IR 05000445/2024003

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Integrated Inspection Report 05000445/2024003 and 05000446/2024003
ML24298A116
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/30/2024
From: Ami Agrawal
NRC/RGN-IV/DORS/PBB
To: Peters K
Vistra Operations Company
References
IR 2024003
Download: ML24298A116 (19)


Text

October 30, 2024

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2024003 AND 05000446/2024003

Dear Ken Peters:

On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 10, 2024, the NRC inspectors discussed the results of this inspection with Heather Winn, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. None of these findings involved a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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, Ami N. Agrawal, Chief Reactor 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, 05000446

License Numbers:

NPF-87, NPF-89

Report Numbers:

05000445/2024003 and 05000446/2024003

Enterprise Identifier:

I-2024-003-0006

Licensee:

Vistra Operations Company LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, TX 76043

Inspection Dates:

July 1 to September 30, 2024

Inspectors:

J. Ellegood, Senior Resident Inspector

S. Hedger, Senior Emergency Preparedness Inspector

P. Nwafor, Project Engineer

H. Strittmatter, Resident Inspector

Approved By:

Ami N. Agrawal, 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

Failure to Identify Post-Maintenance Testing for a Modification Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000445,05000446/2024003-01 Open/Closed

[P.2] -

Evaluation 71152A The inspectors reviewed a self-revealed Green finding without a violation that occurred on September 4, 2020, when the licensee approved a modification to the main feed pump control system. Specifically, the licensee approved a modification to transition from the Mark V control system to the T3000 control system that did not include dynamic testing of the modification. This omission led to acceptance of a control system that was not able to control pump speed to preclude a reactor trip on the loss of a main feed pump.

Failure to Translate Design Input Requirements into the Final Design Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000445,05000446/2024003-02 Open/Closed

[H.12] - Avoid Complacency 71152A The inspectors reviewed a self-revealed Green finding without a violation that occurred on September 4, 2020, and March 14, 2024, when the licensee failed to identify and incorporate design inputs into the final design. Specifically, the design modification for the T3000 did not incorporate power requirements for the servo valve and the amplifier addition mod did not incorporate vendor requirements for shielded cabling and ground separation.

Additional Tracking Items

None.

PLANT STATUS

Units 1 and 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 onsite 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

71111.04 - 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) Unit 1, train A motor-driven auxiliary feedwater pump on August 27, 2024

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 battery/UPS systems on August 14-15, 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)component cooling water on September 23, 2024

(2) Unit 1 main feed and steam enclosures on September 23, 2024
(3) Unit 2 main feed and steam enclosures on September 23, 2024
(4) Unit 1 train B switch gear on September 27, 2024
(5) Unit 2 train B switchgear on September 27, 2024

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on September 17, 2024.

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 high trip risk activity switching Unit 1 circulating water lube water to a temporary strainer on July 24, 2024.

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

(1) The inspectors observed and evaluated a licensed operator requalification training simulator exam session on July 24, 2024.

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 remain capable of performing their intended function:

(1)instrument air system following entry into a(1) status

(2) Unit 1, chemical and volume control system filter housing leaks

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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)unplanned safety chiller inoperability and planned yellow risk for emergency diesel generator testing for the week of September 9, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1)service water with electrical box secured by ratchet straps (2)untested thermal relief valves on safety-related equipment (3)inverter IV1EC1 current fluctuations

(4) Unit 2, channel 1 N-16 with high voltage out of specification

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) (9 Samples)

(1)turbine-driven auxiliary feed water pump discharge to SG 2-01 flow control valve elastomer replacement on July 10, 2024 (2)fire panel power supply replacement on July 11, 2024 (3)containment spray pumps 1-01 and 1-03 bearing cooler clean/inspection and oil replacement on July 30, 2024

(4) Unit 2, train B switchgear fire protection deluge valve diaphragm replacement on August 15, 2024 (5)diesel generator annunciator power supply replacement on August 21, 2024
(6) Unit 1, IV1EC1 static switch control board replacement on August 28, 2024, under Work Order 22-527489
(7) Unit 2, locked high radiation area ladder barrier on September 17, 2024
(8) Unit 2, train C non-safeguards 125 VDC battery charger, BC2D2, component replacement, testing, and calibration on September 9 - 10, 2024
(9) Unit 1, circulating water lube water strainer replacement on September 14, 2024

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, visual examination (VT-2) of the residual heat exchanger on August 13, 2024

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1)safety injection pump 2-02 inservice test on August 6, 2024

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1)observed quarterly inspection of multipurpose high flow flex pumps on July 18 and 22, 2024

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 November 12, 2022, and September 14, 2024.

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 November 12, 2022, and September 14, 2024. 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 10 CFR 50.54(q) emergency plan change process and practices between November 12, 2022, and September 14, 2024. The evaluation reviewed screenings and evaluations documenting implementation of the process. The reviews of the change process documentation do 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 November 12, 2022, and September 14, 2024. The evaluation reviewed evidence of completing various emergency plan commitments, the conduct of drills and exercises, licensee audits and assessments; and the maintenance of equipment important to emergency preparedness.

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) a drill involving a steam generator tube rupture on August 7,

OTHER ACTIVITIES - BASELINE

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

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1 (July 1, 2023, through June 30, 2024)
(2) Unit 2 (July 1, 2023, through June 30, 2024)

EP01: Drill/Exercise Performance Sample (IP Section 02.12) (1 Sample)

(1) July 1, 2023, through June 30, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
(1) July 1, 2023, through June 30, 2024

EP03: Alert And Notification System Reliability Sample (IP Section 02.14) (1 Sample)

(1) July 1, 2023, through June 30, 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)emergency operating procedure 3.0 adequacy to prevent overfilling of the pressurizer (2)plant trip due to loss of main feedwater pump

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program to identify potential trends in the licensee's review and implementation of nuclear safety advisory letters from Westinghouse on September 13 and 16,

INSPECTION RESULTS

Failure to Identify Post-Maintenance Testing for a Modification Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000445,05000446/2024003-01 Open/Closed

[P.2] -

Evaluation 71152A The inspectors reviewed a self-revealed Green finding without a violation that occurred on September 4, 2020, when the licensee approved a modification to the main feed pump control system. Specifically, the licensee approved a modification to transition from the Mark V control system to the T3000 control system that did not include dynamic testing of the modification. This omission led to acceptance of a control system that was not able to control pump speed to preclude a reactor trip on the loss of a main feed pump.

Description:

The licensee contracted with Siemens to develop a modification to the main feed pump control system in 2016. The licensee, with vendor support, installed the system for Unit 1 during 1RF22 (May 2022) and for Unit 2 during 2RF20 (May 2023). The new control system was designated the T3000. Following installation of the modification, the site experienced degraded performance of all four main feed pumps. Issues included feed pump speed oscillations, poor servo valve performance requiring replacements, and feed pump trips. These issues led to a Unit 1 trip on June 16, 2023, and a Unit 2 trip on March 12 and 17, 2024. In addition to control system issues, the pumps have a history of water intrusion into the lubricating/control oil system. The water intrusion has resulted in corrosion products inhibiting proper operation of the mechanical portion of the main feed pump.

During the design process, the licensee relied heavily on the vendor, Siemens, to provide the necessary expertise in designing system controls. In addition, the licensee contracted a third-party reviewer to provide a critical review of the design. Although the third-party reviewer identified that the bases to conclude the T3000 would behave as the predecessor Mark V system was weak, the comments were not addressed prior to site acceptance of the design nor before acceptance of the as-installed modification. Part of the third-party comments addressed the quality and detail of the site's acceptance testing procedure. However, these comments were not addressed. Licensee Procedure IP-ENG-001, Standard Design Process, states post-maintenance testing should validate performance through testing or demonstration.

In January 2024, engineering identified degraded performance of the Unit 2 A main feed pump. On February 2, the licensee reduced power on Unit 2 and replaced the servo valve. At the time of the replacement, the licensee attributed the performance to water intrusion and the impacts of corrosion products on servo performance. However, inspection of the servo did not support this attribution. Further investigation by the licensee revealed that the T3000 generated a +/- 30 mA signal but the servo had an operating range of +/- 250 mA. On March 12, 2024, the licensee performed a servo valve oil filter swap for the Unit 2 A main feed pump. Following the swap, the feed pump performance degraded. Control room operators initiated a manual runback to 700 MWe. The B main feed pump did not ramp up speed as designed. As steam generator level lowered to the Lo/Lo set point, operators determined a manual trip was required; however, an automatic trip occurred prior to insertion of the manual trip.

During the forced outage, the licensee installed amplifiers to match T3000 output to servo capabilities. However, this modification also led to a plant trip which is addressed as a separate finding in this report.

Corrective Actions: The licensee added current amplifiers to address the incompatibility between the T3000 output amperage and required amperage for the servo controlling feed pump speed. The licensee performed dynamic testing following amplifier addition.

Corrective Action References: CR-2024-1805

Performance Assessment:

Performance Deficiency: The licensee's failure to establish a post-maintenance test that would ensure affected equipment was not adversely affected was a performance deficiency. Licensee Procedure ECE-5.08, Standard Design Process, revision 3, appendix 5, step 5.9, states the installer/operations/engineer should ensure that specified post-modification testing will verify that affected equipment has not been adversely affected by the modification. However, the design failed to specify dynamic testing that would validate system response. Weaknesses in specified post-modification testing were identified by the third-party reviewer but not addressed.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate post-maintenance test did not validate that the design would control the main feed pumps as required. This led to multiple plant trips.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as Green in accordance with exhibit 1 of Appendix A to IMC 0609 question B. The issue caused a reactor trip but did not cause a loss of mitigating equipment.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, following installation of the T3000 modification, there were precursor indications of degraded main feed pump performance. These indications were not evaluated thoroughly to determine the cause.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Failure to Translate Design Input Requirements into the Final Design Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000445,05000446/2024003-02 Open/Closed

[H.12] - Avoid Complacency 71152A The inspectors reviewed a self-revealed Green finding without a violation that occurred on September 4, 2020, and on March 14, 2024, when the licensee failed to identify and incorporate design inputs into the final design. Specifically, the design modification for the T3000 did not incorporate power requirements for the servo valve and the amplifier addition mod did not incorporate vendor requirements for shielded cabling and ground separation.

Description:

The licensee contracted with Siemens to develop a modification to the main feed pump control system in 2016. The licensee, with vendor support, installed the system for Unit 1 during 1RF22 (May 2022) and for Unit 2 during 2RF20 (May 2023). The new control system was designated the T3000. Following installation of the modification, the site experienced degraded performance of all four main feed pumps. Issues included feed pump speed oscillations, poor servo valve performance, and feed pump trips. These issues led to a Unit 1 trip on June 16, 2023, and a Unit 2 trip on March 12 and 17, 2024. In addition to control system issues, the pumps have a history of water intrusion into the lubricating/control oil system. The water intrusion has resulted in corrosion products inhibiting proper operation of the mechanical portion of the main feed pump. Following the plant trip on March 12, 2024, the licensee installed an amplifier on the output of the T3000 to address a design issue.

However, the modification also included a design error.

The original design for the T3000 did not include adequate current output from the T3000 to drive the servo. In February 2024, the licensee determined that the T3000 generated a

+/- 30 mA signal but the servo had an operating range of +/- 250 mA. The licensee determined in a root cause analysis that the T3000 design neglected to address the critical design parameter related to servo current requirements. The analysis documented that although the servo was included as a design input, critical characteristics related to the operating current range were not included. In addition, the third-party review identified technical rigor issues; however, these issues were not addressed.

With respect to modification to install a current amplifier, the licensee did not address amplifier vendor specifications to use shielded cabling and to use a star grounding pattern.

These omissions led to noise on the output signal and diagnostic alarms. Ultimately, the Unit 2 B main feed pump tripped causing a subsequent insertion of a manual trip. In the root cause, the licensee documented the omission of these specifications from the design and that these omissions led to pump trip and subsequent unit trip.

Corrective Actions: The licensee added current amplifiers to address the omissions in the T3000 modifications. For the amplifier error, the licensee required the grounding system for the amplifiers prior to unit restart.

Corrective Action References: CR-2024-1805

Performance Assessment:

Performance Deficiency: The licensee's failure to ensure design inputs and bounding technical requirements were properly translated into design was a performance deficiency. Licensee Procedure ECE 5.08, Standard Design Process, revisions 3 and 4, require the design to meet design inputs and technical requirements. For both the T3000 design and amplifier addition, the licensee failed to do so.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the designers did not ensure design inputs and technical requirements were properly translated into the final design.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as Green in accordance with exhibit 1 of Appendix A to IMC 0609 question B. The issue caused a reactor trip but did not cause a loss of mitigating equipment.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. As documented in the root cause, the licensee made assumptions regarding the adequacy of the design.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 8, 2024, the inspectors presented the emergency preparedness program inspection results to Charles O'Dell, Director, Organizational Effectiveness, and other members of the licensee staff.
  • On October 10, 2024, the inspectors presented the integrated inspection results to Heather Winn, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

OPT-215-11

Unit 1 Class 1E Electrical System Operability Data Sheet

OPT-215-21

Unit 2 Class 1E Electrical System Operability Data Sheet

71111.04

Procedures

71111.04

SOP-304A-AF-

V01

Unit 1 Train A Motor Driven Pump Lineup

Miscellaneous

71111.05

Fire Drill Package for 778' Secondary Sample Room

09/17/2024

FPI-107A

Unit 1 Safeguards Building Elevation 852'-6" Electrical

Equipment Area and FW Penetration Area

FPI-107B

Unit 2 Safeguards Building Elevation 852'-6" Electrical

Equipment Area and FW Penetration Area

FPI-401

Auxiliary Building 790' Fire Pre-plan

71111.05

Procedures

71111.05

FPI-501

Electrical and Control Building Elevation 778'-0"

CR-YYYY-NNNN

23-5131, 2023-6269, 2023-7570, 2024-2000, 2024-2003,

24-2010, 2024-2041

71111.12

Corrective Action

Documents

71111.12

TR-YYYY-NNNN

24-2053

71111.13

Miscellaneous

71111.13

Guarded Equipment Posting Log for WO 23-135879

09/10/2024

71111.15

Corrective Action

Documents

71111.15

CR-YYYY-NNNN

22-0303, 2022-1609, 2024-5165

Corrective Action

Documents

71111.24

YYYY-NNNN

2014-6572, 2024-4137

MSM-P0-7308

Containment Spray Pump Lube Oil Cooler Maintenance

OPT-204B

SI System

Procedures

71111.24

OPT-603B

TDAFW Accumulator Check Valve Leak Test

24-253003, 23-21800, 24-212112, 22-78400, 22-86828

71111.24

Work Orders

71111.24

5974223, 4865885

71114.02

Corrective Action

Documents

71114.02

Condition Reports

(CR-)

22-008723, 2023-001466, 2023-002171, 2023-008490,

23-008607

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Miscellaneous

71114.02

Comanche Peak Nuclear Power Plant, Alert and Notification

System Design Report

STA-662

Administrative Control of the Siren System

Procedures

71114.02

Staff Guideline

2

Alert and Notification System Surveillance

Work Orders

71114.02

Work Order

Number

2-385578, 23-118099

Corrective Action

Documents

71114.03

Tracking Report

(TR-)

22-008171, 2023-004091, 2023-004093, 2024-001480,

204-003418

Quarterly Augmentation Verification Results - 4th Quarter,

11/10/2022

11/16/2022

Quarterly Augmentation Verification Results - 1st Quarter,

03/13/2023

03/15/2023

Quarterly Augmentation Verification Results - 2nd Quarter,

05/31/2023

06/05/2023

Quarterly Augmentation Verification Results - 3rd Quarter,

09/8/2023

09/12/2023

Quarterly Augmentation Verification Results - 4th Quarter,

10/11/20203

10/17/2023

Quarterly Augmentation Verification Results - 1st Quarter,

03/5/2024

03/06/2024

Quarterly Augmentation Verification Results - 2nd Quarter,

06/3/2024

06/05/2024

Comanche Peak On-Shift Staffing Analysis

2/21/2012,

04/02/2024

Miscellaneous

71114.03

Task #366

Callout

05/21/2019

71114.03

Procedures

71114.03

SG-005

Quarterly Augmentation Verification of the Emergency

Response Organization (ERO)

Corrective Action

Documents

71114.04

Condition Reports

(CR-)

22-008425

Comanche Peak On-Shift Staffing Analysis

71114.04

Miscellaneous

71114.04

Activity No. AI-

CFR 50.54(q)(3) Screening - Document TRA-105

05/13/2024

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

TR-2024-000402-

Changes

Activity No. AI-

TR-2024-003402-

CFR 50.54(q)(3) Screening - Changes to Documents

Procedures EPP-123, EPP-123-1, and EPP-123-2

06/25/2024

Activity No. EV-

TR-2023-000264-

CFR 50.54(q)(3) Screening and Evaluation - On-Shift

Staffing Analysis, Revision

04/01/2024

CP-

201800662/TXX-

18066

Comanche Peak Nuclear Power Plant, Docket No. 50-445,

50-446, and 72-74; License Amendment Request 18-002 for

Revision of the Emergency Plan

10/31/2018

EPP-123

CFR 50.54(q) Screening and Evaluation of Changes to

Emergency Plan Documentation

3, 4

Procedures

71114.04

TRA-105

Emergency Preparedness Training

Condition Reports

(CR-)

22-008423, 2022-008456, 2023-001209, 2023-001394,

23-002173, 2023-002252, 2023-005015, 2023-005115,

23-005016, 2023-006050, 2023-006961, 2024-000399,

24-000788, 2024-001178, 2024-002608, 2024-005204

Corrective Action

Documents

71114.05

Tracking Report

(TR-)

22-002019-4

Plan of Instruction for Training of Local Officials for Fixed

Nuclear Facility Accident Response, December 14, 2023

01/25/2024

22 Fire Drill with Offsite Participation, 11/08/22

11/16/2022

23 Fire Drill with Offsite Participation (AI-TR-2023-002627-

2)

2/7/2023

Health Physics Drill, 6/21/2023

07/13/2023

Semiannual Health Physics Drill, 11/29/2023

01/22/2024

Health Physics Drill, 5/8/2024

05/15/2024

Offsite Radiological Monitoring Drill, 8/2/2023

08/08/2023

Offsite Radiological Monitoring Drill, 1/30/24

2/05/2024

Comanche Peak Nuclear Power Plant, Emergency

Response Organization, Exercise Report - Red Team -

November 30, 2022

01/11/2023

71114.05

Miscellaneous

71114.05

Comanche Peak Nuclear Power Plant, Emergency

05/04/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Response Organization, Exercise Report - Blue Team -

February 22, 2023

Comanche Peak Nuclear Power Plant, Emergency

Response Organization, Exercise Report - Gold Team - June

21, 2023

06/21/2023

Comanche Peak Nuclear Power Plant, Emergency

Response Organization, Exercise Report - Gold Team - July

26, 2023

07/26/2023

Comanche Peak Nuclear Power Plant, Emergency

Response Organization, Exercise Report - Red Team -

September 27, 2023

09/27/2023

Comanche Peak Nuclear Power Plant, Emergency

Response Organization, Exercise Report - Blue Team -

February 14, 2024

08/22/2024

CP-202300227

Annual Review of Comanche Peak Nuclear Power Plant

Emergency Action Levels

05/17/2023

CPP-202200246

Comanche Peak Nuclear Power Plant (CPNPP), Docket

Nos. 50-445, 50-446, and 72-74; Comanche Peak 2022

Evacuation Time Estimate Analysis

08/25/2022

EVAL-2023-001

CPNPP Nuclear Oversight Audit Report, Emergency

Preparedness, Audit Dates: 01/26/2023 - 04/06/2023

05/06/2023

KLD TR-1324

Comanche Peak Nuclear Power Plant 2023 Population

Update Analysis

05/15/2023

KLD TR-1410

Comanche Peak Nuclear Power Plant 2024 Population

Update Analysis

05/14/2024

TR-2024-000037

Assessment of Emergency Preparedness Program Elements

to Determine if 10 CFR 50.54(t) Audit is Required in 2024

2/26/2024

Tracking Report

(TR-)

24-001149

ABN-907

Acts of Nature

EPP-100

Maintaining Emergency Preparedness

EPP-109

Duties and Responsibilities of the Emergency

Coordinator/Recovery Manager

Procedures

71114.05

EPP-121

Re-entry, Recovery, and Closeout

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EPP-304

Protective Action Recommendations

SG-003

Staff Guideline 003, Emergency Response Data System

(ERDS) Test Program

SG-014

Staff Guideline 014, Emergency Planning Master Guideline

2, 13

SG-021

Staff Guideline 021, Management of Emergency Drill and

Exercise Program

SG-025

Staff Guideline 025, Evaluation and Critique of Exercises

STA-421

Control of Issue Reports

STA-422

Corrective Action Program

STI-421.02

Issue Report Reviews

STI-433.01

Maintaining Equipment Important to Emergency Response

Work Orders

71114.05

Work Order

Number

2-580800, 23-160710, 24-267048

71114.06

Miscellaneous

71114.06

August 7, 2024 Gold Team Drill Scenario Package

07/31/2024

Corrective Action

Documents

71151

Condition Reports

(CR-)

23-006517, 2023-007099, 2024-001757, 2024-003387,

24-003647

LO44.BBS.006

Loss of All AC - APDG Restoration, Simulator Exercise

Guide

LO44.BBS.007

BOS/SOER 99-1 Simulator Exercise Guide

LO44.BBS.011

ATWT Simulator Exercise Guide

Miscellaneous

71151

LO47.E23.PRA

Cycle 23-5 Practice Scenario

71151

Procedures

71151

Staff Guideline

2

Alert and Notification System Surveillance

71152A

Corrective Action

Documents

71152A

CR-YYYY-NNNN

23-4448

Corrective Action

Documents

71152S

YYYY-NNNN

20-1247, 2019-6855, 2020-6878, 2024-04603, 2020-2889,

2019-9336

71152S

Work Orders

71152S

5998393, 5668060