IR 05000445/2025002
| ML25217A046 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/06/2025 |
| From: | Ami Agrawal NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| Agrawal A | |
| References | |
| IR 2025002 | |
| Download: ML25217A046 (1) | |
Text
August 06, 2025
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000445/2025002 AND 05000446/2025002
Dear Ken Peters:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant. On July 14, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, 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:
Report Numbers:
05000445/2025002 and 05000446/2025002
Enterprise Identifier:
I-2025-002-0008
Licensee:
Vistra Operations Company, LLC
Facility:
Comanche Peak Nuclear Power Plant
Location:
Glen Rose, TX 76043
Inspection Dates:
April 1, 2025, to June 30, 2025
Inspectors:
C. Alldredge, Health Physicist
J. Ellegood, Senior Resident Inspector
C. Harrington, Operations Engineer
J. Mejia, Reactor Inspector
A. Sanchez, Senior Project Engineer
E. Simpson, Nuclear Systems Scientist
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, 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 100 percent power. On April 20, the licensee shutdown Unit 1 for a refueling outage. On May 14, 2025, the licensee started the reactor. Unit 1 reached 100 percent power on May 17, 2025. Unit 1 remained at or near 100 percent for the remainder 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)
Hot weather preps
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm weather for the following systems:
- independent spent fuel storage installation
- electric switchyard
- site transformers Systems were walked down during the weeks of June 16 and 23, 2025.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train A auxiliary feedwater on April 14, 2025.
- (2) Unit 1, train B Emergency Diesel Generator on June 23, 2025
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, cable spreading room on June 17, 2025
- (2) Unit 2, cable spreading on June 17, 2025
- (3) Unit 1, control room heating ventilation and air conditioning on June 17, 2025
- (4) Unit 2, control room heating, ventilation and air conditioning on June 17, 2025
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the: Units 1 and 2 trains A and B safety-related battery rooms, on June 18, 2025
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
===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 were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 1 during refueling outage 1RF24 from April 28 to May 6, 2025.
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, TBX-2-2531-14, pipe to elbow
- safety injection, TBX-2-2531-15, elbow to pipe
- reactor coolant system, TBX-1-4201-1, branch connection to elbow
- reactor coolant system, TBX-1-4201-3, pipe to elbow
- reactor coolant system, TBX-1-4201-4, elbow to pipe
- reactor coolant system, TBX-1-4504-1, elbow to pipe Dye Penetrant Examination
- chemical and volume control, CS-1-005, weld 37B, 38, 41A, 42, 43, 44A, 45A, 46, 47A, 78, 79A Magnetic Particle Examination
- main steam, TBX-2-2400-H3, attachment welds Visual Examination
- metal containment, AC-31, containment liner
- metal containment, AC-34, containment liner
- metal containment, AC-38, containment liner
- metal containment, MI-0003, penetration
- metal containment, MI-0004, penetration
- metal containment, MI-0005, penetration
- metal containment, MI-0008, penetration
- metal containment, MV-0011, penetration Welding Activities
- gas tungsten arc welding, o
chemical and volume control system, CS-1-007, pipe to elbow socket weld repair o
component cooling water, CP1-FWAPFP-01, pipe to valve socket weld repair 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) The inspectors reviewed video of reactor vessel head penetrations 2-8, 14-17, 31-37, 39, 41, 44-45, 48-52, 56-58 and observed visual exams of penetrations 66-67.
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-2024-005861-12
- EV-CR-2024-007650-2
- EV-CR-2025-000067-2
- EV-CR-2025-001170-2
- EV-CR-2025-001657-2
- EV-CR-2025-001914-4
- EV-CR-2025-001914-9
- EV-CR-2025-001914-11
- EV-CR-2025-001914-12
- EV-CR-2025-001914-13
- EV-CR-2025-001914-14
- EV-CR-2025-001914-15
- EV-CR-2025-001914-17
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during vacuum filling activities on May 10, 2025.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during reactor start up on May 14, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated just in time training for startup and shutdown in preparation for Unit 1 planned refueling outage on April 17 and 18, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)component cooling water-this system is RED in system health based on tube plugging
- (2) Units 1 and 2, diesel generator starting air compressors
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)1RF24 outage risk profile
- (2) Unit 2, yellow risk due to emergency diesel generator 2-01 output breaker maintenance on April 9, 2025 (3)outage risk mitigation on April 29, 2025 (4)vacuum fill of the RCS on May 10, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, component cooling water surge tank level lowering, IR-2025-1690 (2)reactor headstand and reactor head following inadvertent contact between the headstand and reactor head.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated 1RF24 activities from April 20 to May 14, 2025.
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) (7 Samples)
(1)emergency diesel generator 2-01 fast start after output breaker maintenance on April 9, 2025.
(2)power range nuclear instrument high power trip setpoint adjustment on April 20, 2025 (3)reactor cavity quality assurance inspection before reactor head lift and flood up on April 25, 2025.
(4)reactor vessel foreign object search and retrieval conducted on May 1, 2025 (5)containment readiness for plant restart on May 12, 2025.
(6)train B control room makeup supply fan discharge damper x-20 following actuator rebuild (WO 24-460634) on June 18, 2025 (7)diesel generator 1-01 breaker on June 24, 2025
Surveillance Testing (IP Section 03.01) (5 Samples)
- (1) Unit 2, solid state protection system white noise analysis conducted on March 25, 2025
- (2) Unit 1, containment equipment hatch closure drill on April 22, 2025
- (3) Unit 1, emergency core cooling system flow test on May 6, 2025 (4)subcritical physics testing on May 14, 2025 (5)rod drop timing test on May 14, 2025
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2, motor driven auxiliary feedwater pump 2-02 on June 12, 2025
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1)reactor coolant system loop 1 hot leg sample line isolation valve local leak rate testing on May 2, 2025, work order 24-580864
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, identifies the concentrations and quantities of radioactive materials, and 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)observed the licensee conduct surveys of potentially contaminated packages/equipment from the radiologically controlled area for release offsite and workers existing potential contaminated areas.
(2)evaluated the licensee's physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)locked high radiation area work and job coverage for reactor head visual inspection activities under radiation work permit (RWP) 20251603, Task 1 for work order 23-490491 (2)radiation area work and job coverage for main-steam line insulation removal, inspection, and reinstallation activities under RWP 20251217, Task 1 for work order 23-462035 (3)radiation area work and job coverage for fuel movements under RWP 20251600, Task 3 for Procedure RFO-302, Handling Fuel Assemblies.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
(1)unit-1 reactor building, 790-foot elevation, 153 reactor sump annulus room (2)unit-1 reactor building, 832-foot elevation, 155C regenerative heat exchanger 1-01 room (3)auxiliary building, 810-foot elevation, X-191 waste processing spent resin sluice pump X-01 room 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
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) PCE 24-0005, Dose Assessment, November 11, 2024
- (2) PCE 24-0007, Dose Assessment, November 12, 2024
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Monitoring of two declared pregnant workers and their associated NRC Form 5s
- (2) Use of multipack dosimetry and dose assignment for five individuals
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, 2024, through March 31, 2025)
- (2) Unit 2 (April 1, 2024, through March 31, 2025)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) July 1, 2024, through March 31, 2025 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) July 1, 2024, through March 31, 2025
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)loss of primary ANS on May 3 as described in IR-2025-2331
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 1, 2025, the inspectors presented the occupational radiation safety inspection results to Christopher Jackson, Site Vice President and other members of the licensee staff.
- On May 6, 2025, the inspectors presented the exit meeting inspection results to Hunter Schill, Plant Manager and other members of the licensee staff.
- On July 14, 2025, the inspectors presented the integrated inspection results to Ken Peters, Executive Vice President and Chief Nuclear Company, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
25 Comanche Peak Summer Readiness Presentation
Procedures
SOP-304A
Auxiliary Feedwater System
Revision 18
Calculations
SI-CA-0000-0664
Electrical and Control Building Analysis
Corrective Action
Documents
CR-YYYY-NNNN
24-007228, 2024-007323, 2024-007650. 2024-007773,
25-000066, 2025-000067, 2025-000517, 2025-000552,
25-000562, 2025-000818, 2025-000870, 2025-001002,
25-001014, 2025-001091, 2025-001101, 2025-001170,
25-001243, 2025-001294, 2025-001558, 2025-001623,
25-001657, 2025-001659, 2025-001659
Corrective Action
Documents
Resulting from
Inspection
IR-YYYY-NNNN
25-002318, 2025-002431
Remote Visual Inspection Cover Sheet Vistra - CPNPP -
1RF24 Reactor Head Bare Metal Visual April 27-28 2025
04/28/2025
Miscellaneous
Unit 1 - Fourth Interval ASME Section XI Inservice Inspection
Program Plan
EPG-9.08
Reactor Vessel Closure Head Visual Examination
STI-737.01
Boric Acid Corrosion Detection and Evaluation
TX-ISI-11
Liquid Penetrant Examination for CPSES
TX-ISI-214
Ultrasonic Examination for Welds in Piping Systems and
Vessels
TX-ISI-302
Ultrasonic Examination Procedure for Austenitic Piping Welds
TX-ISI-70
Magnetic Particle Examination for CPSES
TX-ISI-8
VT-1 and VT-3 Visual Examination Procedure
Procedures
TX-ISI-IWE
Metal Containment Visual Examination
Work Orders
WO-
23-113845, 23-490491, 24-488163, 24-517482, 25-140368,
25-106518
IPO-002A
Plant Startup from hot standby
IPO-010A
Reactor Coolant System reduced Inventory Operation
Procedures
SOP-101A
Corrective Action
CR-YYYY-NNNN
25-002224, 2025-2204
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Miscellaneous
ENGAGE health report for component cooling water
05/30/2025
Guarded Equipment Posting Log for EDG 2-01 Breaker
Maintenance
04/09/2025
DIDCP 1RF24-
01A
Defense in Depth Contingency Plan for Loss of Shutdown
Cooling
DIDCP 1RF24-
01A
Defense in Depth Contingency Plan for Spent Fuel Pool
Cooling
Miscellaneous
DIDCP 1RF24-09
Defense in Depth Contingency Plan for Mansell Level
Indication
Corrective Action
Documents
CR-YYYY-NNNN
25-2293, 2025-1666, 2025-1690
Corrective Action
Documents
TR-YYYY-NNNN
25-2661
NUC-111
attachment 2
Inverse Count Rate Ratio Monitoring for Unit 1 Cycle 25
05/14/2025
Miscellaneous
OPT-308
attachment 3
BEACON calculated Estimated Critical Conditions for Unit 1
cycle 25
05/14/2025
Procedures
IPO-002A
Plant Startup from Hot Standby
Corrective Action
Documents
CR-YYYY-NNNN
25-2365, 2025-3279
1RF24_WC61
Detailed Fuel Inspection
04/30/2025
Miscellaneous
AXIS P7214
FOSAR inspection of Comanche Peak reactor Vessel
05/01/2025
MSE-SO-6301
6.9KV Air Circuit Breaker Inspection and Cleaning
NUC-206
Control Rod Drop Timing
NUC-303
Subcritical Physics Testing
OPT-206B
AFW System
OPT-214A
Diesel Generator Operability Test
Procedures
OPT-521A
ECCS Operability
Work Orders
23-458088, 23-450341, 23-248060, 24-599999
Condition Reports
(CR-YYYY-
NNNN)
25-001302
Corrective Action
Documents
Tracking Reports
23-003771, 2024-006398, 2024-006823
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(TR-YYYY-
NNNN)
ODA-102
Conduct of Operations
RPI-110
Radiation Protection Shift Activities
RPI-304
Radiological Posting and Labeling
Procedures
RPI-305
Access Controls for High Radiation Areas
242101
2RF21 Operations Activities
242201
2RF21 Pressurizer (rm 2-161B/C/D/E) & Spray Valve Rm (2-
160B)
242405
2RF21 RCP 2-03 Motor Swap
242600
2RF21 Westinghouse Refueling Activities
250211
U1 Leak Repair and U1 & U2 Vibration Data in Letdown
Orifice
251108
1RF24 Engineering/Management/NRC Walk-Downs (Includes
HRA)
251217
1RF24 Insulator Activities
251404
1RF28 ISI, FAC and Associated Engineering Activities
251600
1RF24 Westinghouse Refueling Activities
Radiation Work
Permits (RWPs)
251603
1RF24 Alloy 600 Reactor Head Inspections & Insulation
Activities
Self-Assessments
EVAL-2024-002
Audit Title: Chemistry/Environmental/Effluent Radioactive
Waste
RPI-528-1;
Multibadge ID:
1706
Multibadge Worksheet
04/24/2023
RPI-528-1;
Multipack ID:
1693
Multibadge Worksheet
04/24/2023
RPI-528-1;
Multipack ID:
1697
Multibadge Worksheet, Multipack ID: 1706
04/24/2023
Calculations
RPI-528-1;
Multipack ID:
1712
Multibadge Worksheet
04/24/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
RPI-528-1;
Multipack ID:
1718
Multibadge Worksheet
04/24/2023
Corrective Action
Documents
TR-YYYY-NNNN
23-003771
Corrective Action
Documents
Resulting from
Inspection
IR-YYYY-NNNN
25-002289
Miscellaneous
RPI-515-2
Neutron Exposure Tracking Sheet
04/08/2024
RPI-303
Radiological Air Sampling
RPI-402
Personnel Contamination Event Documentation
RPI-500
Bioassay Program
RPI-501
In Vitro Sampling
RPI-503
Operation of the Stand-Up Whole Body Counter
RPI-507
Internal Dose Calculation
RPI-509
Personnel Dosimetry Program
RPI-515
Neutron Dose Measurement and Recording
RPI-516
Dose Determination
RPI-527
Quality Control of the Dosimetry Processing Program
RPI-528
Multiple Dosimetry Badging
RPI-530
Dosimeter Badge Issue and Assignment
RPI-534
Calibration of Electronic Personal Dosimeters and Pocket Ion
Chambers (PICS)
RPI-613
Discrete Radioactive Particle Contamination Control
Procedures
STA-655
Exposure Monitoring Program
Comanche Peak Steam Electric Station Offsite Dose
Calculation Manual Unit 1 and Unit 2
24 Annual Radiological Effluents Release Report
71151
Miscellaneous
First Quarter Dose Reports for Gas and Liquid Releases