IR 05000498/2014004
| ML14314B041 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/10/2014 |
| From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
| To: | Koehl D South Texas |
| O'Keefe N | |
| References | |
| IR 2014004 | |
| Download: ML14314B041 (32) | |
Text
UNITED STATES ber 10, 2014
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2014004 AND 05000499/2014004
Dear Mr. Koehl:
On October 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On October 9, 2014, the NRC inspectors discussed the results of this inspection with Mr. A. Capristo, Executive Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. Further, inspectors documented licensee-identified violations which were determined to be of very low safety significance. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, 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, facility.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Regional Administrator, Region IV; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/ David Proulx for Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80
Enclosure:
Inspection Report 05000498/2014004 and 05000499/2014004 w/ Attachment 1: Supplemental Information
REGION IV==
Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2014004 and 05000499/2014004 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: July 5 through October 3, 2014 Inspectors: A. Sanchez, Senior Resident Inspector N. Hernandez, Resident Inspector B. Correll, Reactor Inspector G. Guerra, CHP, Emergency Preparedness Inspector D. Proulx, Senior Project Engineer Approved Neil OKeefe By: Chief, Project Branch B Division of Reactor Projects-1- Enclosure
SUMMARY
IR 05000498/2014004, 05000499/2014004; 07/05/2014 - 10/03/2014; South Texas Project
Electric Generating Station, Units 1 and 2, Problem Identification and Resolution.
The inspection activities described in this report were performed between July 5 and October 3, 2014, by the resident inspectors at the South Texas Project and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, involving the licensees failure to promptly identify and correct a condition adverse to quality. Specifically, following the identification of general corrosion on the Units 1 and 2 control room envelope heating, ventilation, and air conditioning ducts, the licensee failed to identify that moisture condensing and collecting was a condition adverse to quality and failed to correct the condition. As a result, corrosion caused through-wall leaks in 2008 and 2014. The licensee entered this into the corrective action program as Condition Report 14-17723, and planned to evaluate and address the issue.
The failure to promptly identify and correct a condition adverse to quality is a performance deficiency. The performance deficiency was more than minor because it is associated with the barrier performance attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective. Using NRC Inspection Manual Chapter 0609, Appendix A,
Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with evaluation, because the licensee failed to thoroughly evaluate the issue to ensure that the resolution addressed the cause of extent of condition commensurate with the safety significance [P2]. (Section 4OA2)
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
Units 1 and 2 operated at 100 percent power for the entire inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On August 28 through 29, 2014, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions associated with Tropical Disturbance 22. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees preparedness to implement these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
The inspectors also walked down the essential cooling water intake structure and the 345kV switchyard.
These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- August 27, 2014, Unit 2, train B emergency diesel generator while train A emergency diesel generator was out of service
- September 10, 2014, Unit 2, trains B and C essential cooling water system while train A essential cooling water was out of service for maintenance The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the system. They visually verified that critical portions of the trains and systems were correctly aligned for the existing plant configuration.
These activities constituted two partial system walk-down samples, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:
- September 9, 2014, Unit 1, electrical auxiliary building engineered safety features switchgear room train A, Fire Zone Z004
- September 9, 2014, Unit 1, electrical auxiliary building emergency switchgear area, Fire Zone Z029
- September 9, 2014, Unit 1, electrical auxiliary building emergency switchgear room train B, Fire Zone Z042
- September 9, 2014, Unit 1, auxiliary shutdown area, Fire Zone Z071
- September 11, 2014, Unit 1, electrical auxiliary building channel I distribution room, Fire Zone Z003
- September 11, 2014, Unit 2, electrical auxiliary building channel II battery room, Fire Zone Z002 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
.2 Annual Inspection
a. Inspection Scope
On September 23, 2014, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of two fire drills:
- February 27, 2014, unannounced drill
- September 23, 2014, unannounced drill During these drills, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.
These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On September 28, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components (SSCs) that were susceptible to flooding:
- Unit 1, trains A through D of the isolation valve cubicles The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
In addition, on April 21 through April 23, 2014, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected five underground manholes that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:
- Manhole: B0XYAEKEM50
- Manhole: C0XYAEKEM50
- Manhole: B0XYABKEN51
- Manhole: C0XYABKEN51
- Manhole: A0XYABKEM51 The inspectors observed the material condition of the manhole covers, looked for evidence of seal degradation, and observed the licensee take water level measurements. Water levels in each vault were such that none of the cables were submerged and that the rate of water intrusion was acceptable and would be detected within periodic inspection intervals. The inspectors verified that the cables and vaults met design requirements.
These activities constitute completion of one flood protection measures sample and one bunker/manhole sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On August 25, 2014, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.
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 Review of Licensed Operator Performance
a. Inspection Scope
On September 22, 2014, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to a large number of maintenance activities. The inspectors observed the operators performance of the following activities:
- Reactivity manipulation, including the pre-job brief
- Adjusting the main turbine load set point
- Authorizing multiple equipment clearance orders in preparation for maintenance activities In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure 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 reviewed four instances of degraded performance or condition of safety-related SSCs:
- July 15, 2014, Unit 1, train C emergency diesel generator, the diesel failure to run during calibrations following replacement of the governor
- August 4, 2014, Unit 2, train A auxiliary feedwater pump corrective maintenance on containment isolation valve MOV-48 to repair a leaking motor shaft seal
- August 13, 2014, Unit 1, train A emergency diesel generator surveillance failure due to failure of a pressure regulator
- October 3, 2014, periodic assessment of the effectiveness of Maintenance Rule activities October 2012 through January 2014 The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of four maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors observed portions of six emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:
- July 15, 2014, Unit 1, emergent out-of-service time due to human performance issues during post-maintenance testing of the train C emergency diesel generator
- Week of August 4, 2014, Unit 2, emergent work to repair a leaking motor shaft seal on the train A auxiliary feedwater pump containment isolation valve MOV-48
- Week of August 25, 2014, Unit 1, emergent work to repair a failed pump seal on the train B high head safety injection pump
- Week of September 15, 2014, Unit 1, emergent work to replace traveling screens on the train A essential cooling water
- September 19, 2014, Unit 1, emergent work to restore uninterruptable power to the train C, 120 VAC vital distribution panel DP-002
- September 29, 2014, Unit 1, emergent work activity that increased in the length of out-of-service time for instrument air compressor 13 maintenance The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.
The inspectors also reviewed the licensees actions for implementing the Configuration Risk Management Program for exceeding allowed outage time for the following emergent issues listed above: 1) Technical Specification 3.5.2, train B emergency core cooling system to replace the high head safety injection pump seal; and 2) Technical Specification 3.8.3.1, train C vital power to distribution panel DP-002.
These activities constitute completion of six maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed two operability determinations and one functionality assessment that the licensee performed for degraded or nonconforming SSCs:
- July 17, 2014, functionality assessment of the Unit 1 and Unit 2 fire water system following a break of underground piping
- August 6, 2014, operability determination of Unit 1, train B emergency diesel generator due an out-of-calibration lube oil system thermostat
- September 9, 2014, operability determination of Unit 1, train A essential cooling water pump due to increased seal leakage The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constitute completion of three operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed five post-maintenance testing activities that affected risk-significant SSCs:
- July 10, 2014, Unit 1, train C emergency diesel generator following governor speed control circuit replacement
- July 30, 2014, Unit 2, train A auxiliary feedwater pump containment isolation valve MOV-48 following valve motor replacement
- August 7, 2014, Unit 1, train B high head safety injection pump following emergent seal package replacement
- August 31, 2014, Unit 1, train A qualified display processing system following replacement of a failed power supply
- September 17, 2014, Unit 1, train A fuel handling building emergency exhaust system following emergent repair of heating, ventilation, and air conditioning exhaust heater The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed five risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:
In-service tests:
- August 14, 2014, Unit 2, centrifugal charging pump 2A
- August 21, 2014, Unit 2, train D turbine-driven auxiliary feedwater pump Reactor coolant system leak detection tests:
- September 19, 2014, Unit 1, reactor coolant inventory leak rate Other surveillance tests:
- July 22, 2014, Unit 2, component cooling water valve MOV-403 stroke time test
- August 23, 2014, Unit 2, train R reactor trip breaker operational test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of five surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspector performed an in-office review of changes to South Texas Project Electric Generating Station, Units 1 and 2, Emergency Plan, Interim Change Notice (ICN) 20-15, letter dated June 12, 2014, and ICN 20-16, letter dated July 2, 2014. ICN 20-15, effective May 29, 2014, documents a new service provider for the emergency alert system for activation of the alert radios and other editorial changes. ICN 20-16, effective June 16, 2014, documents changes to integrate hostile action based events; the Incident/Unified Command System; and the change to an 8-year planning cycle for exercises.
These revisions were compared to previous revisions, to the criteria of NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revisions did not reduce the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection.
These activities constitute completion of two emergency action level and emergency plan change samples, as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on August 13, 2014, to verify the adequacy and capability of the licensees assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the control room simulator, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.
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 Mitigating Systems Performance Index: Emergency AC Power Systems (MS06)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for emergency ac power systems for Unit 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Mitigating Systems Performance Index: High Pressure Injection Systems (MS07)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for high pressure injection systems for Unit 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index: Heat Removal Systems (MS08)
a. Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the period of July 2013 through June 2014 to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for heat removal systems for Unit 2, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
To verify that the licensee was taking corrective actions to address identified adverse trends that might indicate the existence of a more significant safety issue, the inspectors reviewed corrective action program documentation associated with the following licensee-identified trends:
- Fire watch implementation: an increasing number of issues during the Unit 1 spring 2014 refueling outage in which a higher number of fire watches were established without a corresponding increase in fire watch personnel that led to a number of condition reports that questioned quality and thoroughness of fire watch inspections
- Qualified Display Processing System reliability issues due to repeated component and power supply issues
- Radiation work practices: increased personnel contamination events Also, the inspectors identified the following trends that might indicate the existence of a more significant safety issue, and reviewed the licensees response to them:
- Lack of licensee oversight of work activities in the switchyard, especially with the use of heavy equipment and housekeeping (missile hazards)
- Licensed reactor operator requalification examination quality and evaluation, specifically with respect to technical specification testing, critical task development, and evaluation of operator knowledge following exam scenarios These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Observations and Assessments The inspectors review of the trends identified above produced the following observations and assessments:
- Fire watch implementation: the licensee has written a number of condition reports and has taken action to improve communication concerning fire watch procedural and expectation changes, better plan for the expected increase in required fire watch work load during outages and planned maintenance activities.
- Qualified Display Processing System reliability issues: the licensee has written Condition Report 14-17026 to evaluate the purchase and installation of a new fault-tolerant system due to age and obsolescence issues that are resulting in declining system reliability.
- Radiation work practices: Recently, the licensee and resident inspectors have observed radiation workers not practicing appropriate radiation worker behaviors.
The licensee documented the issue in Condition Report 14-13555. The licensee also wrote Condition Report 14-14595, which determined that site supervision does not adequately observe and coach radiation workers on appropriate contamination control practices. The licensee planned to implement dynamic learning activities to illustrate the incorrect behaviors, perform focused observations, encourage and hold supervisors more accountable for their areas of responsibility, and stop work when any workers are not meeting procedural guidance or site expectations.
Also, while completing this trend review, the inspectors identified the following trends that the licensee had not previously identified and that might indicate the existence of a more significant safety issue. The inspectors also reviewed the licensees response to these trends:
- Oversight during work activities in switchyard: The licensee has entered the issue into the corrective action program as Condition Report 14-16444. The licensee planned to improve oversight to minimize the potential for loss-of-offsite power due to heavy equipment miscues or missile hazards created as a result of work activities in the switchyard.
- Licensed reactor operator requalification examination quality: The licensee entered this issue into the corrective action program as Condition Report 14-17889. The licensee was investigating this issue and planned to strengthen procedural guidance for the development of simulator examinations and provide more supervisory oversight over the scenario evaluation process.
The inspectors did not review any cross-cutting theme because no cross-cutting theme exists at the site.
c. Findings
No findings were identified.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected four issues for an in-depth follow-up:
- From April 11 to June 19, 2014, during Refueling Outage 1RE18, hourly fire watch rounds were not performed in accordance with procedure.
The inspectors assessed the licensees condition reports associated with the dates of concern, and evaluated the compensatory actions taken to address the deficiency. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were adequate to correct the condition.
The finding is described below.
- On April 24, 2014, a through-wall corrosion crack was discovered on Unit 1, train B control room envelope heating, ventilation, and air conditioning system upstream of an outside air supply isolation damper, and documented in Condition Report 14-7985.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory and corrective actions to address the deficiency. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were adequate to correct the condition. The violation is described below.
- On May 1, 2014, Unit 1 reactor operators inadvertently exceeded the pressurizer cool-down and heat-up rate limits in the Technical Requirements Manual 3.4.9.2 while establishing hydrogen cover gas on the volume control tank. An engineering evaluation was performed to ensure pressurizer operability and was reviewed by inspectors and documented in NRC Inspection Report 05000498; 05000499/2014003.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory and corrective actions to address the deficiency. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were adequate to correct the condition.
- On October 29, 2013 while performing a surveillance on Unit 1 reactor coolant system flow loop, instrumentation and calibration technicians bypassed the train A flow loop instead of the train B flow loop, which was already declared inoperable. This resulted in an unplanned entry into Technical Specification 3.0.3 for 29 minutes.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews, and compensatory and corrective actions to address the deficiency. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were adequate to correct the condition.
These activities constitute completion of four annual follow-up samples as defined in Inspection Procedure 71152.
b. Findings
Introduction:
The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, involving the licensees failure to promptly identify and correct a condition adverse to quality. Specifically, following the identification of general corrosion on the Units 1 and 2 control room envelope heating, ventilation, and air conditioning ducts, the licensee failed to identify that moisture was condensing and collecting was a condition adverse to quality and correct the condition.
The licensee entered this into the corrective action program as Condition Report 14-17723.
Description:
On two occasions, the licensee discovered through-wall corrosion on a control room envelope boundary ventilation ductwork, but failed to identify the cause of the corrosion.
- On October 21, 2008, while operating at full power, a general corrosion breach was found on Unit 2, train B control room heating, ventilation, and air conditioning normal outside air makeup duct, and documented in Condition Report 08-16140.
The hole was repaired during a refueling outage, but an extent of condition review and a cause evaluation were not performed.
- On April 24, 2014, during a refueling outage, another through-wall corrosion crack was found on Unit 1, train B control room envelope heating, ventilation, and air conditioning duct upstream of an outside air supply isolation damper and was documented in Condition Report 14-7985. The hole was repaired, an extent of condition review was performed, but again, a cause evaluation was not performed.
The inspectors noted that the affected ducts formed part of the control room ventilation boundary needed to minimize operator dose during an accident. Allowing moisture to continue build-up in these ducts could be reasonably expected to continue to cause corrosion and through-wall holes. Because of the design of the system, such holes had the potential to increase control room in-leakage and increase operator dose during an accident. Based on this impact, the inspectors concluded that the continued moisture build-up constituted a condition adverse to quality.
During the extent of condition review on April 25, 2014, with Unit 1 in a refueling outage and Unit 2 at 100 percent power, additional through-wall holes were found in: Unit 1, train A control room outside air makeup duct; Unit 1, train C control room outside air makeup duct; and on Unit 2, train C control room heating, ventilation, and air conditioning outside air duct. These issues were documented in Condition Reports 14-8021, 14-8022, and 14-8012, respectively. Unit 2 entered Technical Specification 3.7.7 and subsequently declared train B operable but degraded. These three condition reports were categorized in accordance with the site corrective action program per Procedure 0PGP03-ZX-0002, Condition Reporting Process, Revision 48, and did not receive cause evaluations.
The inspectors reviewed the issue, condition reports, site procedures, and interviewed system engineers, and identified that the licensee failed to identify that moisture that was condensing and collecting in the corroded locations was a condition adverse to quality and thus failed to correct the condition. The inspectors also reviewed the Maintenance Rule application to this system and determined that the system is not treated as a run to failure system.
Analysis:
The failure to promptly identify and correct a condition adverse to quality is a performance deficiency. Specifically, following the identification of general corrosion on the Units 1 and 2 control room envelope heating, ventilation, and air conditioning ducts, the licensee failed to identify that condensed moisture was condensing and collecting was a condition adverse to quality and correct the condition. The performance deficiency was more than minor because it is associated with the barrier performance attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective.
Specifically, the licensees failure to identify and correct the cause of corrosion in the control room heating, ventilation, and air conditioning ductwork challenged the ability to maintain the radiological barrier functionality of the control room, thereby affecting the cornerstone objective to provide reasonable assurance that physical design barriers protect control room operators from radionuclide releases caused by accidents or events. Using NRC Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution associated with evaluation, because the licensee failed to thoroughly evaluate the issue to ensure that the resolution addressed the cause of extent of condition commensurate with the safety significance. Specifically, the licensee failed to thoroughly evaluate condition reports for general corrosion occurring on more than one occasion and in both units for a cause and long term corrective actions commensurate with the safety significance (P2).
Enforcement:
Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, a condition adverse to quality was not promptly identified and corrected. Specifically, as of April 24, 2014, the licensee failed to identify that moisture was condensing and collecting, leading to through-wall corrosion in the control room boundary was a condition adverse to quality and correct the condition.
The licensee planned to evaluate and correct the moisture build-up. Because this finding was of very low safety significance and was entered into the corrective action program as Condition Report 14-17723, it is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000498/2014004-01 and 05000499/2014-01, Failure to Identify a Condition Adverse to Quality for the Control Room Envelope.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report 05000499/2013-004-01, Manual Actuation of Main
Steam Isolation Valves that was Not Part of a Preplanned Sequence During Testing or Reactor Operation On December 19, 2013, while in Mode 3 preparing the Unit 2 secondary plant for startup, a failure of the non-safety main turbine bearing oil lift piping occurred, preventing placing the turbine on the turning gear. After approximately 30 minutes with no turbine rotation, efforts to place the main turbine back on the turning gear had failed, so the associated annunciator response station Procedure 0POP09-AN-07M3, Annunciator Lampbox 1(2)-7M03 Response Instruction, Revision 73, guided operators to secure main condenser vacuum and turbine gland seal steam to minimize turbine rotor bowing.
Station Procedure 0POP04-ZO-0003, Secondary Plant Stabilization, Revision 15, directed operators to secure main condenser vacuum and turbine gland seal steam, and to ensure main steam isolation valves and main steam bypass valves are closed, but did not state how to close these valves. Control room operators elected to actuate a main steam isolation switch to ensure these valves were closed as quickly as possible.
Pursuant to 10 CFR 50.73(a)(2)(iv)(A), any event or condition that resulted in the valid manual or automatic actuation of any of the systems listed in paragraph (a)(2)(iv)(B) that was not part of a pre-planned sequence during testing or reactor operation is a reportable event. This event was entered into the stations corrective action program as Condition Report 13-15624, a licensee event report was submitted, and an apparent cause evaluation was performed.
Inspectors reviewed the licensee event report and apparent cause evaluation.
The inspectors also reviewed the plant conditions, alarm response and off-normal procedures, interviewed operators, and observed a simulator demonstration. No findings or violations of NRC requirements were identified.
This licensee event report is closed.
2. (Closed) Violation 05000499/2014007-01, Failure to Accurately Document Completion
of a Maintenance Activity On November 7, 2011, the licensee failed to maintain records required by Technical Specification 6.8.1.a and 10 CFR Part 50, Appendix B, Criterion XVII, that were complete and accurate in all material respects. Specifically, a maintenance supervisor falsified the signature of a maintenance craft worker for torqueing Unit 2 pressurizer spray valve PCV-0655B body-to-bonnet fasteners, a quality activity that could affect safety-related equipment, in Unit 2 Work Order WAN 406103, step 5.9.2, when this activity had not been performed. This finding was evaluated under traditional enforcement due to the NRCs conclusion that it was a deliberate violation that impacted the NRCs ability to perform its regulatory function, and was determined to be a Severity Level IV violation. This violation had no actual safety consequences. Although valve PCV-0655B was later determined to be leaking, the leak was not a result of the failure to perform a hot torque of the body-to-bonnet fasteners. The licensee took significant administrative action to address this violation. In addition, the licensee determined the apparent causes of the valve leakage and repaired valve PCV-0655B.
Thus, this violation did not require a response.
The inspectors reviewed the completed package for Condition Report 12-25979 and the associated apparent cause evaluation, as well as the corrective actions. The inspectors reviewed the licensees closed employee concerns file and verified completion of the licensees evaluation. In addition, the inspectors observed the licensees remote monitoring (video camera) of the condition of valve PCV-655B, and noted that no body-to-bonnet leakage existed. Thus, the inspectors concluded that the licensee took satisfactory action to address the violation.
This violation is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On September 25, 2014, the inspector conducted an exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan and implementing procedures to Mr. M. Crain, Manager, Emergency Response, and other members of the licensee staff. The licensee acknowledged the issues presented.
On October 9, 2014, the inspectors presented the resident inspection results to Mr. A. Capristo, Executive Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
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 6.12.1 states, in part, Pursuant to 10 CFR 20.1601(c), in lieu of the requirements of 20.1601(a), each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is greater than 100 mrem/h but equal to or less than 1000 mrem/h at 30 cm (12 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by a Radiation Work Permit (RWP).
Contrary to the above, on April 11, 2014, the licensee failed to barricade and conspicuously post a high radiation area. Specifically, a radiation protection technician identified that room 201 of the Unit 1 reactor containment building, a high radiation area with measured dose rates as high as 160 mrem/hr, was not barricaded or posted as a high radiation area. The licensee inadvertently removed the high radiation area posting when demobilizing for outage activities. The failure to properly post a high radiation area was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process attribute and adversely affected the Occupational Radiation Safety Cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear power operation. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, inspectors determined that the finding was of very low safety significance (Green) because it did not represent an ALARA planning or work controls, did not represent a substantial potential for nor did it actually result in an overexposure, and did not compromise the ability to assess dose. This issue was entered into the corrective action program as Condition Report 14-7222.
- Title 10 CFR Part 50, Appendix B, Criteria XVI states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, nonconformances are promptly identified and corrected. Contrary to the above, although the licensee promptly identified a condition adverse to quality, the licensee failed to correct that condition. Specifically, the licensee failed to repair a 5 drop-per-minute jacket water leak on emergency diesel generator 12 jacket water flange connection on March 3, 2013, which rapidly increased to 5 gallons per minute during a surveillance run on March 11, 2014. The failure to take timely corrective actions to resolve a condition adverse to quality was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute and affected the Mitigating Systems Cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings at Power, dated July 1, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding did not 1) affect the design or qualification of a mitigating SSC; 2) did not represent a loss of system or function; 3) did not represent an actual loss of function of at least a single train for greater that its technical specification allowed outage time; and 4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as a high safety-significant in accordance with the licensees Maintenance Rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This issue was entered into the corrective action program as Condition Report 14-4762.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Aguilera, Manager, Health Physics
- J. Atkins, Manager, Systems Engineering
- M. Berg, Manager, Design Engineering/Testing and Programs
- C. Bowman, Manager, Nuclear Oversight
- A. Capristo, Executive Vice President and Chief Administrative Officer
- R. Cink, Staff Investigator, Employee Concerns Program
- R. Dunn Jr., Manager, Nuclear Fuel and Analysis
- T. Frawley, Manager, Plant Protection/Emergency Response
- R. Gibbs, Acting Manager, Operations Division - Production Support
- J. Hartley, Manager, Mechanical Maintenance
- G. Hildebrandt, Manager, Operations
- G. Janak, Operations Training Manager
- J. Lovejoy, Manager, I&C Maintenance
- R. McNeil, Manager, Maintenance Engineering
- J. Milliff, Manager, Security
- M. Murray, Manager, Regulatory Affairs
- L. Peter, General Manager, Projects
- J. Pierce, Manager, Operations Division - Integrated Work Management & Outage
- G. Powell, Site Vice President
- M. Ruvalcaba, Manager, Strategic Projects
- R. Savage, Engineer, Licensing Staff Specialist
- R. Scarborough, Manager, Quality Assurance
- M. Schaefer, Plant General Manager
- R. Stastny, Maintenance Manager
- L. Sterling, Supervisor, Licensing
- D. Zink, Supervising Engineering Specialist
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000498/2014004-01 Failure to Identify a Condition Adverse to Quality for the Control NCV
- 05000499/2014004-01 Room Envelope (Section 4OA2)
Closed
Failure to Accurately Document Completion of a Maintenance
- 05000499/2014007-01 VIO Activity (Section 4OA3.2)
Manual Actuation of Main Steam Isolation Valves that was Not
- 05000499/2013-004-01 LER Part of a Preplanned Sequence During Testing or Reactor Operation (Section 4OA3.1)
Attachment