IR 05000445/2021011

Design Basis Assurance Inspection (Teams) Inspection Report 05000445/2021011 and 05000446/2021011 and Notice of Violation

ML21124A130
Person / Time
Site:	Comanche Peak
Issue date:	05/06/2021
From:	Vincent Gaddy NRC Region 4
To:	Peters K Vistra Operations Company
References
IR 2021011
Download: ML21124A130 (37)

Text

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SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000445/2021011 AND 05000446/2021011 AND NOTICE OF VIOLATION

Dear Mr. Peters:

On March 25, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2 and discussed the results of this inspection with Mr. Thomas McCool, Site Vice President and other members of your staff. The results of this inspection are documented in the Enclosure 2.

The enclosed report discusses two violations associated with findings of very low safety significance (Green). The NRC evaluated these violations in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found on the NRC website at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that these violations did not meet the criteria to be treated as non-cited violations (NCVs) because the licensee failed to restore full compliance for the documented NCVs 05000416/2013007-02 and 05000445/2015007-01.

You are required to respond to this letter and should follow the instructions specified in the Notice of Violation (Enclosure 1) when preparing your response. You are required to submit a written explanation or statement under Title 10 of the Code of Federal Regulations (10 CFR) 2.201 within 30 days of the date of the issuance of this Notice of Violation. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.

Additionally, four findings of very low safety significance (Green) are documented in this report.

All of these findings involved violations of NRC requirements. We are treating these violations as (NCVs) 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 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 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Vincent G. Digitally signed by Vincent G.

Gaddy Gaddy Date: 2021.05.06 14:35:15-05'00' Vincent G. Gaddy, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosures:

1. Notice of Violation 2. Inspection Report

Inspection Report

Docket Numbers: 05000445 and 05000446 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2021011 and 05000446/2021011 Enterprise Identifier: I-2021-011-0002 Licensee: Vistra Operations Company LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, Texas Inspection Dates: February 08, 2021 to March 25, 2021 Inspectors: J. Braisted, Reactor Inspector S. Hedger, Emergency Preparedness Inspector R. Kopriva, Senior Reactor Inspector S. Makor, Reactor Inspector C. Smith, Senior Reactor Inspector F. Thomas, Reactor Inspector Approved By: Vincent G. Gaddy, Chief Engineering Branch 1 Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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 Update a Calculation for Station Service Water Cross-Connect Operability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000445,05000446/2021011-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to update a calculation for station service water cross-connect operability for modifications and a power uprate that impacted design input values.

Failure to Provide Adequate Technical Justification for the Reduction in Minimum Bend Radius for the Unit 1 Station Service Water Pump Motor Leads Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.7] - 71111.21M Systems NCV 05000445/2021011-02 Documentation Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to provide adequate technical justification that supports the reduction in the minimum bend radius requirement for motor leads on the safety related Unit 1 Station Service Water Pump replacement motor.

Failure to Perform Adequate Periodic Testing of Class 1E Molded Case Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000445/2021011-03 Open/Closed The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XI, Test Control, for the failure to schedule all Class 1E molded case circuit breaker functional testing to detect deterioration and to demonstrate continued operability.

Failure to Maintain Proficiency of Operators to Meet Time Critical Operation Actions

Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.9] - Training 71111.21M NCV 05000445,05000446/2021011-04 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure that operators are able to implement specified actions in response to operational events and accidents. Specifically, three groups of operators could not achieve a time-critical action within the analysis time requirements for the inadvertent operation of the emergency core cooling system response as described in the licensees safety analysis report.

Failure to Restore Compliance and Evaluate Inverter Fault Interrupting Capability During Design Basis Loss of Offsite Power and Seismic Conditions Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NOV 05000445/2021011-05 Open The inspectors identified a Green finding and associated notice of violation (NOV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to restore compliance of previously identified non-cited violation NCV 05000445/2015007-01. The violation identified the licensee's failure to verify or check the adequacy of the design by performing an analysis or test that demonstrated that the Class 1E inverters would continue to operate reliably when subjected to the effects of electrical faults that could be postulated to occur at non-Class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss-of-offsite power, and seismic events.

Failure to Restore Compliance for Inadequate Voltage Calculations for the 120 VAC Buses Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NOV 05000446/2021011-06 Open The inspectors identified a Green finding and associated notice of violation (NOV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to restore compliance of previously identified non-cited violation NCV 05000446/2013007-02. The violation identified the licensee's failure to perform accurate voltage calculations for the 125 VDC system and 120 VAC bus.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

===71111.21M - Design Bases Assurance Inspection (Teams) The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience: Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (6 Samples) From February 8, 2021 to March 25, 2021, the team inspected the following components and listed applicable attributes.

(1) Safety Chill Water Storage Tank - Unit 2 (SCW-TNK-ATST02)

• Material condition and installed configuration (e.g., visual inspection/walkdown).
• Normal, abnormal, and emergency operating procedures.
• Consistency among design and licensing bases and other documents/procedures.
• System health report, maintenance effectiveness and records, and corrective action history.
• Design calculations for sizing capacity and seismic adequacy.

(2) Motor Driven AFW Pump Unit 2-02 and motor.

• Material condition and installed configuration (e.g., visual inspection/walkdown).
• Normal, abnormal, and emergency operating procedures.
• Consistency among design and licensing bases and other documents/procedures.
• System health report, maintenance effectiveness and records, and corrective action history.
• Design calculations for net positive suction head, service water system hydraulics, setpoints, and cross-connect operability.
• Surveillance testing and recent test results.
• Vendor manuals for the pump and motor.
• System and component level performance monitoring.

(3) Service Water Pump Unit 1-02 (CP1-SWAPSW-02)

• Material condition and installed configuration (e.g., visual inspection/walkdown)
• Normal, abnormal, and emergency operating procedures
• Consistency among design and licensing bases and other documents/procedures
• System health report, maintenance effectiveness and records, and corrective action history
• Design calculations for net positive suction head, service water system hydraulics, setpoints, and cross-connect operability
• Surveillance testing and recent test results
• Vendor manuals for the pump and motor
• System and component level performance monitoring

(4) Diesel output breaker 1EG1

• Vendor manuals for EDG output breaker and ancillary components
• Diesel generator output breaker control logic to verify the appropriate functionality was implemented.
• Completed surveillances to verify that the technical specification requirements were met.
• Protection/coordination and short-circuit calculations to verify the EDG was adequately protected by protective devices.
• EDG output breaker maintenance and control voltage to verify that the components would function when required.
• The team performed a walk down of the emergency diesel generator and breaker to assess the installed configuration, material condition, and potential vulnerability to hazards.

(5) Safeguards Loop Component Cooling Water Supply Header Pressure Indicating Switch (2-PS-4519)

• System health report, maintenance effectiveness and records, and corrective action history
• Vendor manuals for pressure switch
• Calibration history and setpoint calculations
• Plant qualification evaluation report and drawings
• Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance.

(6) Operator Actions 1. Control room operator actions resulting from a simulated break in the letdown system piping. From the receipt of associated alarms, actions to isolate the leak are completed within 10 minutes as described in the Final Safety Analysis Report (FSAR) (Amendment No. 110).

2. Control room operator actions resulting from an inadvertent actuation of the emergency core cooling (ECCS) systems as described in the FSAR (Amendment No. 110).

a. Control room operators restore decay heat removal via three of four steam generator atmospheric relief valves (ARVs) within 8 minutes of the inadvertent actuation.

b. Control room operators terminate ECCS injection within 14 minutes of the inadvertent actuation.

3. Control room and auxiliary operator actions to refill the refueling water storage tank (RWST) following a small break loss of coolant accident (SBLOCA),complicated by the inability to establish a containment sump recirculation lineup, within 49 minutes.

4. Control room and auxiliary operator actions to establish manual control of auxiliary feedwater flow to all four steam generators after a loss of all AC power event within 28.5 minutes.

Design Review - Large Early Release Frequency (LERF) (IP Section 02.02) ===

From February 8 to March 25, 2021, the team inspected the following components and listed applicable attributes.

(1) Service Water Pump Discharge Valve Unit 1-HV-4286 (LERF)

• Procedures for motor operated valve setpoint control
• Procedures for limitorque actuator periodic electrical and mechanical inspection
• results of recent system health reports for 2020
• Calculation for Westinghouse 7300 process control system scaling calculation
• Calculation for normal operating inlet pressures for Unit 2 station service water system motor operated valves
• Calculations for component cooling water heat exchanger 1-02 station service water outlet header temperature.
• Design bases document and piping and instrumentation diagrams for service water system
• Vendor manuals for limitorque operation, maintenance, and bulletins
• Corrective action documents discussing critical and non-critical classification of certain service water valves

(2) Motor Control Center 1EB3-3 [EPMCEB-07] (LERF)

• System health reports, component maintenance history, and corrective action program reports to verify the monitoring and correction of potential degradation.
• Calculations for electrical distribution, system load flow/voltage drop, short circuit, and electrical protection to verify that electrical equipment capacity and voltages remained within minimum acceptable limits.
• The protective device settings and circuit breaker ratings to ensure adequate selective protection coordination of connected equipment during worst-case short circuit conditions.
• Procedures for preventive maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance.
• Results of completed preventative maintenance on motor control centers and breakers.

(3) 118Vac Safeguards BOP Inverter IV1EC1 (LERF)

• Load study for adequacy of inverter and system cable sizing.
• Manufacturer recommended preventative maintenance performed during periodic maintenance activities.
• Inverter fault current clearing capability for postulated faults on non-Class 1E circuits during design basis conditions.
• Periodic testing to confirm inverter system design features and rated output capability.
• Procedures for preventative maintenance, inspection, and testing to compare maintenance practices against industry and vendor guidance
• The team also performed walkdowns and conducted interviews with system engineering personnel to ensure the capability of this component to perform its desired design basis function.

Modification Review - Permanent Mods (IP Section 02.03) (4 Samples)

From February 8 to March 25, 2021, the team inspected the following components and listed applicable attributes.

(1) FDA-2016-000022-01-00, Clarify optional shim construction for Station Service Water seismic supports. This FDA is being completed in response to AI-CR-2016-

===001306-19.

(2) FDA-2017-000167-01-01, DIESEL GENERATOR CP1-MEDGEE-02 # 4L cam cover has a bolt thread that is damaged. Reference IR-2017-011755 That activity proposes repairing the bolt hole with a helicoil.

Revision 1: CR 2018-002139 identifies a conflict with FDA 2017-000167-01-00 and FDA-2012-000002-07-01, A revision to this FDA will remove the option to increase bolt diameter.

(3) FDA-2017-000196-01-00. Revise DBD-ME-233 Attachment 1A for SSWP 1-01 preservice test.

(4) FDA-2020-000100-01-00, Minimum bend radius for CP1-SWAPSW-02M replacement motor. One Time Deviation to Specification 2323-ES-100 to allow minimum bend radius of service water pump motor leads (silicone insulated cable manufactured by Rowe Industries, 2AWG, stranded flexible) to be three times the outside diameter of the cable.

Review of Operating Experience Issues (IP Section 02.06) ===

From February 8 to March 25, 2021, the team inspected the following components and listed applicable attributes.

(1) NRC Information Notice IN- 20-02 FLEX Diesel Generator Operational Challenges.

• The team reviewed licensee response to this information notice under their Operating Experience Program. The team reviewed the Operating Experience process procedure STI-426.02. Per their procedure, the licensee generated an administrative tracking report to review and take actions as deemed necessary. The licensee's actions included participation in industry FLEX summits and benchmarking activities and determined that the site was not susceptible to the concerns in IN-2020-02.

(2) NRC Information Notice IN 17-05 Potential Binding of Schneider Electric/Square-D Masterpact NT and NW 480-VAC Circuit Breaker Anti-Pump Feature.

• The team reviewed licensee response to this information notice under their Operating Experience Program. The team reviewed the Operating Experience process procedure STI-426.02. Per their procedure, the licensee determined that CPNPP does not use Masterpact 480V NT, NW or any similar breakers, and IN-2017-05 was not applicable.

(3) NRC Information Notice IN 20-01 Increased Electronic Equipment Issues After Electrostatic Cleaning.

• The team reviewed the licensee response to this information notice under their Operating Experience Program. The team reviewed Operating Experience process procedure STI-426.02. Per their procedure, the licensee determined that the information notice was not applicable and Comanche Peak Nuclear Power Plant does not use the electrostatic spray cleaning of concern.

(4) NRC Information Notice IN-19-10 Failures Reported in Eaton/Cutler Hammer A200 And Freedom Series Contactor.

• The team reviewed licensee response to this information notice under their Operating Experience Program. The team reviewed the Operating Experience process procedure STI-426.02. Per their procedure, the licensee determined that CPNPP has not purchased safety-related Eaton/Cutler Hammer A200 and Freedom Series contactors.

INSPECTION RESULTS

Failure to Update a Calculation for Station Service Water Cross-Connect Operability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000445,05000446/2021011-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the failure to update a calculation for station service water cross-connect operability for modifications and a power uprate that impacted design input values.

Description:

The station service water system (SSWS) removes heat from the component cooling water system (CCWS) heat exchangers and from the emergency diesel generators, and supplies cooling water to the safety injection, centrifugal charging pump lube oil coolers and the containment spray pump bearing oil coolers. In conjunction with the CCWS, the SSWS supplies cooling water to meet the plant cooling requirements during normal operation, shutdown, and during or after a postulated loss-of-coolant accident of either unit.

The technical specification for the SSWS is 3.7.8. The limiting condition for operation states that two SSWS trains and a station service water pump on the opposite unit with its associated cross-connects shall be operable in modes 1, 2, 3, and 4. Condition A requires specific actions if a station service water pump on the opposite unit or its associated cross-connects are inoperable. The basis for this condition is that, if no station service water pump on the opposite unit or its associated cross-connects are operable, the overall reliability is degraded since a back-up in the event of a loss of station service water (LOSSW) event may not be capable of performing the function. A station service water pump on the opposite unit is operable as back-up in the event of a Loss of Station Service Water (LOSSW) if it is capable of providing required flow rates.

In response to NRC Generic Letter 91-13, Request for Information Related to the Resolution of Generic Issues 130, Essential Service Water System Failures at Multi-Unit Sites, the licensee developed calculation ME-CA-0400-3218, Service Water Cross-Connect Operability, dated November 4, 1993, in support of these changes. Specifically, the licensee developed ME-CA-0400-3218 to ensure the adequacy of one service water pump providing adequate flow to remove heat loads on both units for certain postulated operating scenarios. The scenarios involved a unit initially in modes 5 or 6 (the shutdown unit) and the other unit initially in modes 1, 2, 3, or 4 (the operating unit). The scenarios also included analyses of isolating service water to various non-safety-related and safety-related heat loads.

The inspectors reviewed ME-CA-0400-3218 and noted that it had not been revised since 1993 despite the 2007 stretch power uprate and other station modifications. Subsequently, the inspectors identified several concerns and questioned whether: 1) the assumed safety-related and non-safety-related heat loads remained bounding given the power uprate and modifications; 2) the single running service water pump could provide adequate flow without experiencing a runout condition given certain system alignments; 3) an assumption of a time delay to reduce the heat loads given the stations operating procedures and technical specifications; and 4) the operating unit remaining in mode 4 given the stations current technical specifications. The licensee reviewed the calculation and confirmed the inspectors concerns that the heat loads were not bounding, the service water pump would reach a run out condition if valves were not throttled properly, the delay time was inconsistent with station procedures, and technical specifications would require taking the operating unit to mode 5, not mode 4. The licensee also identified that another assumption for the shutdown unit in some of the scenariosa two-train residual heat removal system cooldownwas also incorrect. Given the above, the inspectors concluded there was a reasonable doubt as to whether a single service water pump could provide the flow rates required for adequate heat removal to both units without exceeding pump runout conditions or other system temperature limits.

Licensee procedure ECE-5.01, Design Control Program, established the general requirements for design control at the station and the functional responsibilities required to ensure that safety-related and non-safety-related design activities, subject to 10 CFR Part 50, Appendix B, are conducted in a planned and controlled manner. The procedure applied to all design activities during the maintenance, modification, and operation of the station in the preparation of design drawings, calculations, design basis documents, specifications, and design change documents. This also included updating design documents to reflect the as-build plant conditions accurately, subsequent to completion of plant modifications. Given that the licensee did not update ME-CA-0400-3218 after the stretch power uprate and modifications between approximately 1993 and 2007, the inspectors concluded that the licensees established design control measures failed to verify the adequacy of design of a single station service water pump to perform its LOSSW function.

Corrective Actions: The licensee documented the condition in their corrective action program and performed an operability determination. The operability determination reanalyzed the most limiting scenario from ME-CA-0400-3218 and determined the SSWS remained operable. Therefore, the condition does not represent and immediate safety concern.

Corrective Action References: CR-2021-001358

Performance Assessment:

Performance Deficiency: The failure to update a calculation for station service water cross-connect operability for modifications and a power uprate that impacted design input values was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the calculational errors and out of date inputs resulted in a reasonable doubt of the availability, reliability, and capability of the service water system in that it could not be reasonably determined that a single service water pump could provide the flow rates required for adequate heat removal to both units without exceeding pump runout conditions or other system temperature limits.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, or component; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. The licensee established quality procedure ECE-5.01, Design Control Program, to ensure safety-related and nonsafety-related design activities subject to 10 CFR Part 50, Appendix B, are conducted in a planned and controlled manner.

Contrary to the above, from August 2007 (estimated) to February 22, 2021, the licensees design control measures did not provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, procedure ECE-5.01 did not ensure that calculation ME-CA-0400-3218, which was developed to demonstrate the adequacy of design of a single service water pump to provide adequate cooling to two units during a loss of station service water event, remained valid following the stretch power uprate and other modifications to the station. As such, the licensee did not identify calculational errors in ME-CA-0400-3218, leading to a reasonable doubt as to whether a single service water pump could perform its loss of station service water function.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Provide Adequate Technical Justification for the Reduction in Minimum Bend Radius for the Unit 1 Station Service Water Pump Motor Leads Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.7] - 71111.21M Systems NCV 05000445/2021011-02 Documentation Open/Close The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to provide adequate technical justification that supports the reduction in the minimum bend radius requirement for motor leads on the Unit 1 Station Service Water Pump replacement motor.

Description:

The inspectors reviewed modification document FDA-2020-000100-01-00 and the Electrical Installation Specification 2323 ES-100, Revision 121. The scope of work for the FDA-2020-000100-01-00 modification was the one time deviation to Specification 2323-ES-100 to allow minimum bend radius of service water pump motor leads (silicone insulated cable manufactured by Rowe Industries, 2AWG, stranded flexible) to be three times the outside diameter (3 x OD) of the cable. The Electrical Installation Specification section 1.8.2.1 states that Motor leads for Station Service Water pump motors may be provided by Rowe Industries. These motor leads utilize a silicone rubber insulation and are white in color. These motor leads shall have a minimum bend radius of five times the motor lead outside diameter.

The Engineering Basis section of FDA-2020-000100-01-00 (page 8 of 12), states, in part, that "the 2AWG motor lead wire is a silicon insulated wire provided by Rowe Industries. The conductor with a high number of strands is flexible and the silicon insulation is also flexible. This will ensure that the conductor and insulation stresses, due to reduced bend radius, are minimized." It also states, "the ampacity of 2AWG conductor in air for a conductor temperature of 90 degrees Celsius and ambient air temperature of 40 degrees Celsius is 195 Amperes (IPCEA 46-426 page 215). The motor full load amps are 72 Amperes (Ref: EE-CA-0008-3097). This shows that the conductor is lightly loaded. Low loading of the conductor will minimize any adverse impact on conductor life due a reduced bend radius. Furthermore, the Engineering Basis states, in part, " the cable configuration and circuit loading are such that a reduced cable bend radius has no adverse impact on cable life, and that it is acceptable to allow a cable bend radius of 3 x OD for CP1-SWAPSW-02M."

Based on the review of all provided documentation, the inspectors concluded that the perceived flexibility of the cable and the light loading is not an adequate justification for reducing the minimum bend radius without vendor information or other specific data stating that the 3 x OD minimum bend radius was acceptable. Furthermore, the inspectors discussed the concern with the electrical subject matter experts in the NRC Office of Nuclear Reactor Regulation (NRR). The subject matter experts concurred that there was not adequate technical justification for reducing the minimum bend radius, and that manufacturer documentation (data sheet or specification) or consensus standards would be required. The inspectors determined that the perceived flexibility and light loading of the cable was not sufficient justification in that light loading indicates that the cable is performing within its rating and will have lower thermal stress when operating at rated conditions. Light loading is not a justification for reducing the bend radius, since the bend radius relates to physical properties of the cable (damaging/overstressing the cable insulation and jacket). The licensee did not provide any manufacturer information indicating that reducing the bend radius to 3 x OD would not have any impacts to cable function over the service life of the cable. Also, there was no consensus standard information provided indicating that the bend radius for silicone insulated cable manufactured by Rowe Industries could be reduced.

Corrective Actions: The licensee entered this concern into their corrective action program. The condition does not present an immediate safety concern because satisfactory post maintenance testing of the Unit 1 Station Service Water Pump Motor CP1-SWAPSW-02M was completed on October 22, 2020.

Corrective Action References: IR-2021-001493

Performance Assessment:

Performance Deficiency: The failure to provide adequate technical justification to support the change in minimum bend radius from 5 x OD to 3 x OD is a performance deficiency.

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. Specifically, the failure to adequately justify the change in minimum bend radius from 5 x OD to 3 x OD could adversely affect the availability, reliability, and capability of Unit 1 Station Service Water Pump Motor CP1-SWAPSW-02M. This is critical in that there is no means to verify that the motor leads were installed in a configuration that will not cause degradation of the lead cable.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, or component; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. Specifically, the licensee failed to create and maintain up to date technical documentation for the motor leads on the Unit 1 Station Service Water Pump that ensured the safe and reliable operation of the pump when they approved a reduced cable bend radius without documenting an adequate technical basis for the change.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

Contrary to the above, from October 22, 2020, to March 25, 2021, the licensee failed to assure that applicable regulatory requirements and the design basis, were correctly translated into specifications, drawings, procedures, and instructions and that deviations from appropriate quality standards were controlled. Specifically, the licensee failed to provide adequate technical justification or analysis to support the change in minimum bend radius from 5 x OD to 3 x OD for motor leads on the Unit 1 Station Service Water Pump replacement motor CP1-SWAPSW-02M.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Perform Adequate Periodic Testing of Class 1E Molded Case Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000445/2021011-03 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion XI, Test Control, for the failure to schedule all Class 1E molded case circuit breaker functional testing to detect deterioration and to demonstrate continued operability.

Description:

The inspectors reviewed design basis information and other documents pertaining to Class IE motor control center (MCC) 1 EB3-3 including the associated General Electric THED 136015 molded case circuit breakers (MCCBs). Included in the inspectors review was the functional testing program for Class 1E equipment. The Comanche Peak Nuclear Power Plant Updated Final Safety Analysis Report, subsection: 8.3.1.2.1 Compliance, section 2, references 10 CFR Part 50, Appendix A, General Design Criteria 18. General Design Criteria 18 states that electric power systems are designed to permit inspection and testing of all Class 1E systems. Periodic testing is performed on a scheduled basis to demonstrate the operability and continuity of all safety-related systems and components. Furthermore, it states that plant design also provides testing capability of other Class 1E equipment as required by the Institute of Electrical and Electronic Engineers (IEEE)standard IEEE 308.

The inspectors noted that IEEE 308-1974, Section 4.9 Connection of Non-Class IE Equipment, stated non-Class IE equipment which is required to maintain the station in a safe and orderly condition, may be supplied from Class IE power systems, provided that the Class IE systems are maintained at an acceptable level with respect to the requirements of this document. Furthermore, IEEE 308-1974, Section 5.2 Alternating-Current Power Systems, subsection 5.2.2, Distribution System, Paragraph 4, Surveillance, stated, the distribution system shall be monitored to the extent that is shown to be ready to perform its intended function. Section 6, Surveillance Requirements, Subsection 6.3, Periodic Equipment Tests, stated, in part, tests shall be performed at scheduled intervals to: 1. Detect the deterioration of the system toward unacceptable condition.

2. Demonstrate that standby power equipment and other components that are not exercised during normal operation of the station are operable.

MCC 1 EB3-3and MCCB-3M are safety related Class 1E components. The Class 1E MCCB-3M supplies a 480/120 VAC Transformer for MCC and motor space heaters, which are non-class 1E components. Isolation of non-Class 1E MCC and Motor Space Heaters from safety related bus 1EB3-3 is provided by compartment 3M safety related breaker. The breaker is tripped by the safety injection signal to isolate the non-Class 1E load from the safety related bus on occurrence of a design basis accident. The breaker is also coordinated with bus 1EB3-3 feed breaker MCC 1EB3-3 in switchgear 1B3, to ensure selective isolation of circuit faults by MCCB-3M to prevent any adverse impact on MCC Bus 1EB3-3 or its loads. The inspectors inquired about why preventive maintenance activities were not being performed on MCCB-3M, and whether or not there was an analysis to prove that a failure of the MCCB-3M would not affect other Class 1E components. The licensee indicated that the breaker was classified as Run-to-Maintenance and Non-Critical based on their component criticality classification system. With the Run-to-Maintenance classification, there are no recurring preventative maintenance tasks unless the Preventative Maintenance Review Committee approves a regular preventative maintenance task for this component. Furthermore, the licensee indicated that an analysis to ensure that a failure of MCCB-3M would not affect bus 1EB3-3 and its safety related loads was not required. Based on the information provided by the licensee, the inspectors determined that Preventive Maintenance tests were not being performed on MCCB-3M, installed in MCC 1EB3-3. Upon review of the inspectors concern, regulatory requirements, and other governing documents, the licensee indicated that a failure of a safety related MCCB-3M to perform its function may adversely impact Train A system bus 1EB3-3 and its loads. However, a Single Failure of MCCB-3M breaker would not have any adverse impact on the redundant Train B system to adequately perform their functions.

The inspectors did discover that the licensee does cycle this breaker periodically as a part of Train A Safeguards Slave Relay K615 Actuation Testing done by procedure OPT-469A, Revision 12. The inspectors also discovered that the licensee's procedure "Molded Case Circuit Breaker Test and Inspections," performed in MSE-S0-6303, Revision 9, includes testing criteria for the General Electric THED136015 that test for thermal overload and instantaneous trip functions. This procedure also includes insulation resistance testing. However, none of these tests were being performed on MCCB-3M.

Corrective Actions: The licensee entered this concern into their corrective action program and determined that there was no immediate safety concern because the last surveillance test involving the function this breaker was performed satisfactorily on July 3, 2019.

Corrective Action References: IR-2021-001393

Performance Assessment:

Performance Deficiency: The failure to schedule all Class 1E molded case circuit breaker functional testing to detect deterioration and demonstrate operability was a performance deficiency.

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. Specifically, inadequate testing to detect deterioration and to demonstrate continued operability was a programmatic deficiency that would adversely affect the reliability of Class 1E molded case circuit breakers to perform satisfactorily in service.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, issued November 30, 2020, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, or component; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, requires in part, that a test program shall assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Contrary to the above, prior to February 23, 2021, the licensee failed to assure that testing required to demonstrate that structures, systems and components would perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, the licensee failed to assure that all required testing was performed on MCCB-3M to detect deterioration and demonstrate operability in accordance with IEEE 308-1974.

Enforcement Action: This violation is being treated a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Maintain Proficiency of Operators to Meet Time Critical Operation Actions Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.9] - Training 71111.21M NCV 05000445,05000446/2021011-04 Open/Closed The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure that operators are able to implement specified actions in response to operational events and accidents. Specifically, three groups of operators could not achieve an action within the analysis time requirements for the inadvertent operation of the emergency core cooling system response as described in the licensees safety analysis report.

Description:

For proper operation of the components installed in the plant, and to meet their design requirements in the most limiting accident conditions, specific components have restrictions as to how long it takes for the components to operate or be manually operated. As part of the inspection, the licensee arranged evaluation opportunities for the inspectors to observe whether operators could meet the assumed time critical action times detailed in their FSAR document, human reliability analysis, and other licensing basis documentation. The inspectors selected the scenario of an inadvertent actuation of the emergency core cooling system (ECCS) event as described in section 15.5.1 of the FSAR.

On February 22 and 24, 2021, the inspectors observed a licensee evaluation of the assumed action times associated with mitigating the effects of an inadvertent operation of the ECCS event. Two actions described in the Final Safety Analysis Review FSAR, Section 15.5.1.2, assumption 8 (Amendment Number 108) are to manually open at least three of the four steam generator atmospheric relief valves (ARVs) within 8 minutes, and to secure ECCS flow within 14 minutes. The times were evaluated with three licensed operator groups in the plant simulator.

The licensed operator groups were successful in securing ECCS flow within 14 minutes in all cases. For the action to manually operate steam generator ARVs, it took one licensed operator group 8.33 minutes to accomplish the task. The two other groups performing the tasks, failed to take action to manually operate the ARVs following ECCS flow termination, and the event evaluation was terminated at 14.96 and 12.28 minutes. This demonstrated that the licensee had not implemented design control measures to verify that this time critical operator action time, as described in their FSAR, could be adequately met or maintained.

Following the observations, the inspectors inquired as to what training and evaluation had recently been performed to ensure that operators could meet the time critical assumptions. Information provided revealed the following:

• Training materials regarding safety injection (SI) termination procedure EOS-1.1A mention that there are timed operator actions associated with an inadvertent ECCS actuation. However, training on plant recovery techniques from a safety injection actuation do not include a verification that the reactor coolant system heat removal tasks that satisfy part of the time assumptions, which are performed in EOP-0.0A, Step 9, have been addressed. During instances where EOS-1.1A is being implemented following an inadvertent ECCS actuation, this action has the most significance (references LOCA ERGs/E-1 Series, dated July 1, 2019; and document LO21ERGE11, EOS 1.1, SI Termination, dated February 16, 2021).
• The operators had been evaluated once during the present performance period on performing actions required for this specific design basis event. On April 4, 2018, twelve licensed operator groups were evaluated on their ability to meet time assumptions in the ECCS inadvertent operation event. Eleven of the twelve groups were able to meet both of the associated time assumptions. One of the groups took action to terminate ECCS flow within 14 minutes but failed to take any action by the end of the evaluation period to manually open the steam generator ARVs. For these evaluations, the licensee had provided each group with an additional operator above the Technical Specification minimum crew staffing. The results provided an indication that even with additional operating group members allowed, there was still a possibility that the operator population could still fail to take the assumed actions associated with the steam generator ARVs. In addition, an evaluation with more than the Technical Specification minimum crew staffing for a design basis accident scenario masked any performance issues that may exist.

Following the failures to meet the time critical operator actions detailed above, the licensee evaluated whether the results of the inadvertent ECCS actuation analysis would be maintained if operating groups did not take any action to open three of four steam generator ARVs. As previously evaluated, the results with successful timely action were that the pressurizer would not fill solid, nor would water pass through the pressurizer power operated relief valves (PORVs) or safety valves. Relieving water through these valves could escalate the event to a small break loss of coolant accident (LOCA) if the valves stick open. The licensees recent evaluation demonstrated that not taking timely action to operate the steam generator ARVs would result in the pressurizer filling to a solid condition, with PORV and safety valve operation likely. However, the licensee has the capability to make up for these losses using their normal makeup system, so there is no immediate safety concern.

Corrective Actions: The licensee entered these issues into the corrective action program. In addition, the licensee conducted an analysis of the as-found conditions. Evaluation of this analysis and other mitigating factors result in no immediate safety concern.

Corrective Action References: IR-2021-001490.

Performance Assessment:

Performance Deficiency: The failure to ensure time critical operator actions could be implemented as stated in their design analysis was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, it impacted the design control attribute because the inadvertent safety injection could propagate to a loss of coolant accident.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Manual Chapter 609, Attachment 4, Tables 1, 2, and 3 worksheets (effective date December 13, 2019); and the corresponding Attachment A, Exhibit 1 (issue date November 30, 2020), the inspectors determined this finding would not result in exceeding a reactor coolant system leak rate in excess of normal makeup system capacity, nor would it likely affect other systems used to mitigate a loss of coolant accident. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the combination of periodic training and evaluation over the present performance period for the operators did not ensure that the operator population could demonstrate the capabilities necessary to meet the inadvertent emergency core cooling system actuation response assumptions.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.

Contrary to the above, from approximately April 4, 2018 until February 26, 2021, the licensee did not provide for verifying and checking the adequacy of design. Specifically, the licensee failed to ensure that operators remained proficient and knowledgeable of time critical operations could be completed by the operators as required by the licensing documents.

Enforcement Action: This violation is being treated a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Restore Compliance and Evaluate Inverter Fault Interrupting Capability During Design Basis Loss of Offsite Power and Seismic Conditions Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NOV 05000445/2021011-05 Open The inspectors identified a Green finding and associated notice of violation (NOV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to restore compliance of previously identified non-cited violation NCV 05000445/2015007-01. The violation identified the licensee's failure to verify or check the adequacy of the design by performing an analysis or test that demonstrated that the Class 1E inverters would continue to operate reliably when subjected to the effects of electrical faults that could be postulated to occur at non-Class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss-of-offsite power, and seismic events.

Description:

In 2015, an NRC inspection had selected the plant's essential electrical inverter as a component to inspect. The essential inverters in each of the four safety related instrumentation power channels provide an uninterruptible 120 VAC power supply to safety-related plant protection system equipment and other safety-related Class 1E systems including equipment in the power channel through a Class 1E breaker distribution panel. In addition, the inverter-backed Class 1E breaker distribution panel provided power to non-Class 1E system equipment through two non-Class 1E fuses provided in series to the non-Class 1E equipment. The inspectors identified that the inverter itself was not capable of interrupting faults on its output in all cases, and therefore relied on an automatic transfer to an alternate alternating current bypass source designed and sized to provide sufficient current to operate the breakers and fuses that protect circuits from faulted conditions. However, during a design basis loss of offsite power event, the bypass source would not be available during the time period when the loss of offsite power occurred and before the diesel generator was supplying standby power to the Class 1E electric power system.

The inspectors were concerned that if the bypass alternating current source was not available, such as during a loss of offsite power condition when the diesel generator has not yet provided power to the inverter bypass alternating current source, the inverter could go into a current limiting condition when providing current to a postulated faulted non-Class 1E circuit. The current limiting condition is an inherent protection feature of the inverter, whereby the voltage output of the inverter collapses as a result of a current overload condition that is above the inverter rated output capability. The inspectors requested the licensees fault current and coordination study for the condition when only the inverter was available to supply the necessary fault current for the protective devices to operate and found that the licensees staff had not evaluated this condition. The inspectors issued non-cited violation, NCV 05000445/2015007-01.

The licensee initiated condition report CR-2015-005530 to evaluate the condition. The licensee performed an operability evaluation to identify the most limiting circuit loading that the non-Class 1E fuses could experience. The review also evaluated conditions for entering current limiting conditions that would adversely affect the inverter output voltage.

During the 2021 Design Basis Assurance Inspection, the inspectors sampled the effectiveness of corrective actions implemented by the licensee to address concerns identified during previous Component Design Basis Inspections and Design Basis Assurance Inspections. In the review of non-cited violation NCV 05000445/2015007-01, the inspectors identified that the licensee had failed to complete the corrective actions in condition report CR-2015-005530, which were to verify or check the adequacy of the design by performing an analysis or test that demonstrated that the Class 1E inverters would continue to operate reliably when subjected to the effects of electrical faults that could be postulated to occur at non-Class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss-of-offsite power and seismic events. At the time of the 2021 Design Basis Assurance Inspection the licensee determined that a calculation or test was required to verify and document the adequacy of the design, but they had not determined which resolution they intended to implement to establish compliance with the design basis.

Corrective Actions: There was no immediate safety concern or additional risk. The 2015 non-cited violation was addressed in 3 condition reports. Condition report CR-2015-012009 is closed. Condition report CR-2015-005530 is still open with 20 actions to review for non-1E loads on various panels. Condition report CR-2015-008479 is also still open to perform a review to ensure that the Finding/Cross Cutting Aspect was properly addressed in their Corrective Action Program.

Corrective Action References: CR-2015-005530, CR-2015-008479, CR-2015-012009, and CR-2021-001500.

Performance Assessment:

Performance Deficiency: The failure to restore compliance of the previously identified non-cited violation NCV 05000445/2015007-01, which identified the failure to evaluate the fault clearing capability of the Class 1E inverters, was a performance deficiency.

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. Specifically, the licensee failed to evaluate the fault clearing capability of the inverter during design basis loss of offsite power and seismic conditions which resulted in a reasonable doubt of the operability of the system.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC) 0609, issued November 30, 2020, the inspectors determined this finding did not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from June 18, 2015 to March 25, 2021, the licensee did not assure that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to verify or check the adequacy of the design by performing an analysis or test that demonstrated that the Class 1E inverters would continue to operate reliably when subjected to the effects of electrical faults that could be postulated to occur at non-Class loads, due to a lack of seismic qualification of the loads, during and after a design basis loss-of-offsite power and seismic event. Condition report CR-2015-005530 is still open with 20 actions to review for non-Class 1E loads on various panels. Condition report CR-2015-008479 is also still open to perform a review to ensure that the Finding/Cross Cutting Aspect was properly addressed in their Corrective Action Program.

Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Restore Compliance for Inadequate Voltage Calculations for the 120 VAC Buses Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NOV 05000446/2021011-06 Open The inspectors identified a Green finding and associated Notice of Violation (NOV) of Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, for the failure to restore compliance of previously identified non-cited violation NCV 05000446/2013007-02. The violation identified the licensee's failure to perform accurate voltage calculations for the 125 VDC system and 120 VAC bus.

Description:

In 2013, an NRC inspection had selected the plant's essential electrical inverters as a component to inspect. The 118 VAC uninterruptible power system supplies critical instrumentation and control circuits from battery powered inverters. There are four Class 1E inverters per train, two for the reactor protection system and the other two for the balance of plant systems. Each inverter is connected independently to one Class 1E distribution panel. Two sources of backup 120V AC power are also provided to the inverter panels (one source per train). Four of the eight distribution panels are connected to each source. Each distribution panel can receive power from the 120 VAC backup source under operator control. The backup source for each train consists of a 480/120V transformer connected to a Class 1E 480V MCC. The transformers do not have automatic voltage regulation capability, so when connected to the transformer source, the 120 VAC distribution panel voltage will fluctuate with the voltage on the upstream 480V MCC source.

Branch Technical Position PSB-1, to which the licensee is committed, requires that the setpoints for the degraded voltage relays be determined from an analysis of the voltage requirements of the Class 1E loads at all onsite system distribution levels. The inspectors reviewed voltage calculation EE-1E-1EB4-1, which determined voltage at MCC 1EB4-1, for bypass transformer T1EC4. The inspectors noted that the calculation used an available voltage at the motor control center considerably higher (444.96V) than the voltage provided by the degraded voltage relays (433V) under accident loading conditions. In response to the inspectors inquiries, the licensee initiated condition report CR-2013-006396 and provided preliminary calculations showing that voltage required at the motor control centers, supplying the bypass transformers, was considerably higher than previously analyzed and higher than voltage provided by the degraded voltage relays. For instance, the preliminary calculations showed that for Transformer T1EC3, a voltage of 466.32V was required at motor control center 1EB3-1 to ensure operability of downstream 120V vital loads during steady state conditions, and 505.32V was required to ensure adequate voltage to loads requiring uninterruptible power during voltage dips associated with the starting of large loads at the start of an accident. Based on these results, condition report CR-2013-06396 concluded that when aligned to the 120 VAC transformer bypass source, the affected 120V vital bus should be considered inoperable, and LCO 3.8.9 action B1 which requires restoration of the vital bus to operable status in 2 hours would be applicable, instead of LCO 3.8.7 which would permit operation of a vital bus on 120 VAC bypass power for up to 24 hours. The licensee issued Limiting condition for operation action requirement (LOCAR) TX-130098 to implement this action and the inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to perform accurate voltage calculations for the 125 VDC system and 120 VAC bus. (NCV 05000446/2013007-02).

In 2017, the licensee reviewed LOCAR TX-13-0098 for risk significance. After reviewing the LOCAR and concluding that there was no increase in risk, the licensee exited the LOCAR per condition report CR-2017-00600. Per AI-CR-2013-008394-36, the licensee determined that the vital panels would remain operable when fed from bypass power supply as long as the 480V bus voltages were within technical specification limits. The licensee still needed to complete a new calculation to justify this analysis. Additionally, EV-CR-2017-000600-3 and -4 provided justification for ensuring operability of the vital panels while powered from the bypass power supply.

During the 2021 Design Basis Assurance Inspection, the inspectors sampled the effectiveness of corrective actions taken by the licensee to issues identified during previous Component Design Basis Inspections and Design Basis Assurance Inspections. In the review of non-cited violation NCV 05000446/2013007-02, the inspectors identified that the licensee had completed the calculation and corrective actions associated with the 125 VDC calculation that did not take into account the maximum inrush currents and actual accident loading, but had not completed the revision to the 120 VAC calculation that did not properly account for low voltage when the buses were supplied from their alternate source. Additionally, review of operator logs for the prior three years was performed and confirmed that there were no instances of a 120V vital bus having been aligned to its alternate transformer source in excess of two hours. As a result of the review, the inspectors concluded that prior to June 20, 2013 to February 28, 2021, the licensee had failed to restore compliance of non-cited violation NCV 05000446/2013007-02 because they had failed to revise the 120 VAC calculation that did not properly account for low voltage when the buses are supplied from their alternate source.

Corrective Actions: There was no immediate safety concern or additional risk. Condition reports CR-2013-006396 and CR-2013-006273 were closed to CR-2013-008394 which has 25 actions currently open to revise calculations for panel and load voltages.

Corrective Action References: CR-2013-006273, CR-2013-006396, CR-2013-008394, CR-2017-00600, and CR-2021-01499.

Performance Assessment:

Performance Deficiency: The failure to restore compliance of previously identified non-cited violation NCV 05000446/2013007-02, which required the correction of the 120 VAC calculation, was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to complete the 120 VAC calculation which had not properly accounted for low voltage when the buses are supplied from their alternate source, which would affect the capability of the system that respond to initiating events to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC) 0609, issued November 30, 2020, the inspectors determined this finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, requires, in part, that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, from June 20, 2013, to March 25, 2021, the licensee did not assure that applicable regulatory requirements and design basis are correctly translated into specifications, drawings, procedures, and instructions. Specifically, the 125 VDC calculation did not account for the maximum inrush currents and actual accident loading, and the 120 VAC calculation did not properly account for low voltage when the buses are supplied from their alternate source. Condition reports CR-2013-006396 and CR-2013-006273 were closed to CR-2013-008394 which has 25 actions currently open to revise calculations for panel and load voltages.

Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified 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 March 25, 2021, the inspectors presented the design basis assurance inspection (teams) inspection results to Mr. Thomas McCool, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.21M Calculations 0214-260-2-SW- Design Basis Review Calculation - 2-HV-4286 0 286-DP 71111.21M Calculations 1-SC-04-02 Westinghouse 7300 Process Control Systems Scaling 4 Calculation 1-T-4268 Component Cooling Water Heat Exchanger 02 Station Service Water Outlet Header Temperature 71111.21M Calculations 16345-ME(B)-088 Station Service Water System Steady State Hydraulic 8 Calculations 71111.21M Calculations 16345-ME(B)-372 Service Water Pumps NPSH and Submergence 2 71111.21M Calculations 16345-ME-162 Auxiliary Feedwater Pump Suction Flow Relief Valve Sizing 1 71111.21M Calculations 2-ME-0049 Normal Operation Inlet Pressures for Unit 2 SSWS MOV's 0 71111.21M Calculations 2-SC-04-02 Westinghouse 7300 Process Control Systems Scaling 1 Calculation, 2-T-4268, Component Cooling Water Heat exchanger-02 Station Service Water Outlet Header Temperature 71111.21M Calculations 911024-513 MOV Calculations - MOV Design Basis Reviews and 01/11/1993 Thrust/Torque Calculations Unit #2 71111.21M Calculations CN-TA-07-59 Comanche Peak Units 1 and 2 (TBX/TCX) Inadvertent 1 ECCS Actuation at Power Analysis for the Power Uprate Program 71111.21M Calculations EE-1E-1EB3-3 480 VAC Motor Control Center CP1-EPMCEB-07 (1EB3-3) 01 Bus Based Calculation 71111.21M Calculations EE-AC- AC Distribution Panels below 480V 4 Methodology 71111.21M Calculations EE-CA-0008-169 Coordination Study - 480V Class 1E Unitized MCC Buses 03 71111.21M Calculations EE-MCC- 480 MCC, Distribution Panel and Switchgear Methodology 11 METHODOLOGY 71111.21M Calculations EE-SC-U1-1E Unit 1 and Unit 2 Class 1E System Short Circuit Study with 5 Unit 1 Preferred Source Lineup 71111.21M Calculations EE-VP-U1-1E Unit 1 Class 1E System Voltage Profile 5 71111.21M Calculations ME-CA-0000- Design Data for CPSES Units 1, 2, Common Safety-Related 26 1093 Motor-Operated Valves (MOV) within the Scope of NRC Inspection Type Designation Description or Title Revision or Procedure Date Generic Letter 89-10 71111.21M Calculations ME-CA-0000- Safe Shutdown Impoundment Hydrothermal Analysis 4 264 71111.21M Calculations ME-CA-0000- Flow of SW Into AF System, With Backflow to Idle SW Train 0 3339 71111.21M Calculations ME-CA-0233- The Impact of Increasing the SSW Traveling Screens DP 1 5117 Alarm Setpoint 71111.21M Calculations ME-CA-0313- UPS Inverter Rooms Temperature Transient Following 3 4079 Station Blackout 71111.21M Calculations ME-CA-0400- Service Water Cross-Connect Operability 0 218 71111.21M Calculations MEB-200-00 Normal Operation Inlet Pressures for Station Service Water 0 System Motor Operated Valves 71111.21M Calibration 16345-ME(B)-205 Service Water System Op & Design Conditions 1 Records 71111.21M Corrective Action 2020-008526, Documents 2015-007472, 2017-000600, 2015-012009, 2013-006273, 2013-006396, 2013-008394, 2015-005530, 2017-07577, 2018-003367 71111.21M Corrective Action Condition Report 2012-000023, 2012-009009, 2013-001105, 2013-005889, Documents (CR-) 2013-006566, 2014-011024, 2014-011089, 2015-007980, 2016-007329, 2019-008102, 2019-009636, 2020-007650, 20-007695, 2020-008600, 2020-008929, 2020-009221, 2016-001306 71111.21M Corrective Action Tracking Report 2017-005862, 2017-009844, 2018-007012, 2017-001459, Documents (TR-) 2016-007615, 2017-007801, 2016-004759, 2020-007917, 20-007741 71111.21M Corrective Action Issue Report (IR-) 2021-001086, 2021-001358 Inspection Type Designation Description or Title Revision or Procedure Date Documents Resulting from Inspection 71111.21M Corrective Action Tracking Report 2021-001051 Documents (TR-) Resulting from Inspection 71111.21M Drawings 10-102722 Outline 10KVA inverter 125VDC, 120VAC, 1PH, 60Hz 3/29/96 71111.21M Drawings 10-102722 Outline 10kva Inverter One Line Diagram 3/29/96 71111.21M Drawings 10-102723 Outline 10KVA Inverter Front Panel Identifications 3/29/96 71111.21M Drawings BRP-SW-1-SI- Station Service Water CP-4 003 71111.21M Drawings E1-0001 Plant One Line Diagram - Units 1 and 2 CP-35 71111.21M Drawings E1-0004 6.9 KV Auxiliaries One Line Diagram Safeguard Buses CP-44 71111.21M Drawings E1-0005 480V Auxiliaries One Line Diagram - Safeguard Buses CP-27 71111.21M Drawings E1-001 Plant One Line Diagram Unit 1 and Common Distribution CP-18 Panels 71111.21M Drawings E1-0014 Service Water Intake Structure and Diesel Generator CP-33 Safeguard 480V MCCS, One Line Diagram 71111.21M Drawings E1-0018 118V AC Instrument Bus Distribution One Line Diagram CP-26 71111.21M Drawings E1-0018 120V AC Bypass Distribution One Line Diagram CP-9 71111.21M Drawings E1-0018 118V AC Instrument Bus Distribution One Line Diagram CP-3 71111.21M Drawings E1-0020 125V DC One Line Diagram CP-23 71111.21M Drawings E1-0020 125V DC One Line Diagram CP-18 71111.21M Drawings E1-0030 6.9 KV Switchgear Bus 1EA1 Lockout Relays 86-1/1EA1 CP-3 and 86-2/1EA1 Schematic Diagram 71111.21M Drawings E1-0030 6.9 KV Switchgear Safeguard Bus 1EA1 Undervoltage AUX CP-11

                                            [Auxiliary] Relays

71111.21M Drawings E1-0031 6.9 KV SWITCHGEAR BUS 1EA1 STATION SERVICE CP-5 WATER PP 11 TAG CP1-SWAPSW-0 1 BKR 1APSW1 SCHEMATIC DIAGRAM 71111.21M Drawings E1-0043 Service Water System Schematic and Connection Diagrams CP-9 Index 71111.21M Drawings E1-0043 Motor Operated Valve 1-HV-4268 Station Service Water PP- CP-7 Inspection Type Designation Description or Title Revision or Procedure Date Discharge To Strainer Isolation Valve 71111.21M Drawings E1-0043 SERVICE WATER PUMPHOUSE VENTILATION CP-6 EXHAUST FAN 06 TAG CPX-VAFNWV-96 71111.21M Drawings E1-0066 BOP Miscellaneous System Schematic and Connection CP-19 Diagram Index 71111.21M Drawings E1-0066 Safeguard DC SWBD 1ED1 Battery Chargers BC1ED1-1,2 CP-7 and DC Inverters IV1PC 71111.21M Drawings E1-0066 BOP MISCELLANEOUS SYSTEM SCHEMATIC AND CP-19 CONNECTION DIAGRAM INDEX 71111.21M Drawings E1-0067 MONITOR LIGHT BOX 1-MLB-9 MCC FEEDER BREAKER CP-1 OPEN INDICATION SCHEMATIC DIAGRAM 71111.21M Drawings E1-0071 1-SS11-1 118V AC and Bus Tie Bkr Schematic Diagram CP-12 71111.21M Drawings E1-0076 Annunciator Lamp Cabinet 1-ALB-10B Schematic Diagram CP-7 Sh3 71111.21M Drawings E1-0079 Annunciator Lamp Cabinet 1-ALB-10B Window Engravings CP-7 71111.21M Drawings E1-2400 Protective Device Settings D.C. System CP-2 71111.21M Drawings F43795 - 24 inch Type 9220 Valve with Limitorque SMB-00/15 H3BC A 2HV4268 Actuator 71111.21M Drawings M1-0233 Flow Diagram Station Service Water System CP-45 71111.21M Drawings M1-2200 Instrumentation & Control Diagram Safety System CP-8 Inoperable Indicator Logic 71111.21M Drawings M1-2233 Instrumentation and Control Diagram Station Service Water CP-9 System Channel 4250/4251 71111.21M Drawings M1-2233, Sht 5 2/4287 CP-5 Station Service Water System Instrumentation and Control Diagram Channel 4282/4287 71111.21M Drawings M1-2401 CPSES Unit 1 Motor Operated Valve Setpoint Control CP-3 Document 71111.21M Drawings S-0791 EC Bldg EL 790-6 Rooms 119, 121 & 125 Inverter, Battery CP-5 Charger & UPS Plan View Location Drawing 71111.21M Drawings S-0791 E.C. Bldg El 790-6 Rm 121 Unit 1 A Train Inverter & CP-2 Battery Charger & UPS Equipment Base Plate Details 71111.21M Drawings S-1114 S.W. Intake Struct. Concrete Inserts 7 71111.21M Engineering FDA-2017- EDG cam cover bolt thread helicoil replacement 01 Inspection Type Designation Description or Title Revision or Procedure Date Changes 000167-01-01 71111.21M Engineering FDA-2020- Minimum bend radius for CP1-SWAPSW-02M replacement 10/23/2020 Changes 000100-01-00 motor.; One Time Deviation to Specification 2323-ES-100 to allow minimum bend radius of service water pump motor leads (Silicone Insulated Cable manufactured by Rowe Industries, 2AWG, stranded flexible) to be 3 time the outer diameter of the cable. 71111.21M Engineering ER-EA-010 Risk-Based In-Service Testing Program, Integrated 5 Evaluations Decision-Making Panel 2018 Periodic Reassessment 71111.21M Miscellaneous Inservice Testing Plan for Pumps & Valves, Third Interval 2 71111.21M Miscellaneous 2014-0009 Final SSW [Station Service Water] Motor Refurbishment 5/28/2014 Report 71111.21M Miscellaneous 2323-ES-100 Specification - Electrical Installation 121 71111.21M Miscellaneous 2nd Quarter FY CPNPP System Status, Service Water System, System 2nd Quarter, Health Report 2020 71111.21M Miscellaneous 4th Quarter FY 20 CPNPP System Status , Service Water System, System 4th Quarter, Health Report 2020 71111.21M Miscellaneous 661-76268-003 Limitorque Operation and Maintenance Manual and 48 Bulletins 71111.21M Miscellaneous CP-0010-001 Station Service Water Pumps 23 71111.21M Miscellaneous CP-0411A-002 Service Water Motor Pumps 13 71111.21M Miscellaneous CPES-P-1079 Field Fabrication and Erection of Pipe Supports 11 71111.21M Miscellaneous DBD-EE-041 480V and 120V AC Electrical Power System 32 71111.21M Miscellaneous DBD-ME-007 Pipe Break Postulation and Effects 16 71111.21M Miscellaneous DBD-ME-011 Diesel Generator Sets 41 71111.21M Miscellaneous DBD-ME-026 Station Blackout 14 71111.21M Miscellaneous DBD-ME-027 Radiological Accident Analysis 13 71111.21M Miscellaneous DBD-ME-029 Seismic Qualification of Equipment 10 71111.21M Miscellaneous DBD-ME-206 Auxiliary Feedwater System 40 71111.21M Miscellaneous DBD-ME-233 Station Service Water System 38 71111.21M Miscellaneous DBD-ME-233 Design Basis Document - Station Service Water System 38 71111.21M Miscellaneous DBD-ME-312 Service Water Intake Structure Ventilation System 10 Inspection Type Designation Description or Title Revision or Procedure Date 71111.21M Miscellaneous DBD-ME-313 Uninterruptible Power Supply HVAC System 13 71111.21M Miscellaneous JPM # AO6407 Locally Control AFW to Steam Generator in Response to 0 Loss of Instrument Air 71111.21M Miscellaneous JPM #AO5212 Recirculate a Boric Acid Tank Through a Boric Acid Filter 0

                        (U1)

71111.21M Miscellaneous LO21ERGE11 EOS 1.1, SI Termination 0 71111.21M Miscellaneous LO41.ERG.EO1 LOCA ERGs/E-1 Series (Lesson Plan) 7/1/2019 71111.21M Miscellaneous NE-15877 Comanche Peak Steam Electric Station Auxiliary Feedwater 1/28/1988 System, Reference: SWTU-4043 71111.21M Miscellaneous PRATA-3.2 Initiate Feed and Bleed in FRH-0.1 Simulator Exercise 0 Guide 71111.21M Miscellaneous TCA-1.1 Faulted SG - Feedline Break Simulator Evaluation Guide 0 71111.21M Miscellaneous TCA-1.7 Terminate ECCS Following a Spurious Safety Injection 0 71111.21M Miscellaneous TCA-1.8 Postulated Pipe Failure Analysis Simulator Evaluation Guide 0 71111.21M Miscellaneous TFEGT-PPT-50- Comanche Peak Nuclear Power Plant MOV Diagnostic Test 3 6000-1 Instructions / Criteria 71111.21M Miscellaneous TSA-2.12 Manually Initiate a Safety Injection for a SB LOCA Simulator 0 Evaluation Guide 71111.21M Miscellaneous TXX-19057 Comanche Peak Nuclear Power Plant, Docket Nos. 50-446 5/16/2019 and 50-446, Updated Response to Station Blackout Rule 71111.21M Miscellaneous TXX-92410 Comanche Peak Steam Electric Station (CPSES), Docket 08/31/1992 Nos. 50-445 and 50-446, Submittal LAR 92-002, Combined Unit 1 and 2 Technical Specifications 71111.21M Miscellaneous TXX-92447 Comanche Peak Steam Electric Station (CPSES), Docket 10/1/1992 No. 50-445 and 50-446, Response to Station Blackout

                                      (SBO) Rule

71111.21M Miscellaneous TXX-96405 Comanche Peak Steam Electric Stations (CPSES), Docket 7/10/1996 Nos. 50-446 and 50-446, Submittal of License Amendment Request 96-004, Uninterruptible Power Supplies (UPS) HVAC System Addition of Fan Coil Units to Technical Specifications 71111.21M Miscellaneous TXX-96475 Comanche Peak Steam Electric Stations (CPSES), Docket 10/1/1996 Nos. 50-446 and 50-446, Additional Information for License Amendment 96-004, Uninterruptible Power Supplies (UPS) Inspection Type Designation Description or Title Revision or Procedure Date HVAC System Addition of Fan Coil Units to Technical Specifications 71111.21M Miscellaneous WCAP-14882-P-A RETRAN-02 Modeling and Qualification for Westinghouse 4/1/1999 Pressurized Water Reactor Non-LOCA 71111.21M Miscellaneous WCAP-16480-P Delta 76 Replacement Steam Generator Thermal and 1 Hydraulic Design Analysis Report for Comanche Peak Unit 71111.21M Miscellaneous WCAP-16871-P Comanche Peak Nuclear Power Plant Stretch Power Uprate 0 Engineering Report 71111.21M Miscellaneous WCAP-16902-P Loss of Secondary Heat Sink, Upgrade Analysis for 0 Emergency Response Guideline FR-H.1 71111.21M Miscellaneous WPT-17340 Luminant Comanche Peak Nuclear Power Plant Units 1 and 6/5/2009 2, Power Plant Uprating Inadvertent ECCS Actuation Analysis 71111.21M Miscellaneous WPT-17343 Luminant Comanche Peak Nuclear Power Plant Units 1 and 6/10/2009 2, Plant Power Uprating, Inadvertent ECCS Actuation Analysis Additional Sensitivity Studies 71111.21M Procedures ABN-103 Excessive Reactor Coolant Leakage 10 71111.21M Procedures ABN-105 Chemical and Volume Control System Malfunction 8 71111.21M Procedures ABN-501 Station Service Water Malfunction 10 71111.21M Procedures ABN-601 Response to a 138/435 KV System Malfunction 13 71111.21M Procedures ALM-0061A Alarm Procedure 1-ALB-6A 7 71111.21M Procedures Comanche Peak ECE-5.08-01 0

                       (Utility) Design

Change Process 71111.21M Procedures ECA-0.0A Loss of All AC Power 9 71111.21M Procedures ECA-1.1A Loss of Emergency Coolant Recirculation 9 71111.21M Procedures ECE-5.01 Design Control Program 10, 11, 12 71111.21M Procedures ECE-5.02 Specifications 16 71111.21M Procedures EOP-0.0A Reactor Trip or Safety Injection 9 71111.21M Procedures EOP-1.0A Loss of Reactor or Secondary Coolant 9 71111.21M Procedures EOP-2.0A Faulted Steam Generator Isolation 9 71111.21M Procedures EOS-1.1A Safety Injection Termination 9 71111.21M Procedures ETP-501 Station Service Water System Cross Connect Flush 3 Inspection Type Designation Description or Title Revision or Procedure Date 71111.21M Procedures FRH-0.1A Response to Loss of Secondary Heat Sink 9 71111.21M Procedures IST-301 Inservice Testing of Motor-Operated Valves 6 71111.21M Procedures MSE-C0-4318 Station Service Water Pump Motor Rework 6 71111.21M Procedures MSE-C0-6305 6.9 KV 7.5 HK Circuit Breaker Enhanced Maintenance 3 71111.21M Procedures MSE-G0-4003 Motor Insulation Resistance Testing 5 71111.21M Procedures MSE-G0-4004 Baker On-Line Motor Testing 5 71111.21M Procedures MSE-G0-6300 Breaker Removal and Installation 3 71111.21M Procedures MSE-P0-8349 Limitorque Actuator Periodic Electrical and Mechanical 9 Inspection 71111.21M Procedures MSE-S0-6303 Molded Case Circuit Breaker Test and Inspection 9 71111.21M Procedures MSE-S0-6304 Westinghouse 480 Volt Air Circuit Breaker PM and 3 Surveillance Inspections 71111.21M Procedures MSM - C0 - 3805 EMERGENCY DIESEL ENGINE CAMSHAFT AND TAPPET 3 MAINTENANCE 71111.21M Procedures MSM-C0-7310 Service Water Pump Maintenance 6 71111.21M Procedures ODA-102 Conduct of Operations 34 71111.21M Procedures OPT-207A Service Water System 18 71111.21M Procedures OPT-468A Train A Safeguards Slave Relay K610 Actuation Test 9 71111.21M Procedures OPT-469A Train A Safeguards Slave Relay K615 Actuation Test 12 71111.21M Procedures PPT-S0-6000 Motor Operated Valve Risk-Informed IST Testing 3 71111.21M Procedures SOP-102A Residual Heat Removal System 22 71111.21M Procedures SOP-304A Auxiliary Feedwater System 17 71111.21M Procedures SOP-501A Station Service Water System 20 71111.21M Procedures STA-214 Timed Operator Action Program 2 71111.21M Procedures STI-211.07 Heat Stress Management 0 71111.21M Procedures STI-214.01 Control of Timed Operator Actions 2 71111.21M Procedures STI-426.02 Processing Important OE [Operating Experience], IERL3 1

                                     [INPO Event Report Level 3] & IERL4 [[INPO Event Report

Level 4], INS [Information Notices] & OPESS [Operating Experience Smart Sample] Reports 71111.21M Procedures STI-716.06 Design Attribute Review (DAR) 1 71111.21M Work Orders Work Order (WO- 4627624, 5529331, 5536416, 5571820, 5705751, 5788037,

                     )               5917223, 5945664, 5948865, 5931245, 5980342, 5776536,

Inspection Type Designation Description or Title Revision or Procedure Date 5949390, 5936084, 5967154, 5927886, 5735060, 4297555 34 }}