IR 05000445/2022001
| ML22109A182 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak |
| Issue date: | 04/26/2022 |
| From: | Greg Werner NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2022001 | |
| Download: ML22109A182 (16) | |
Text
April 26, 2022
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000445/2022001 AND 05000446/2022001
Dear Mr. Peters:
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On April 7, 2022, 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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, Gregory E. Werner, Chief 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:
05000445/2022001 and 05000446/2022001
Enterprise Identifier: I-2022-001-0006
Licensee:
Vistra Operations Company, LLC
Facility:
Comanche Peak Nuclear Power Plant, Units 1 and 2
Location:
Glen Rose, TX 76043
Inspection Dates:
January 1, 2022, to March 31, 2022
Inspectors:
N. Day, Resident Inspector
J. Ellegood, Senior Resident Inspector
D. Nani, Project Engineer
D. Proulx, Senior Project Engineer
A. Smallwood, Project Engineer
H. Strittmatter, Project Engineer
S. Hedger, Senior Emergency Preparedness Inspector
Approved By:
Gregory E. Werner, Chief
Projects Branch B
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,
Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Maintain FLEX Strategy Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000446,05000445/2022001-01 Open/Closed
[P.5] -
Operating Experience 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.155,
Mitigation of Beyond Design Bases Events. Specifically, the licensee failed to maintain batteries associated with the steam generator fill pumps. This resulted in a failure to meet the minimum number of two pumps necessary to ensure sufficient capacity and capability to meet the FLEX strategy for a loss of normal heat sink.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000446/21001-01 Reactor Trip Due to Fault on Main Transformer 2MT1 71153 Closed
PLANT STATUS
Unit 1 operated at or near 100 percent power for the entire inspection period.
Unit 2 operated at or near 100 percent with two exceptions when the unit reduced power in response to grid congestion.
- On March 14, 2022, Unit 2 reduced power to approximately 85 percent. The unit returned to 100 percent on March 15, 2022.
- On March 29, 2022, Unit 2 reduced power to approximately 63 percent and returned to 100 percent later that day.
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, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of cold temperatures.
- Feedwater on January 6.
- Condensate Storage tanks on January 21
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)25 KV loop equipment on January 12, 2022
- (2) Unit 2, Emergency Diesel Generator 2-01 on February 1, 2022
- (3) Unit 1, turbine driven auxiliary feedwater pump on February 18, 2022
- (4) Spent fuel pool cooling train A on March 10, 2022
- (5) Unit 1, lightning arrester system on March 24, 2022
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, component cooling water pump Rooms 1-01 and 1-02, Fire Areas 27 and 33 on February 2, 2022
- (2) Unit 2, centrifugal charging pump Rooms 2-01 and 2-02, Fire Areas 29 and 30, on February 2, 2022
- (3) Unit 2, train B emergency diesel generator on March 7, 2022
- (4) Unit 2, train A emergency diesel generator on March 8, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
- (1) Centrifugal Charging Pump 2-01 lube oil cooler on February 15, 2022
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 component cooling water system realignment on March 9, 2022
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a scenario on February 7, 2022
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Partial)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)
(Partial) Unit 2 neutron monitoring well ventilation
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2, elevated risk due to Emergency Diesel Generator 2-02 maintenance on February 2, 2022
- (2) Unit 1, elevated risk due to component cooling water motor oil replacement on February 17, 2022
- (3) Unit 2, elevated risk during Emergency Diesel Generator 2-02 ventilation maintenance on March 2, 2022
- (4) Unit 1, storage of material and temporary equipment in containment at power on March 23, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Radiation monitor 2-RE-5503 with periodic spikes
- (2) Units 1 and 2, train B control room air conditioning with compressor X-03 not functional
- (3) Condensate storage tank level indicators bias from nitrogen blanket
- (4) Pressurizer power operated relief valve with loose fuse
- (5) Offsite power following firewater spray on transformers auxiliary power source
71111.18 - Plant Modifications
Control Room heating, ventilation, and air conditioning system for the following:
- Like-for-like compressor change for control room air compressor X-03
- Configuration management of control room air compressor X-03 compressor change
- Technical specification bases revision to allow operability of a train with one control room air compressor unit inoperable
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
- (1) Control room air conditioning from bases change and like-for-like compressor replacement
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Unit 1, Residual Heat Removal Pump 1-01 per Work Order 21-802016 on January 13, 2022
- (2) Unit 1, train B containment spray pumps per Work Orders 6034550 and 6034618 on March 23, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
- (1) Unit 1, fuel transfer tube leakage rate testing per Work Order 5927472 on January 11, 2022
- (2) Unit 2, Emergency Diesel Generator 2-02 surveillance on March 2, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Inservice test of Safety Injection Pump 1-02 on January 31, 2022
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 in Emergency Action Level (EAL) Classification Matrix and EAL Technical Bases Document, Revision 3, to the NRC on January 13, 2022. The inspectors conducted an in-office review of the changes from January 16 to February 22, 2022. This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) Emergency planning drill on February 16,
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 02.01)===
- (1) Unit 1 (January 1, 2021, through December 31, 2021)
- (2) Unit 2 (January 1, 2021, through December 31, 2021)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 1 (January 1, 2021, through December 31, 2021)
- (2) Unit 2 (January 1, 2021, through December 31, 2021)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 1 (January 1, 2021, through December 31, 2021)
- (2) Unit 2 (January 1, 2021, through December 31, 2021)
===71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02)===
- (1) Steam generator FLEX pump and meteorological tower diesel generators following battery failures
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample 1 Partial)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000446/2021-001-01, Reactor Trip Due to Fault on Main Transformer 2MT1 (ADAMS Accession No. MLML22060A103). The inspectors did not identify a violation of NRC requirements nor did the inspectors identify a performance deficiency.
(2)
(Partial)
LER 05000445/2020-001-00, Main Feedwater Pump Failure to Trip (ADAMS Accession No. ML21041A178): The licensee has not completed a cause determination for the failure of the main feed pump to trip since the evaluation requires an outage. Therefore, the inspectors cannot determine if a performance deficiency exists. The licensee plans on additional investigation during a planned outage in the second quarter of 2022. The inspectors have not identified any on-going safety concerns.
INSPECTION RESULTS
Failure to Maintain FLEX Strategy Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000446,05000445/2022001-01 Open/Closed
[P 5] - Operating Experience 71152A The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.155, Mitigation of Beyond Design Bases Events. Specifically, the licensee failed to maintain batteries associated with the steam generator fill pumps. This resulted in a failure to meet the minimum number of two pumps necessary to ensure sufficient capacity and capability to meet the FLEX strategy for a loss of normal heat sink.
Description:
Comanche Peak has three steam generator auxiliary feedwater low pressure FLEX pumps, designated X-01, X-02, and X-03, intended to provide inventory to steam generators in the event of a beyond-design-bases event. On July 26, 2021, the licensee identified that the battery for FLEX pump X-03 was dead and replaced the battery.The licensee had just completed a quarterly test run of FLEX pumps X-01 and X-02, thus establishing the current functionality of those pumps. On August 10, 2021, the site received, and entered into their tracking system operating experience from South Texas Project regarding a non-cited violation for failing to maintain batteries for FLEX diesel generators. The only action taken on this operating experience was informal benchmarking and that was not performed until January 2022. On September 29, 2021, the licensee started the yearly maintenance on the pumps.The first pump tested, FLEX pump X-01, failed due to a dead battery. Rather than replacing the battery expeditiously and completing the scheduled maintenance testing on the other two pumps, the licensee stopped testing, pendingFLEX pump X-01 battery replacement. The following provides a timeline of their actions:
- 09/29/2021 -Yearly inspection in accordance with Work Order 5977589 started for all three steam generator FLEX fill pumps with maintenance personnel identifying the battery for FLEX pump X-01 dead. Maintenance personnel emailed the FLEX engineer that the FLEX pump X-01 had a dead battery but no corrective action document was initiated.
- 10/04/2021 - Engineering performed a FLEX building walkdown and found the FLEX pump X-01 battery dead and the battery charger missing. Condition report CR-2021-006325 and Work Order 21-772917 were created.
- 10/14/2021 - Maintenance satisfactorily tested FLEX pumps X-01, X-02 and X-03 via quarterly Work Order 21-731086 and Preventive Maintenance 350678 tasks.
There was no record of FLEX pump X-01 battery replacement.
- 11/22/2021 - FLEX pump X-03 battery charger found not functioning. The licensee initiated corrective action document TR-2021-008003 and Work Orders 21-873125 and 21-873126.
- 12/20/2021 - Maintenance, with the NRC resident observing, goes back out to complete yearly maintenance in accordance with Work Order 5977589. The licensee initiated corrective action document TR-2021-008547 and Work Order 6008784.
- 12/21/2021 - Maintenance replaced the battery for FLEX pump X-01 and successfully started the pump.
- 12/22/2021 - Maintenance found FLEX pump X-02 battery dead. The licensee initiated condition report CR-2021-008575, replaced the battery, and successfully started FLEX pumps X-02 and X-03 later that day, completing the yearly maintenance (Work Order 5977589)..
The licensee adopted NRC endorsed NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, for FLEX implementation.Step 11.5, states in part, that, "Portable equipment that directly performs a FLEX mitigation strategy for the core, containment, or SFP should be subject to maintenance and testing guidance provided in INPO AP 913, Equipment Reliability Process, to verify proper function. The maintenance program should ensure that the FLEX equipment reliability is being achieved." In this case, the pumps mitigate core damage by providing a water source to the steam generators which then removes heat from the reactor.The licensee failed to ensure FLEX equipment reliability in that two FLEX pumps used for loss of normal heat sink to fill the steam generators were non-functional at the same time due to dead batteries on FLEX pumps X-01 and X-02.
Corrective Actions: The licensee replaced the degraded batteries on December 22, 2021 and tested all thee FLEX pumps satisfactorily.
Corrective Action References: TR 2021-8575
Performance Assessment:
Performance Deficiency: The licensee failed to maintain strategies to mitigate beyond-design basis external events. Specifically the licensee failed to ensure batteries for FLEX pumps remained functional.Internal and external operating experience provided indications that batteries required maintenance or replacement to ensure strategies for mitigating beyond design bases events were maintained.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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.
Significance: The inspectors assessed the significance of the finding using the mitigating systems cornerstone questions in Exhibit 2 of IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Per question number E2, a detail risk evaluation was needed to be performed. A senior reactor analyst performed a detailed risk evaluation of the performance deficiency, assuming the error existed from October 14, 2021 through December 21, 2021. The finding was determined to have a total delta core damage frequency of 3.1E-7/year, which is very low safety significance (Green).
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. The inspectors noted that the licensee neither evaluated nor assessed extent of condition from July 26, 2021, to December 22, 2021.Timely action in response to earlier failures or to operating experience, internal and external, would have ensured the mitigating strategy remained viable.
Enforcement:
Title 10 CFR 50.155(b) requires, in part, that "licensee shall develop, implement, and maintain:
- (1) Mitigation strategies for beyond-design basis external eventsStrategies and guidelines to mitigate beyond-design-basis external events from natural phenomena that are developed assuming a loss of all ac power concurrent with either a loss of normal access to the ultimate heat sink or, for passive reactor designs, a loss of normal access to the normal heat sink. These strategies and guidelines must be capable of being implemented site-wide..." In addition, 10 CFR 50.155(c)(1), requires in part, The equipment relied on for the mitigation strategies and guidelines required by paragraph (b)(1) of this section must have sufficient capacity and capability to perform the functions required by paragraph (b)(1) of this section. Contrary to these requirements, the licensee failed to maintain the equipment relied on for the mitigation strategies sometime between the October 14 test and the December 21, 2021 test.Specifically, FLEX pumps X-01 and X-02 were not able to be started due to dead batteries and therefore could not provide sufficient capacity and capability, which was a minimum of two pumps, necessary to perform the functions needed to implement the mitigation strategy.
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 February 22, 2022, the inspectors presented the emergency action levels documentation in-office review inspection results to Mr. P. Allen, Manager, Emergency Preparedness, and other members of the licensee staff.
- On April 7, 2022, the inspectors presented the integrated inspection results to Thomas McCool, Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed an Institute on Nuclear Power Operations report that was issued in the fourth quarter of 2021.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
SOP-609B
Diesel Generator System
Procedures
FPI-403
Auxiliary Building Elevation 810'-6"
Corrective Action
Documents
IR-2022-001140
Documenting thin black scale on CCP 2-01 and 2-02 lube oil
cooler service water tubes
Engineering
Evaluations
EV-IR-2022-
000703-1
Past Operability for 2-02 CCP LO Cooler Gasket
Miscellaneous
DBD-ME-233
Design Basis Document Station Service Water System
Work Orders
Service Water Visual Inspection Form for CCP 2-01 Lube Oil
Cooler
2/15/2022
71111.11Q Miscellaneous
LO47.B22.CLS
Cycle 22-2 Cold Look
Procedures
STI-600.01
Protecting Plant Equipment and Sensitive Equipment
Controls
Calculations
MEB-240
Condensate Storage Tank Technical Specification Limit
Calculations
IC(B)097
Instrument Uncertainties and Indicator Loop Accuracy for
CST Level Instrumentation Loops 1-LI-2478A and 1-LI-
2479A
Corrective Action
Documents
CR-YYYY-NNNN
2017-10280, 2017-10346, 2017-10346, 2017-10346,
21-008257, 2021-008257
Drawings
E1-0017
Common Turbine Control and Auxiliary BLDGs Normal 480v
MCC's One Line Drawing
Procedures
OPT-204A
SI System
Miscellaneous
CP-202000209,
Comanche Peak Nuclear Power Plant (CPNPP), Docket
Nos. 50-445 and 50-446; License Amendment Request 20-
004 for Revision to the Emergency Plan - Changes to
Certain Emergency Action Levels
05/21/2020
Miscellaneous
CP-202100113,
Comanche Peak Nuclear Power Plant (CPNPP), Docket
Nos. 50-445 and 50-446; Supplement to Request a Change
to the Implementation Date for License Amendment Request
20-004 for Revision to the Emergency Plan - Changes to
Certain Emergency Action Levels
2/24/2021
Miscellaneous
CP-202200020,
Comanche Peak Nuclear Power Plant (CPNPP), Docket
Nos. 50-445, 50-446 and 72-74; Transmittal of Revised
01/13/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency Action Level (EAL) Classification Matrix and EAL
Bases Document
Miscellaneous
EPP-201, Tech
Bases
Emergency Action Level Technical Bases Document
1, 2, 3
Miscellaneous
TR-2018-000626;
TR-2021-000145
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Screening Evaluation Form, Correct Error on RCS Extended
Wide Range Device and RG1 References in Emergency
Action Levels (EAL) Technical Bases Document
2/01/2021
Miscellaneous
TR-2019-002081,
TR-2019-006051
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Screening Evaluation Form, Changes to the Comanche
Peak Nuclear Power Plant (CPNPP) Emergency Action
Levels (EALs)
2/10/2019
Miscellaneous
TR-2019-002081,
TR-2019-006051
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Effectiveness Evaluation Form, Changes to the Comanche
Peak Nuclear Power Plant (CPNPP) Emergency Action
Levels (EALs)
2/10/2019
Miscellaneous
TR-2021-000145;
TR-2021-002480
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Effectiveness Evaluation Form, Changes to the NRC
Emergency Telecommunications System
05/24/2021
Miscellaneous
TR-2021-000145;
TR-2021-002938
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Screening Evaluation Form, Adding Satellite Phones to List
of Communication Systems with Offsite and NRC
Organizations
11/3/2021
Miscellaneous
TR-2021-000145;
TR-2021-002938
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Effectiveness Evaluation Form, Adding Satellite Phones to
List of Communication Systems with Offsite and NRC
Organizations
11/3/2021
Miscellaneous
TR-2021-002480;
TR-2021-000145
Comanche Peak Nuclear Power Plant 10 CFR 50.54(q)(3)
Screening Evaluation Form, Changes to the NRC
Emergency Telecommunications System
05/24/2021
Procedures
EPP-123
CFR 50.54(q) Screening and Evaluation of Changes to
Emergency Plan Documentation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
EPP-201
Assessment of Emergency Action Levels Emergency
Classification and Plan Activation
Corrective Action
Documents
CR-YYYY-NNNN
20-7334,2021-3763