IR 05000498/2018007
| ML18277A295 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/04/2018 |
| From: | Gerond George Division of Reactor Safety IV |
| To: | Gerry Powell South Texas |
| George G | |
| References | |
| IR 2018007 | |
| Download: ML18277A295 (16) | |
Text
ber 4, 2018
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2018007 AND 0500499/2018007
Dear Mr. Powell:
On August 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project Electric Generating Station, Units 1 and 2 facility and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Gerond A. George, Acting Team Leader Inspection Program and Assessment Team Division of Reactor Safety Docket Nos. 50-498; 50-499 Licenses Nos. NPF-76; NPF-80 Enclosure:
Inspection Report 05000498/2018007 and 0500499/2018007 w/ Attachment: Information Request
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000498, 05000499 License Numbers: NPF-76, NPF-80 Report Numbers: 05000498/2018007 and 0500499/2018007 Enterprise Identifier: I-2018-007-0006 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: Wadsworth, Texas Inspection Dates: August 6, 2018, to August 23, 2018 Inspectors: H. Freeman, Senior Reactor Inspector (Team Lead)
J. McHugh, Senior Reactor Technology Instructor A. Athar, Project Engineer J. Choate, Resident Inspector R. Lanfear, Physical Security Specialist Approved By: G. George, Acting Team Leader Inspector Program and Assessment Team Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at South Texas Project Electric Generating Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below.
Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.
List of Findings and Violations No findings or violations of more than minor significance were identified during the inspection.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152Problem Identification and Resolution Biennial Team Inspection
The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety-conscious work environment. The assessment is documented below:
- (1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions - The inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee. The sample included approximately 100 condition reports with associated root and apparent cause evaluations. This included an in-depth 5-year review of condition reports associated with the electrical auxiliary buildings heating, ventilation, and air condition system and the essential cooling water system.
- (2) Operating Experience, Self-Assessments, and Audits - The team evaluated the stations processes for use of industry and NRC operating experience. The team also evaluated the effectiveness of the stations audits and self-assessments program. The sample included industry operating experience communications including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute, plus associated site evaluations.
- (3) Safety-Conscious Work Environment - The team evaluated the stations safety-conscious work environment. The team interviewed 53 station personnel in 5 focus groups and individual interviews. The individuals were selected randomly from available members of the security, instrumentation and controls, mechanical maintenance, electrical maintenance, operations, and engineering organizations. The team also interviewed members of the employee concerns program (including the program manager) and reviewed selected case files.
INSPECTION RESULTS
Corrective Action Program Assessment 71152Problem Identification and Resolution Corrective Action Program: Based on the samples reviewed, the team determined that the staffs performance in each of these areas adequately supported nuclear safety.
Effectiveness of Problem Identification: Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. On average, the licensee was identifying and documenting over 1,200 condition reports (adverse and non-adverse) per month.
However, the team identified that there was still some inconsistency on how repeat examples of equipment failures were documented. System engineers believed that an additional example of a failure would be documented on a new condition report as they occurred in order to support tracking and trending. The team found that in the case of the electrical auxiliary building battery room heater issue, not all examples of failure of the temperature controller were documented on a new condition report, but were sometimes recorded on the existing open condition report. Interviews with operations personnel confirmed that this was considered an acceptable practice. The team found that this could have led to a delay in initiating effective evaluations of the cause of the failures.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then, prioritized the evaluation and corrective actions in accordance with program guidance.
However, while not a procedural or regulatory requirement, the team identified examples where the operability determinations did not document a deterministic basis for the reasonable expectation of continued operability. In one condition report, the operability determination was based upon the system engineers opinion that the surface corrosion had no impact on structural integrity of the screens (CR 18-9335), while in another the operability determination stated that the approximately 4-5 square feet of insulation missing from the control room envelope was negligible and had no effect on operability (CR 18-9377). The team found that ultimately these were correct operability determinations.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensees corrective actions supported nuclear safety. However, the team noted a trend to extend due dates and completion of corrective actions and evaluations without adequate basis which may warrant additional management oversight and attention.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensees corrective action program complied with regulatory requirements and self-imposed standards, and the licensees implementation of the corrective action program adequately supported nuclear safety. The team found that managements oversight of the corrective action program process was effective.
Operating Experience, Self-Assessments, and Audits Assessment 71152Problem Identification and Resolution Operating Experience, Self-Assessments, and Audits: Based on the samples reviewed, the team determined that the staffs performance in each of these areas adequately supported nuclear safety.
Safety-Conscious Work Environment Assessment 71152Problem Identification and Resolution Safety-Conscious Work Environment: The team found no evidence of challenges to the organizations safety-conscious work environment. Employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
However, the team found evidence within one work organization, that while the individuals indicated they were satisfied with the licensees response to nuclear safety concerns, they did not feel that non-nuclear safety issues and industrial safety issues received the same level of attention, and that the lack of response to these types of issues may be influencing their willingness to raise similar issues. The team confirmed that this group felt free to raise any type of safety concern without retaliation. The team also confirmed that none of the other work organizations interviewed held similar opinions regarding the licensees response to non-nuclear safety or industrial safety issues.
The team also found that licensee management continued to address work environment issues within the security organization such that security personnel felt comfortable raising nuclear and non-nuclear safety concerns without the fear of retaliation, and with a greater degree of confidence that their concerns would be addressed.
EXIT MEETINGS AND DEBRIEFS
On August 23, 2018, the NRC team leader presented the biennial problem identification and resolution inspection results to Mr. G. T. Powell and other members of the licensee staff. The inspectors confirmed that no proprietary information was documented in this report and that any sensitive material was appropriately controlled to protect from public disclosure.
DOCUMENTS REVIEWED
71152 - Problem Identification and Resolution
Condition Reports
14-13126 15-21592 15-24053 15-26657 15-6150
16-10169 16-11891 16-11891 16-11908 16-13825
16-14557 16-14611 16-6496 16-6496 17-11857
17-12897 17-13155 17-1370 17-13726 17-14510
17-16376 17-1661 17-17236 17-1741 17-18175
17-19255 17-19731 17-20254 17-20262 17-20263
17-20423 17-21547 17-21699 17-22662 17-22934
17-22934 17-23022 17-23609 17-23980 17-24015
17-24596 17-36662 18-0911 18-1002 18-1931
18-2587 18-3169 18-3343 18-3374 18-3505
18-3518 18-3533 18-3533 18-3608 18-3615
18-387 18-4098 18-4383 18-4627 18-4627
18-4872 18-5103 18-5997 18-6210 18-6213
18-632 18-6998 18-7114 18-7183 18-7184
18-7185 18-7186 18-7186 18-7450 18-7536
18-9167 18-9335 18-9374 18-9377 18-9404
18-9405 18-9425 18-9452 18-959 18-9634
18-9851 18-9886 18-9943 18-9970
WANs (Work Orders)
559301 571449 549077 579810 580277 575793 559301
Facilities Work Orders
FS18-00580 FS18-02029 FS18-02204 FS18-02262 FS18-02373
FS18-02379 FS18-03008 FS18-03141 FS18-03144 FS18-03172
Procedures Number Title Revision
STP Reporting Manual 17
0PGP03-ZM-0025 Post-Maintenance Testing Program 15, 16
0PGP03-ZX-0002 Condition Reporting Process 52
0PGP03-ZX-0002A CAQ Resolution Process 11
0PGP03-ZX-0003 Station Self-Assessment Program 14
0PGP03-ZX-0008 Condition Not Adverse to Quality (CNAQ)
Resolution Process
0PGP03-ZX-0013 Operating Experience Program 14
Procedures Number Title Revision
0PGP03-ZX-0013A Processing Industry Operating Experience 0
0PGP03-ZX-0013B Site OE and INPO Reporting Process 0
OPOP01-ZO-0011 Operability, Functionality, and Reportability 11
Guidance
OPOP03-ZO-9900 Operability Determinations and Functionality 8
Assessments Program
OPOP03-ZO-9900A Operability Determinations and Functionality 5
Assessments Implementation
CAP-0002 Cause Analysis Guideline 5
CAP-0003 Condition Report Screening 1
OGP03-ZM-0028 Erection and Use of Scaffolding 22
0PG03-ZA-0140 Plant Status Control 9
0PGP03-ZC-0004 M&TE Control Program 13
0PGP03-ZO-0011 Operability, Functionality, and Reportability 10
Guidance
0PGP03-ZX-0002 Condition Reporting Process 52
0PGP03-Zx-0003 Self-Assessments 14
0PGPO1-ZA-0049 Condition Report Operations evaluation 7
program
0PGPO3-ZO-9900 Operability Determinations and Functionality 8
Assessment
0PGPO3-ZO-9900A Op. Determination Implementation 5
0PGPO3-ZX-0002A CAQ Resolution Process 10
0PGPO3-ZX-0002B Station Cause Analysis Program 9
0PGPO3-ZX-0016 Trending Process Procedure 4
Procedures Number Title Revision
0PGPO4-ZA-0002 Condition Report Engineering Evaluation 25
OPOPO4-ZO-0002 Natural or Destructive Phenomena Guidelines 54
Drawing
Number Title Revision
3A01S10003 Seismic Separation Control 8
Miscellaneous Revision
Documents Number Title or Date
Management Review Meeting May 2018
DCN 14-22645-1 Seismic Separation Control Drawing 33
STP Calculation CC-9913 Seismic Separation Acceptance Criteria October 1989
4Z519ZS1040 Thermal Growth Criteria 6
U-1 RIS- 05-20 Report March 2018
U-1 RIS- 05-20 Report June 2018
U-2 RIS- 05-20 Report March 2018
U-2 RIS- 05-20 Report June 2018
MPIC Meeting Minutes January 2018
MPIC Meeting Minutes February 2018
ECW System Health Report December 2017
year Table of EW issues August 2018
95-14544-2 Evaluate Floor Drain Under Fire Door 090 November 1996
Information Request
Biennial Problem Identification and Resolution Inspection at South Texas Project
January 23, 2018
Inspection Report: 2018007
On-site Inspection Dates: Weeks of August 6 and August 20, 2018
Assessment Period: August 26, 2016, through August 23, 2018
This inspection will cover the period from August 26, 2016, through the end of the onsite
inspection. The scope of this request is information associated with activities during this
inspection period unless otherwise specified. To the extent possible, the requested information
should be provided electronically in word-searchable Adobe PDF (preferred) or Microsoft Office
format. Any sensitive information should be provided in hard copy during the teams first week
on site; do not provide any sensitive or proprietary information electronically.
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable
format. Please be prepared to provide any significant updates to this information during the
teams first week of on-site inspection. As used in this request, corrective action documents
refers to condition reports, notifications, action requests, cause evaluations, and/or other similar
documents.
Please provide the following information no later than July 16, 2018:
1. Document Lists
Note: For these summary lists, please include the document/reference number, the
document title, initiation date, current status, and long-text description of the issue.
a. Summary list of all corrective action documents related to significant conditions
adverse to quality that were opened, closed, or evaluated during the period
b. Summary list of all corrective action documents related to conditions adverse to
quality that were opened or closed during the period
c. Summary lists of all corrective action documents that were upgraded or
downgraded in priority/significance during the period (these may be limited to
those downgraded from, or upgraded to, apparent-cause level or higher)
d. Summary list of all corrective action documents initiated during the period that
roll up multiple similar or related issues, or that identify a trend
e. Summary lists of operator workarounds, operator burdens, temporary
modifications, and control room deficiencies (1) currently open and (2) that were
evaluated and/or closed during the period
f. Summary list of safety system deficiencies that required prompt operability
determinations (or other engineering evaluations) to provide reasonable
assurance of operability
g. Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent) (sensitive information should be made
available during the teams first week on sitedo not provide electronically)
2. Full Documents with Attachments
Note: Please include a summary list or index if document titles are not descriptive.
a. Root Cause Evaluations completed during the period; include a list of any
planned or in progress
b. Apparent Cause Evaluations completed during the period
c. Quality Assurance audits performed during the period
d. Audits/surveillances performed during the period on the Corrective Action
Program, of individual corrective actions, or of cause evaluations
e. Functional area self-assessments and non-NRC third-party assessments (e.g.,
peer assessments performed as part of routine or focused station self- and
independent assessment activities; do not include INPO assessments) that
were performed or completed during the period; include a list of those that are
currently in progress
f. Any assessments of the safety-conscious work environment
g. Corrective action documents generated during the period associated with the
following:
i. NRC findings and/or violations
ii. Licensee Event Reports issued by South Texas Project
h. Corrective action documents generated for the following, if they were
determined to be applicable to South Texas Project (for those that were
evaluated but determined not to be applicable, provide a summary list):
i. NRC Information Notices, Bulletins, and Generic Letters issued or
evaluated during the period
ii. Part 21 reports issued or evaluated during the period
iii. Vendor safety information letters (or equivalent) issued or evaluated
during the period
iv. Other external events and/or Operating Experience evaluated for
applicability during the period
Corrective action documents generated for the following:
v. Emergency planning drills and tabletop exercises performed during the
period
vi. Maintenance preventable functional failures that occurred or were
evaluated during the period
vii. Action items generated or addressed by offsite review committees
during the period
viii. Findings, violations, and comments/observations documented in the
2015 NRC PI&R inspection report
3. Logs and Reports
a. Corrective action performance trending/tracking information generated during
the period and broken down by functional organization (if this information is fully
included in item 3.b, it need not be provided separately)
b. Current system health reports, Management Review Meeting package, or
similar information; provide past reports as necessary to include 12 months of
metric/trending data
c. Radiation protection event logs during the period
d. Security event logs and security incidents during the period (sensitive
information should be made available during the teams first week on sitedo
not provide electronically)
e. List of training deficiencies, requests for training improvements, and simulator
deficiencies for the period
Note: For items 3.c and 3.d, if there is no log or report maintained separate from the
corrective action program, please provide a summary list of corrective action program
items for the category described.
4. Procedures
Note: For these procedures, please include all revisions that were in effect at any time
during the period.
a. Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures that implement
the corrective action program
b. Quality Assurance program procedures (specific audit procedures are not
necessary)
c. Employee Concerns Program (or equivalent) procedures
d. Procedures that implement/maintain a Safety-Conscious Work Environment
e. Conduct of Operations procedure (or equivalent) and any other procedures or
policies governing control room conduct, operator burdens and workarounds,
etc.
f. Operating Experience (OE) program procedures and any other procedures or
guidance documents that describe the sites use of OE information
5. Other
a. List of risk-significant components and systems, ranked by risk worth
b. List of structures, systems, and components and/or functions that were in
maintenance rule (a)(1) status at any time during the inspection period; include
dates and results of expert panel reviews and dates of status changes
c. Organization charts for plant staff and long-term/permanent contractors
d. Electronic copies of the UFSAR (or equivalent), technical specifications, and
technical specification bases, if available
e. Table showing the number of corrective action documents (or equivalent)
initiated during each month of the inspection period, by screened significance
f. For each day the team is on site,
i. Planned work/maintenance schedule for the station
ii. Schedule of management or corrective action review meetings (e.g.
operations focus meetings, condition report screening meetings, CARBs,
MRMs, challenge meetings for cause evaluations, etc.)
iii. Agendas for these meetings
Note: The items listed in 5.f may be provided on a weekly or daily basis after the
team arrives on site.
All requested documents should be provided electronically where possible. Regardless of
whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide
copies on CD or DVD.
One copy of the CD or DVD should be provided to the resident inspector at South Texas
Project; and one additional copy should be provided to the team lead, to arrive no later than July
16, 2018:
U.S. NRC Region IV
Attn: Harry Freeman
1600 E. Lamar
Arlington, TX 76011
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: HAF Yes No Publicly Available Sensitive
OFFICE SRI:IPAT SRTI:TTC PE:PBA RI:PBB PSI:PSB1 C:PBB ATL:IPAT
NAME HFreeman JMcHugh AAthar JChoate RLanfear NTaylor GGeorge
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 10/01/2018 10/02/2018 10/02/2018 10/02/2018 10/01/2018 10/03/2018 10/03/2018