ML22299A056
| ML22299A056 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/01/2022 |
| From: | Greg Werner NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| Werner G | |
| References | |
| IR 2022003 | |
| Download: ML22299A056 (30) | |
See also: IR 05000445/2022003
Text
November 1, 2022
Mr. Ken Peters
Senior Vice President
and Chief Nuclear Officer
Vistra Operations Company, LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 INTEGRATED
INSPECTION REPORT 05000445/2022003 AND 05000446/2022003 AND NOTICE
OF VIOLATION
Dear Mr. Peters:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On October 6, 2022, the
NRC inspectors discussed the results of this inspection with Mr. A. Marzloff, Plant Manager, and
other members of your staff. The results of this inspection are documented in the enclosed
report.
The enclosed report discusses a Severity Level IV violation. The NRC evaluated this violation in
accordance with section 2.3.2 of the NRC Enforcement Policy, which can be found at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in
Enclosure 1, Notice of Violation (Notice), and the circumstances surrounding it are described in
detail in the subject inspection report (Enclosure 2). We determined that this violation did not
meet the criteria to be treated as a non-cited violation (NCV) because your staff failed to restore
compliance within a reasonable period after the violation was identified consistent with
section 2.3.2 of the NRC Enforcement Policy. You are required to respond to this letter and
should follow the instructions specified in the enclosed Notice when preparing your response.
The NRCs review of your response will also determine whether further enforcement action is
necessary to ensure your compliance with regulatory requirements.
Additionally, 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 an NCV
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
K. Peters 2
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.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter, its enclosures, and your response will be made available electronically for public
inspection in the NRC Public Document Room or in the NRCs Agencywide Documents
Access and Management System (ADAMS), accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not
include any personal privacy or proprietary information so that it can be made available to the
public without redaction.
Sincerely,
Signed by Werner, Gregory
on 11/01/22
Gregory E. Werner, Chief
Projects Branch B
Division of Operating Reactor Safety
Docket Nos. 05000445, 05000446
Enclosures:
1. Notice of Violation
2. Inspection Report 05000445/2022003
and 05000446/2022003
cc w/ encl: Distribution via LISTSERV
X Non-Sensitive x Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE SRI:DORS/B RI:DORS/B SEC:ACES TL/ACES
SIGNATURE JEllegood /RA/ NDay /RA/ JKramer /RA/ JGroom /RA/
DATE 10/19/2022 10/19/2022 10/27/2022 10/28/2022
OFFICE SPE:DORS/B BC:DORS/B D: DORS BC:DORS/B
SIGNATURE DProulx /RA/ GWerner GEW RLantz GWerner GEW
DATE 10/26/2022 10/26/2022 10/31/2022 11/01/2022
NOTICE OF VIOLATION
Vistra Operations Company, LLC Docket No. 50-445
Comanche Peak Nuclear Power Plant, Unit 1 License No. NPF-87
During an NRC inspection conducted from June 1 to September 30, 2022, a violation of NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 of the Code of Federal Regulations (10 CFR) 50.59(c)(2) requires, in part, that a
licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing
a proposed change if the change would: result in more than a minimal increase in the
likelihood of occurrence of a malfunction of a structure, system, or component (SSC)
important-to-safety previously evaluated in the final safety analysis report (as updated); or,
create a possibility for a malfunction of an SSC important to safety with a different result
than any previously evaluated in the final safety analysis report (as updated).
Contrary to the above, from February 13, 2019, to September 30, 2022, the licensee failed
obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed
change if the change that would: result in more than a minimal increase in the likelihood of
occurrence of a malfunction of a SSC important-to-safety previously evaluated in the final
safety analysis report (as updated); or, create a possibility for a malfunction of an SSC
important to safety with a different result than any previously evaluated in the final safety
analysis report (as updated). Specifically, the licensee revised the Final Safety Analysis
Report associated with the Unit 1 DC power system to change the facility's commitments to
NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with General Design
Criterion 5, without obtaining a license amendment.
This is a Severity Level IV violation (Enforcement Policy Section 6.1.d.4).
Pursuant to the provisions of 10 CFR 2.201, Vistra Operations Company, LLC., is hereby
required to submit a written statement or explanation to U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd., Arlington,
TX 76011-4511, and a copy to the NRC resident inspector at Comanche Peak Nuclear Power
Plant, Units 1 and 2, within 30 days of the date of the letter transmitting this Notice of Violation
(Notice). This reply should be clearly marked as a Reply to a Notice of Violation and should
include for the violation: (1) the reason for the violation or, if contested, the basis for disputing
the violation or severity level, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will
be achieved.
Your response may reference or include previous docketed correspondence if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
2
If you contest this enforcement action, you should also provide a copy of your response, with the
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs Agencywide Documents Access and Management
System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-
rm/adams.html, to the extent possible, it should not include any personal privacy or proprietary
information so that it can be made available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure of information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
Dated this 1st day of November, 2022
3
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000445 and 05000446
License Numbers: NPF-87 and NPF-89
Report Numbers: 05000445/2022003 and 05000446/2022003
Enterprise Identifier: I-2022-003-0003
Licensee: Vistra Operations Company, LLC
Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2
Location: Glen Rose, TX 76043
Inspection Dates: June 1 to September 30, 2022
Inspectors: R. Alexander, Regional State Liaison Officer
J. Braisted, Senior Reactor Inspector
D. Bryen, Reactor Inspector
N. Day, Resident Inspector
J. Ellegood, Senior Resident Inspector
G. George, Senior Reactor Inspector
R. Kopriva, Senior Reactor Inspector
D. Reinert, Reactor Inspector
H. Strittmatter, Emergency Preparedness Inspector
Approved By: Gregory E. Werner, Chief
Projects Branch B
Division of Operating Reactor Safety
Enclosure 2
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 Restore Compliance for Non-Cited Violation 05000445/2019001-02 "Failure to
Evaluate a Change to the Facility DC Power System"
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71111.17T
Open
The inspectors identified a Severity Level IV, notice of violation of 10 CFR 50.59, "Changes,
tests, and experiments," for the failure to restore compliance of previously identified non-cited
violation 05000445/2019001-02. The previous violation identified the licensee's failure to
obtain a license amendment or perform a written evaluation demonstrating the basis for not
obtaining a license amendment prior to making a change to the facility as described in the
Final Safety Analysis Report. Specifically, the licensee revised the Final Safety Analysis
Report to change the facility's commitments to NRC Regulatory Guide 1.81, which
demonstrated compliance with General Design Criterion 5, without obtaining a license
amendment.
Degraded Emergency Response Facility Communications Capabilities
Cornerstone Significance Cross-Cutting Report
Aspect Section
Emergency Green [P.3] - 71152A
Preparedness NCV 05000445,05000446/2022003-02 Resolution
Open/Closed
The inspectors identified a Green finding and associated non-cited violation of 10 CFR
50.47(b)(6) when the licensee failed to ensure prompt communications among principal
response organizations were available from the main control room. Specifically, on March 21,
2022, due to a loss of internet and degraded backup communication methods, there were no
communication methods available from within the main control room to contact offsite
response organizations.
Additional Tracking Items
None.
2
PLANT STATUS
On September 5, Unit 1 tripped due to a trip of the main turbine from 100 percent power. The
licensee corrected the issue causing the trip and restarted Unit 1 on September 12, 2022. Unit 1
returned to 100 percent on September 15, 2022.
Unit 2 remained at or near rated thermal power for the entire assessment 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
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1) High winds and drought conditions contributed to wildfires that came within three
miles of the plant on July 19, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1, diesel generators diesel and exhaust systems on July 20, 2022
(2) fire pumps on July 22, 2022
(3) independent spent fuel storage installation on July 30, 2022
(4) Unit 2, train A diesel generator starting air system on September 1, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
Unit 2 containment spray A system on August 4, 2022.
3
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, trains A and B component cooling water pumps on August 8, 2022
(2) Units 1 and 2, component cooling water heat exchanger room on August 8, 2022
(3) Unit 1, emergency diesel generator 1-01 room and fuel oil day tank 1-01 room on
September 26, 2022
(4) Unit 1, emergency diesel generator 1-02 room and fuel oil day tank 1-02 room on
September 26, 2022
(5) Unit 1, charging pump rooms on September 29, 2022
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the onsite fire brigade training and performance during an
unannounced fire drill on September 2, 2022.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
(1) Unit 2, feedwater enclosures
(2) 25KV power cable vaults supplying independent spent fuel storage installation power
71111.07T - Heat Exchanger/Sink Performance
Heat Exchanger (Service Water Cooled) (IP Section 03.02) (1 Sample)
The inspectors evaluated heat exchanger performance on the following:
(1) component cooling water pump lube oil cooler 1-02
Heat Exchanger (Closed Loop) (IP Section 03.03) (2 Samples)
The inspectors evaluated heat exchanger performance on the following:
(1) motor driven auxiliary feedwater pump room fan cooler 1-07
(2) residual heat removal pump room fan cooler 2-01
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
The inspectors evaluated the ultimate heat sink performance on the following:
(1) ultimate heat sink and service water system
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 plant cooldown to 205 degrees Fahrenheit on September 7, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated a simulated control room fire and plant
shutdown on August 9, 2022.
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) Units 1 and 2, 6.9 kilovolt distribution system.
(2) Unit 2, turbine control system.
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 1, risk controls associated with feedwater heater outlet pressure transmitter 0508
card replacement on July 17, 2022
(2) Unit 1, operator actions to maintain availability of the turbine driven auxiliary
feedwater pump 1-01 on August 4, 2022
(3) Unit 1, flooding, and operator response due to circulating water lube water
pumps 1-01 and 1-02 flooding on August 9, 2022
(4) Unit 1, forced outage risk for the week of September 5, 2022
(5) Unit 1, startup risk on September 11 and 12, 2022
(6) Unit 1, risk during emergent motor driven feedwater pump 1-01 recirculation line leak
on September 15, 2022.
5
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) Unit 2, pressurizer heaters per condition report 2022-5808
(2) Unit 1, pressurizer master controller 1-PK-455A per condition report 2022-005681
(3) Unit 1, turbine driven and motor driven feedwater pump 1-02 per condition
report 22-006748
(4) Unit 1, emergency diesel generator 1-02 starting air receiver 1-03 leaking by
valve 1DO-0041 per condition reports 21-008182 and 22-006804
(5) Unit 2, tornado door per tracking report 2022-006923.
71111.17T - Evaluations of Changes, Tests, and Experiments
Sample Selection (IP Section 02.01) (27 Samples)
The inspectors reviewed the following evaluations, screenings, and/or applicability
determinations for 10 CFR 50.59 from [enter dates].
(1) EV-CR-2019-000901-2, Replace Units 1 and 2 Diesel Generator Starting Air
Compressors
(2) EV-CR-2022-005805-8, Comp Action to Intermittently Isolate 1-HV-4393, Diesel
Generator, Service Water Outlet Flow Valve
(3) EV-IR-2021-003710-1, Shift Manager Clearance SMP21-0016 STA-707 Review
(4) EV-TR-2019-001133-5, FDA-2019-000036-01 / TM 5735389
(5) EV-TR-2019-009096-1, Maintenance Clearance TR-2019-009096 Spent Fuel
Pool X-02 Ventilation Exhaust Fan X-35 Motor
(6) EV-TR-2020-005137-11, Containment Building Polar Crane Use During Modes 3
Through 4
(7) EV-TR-2020-007888-3, Lubrication Recommendation Change to the Station Service
Water Pump Motor 1-02 Lower Bearing Grease
(8) EV-TR-2021-002308-9, Plugging up to 65 Tubes in the Unit 1 & Unit 2 CCW HXs
(CP1/2-CCAHHX-01/-02)
(9) EV-TR-2021-003204-1, Maintenance Clearance Greater Than 90 Days on
CPX-WTPMWP-01 Water Treatment Waste Sump X-01
(10) EV-IR-2021-003254-1, Comp Action Evaluation for Monitoring RCP 1-03 Vibration
(11) EV-TR-2019-000777-6, VDRT 5775695, Westinghouse Calculation CN-PCSA-14-5,
Revision 2
(12) EV-CR-2019-003377-8, Change Control Room A/C Units (CRAC) Compressor
Suction Pressure Pumpdown Setpoint to greater than or equal to 45 psig
(13) EV-TR-2020-003698-5, Shift Manager Clearance Placed to Isolate 2-HV-4166
Leaking By
(14) EV-TR-2021-000607-1, Maintenance Clearance CP20-1066 Unit 2 Train A UPS
Room Fan Coil Unit CP2-VAAUPR-01
(15) EV-TR-2019-06006-15, Application of WCAP-17627, Revision 1, to Unit 2 Reload
Analyses, beginning with Unit 2 Cycle 19 and Subsequent Unit 1 and Unit 2 Reload
Analyses (50.59 Safety Evaluation)
6
(16) EV-TR-2019-007450-4, Procedure Revision - Response to a Fire in the Control
Room or Cable Spreading Room
(17) EV-CR-2020-009014-1, Unit 1 Turbine Shaft Displacement Channel 1 Defective
Components
(18) EV-CR-2019-004542-5, Perform STA-707
(19) EV-CR-2020-005070-11, Compensatory Action: Manually Purging of Safety Chiller
(20) EV-CR-2021-002241-3, XEB4-2/1SS Motor Control Center Transfer Switch
Maintained in Off Position
(21) EV-CR-2020-002810-9, Unit 2 Train B Core Exit Thermocouple Alternate
Temperature Monitoring
(22) EV-TR-2020-002067-7, Manual Control Rod Drop Timing
(23) EV-TR-2019-008867-1, Degraded RCP Seal Standpipe Level Control Valve on
Reactor Coolant Pumps 2-01 and 2-03
(24) EV-CR-2018-004605-4, Component Cooling Water Pump Shaft Bearing Diameter
and Tolerance Changes
(25) 59SC-2017-000182-01, Increase Time Delay for Reactor Coolant Pump Vibration
Alarm
(26) 59SC-2019-000025-01, Replace Alternate Power Diesel Generators
(27) 59SC-2019-000051-01, Motor Operated Valve Limit Switch Setting Modifications
71111.18 - Plant Modifications
Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)
(1) The inspectors verified the site Severe Accident Management Guidelines were
updated in accordance with the pressurized water reactor generic severe accident
technical guidelines and validated in accordance with NEI 14-01, Emergency
Response Procedures and Guidelines for Beyond Design Basis Events and Severe
Accidents, revision 1.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) Unit 1, pressure transmitter 0508 feedwater heater outlet header pressure transmitter
following card replacement per work order 22-345906
(2) Unit 1, repairs to turbine shaft displacement probes between per work
order 22-448268
(3) Unit 1, pressurizer heater control 1-PK-455A per work order 22-381599
(4) Unit 2, pressurizer heater control 2-PK-455A per work order 22-394264
(5) Unit 1, motor driven auxiliary feedwater pump 1-01 recirculation line leak repair per
work order 22-457619
(6) Unit 1, main feedwater pump 1B following servo replacement per work
orders 22-456325 and 22-456467
7
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated a forced outage between September 6 and 12, 2022
caused by a unit trip. The unit trip resulted from a turbine trip caused by a spurious
shaft displacement indication.
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) (4 Samples)
(1) Unit 2, pressurizer heater per procedure IPO-001B on December 1, 2021
(2) Unit 1, pressurizer heaters per procedure IPO-001A on May 8, 2022
(3) Unit 2, condensate storage tank inspection on August 23, 2022
(4) Unit 1, scram breaker testing on September 12, 2022.
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
(1) The inspectors evaluated the biennial emergency plan exercise conducted on July 26
and 27, 2022. The exercise scenario simulated a greater than Operating Basis
Earthquake seismic event resulting in several simulated in-plant failures requiring the
rapid escalation to a Site Area Emergency declaration due the loss of all cooling
water flow to the secondary heat sink. Though the scenario did not include a
radiological release requiring issuance of protective action recommendations to the
offsite authorities, it did include opportunities for the licensee emergency response
organization to mitigate and repair additional simulated failures in electrical
switchgear and respond to a simulated medical emergency. The licensee's exercise
activities during the week also included a separate emergency scenario which
required the licensee demonstrate of one of the station's extensive damage mitigation
guideline strategies, per the requirements of 10 CFR 50.155(b)(2), in mitigating the
loss of the spent fuel pool water inventory.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
(1) The inspectors evaluated the following submitted Emergency Action Level and
Emergency Plan changes.
- ANS (Alert and Notification System) Design Report, revision 2, change
1 -effective March 11, 2021
- On-Shift Staffing Analysis, revision 1 - effective June 24, 2021
- Emergency Plan, revision 45 - effective June 15, 2022.
This evaluation does not constitute NRC approval.
8
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
(1) Unit 1 (July 1, 2021, through June 30, 2022)
(2) Unit 2 (July 1, 2021, through June 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
(1) Unit 1 (July 1, 2021, through June 30, 2022)
(2) Unit 2 (July 1, 2021, through June 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
(1) Unit 1 (July 1, 2021, through June 30, 2022)
(2) Unit 2 (July 1, 2021, through June 30, 2022)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
(1) Unit 1 (July 1, 2021, through June 30, 2022)
(2) Unit 2 (July 1, 2021, through June 30, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
(1) Unit 1 (July 1, 2021, through June 30, 2022)
(2) Unit 2 (July 1, 2021, through June 30, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
(1) April 1, 2021, through June 30, 2022
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)
(1 Sample)
(1) April 1, 2021, through June 30, 2022
EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1) April 1, 2021, through June 30, 2022
9
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) loss of internet in the main control room and the impact on Emergency Plan
communication equipment
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Followup (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated a Unit 1 trip and licensees response on September 5 and
6, 2022.
INSPECTION RESULTS
Failure to Restore Compliance for Non-Cited Violation 05000445/2019001-02 "Failure to
Evaluate a Change to the Facility DC Power System"
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Severity Level IV Not 71111.17T
Applicable NOV 05000445/2022003-01 Applicable
Open
The inspectors identified a Severity Level IV, notice of violation (NOV) of 10 CFR 50.59,
"Changes, tests, and experiments," for the failure to restore compliance of previously
identified non-cited violation (NCV)05000445/2019001-02. The previous violation identified
the licensee's failure to obtain a license amendment or perform a written evaluation
demonstrating the basis for not obtaining a license amendment prior to making a change to
the facility as described in the final safety analysis report. Specifically, the licensee revised
the Comanche Peak Final Safety Analysis Report (FSAR) to change the facility's
commitments to NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with
General Design Criterion 5, without obtaining a license amendment.
Description: The inspectors reviewed corrective actions associated with
NCV 05000445/2019001-02. Through review of the associated condition
reports (CR) 2019-001711 and CR-2019-004542, the inspectors identified that the licensee
did not restore compliance with the requirements of 10 CFR 50.59, Change, tests, and
experiments. Specifically, the licensee failed to correct the NCV when they closed corrective
actions for the violation without obtaining a license amendment.
In January 2000, the licensee discovered electrical power panels that shared safety-related
alternating current and direct current electrical power between Units 1 and 2, contrary to what
was described in the Comanche Peak FSAR and NUREG-0797, Safety Evaluation Report
related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2, Docket
Nos. 50-445 and 50-446, Supplement 22. The licensee took corrective action to modify the
plant and revise the FSAR description of their original commitments to NRC RG 1.81,
Shared Emergency and Shutdown Electric Systems for Multi-Unit Nuclear Power Plants.
9
RG 1.81 was used by the licensee to comply with General Design criterion 5, Sharing of
structures, systems, and components.
In April 2002, the licensee issued 10 CFR 50.59 screening document 59SC-2000-000142-02-
02 which changed the description of RG 1.81 commitments in the FSAR. The licensee was
originally committed to positions C.1 and C.3 of RG 1.81, which describes that there was no
sharing of emergency power sources between units. The 10 CFR 50.59 screening document
changed the description of the licensees commitment to position C.2 of RG 1.81, which
allowed sharing of emergency power sources given specific conditions. Specifically,
position C.2 applied only to plants under construction permits issued before June 1, 1973,
and the position was NRC reviewed on an individual case basis. The change was
screened-out of the 10 CFR 10.59 process and no license amendment was submitted.
The inspectors determined that the licensee inappropriately applied position C.2 of RG 1.81
because the Comanche Peak construction permit was issued after June 1, 1973, and
Comanche Peak was originally evaluated against position C.3 of RG 1.81. The inspectors
determined these were changes to commitments that were used to meet General Design
Criteria 5. Additionally, the unit specific loads on the common unit panels could result in new
failure modes for previously evaluated accidents.
The inspectors reviewed 10 CFR 50.59 guidance as documented in NEI 96-07, revision 1,
Guidelines for 10 CFR 50.59 Implementation, as endorsed by NRC RG 1.187, revision 3,
"Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments." Based
on this determination, the inspectors determined that the 10 CFR 50.59 screening document
should have screened to a 10 CFR 50.59 evaluation. Further, the 10 CFR 50.59 safety
evaluation would have determined that the licensee was required to submit a license
amendment for the change because the change resulted in more than a minimal increase in
the likelihood of occurrence of a malfunction of a structure, system, or component important
to safety previously evaluated in the final safety analysis report. Additionally, the change
created a possibility for a malfunction of a structure, system, or component important to
safety with a different result than any previously evaluated in the final safety analysis report.
Corrective Actions: The licensee entered the issue into the corrective action program. There
are no operability concerns because the licensee corrected the technical aspects of the issue
in previous corrective actions.
Corrective Action References: CR 2019-001711, CR-2019-003684, CR-2019-004542,
CR-2019-006767, CR-2022-006915, CR-2022-006916
Performance Assessment: The inspectors determined this violation was associated with a
minor performance deficiency.
Enforcement: The reactor oversight processes 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.
Severity: The violation was determined to be Severity Level IV using Section 6.1.d.4 of the
NRC Enforcement Policy, dated January 14, 2022. Specifically, it was a violation of
10 CFR 50.59 because the change required prior Commission review and approval, and the
violation was determined to be associated with a minor performance deficiency.
11
Violation: Title 10 CFR 50.59(c)(2) requires, in part, that a licensee shall obtain a license
amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change if the
change would: result in more than a minimal increase in the likelihood of occurrence of a
malfunction of a structure, system, or component (SSC) important-to-safety previously
evaluated in the final safety analysis report (as updated); or, create a possibility for a
malfunction of an SSC important to safety with a different result than any previously
evaluated in the final safety analysis report (as updated).
Contrary to the above, from February 13, 2019, to September 30, 2022, the licensee failed
obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed
change if the change that would: result in more than a minimal increase in the likelihood of
occurrence of a malfunction of a SSC important-to-safety previously evaluated in the final
safety analysis report (as updated); or, create a possibility for a malfunction of an SSC
important to safety with a different result than any previously evaluated in the final safety
analysis report (as updated). Specifically, the licensee revised the Final Safety Analysis
Report associated with the Unit 1 DC power system to change the facility's commitments to
NRC Regulatory Guide (RG) 1.81, which demonstrated compliance with General Design
Criterion 5, without obtaining a license amendment.
Enforcement Action: This violation is being cited because the licensee failed to restore
compliance within a reasonable period after the violation was identified consistent with
section 2.3.2 of the Enforcement Policy.
Degraded Emergency Response Facility Communications Capabilities
Cornerstone Significance Cross-Cutting Report
Aspect Section
Emergency Green [P.3] - 71152A
Preparedness NCV 05000445,05000446/2022003-02 Resolution
Open/Closed
The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.47(b)(6) when the licensee failed to ensure prompt communications among principal
response organizations were available from the main control room. Specifically, on March 21,
2022, due to a loss of internet and degraded backup communication methods, there were no
communication methods available from within the main control room to contact offsite
response organizations.
Description: On March 21, 2022, Comanche Peak experienced a loss of internet at the site.
This loss created degradation of communications in multiple emergency response facilities,
especially the main control room. The main control room has multiple methods of
communication available to communicate to various onsite, offsite, stakeholders, and the
NRC as described in section 4.0 of the Emergency Plan. Since many of the methods rely on
internet (e.g., voice over internet protocol (VOIP)) technology, the dependent communication
methods that relied upon internet were rendered non-functional. Table 4.1 in the Emergency
Plan illustrates the communication interfaces from Comanche Peak's facilities to the other
onsite/offsite facilities and response organizations with the different communication methods
available. The inspectors discussed available communications methods with licensee staff
and were informed that no communications methods were available in the control room
without breaching the control room envelope.
12
The unplanned loss of internet on March 21, 2022, lasted approximately one hour. The
inspectors noted that from March 10 through April 18, 2022, there were a total of five
instances of the loss of all internets at the site ranging from one hour to seventeen hours;
however, aside from the March 21, 2022, instance, some form of emergency communications
was available from within the control room. Furthermore, the inspectors noted there were
multiple loss of internet occurrences in 2021. However, the loss of internet occurrence on
March 21, 2022, was the most significant due to the contributing factors affecting the other
methods of communication concurrent with that loss. Specifically, the following methods were
affected; all commercial telephones due to their reliance on VOIP, the emergency notification
number due to its reliance on VOIP, the black start satellite phone (which is antenna wired
capable for control room use) due to inadequate instructions, VESTA online notification
program (notifies state/local authorities) due to its reliance on internet, and the land line
telephone system (copper based redundant telephone lines) due to degraded connection and
static. The individuals in the control room were left with no methods to make phone calls from
the control room envelope; however, the black start satellite phone could receive calls.
On March 21, 2022, Comanche Peak did have handheld satellite phones available; however,
for those phones to function, the antenna needed to be deployed outside of the control room
envelope. Although there is a door to the turbine building roof from the main control room, the
door forms part of the control room envelope and routing through the door violates the control
room envelope. While cell phones can normally be used via Wi-Fi, the internet loss precluded
main control room use of cell phones on March 21, 2022. The inspectors assessed this
situation to see if a viable compensatory method of communications among principal
response organizations was provided for in the event of a radiological emergency. To ensure
assumptions about the maximum radiological dose to control room emergency workers were
provided for their protection, the ventilation envelope could not be breached to set up the
antenna. Therefore, there was no viable compensatory measure in place. .
Comanche Peak updated the dedicated copper lines federal telephone system to VOIP
emergency notification system using RIS 2000-11 in the spring 2021 due to reliability
concerns of the copper circuitry. The inspectors noted that the licensee's modification to
VOIP protocols failed to account for the introduction of single point vulnerabilities.
Specifically, the connection to the sites internal network by the internet service provider
included only one line. Internet outages created by damage or degradation of a single line
occur on occasion; therefore, they are reasonably within the licensee's ability to foresee. In
addition, numerous losses occurred in 2021 providing the licensee with sufficient information
to recognize the vulnerability and take interim actions to ensure communications capability
until redundancy in the internet connection could be implemented. The inspectors note that
there was overall improvement in line clarity with the upgrade to emergency notification
system, but the station remained vulnerable to communications degradation due to the known
single point vulnerability.
The inspectors previously reviewed emergency preparedness communication issues in 2021.
No more than minor performance deficiencies were identified during that review. This
inspection was documented in the 71152 Inspection in the 2021004 (ADAMS Accession No.
ML22019A304 https://www.nrc.gov/docs/ML2201/ML22019A304.pdf).
Corrective Actions: For completed corrective actions, Comanche Peak has updated the black
start satellite telephone dialing protocol procedure and added a second internet line with a
diverse method (microwave vs. local area network). Planned corrective action included
adding a third internet line with a diverse switch which eliminates an existing single point
14
vulnerability in the currently installed internet lines. Additional actions are I documented in
CR-2022-1892.
Corrective Action References: Comanche Peak entered the loss of internet events into the
corrective action program under CR-2021-7895, tracking report (TR) 2022-1822,
TR-2022-1892, TR-2022-1886, CR-2021-3239, TR-2021-7938, CR-2021-6637,
TR-2021-5058, CR-2021-5014, TR 2021-1209, TR-2022-1688, TR-2021-5017,
CR-2022-1894, TR-2022-1823, TR-2022-1848, CR-2021-2796, TR-2021-7588.
Performance Assessment:
Performance Deficiency: The failure to ensure reliable emergency communication methods
were available from the control room was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Facilities and Equipment attribute of the Emergency
Preparedness cornerstone and adversely affected the cornerstone objective to ensure that
the licensee can implement adequate measures to protect the health and safety of the public
in the event of a radiological emergency. Specifically, on March 21, 2022, the unplanned loss
of internet impacted emergency communication methods to offsite response organizations,
which effects public health and safety in the event of a radiological emergency.
Significance: The inspectors assessed the significance of the finding using Manual
Chapter 0609, Significance Determination Process, attachment 4 (effective date December
13, 2019), and the corresponding Appendix B, Emergency Preparedness Significance
Determination Process, table 5.6-1. The performance deficiency was determined have very
low safety significance (Green) because it was a failure to comply with NRC requirements,
was a degraded planning standard function, and the deficiency lasted less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from
the time of discovery and there were no compensatory measures implemented.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to
address issues in a timely manner commensurate with their safety significance. Comanche
Peak modified the site's telecommunication infrastructure with the intent to improve the
reliability of control room communication by transitioning from degraded copper circuitry to
VOIP technology. However, the site experienced multiple outages the year following the
modification but failed to implement timely corrective actions prior to more significant
communications equipment outages.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and
maintain the effectiveness of an emergency plan which meets the requirements of
appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(6) requires, in part, that provisions exist for prompt communications among principal
response organizations to emergency personnel and to the public.
Contrary to the above, on March 21, 2022, the licensee failed follow and maintain the
effectiveness of an emergency plan which meets the requirements of appendix E to
10 CFR Part 50 and the standards of 10 CFR 50.47(b). Specifically, the license failed to meet
the planning standard in 10 CFR 50.47(b)(6) due to a loss of internet event and degraded
backups resulting in no communication methods available from within the main control room
to offsite response organizations.
14
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 July 28, 2022, the inspectors presented the triennial heat exchanger and heat sink
performance inspection results to Mr. T. McCool, Site Vice President, and other
members of the licensee staff.
On August 25, 2022, the inspectors presented the emergency plan exercise inspection
results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.
On September 22, 2022, the inspectors presented the evaluations of changes, tests, and
experiments inspection results to Mr. T. McCool, Site Vice President, and other
members of the licensee staff.
On October 6, 2022, the inspectors presented the integrated inspection results to
Mr. A. Marzloff, Plant Manager, and other members of the licensee staff.
15
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures SOP-204B Containment Spray System 6
71111.04 Procedures SOP-809A Diesel Generator Ventilation System 13
71111.04 Procedures SOP-904 Fire Protection Main Water Supply and Fire Pumps System 17
71111.04 Procedures SOP-908B Diesel Generator System 18
71111.05 Fire Plans FPI-104A Unit 1 Train A Diesel Generator and Equipment Elevation 4
810 and Fuel Oil Day Tank Room Elevation 844
71111.05 Fire Plans FPI-105A Unit 1 Train B Diesel Generator and Equipment Elevation 4
810 and Fuel Oil Day Tank Room Elevation 844
71111.05 Fire Plans FPI-401 Auxiliary Building Elevation 790'-6" 3
71111.05 Fire Plans FPI-403 Auxiliary Building Elevation 810'-6" 5
71111.05 Miscellaneous Drill No 22-12-03 Fire Drill Scenario: Train A Centrifugal Charging Pump 09/02/2022
71111.06 Calculations 2-NU-0059 Unit 2 Safeguards Building Flooding Analysis 3
71111.06 Corrective Action TR-YYYY-NNNN TR-2022-000683
Documents
71111.06 Corrective Action CR-YYYY-NNNN 2015-000079
Documents
71111.07T Calculations 1-EB-302-04 Auxiliary Feedwater Pump Rooms - Unit 1 6
71111.07T Calculations 1-EB-302-05 RHR Pump Rooms Unit 1 5
71111.07T Calculations 1-EB-303-01 Centrifugal Charging Pump Rooms -Unit 1 7
71111.07T Calculations 1-EB-311-01 ESF Local Cooler Areas Summary Spare Heat Gains and 9
Maximum Temperatures (LOCA with LOOP)
71111.07T Calculations 1-EB-311-08 Safety Chilled Water Pump Evaluation 5
71111.07T Calculations 1-EB-311-12 Evaluation of Safety Chiller Capacities at Reduced CCW 0
Flow Rates - Unit 1
71111.07T Calculations 1-EB-311-3 ESF Local Cooler Areas Summary - Space Heat Gains and 4
Maximum Temperatures (LOCA w/OPA) - Unit 1
71111.07T Calculations 16345-ME(B)-088 Station Service Water System Steady State Hydraulic 8
Calculations
71111.07T Calculations 16345-ME(B)-183 SSI Heat Loads 5
71111.07T Calculations X-SC-04-04 SSW Travelling Screen 02 Differential Pressure X-L-4289A 8
16
71111.07T Corrective Action CR-YYYY-NNNN 2019-007485, 2020-004666, 2020-004864, 2020-006675,
Documents 2020-009296, 2021-002257, 2021-002716, 2021-005490,
2022-002640, 2022-003351, 2022-004955
71111.07T Corrective Action TR-YYYY-NNNN 2021-005163
Documents
71111.07T Corrective Action Issue Report (IR) 2022-005606, 2022-005664
Documents
Resulting from
Inspection
71111.07T Drawings M1-0229 Flow Diagram Component Cooling Water System CP-22
71111.07T Drawings M1-0311 Flow Diagram Ventilation Safety Chilled Water System CP-30
71111.07T Miscellaneous Open Cooling Water Plant Specific Guidelines 4
71111.07T Miscellaneous CCP 1-02 Lube Unit 1 Service Water Visual Inspection Form 03/03/2021
Oil Cooler
71111.07T Miscellaneous CCP 1-02 Lube Unit 1 Service Water Visual Inspection Form 03/26/2019
Oil Cooler
71111.07T Miscellaneous CP-0001-024 Centrifugal Charging Pumps and Motors 73
71111.07T Miscellaneous CP-0081-001 Air Handling Units 3
71111.07T Miscellaneous CPNPP System Safety Chilled Water 2nd Quarter,
Status 2022
71111.07T Miscellaneous DBD-CS-096 Safe Shutdown Impoundment/Dam 14
71111.07T Miscellaneous DBD-ME-229 Comanche Peak Nuclear Power Plant Units 1 and 2, Design 50
Basis Document, Component Cooling Water System
71111.07T Miscellaneous DBD-ME-233 Comanche Peak Nuclear Power Plant Units 1 and 2 Design 39
Basis Document, Station Service Water System
71111.07T Miscellaneous DBD-ME-311 Comanche Peak Nuclear Power Plant Units 1 and 2, Design 21
Basis Document, Safety Chilled Water System
71111.07T Miscellaneous NALCO Water Quarterly Closed Loop Analysis - 2022 Q1 06/15/2022
Letter
71111.07T Procedures ABN-501 Station Service Water Malfunction 10
71111.07T Procedures ABN-907 Acts of Nature 17
71111.07T Procedures COP-501 Chemistry Operating Procedures, Station Service Water 12
71111.07T Procedures COP-502A Unit 1 Chemistry Operating Procedures Manual, Component 7
Cooling Water
71111.07T Procedures COP-814 Unit 1 Chemistry Operating Procedure Manual, Ventilation 5
17
Chilled Water
71111.07T Procedures COP-815A Unit 1 Chemistry Operating Procedures Manual, Safety 5
Chilled Water
71111.07T Procedures MSE-G0-4003 Motor Insulation Resistance Testing 5
71111.07T Procedures OPT-201A Charging System 15
71111.07T Procedures OPT-207A Service Water System 20
71111.07T Procedures OPT-209A Surveillance Test, Safety Chilled Water System 16
71111.07T Procedures OPT-209B Surveillance Test, Safety Chilled Water System 12
71111.07T Procedures PPT-SX-7517 Safe Shutdown Impoundment Inspection 2
71111.07T Procedures STA-734 Service Water System Fouling Monitoring Program 5
71111.07T Procedures TDM-901A Systems Data, Throttled Valves/Flow Rates 14
71111.07T Procedures TSP-509 Predictive Maintenance Thermographic Analysis Program 6
71111.07T Work Orders Work Orders 3667839, 3868301, 3953450, 3975749, 4260995, 4434930,
(WO) 4765986, 4813602, 4941796, 5135252, 5282413, 5326811,
5370719, 5436260, 5532319, 5535113, 5671623, 5685144,
5695618, 5779054, 5794744, 5813178, 5814385, 5823278,
5924058, 5926668, 5927760, 5928617, 5951210, 5955001,
5958222, 5968810, 5972626, 5974285, 5980342, 6006826,
6020235, 6024697, 21-776632, 21-940915, 21-941868, 22-
103231, 22-14288, 22-183905, 22-70886, 22-79326
71111.12 Corrective Action CR-YYYY-NNNN 2019-7903, 2022-1492
Documents
71111.12 Miscellaneous System Health Report AC Distribution 6.9KV Switchgear 4th quarter
2021
71111.12 Miscellaneous Maintenance Rule Program Reports
Database for Unit
71111.12 Miscellaneous System Health
Report for Unit 2
71111.13 Corrective Action TR-YYYY-NNNN 2022-004908
Documents
71111.13 Miscellaneous SORC 22-010 Unit 1 Forced Outage Start up Meeting Package 09/11/2022
71111.17T Calculations ME-CA-0229- CCW Parameters for Fouling Monitoring 1
18
5129
71111.17T Corrective Action CR-YYYY-NNNN 2019-001271, 2019-001317, 2019-001428, 2019-001430,
Documents 2019-001711, 2019-004542, 2019-003684, 2019-006767,
2022-005805
71111.17T Corrective Action TR-YYYY-NNNN 2019-001133, 2019-009096, 2020-005137, 2020-007888,
Documents 2021-002308, 2021-003710, 2022-000031, 2022-004593
71111.17T Corrective Action Issue Report (IR-) 2022-006839, 2022-006874, 2022-006886, 2022-006890,
Documents 2022-006915, 2022-006916
Resulting from
Inspection
71111.17T Drawings 554 Starting Air Receivers Delaval Part No. 76001-125 7
71111.17T Drawings M1-0215 Flow Diagram Starting Air Piping CP1-MEDGEE-01 CP-27
71111.17T Engineering FDA-2017- Replace the Unit 1 and Unit 2 Emergency Diesel Generator 12
Changes 000092-01 Starting Air Compressors
71111.17T Miscellaneous DBD-ME-006 Control of Heavy Loads at Nuclear Plants 40
71111.17T Miscellaneous DBD-ME-011 Diesel Generator Sets 41
71111.17T Miscellaneous DBD-ME-303-01 Fuel Building Ventilation System 11
71111.17T Procedures CPNPP 50.59 Resource Manual 6
71111.17T Procedures ABN-712 Rod Control System Malfunction 14
71111.17T Procedures INC-3027 Control Rod Drop Timing 0
71111.17T Procedures IPO-010B Reactor Coolant System Reduced Inventory Operations 18
71111.17T Procedures MDA-304 Control of Heavy Loads and Critical Lifts 7
71111.17T Procedures MSG-2013 Polar Crane/Telescoping Jib Crane Operating Instructions 4
and Restrictions
71111.17T Procedures NUC-114 Core Performance Engineering Periodic Duties 20
71111.17T Procedures NUC-206 Control Rod Drop Timing 22
71111.17T Procedures SOP-608A 120, 208, 208/120, and 120/240 VAC Distribution System 14
71111.17T Procedures SOP-608B 120, 208, 208/210, and 120/240 VAC Distribution System 5
71111.17T Procedures STA-707 10CFR50.59 and 10CFR72.48 Reviews 23
71111.17T Procedures STI-707.01 10CFR50.59 Screens 0
71111.17T Procedures STI-707.04 10CFR50.59 and 10CFR72.48 Reviews Applicability 1
Determinations
71111.18 Corrective Action TR-YYYY-NNNN 2018-3643, 2022-1952, 2022-1407
Documents
20
71111.18 Procedures SAG-1.0 Control Room Severe Accident Initial Response 0
71111.18 Procedures SAG-9.0 Technical Severe Accident Response Mitigate Fission 0
Product Release
71111.18 Procedures STI-203.02 Preparation of Sever Accident Management Guidance 0
71111.18 Procedures STI-203.02 Preparation of Severe Accident Management Guidance 0
71111.19 Corrective Action TR-YYYY-NNNN 2022-4908
Documents
71111.22 Procedures IPO-002A Plant Startup from Hot Standby 23
71114.01 Corrective Action CR-YYYY-NNNN CR-2017-009505, CR-2019-008751, CR-2019-008766,
Documents TR-YYYY-NNNN CR-2019-008787, CR-2019-008798, CR-2019-008800,
CR-2020-001364, CR-2020-001368, CR-2020-002313,
CR-2020-004960, CR-2020-006058, CR-2020-006768,
CR-2020-007289, CR-2021-008503, CR-2021-008514,
CR-2022-000174, CR-2022-001649, CR-2022-004837,
CR-2022-005181, CR-2022-005234, CR-2022-006005,
CR-2022-006006, CR-2022-006007, CR-2022-006008,
CR-2022-006052, CR-2022-006061, CR-2022-006063,
CR-2022-006064, TR-2017-009355, TR-2017-009418,
TR-2017-009419, TR-2017-009430, TR-2017-009436,
TR-2017-009487, TR-2017-009491, TR-2017-009492,
TR-2017-009506, TR-2017-009508, TR-2017-009509,
TR-2017-009511, TR-2019-008671, TR-2019-008770,
TR-2019-008799, TR-2021-008177, TR-2022-005307,
TR-2022-0060062
71114.01 Corrective Action Issue Reports IR-2022-006242
Documents
Resulting from
Inspection
71114.01 Miscellaneous Management Challenge Presentation: 07/27/2022 Green 08/15/2022
Team Exercise Summary
71114.01 Miscellaneous Control Room Simulator Exercise Participant Logs 07/27/2022
71114.01 Miscellaneous Exercise Report, Red Team November 06, 2019 07/12/2022
71114.01 Miscellaneous Exercise Report, Gold Team, August 16,2017 10/15/2017
71114.01 Miscellaneous Green Team, Exercise Report, June 24, 2020 07/12/2022
71114.01 Miscellaneous Technical Support Center Exercise Participant Logs 07/27/2022
21
71114.01 Miscellaneous Technical Support Center Focused Drill Participant Logs 07/26/2022
71114.01 Miscellaneous Operations Support Center Exercise Participant Logs 07/27/2022
71114.01 Miscellaneous Operations Support Center Focused Drill Participant Logs 07/26/2022
71114.01 Miscellaneous Emergency Operations Facility Exercise Participant Logs 07/27/2022
71114.01 Miscellaneous Joint Information Center Exercise Participant Logs 07/27/2022
71114.01 Miscellaneous CPNPP Emergency Plan 45
71114.01 Miscellaneous Management Challenge Presentation: 7/26/2022 Green 08/15/2022
Team Exercise Summary (Focused Area Drill TSC and OSC
Only)
71114.01 Procedures ABN-907 Acts of Nature 17
71114.01 Procedures ABN-909 Spent Fuel Pool/Refueling Cavity Malfunction 9
71114.01 Procedures BSI-3.0 Spent Fuel Cooling Safety Function Restoration 0
71114.01 Procedures EPP-116 Emergency Repair & Damage Control and Immediate Entries 9
71114.01 Procedures EPP-201 Assessment of Emergency Action Levels Emergency 13
Classification and Plan Activation
71114.01 Procedures EPP-201 Emergency Action Level Technical Bases Document 1
Technical Bases
71114.01 Procedures EPP-203 Notifications 16
71114.01 Procedures EPP-205 Activation and Operation of the Operations Support 12
Center (OSC)
71114.01 Procedures EPP-206 Activation and Operation of the Emergency Operations 18
Facility (EOF)
71114.01 Procedures EPP-303 Operation of Computer Based, Emergency Dose 13
Assessment System
71114.01 Procedures EPP-304 Protective Action Recommendations 22
71114.01 Procedures EPP-309 Onsite/In-Plant Radiological Surveys and Offsite Radiological 15
Monitoring
71114.01 Procedures FRH-0.1A Response to Loss of Secondary Heat Sink 9
71114.01 Procedures SAG-1.0 Control Room Severe Accident Initial Response 0
71114.01 Procedures SAG-10.0 TSC Severe Accident response Control SFP Level 0
71114.01 Procedures SOP-506 Spent Fuel Pool Cooling and Cleanup System 22
71114.04 Miscellaneous CPNPP 10 CFR 50.54(q)(3) Screening Evaluation Form for 03/11/2021
ANS Design Report Change
22
71114.04 Miscellaneous CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness 06/23/2021
Evaluation Forms for OSSA Change
71114.04 Procedures CPNPP 10 CFR 50.54(q)(3) Screening and Effectiveness 05/24/2021
Evaluation Form for Emergency Plan Revision 45
71114.04 Procedures CPNPP Emergency Plan 45
71114.04 Procedures CPNPP Emergency Plan 44
71114.04 Procedures EPP-123 10 CFR 50.54(q) Screening and Evaluation of Changes to 3
Emergency Plan Documentation
71151 Miscellaneous NucIQ data on reactor coolant system for Units 1 and 2 for
June, 2022
71151 Miscellaneous Control room log leak rate readings July 1, 2021, through
June 30, 2022.
71151 Miscellaneous MSPI Margin Reports
PRA Living Model Report
71151 Miscellaneous ANS Test Report Data 2021Q2-2022Q2
71151 Miscellaneous Quarterly Key ERO Member Drill Participation
Trackers 2021Q2-2022Q2
71151 Miscellaneous DEP PI Data 2021Q2-2022Q2
71151 Procedures SG-012 Alert and Notification System Surveillance 31
71151 Procedures SG-020 NRC Performance Indicators 23
71151 Procedures STA-662 Administrative Control of the Siren System 1
71152A Procedures STI-433.02 Emergency Response Facility Functionality Evaluation 2
24