IR 05000445/2024002
| ML24208A053 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/31/2024 |
| From: | Greg Werner NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| Proulx D | |
| References | |
| IR 2024001, IR 2024002 | |
| Download: ML24208A053 (13) | |
Text
July 31, 2024
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INTEGRATED INSPECTION REPORT 05000445/2024002, 05000446/2024002, AND 07200074/2024001
Dear Ken Peters:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On July 11, 2024, the NRC inspectors discussed the results of this inspection with Steven Sewell, Site Vice President, 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 Reactor Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000445, 05000446, 07200074 License Nos. NPF-87, NPF-89
Enclosure:
As stated
Inspection Report
Docket Nos.
05000445, 05000446, and 07200074
License Nos.
Report Nos.
05000445/2024002, 05000446/2024002, and 07200074/2024001
Enterprise Identifier:
I-2024-002-0010 and I-2024-001-0013
Licensee:
Vistra Operations Company, LLC
Facility:
Comanche Peak Nuclear Power Plant, Units 1 and 2, and Independent
Spent Fuel Storage Installation
Location:
Glen Rose, TX 76043
Inspection Dates:
April 1, 2024, to June 30, 2024
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
J. Ellegood, Senior Resident Inspector
J. Freeman, Spent Fuel Storage Inspector
N. Greene, Senior Health Physicist
R. Kopriva, Senior Project Engineer
H. Strittmatter, Resident Inspector
Approved By:
Gregory E. Werner, Chief
Reactor 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
None.
PLANT STATUS
Unit 1 began the inspection period at or near 100 percent power. On May 10, 2024, Unit 1 was shut down for a planned maintenance outage on both main feedwater pumps. On May 16, 2024, the licensee restarted Unit 1 and reached 100 percent power on May 17, 2024. Unit 2 operated at or near 100 percent power for the rest of the inspection period.
Unit 2 remained 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.
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 summer for the following systems:
- on site transformers on June 10, 2024
- electrical switchyard June 12, 2024
- pre-staged temporary air conditioning units on June 13, 2024
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, auxiliary feedwater on May 3, 2024
- (2) Unit 1, train B component cooling water on May 21, 2024
- (3) Unit 1, turbine driven auxiliary feedwater pump on June 7, 2024 (4)interim spent fuel storage facility on June 18, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)fuel handling building, 810' elevation on June 12, 2024 (2)fuel handling building, 838' - 9" elevation on June 21, 2024 (3)fuel handling building, 841' elevation on June 21, 2024 (4)fuel handling building, 860' elevation on June 21, 2024 (5)electrical and control building, 778' elevation on June 27, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding in the Units 1 and 2 electrical equipment rooms, 1-096 and 2-096.
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 reactor start-up on May 16, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance during a simulator training session on steam generator tube leaks on May 8, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
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, anticipated transients without scram mitigation system actuation circuitry related failures on July 31, and November 3, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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, station transformer 2ST outage on April 10, 2024
- (2) Unit 2, main feed pump servo filter swap and replacement on April 18, 2024
- (3) Unit 1, unplanned 1-06 safety chiller outrage on April 23, 2024
- (4) Unit 1, train B component cooling water outage on May 20, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, train B containment spray with incorrect valve stroke time
- (2) Unit 1, failed bolt on the 1-01 emergency diesel generator fuel line.
- (3) Unit 1, ceiling cracks in safeguards building, TR-2024-002145
- (4) Unit 1, safety function of remote shutdown panel with gamma metrics nuclear instrument not re-energizing
- (5) Units 1 and 2, safety chillers with modified filters
- (6) Unit 1, pressurizer spray valve with leak at flange
- (7) Unit 2, containment spray pump 2-02 inboard pump seal leak, condition report 2023-003460
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated a planned Unit 1 maintenance outage to install a design modification on the main feed pumps. The outage took place from May 10 to 17, 2024.
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) (3 Samples)
- (1) Unit 2, containment spray chemical addition tank discharge valve 4755 periodic inspection and lubrication on May 7, 2024
- (2) Unit 2, train B air receiver on May 22, 2024
- (3) Unit 1, residual heat removal flow switch calibration on May 23, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) Unit 1, OPT-216A, train A 6.9KV electrical remote shutdown operability test on April 5, 2024.
- (2) Unit 1, boric acid walkdown on May 13, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 1, train B residual heat removal pump test on May 2, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) a limited participation drill on April 3,
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Shipment Preparation (IP Section 03.04)
- (1) The inspectors observed the preparation of radioactive shipment 2024-19 of dry active waste on May 29,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2023, through March 31, 2024)
- (2) Unit 2 (April 1, 2023, through March 31, 2024)
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)anticipated transients without scram mitigation system actuation circuitry repeated failures.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation Of An ISFSI The inspectors performed a review of the licensees independent spent fuel storage installation (ISFSI) activities to verify compliance with requirements of the Certificate of Compliance 72-1014, License Amendment 7, and the HI-STORM 100 Final Safety Analysis Report (FSAR)
Revision 9. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC regulations.
Operation of An ISFSI===
- (1) The inspectors evaluated the licensees dry cask storage operations, from March 25 to 29, 2024, during an on-site inspection and continued the inspect through an in-office review from March 29 to June 20, 2024. The ISFSI is located approximately 2,900 feet southeast of the Unit 1 reactor building within a separate protected area. The pad was designed to hold 84 HI-STORM 100S (Version B)loaded with the multi-purpose canisters, each with 32 spent fuel assemblies (MPC-32). The pad is designed to store the casks in a 6 by 14 array. At the time of the routine loading inspection, the ISFSI pad contained a total of 55 HI-STORM 100S overpacks. The licensee was in the process of transporting the 56th cask to the ISFSI and loading/processing the 57th cask in the spent fuel building.
During the on-site inspection, the inspectors evaluated and observed the following activities:
- walk-down of the ISFSI haul path
- transportation of the 56th cask on the vertical cask transporter from the spent fuel building to the ISFSI
- fuel assembly selection and placement into the 57th canister
- heavy load lifts using the cask handling crane to remove the transfer cask with the loaded canister from the spent fuel pool to the canister processing area
- welding and non-destructive testing of the lid-to-shell weld
- processing of the spent nuclear fuel for storage, including bulk water removal, forced helium dehydration, and helium backfill operations
- final sealing of the canister, including welding of the vent and port cover plates and non-destructive testing
- heavy load lifts using the cask handling crane to download the canister from the transfer cask into the HI-STORM 100S overpack The inspectors reviewed and evaluated the following documentation during the inspection:
- fuel selection evaluations for the canisters loaded since the last NRC ISFSI inspection, the inspectors reviewed the contents of casks 46-57 against the license's technical specifications for approved contents
- radiation surveys for dose at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for calendar years 2021, 2022, and 2023
- quality assurance program implementation, including recent quality assurance audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations
- compliance to technical specifications for operational surveillance activities and FSAR required annual maintenance activities
- documentation of annual maintenance activities for the sites cask handling crane and special lifting devices
- selected licensee design changes and program changes to the ISFSI performed under the site's 10 CFR 72.48 program
- changes made by the licensee in the site's 10 CFR 72.212 evaluation report from revision 12 to revision 14
- review of the licensee's replacement overhead crane to meet the requirements of ASME NOG-1, Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder), and NUREG 0554, Single-Failure-Proof Cranes for Nuclear Power Plants, for single-failure-proof cranes
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 30, 2024, the inspectors presented the radiation protection inspection results to Steven Sewell, Site Vice President, and other members of the licensee staff.
- On July 2, 2024, the inspectors presented the ISFSI triennial and loading inspection results to Steven Sewell, Site Vice President, and other members of the licensee staff.
- On July 11, 2024, the inspectors presented the integrated inspection results to Steven Sewell, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2022-008037
CR for bent cap screws
CR-2024-000591
CR for missing springs on Fuel building overhead
crane.
ECO-5014-294 _ VDRT-
5888278
Screen for MPC Fuel Basket Support System
using Extruded Aluminum Structures
EV-TR-2023-005759_4
2.48 evaluation of Comanche Peak weather-
related administrative controls at ISFSIs
MPC 55 Prelim CARCASS
Cask Acceptability Report and Comprehensive
Assembly Specifications Supplement for Cask
- 055
Engineering
Evaluations
MPC_053_FINAL_CARCASSa
Cask Acceptability Report and Comprehensive
Assembly Specifications Supplement for Cask
- 053
EVAL-2021-008
CPNPP Nuclear Oversight Audit Report for Core
Performance Engineering and Fuel Management
HI-2002444
Final Safety Analysis Report for HI-STORM 100
CASK System
ISFSI - CPNNP 212 Report
Comanche Peak Nuclear Power Plant 10 CFR 2.212 Evaluation Report Docket Number 72-74
Pages from OPT-102A-1-2022
Storage module vent surveillance procedure and
documentation for the surveillances
QVE-0454.1. A_54
QA surveillance activities performed from
January 1 - April 30, 2022, by resident inspectors
at the HMD/Orrvilon and Holtec Camden AMD
facilities for
the manufacture of Dry Cask Spent Fuel Storage
System equipment for Luminant.
Miscellaneous
VDRT-6035293
Certificate of Compliance for Spent Fuel Storage
Casks 72-1014 HI-STORM 100
DCS-201_R13
Transporting loaded and unloaded HI-STORM
60855
Procedures
DCS-301-R12
Dry Cask Storage Equipment Malfunction, Loop,
LOCA, and Contingencies Guidance
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
GAM Results from 2021 to
23
TLD dose rates for each quarter to demonstrate
FCR 72.104 compliance.
Radiation
Surveys
M-20230126-4
Radiation surveys of the ISFSI pad
01/26/2023
Maintenance/inspection of Fuel Building
Overhead Crane X-01
Work Orders
WO-22-95159_1
Inspection of HI-TRAC 125D Transfer Cask Lift
Yoke Ancillary #702
OPT-206A-3
TDAFW Pump Valve Position Verification Data
Sheet
SOP-304A-AF-VO1
Train A MDAFW Pump Lineup
SOP-304A-AF-VO3
TDAFW Pump Lineup
Procedures
SOP-304A-AF-VO4
CST Lineup
Fire Plans
FPI-501
electrical and control building elevation 778'
Fire Protection Report
FPI-602
Fire Preplan Instruction Manual, Fuel Handling
Building, Elev. 810'
FPI-603
Fire Preplan Instruction Manual, Fuel Handling
Building, Elev. 838" - 9"
Miscellaneous
FPI-604
Fire Preplan Instruction Manual, Fuel Handling
Building, Elev. 860'
210-063-0074
Suppression System Flooding Analysis
R&R-PN-021
Internal Flood Analysis
Calculations
SI-CA-0000-0062
Unit 1 Safeguards Building Flooding Analysis
Miscellaneous
LO44.BBS.026
Indian Point 2 Steam Generator Tube Leak
04/10/2024
ABN-106
High Secondary Activity
Steam Generator Tube Rupture
IPO-003A
Power Operations
IPO-005A
Plant Cooldown from Hot Standby to Cold
Shutdown
Procedures
SOP-102A
Residual Heat Removal System
Guarded Equipment Posting for 2ST Outage
04/10/2024
Miscellaneous
Guarded Equipment Postings for Inoperable
Safety Chiller 1-06
04/22/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
STI-600.01
Protecting Plant Equipment and Sensitive
Equipment Controls
Corrective
Action
Documents
CR-YYYY-NNNN
2010-9232, 2016-3101, 2023-4276, 2023-7273,
24-2119, 2014-9418, 2024-0774, 2020-0934,
24-2731
OPT-205A-4
Train B containment Spray Valve data Sheet
Procedures
STI-744.09
Structural Monitoring Inspection Guide
Work Orders
5682592
Miscellaneous
LOB8C24LR1
Unit 1 Downpower JITT Tabletop (MFP Repairs)
Corrective
Action
Documents
Resulting from
Inspection
IR-YYYY-NNNN
24-002168
MSE-P0-8349
Limitorque Actuator Periodic Electrical and
Mechanical Inspection
OPT-203A
Residual Heat Removal System
OPT-216A
Remote Shutdown Operability Test
Procedures
SOP-102A
Residual Heat Removal System
2-5226207
Major inspection of 2-LV-4755-MO
05/07/2024
Work Orders
24-86000
RHR Pump 1-01 Operability Test
05/02/2024
Shipping
Records
24-19
UN3321, Radioactive Material, low specific
activity (LSA-II), 7, dry active waste
05/29/2024
Corrective
Action
Documents
CR-YYYY-NNNN
2003-000377, 2007-003161, 2011-007126,
2012-00803, 2013-011737, 2014-000193,
2015-004134, 2015-012254, 2016-008844,
2019-004745, 2020-008429, 2010-005373,
2011-003954, 2014-007548, 2017-006123