TR-YYYY-NNNN 2022-008418, 2022-008420, 2022-008421, 2022-008470

Documents

Resulting from

Inspection

71124.03 Miscellaneous Scott Authorized Service Center Certification ID: C007797-2 08/02/2020

71124.03 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

71124.05 Corrective Action CR/TR-YYYY- CR-2020-000814, TR-2020-000838, TR-2020-002420,

Documents NNNN TR-2021-001492, TR-2021-002846, TR-2021-005888,

TR-2021-008670, TR-2022-001797

71124.05 Corrective Action CR/TR-YYYY- TR-2022-007842, TR-2022-007856, TR-2022-007897,

Documents NNNN TR-2022-007898, TR-2022-007899, CR-2022-008715

Resulting from

Inspection

71124.05 Miscellaneous CPNPP Offsite Dose Calculation Manual 34

71124.05 Miscellaneous Chapter 12 of the CPNPP Final Safety Analysis Report 104

71124.05 Miscellaneous Chapter 11 of the CPNPP Final Safety Analysis Report 111

71124.05 Miscellaneous 2nd QTR FY22 CPNPP System Status: Radiation Monitoring 06/30/2022

71124.05 Miscellaneous 4th QTR FY21 CPNPP System Status: Radiation Monitoring 12/31/2021

71124.05 Miscellaneous CP-202100152 2020 Annual Radioactive Effluent Release Report 04/28/2021

71124.05 Miscellaneous CP-202100225 2020 Annual Radiological Environmental Operating Report 04/29/2021

71124.05 Miscellaneous CP-202200145 2021 Annual Radioactive Effluent Release Report 04/18/2022

71124.05 Miscellaneous CP-202200183 2021 Annual Radiological Environmental Operating Report 04/28/2022

71124.05 Miscellaneous EV CR-2011- Evaluation of Changes to Eberline AMS-4 Procedure 2011

2968

71124.05 Procedures ICI-4995X Channel Calibration Plant Vent Stack Gas Channels: X-RE- 6

5567A & X-RE-5567B

71124.05 Procedures INC-4915X Channel Calibration Auxiliary Building Vent Duct Exhaust 2

Gas Process Radiation Monitor Channel: X-RE-5701

71124.05 Procedures INC-7079 Channel Calibration Containment High Range Radiation 6

Monitor Channels: 1-RE-6290A/B and 2-Re-6290A/B

71124.05 Procedures INC-7082 Digital Channel Operational Test and Channel Calibration 7

Service Water System Effluent Liquid Process Radiation

Monitors Channels: 1-RE-4269, 1-RE-4270, 2-RE-4269, 2-

RE-4270

71124.05 Procedures INC-7090X Digital Channel Operational Test Channel Operational Test 8

and Channel Calibration Plant Vent Stack Wide Range Gas

Monitor Channels: X-RE-5570A, X-RE-5570B

71124.05 Procedures RPI-301 Portable Survey Instruments 16

71124.05 Procedures RPI-800 Control of Radiation Protection Equipment 18

71124.05 Procedures RPI-802 Performance of Source Checks 31

71124.05 Procedures RPI-862 Calibration of the ARGOS SIRIUS Personnel Contamination 15

Monitor and GEM-5 Gamma Exit Monitor

71124.05 Procedures RPI-881 Calibration of Portable Dose Rate Instruments 38

71124.05 Procedures RPI-882 Calibration of Portable Count Rate Instruments 15

71124.05 Procedures RPI-889 Calibration of the Eberline AMS-4 5

71124.05 Procedures STA-619 Administrative Control of the Digital Radiation Monitoring 8

System

71124.05 Procedures STA-658 Radiation Protection Equipment Calibration Program 17

71124.05 Procedures STA-700 Surveillance Frequency Control Program 2

71124.05 Self-Assessments GEL Environmental Laboratory Quality Report: 2022 - First 06/17/2022

Quarter

71124.05 Self-Assessments GEL Environmental Laboratory Quality Report: 2022 - 08/22/2022

Second Quarter

71124.05 Self-Assessments GEL 2021 Annual Quality Assurance Report for the 03/15/2022

Radiological Environmental Monitoring Program (REMP)

71124.05 Self-Assessments EVAL-2021-006 CPNPP Nuclear Oversight Audit Report: Chemistry, 03/31/2022

Environmental, Effluent, and Radioactive Waste

71124.05 Work Orders 5371788 Auxiliary Building Vent Exhaust Radiation Monitor, X-RE- 07/18/2019

5701

71124.05 Work Orders 5826291 South Vent Stack Wide Range Gas Monitor, X-RE-5570A 06/24/2021

71124.05 Work Orders 5833378 Liquid Waste Processing Discharge Radiation Monitor, X- 03/09/2021

RE-5253

71124.05 Work Orders 5901918 Unit 2 Containment EL 905 High Range Radiation Monitor, 10/23/2021

2-RE-6290A

71124.05 Work Orders 5946156 North Vent Stack Discharge Gas Radiation Detector, X-RE- 03/02/2022

5567B

71124.08 Corrective Action CR/TR-YYYY- TR-2021-004459, TR-2021-006713, TR-2021-007297,

Documents NNNN TR-2021-008001, TR-2022-001442, CR-2022-001458

71124.08 Corrective Action CR/TR-YYYY- TR-2022-007709, TR-2022-007934, CR-2022-008665

Documents NNNN

Resulting from

Inspection

71124.08 Miscellaneous 2022 - Unit 2 waste characterization sample for reactor 06/07/2022

coolant system

71124.08 Miscellaneous 2021 - Unit 1 waste characterization sample of the reactor 06/28/2021

coolant system filter

71124.08 Procedures RPI-202 Receipt of Radioactive Material 19

71124.08 Procedures RPI-204 Radioactive Waste Handling 15

71124.08 Procedures RPI-212 Radioactive Source Control 13

71124.08 Procedures RPI-213 Survey and Release of Material 30

71124.08 Procedures RPI-215 Waste Stream Sampling 9

71124.08 Procedures RPI-232 Characterizing Radioactive Material for Shipment 11

71124.08 Procedures RPI-238 Radioactive Material/Waste Shipment Surveys 15

71124.08 Procedures RPI-240 Radioactive Waste Shipments 12

71124.08 Procedures RPI-242 Radioactive Waste Characterization and Classification 10

71124.08 Procedures RPI-243 Packaging Radioactive Waste for Shipment 9

71124.08 Procedures RPI-261 Operating Instructions for the Use of Filter Disposal 6

Containers

71124.08 Procedures RPI-271 Interim Storage of Low-Level Radioactive Waste 3

71124.08 Procedures RPI-273 Rad-Vault/Trailer Inspections and Movement 6

71124.08 Procedures RPI-274 CPNPP Transportation Security Plan 6

71124.08 Procedures RPI-304 Radiological Posting and Labeling 4

71124.08 Procedures STA-709 Radioactive Waste Management Program 10

71124.08 Procedures STA-713 Process Control Program (PCP) 3

71124.08 Shipping Records 2020044 Shipping package and associated documents for shipment 08/18/2020

1. 2020044

71124.08 Shipping Records 2021017 Shipping package and associated documents for shipment 05/19/2021

1. 2021017

71124.08 Shipping Records 2022024 Shipping package and associated documents for shipment 11/02/2022

1. 2022024

71124.08 Shipping Records 2022056 Shipping package and associated documents for shipment 10/18/2022

1. 2022056

71151 Corrective Action CR-YYYY-NNNN 2021-007878

Documents

71151 Corrective Action TR-YYYY-NNNN 2022-003934, 2022-004991

Documents

71151 Miscellaneous 2021 Annual Radiological Effluents Release Report: 04/09/2022

January 1, 2021 - December 31, 2021

71151 Miscellaneous 2022 Quarterly Air Doses Due to Gaseous Releases -

January through September

71151 Miscellaneous 2022 Quarterly Doses to a member of the public due to

Liquid Releases - January through September

71151 Miscellaneous 2022 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 11/22/2022

Cooling Water System

71151 Miscellaneous MSPI Margin Report for Unit 1 Heat Removal System and 11/22/2022

Cooling Water System

71151 Miscellaneous Maximo Limiting Condition for Operation database for AFW, 07/01/2021 -

Service Water, and Component Cooling Water 09/30/2022

71152A Calculations RXE-TA-CPX/0- Analysis of Proposed Auxiliary Feedwater Turbine Drain 0

2 System for CPSES

71152A Corrective Action CR-YYYY-NNNN 2022-3593, 2022-6527, 2021-007070

Documents

71152A Corrective Action TR-YYYY-NNNN 2022-4854, 2021-006947

Documents

71152A Miscellaneous Comanche Peak Unit 2 MSIP High Pressure Box Press 04/2022

Failure Root Cause Analysis Report

71152A Miscellaneous MRS-SSP-2592- Comanche Peak Unit 1 Reactor Vessel Inlet Nozzle to Sale 1

End Weld Mechanical Stress Improvement Process Field

Service Procedure

71152A Miscellaneous MRS-SSP-3538 Comanche Peak Unit 2 (TCX) Reactor Vessel to Nozzle 0

Safe End Weld Mechanical Stress Improvement Process

Field Service Procedure

71152A Miscellaneous TCX-PP000-CN- Comanche Peak Unit 2 Operability Assessment of the 0

PX-000002 Reactor Coolant Piping and Support System due to the

MSIP Tool Failures

71152A Miscellaneous TCX-PP000-TR- Reactor Coolant Loop (RCL) Piping and Support System 0

PX-000001 Operability Assessment due to impact of the MSIP Tool

Failure at Comanche Peak Unit 2 by Westinghouse

71152A Procedures ECE-5.01 Design Control Program

71152A Procedures ECE-5.08 Standard Design Process

71152A Procedures ECE-5.09 Engineering Design Review Process

71152A Procedures NQA-3.14 Control Of Vendor Activities 24

71152A Procedures STA-206 Review Of Vendor Documents and Vendor Technical 25

Manuals

71152A Procedures STA-627 Control Of Planned Outages 15

71152A Procedures STI-604.04 Outage Safety Function Guide 3

71152A Procedures VISTRAOPCO Comanche Peak Nuclear Power Plant Quality Assurance 24

Manual

28