IR 05000498/2013004
| ML13309B597 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/05/2013 |
| From: | Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A |
| To: | Koehl D South Texas |
| References | |
| IR-13-004 | |
| Download: ML13309B597 (35) | |
Text
UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON R E G IO N I V 1600 EAST LAMAR BLVD AR L I NGTON , TEXAS 7 601 1- 4511 November 5, 2013 Mr. Dennis Koehl President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Subject: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2013004 AND 05000499/2013004
Dear Mr. Koehl:
On September 28, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2. On October 3, 2013, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
No NRC-identified or self-revealing findings were identified during this inspection.
However, inspectors documented licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, 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, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2.
In accordance with Title 10 of the Code of Federal Regulations (10CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
-1- ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Wayne C. Walker, Chief Project Branch A Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80
Enclosure:
Inspection Report 05000498/2013004 and 05000499/2013004 w/ Attachment: Supplemental Information
REGION IV==
Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2013004 and 05000499/2013004 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: June 30 through September 28, 2013 Inspectors: G. Guerra, Emergency Preparedness Inspector J. Laughlin, Emergency Preparedness Inspector, NSIR A. Sanchez, Senior Resident Inspector D. You, Acting Resident Inspector Approved Wayne Walker, Chief By: Project Branch A Division of Reactor Projects-1- Enclosure
SUMMARY OF FINDINGS
IR 05000498/2013004, 05000499/2013004; 06/30/2013 - 09/28/2013; South Texas Project
Electric Generating Station, Units 1 and 2, Integrated Resident and Regional Report.
The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by a region-based inspector. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609,
Significance Determination Process. The cross-cutting aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
NRC-Identified Findings and Self-Revealing Findings
None
Licensee-Identified Violations
Violations of very low safety significance that were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
PLANT STATUS
Unit 1 began the inspection period at 100 percent reactor power. On August 3, 2013, the unit down powered to 80 percent reactor power due to a failed extraction steam line bellows in the condenser. On August 5, 2013, the unit returned to 100 percent reactor power following an engineering evaluation that determined there were no turbine blade loading issues stemming from the failed bellows. Upon further evaluation by engineering, the unit was again down powered to 86 percent reactor power on August 29, 2013, to ensure turbine blade loading was not outside design margin. The unit remained at 86 percent for the rest of the period.
Unit 2 began the inspection period at 100 percent reactor power. On September 28, 2013, the unit was down powered to 90 percent for main turbine governor valve testing. The unit was returned to 100 percent on September 29, 2013, and remained there for the rest of the period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
- August 7, 2013, Unit 1, train B auxiliary feedwater while train C auxiliary feedwater was out of service for planned maintenance
- August 26, 2013, Unit 1, emergency standby diesel generator 11 while emergency standby diesel generator 12 was out of service for planned maintenance
- August 28, 2013, Unit 1, train A component cooling water while train B component cooling water was out of service for planned maintenance
- September 20, 2013, Unit 1, train C electrical auxiliary building heating, ventilation, and air conditioning while train A was out of service for planned mechanical maintenance The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected while considering out of service time, inoperable or degraded conditions, recent system outages, and maintenance, modification, and testing. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, UFSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four partial system walkdown samples, as defined in Inspection Procedure 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Fire Inspection Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
- July 24, 2013, Unit 1, train C engineered safety feature switchgear room, Fire Zone Z052
- July 29, 2013, Unit 1, train D isolation valve cubicle pump room, Fire Zone Z400
- September 6, 2013, Unit 2, turbine generator building 4.16kV switchgear room, Fire Zone Z702
- September 20, 2013, Unit 1, train A electrical auxiliary building heating; ventilation; and air conditioning room, Fire Zone Z005
- September 20, 2013, Unit 1, train C electrical auxiliary building heating; ventilation; and air conditioning room, Fire Zone Z049 The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition; and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features. The inspectors also verified that minor issues identified during the inspection were entered into the licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five quarterly fire protection inspection samples, as defined in Inspection Procedure 71111.05-05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Quarterly Review of Licensed Operator Requalification Program
a. Inspection Scope
On September 2, 2013, the inspectors observed a crew of licensed operators in the plants simulator during requalification training. The inspectors assessed the following areas:
- Licensed operator performance
- The quality of the training provided
- The modeling and performance of the control room simulator
- The quality of post-scenario critiques
- Follow-up actions taken by the licensee These activities constitute completion of one quarterly licensed-operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Quarterly Observation of Licensed Operator Performance
a. Inspection Scope
On August 27, 2013, the inspectors observed the performance of on-shift licensed operators in the Unit 1 main control room. At the time of the observations, the plant was in a period of heightened activity due to a planned down power to 97.8 percent and a locked in rod control urgent alarm.
In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations shift operating practices and other operations department policies.
These activities constitute completion of one quarterly licensed-operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk-significant systems:
- July 24, 2013, Unit 2, rod control system
- August 12, 2013, Units 1 and 2, electrical auxiliary building roof drains
- September 27, 2013, Units 1 and 2, instrument air compressor system The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensees actions to address system performance or condition problems in terms of the following:
- Implementing appropriate work practices
- Identifying and addressing common cause failures
- Scoping of systems in accordance with 10 CFR 50.65(b)
- Characterizing system reliability issues for performance
- Charging unavailability for performance
- Trending key parameters for condition monitoring
- Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)
- Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were appropriately handled by a screening and identification process, and that issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed licensee personnels evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
- August 21, 2013, Unit 2, emergent maintenance to replace steam dump controller PK-0557 due to erratic performance while swapping from average temperature (Tave) mode to steam pressure mode
- September 2 through 6, 2013, Unit 1, planned activities for train C work week
- September 4, 2013, Unit 1, emergent maintenance on essential cooling water pump 1A to repair the self-cleaning strainer
- September 9 through 13, 2013, Unit 2, train C sequencer power replacement
- September 19 through 20, 2013, Unit 1, expanded maintenance scope on train A electrical auxiliary building heating, ventilation, and air conditioning system which extended maintenance window an extra day The inspectors selected these activities based on potential risk-significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensees probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk-assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed the following assessments:
- July 29, 2013, Unit 1, smoke from essential cooling water 1A motor
- August 14, 2013, Units 1 and 2, residual heat removal system operability concerns while calibrating pressure transmitters PT-405, PT-406, and PT-407
- August 25, 2013, Unit 1, loss of digital rod position indication B data
- September 4, 2013, Units 1 and 2, main feedwater temperature above upper limit of 440 degrees as stated in station Procedure 0POP03-ZG-0008, Power Operations, Revision 55
- September 27, 2013, Unit 1, slow buildup of discharge pressure of the 1B emergency cooling water pump due to system leakage when train is not in operation The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems along with other factors, such as engineering analysis and judgment; operating experience; and performance history. The inspectors evaluated the technical adequacy of the evaluations to ensure technical specification operability was properly justified and to verify the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled.
Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five operability evaluations inspection samples, as defined in Inspection Procedure 71111.15-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:
- July 4, 2013, Unit 2, steam generator 2A power operated relief valve potentiometer replacement
- August 21, 2013, Unit 2, troubleshooting and replacement of steam dump controller PK-0557
- August 22, 2013, Unit 1, main steam isolation bypass valve power supply replacement
- September 4, 2013, Unit 1, essential cooling water pump 1A repair of the self-cleaning strainer
- September 9, 2013, Unit 2, train C engineered safety feature load sequencer power supply replacement The inspectors selected these activities based upon the structure, system, or components ability to affect risk. The inspectors evaluated these activities for the following (as applicable):
- The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed
- Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors selected risk-significant surveillance activities based on risk information and reviewed the UFSAR, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:
- Preconditioning
- Evaluation of testing impact on the plant
- Acceptance criteria
- Test equipment
- Procedures
- Jumper/lifted lead controls
- Test data
- Testing frequency and method demonstrated technical specification operability
- Test equipment removal
- Restoration of plant systems
- Fulfillment of ASME Code requirements
- Updating of performance indicator data
- Engineering evaluations, root causes, and bases for returning tested systems; structures; and components not meeting the test acceptance criteria were correct
- Reference setting data
- Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.
- July 23, 2013, Unit 1, high-head safety injection pump 1A to hot leg motor operated valve functional test and inspection
- August 6, 2013, Unit 2, standby diesel generator 22 surveillance test
- August 22, 2013, Unit 2, auxiliary feedwater pump 14 in-service test
- August 22, 2013, Unit 2, calibration surveillance of the control rod speed loop
- September 13, 2013, Unit 2, solid state protection system train C quarterly slave relay test Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22-05.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
The inspector discussed with licensee staff the operability of off-site emergency warning systems and backup alerting methods to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensees alert and notification system testing program was compared with the following:
- NUREG-0654, A Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Revision 1)
- FEMA Report REP-10, A Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants The FEMA-approved design for the licensees alert and notification system is addressed in the following document:
- South Texas Project Electric Generating Station Updated Prompt Notification System Design Report, dated September 30, 2010 The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one alert and notification system evaluation sample, as defined in Inspection Procedure 71114.02-06.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation
a. Inspection Scope
The inspector discussed with licensee staff the operability of primary and backup systems for augmenting on-shift staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan and the requirements of 10 CFR Part 50, Appendix E, including provisions for staffing alternate or backup facilities. The inspector also reviewed licensee training on augmentation procedures, augmentation system testing programs, and selected entries in the licensee corrective action system related to emergency response facility staffing. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one emergency response organization staffing and augmentation sample, as defined in Inspection Procedure 71114.03-06.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)
a. Inspection Scope
The Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various emergency plan implementing procedures and the Emergency Plan located under ADAMS Accession Number ML13239A440, as listed in the attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the plan, and that the revised plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-06.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspector reviewed the licensees corrective action program requirements as stated in station procedures. The inspector reviewed summaries of corrective action program documents assigned to the emergency preparedness department and emergency response organization between May 2011 and June 2013, and selected 37 for detailed review against the program requirements. The inspector evaluated the response to the corrective action requests to determine the licensees ability to identify, evaluate, and correct problems in accordance with the licensee program requirements; planning standard 10 CFR 50.47(b)(14); and 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.
The inspector also reviewed:
- Licensee audits, assessments, drill evaluations, and post-event after action reports conducted between May 2011 and June 2013
- Memorandum of Understanding between the licensee and off-site agencies and organizations relied upon to support site emergency response efforts
- Procedures for equipment relied upon to support site emergency response efforts These activities constitute completion of one maintenance of emergency preparedness sample, as defined in Inspection Procedure 71114.05-06.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated the conduct of a routine licensee emergency drill on July 31, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the control room simulator and technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-06.
b. Findings
No findings were identified.
.2 Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on September 10, 2013, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.
These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06-06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the licensee for the second quarter 2013 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.
The emergency preparedness inspector reviewed data submitted by the licensee for the second quarter 2012, third quarter 2012, fourth quarter 2012, and first quarter 2013 performance indicators to identify any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.
b. Findings
No findings were identified.
.2 Safety System Functional Failures (MS05)
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures performance indicator for Units 1 and 2 for the period from the second quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73. The inspectors reviewed the licensees operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of April 2012 through July 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of two safety system functional failures samples, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors sampled licensee submittals for the reactor coolant system specific activity performance for Units 1 and 2 for the period from the second quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees reactor coolant system chemistry samples, technical specification requirements, issue reports, event reports, and NRC integrated inspection reports for the period of April 2012 through July 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. In addition to record reviews, the inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of two reactor coolant system specific activity samples, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.4 Reactor Coolant System Leakage (BI02)
a. Inspection Scope
The inspectors sampled licensee submittals for the reactor coolant system leakage performance indicator for Units 1 and 2 for the period from the second quarter 2012 through the second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator logs, reactor coolant system leakage tracking data, issue reports, event reports, and NRC integrated inspection reports for the period of April 2012 through July 2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.
Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of two reactor coolant system leakage samples, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.5 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors sampled licensee submittals for the drill/exercise performance performance indicator for the period from the second quarter 2012 through the first quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions; performance during the 2012 biennial exercise; and performance during other drills. The specific documents reviewed are described in the attachment to this report.
These activities constitute completion of the drill/exercise performance sample, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.6 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors sampled licensee submittals for the emergency response organization drill participation performance indicator for the period from the second quarter 2012 through the first quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; rosters of personnel assigned to key emergency response organization positions; and exercise participation records.
The specific documents reviewed are described in the attachment to this report.
These activities constitute completion of the emergency response organization drill participation sample, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.7 Alert and Notification System (EP03)
a. Inspection Scope
The inspectors sampled licensee submittals for the alert and notification system performance indicator for the period from the second quarter 2012 through the first quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, were used. The inspectors reviewed the licensees records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests. The specific documents reviewed are described in the attachment to this report.
These activities constitute completion of the alert and notification system sample, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensees corrective action program because of the inspectors observations are included in the attached list of documents reviewed.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees corrective action program. The inspectors accomplished this through review of the stations daily corrective action documents.
The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
4OA3 Followup of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000498/2013-001-00 and -01, Delta Temperature/
T-Average Channel A Inoperable for Longer than Allowed by Technical Specifications On May 1, 2013, with Unit 1 in Mode 1 at 100 percent power, maintenance personnel discovered that channel A overpower delta temperature reactor trip setpoint delta-flux penalty summing amplifier had failed low, effectively disabling the associated overpower delta temperature setpoint correction, which resulted in the delta temperature/ T-average channel A being inoperable. Investigation determined that there was evidence that the failure had occurred on April 17, 2013, thus rendering the channel inoperable for longer than Technical Specifications 3.3.1 and 3.3.2, Reactor Trip System Instrumentation, and Engineered Safety Features Actuation System Instrumentation, which is to trip the channel within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or shut down the unit within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee determined that the failure of the channel was due to a random card failure, however, operations staff failed to identify the issue because of inadequate procedural guidance in station Procedure 0PSP03-ZQ-0028, Operator Logs, Revision 131, in which the acceptance criteria for channel checks was not accurate enough to detect a degraded or failed condition. The licensee took immediate corrective actions to replace the faulted circuit card, and is scheduled to complete corrective actions to modify the procedure by the end of October 2013. This condition was placed into the corrective action program as Condition Report 13-5396. See Section 4OA7 for the enforcement aspects of this licensee event report. This licensee event report is closed.
.2 (Closed) Licensee Event Report 05000498/2013-002-00, Steam Turbine-Driven Auxiliary
Feedwater Pump Flow Regulating Valve Inoperable for Longer than Allowed by Technical Specifications On May 20, 2013, with Unit 1 in Mode 1 at 100 percent power, the auxiliary feedwater flow loop 4 channel D high limit was found low out of tolerance during the performance of a scheduled surveillance. This condition resulted in the flow control valve for the steam turbine-driven auxiliary feedwater pump not being capable of providing required flow to its respective steam generator under all accident conditions, thus making the pump and flow regulating valve inoperable. Subsequently, it was determined that this condition had existed since December 14, 2012, during an earlier troubleshooting activity. The affected components were inoperable for a period longer than permitted by Technical Specification 3.7.1.2. In addition, with the steam turbine-driven auxiliary feedwater pump considered inoperable, Technical Specification 3.8.1.1, Action d., to verify that the steam-driven auxiliary feedwater pump is operable with one standby diesel generator inoperable could not be met. The steam turbine-driven auxiliary feedwater pump and regulating valve were returned to operable status on May 21, 2013. See Section 4OA7 for the enforcement aspects of this licensee event report. This licensee event report is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On June 27, 2013, the inspector presented the onsite emergency preparedness inspection results to Mr. D. Koehl, President and Chief Executive Officer, and other members of the licensees staff. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On October 3, 2013, the inspectors presented the inspection results to Mr. D. Koehl, President and Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
4OA7 Licensee-Identified Violations
The following violations of very low safety significance (Green) were identified by the licensee and are violations of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as non-cited violations.
- Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifically Section 1, Administrative Procedures, part h, Log Entries. Contrary to the above, operators used acceptance criteria for channel checks contained in station Procedure 0PSP03-ZQ-0028, Operator Logs, Revision 131, that was not accurate enough to detect a degraded or failed channel of overpower delta temperature.
Specifically, the operators failed to identify a failed circuit board that led to a nonconservative step change in the overpower delta temperature channel A for actuation. The inspectors used Manual Chapter 0609, Appendix A, to determine that the finding was of very low safety significance because it did not affect a single reactor protection channel and the function of other redundant trip or diverse methods of reactor shutdown; did not involve control manipulations that unintentionally added positive reactivity; and did not result in a mismanagement of reactivity by operators.
The licensee entered this issue into the corrective action program as Condition Report 13-5396.
- Technical Specification 6.8.1.a requires, in part, that written procedures shall be established; implemented; and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, specifically Section 9, Procedures for Performing Maintenance, part a. Contrary to the above, on December 15, 2013, maintenance personnel incorrectly configured the replacement circuit boards for the qualified display processing system. A combination of poorly written maintenance procedures (contained in work order 522613 and 0PGP03-ZM-0025A, Post-Maintenance Testing Implementation, Revision 4) and inadequately trained personnel led to the flow control HI LIMIT value on the replacement cards to be set to 0.0 gpm when it should have been set at 35 gpm. This error was discovered in a surveillance performed on May 5, 2013. This could have led to the failure of the feed regulating valves motor due to exceeding the motors duty cycle time, thereby reducing the feedwater flow below its required flow rate as specified in the technical specifications. The inspectors discussed this with a senior reactor analyst and used Manual Chapter 0609, Appendix A, to determine that the finding was of very low safety significance (Green) because the finding did not contribute to the loss of mitigation equipment. The licensee entered this issue into the corrective action program as Condition Report 13-6145.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Aguilera, Manager, Health Physics
- M. Berg, Manager, Design Engineering
- C. Bowman, General Manager, Engineering
- R. Dunn Jr., Manager, Nuclear Fuel and Analysis
- J. Enoch, Supervisor, Emergency Preparedness
- T. Frawley, Manager, Strategic Business Projects
- J. Hartley, Manager, Mechanical Maintenance
- G. Hildebrandt, Manager, Operations
- G. Janak, Manager, Unit 1 Operations
- B. Jenewein, Manager, Systems Engineering
- J. Lovejoy, Manager, I&C Maintenance
- B. Migl, Manager, Maintenance Engineering (Acting)
- J. Milliff, Manager, Unit 2 Operations
- M. Murray, Manager, Regulatory Affairs
- J. Paul, Supervisor, Licensing
- L. Peter, Plant General Manager
- G. Powell, Site Vice President
- C. Reddix, Manager, Security
- M. Ruvalcaba, Manager, Testing and Programs
- R. Savage, Engineer, Licensing Staff Specialist
- M. Schaefer, Manager, Nuclear Oversight
- R. Stastny, Maintenance Manager
- T. Walker, Manager, Quality Assurance
- K. Wallis, Supervising Engineering Specialist
- D. Zink, Supervising Engineering Specialist
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
Delta Temperature/ T-Average Channel A Inoperable for
- 05000498/2013-001-00, LER Longer than Allowed by Technical Specifications
- 05000498/2013-001-01 (Section 4OA3.1)
Steam Turbine-Driven Auxiliary Feedwater Pump Flow
- 05000498/2013-002-00 LER Regulating Valve Inoperable for Longer than Allowed by Technical Specifications (Section 4OA3.2)