IR 05000445/2024004

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Integrated Inspection Report 05000445/2024004 and 05000446/2024004
ML25037A139
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/11/2025
From: Ami Agrawal
NRC/RGN-IV/DORS/PBB
To: Peters K
Vistra Operating Co. (VistraOpCo)
References
IR 2024004
Download: ML25037A139 (30)


Text

February 11, 2025

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2024004 AND 05000446/2024004

Dear Ken Peters:

On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 23, 2025, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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, Ami N. Agrawal, Chief Reactor Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000445 and 05000446

License Numbers:

NPF-87 and NPF-89

Report Numbers:

05000445/2024004 and 05000446/2024004

Enterprise Identifier:

I-2024-004-0004

Licensee:

Vistra Operations Company LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, TX 76043

Inspection Dates:

October 1 to December 31, 2024

Inspectors:

B. Baca, Health Physicist

M. Bloodgood, Senior Project Engineer

J. Drake, Senior Reactor Inspector

J. Ellegood, Senior Resident Inspector

L. Flores, Resident Inspector

N. Greene, Senior Health Physicist

S. Hedger, Senior Emergency Preparedness Inspector

J. Kirkland, Senior Operations Engineer

J. Mejia, Reactor Inspector

P. Nwafor, Project Engineer

H. Strittmatter, Resident Inspector

J. Vera, Senior Resident Inspector

D. You, Operations Engineer

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

Non-Functional Fire Barrier Between Auxiliary and Unit 2 Safeguards Buildings Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000446/2024004-01 Open/Closed

[P.3] -

Resolution 71111.05 The inspectors identified a Green finding and associated non-cited violation of License Condition 2.G for failing to maintain a 3-hour fire barrier intact. The inspectors identified that a normally open, automatically-closing fire door that separates the auxiliary building and Unit 2 safeguards building at the 810 elevation, was unable to close without assistance due to interference with the flooring.

Failure to Perform ASME Examination of Unit 2 Containment Moisture Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000446/2024004-02 Open/Closed None (NPP)71111.08P The inspectors identified a Green non-cited violation of Title 10 Code of Federal Regulations 50.55a(g)(4), Inservice inspection standards requirement for operating plants, for the licensees failure to conduct general visual examinations of the moisture barriers to the containment liner in accordance with Subsection IWE of ASME Boiler Pressure Vessel Code,

Section XI. Specifically, the licensee failed to perform visual examinations of the sealant applied to the expansion joint between the concrete-to-metal containment liner of Unit 2 as required by ASME Boiler Pressure Vessel Code,Section XI, Table IWE-2500-1, item E1.30.

Failure to Review Inservice Inspection Plan Prior to the Start of the 4th Interval for Unit 2 Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000446/2024004-03 Open/Closed Not Applicable 71111.08P The inspectors identified a Severity Level IV violation of Title 10 Code of Federal Regulations 50.55a(g)(4) for the failure of the authorized nuclear inservice inspector to review the inspection plan prior to the start of the 4th interval for Unit 2 as required by ASME Code IWA-2110(a).

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near 100 percent power for the entire inspection period.

Unit 2 began the inspection period at 100 percent power. On October 20, 2024, Unit 2 was shut down for a planned refueling outage. On November 19, 2024, Unit 2 achieved criticality and on November 21, 2024, Unit 2 reached 100 percent power and remained 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 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

71111.01 - 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 winter weather of the following systems:
  • condensate storage tank

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) Unit 2 Mansell level indication on November 7, 2024
(2) Alert and notification system backup radio repeater on December 19, 2024
(3) Unit 1 motor-driven auxiliary feedwater train B and turbine-driven auxiliary feedwater pump on December 31, 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) Unit 2 safeguards building 810 hallway on October 25, 2024
(2) Auxiliary building 810 hallway on October 25, 2024
(3) Unit 1 train A switchgear on December 10, 2024
(4) Unit 1 safeguards building 810 hallway on December 10, 2024
(5) Unit 2 train A switchgear on December 12, 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 announced drill on November 26, 2024.

===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 2 during refueling outage 2RF21 from October 21 to December 30, 2024.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination
  • safety injection, TCX-2-2530-33, pipe to elbow
  • safety injection, TCX-2-2530-34, elbow to pipe
  • safety injection, TCX-1-4203-H1-WA, pipe support lugs Visual # Examination
  • containment, SGM-1, moisture barrier-seismic gap material
  • shielded metal arc welding, o

feedwater, TCX-2-2101-MR1, moment restraint repair welds 1, 2, 3

service water, 2SW-0404, socket weld TUX-33 o

service water, SW-2-946, socket welds FW-1, 11A, 31 PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Reviewed video of reactor vessel head penetrations 3, 6, 9, 12, 16, 17, 18, 19, 24, 27, 29, 37, 38, 40, 41, 42, 44, 46, 52, 53, 54, 55, 61, 62, 64, 70, 75, 78, vent line and general head area.

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

  • EV-CR-2024-006208-2, 2-7131A
  • EV-CR-2024-006662-2, 2-TE-0127 PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04)

No steam generator tube inspection was required this refueling outage.

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 July to August 2024 and the biennial written examinations completed on October 17, 2024.

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 August 5 to October 17, 2024.

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.

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 plant shutdown and cooldown on October 20, 2024.

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

(1) The inspectors observed and evaluated just-in-time training for plant shutdown and cooldown on October 16, 2024.

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)2B main feedwater pump tuning post outage

(2) Two socket weld failures on Unit 1 bravo orifice letdown line
(3) Unit 1 low voltage power transfer switch failure

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) Personnel air lock and station batteries

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 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) Outage risk profile on October 11, 2024
(2) Unit 2 refueling outage train A work window, defense-in-depth 01B, on October 31 and November 1, 2024
(3) Risk associated with unplanned unavailability of the turbine-driven auxiliary feedwater pump on November 18, 2024

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)2-02 emergency diesel generator following sprinkler failure on October 8, 2024

(2) Reactor coolant system with leak in the letdown orifice line
(3) Control room air conditioning train B unplanned outage on October 29, 2024
(4) Condition Report CR-2024-6913 2-01 containment sump level indication
(5) Containment close out observations on November 16, 2024
(6) M<ain feed pump functionality with leak in control oil
(7) Pressurizer with failed heaters
(8) Commodity clearance between diesel starting air strainers and catwalk decking

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) Service water lube water system modification
(2) Temporary modification to install time delay relay on 1-NY-0050A and 1-NY-0050B

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Unit 2 refueling outage 21 activities from October 20 to November 19, 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) (6 Samples)

(1) Unit 1 containment spray/component cooling water heat exchanger component cooling water return valve failing to stroke as required on September 30, 2024
(2) Unit 2 scaffolds from October 4 - 9, 2024
(3) Unit 1 letdown orifice repair following a leak in the elbow on October 10, 2024
(4) Physics testing following core reload on November 18, 2024
(5) Control rod drop testing on November 18, 2024
(6) Unit 1 normal letdown line B in the overhead weld repair on December 13, 2024

Surveillance Testing (IP Section 03.01) (6 Samples)

(1) Unit 2 containment equipment hatch closure drill on October 21, 2024
(2) Unit 2 train A integrated test sequence (loss of offsite power/loss-of-coolant accident)on October 29, 2024
(3) VT-2 testing of seal table and under-vessel on November 18, 2024
(4) Digital rod position indication operability test following outage, OPT-117, on November 18, 2024
(5) Flux mapping of Unit 1 on December 23, 2024
(6) Diesel generator 1-02 monthly test on December 26, 2024

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

(1) Unit 2 auxiliary feedwater reverse flow test on November 5, 2024

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Leak rate test of penetration 2-MV-0016 on November 8, 2024

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Elevated Unit 1 reactor coolant system leakage due to leaks on letdown orifice line on September 29 and December 10,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Personnel exiting the radiologically controlled area using tool and equipment monitors, personal contamination monitors, and portal monitors
(2) Personnel exiting from the fuel transfer canal work activities

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Radiation Work Permit (RWP) 2024-2500, "Radioactive Waste and Filter Handling Activities," revision 0, task 2, involving radioactive filter removal and transfer to the filter carousel
(2) RWP 2024-2600, "WEC Refueling Activities," revision 0, task 7, involving prejob walkdown prior to removal of reactor head ductwork activities in the reactor cavity
(3) RWP 2024-2600, "WEC Refueling Activities," revision 0, task 35, involving core exit thermocouple nozzle assembly and reactor vessel level instrumentation system connection determination work activities in the reactor cavity
(4) RWP 2024-2600, "WEC Refueling Activities," revision 0, task 51, involving blind flange removal work activities in the fuel transfer canal
(5) RWP 2024-2600, "WEC Refueling Activities," revision 0, task 51, involving hydraulic ram replacement work activities in the fuel transfer canal High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas (VHRAs):

(1) Radioactive waste filter carousel (FB-810)
(2) Unit 1 and Unit 2 fuel transfer tube access points (X-FB-860-272)
(3) Unit 2 refueling cavity (2-RB-860-157)
(4) Unit 2 fuel transfer canal (2-RB-860-158)
(5) Unit 2 regeneration heat exchanger room (2-RB-832-155C)

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Control room emergency ventilation system

Temporary Ventilation Systems (IP Section 03.02) (2 Samples)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) High efficiency air particulate (HEPA) used during work activities involving the fuel transfer canal
(2) HEPA used during work activities involving core exit thermocouple nozzle assembly and reactor vessel level instrumentation system of the reactor head

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

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.

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 October 1, 2023, through September 30, 2024
(2) Unit 2 October 1, 2023, through September 30, 2024

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 October 1, 2023, through September 30, 2024
(2) Unit 2 October 1, 2023, through September 30, 2024

BI01: Reactor Coolant System Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1 October 1, 2023, through September 30, 2024
(2) Unit 2 October 1, 2023, through September 30, 2024

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) April 1, 2023, through June 30, 2024 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) April 1, 2023, through June 30, 2024

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

(1) The inspectors reviewed the licensees corrective action program to identify inspect the licensee's actions to address an adverse trend in human performance.

INSPECTION RESULTS

Non-Functional Fire Barrier Between Auxiliary and Unit 2 Safeguards Buildings Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000446/2024004-01 Open/Closed

[P.3] -

Resolution 71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of License Condition 2.G for failing to maintain a 3-hour fire barrier intact. The inspectors identified a normally open, automatically-closing fire door that separates the auxiliary building and Unit 2 safeguards building at the 810 elevation, was unable to close without assistance due to interference with the flooring.

Description:

On October 4, 2024, the inspectors performed a plant status tour of the auxiliary and Unit 2 safeguards buildings. During the tour, the inspectors noted that the diamond textured floor plates underneath one leaf of a double door separating auxiliary and Unit 2 safeguards buildings exhibited signs of significant wear. The wear pattern appeared consistent with what one would expect if a door was dragging on the floor. The inspectors questioned whether the door could automatically close and latch, given the apparent interference with the floor. Subsequent checks by the licensee revealed the door would not close and latch without assistance.

The fire door in question, S2-45, is a normally open double door with thermal links to allow automatic closure in the event of a fire. The fire areas on either side of the barrier contain fire safe shutdown equipment. They also have adequate automatic water suppression systems.

The licensee had previously documented this issue multiple times in their corrective action program:

  • August 31, 2018: The issue was identified after an unsatisfactory inspection of door S2-45. (Condition Report (CR) CR-2018-005867)
  • November 11, 2019: A temporary fix (adjusting lower flush bolt) was implemented.

The need for a more permanent solution was also documented at this time. (CR-2019-008802 and Work Order (WO) 5645235)

  • February 13, 2020: Engineering evaluation to grind diamond pattern on floor to allow more clearance was completed in CR-2019-008802. The evaluation references a design change notice from 1997 when the diamond decking was interfering with opening the door.
  • November 1, 2021: CR-2021-005699 generated to document unsatisfactory inspection of door S2-45. This CR was closed to work management with WO 21-696277.
  • March 21, 2022: CR-2022-001872 documented need to shave bottom of door or floor plate and that WO 21-696277 may need to be revised to add these further steps.
  • November 8, 2022: WO 21-696277 completed with only readjusting hinges. Tracking Report (TR) TR-2022-008035 created to request engineering evaluation to modify the door by grinding 1/8 off the bottom of the door. This tracking report remains open with no evaluation.

Corrective Actions: The licensee documented a fire impairment and established an hourly roving fire watch. Furthermore, a condition report was generated to document the condition and track completion of repairs to the door and/or flooring.

Corrective Action References: CR-2024-005983

Performance Assessment:

Performance Deficiency: The licensee failed to ensure the fire door between the auxiliary and Unit 2 safeguards building at the 810 elevation was free of obstructions that would prevent it from operating freely and fully closing and latching in the event of a fire. This is a licensee required weekly visual inspection.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors reviewed Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, dated November 1, 2023, and determined that this performance deficiency was similar to the more than minor example 2.d. in that the fire barrier functionality of the door was compromised.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors used IMC 0609, Appendix F, attachment 1, "Fire Protection Significance Determination Process Worksheet" dated May 2, 2018, to screen the significance of this finding. Per step 1.4.4, question 1.4.4-B, since there was adequate automatic fire suppression on both sides of the fire door barrier, the finding screened to Green.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the inspectors concluded that the licensee had previously documented in the corrective action program temporary fixes for this door but also documented the need for a more permanent solution. However, this permanent solution was not implemented.

Enforcement:

Violation: License Condition 2.G of the facility operating license states, in part, that the site will comply with their fire protection program as described in the final safety analysis report (FSAR). Section 9.5.1, Fire Protection System, of the FSAR, which contains the description of the fire protection program states, in part, that "Fire doors located in fire barriers are normally closed or are automatically closed by listed closure devices and released by solenoids, thermal-links, or electro-thermal links." Section 9.5.1.3 invokes the fire hazard analysis which describes the wall between auxiliary and Unit 2 safeguards buildings as a 3-hour fire barrier. Contrary to this requirement on October 4, 2024, fire door S2-45, a normally open door, which was part of the 3-hour fire barrier wall, was found obstructed such that it could not automatically close and latch in the event of a fire.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Perform ASME Examination of Unit 2 Containment Moisture Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000446/2024004-02 Open/Closed None (NPP)71111.08P The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4), Inservice inspection standards requirement for operating plants, for the licensees failure to conduct general visual examinations of the moisture barriers to the containment liner in accordance with Subsection IWE of ASME Boiler Pressure Vessel (BPV)

Code,Section XI. Specifically, the licensee failed to perform visual examinations of the sealant applied to the expansion joint between the concrete-to-metal containment liner of Unit 2 as required by ASME BPV Code,Section XI, Table IWE-2500-1, item E1.30.

Description:

ASME Code,Section XI, Subsection IWE, contains Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Plants. Subsection IWE, Table IWE-2500-1, Category E-A, Containment Surfaces, Item E1.30, Moisture Barriers, requires a general visual examination of 100 percent of moisture barriers. The reference to moisture barriers is further defined in Note

(3) of this table, which states in part, Examination shall include moisture barrier materials intended to prevent intrusion of moisture against inaccessible areas of the pressure retaining metal containment shell or liner at concrete-to-metal interfaces and at metal-to-metal interfaces which are not seal welded.

Contrary to this requirement, the licensee failed to perform a visual inspection of the moisture barrier or request relief for an acceptable alternative.

During review of a visual examination report of the Unit 2 containment moisture barrier, the inspectors inquired about pictures in the report displaying a black foam type material with varying degrees of degradation. The examination report identified the component as the moisture barrier but during discussion with licensee staff and review of design drawings, the material was determined to be a protective cap over the design moisture barrier (concrete-to-metal interface). The cap is a one-half inch thick foam type material adhered to the 808-foot elevation concrete curb and butted up to the metal containment liner. Discussion with licensee staff revealed that the cap only provides protection over the moisture barrier around the entire perimeter except behind the elevator shaft. The examination report also listed a drawing that did not pertain to a concrete-to-metal interface but was similar in profile only listing a detail of the cap material.

Design drawings for the 808-foot elevation did not show a cap over the moisture barrier section view, nor did it reference the drawing as listed on the examination report. A previous visual examination report also listed the same incorrect drawing. Further discussion with licensee staff revealed that the visual examination was only performed on the condition of the cap material and not the actual moisture barrier seal. Discussion also revealed that the cap was not removed to inspect the moisture barrier seal and has never been removed for inspection of the moisture barrier since installation. The examination reports stated that there has been no apparent damage to the moisture barrier seal, even though no actual visual inspection of the moisture barrier had been completed. The ASME Code required visual examination of the moisture barrier was not completed during the 2nd, 3rd, or 4th inspection intervals.

Corrective Actions: The licensee documented the issue in their corrective action program and initiated actions to determine the configuration of the original design. The licensee plans to submit a relief request to the NRC for exception of inspection of the moisture barrier due to inaccessibility by the black cap material.

Corrective Action References: CR-2024-007898

Performance Assessment:

Performance Deficiency: The failure to conduct a general visual examination of 100 percent of the moisture barriers intended to prevent intrusion of moisture against inaccessible areas of the containment liner was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The inspectors determined that this finding was of more than minor significance because the failure to conduct required visual examinations and identify potential degraded moisture barriers, which could allow the intrusion of water, had the potential to lead to a more significant concern.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Specifically, visual examinations of the containment metal liner or moisture barrier provide assurance that the liner remains capable of performing its intended safety function. The inspectors reviewed Exhibit 3, Barrier Integrity Screening Questions, dated January 1, 2021, and determined that the finding was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of the reactor containment and did not involve an actual reduction in function of hydrogen igniters in the reactor containment.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR 50.55a(g)(4), Inservice inspection standards requirement for operating plants, states in part, that systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the applicable requirements of the ASME BPV Code, subject to the conditions in 10 CFR Part 50.55a(g)(4). The 1998 Edition with the 2000 Addenda of ASME BPV Code,Section XI, Subsection IWE, through the latest edition and addenda incorporated by reference in paragraph 10 CFR 50.55a(a) (i.e. 2007 Edition with 2008 Addenda) require examination of moisture barriers in metal containments.

Specifically, Table IWE-2500-1, Category E-A, Containment Surfaces, Item E1.30, Moisture Barriers, requires a general visual examination of 100 percent of moisture barriers intended to prevent intrusion of moisture against inaccessible areas of the pressure retaining metal containment shell every inspection period.

Contrary to these requirements, from the 2nd interval which ended on August 2, 2014, until present, the licensee failed to perform visual examination of 100 percent of the moisture barriers in the metal containment shell of Unit 2. Specifically, the licensee failed to inspect the sealant at the expansion joint locations, which provides a moisture barrier to the basement containment liner during the 2nd interval when the inspection requirement was in effect, and during all subsequent inspection intervals. This issue has been entered into the licensees corrective action program as Condition Report CR-2024-007898.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.

Failure to Review Inservice Inspection Plan Prior to the Start of the 4th Interval for Unit 2 Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000446/2024004-03 Open/Closed Not Applicable 71111.08P The inspectors identified a Severity Level IV (SLIV) violation of 10 CFR 50.55a(g)(4) for the failure of the authorized nuclear inservice inspector (ANII) to review the inspection plan prior to the start of the 4th interval for Unit 2 as required by ASME Code IWA-2110(a).

Description:

During review of the licensees 4th interval inservice inspection (ISI) program plan, revision 0, dated August 1, 2024, the inspectors identified that the Unit 2, 4th interval began August 3, 2023, and the ISI program plan was reviewed by the ANII on August 5, 2024. The Code of record was the 2007 Edition through the 2008 Addenda of ASME BPV Code. The licensee submitted a relief request to implement the 2019 code edition into the 4th interval ISI program plan, dated September 15, 2023. The 3rd interval ended August 2, 2023, and the 4th interval began on August 3, 2023. The 4th interval ISI program plan was reviewed by the ANII on August 5, 2024. Based on discussions with the licensee, no repair/replacement had occurred between August 3, 2023 to August 5, 2024.

Title 10 CFR 50.55a(g)(4), ISI standards requirement for operating plants states in part that, "Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) that are classified as ASME BPV Code Class 1, Class 2, and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions and addenda of the ASME BPV Code that become effective subsequent to editions specified in paragraphs (g)(2)and

(3) of this section and that are incorporated by reference in paragraph (a)(1)(ii) or
(iv) of this section for snubber examination and testing of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components." The preface of ASME BPV Code,Section XI stipulates that the duties of the ANII (also referred as the Inspector) to verify that the mandatory program has been completed. ASME Code Section XI, IWA-2110, "Duties of the Inspector (Authorized Nuclear Inservice Inspector)"requires that the Inspector shall review the inspection plan and as necessary, the implementation schedule (IWA-2420) prior to the start of preservice inspection and each inspection interval. ASME BPV Code,Section XI, IWA-2420, Inspection Plans and Schedule, in part, states that inspection plans and schedules shall be prepared for subsequent ISI intervals.

Corrective Actions: The licensee documented the issue in their corrective action program and initiated actions to remediate.

Corrective Action References: CR-2024-007897

Performance Assessment:

None.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The licensees failure to review the ISI program plan prior to the start of the 4th interval was determined to be a violation not associated with an ROP finding and was disposed using the traditional enforcement process that impeded the regulatory process. The inspectors compared the issue to the examples in the Enforcement Manual. Although the examples under section 6.1, Reactor Operations, did not apply; an example under 6.5, Facility Construction, did. Specifically, example 2 of SLIV violations states, A licensee fails to establish, maintain, or implement adequate controls over procurement, construction, examination, or testing processes that are important to safety.

For this issue, the licensee failed to maintain adequate controls on the examination process as specified in ASME BPV code.

Severity: Severity Level IV - The violation involved the failure to maintain adequate control over the ISI program as specified in the ASME BPV code. The inspectors compared the issue to the examples in section 6 of the Enforcement Policy. Section 6.1, Reactor Operations, does not include a violation example involving the failure to maintain adequate controls over the inspection process. Consistent with the guidance in section 1.2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the enforcement policy violation examples, it should be assigned a severity level:

(1) commensurate with its safety significance, and
(2) informed by similar violations addressed in the violation examples. The violation was evaluated to be most similar to Enforcement Policy example 6.5.d.2, which states, A licensee fails to establish, maintain, or implement adequate controls over procurement, construction, examination, or testing processes that are important to safety.

For this issue, the licensee failed to maintain adequate controls on the examination process as specified in ASME BPV code. This violation was determined to be of more than minor safety significance because if left uncorrected it would become a more significant safety concern Violation: Title 10 CFR 50.55a(g)(4) states, in part, that components that are classified as ASME BPV Code Class 1, Class 2, and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the ASME BPV Code.

Section XI of the ASME BPV Code, IWA-2110, Duties of the Inspector, states that the inspector shall review the inspection plan and, as necessary, the implementation schedule prior to the start of preservice inspection and each inspection interval.

Contrary to the above, from August 3, 2023, until August 5, 2024, the licensee failed to have the inspector review the inspection plan and, as necessary, the implementation schedule prior to the start of preservice inspection and each inspection interval. Specifically, the licensee failed to have the ANII review the ISI program before the start of the 4th interval, which began on August 3, 2023. The 4th interval ISI program was reviewed by the ANII on August 5, 2024.

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 November 4, 2024, the inspectors presented the occupational radiation safety inspection results to Steven Sewell, Site Vice President, and other members of the licensee staff.
  • On November 19, 2024, the inspectors presented the biennial requalification inspection results to Chris Jackson, Plant General Manager, and other members of the licensee staff.
  • On December 30, 2024, the inspectors presented the inservice inspection results to Steven Sewell, Site Vice President, and other members of the licensee staff.
  • On January 23, 2025, 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

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-007825

OWI-912

Cold Weather

Procedures

STA-634

Extreme Temperature Equipment Protection Program

71111.01

Work Orders

WO

24-235021, 24-234941, 24-2356021

SOP-101B-RC-

V02

Reduced Inventory Lineup

SOP-304A-AF-

V01

Train A MDAFW Pump Lineup

Miscellaneous

SOP-304A-AF-

VO3

TDAFW Lineup

71111.04

Procedures

IPO-010B

Reactor Coolant System Reduced Inventory Operations

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-5983

FPI-103A

Unit 1 Safeguards Building Elevation 810'-6" Rad Pen.

Area and Elev. Equip. RM

FPI-103B

Unit 2 Safeguards Building Elev. 810'-6" Rad. Pen. Area

and Elec. Equip. RM

FPI-302B

Unit 2 Switchgear and RCA Access Elevation 810'-6"

Fire Plans

FPI-403

Auxiliary Building Elev. 810'-6"

Miscellaneous

Drill 24-11-04

Fire Drill Package

Run on

11/26/2024

Procedures

FIR-302

Fire Door Tests and Inspections

71111.05

Work Orders

24-78266, 22-

2235, 24-

44720

Fire Door Maintenance Work Orders

71111.08P

Corrective Action

Documents

Condition Report

(CR-)

23-003719, 2023-007406, 2023-007255, 2023-

007977, 2023-008086, 2024-001006, 2024-001522,

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

24-004035, 2024-005496, 2024-005559, 2024-

006473

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-007897, 2024-007898

M2-1901-SH01

Penetration Seals Typical Details

10/31/2015

M2-1901-SH03

Penetration Seals Typical Details

10/19/2009

S2-0519

RB Internal Structure EL 808'-0" Northwest Outline

CP-6

Drawings

S2-0519-A

CP-4

Remote Visual Inspection Summary, Comanche Peak

Nuclear Power Plant 2RF21 - Reactor Head BMV

Miscellaneous

23-SS-13

Joint Fillers and Sealers

10/15/1974

1RF20-IWE-069

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

05/11/2019

1RF22 (I4)-VT-51

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

04/21/2022

2RF21-UT-1

Ultrasonic examination. TCX-1-4101-11, pipe to elbow

10/31/2024

2RF21-UT-46

Ultrasonic examination, TCX-2-2530-33, pipe to elbow

11/03/2024

2RF21-UT-47

Ultrasonic examination, TCX-2-2530-34, elbow to pipe

11/03/2024

2RF21-UT-5

Ultrasonic examination, TCX-1-4102-4, pipe to elbow

11/01/2024

2RF21-UT-6

Ultrasonic examination, TCX-1-4102-5, pipe to pipe

11/03/2024

2RF21-UT-7

Ultrasonic examination, TCX-1-4102-6, elbow to pipe

11/01/2024

2RF21-VT-170

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

10/28/2024

2RF21-VT-34

Visual examination, TCX-2-2100-MR1, restraint

10/24/2024

2RF21-VT-40

Visual examination, TCX-2-2101-H6, restraint

10/24/2024

2RF21-VT-6

Visual Examination, AF-2-SB-013-H7, anchor

10/24/2024

CPNPP DM Weld

Visual

Examination

RPV Nozzle Hot Leg Loop 1, RPV Nozzle Hot Leg Loop

2, RPV Nozzle Hot Leg Loop 3, RPV Nozzle Hot Leg

Loop 4

11/01/2024

NDE Reports

CPNPP DM Weld

Visual

Examination

RPV Nozzle Cold Leg Loop 1, RPV Nozzle Cold Leg

Loop 2, RPV Nozzle Cold Leg Loop 3, RPV Nozzle

Cold Leg Loop 4

11/01/2024

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

VT-2014-300

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

04/16/2014

VT-2014-412

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

10/13/2014

VT-2015-174

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

10/23/2015

VT-2016-165

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

05/19/2016

VT-2018-100

Visual examination, SGM-1, Moisture Barrier-Seismic

Gap Material

2/22/2018

EPG-9.08

Reactor Vessel Closure Head Visual Examination

PDI-UT-2

PDI Generic Procedure for the Ultrasonic Examination

of Austenitic Pipe Welds

J

TX-ISI-11

Liquid Penetrant Examination for CPSES

TX-ISI-210

Ultrasonic Examination Procedure for Welds in Ferritic

Steel Vessels Comanche Peak Unit 1&2

TX-ISI-301

Ultrasonic Examination of Ferritic Piping Welds

TX-ISI-302

Ultrasonic Examination Procedure of Austenitic Piping

Welds

TX-ISI-8

VT-1 and VT-3 Visual Examination Procedure

TX-ISI-IWE

Metal Containment Visual Examination

Procedures

WLD-106

CPNPP Welding Program Manual

Work Orders

WO

23-161021, 23-231623, 23-275444, 23-445955,

24-488163, 24-517482, 4612088

71111.11A

Corrective Action

Documents

Condition Report

(CR-)

24-001805

Corrective Action

Documents

Condition Report

(CR-)

23-000714, 2023-001864, 2023-004463, 2023-

007735, 2024-001497, 2024-002716

24 LORT Annual Operational Exam 5 (SRO/RO

JPMs)

24 LORT Annual Operational Exam 5 (Simulator

Dynamic)

Various Licensed Operator Medical Records

71111.11B

Miscellaneous

Comanche Peak Active License Status Database

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

24 LORT Annual Operational Exam 6 (SRO/RO

JPMs)

24 LORT Annual Operational Exam 6 (Simulator

Dynamic)

23SA0040

U1C24 Core Performance Testing

23

ANSI/ANS-3.5

Nuclear Power Plant Simulators for Use in Operator

Training

1985

LO49F24ER4

Cycle 24-6 Biennial RO Written Exam 4

9/17/2024

LO49F24ES5

Cycle 24-6 Biennial SRO Written Exam 5

10/01/2024

ODA-315

Licensed Operator Maintenance Tracking

ODA-315-2

Return to Active License Status Form

SAR 23SA0040

Simulator Annual Performance Test Summary

23

SOMI-09

Simulator Configuration Control

STA-121

License Operator Physicals and License Application

Process

TRA-204

Licensed Operator Requalification Training

TRA-206

Operations Training Department Examination Control

and Implementation

TRA-207

Simulator Configuration Management

TRA-207.01

Simulator Maintenance

TRI-206.02

NRC Requalification Exam Development Process

Procedures

TRI-208.02

Conduct of LORT Simulator Training

71111.11Q

Procedures

IPO-005B

Plant Cooldown from Hot Standby to Cold Shutdown

Corrective Action

Documents

Condition Report

(CR-)

22-003981, 2023-08235, 2023-00846, 2023-004119,

23-004125

Engineering

Evaluations

EV-CR-2024-

000126-9, EV-

CR-2024-

005861-7

Maintenance Rule Evaluation

Certificate of Conformance for Personnel Air Lock

gasket

09/18/2020

Certificate of Conformance for Compression Gasket

09/04/2020

71111.12

Miscellaneous

PO 1621625

Purchase order to Paragon for Class 1E batteries

0, 1 and 2

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

QAA-24-015

NUPIC Audit of Paragon Energy Solutions

2/06/2024

VP-NEE0664-1

Battery Cell Verification Plan Inspection Report

08/14/2024

22384

Replacement of ASCO transfer switches

05/28/2024

Work Orders

22385

Replacement of ASCO transfer Switches

05/09/2024

Corrective Action

Documents

Condition Report

(CR-)

24-7205

Loss Of Shutdown Cooling Defense-in-Depth Tracking

Log

71111.13

Miscellaneous

AI-TR-2024-

000004-7

2RF21 Outage Schedule Risk Assessment

August 2024

Corrective Action

Documents

Condition Report

(CR-)

24-5985, 2024-7386, 2024-7504, 2024-7598,

24-7599, 2024-7703, 2024-7878, 2024-4448,

24-5823, 2024-7637

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-7599, 2024-7703, 2024-7157, 2024-6317

71111.15

Engineering

Evaluations

EV-TR-2024-

007703-01

Corrective Action

Documents

CR-2023-007273

Reliability of the Gamma Metrics HVPS

10/23/2023

Engineering

Changes

FDA-2023-

0000071-02

Modify Station Service Water Lube Water

59SC-2023-

000071-02-01

50.59 Screen for Service Water Lube Water

Modification

11/08/2024

59SC-2024-

000021-01-01

Install time delay relay for 1-NY-0050A and 1-NY-0050B

04/22/2024

71111.18

Engineering

Evaluations

FDA-2024-

000021-01

TM required to install time delay relay on 1-NY-0050A

and 1-NY-0050B

Condition Report

(CR-)

24-6538, 2024-6743, 2024-6951

IR-2024-007045

Corrective Action

Documents

IR-2024-6943

71111.20

Miscellaneous

Outage work hour reports for Maintenance Team 2,

October/November

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

Westinghouse, and Day/Zimmerman

24

Procedures

SOP-101B

Reactor Coolant System

03/28/2022

Corrective Action

Documents

Condition Report

(CR-)

24-4832, 2024-5601, 2024-6551, 2024-5891, 2024-

23, 2024-7637

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-5935, 2024-5992

NUC-102

Movable Incore Detector System (MIDS) Operating

Instructions

NUC-115

Performing Power Distribution Measurements

NUC-201

Surveillance of Core Power Distribution Factos

Procedures

OPT-214A

Diesel Generator Operability Test

WO 23-157945

Diesel Generator 2-01 Integrated test Sequence

10/29/2024

WO 23-168741

Penetration for Fire Protection to Containment Local

Leak Rate Test

11/08/2024

WO 24-488163

Unit 1 Letdown Orifice Isolation Valve 75 8149 Weld

Repair

10/09/2024

WO 24-582842

Diesel Generator 1-02 Monthly test

December 26,

24

WO 24-591695

2/12/2024

71111.24

Work Orders

WO-24-480090

Unit 2 CCW RET VLV Troubleshoot and Repair

10/04/2024

Corrective Action

Documents

TR-YYYY-NNNN

23-3039, 2023-3088, 2024-5053, 2024-5641

IR-YYYY-NNNN

24-6567

Corrective Action

Documents

Resulting from

Inspection

TR-YYYY-NNNN

24-006382

RPI-302

Radiation and Contamination Surveys

RPI-304

Radiological Posting and Labeling

RPI-305

Access Controls for High Radiation Areas

RPI-308

Use and Control of HEPA Filtration and Vacuum

Equipment

71124.01

Procedures

RPI-602

Radiological Surveillance

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

RPI-606

Radiation Work and General Access Permits

RPI-616

Radiological Control During Filter Media Handling

STA-656

Radiation Work Control

M-20241021-15

Filter Carousel Survey - filter in Teledyne shielded

transfer container

10/21/2024

M-20241021-15

Filter Carousel Down-posting Survey

10/21/2024

M-20241022-18

Filter Carousel Survey

10/22/2024

M-20241023-2

Unit 2 834-foot CETNA/RVLIS EPRI Survey

10/23/2024

Radiation

Surveys

M-20241023-5

Unit 2 Refueling cavity EPRI Survey

10/23/2024

Radiation Work

Permits (RWPs)

24-2603

Refuel In-Service Inspection, Guide Card Wear

Maintenance, and Support Activities

Corrective Action

Documents

Resulting from

Inspection

Condition Report

(CR-)

24-6419

Posi3 USB Test Results: Posi3 USB Serial #U09095

(regulator NM0304773EZUR4 and reducer

NK030810045SM2)

10/10/2023

Posi3 USB Test Results: Posi3 USB Serial #U09095

(regulator NK0330041EZNA4, reducer 40100033I)

10/10/2023

SCBA Monthly Inspection: January - December 2022

SCBA Monthly Inspection: January - December 2023

SCBA Monthly Inspection: January - August 2024

Miscellaneous

GEDORPTBFl

Self-Contained Breathing Apparatus (SCBA) Training

RPI-914

Airline Breathing Systems

SAF-101

Recharging Breathing Air Cylinders

SAF-104

Inspection of Respiratory Protection Equipment

(Maintenance and Repair)

SAF-105

Airline Breathing Systems

SAF-106

Testing of Breathing Air Systems

Procedures

STI-211.06

Use of Respiratory Protection

71124.03

Radiation Work

Permits (RWPs)

24-2600

WEC Refueling Activities, Task 51, Blind Flange

Removal/Installation and Hydraulic Ram replacement

Inspection

Procedure

Type

Designation

Description or Title

Revision or Date

24-2603

Refuel In-Service Inspection, Guide Card Wear

Maintenance, and Support Activities, Task 1,

Measurements/Inspections in Hot Leg and Cold Leg

Sandboxes

Comanche Peak Nuclear Power Plant (CPNPP) 2023

Annual Radiological Effluents Release Report

04/18/2024

Air Doses to Members of the Public Due To Gaseous

Releases: 1st, 2nd, and 3rd Quarters 2024

Doses to Members of the Public Due to Radioiodines,

Tritium, and Particulates in Gaseous Releases: 1st,

2nd, and 3rd Quarters 2024

Miscellaneous

Doses to Members of the Public Due to Liquid

Releases: 1st, 2nd, and 3rd Quarters 2024

MSPI Bases Document

0PGP05-ZN-

0007

Preparation and Submittal of NRC Performance

Indicators

71151

Procedures

SEG-0007

Mitigating System Performance Indicator Collection,

Processing and Maintenance of Data

71152S

Corrective Action

Documents

TR-2024-5506