IR 05000445/2023001

Integrated Inspection Report 05000445/2023001 and 05000446/2023001

ML23102A149
Person / Time
Site:	Comanche Peak
Issue date:	04/13/2023
From:	Greg Werner NRC/RGN-IV/DORS/PBB
To:	Peters K Vistra Operating Co. (VistraOpCo)
References
IR 2023001
Download: ML23102A149 (12)

Text

April 13, 2023

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2023001 AND 05000446/2023001

Dear Ken Peters:

On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 13, 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.

No findings or violations of more than minor significance were identified during this inspection.

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 Proulx, David signing on behalf of Werner, Gregory on 04/13/23

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000445 and 05000446

License Numbers:

NPF-87 and NPF-89

Report Numbers:

05000445/2023001 and 05000446/2023001

Enterprise Identifier:

I-2023-001-0004

Licensee:

VISTRA Operations Company, LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, Texas 76043

Inspection Dates:

Inspectors:

Approved By:

January 1, 2023 to March 31, 2023

N. Day, Resident Inspector

J. Ellegood, Senior Resident Inspector

D. Proulx, Senior Project Engineer

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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000445/2022-001-00 Reactor Trip Due to Turbine Trip Greater Than 50%

Power 71153 Closed

PLANT STATUS

Unit 1 began the inspection period at or near 100 percent power. On March 11, 2023, operators reduced power to about 65 percent power for turbine valve testing. Operators returned the unit to 100 percent power the same day. On March 22, 2023, operators reduced power to about 86 percent based on grid power demand and returned to 100 percent the same day. Unit 1 operated at or near 100 percent for the remainder of the inspection period.

Unit 2 operated at or near 100 percent power for the entire 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1)auxiliary building train B common electrical loads on February 15, 2023

(2) Unit 2, diesel generator 2-01 fuel oil transfer system on February 28, 2023 (3)spent fuel pool cooling pump X-01 on March 7, 2023

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

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 auxiliary feedwater system on February 7, 2023.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 1, emergency train A emergency switchgear room on February 21, 2023

(2) Unit 1, high pressure feedwater high pressure chemical injection room on February 22, 2023

(3) Unit 2, electrical equipment room on March 13, 2023

(4) Unit 2, train A safeguards bus room on March 13, 2023

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the:

control building elevation 792 containing safety related batteries, inverters, and uninterruptible power supplies for both units.

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 Unit 1 train A solid state protection system testing on February 6, 2023.

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

(1)licensed operator requalification training during a simulated electrohydraulic pump trip on January 20, 2023

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Unit 1, circulating water

(2) Unit 2, circulating water

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, yellow risk due to service water pump 2-02 borescope inspection during thunder sleet storm on January 31, 2023

(2) Unit 1, troubleshooting of feedwater heater 2A level controller on March 2, 2023 (3)yellow risk during spent fuel pool pump X-02 maintenance

(4) Unit 1, troubleshooting and repair of the main steam line pressure channel 525A on March 7, 2023

(5) Unit 2, emergency diesel generator troubleshooting 2-01 during work order 23-118164 on March 15, 2023

(6) Unit 1, 150-megawatt electric down power to 88 percent power for grid conditions on March 22, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

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

(1) Unit 2 low indicated frequency on 118 VAC non-safeguards inverter IV2C3 per TR-2023-000138

(2) Unit 1, emergency diesel generator 1-01 due to frequency fluctuations per condition report 2023-000265 station transformer XST2 with high impedance per condition report 2023-000941

(4) Unit 2 through wall leak in component cooling water tank discharge line per TR-2023-1473

(5) Unit 2, diesel generator 2-01 with air leak in pneumatic control board

(6) Units 1 and 2, ASME relief valves not tested per inservice testing requirements per condition report 2022-000303

71111.24 - Testing and Maintenance of Equipment Important to Risk

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

Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)

(1) Unit 1, motor driven auxiliary feedwater pump 1-01 to steam generator 1-01 flow control valve stroke testing following air control system work per work order 6015483 on January 9, 2023

(2) Unit 2, train B solid state protection system testing on per work order 22-520884 March 21, 2023

(3) Unit 1, turbine driven feedwater pump flow control valve to steam generator 3 per work order 21-731918 on February 9, 2023

(4) Unit 1, turbine driven feedwater pump flow control valve to steam generator 4 per work order 21-731785 on February 9, 2023

(5) Unit 1, containment particulate, iodine and gaseous radiation monitor per work order 22-570019 on February 21 and March 21, 2023

(6) Unit 2, emergency diesel generator 2-01 extended run and hot web deflection tests per work order 5648161 on March 16, 2023

Surveillance Testing (IP Section 03.01) (4 Samples)

(1) Unit 2, emergency diesel generator fuel oil transfer pump 2-03 for VT-2 visual pressure inspection per work orders 22-53854 and 5948069 on January 23, 2023

(2) Unit 1, reactor trip breaker A testing per work order 22-429886 on March 6, 2023

(3) Unit 1, residual heat removal heat exchanger 1-01 per work order 21-625132 on March 8, 2023

(4) Unit 2, train B sequencer under-voltage sequencer per work order 21-672057

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

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

(1) Unit 1 (January 1, 2022, through December 31, 2022)

(2) Unit 2 (January 1, 2022, through December 31, 2022)

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

(1) Unit 1 (January 1, 2022, through December 31, 2022)

(2) Unit 2 (January 1, 2022, through December 31, 2022)

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

(1) Unit 1 (January 1, 2022, through December 31, 2022)

(2) Unit 2 (January 1, 2022, through December 31, 2022)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

(1) The inspectors accompanied multiple nuclear equipment operators during routine rounds to assess operator proficiency. No findings of significance were identified.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP section 03.02)

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

(1) LER 05000455/2022-001-00, Reactor Trip Due to Turbine Trip Greater Than 50%

Power, ADAMS Accession No. ML22307A292. The inspection conclusions associated with this LER are documented in Inspection Report 05000455/2023010 as FIN 05000445/2023010-01. This LER is Closed.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On April 13, 2023, the inspectors presented the integrated inspection results to Al Marzloff, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Drawings

M1-0202

Flow Diagram Main Steam Reheat and Steam Dump

CP-2

71111.04

Drawings

M1-0206

Flow Diagram Auxiliary Feedwater System

CP-21

71111.04

Miscellaneous

CP22-1094

Spent Furl Pool Pump X-01 Clearance

03/07/2022

71111.04

Procedures

OPT-206A

AFW System

71111.04

Procedures

SOP-304A

Auxiliary Feedwater System

71111.04

Procedures

SOP-506

Spent Fuel Pool Cooling and Cleanup System

71111.04

Procedures

SOP-608A

20,208.208/120 and 120/240 VAC Distribution System

71111.04

Procedures

SOP-610B

Diesel Generator and Fuel Oil transfer System

71111.05

Drawings

M2-1921

Fire Hazard Analysis Unit 2 Containment and Safeguards

Buildings Plans at 808'-0" and 810'-6"

71111.05

Fire Plans

FPI-103A

UNIT 1 SAFEGUARDS BUILDING ELEVATION 810'-6" RAD,

PEN. AREA & ELEC. EQUIP. RM

71111.05

Fire Plans

FPI-107A

U1 SAFEGUARDS BUILDING, ELEVATION 852'-6"

ELECTRICAL EQUIPMENT AREA & FW PENETRATION

AREA

71111.05

Procedures

FPI-107B

U2 Safeguards Elev. 852' Electrical Equipment Area and

Feedwater Penetration Area

71111.06

Calculations

SI-CA-0803-3381

SI-CA-0000-0664

SI-CA-0000-0921

218-PR-0152

SI-CA-0000-4005

Control Building 792-foot elevation flooding calculations

71111.12

Miscellaneous

Unit 1 and 2 Circulating Water System Health Reports and

Maintenance Rule Program

71111.13

Procedures

SOP-602

138 KV and 345 KV Transformers and Switchyard Air Switches

71111.13

Procedures

STI-600.01

Protecting Plant Equipment and Sensitive Equipment Controls

71111.15

Drawings

M1-0233

Flow Diagram Station Service Water

CP-45

71111.15

Drawings

M2-0231

Flow Diagram Component Cooling Water System

71111.15

Drawings

M2-0231A

Flow Diagram Component Cooling Water System

71111.15

Drawings

M2-0326A

Flow Diagram Vents and Drains System Safeguards Building.

71111.15

Drawings

M2-2730

Diesel Generator Engine Start Stop Pneumatic Control

Schematic

CP-3

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.15

Procedures

IST-100

Pump and Valve Inservice Testing Program

71111.15

Procedures

IST-312

Inservice Testing of Relief Valves

71111.24

Procedures

EPG-725

Pressure Testing

71111.24

Procedures

NDE4.02

ASME Section XI Visual Examination VT-2

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