IR 05000498/2014007

NRC Inspection Report (05000498/2014007 and 05000499/2014007); Investigation Report 4-2013-001 and Notice of Violation

ML14078A663
Person / Time
Site:	South Texas
Issue date:	03/18/2014
From:	O'Keefe N NRC/RGN-IV/DRP/RPB-B
To:	Koehl D South Texas
D. Proulx
References
EA-13-213 4-2013-001, IR-14-007
Download: ML14078A663 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511 March 18, 2014 EA-13-213 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 INSPECTION REPORT (05000498/2014007 and 05000499/2014007); INVESTIGATION REPORT 4-2013-001 AND NOTICE OF VIOLATION

Dear Mr. Koehl:

On March 6, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. The NRC Office of Investigations completed their associated Investigation on September 30, 2013. On March 6, 2014, the NRC inspectors discussed the results of this inspection with Mr. G. Powell, Site Vice President, and other members of your staff. The enclosed report presents the results of this inspection.

During this inspection, the NRC staff examined activities conducted under your license as they relate to public health and safety to confirm compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. This issue was evaluated under the risk significance determination process as having very low safety significance (Green).

The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it involved willfulness and impacted the ability of the NRC to perform its regulatory oversight function. Specifically, the NRC determined that a supervisory employee of your staff deliberately falsified a work order to indicate completion of a step to tighten fasteners on a pressurizer spray valve following plant heat-up when this step was not performed. This impacted the ability of the NRCs ability to perform its regulatory function because the work order was required to be complete and accurate in all material respects in order to demonstrate that all quality requirements were met during this maintenance activity. Willful violations are of particular concern because the NRCs regulatory program is based on licensees and their contractors, employees, and agents acting with integrity and communicating with candor. Thus, the criteria contained in Section 2.3.2. of the Enforcement Policy were not met to treat this as a non-cited violation.

The NRC has concluded that information regarding: (1) the reason for the violation; (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in NRC Inspection Report Numbers 05000498/2014007 and 05000499/2014007. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.

Sincerely,

/RA/

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 05000498/2014007 and 05000499/2014007 w/Attachment:

1. Notice of Violation 2. Supplemental Information Electronic Distribution to South Texas Project Electric Generating Station

SUMMARY

IR 05000498/2014007, 05000499/2014007; 01/21/2014 - 3/6/2014; South Texas Project

Electric Generating Station, Units 1 and 2, Problem Identification and Resolution.

The inspection activities described in this report were performed by a senior project engineer from the NRCs Region IV office. One finding of very low safety significance is documented in this report. This finding involved a violation of NRC requirements. The significance of most 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 NRCs 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: Initiating Events

Green.

The inspectors identified a violation of 10 CFR 50.9; 10 CFR 50, Appendix B,

Criterion XVII; and Technical Specification 6.8.1.a, for failure to accurately document completion of a maintenance activity. Specifically, on November 7, 2011, a maintenance supervisor documented that a work order step to hot torque the Unit 2 pressurizer spray valve hold down bolts had been performed, when this activity was never completed. The NRCs investigation determined that this falsification was deliberate violation that impacted the NRCs ability to perform its regulatory function, so this violation is being cited in accordance with the NRC Enforcement Policy (EA-13-213). This issue was entered into the licensees corrective action program under Condition Report 14-4633. The individual who falsified the document was subject to administrative action in accordance with the licensees program, and licensee management reinforced the need to ensure accurate quality records with workers.

The failure to accurately document completion of a maintenance activity was a performance deficiency. The performance deficiency was more than minor, therefore, a finding, because it affected the initiating events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Section A, LOCA Initiators, the inspectors determined that the finding was of very low safety significance (Green) because the performance deficiency did not result in an actual degradation of the reactor coolant pressure boundary. In addition, this finding was evaluated under traditional enforcement due to the 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. The finding was not assigned a cross-cutting aspect because it was not representative of current licensee performance in that the violation occurred more than 2 years ago (Section 4OA2.1).

REPORT DETAILS

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

4OA2 Problem Identification and Resolution

.1 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected the following issue for an in-depth follow-up:

• On August 27, 2012, Condition Report 12-25979 was written to address leakage from pressurizer spray valve PCV-0655B and its causes.

• The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions appear to be adequate to correct the condition.

These activities constitute completion of one annual follow-up sample, as defined in Inspection Procedure 71152.

b. Findings

Introduction.

A Green violation of 10 CFR 50.9, 10 CFR 50, Appendix B, Criterion XVII, and Technical Specification 6.8.1.a was identified for failure to accurately document a maintenance activity. Specifically, on November 7, 2011, a maintenance supervisor documented that a hot torque of pressurizer spray valve PCV-0655B hold down bolts had been performed, when this activity was never completed. The NRCs investigation determined that this falsification was deliberate violation that impacted the NRCs ability to perform its regulatory function, so this violation is being cited in accordance with the NRC Enforcement Policy (EA-13-213).

Description.

On August 27, 2012, Unit 2 valve PCV-0655B (pressurizer spray valve)developed a small body to bonnet leak (~0.02 gpm). The licensee initiated Condition Report 12-25979 to determine the cause of the leak and identify corrective actions.

Because the leakage was located on a mechanical joint with a gasket, it was not considered reactor coolant pressure boundary leakage as defined in the Technical Specifications.

The licensee evaluated whether to perform a hot torque (i.e. retorquing the body to bonnet fasteners at normal operating temperature and pressure, 587 degrees F and 2335 psig) to attempt to correct the leakage. The licensee decided not to hot torque the bolts on this valve because the body and bonnet already made metal-to-metal contact when torqued with the valve at room temperature. The evaluation also noted that the work would be in a high dose and very hot work area. Because the gasket was crushed to the point where the flange faces were flush and making metal-to-metal contact during the initial torquing, thus limiting the flow rate of a leak to a very small value by design, the licensee concluded that additional hot torquing would not further crush the gasket or reduce leakage. The licensee contained the leakage and used cameras to remotely monitor the leakage until the subsequent refueling outage.

The inspector reviewed work order number WAN 406103 and implementing Procedure 0PMP04-RC-007, Pressurizer Spray Valve Maintenance, Revision 19, to determine if work practices contributed to the leakage. The inspector noted the following anomalies:

• Maintenance work on valve PCV-0655B was completed on November 7, 2011.

Step 5.9.2 of work order WAN 406103 contained a conditional step that required the user to perform a hot torque of the body to bonnet fasteners to between 290 and 310 ft-lbs if the valve leaked while in service (i.e. at normal operating temperature). However, the work order documented an out of specification torque of 21 ft-lbs, instead of a value between 290 and 310 ft-lbs.

• In addition, Unit 2 was in cold shutdown on November 7, 2011, and was not heated up to normal operating temperature and pressure until November 21, 2011. Since the plant was in Mode 5 (Cold Shutdown) and depressurized when this signature was made, the step could not have been performed as written on the date the document indicated that the step had been signed off.

• The supervisory review was signed off satisfactorily on November 14, 2011, and the operations review prior to the post-maintenance test was performed on November 21, 2011, without identifying the above problems. The post-maintenance test of valve PCV-655B (an operational leak check and cycling of the valve) was performed satisfactorily on November 21, 2011.

The NRC Office of Investigations (OI) investigated the apparent discrepancies with the performance of work order number WAN 406103 and Step 5.9.2 of Procedure 0PMP04-RC-007. This investigation determined that the individual whose initials were documented in Step 5.9.2 of Procedure 0PMP04-RC-007 did not perform the hot torque of valve PCV-0655B and did not write in 21 ft-lbs as the torque value.

The OI investigation revealed that the maintenance craft supervisor wrote in the 21 ft-lbs, then initialed and dated the entry with a mechanics initials. Thus, the maintenance supervisor documented completion of a work activity that was not complete and accurate in all material aspects, because it was documented that a hot torque was completed when it had not actually been performed. The NRC determined that these actions were a deliberate violation.

The licensee monitored the leakage for the duration of the operating cycle, which was significantly below the Technical Specification limit for unidentified leakage of 1 gpm.

The licensee determined that the apparent cause of the leakage at the body-to-bonnet joint of valve PCV-0655B was unrelated to the falsified documentation of the hot torque, in that the gasket being used was not appropriate for the operating temperature experienced by the valve. The leak was corrected and an appropriate gasket was installed during the next refueling outage in May of 2013.

The inspector determined that the work step that was falsified would not have been required to be performed. When the plant was pressurized and heated up to normal operation temperature, the post-maintenance test indicated no leakage from the body to bonnet joint of PCV-655B. Therefore, the hot torqueing would not have been required by Step 5.9.2. The small leak that developed 9 months later was not caused by the falsified work step or by not hot torqueing the fasteners because the fasteners were sufficiently tightened at room temperature to ensure metal-to-metal contact between the valve body and bonnet.

The individual who falsified the document was subject to administrative action in accordance with the licensees program. The licensee performed an extent of condition review for other work orders associated with this individual, and did not identify any further cases of falsification. Licensee management also met with workers to reinforced the need to ensure accurate quality records. The licensee repaired the leak and replaced the gasket with material suitable for the operating temperature of the valve, restoring full compliance.

Analysis.

The failure to accurately document completion of a maintenance activity was a performance deficiency. The performance deficiency was more than minor, and therefore, a finding, because it affected the initiating events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Section A, LOCA Initiators, the inspectors determined that the finding was of very low safety significance (Green) because the performance deficiency did not result in an actual degradation of the reactor coolant pressure boundary.

The finding was not assigned a cross-cutting aspect because it was not representative of current licensee performance, in that the violation occurred more than 2 years ago. This issue was entered into the licensees corrective action program under Condition Report 14-4633.

Enforcement.

Title 10 of the Code of Federal Regulations Part 50.9 requires, in part, that information required by statute, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVII, "Quality Assurance Records,"

states, in part, that sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include... monitoring of maintenance activities.

Technical Specification 6.8.1.a, states, in part, that written procedures shall be established, implemented, and maintained for the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," Appendix A, Section 9.a, requires that maintenance that can affect the performance of safety related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings. Unit 2 Work Order WAN 406103 and Procedure 0PMP04-RC-007, Pressurizer Spray Valve Maintenance, Revision 19 implemented this requirement for repairs of pressurizer spray valve PCV-0655B.

Contrary to the above, on November 7, 2011, the licensee failed to maintain records required by Technical Specification 6.8.1.a and 10 CFR 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-body 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.

This is a violation of 10 CFR 50.9, 10 CFR 50, Appendix B, Criterion XVII, and Technical Specification 6.8.1.a. A Notice of Violation is attached. (VIO 05000499/2014007-001, Failure to Accurately Document Completion of a Maintenance Activity). (EA-13-213)

4OA6 Meetings, Including Exit

Exit Meeting Summary

On March 6, 2014, the inspectors presented the inspection results to Mr. G. Powell, Site Vice President, 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.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Berg, Manager, Design Engineering

C. Bowman, General Manager, Engineering

S. Dubey, Engineer, Steam Generators

G. Hildebrandt, Manager, Operations

D. Koehl, President and CEO

M. Murray, Manager, Regulatory Affairs

J. Paul, Supervisor, Licensing

L. Peter, Plant General Manager

G. Powell, Site Vice President

F. Puleo, Engineer, Licensing

D. Rencurrel, Senior Vice President, Operations

R. Savage, Engineer, Licensing Staff Specialist

M. Schaefer, Manager, Nuclear Oversight

R. Stastny, Maintenance Manager

K. Taplett, Supervisor, Licensing

T. Walker, Manager, Quality Assurance

K. Wallis, Manager, Systems Engineering

NRC

A. Sanchez, Senior Resident Inspector

N. Hernandez, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000499/2014007-01 VIO Failure to Accurately Document Completion of a Maintenance

Activity

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

0PGP04-ZA-0002 Condition Report Engineering Evaluation 19

0PMP04-RC-007 Pressurizer Spray Valve Maintenance 19

0PGP04-ZA-0108 Vendor Document Control Manual 8

Attachment 2

0PGP03-ZA-0504 Employee Concerns Program 13

Work Orders

WAN 0406103 Reactor Coolant Loop 2D Spray Valve 0

Condition Reports (CRs)

04-11923 04-05929 04-0651 04-11523 13-12549

2-25979 10-10797 14-4633

Other

NRC Office of Investigations Report 4-2013-001, dated September 30, 2013

Instruction Manual Type SS-84 Vee-Ball Valve Body, Revision 0

A-2