IR 05000445/2019004

Integrated Inspection Report 05000445/2019004; 05000446/2019004, and Independent Spent Fuel Storage Inspection 07200074/2019001

ML20041D968
Person / Time
Site:	Comanche Peak
Issue date:	02/07/2020
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Peters K Vistra Operations Company
References
IR 2019001, IR 2019004
Download: ML20041D968 (22)

Text

ary 7, 2020

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INTEGRATED INSPECTION REPORT 05000445/2019004; 05000446/2019004, AND INDEPENDENT SPENT FUEL STORAGE INSPECTION 07200074/2019001

Dear Mr. Peters:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2. On January 9, 2020, the NRC inspectors discussed the results of this inspection with Mr. T. McCool, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Comanche Peak Nuclear Power Plant, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Docket Nos. 05000445, 05000446, and 07200074 License Nos. NPF-87 and NPF-89

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000445; 05000446 and 07200074 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2019004; 05000446/2019004 and 07200074/2019001 Enterprise Identifier: I-2019-004-0011 and 1-2019-001-138 Licensee: VISTRA Operations Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: Glen Rose, TX 76043 Inspection Dates: October 1, 2019, to December 31, 2019 Inspectors: R. Alexander, Senior Project Engineer M. Chambers, Physical Security Inspector N. Day, Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspect J. Ellegood, Senior Resident Inspector S. Hedger, Emergency Preparedness Inspector C. Jewett, Physical Security Inspector E. Simpson, Health Physicist Inspector, ISFSI Approved By: Neil F. O'Keefe, Chief Reactor Projects Branch B Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Comanche Peak Nuclear Power Plant,

Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Critique Weaknesses During a Biennial Exercise Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.14] - 71114.01 Preparedness NCV 05000445,05000446/2019004-01 Conservative Open/Closed Bias The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on November 6, 2019. Specifically, the licensee did not identify two examples of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000446/2018-001-00 Automatic Reactor Trip Due to 71153 Closed Turbine Trip LER 05000446/2018-002-00 Automatic Actuation of 71153 Closed Auxiliary Feedwater System

PLANT STATUS

Unit 1 operated at or near 100 percent rated thermal power for the entire inspection period.

Unit 2 operated at or near 100 percent rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following system:

Service water system and flex equipment in accordance with Procedure OWI-912 on November 15, 2019

Impending Severe Weather Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated readiness for impending adverse weather conditions for licensee actions for severe weather on October 21, 2019.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Instrument air system alignment post maintenance on the X-02 instrument air compressor on October 29, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Yard fire area on October 16, 2019

(2) Unit 1, cable spreading room on November 15, 2019

(3) Unit 2, cable spreading room on November 15, 2019

(4) Unit 1, control room on December 13, 2019

(5) Unit 2, control room on December 13, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 generator testing and solid-state protection system testing per Work Order 5804827 on December 2, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a steam generator tube rupture scenario on November 18, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Control room air conditioning system on November 27, 2019

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Commercial grade dedication plans and receipt inspection of parts for safety-related applications

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Risk incurred on Unit 1, emergency diesel generator 2, due to slow start procedure on October 9, 2019

(2) Heavy lift of loaded independent spent fuel storage installation canister on October 15, 2019

(3) Protected equipment lineup due to 138kV east bus maintenance on November 15, 2019

(4) Unit 2, plant computer replacement on November 24, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1, emergency diesel generator 1, with spurious alarms, as described in Condition Report 2019-09002 on November 20, 2019

(2) Unit 2, slave relay testing operability due to test switch failure during OPT-406A on October 16, 2019

(3) Unit 2, gamma-metric source range nuclear instruments

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary modification:

(1) Isolation of two Unit 2 steam dump to condenser valves on October 7, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post-maintenance tests:

(1) Unit 1, reactor coolant loop 2 overtemperature N16 card TY411D replacement and post maintenance test using OPT7660AI0, Work Order 5825082 on October 25, 2019

(2) Unit 2, containment spray pump A, motor breaker maintenance post maintenance test using Work Order 5796519 on October 28, 2019

(3) Unit 2, turbine driven auxiliary feedwater pump inadvertent start on October 31, 2019 per Work Order 5827859, as described in Condition Report 2019-08435

(4) Unit 1, emergency diesel generator 1, following maintenance and annunciator troubleshooting per Work Order 5825230 on November 20, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) OPT-207A, Unit 1 service water system surveillance test, Work Orders 5788024 and

===578037 on October 8, 2019

(2) OPT-214A, (Slow Start) Unit 1, emergency diesel generator 2 operability test, Work Order 5809941 on October 10, 2019

(3) OPT-447A, Unit 1, train A solid state protection system quarterly surveillance, Work Order 5788227 on October 21, 2019 Inservice Testing (IP Section 03.01) ===

(1) OPT-515B, Unit 2, emergency diesel generator 1 fuel oil transfer pumps, Work Orders 4501250, 5228546, and 5814518

71114.01 - Exercise Evaluation Inspection Review (IP Section 02.01-02.11)

(1) The inspectors evaluated the biennial emergency plan exercise conducted on November 6, 2019. The exercise scenario simulated leaking fuel pins, a fire in a room containing safety-related equipment, and an escalating loss of coolant accident with a containment equipment hatch seal failure.

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) The inspectors observed a licensed operator training evolution that included a drill/exercise performance opportunity on December 4, 2019.

71114.08 - Exercise Evaluation Scenario Review Inspection Review (IP Section 02.01 - 02.04)

(1) The inspectors reviewed and evaluated the proposed scenario for the biennial emergency plan exercise conducted on November 6,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) October 1, 2018, through September 30, 2019

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) October 1, 2018, through September 30, 2019 EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) October 1, 2018, through September 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 (October 1, 2018, through September 30, 2019)

(2) Unit 2 (October 1, 2018, through September 30, 2019)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (October 1, 2018, through September 30, 2019)

(2) Unit 2 (October 1, 2018, through September 30, 2019)

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in equipment performance that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Operator workarounds on October 17, 2019

(2) IR 2019-7675, ambulance left running in protected area during drill

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated loss of emergency action level (EAL) assessment due to unavailable main steam line radiation monitors U2-RE-2325 and -2327, as reported in Event Report 54329 on October 15, 2019.

Event Report (IP Section 03.02) (No Samples)

The inspectors administratively closed the following licensee event reports (LER) because the licensee issued revisions:

(1) LER 05000446/2018-001-00 Automatic Reactor Trip Due to Turbine Trip (ADAMS Accession No.: ML19282A382)

(2) LER 05000446/2018-002-00 Automatic Actuation of Auxiliary Feedwater System (ADAMS Accession No.: ML19029A146)

OTHER ACTIVITIES

- TEMPORARY INSTRUCTION, INFREQUENT AND ABNORMAL 60855 - Operation of an ISFSI at Operating Plants The Comanche Peak Independent Spent Fuel Storage Installation (ISFSI) consisted of a single 26,724 sq. ft. (102 ft. by 262 ft.) concrete pad designed for the storage of up to 84 Holtec International HI-STORM 100S Version B casks. At the time of the routine inspection, the Comanche Peak ISFSI pad contained a total of 38 HI-STORM 100 overpacks and the licensee was in the process of loading and processing canister 39. The licensee was loading canisters to the Holtec Certificate of Compliance No. 1014, Amendment 7, and HI-STORM 100 Final Safety Analysis Report (FSAR), Revision 9.

The inspectors evaluated the licensees ISFSI cask loading from October 21 through 25, 2019.

Specifically, the inspectors observed the following activities:

• Fuel assembly selection and placement into the dry fuel storage canister

• Processing of the spent nuclear fuel for storage, including forced helium dehydration and helium backfill operations

• Heavy load lifts by the cask handling crane of the transfer cask and its spent fuel contents

• Stack-up operations for transferring the storage canister from the transfer cask to the HI-STORM overpack

• Transport of the loaded HI-STORM overpack from the auxiliary building to the ISFSI pad using the vertical cask transporter (VCT)

The inspectors also evaluated the licensee's operational response and recovery actions associated with malfunctioning forced helium dehydrator equipment, trouble-shooting, and repairs.

The inspectors performed a walk-down of the ISFSI radiologically controlled area and completed an independent radiation survey. The inspectors also performed a walk-down of the spent fuel floor for Comanche Peak, Units 1 and 2. The inspectors observed the movement of the loaded HI-STORM cask on the low-profile-transporter as it was moved from the fuel building, transferred to the VCT, and taken along the haul path to the ISFSI pad for storage.

The inspectors evaluated the following:

• Spent fuel selection for both reactor units (1 and 2) in this sixth dry cask loading campaign for Comanche Peak (casks 37-42)

• Compliance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 72.104 for calendar years 2017 and 2018

• Fire hazards analyses and control of combustibles for ISFSI operations

• Conditions for use of the cask supplemental cooling system

• Selected radiological surveys of the ISFSI and dry fuel storage casks

• Selected ISFSI related condition reports

• Quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations

• Compliance with Technical Specifications for operational surveillance activities and FSAR required annual maintenance activities

• Documentation of annual maintenance activities for heavy lifting components, including special lifting devices, the sites cask handling crane, and the sites VCT 60857 - Review of 10 CFR 72.48 Evaluations The inspectors reviewed a list of 10 CFR 72.48 screenings performed by the licensee since May 2018. During this time period, the licensee did not perform any 10 CFR 72.48 evaluations.

The inspectors evaluated the following:

• Selected licensee 10 CFR 72.48 screenings and associated changes, tests, or experiments - primarily associated with procedure changes

• The process by which the licensee evaluates 10 CFR 72.48 screenings and evaluations performed by the Certificate of Compliance holder

• Changes made to the licensees 10 CFR 72.212 Report since May 2018 (from 72.212 Report, Revisions 10 to 11)

INSPECTION RESULTS

Failure to Critique Weaknesses During a Biennial Exercise Cornerstone Significance Cross-Cutting Report Section Aspect Emergency Green [H.14] - 71114.01 Preparedness NCV 05000445,05000446/2019004-01 Conservative Open/Closed Bias The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during a biennial emergency preparedness exercise conducted on November 6, 2019.

Specifically, the licensee did not identify two examples of performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency.

Description:

The inspectors observed an emergency preparedness exercise conducted on November 6, 2019, and observed the licensees formal exercise critique conducted on November 13, 2019. Based on these observations, and review of corrective action documentation, the inspectors determined that the licensee failed to identify emergency response organization weaknesses in emergency response facility manning and radiological protective measure assessment and, as a result, did not ensure that the weaknesses would be corrected.

The NRC inspectors observed the performance of the licensees emergency response organization, including organization members in the control room simulator, technical support center (TSC) and the emergency operations facility (EOF). During an emergency, the emergency director has the authority to call for emergency response facility manning when he or she determines that the resources are needed. With changing radiological conditions, health physics (HP) and security staff in the EOF need to assess changes in radiological release severity and meteorological conditions to ensure that security personnel are given directions which prevent or minimize their radiological exposure.

Example 1:

The Comanche Peak emergency plan states the emergency conditions when emergency response organization (ERO) members can be summoned to their assigned facilities.

Section 1.1.2 says that at an Alert classification, a callout is initiated. However, it also states, "Prior to declaring an Alert, the Shift Manager (Emergency Coordinator) has the authority to call in any portion of the augmentation staff specifiedas may be required for emergency response." The callout of the ERO members is primarily accomplished via an automatic dialing system. The licensee implements an "all call" approach to calling ERO members. This means when the automatic dialing system is activated, it calls all ERO members to report to their assigned facilities.

For the purpose of the exercise, the licensee communicated to participants that the response expectations were the same for the exercise situation as if they had to respond to an actual emergency. The document "Safety, Guidelines, and Extent of Play for All ERO Members," used to brief participants prior to the exercise, stated, "All ERO members are expected to respond.

Personnel arriving first shall fill their position, until relieved by the team member assigned for the exercise."

At 7:57 a.m., the shift manager (Emergency Coordinator) classified an Unusual Event. Based on the Emergency Coordinators assessment of plant conditions, a decision was made to activate the automatic dialing system to call in all available ERO members to respond to their facilities. At 8:01 a.m., the message conveyed by the automatic dialing system said that an emergency had been declared and requested ERO members fit for duty to report to their assigned facilities. By 8:32 a.m., once manning had achieved a steady-state level, inspectors observed 3 of 16 TSC staff members and 7 of 23 EOF staff members had reported to their respective facilities. The staff members in these facilities did not fill enough minimum roles needed to activate all functions.

The Emergency Coordinator classified an Alert at 8:28 a.m. A public address system announcement at the plant was made at 8:37 a.m. In this announcement, it said that an Alert had been declared, and that all ERO personnel were to report to their emergency response facilities. After the announcement, the rest of the aforementioned facilitys staff arrived. Since no other automatic dialing system activation took place after 8:01 a.m., the inspectors concluded that the action that caused the majority of the ERO staff to arrive at their facilities was the plant announcement.

The public address system can only be heard by staff members at the plant site. With respect to the automatic dialing systems message during an actual emergency, it communicates the same key messages as the one during a drill or exercise (an emergency had been declared and requested ERO members fit for duty are to report to their assigned facilities). Based on this, the inspectors concluded that, had a real emergency occurred at a time when plant staffing on site was low (for example, on non-workdays or at night), the level of response to the manning call demonstrated during the exercise would have resulted in incomplete staffing of all ERO facilities.

In document TR-2019-008786, the licensee identified that there was confusion among the exercise players regarding the ERO notifications at the Unusual Event classification. They concluded that it was a minor issue, with the facilitys manning being reached by their time goals. By focusing on time goals, the licensee failed to consider if crediting the plant announcement masked a performance issue with response to the automatic dialing system alone.

The inspectors concluded the failure to demonstrate adequate staffing in the TSC and EOF when prompted by the automatic dialing system would have precluded the effective implementation of the licensees emergency plan and constituted a weakness in emergency response organization performance.

Example 2:

At 10:30 a.m., the exercise scenario indicated steam was escaping from the units containment equipment hatch after a large break loss of coolant accident occurred. A Site Area Emergency was declared and it was recognized that a radiological release was in progress. Meteorological data showed that the wind was blowing in a direction which resulted in the release path moving directly over security personnels position. Review of the player logs showed that EOF security and health physics staff coordinated to evaluate the radiological conditions for these security personnel at 8:37 a.m. and 10:27 a.m. At the time, it was determined that they had adequate radiological protective measures provided where they were located.

Simulated radiological conditions changed based on fuel degradation and increased containment leakage. At 11 a.m., containment high range radiation monitors increased above the threshold associated with a loss of the fuel clad barrier. The size of the simulated leak from containment increased at 11:30 a.m. Based on these conditions, the radiological dose being received by the security personnel should have been re-evaluated to determine if additional protective measures were needed. Based on review of player logs, the EOF security and health physics staff did not evaluate the changing conditions to determine if appropriate protective measures were being provided to these personnel.

Procedure EPP-309, "Onsite/In-Plant Radiological Surveys and Offsite Radiological Monitoring,"

Revision 14, Step 4.9.2, states "Onsite and offsite radiological monitoring shall continue, as required, throughout the duration of the emergency so that the need for protective measures can be quickly addressed." According to Step 4.10.4, "Entry into an area greater than the 1000 mrem/hr turnback dose rate should not be attempted until approved by the Operational Support Center (OSC) Radiation Protection Coordinator, EOF Radiation Protection Coordinator, or the TSC Onsite Radiological Assessment Coordinator." According to radiological data from the exercise scenario, the dose rates in the plume path in the protected area were 5600 mrem/hour. Any in-plant repair team needing to enter that area would have to receive special approval. Based on review of player and controller/evaluator logs, the security personnel stationed or moving through the plume path did not receive approval as required by Step 4.10.4 above. The inspectors concluded the failure to provide appropriate radiological protection to security personnel located in the plume path following the increased radiological release precluded the effective implementation of the licensees emergency plan and constituted a weakness in emergency response organization performance.

In Condition Report (CR) 2019-008800, the licensee identified several issues with emergency worker protection for repair team personnel being coordinated through the Operations Support Center. However, the failure to assess and provide protective measures for security personnel in the plume pathway was not addressed.

Corrective Actions: The licensee entered these issues into the corrective action program.

Corrective Action References: CR-2019-009542

Performance Assessment:

Performance Deficiency: The licensees failure to correct weaknesses that occurred during an exercise was a performance deficiency. These were within the licensees ability to foresee and correct. A weakness is defined in Section 2.0(o) of Inspection Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process,"

(dated September 22, 2015) as emergency response organization performance that would have prevented the effective implementation of the licensees emergency plan had the circumstances occurred. The emergency response organizations failures to demonstrate staff augmentation and to provide a range of protective measures to emergency workers were weaknesses requiring correction.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO performance attribute of the Emergency Preparedness Cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to ensure that adequate measures will be taken to protect the health and safety of the public is degraded when weak emergency response organization performance is not corrected.

Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. Using Manual Chapter 0609, "Significance Determination Process," Attachment 4, Tables 1, 2, and 3 worksheets (effective date October 7, 2016) and the corresponding Appendix B, "Emergency Preparedness Significance Determination Process,"

2 (issue date September 22, 2015), the performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The finding was not a loss of planning standard function because the licensee appropriately critiqued some weaknesses associated with risk-significant activities and the 10 CFR 50.47(b) planning standards.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision-making practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. The finding had a cross-cutting aspect in the area of conservative bias associated with human performance because the licensee failed to emphasize prudent choices over those that are allowable.

Specifically, the licensee did not exhibit conservative bias in their determination that all performance weaknesses were identified, ending their formal critique process. For the two examples, there were unusual conditions involved in each that warranted review prior to closing the critique process to ensure that all weaknesses were identified.

Enforcement:

Violation: Title 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(14) requires, in part, that deficiencies identified as a result of exercises or drills are (will be) corrected.

Contrary to the above, on November 13, 2019, the licensee failed to correct deficiencies identified as a result of exercises or drills. Specifically, the licensee failed to identify emergency response organization performance deficiencies (weaknesses) occurring during the November 6, 2019, biennial exercise and did not ensure correction of the weaknesses. There was no actual or potential safety significance because the weak performance occurred during an exercise.

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

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 24, 2019, the inspectors presented the independent spent fuel storage inspection (ISFSI) results to Mr. B. St. Louis, Plant Manager, and other members of the licensee staff.

• On November 14, 2019, the inspectors presented the emergency exercise scenario review inspection telephonic exit inspection results to Mr. T. McCool, Site Vice President, ,and other members of the licensee staff.

• On November 14, 2019, the inspectors presented the emergency preparedness exercise inspection telephonic exit inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

• On December 18, 2019, the inspectors presented the emergency preparedness exercise inspection telephonic re-exit inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

• On January 9, 2020, the inspectors presented the integrated inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures OWI-912 Cold Weather 4

71111.05Q Fire Plans FPI-506 Electrical and Control Building Control Room Elevation 830'- 5

0"

71111.11Q Miscellaneous LO44.BBS.025 Steam Generator Tube Rupture with Loss of Coolant 00

Accident Simulator Exercise Guide

Work Orders 5804827 Provided surveillance OPT-448B, for unit 2 sold state

protection system train B input/logic

5814518 Diesel Generator 2-01 Fuel Oil Transfer Pump 2-01 December

18, 2019

71111.12 Corrective Action CR-YYYY-NNNN 2018-000993, 2018-001056, 2018-003900, 2018-006453

Documents 2018-006878, 2018-007827, 2019-007657

Miscellaneous Control Room System Health Report 4th quarter

FY19

2285 Capacitor. Alum, Electrolytic, 10mF, 100VDC, -10/+50, 0

RoHS

465655 Commercial Grade Item Dedication Connector, Elec, CU,

Term, 2-Hole, Common, Non-insul, Long Barrel, 1/2 in Stud,

1. 6 AWG

NEE0753210 Commercial Dedication for Conduit. rigid, steel, with a 0

coupling on one end and thread protector on other, hot dip

galvanized

RR 93584 Inspection Results for purchase order 627928 11/18/2019

SAR 29020 Commercial Grade Item Dedication Connector, Elec, CU, N/A

Term, Ring Tongue

71111.19 Drawings E2-0020, Rev Turbine Driven Auxiliary Feedwater Pump Logic Drawings

CP7

E2-0037, Rev

CP9

M2-2206, Rev

CP-3

Work Orders 5825082 Troubleshoot and repair condition described in IR-2019-

008279

Inspection Type Designation Description or Title Revision or

Procedure Date

25230 Providing surveillance OPT-214A for diesel generator 1-01

27859 Perform thermography of fuses for IR-2019-008435

71111.22 Procedures OPT-448B Modes 1, 3, and 4 Train B SSPS Actuation Logic Test 11

Work Orders 5788227 Provide surveillance OPT-447A, TADOT Train A SSPS

Logic Actuation Test

71114.01 Corrective Action CR-YYYY-NNNN 2017-009379, 2017-009505, 2018-002566, 2018-006928,

Documents 2019-001353, 2019-003057, 2019-005327, 2019-006459,

2019-006627, 2019-007133, 2019-008831, 2019-009542

TR-YYYY-NNNN 2017-009345, 2017-009431, 2017-009434, 2017-009498,

2017-009511, 2018-001402, 2018-001937, 2018-002663,

2018-002665, 2018-003069, 2018-004711, 2018-005663,

2018-006473, 2018-006785, 2018-007108, 2018-007112,

2019-000037, 2019-001379, 2019-001825, 2019-005516,

2019-005521, 2019-005800, 2019-005810, 2019-006326,

2019-006458, 2019-007129, 2019-007020, 2019-007817

Miscellaneous Comanche Peak Nuclear Power Plant, Emergency 2/2/2017

Response Organization, Exercise Report, Green Team -

January 11, 2017

Comanche Peak Nuclear Power Plant, Emergency 10/10/2019

Response Organization, Exercise Report, Green Team -

January 29, 2019

Comanche Peak Nuclear Power Plant, Emergency 8/28/2018

Response Organization, Exercise Report, Gold Team -

February 14, 2018

Comanche Peak Nuclear Power Plant, Emergency 4/21/2017

Response Organization, Exercise Report, Blue Team -

February 15, 2017

Comanche Peak Nuclear Power Plant, Emergency 8/28/2018

Response Organization, Exercise Report, Blue Team - April

4, 2018

Comanche Peak Nuclear Power Plant, Emergency 10/10/2018

Response Organization, Exercise Report, Gold Team - June

26, 2019

Comanche Peak Nuclear Power Plant, Emergency 7/27/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

Response Organization, Exercise Report, Red Team - June

28, 2017

Comanche Peak Nuclear Power Plant, Emergency 8/28/2018

Response Organization, Exercise Report, Green Team -

June 11, 2018

Comanche Peak Nuclear Power Plant, Emergency 10/18/2017

Response Organization, Exercise Report, Gold Team - July

2, 2017

Comanche Peak Nuclear Power Plant, Emergency 10/10/2019

Response Organization, Exercise Report, Blue Team - July

17, 2019

Comanche Peak Nuclear Power Plant, Emergency 10/15/2017

Response Organization, Exercise Report, Gold Team -

August 16, 2017

Comanche Peak Nuclear Power Plant, Emergency 1/16/2019

Response Organization, Exercise Report, Red Team -

October 10, 2018

Simulator/Control Room Player/Participant Logs from ERO 11/06/2019

Red Team Exercise

Comanche Peak Operation Support Center Records of 11/06/2019

Operating Logs, Activation Checklist, Shift Relief Worksheet,

Player Critique, Controller Logs, Radiological Monitoring

Data Sheets and Emergency Work Permits utilized during

the exercise

CFR Need to Clarify Impediments to Evacuation in EPP-304 3/15/2018

50.54(q)(3)

Effectiveness

Evaluation Form

CFR Protective Action Strategy Development Tool in EPP-304 11/29/2018

50.54(q)(3)

Effectiveness

Evaluation Form

CFR Protective Action Strategy Development Tool in EPP-304 11/29/2018

50.54(q)(3)

Inspection Type Designation Description or Title Revision or

Procedure Date

Screening

Evaluation Form

CFR Need to Clarify Impediments to Evacuation in EPP-304 3/15/2018

50.54(q)(3)

Screening

Evaluation Form

CPNPP EPP-201, Comanche Peak Nuclear Power Plant, EPP-201, 1/6/2017

EAL Tech Bases Emergency Action Level Technical Bases Document

Procedures Position Assistance Document for Shift Manager (Various 08/07/2019

Tasks dated 8/30/1996 - 8/7/2019)

Position Assistance Document for Control Room 05/27/2019

Communicator (Various Tasks dated 8/30/1996 - 5/21/2019)

Position Assistance Document for TSC OnRAC (Various 11/28/2018

Tasks dated 9/15/1997 - 11/28/2018)

Position Assistance Document for OSC RP Coordinator 08/07/2019

(Various Tasks dated 9/15/1997 - 8/7/2019)

EPP-109 Duties and Responsibilities of the Emergency 15

Coordinator/Recovery Manager

EPP-201 Assessment of Emergency Action Levels Emergency 13

Classification and Plan Activation

EPP-203 Notifications 16

EPP-309 Onsite/In-Plant Radiological Surveys and Offsite 14

Radiological Monitoring

ODA-102 Conduct of Operations 27

SG-021 Drill and Exercise Critique 24

71114.06 Miscellaneous LO44.BSS.012 ECCS Operations Simulator Exercise Guide 0

71114.08 Miscellaneous CP-201900530, Comanche Peak Nuclear Power Plant, Docket Nos. 50-445, 9/4/2019

TXX-19086 50-446, and 72-74; Transmittal of the Comanche Peak

Nuclear Power Plant Biennial Emergency Preparedness

Exercise Scenario

71151 Miscellaneous Comanche Peak Nuclear Power Plant, 2019 Quarterly ERO 3/26/2019

Tabletop

MSPI Indicator Margin Report for Units 1 and 2 2 for Printed

Residual Heat Removal and Cooling Water Systems. 19/9/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

LO47.A19.CLS Cycle 19-1 Cold Look Simulator Exercise Guide 4/17/2019

Simulator WANO EP Exercise January 2019 1/29/2019

Exercise Guide

EP37.TEX.XY1

Simulator Loss of All AC - FLEX 7/8/2019

Exercise Guide

LO44.FLX.001

Procedures SG-012 Alert and Notification System Surveillance 28

SG-020 NRC Performance Indicators 21

71152 Miscellaneous CPNPP System Status Matrix, Second

Quarter

2019

CR 2019-002428 Severity Level IV Violation of 10 CFR 55.25 from NRC IR NA

19-02

TR-2222-000000 Severity Level IV Violation of 10 CR 50.59 from NRC IR 18- NA

60855 Corrective Action CR/TR-YYYY- 2018-3292, 2018-5609, 2019-7406

Documents NNNN

Corrective Action CR/IR-YYYY- 2019-8208, 2019-8229, 2019-8268, 2019-8269,

Documents NNNN 2019-8282

Resulting from

Inspection

Procedures DCS-201 Transporting Loaded and Unloaded HI-STORM 8

Procedures DCS-202 MPC Preparation for Loading 7

Procedures DCS-203 MPC Handling and Fuel Loading Operations 8

Procedures DCS-204 MPC Closure Operations 8

Procedures DCS-205 Stack-Up and Transfer of Loaded MPC 8

Procedures DCS-206 Transporting and Transferring a Loaded MPC for Unloading 7

Procedures DCS-207 Unloading a Loaded MPC 7

Procedures GQP-9.2 High Temperature Liquid Penetrant Examination and 10

Acceptance Standards for Welds, Base Materials, and

Cladding

Procedures GQP-9.6 Visual Examination of Welds 18

Procedures NUC-212 Spent Fuel Limits for Dry Cask Operations 14

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures OPT-201A Operations Shiftily Routine Tests 15

Procedures PI-CNSTR-OP- Closure Welding of Holtec MPCs - HI-STORM 100, HI- 3

HLTC-01 STAR100, HI-STORM FW, &UMAX Systems

Procedures RFO-106 Development and Implementation of Fuel Shuffle Sequence 30

Plans

Procedures RFO-302 Handling of Fuel Assemblies 22

Procedures STA-421 Control of Issue Reports 21

Procedures STA-422 Corrective Action Program 34

Radiation 2017-GAM DATA TLD/OSLD Area Monitoring Results 04/09/2018

Surveys

Radiation 2018 GAM DATA TLD/OSLD Area Monitoring Results 07/25/2019

Surveys

Radiation 2019 First TLS/OSLD Area Monitoring Results 08/06/2019

Surveys Quarter GAM

DATA

Radiation M-20190917-17 VSDS Standard Map Survey Report 09/17/2019

Surveys

Self - EVAL-2018-005 CPNPP Nuclear Oversight Evaluation Report 02/26/2018

Assessments

Work Orders 6568906, 5624605, 5592172, 5566108, 5775553,

5798789, 5785574, 5585411

60857 Engineering LDCR DC-2018- Applicability Determination 07/11/2018

Changes 001

Engineering LDCR DC-2018- 72.48 Screen 08/14/2018

Changes 001

Engineering LDCR DC-2018- Applicability Determination 12/19/2018

Changes 002

Engineering STA-707 10 CFR 50.59 and 10 CFR 72.48 Reviews 21

Changes

Engineering STI-707.04 10 CFR 50.59 and 10 CFR 72.48 Reviews Applicability 1

Changes Determinations

19