ML25217A046
| ML25217A046 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/06/2025 |
| From: | Ami Agrawal NRC/RGN-IV/DORS/PBB |
| To: | Peters K Vistra Operations Company |
| Agrawal A | |
| References | |
| IR 2025002 | |
| Download: ML25217A046 (1) | |
Text
August 06, 2025 Ken Peters, Executive Vice President and Chief Nuclear Officer Vistra Operations Company, LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000445/2025002 AND 05000446/2025002
Dear Ken Peters:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant. On July 14, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami N. Agrawal, Chief Reactor Projects Branch B Division of Operating Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Agrawal, Ami on 08/06/25
ML25217A046 SUNSI Review By: ANA Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword NRC-002 OFFICE SRI:DORS/PBB BC:DORS/PBB NAME JEllegood AAgrawal SIGNATURE
/RA/
/RA/
DATE 08/05/25 08/06/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000445 and 05000446 License Numbers:
NPF-87 and NPF-89 Report Numbers:
05000445/2025002 and 05000446/2025002 Enterprise Identifier:
I-2025-002-0008 Licensee:
Vistra Operations Company, LLC Facility:
Comanche Peak Nuclear Power Plant Location:
Glen Rose, TX 76043 Inspection Dates:
April 1, 2025, to June 30, 2025 Inspectors:
C. Alldredge, Health Physicist J. Ellegood, Senior Resident Inspector C. Harrington, Operations Engineer J. Mejia, Reactor Inspector A. Sanchez, Senior Project Engineer E. Simpson, Nuclear Systems Scientist H. Strittmatter, Resident Inspector Approved By:
Ami N. Agrawal, Chief Reactor Projects Branch B Division of Operating Reactor Safety
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, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations No findings or violations of more than minor significance were identified.
Additional Tracking Items None.
3 PLANT STATUS Unit 1 began the inspection period at 100 percent power. On April 20, the licensee shutdown Unit 1 for a refueling outage. On May 14, 2025, the licensee started the reactor. Unit 1 reached 100 percent power on May 17, 2025. Unit 1 remained at or near 100 percent for the remainder of the inspection period.
Unit 2 remained at or near 100 percent power for the entire inspection period.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY 71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
Hot weather preps (1)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm weather for the following systems:
independent spent fuel storage installation electric switchyard site transformers Systems were walked down during the weeks of June 16 and 23, 2025.
71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
Unit 1, train A auxiliary feedwater on April 14, 2025.
(2)
Unit 1, train B Emergency Diesel Generator on June 23, 2025
4 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
(1)
Unit 1, cable spreading room on June 17, 2025 (2)
Unit 2, cable spreading on June 17, 2025 (3)
Unit 1, control room heating ventilation and air conditioning on June 17, 2025 (4)
Unit 2, control room heating, ventilation and air conditioning on June 17, 2025 71111.06 - Flood Protection Measures Flooding Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated internal flooding mitigation protections in the:
Units 1 and 2 trains A and B safety-related battery rooms, on June 18, 2025 71111.07A - Heat Exchanger/Sink Performance Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
CCW HX 1-02 during unit refueling outage on April 29, 2025 71111.08P - Inservice Inspection Activities (PWR)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary were appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 1 during refueling outage 1RF24 from April 28 to May 6, 2025.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) (1 Sample)
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
(1)
Ultrasonic Examination safety injection, TBX-2-2531-14, pipe to elbow safety injection, TBX-2-2531-15, elbow to pipe reactor coolant system, TBX-1-4201-1, branch connection to elbow reactor coolant system, TBX-1-4201-3, pipe to elbow reactor coolant system, TBX-1-4201-4, elbow to pipe reactor coolant system, TBX-1-4504-1, elbow to pipe
5 Dye Penetrant Examination chemical and volume control, CS-1-005, weld 37B, 38, 41A, 42, 43, 44A, 45A, 46, 47A, 78, 79A Magnetic Particle Examination main steam, TBX-2-2400-H3, attachment welds Visual Examination metal containment, AC-31, containment liner metal containment, AC-34, containment liner metal containment, AC-38, containment liner metal containment, MI-0003, penetration metal containment, MI-0004, penetration metal containment, MI-0005, penetration metal containment, MI-0008, penetration metal containment, MV-0011, penetration Welding Activities gas tungsten arc welding, o
chemical and volume control system, CS-1-007, pipe to elbow socket weld repair o
component cooling water, CP1-FWAPFP-01, pipe to valve socket weld repair PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the licensee conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
(1)
The inspectors reviewed video of reactor vessel head penetrations 2-8, 14-17, 31-37, 39, 41, 44-45, 48-52, 56-58 and observed visual exams of penetrations 66-67.
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
EV-CR-2024-005861-12 EV-CR-2024-007650-2 EV-CR-2025-000067-2 EV-CR-2025-001170-2 EV-CR-2025-001657-2 EV-CR-2025-001914-4 EV-CR-2025-001914-9 EV-CR-2025-001914-11 EV-CR-2025-001914-12
6 EV-CR-2025-001914-13 EV-CR-2025-001914-14 EV-CR-2025-001914-15 EV-CR-2025-001914-17 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
(1)
The inspectors observed and evaluated licensed operator performance in the control room during vacuum filling activities on May 10, 2025.
(2)
The inspectors observed and evaluated licensed operator performance in the control room during reactor start up on May 14, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated just in time training for startup and shutdown in preparation for Unit 1 planned refueling outage on April 17 and 18, 2025.
71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1) component cooling water-this system is RED in system health based on tube plugging (2)
Units 1 and 2, diesel generator starting air compressors 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1) 1RF24 outage risk profile (2)
Unit 2, yellow risk due to emergency diesel generator 2-01 output breaker maintenance on April 9, 2025 (3) outage risk mitigation on April 29, 2025 (4) vacuum fill of the RCS on May 10, 2025
7 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)
Unit 1, component cooling water surge tank level lowering, IR-2025-1690 (2) reactor headstand and reactor head following inadvertent contact between the headstand and reactor head.
71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated 1RF24 activities from April 20 to May 14, 2025.
71111.24 - Testing and Maintenance of Equipment Important to Risk The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
(1) emergency diesel generator 2-01 fast start after output breaker maintenance on April 9, 2025.
(2) power range nuclear instrument high power trip setpoint adjustment on April 20, 2025 (3) reactor cavity quality assurance inspection before reactor head lift and flood up on April 25, 2025.
(4) reactor vessel foreign object search and retrieval conducted on May 1, 2025 (5) containment readiness for plant restart on May 12, 2025.
(6) train B control room makeup supply fan discharge damper x-20 following actuator rebuild (WO 24-460634) on June 18, 2025 (7) diesel generator 1-01 breaker on June 24, 2025 Surveillance Testing (IP Section 03.01) (5 Samples)
(1)
Unit 2, solid state protection system white noise analysis conducted on March 25, 2025 (2)
Unit 1, containment equipment hatch closure drill on April 22, 2025 (3)
Unit 1, emergency core cooling system flow test on May 6, 2025 (4) subcritical physics testing on May 14, 2025 (5) rod drop timing test on May 14, 2025 Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)
Unit 2, motor driven auxiliary feedwater pump 2-02 on June 12, 2025
8 Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1) reactor coolant system loop 1 hot leg sample line isolation valve local leak rate testing on May 2, 2025, work order 24-580864 RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels, identifies the concentrations and quantities of radioactive materials, and assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1) observed the licensee conduct surveys of potentially contaminated packages/equipment from the radiologically controlled area for release offsite and workers existing potential contaminated areas.
(2) evaluated the licensee's physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1) locked high radiation area work and job coverage for reactor head visual inspection activities under radiation work permit (RWP) 20251603, Task 1 for work order 23-490491 (2) radiation area work and job coverage for main-steam line insulation removal, inspection, and reinstallation activities under RWP 20251217, Task 1 for work order 23-462035 (3) radiation area work and job coverage for fuel movements under RWP 20251600, Task 3 for Procedure RFO-302, Handling Fuel Assemblies.
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
9 (1) unit-1 reactor building, 790-foot elevation, 153 reactor sump annulus room (2) unit-1 reactor building, 832-foot elevation, 155C regenerative heat exchanger 1-01 room (3) auxiliary building, 810-foot elevation, X-191 waste processing spent resin sluice pump X-01 room Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
(1)
The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements 71124.04 - Occupational Dose Assessment Source Term Characterization (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated licensee performance as it pertains to radioactive source term characterization External Dosimetry (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated how the licensee processes, stores, and uses external dosimetry Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
(1)
PCE 24-0005, Dose Assessment, November 11, 2024 (2)
PCE 24-0007, Dose Assessment, November 12, 2024 Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)
Monitoring of two declared pregnant workers and their associated NRC Form 5s (2)
Use of multipack dosimetry and dose assignment for five individuals OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)
(1)
Unit 1 (April 1, 2024, through March 31, 2025)
(2)
Unit 2 (April 1, 2024, through March 31, 2025)
10 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
July 1, 2024, through March 31, 2025 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
(1)
July 1, 2024, through March 31, 2025 71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
(1) loss of primary ANS on May 3 as described in IR-2025-2331 INSPECTION RESULTS No findings were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On May 1, 2025, the inspectors presented the occupational radiation safety inspection results to Christopher Jackson, Site Vice President and other members of the licensee staff.
On May 6, 2025, the inspectors presented the exit meeting inspection results to Hunter Schill, Plant Manager and other members of the licensee staff.
On July 14, 2025, the inspectors presented the integrated inspection results to Ken Peters, Executive Vice President and Chief Nuclear Company, and other members of the licensee staff.
11 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71111.01 Miscellaneous 2025 Comanche Peak Summer Readiness Presentation 71111.04 Procedures SOP-304A Auxiliary Feedwater System Revision 18 71111.06 Calculations SI-CA-0000-0664 Electrical and Control Building Analysis 5
Corrective Action Documents CR-YYYY-NNNN 2024-007228, 2024-007323, 2024-007650. 2024-007773, 2025-000066, 2025-000067, 2025-000517, 2025-000552, 2025-000562, 2025-000818, 2025-000870, 2025-001002, 2025-001014, 2025-001091, 2025-001101, 2025-001170, 2025-001243, 2025-001294, 2025-001558, 2025-001623, 2025-001657, 2025-001659, 2025-001659 Corrective Action Documents Resulting from Inspection IR-YYYY-NNNN 2025-002318, 2025-002431 Remote Visual Inspection Cover Sheet Vistra - CPNPP -
1RF24 Reactor Head Bare Metal Visual April 27-28 2025 04/28/2025 Miscellaneous Unit 1 - Fourth Interval ASME Section XI Inservice Inspection Program Plan 2
EPG-9.08 Reactor Vessel Closure Head Visual Examination 6
STI-737.01 Boric Acid Corrosion Detection and Evaluation 1
TX-ISI-11 Liquid Penetrant Examination for CPSES 18 TX-ISI-214 Ultrasonic Examination for Welds in Piping Systems and Vessels 8
TX-ISI-302 Ultrasonic Examination Procedure for Austenitic Piping Welds 6
TX-ISI-70 Magnetic Particle Examination for CPSES 15 TX-ISI-8 VT-1 and VT-3 Visual Examination Procedure 12 Procedures TX-ISI-IWE Metal Containment Visual Examination 7
71111.08P Work Orders WO-23-113845, 23-490491, 24-488163, 24-517482, 25-140368, 25-106518 IPO-002A Plant Startup from hot standby 25 IPO-010A Reactor Coolant System reduced Inventory Operation 23 71111.11Q Procedures SOP-101A Reactor Coolant System 20 71111.12 Corrective Action CR-YYYY-NNNN 2025-002224, 2025-2204
12 Inspection Procedure Type Designation Description or Title Revision or Date Documents Miscellaneous ENGAGE health report for component cooling water 05/30/2025 Guarded Equipment Posting Log for EDG 2-01 Breaker Maintenance 04/09/2025 DIDCP 1RF24-01A Defense in Depth Contingency Plan for Loss of Shutdown Cooling 0
DIDCP 1RF24-01A Defense in Depth Contingency Plan for Spent Fuel Pool Cooling 0
71111.13 Miscellaneous DIDCP 1RF24-09 Defense in Depth Contingency Plan for Mansell Level Indication 0
71111.15 Corrective Action Documents CR-YYYY-NNNN 2025-2293, 2025-1666, 2025-1690 Corrective Action Documents TR-YYYY-NNNN 2025-2661 NUC-111 attachment 2 Inverse Count Rate Ratio Monitoring for Unit 1 Cycle 25 05/14/2025 Miscellaneous OPT-308 attachment 3 BEACON calculated Estimated Critical Conditions for Unit 1 cycle 25 05/14/2025 71111.20 Procedures IPO-002A Plant Startup from Hot Standby 25 Corrective Action Documents CR-YYYY-NNNN 2025-2365, 2025-3279 1RF24_WC61 Detailed Fuel Inspection 04/30/2025 Miscellaneous AXIS P7214 FOSAR inspection of Comanche Peak reactor Vessel 05/01/2025 MSE-SO-6301 6.9KV Air Circuit Breaker Inspection and Cleaning 8
NUC-206 Control Rod Drop Timing 25 NUC-303 Subcritical Physics Testing 1
OPT-206B AFW System 28 OPT-214A Diesel Generator Operability Test 25 Procedures OPT-521A ECCS Operability 12 71111.24 Work Orders 23-458088, 23-450341, 23-248060, 24-599999 Condition Reports (CR-YYYY-NNNN) 2025-001302 71124.01 Corrective Action Documents Tracking Reports 2023-003771, 2024-006398, 2024-006823
13 Inspection Procedure Type Designation Description or Title Revision or Date (TR-YYYY-NNNN)
ODA-102 Conduct of Operations 40 RPI-110 Radiation Protection Shift Activities 40 RPI-304 Radiological Posting and Labeling 6
Procedures RPI-305 Access Controls for High Radiation Areas 6
20242101 2RF21 Operations Activities 2
20242201 2RF21 Pressurizer (rm 2-161B/C/D/E) & Spray Valve Rm (2-160B) 1 20242405 2RF21 RCP 2-03 Motor Swap 1
20242600 2RF21 Westinghouse Refueling Activities 4
20250211 U1 Leak Repair and U1 & U2 Vibration Data in Letdown Orifice 0
20251108 1RF24 Engineering/Management/NRC Walk-Downs (Includes HRA) 0 20251217 1RF24 Insulator Activities 0
20251404 1RF28 ISI, FAC and Associated Engineering Activities 0
20251600 1RF24 Westinghouse Refueling Activities 0
Radiation Work Permits (RWPs) 20251603 1RF24 Alloy 600 Reactor Head Inspections & Insulation Activities 0
Self-Assessments EVAL-2024-002 Audit
Title:
Chemistry/Environmental/Effluent Radioactive Waste RPI-528-1; Multibadge ID:
1706 Multibadge Worksheet 04/24/2023 RPI-528-1; Multipack ID:
1693 Multibadge Worksheet 04/24/2023 RPI-528-1; Multipack ID:
1697 Multibadge Worksheet, Multipack ID: 1706 04/24/2023 71124.04 Calculations RPI-528-1; Multipack ID:
1712 Multibadge Worksheet 04/24/2023
14 Inspection Procedure Type Designation Description or Title Revision or Date RPI-528-1; Multipack ID:
1718 Multibadge Worksheet 04/24/2023 Corrective Action Documents TR-YYYY-NNNN 2023-003771 Corrective Action Documents Resulting from Inspection IR-YYYY-NNNN 2025-002289 Miscellaneous RPI-515-2 Neutron Exposure Tracking Sheet 04/08/2024 RPI-303 Radiological Air Sampling 3
RPI-402 Personnel Contamination Event Documentation 38 RPI-500 Bioassay Program 16 RPI-501 In Vitro Sampling 10 RPI-503 Operation of the Stand-Up Whole Body Counter 26 RPI-507 Internal Dose Calculation 8
RPI-509 Personnel Dosimetry Program 16 RPI-515 Neutron Dose Measurement and Recording 20 RPI-516 Dose Determination 38 RPI-527 Quality Control of the Dosimetry Processing Program 14 RPI-528 Multiple Dosimetry Badging 16 RPI-530 Dosimeter Badge Issue and Assignment 17 RPI-534 Calibration of Electronic Personal Dosimeters and Pocket Ion Chambers (PICS) 15 RPI-613 Discrete Radioactive Particle Contamination Control 10 Procedures STA-655 Exposure Monitoring Program 24 Comanche Peak Steam Electric Station Offsite Dose Calculation Manual Unit 1 and Unit 2 2024 Annual Radiological Effluents Release Report 71151 Miscellaneous First Quarter Dose Reports for Gas and Liquid Releases