ML21131A095
| ML21131A095 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/11/2021 |
| From: | O'Keefe N NRC/RGN-IV/DRP |
| To: | Peters K Vistra Operating Co. (VistraOpCo) |
| References | |
| IR 2021001 | |
| Download: ML21131A095 (17) | |
See also: IR 05000445/2021001
Text
May 11, 2021
Mr. Ken Peters
Senior Vice President
and Chief Nuclear Officer
VISTRA Operating Company, LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000445/2021001 AND
Dear Mr. Peters:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 16, 2021, the NRC inspectors
discussed the results of this inspection with Mr. Thomas McCool and other members of your
staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding did
not involve a violation of NRC requirements.
If you disagree with 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.
K. Peters 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,
Cornelius F. Digitally signed by
Cornelius F. O'Keefe
O'Keefe Date: 2021.05.11
12:38:11 -05'00'
Neil F. O'Keefe, Chief
Reactor Projects Br B
Division of Reactor Projects
Docket Nos. 05000445 and 05000446
License Nos. NPF-87 and NPF-89
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE SRI:DRP/B RI:DRP/B TL:DRS/IPAT BC:DRS/EB1
NAME JEllegood JAE NDay NHD AAgrawal ANA VGaddyvgg
DATE 05/10/2021 04/28/2021 5/6/2021 05/06/2021
OFFICE BC:DRS/EB2 ABC:DRS/RCB BC:DRS/OB ABC:DNMS/RxIB
NAME NTaylor NHT JRollins JMR HGepford hjg NGreene / NAG
DATE 5/6/2021 5/10/2021 5/10/2021 05/06/2021
OFFICE SPE:DRP/B BC:DRP/B
NAME DProulx DLP NOKeefe nfo
DATE 5/10/2021 5/11/21
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000445 and 05000446
License Numbers: NPF-87 and NPF-89
Report Numbers: 05000445/2021001 and 05000446/2021001
Enterprise Identifier: I-2021-001-0095
Licensee: VISTRA Operating Company, LLC
Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2
Location: Glen Rose, TX
Inspection Dates: January 1, 2021 to March 31, 2021
Inspectors: L. Brookhart, Senior Spent Fuel Storage Inspector
N. Day, Resident Inspector
J. Drake, Senior Reactor Inspector
J. Ellegood, Senior Resident Inspector
S. Hedger, Emergency Preparedness Inspector
J. Melfi, Project Engineer
Approved By: Neil F. O'Keefe, Jr., Chief
Reactor Projects Br B
Division of Reactor Projects
Enclosure
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 of Unit 1 Turbine First Stage Pressure Line
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green None (NPP) 71111.12
Systems FIN 05000445/2021001-01
Open/Closed
The inspectors identified a finding of very low safety significance, Green, following the failure
of a weld on the root valve for the main turbine first stage pressure transmitter 1-PT-0505.
Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new
valve was not the same model as the installed valve which resulted in premature failure of a
weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown
to make repairs. The licensee failed to properly control inventory in the supply system. As a
result, the licensee installed a valve in the plant without doing the necessary part evaluations
needed to verify it was appropriate for the application.
Additional Tracking Items
None.
2
PLANT STATUS
Units 1 began the inspection period at or near 100 percent power. On March 29, 2021, Unit 1
main feedwater pump A tripped. An automatic runback occurred in response to the main
feedwater pump trip which reduced power to about 57 percent. Unit 1 remained at about 57
percent power for the remainder of the inspection period.
Unit 2 operated at or near rated thermal 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 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President
of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),
resident inspectors were directed to begin telework and to remotely access licensee information
using available technology. During this time, the resident inspectors performed periodic site
visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant
Status; observed risk-significant activities; and completed on-site portions of IPs. In addition,
resident and regional baseline inspections were evaluated to determine if all or portions of the
objectives and requirements stated in the IP could be performed remotely. If the inspections
could be performed remotely, they were conducted per the applicable IP. In some cases,
portions of an IP were completed remotely and on-site. The inspections documented below met
the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1) On February 11, 2021, the inspectors evaluated readiness for seasonal extreme
weather conditions prior to the onset of cold weather per procedure OWI-912, Cold
Weather, for the following systems:
Station Service Water
Fire Water
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
3
(1) The inspectors evaluated the adequacy of the overall preparations to protect
risk-significant systems from impending severe weather for high winds on January 14,
2021
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) Systems, structures and components in service water and fire water for both units
that were vulnerable to freezing following extreme cold on February 20, 2021
(2) Unit 1, residual heat removal system A following quarterly surveillance on March 11,
2021
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) Flex equipment storage building, area X-FX-2K19, on February 22, 2021
(2) Unit 1, main feedwater pumps, area TB, on March 12, 2021
(3) Station service water intake structure, area WB, on March 22, 2021
(4) Unit 1, safeguards building ventilation, area SK17a, on March 30, 2021
(5) Unit 1, main steam isolation and atmosphere relief valve room, area SK17c, on
March 30, 2021
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 March 18, 2021
71111.06 - Flood Protection Measures
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated cable submergence protection in:
(1) Unit 1, station service water cable vault E1B2 on January 28, 2021.
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1) Unit 1, containment spray pump 1-01 and lube oil cooler 1-03
4
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 service water restoration on March 26, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated a simulated complete loss of component
cooling water on January 27, 2021
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) Unit 1, service water pump fouling on November 18, 2020
(2) Failure of Unit 1 PT-0505, turbine first stage pressure transmitter, instrument line on
November 6, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) Unit 2, simultaneous scheduling power range nuclear instrument calibrations for N-41
and N-42 on January 4, 2021
(2) Unit 1, unplanned inoperability train B auxiliary feedwater (AFW) pump on January 6,
2021
(3) Recovery of breaker 1A1-1, normal offsite power to nonvital 6.9KVon January 20,
2021
(4) Low temperatures and high grid load during the week of February 15, 2021
(5) Extended service water pump 2-02 outage during the week of March 22, 2021
(6) Unit 1, repairs to main feed pump A during the week of March 29, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
5
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Unit 1, repair of B AFW pump flow transmitter
(2) Operability of 2-01 emergency diesel generator with unit trip light illuminated
(3) Offsite power with low frequency on February 15, 2021
(4) Service water pumps pursuant to Generic Letter 91-13.
(5) Circuit breaker 1EB3-3 due to missing overcurrent testing
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following permanent modification:
(1) Unit 1, PT-0505 modification to improve vibration resilience
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system
operability and functionality:
(1) Unit 1, motor driven AFW flow transmitter 1-FT-2457 on
January 12, 2021
(2) Component cooling water pump 1-02 breaker replacement on February 4, 20201.
(3) Unit 2, main steam isolation valve 2-03 following pressure gauge root valve leak on
February 25, 2021
(4) Unit 2, replacement of train A accident sequencer optical isolator on March 16, 2021
(5) Service water pump 2-02 following replacement on March 27, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1) Unit 2, power range nuclear instrument on January 5, 2021
(2) Unit 2, reactor trip breaker B on January 25, 2021
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
(1) The licensee submitted a summary of emergency plan changes (Revision 44) to the
NRC on November 12, 2020. The inspectors conducted an in-office review of the
changes from January 4 to 21, 2021. This evaluation does not constitute NRC
approval
6
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)
(1) Unit 1 (January 1, 2020, through December 31, 2020)
(2) Unit 2 (January 1, 2020, through December 31, 2020)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2
Samples)
(1) Unit 1 (January 1, 2020, through December 31, 2020)
(2) Unit 2 (January 1, 2020, through December 31, 2020)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)
(1) Unit 1 (January 1, 2020, through December 31, 2020)
(2) Unit 2 (January 1, 2020, through December 31, 2020)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Lack of engineering rigor on multiple engineering products
(2) Unit 1, main feed water pump A cause evaluation and corrective actions described in
Condition Report 2020-07334
71153 - Followup of Events and Notices of Enforcement Discretion
Event Followup (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated the Unit 1 main feedwater pump A trip and licensees
response on March 29, 2021
(2) The inspectors evaluated the response to severe cold weather and grid frequency
variations during the week of February 13
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of An Independent Spent Fuel Storage Installation (ISFSI)
The inspectors performed a review of the licensees ISFSI activities to verify compliance with
requirements of the Certificate of Compliance 72-1014, License Amendment 7, and the
HI-STORM ISFSI Final Safety Analysis Report (FSAR), Revision 9. The inspectors reviewed
selected procedures, corrective action reports, and records to verify ISFSI operations were
7
compliant with the Certificate's Technical Specifications, requirements in the FSAR, and NRC
regulations
Operation Of An ISFSI (1 Sample)
(1) The inspectors evaluated the licensees dry cask storage operations, from March 22
through 26, 2021, during an on-site inspection. The Comanche Peak ISFSI is located
approximately 2,900 feet southeast of the Unit 1 reactor building within a separate
protected area. The pad was designed to hold 84 HI-STORM 100S (Version B)
loaded with the Multi-Purpose Canisters, each with 32 spent fuel assemblies
(MPC-32). The pad is designed to store the casks in a 6 by 14 array. At the time of
the routine loading inspection, the Comanche Peak ISFSI pad contained a total of 43
HI-STORM 100S overpacks. The licensee was in the process of transporting the 44th
cask to the ISFSI and loading/processing the 45th cask in the spent fuel building
During the on-site inspection, the inspectors evaluated and observed the following
activities:
- Walk-down of the ISFSI haul path
- Transportation of the 44th cask on the vertical cask transporter from the spent
fuel building to the ISFSI
- Fuel assembly selection and placement into the 45th canister
- Heavy load lifts using the cask handling crane to remove the transfer cask
with the loaded canister from the spent fuel pool to the canister processing
area
- Welding and non-destructive testing of the lid-to-shell weld
- Processing of the spent nuclear fuel for storage, including bulk water removal,
forced helium dehydration, and helium backfill operations
- Final sealing of the canister, including welding of the vent and port cover
plates, non-destructive testing, and helium leak-testing
The inspectors reviewed and evaluated the following documentation during the
inspection:
- Fuel selection evaluations for the canisters loaded since the last NRC ISFSI
inspection, the inspectors reviewed the contents of casks 40-45 against the
license's Technical Specifications for approved contents
- Radiation surveys for dose at the owner-controlled boundary to verify
compliance with the requirements of 10 CFR 72.104 for calendar years 2019
and 2020
- Selected ISFSI related condition reports (CRs) issued since the last NRC
ISFSI inspection (October 2019)
surveillances, receipt inspection, and quality control activities related to ISFSI
operations
- Compliance to Technical Specifications for operational surveillance activities
and FSAR required annual maintenance activities
- Documentation of annual maintenance activities for the sites cask handling
crane and special lifting devices
- Selected licensee design changes and program changes to the ISFSI
performed under the site's 10 CFR 72.48 program
8
- Changes made by the licensee in the site's 72.212 Evaluation Report from
Revisions 11 to 12
INSPECTION RESULTS
Failure of Unit 1 Turbine First Stage Pressure Line
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green None (NPP) 71111.12
Systems FIN 05000445/2021001-01
Open/Closed
The inspectors identified a finding of very low safety significance (Green) following the failure
of a weld on the main turbine first stage pressure transmitter root valve 1-MS-0285.
Specifically, the licensee replaced the valve during the fall 2020 refueling outage. The new
valve was not the same model as the installed valve which resulted in premature failure of a
weld because the new valve induced harmonic vibration, resulting in an unplanned shutdown
to make repairs. The licensee failed to properly control inventory in the supply system. As a
result, the licensee installed a valve in the plant without doing the necessary part evaluations
needed to verify it was appropriate for the application.
Description: The licensee replaced the main turbine first stage pressure transmitter root
valve 1-MS-0285 during the fall 2020 refueling outage as a preventive maintenance
activity. Shortly after unit start up, on November 6, 2020, main turbine first stage pressure
transmitter 1-PT-0505 failed low. A parallel indicator continued to function correctly. A
non-licensed operator investigated the condition and observed a steam plume from the inlet
side of the instrument root valve 1-MS-0285. Since the leak could not be isolated, the
licensee shut the unit down and replaced the valve.
In order to understand the failure, the licensee contracted for an analysis of the failed weld.
The lab performing the analysis determined the weld failed as a result of fatigue crack
initiation. Further analysis by the licensee determined the failure occurred as a result of
vibration at resonant frequency. This resonance response resulted from installation of a
valve that weighed 2 pounds more than the previously installed valve, which altered the
natural frequency of the section of piping.
The inspectors reviewed the licensee's work order associated with valve replacement as well
as procurement documents associated with the work. Supply chain documents revealed that
the replacement valve was transferred to Comanche Peak from coal plant. When it arrived,
the licensee accepted the valve into their inventory under the Texas Utility part number. At
the time, Texas Utility was the corporate owner of Comanche Peak and numerous fossil
plants. The licensee correlated the valve to locations for other steam instrument isolation
valves; however, the valve was not initially correlated to location 1-MS-0285. An update to a
logistics database in 1998 correlated the part number to the location for 1-MS-0285. In
reviewing the procedure in effect in 1990, the inspectors determined that the procedure
required the site to verify the materiel description matched that in the database for the part. If
it did not, a new part number was required. In this case, the replacement valve did not match
any valves with an existing part number; however, the licensee failed to assign the valve a
new part number.
PT-0505 provides indication of turbine first stage pressure as well as input to Anticipated
Transient without Scram Mitigation System Actuation Circuitry (AMSAC) and the P-13
permissive. The AMSAC input allows AMSAC to arm when power is above 40 percent.
9
Since the instrument failed low, AMSAC would not automatically actuate and operators would
have needed to manually initiate AMSAC if the system was needed. The P-13 permissive is
associated with P-7 permissive which blocks certain trips when at low power.
During review of this issue, the licensee identified the technical cause of the weld failure.
However, the licensee did not pursue the underlying cause that allowed an incorrect valve to
be installed. The inspectors discussed potential performance deficiencies with the licensee
which prompted the licensee to understand how the valve was issued for installation. The
licensee plans to incorporate this event into training for supply chain staff.
Corrective Actions: The licensee documented the condition in their Corrective Action
Program (CAP) as CR-2020-8429 and replaced the valve with the correct valve.
Corrective Action References: CR-2020-8429
Performance Assessment:
Performance Deficiency: The licensee failed to properly control inventory in the supply
system. As a result, the licensee installed a valve in the plant without doing the necessary
part evaluations needed to verify it was appropriate for the application. Consequently, the
natural frequency of a high-pressure steam pressure transmitter piping changed causing
premature failure. Repair of the leak required a plant shutdown.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control 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 determined that the performance deficiency was more than
minor because it adversely affected the mitigating system cornerstone objective of ensuring
the reliability of systems that respond to initiating events. The performance deficiency had a
substantive impact on the equipment performance attribute because the failure of the weld as
a result of the performance deficiency led to PT-0505 unavailability. This instrument provides
input to the P-13 permissive as well as the AMSAC system.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. The inspectors reviewed
the finding in using Appendix A of IMC 0609. The inspectors answered no to all of the
questions in Exhibit 2, section A because the affected mitigating systems were only briefly
non-functional; therefore, the finding screened as Green.
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. Specifically, the part designation error occurred in 1998.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
Observation: Actions to address weaknesses in engineering rigor 71152
The inspectors noted several examples in 2019 and 2020 regarding weaknesses in
engineering technical rigor. These examples are documented as samples in reports:
05000445/2019004; 05000446/2019004 (ML20041D968)
05000445/2020002; 05000446/2020002 (ML20217L240)
10
05000445/2020004; 05000446/2020004 (ML21040A051)
The inspectors searched the corrective action program and identified several examples of
where the site had attempted to improve engineering technical rigor, however, the inspectors
concluded that the prior efforts had not been sustainable. The inspectors also reviewed a
presentation on engineering technical rigor provided to engineering staff. The Inspectors
noted that the training had not been given in over 10 years. The inspectors concluded that
training on this frequency would not result in sustainable improvement. Subsequently, the
inspectors discussed actions in place to improve and sustain engineering technical rigor. The
licensee informed the inspectors that the site would have biennial training on engineering
technical rigor. In addition, engineering supervisors provide reinforcement of engineering
rigor during one on one discussions with engineers and in staff meetings. If the licensee
maintains initiatives to improve engineering rigor, the inspectors expect to see improvement
in engineering products.
Observation: Licensee Response to Frigid Weather 71153
During the week of February 14, 2021, Comanche Peak experienced frigid weather
conditions for multiple days. Prior to the onset of the cold weather, the licensee
implemented their abnormal procedure to prepare for cold weather with supplemental
actions based on operating experience. The inspectors performed walkdowns of licensee
actions using inspection procedure 71111.01. Following the onset of cold weather, the site
experienced a grid frequency drop on February 15, 2021. As part of the response, as
specified in ABN-601 Response to a 138/345 KV System Malfunction, the licensee started
train A emergency diesel generators in both units and transferred the train A emergency
busses to the diesel. Concurrently, the shift manager contacted the grid operator and
requested the grid operator recover grid frequency to greater than 59.9 Hz. The grid
operator reduced grid load and operators restored the plant to a normal electrical
configuration. The inspectors verified the licensee responded in accordance with approved
procedures by discussion, log reviews, and computer trend reviews. The licensee
maintained the plant in a stable condition with limited work activities for the rest of the
week. The inspectors continued to monitor plant parameters and activities using
procedures 71111.13 and 71111.15. After the cold weather subsided, on February 20,
2021, the inspectors used inspection procedure 71111.04 to inspect the condition of
systems and components susceptible to freezing. The inspectors concluded site personnel
maintained the plant in a safe condition and the cold weather did not cause significant
damage to the plant.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 21, 2021, the inspectors presented the Emergency Plan Revision In-Office
Review Results inspection results to Mr. Patrick Allen, Manager, Emergency
Preparedness and other members of the licensee staff.
- On March 25, 2021, the inspectors presented the routine ISFSI inspection results to
Mr. Thomas McCool, Site Vice President, and other members of the licensee staff.
- On April 16, 2021, the inspectors presented the integrated inspection results to
Mr. Thomas McCool and other members of the licensee staff.
11
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60855 Corrective Action CR-YYYY-NNNN 2019-009399, 2020-001626, 2020-008755, 2021-001243,
Documents TR-YYYY-NNNN TR-2019-008506, TR-2019-009009, TR-2020-000102,
TR-2020-005224
60855 Engineering EVAL-2019-009 Nuclear Oversight Core Performance Engineering and Fuel 03/11/2020
Evaluations Management QA Audit
60855 Engineering NUC 212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
Evaluations 40 Specifications Supplement
60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
Evaluations 41 Specifications Supplement
60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 09/05/2019
Evaluations 42 Specifications Supplement
60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
Evaluations 43 Specifications Supplement
60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
Evaluations 44 Specifications Supplement
60855 Engineering NUC-212 Cask Cask Acceptability Report and Comprehensive Assembly 02/24/2021
Evaluations 45 Specifications Supplement
60855 Miscellaneous 72.212 Report CPNPP 10CFR72.212 Evaluation Report 12
60855 Procedures DCS-201 Transporting Loaded and Unloaded HI-STORM 9
60855 Procedures DCS-202 MPC Preparation for Loading 9
60855 Procedures DCS-203 MPC Handling and Fuel Loading Operations 12
60855 Procedures DCS-204 MPC Closure Operations (Sealing, Drying, Backfilling) 13
60855 Procedures DCS-205 Stack-up and Transfer of Loaded MPC 10
60855 Procedures OPT-102A-1 Operations Shiftly Routine Tests 15
71111.01 Work Orders 5939919
71111.04 Procedures SOP-102A Residual Heat Removal System 22
71111.04 Work Orders 5820443
71111.05 Fire Plans FPI-108A Fire Preplan for UNIT 1 SAFEGUARDS BUILDING MAIN 4
STEAM PENETRATION AREA 880'-6"
71111.05 Fire Plans FPI-2001 Fire Preplan for FLEX STORAGE BUILDING X-FX-2K19 1
71111.05 Fire Plans FPI-302A Fire Preplan for UNIT 1 & 2 TURBINE BUILDING 8
ELEVATION 803'-0"
12
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.05 Fire Plans FPI-701 Fire Preplan for SERVICE WATER INTAKE STRUCTURE 4
ELEV. 796'-0" & 810'-6"
71111.07A NDE Reports Containment Spray Pump 1-01 and 1-03 Visual Inspection 01/20/2021
Report
71111.12 Corrective Action CR-YYYY-NNNN 2020-7695, 2020-8429
Documents
71111.12 Miscellaneous Service water system health report 08/25/2020
71111.12 Miscellaneous Maintenance Rule Database for Main Steam
71111.12 Miscellaneous Maintenance Rule Database for Unit 1 Service Water
71111.12 Miscellaneous 6S832645 Material Transfer Form 05/01/1990
71111.12 Miscellaneous MDIR-98-000314- 03/13/1998
00-00
71111.12 Procedures MMO-6.09 TSN Assignment and Transfer of Warehouse Material. 0
71111.13 Procedures STI-600.01, Protecting Plant Equipment and Sensitive Equipment 3
Controls
71111.15 Corrective Action CR-YYYY-NNNN 2021-001393, 2021-1224, 2021-553
Documents
71111.15 Miscellaneous PQE 208 Rosemont Pressure Transmitter Plant Qualification 12/23/2018
Evaluation
71111.18 Engineering FDA-2017- Modify 1-PT-0505 2
Changes 000020-01-01
71111.19 Procedures OPT-205B Containment Spray System Post Test for WO 5813767 and 18
5813740
71111.19 Work Orders 5405494, 595445
71111.19 Work Orders 5958368
71111.22 Work Orders 5790214
71114.04 Miscellaneous Comanche Peak Nuclear Power Plant Emergency Plan, 43
Units 1 and 2
71114.04 Miscellaneous AI-TR-2020- Use of Terms "Onsite," "Offsite," "Site," "Site Boundary," and 09/16/2020
000756-13 "Exclusion Area" in the Emergency Plan
71114.04 Miscellaneous CP-20200627, Comanche Peak Nuclear Power Plant (CPNPP), Docket 11/12/2020
TXX-20093 Nos. 50-445, 50-446; Transmittal of Revised Emergency
Plan (Revision 44)
71114.04 Miscellaneous EV-TR-2018- Remove Letter of Agreement References from Comanche 08/18/2020
13
Inspection Type Designation Description or Title Revision or
Procedure Date
005896-5 Peak Emergency Plan Appendix H
71114.04 Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 2
Emergency Plan Documentation
71152 Corrective Action CR-YYYY-NNNN 2018-1550, 2018-2038, 2020-008417
Documents
71152 Corrective Action TR-YYYY-NNNN 2018-2038 ,2018-5898, 2020-5057, 2021-000414
Documents
14