IR 05000498/2019003
| ML19303D906 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/30/2019 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2019003 | |
| Download: ML19303D906 (25) | |
Text
October 30, 2019
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1
AND 2 - INTEGRATED INSPECTION REPORT 05000498/2019003 AND 05000499/2019003
Dear Mr. Powell:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On October 10, 2019, the NRC inspectors discussed the results of this inspection with Mr. A. Capristo, Executive Vice President and Chief Administrative Officer, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at South Texas Project.
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at South Texas Project. 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/
Jeffrey E. Josey, Chief Reactor Projects Branch A Division of Reactor Projects
Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000498 and 05000499
License Numbers:
Report Numbers:
05000498/2019003 and 05000499/2019003
Enterprise Identifier: I-2019-003-0004
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station
Location:
Wadsworth, TX 77483
Inspection Dates:
July 1, 2019 to September 30, 2019
Inspectors:
J. Choate, Resident Inspector
S. Hedger, Emergency Preparedness Inspector
A. Sanchez, Senior Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at South Texas Project Electric Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Establish Maintenance Rule (a)(1) Goals for Safety-Related Chillers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000499,05000498/2019003-01 Open/Closed
[P.2] -
Evaluation 71111.12 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50.65(a)(1) for the licensees failure to establish goals commensurate with safety for equipment subject to the Maintenance Rule. Specifically, once the essential chilled water system was placed into Maintenance Rule (a)(1) for a repeat functional failure of the auxiliary oil pump seal, the licensee did not establish performance goals that were different than the existing performance criteria.
Failure to Follow Procedure Results in Load Rejection Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green FIN 05000498,05000499/2019003-02 Open/Closed
[H.4] -
Teamwork 71152 The inspectors reviewed a Green, self-revealed finding for the licensees failure to implement procedures for a surveillance resulting in a change in reactivity. Specifically, a licensed operator failed to adjust limits on the main steam governor valves during performance of a station test procedure, resulting in an unplanned load rejection of 3.8 percent thermal reactor power.
Additional Tracking Items
None
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 began the inspection period at rated thermal power. On September 29, 2019, Unit 2 began coast down operation. Unit 2 ended the inspection period at 98 percent rated thermal power.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated readiness for impending adverse weather conditions for Tropical Storm Imelda on September 17, 2019.
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, train B emergency core cooling system during train C emergency core cooling system welding activities on July 9, 2019
- (2) Unit 2, train B component cooling water system during train A component cooling water maintenance on July 22, 2019
- (3) Unit 1, positive displacement charging pump during train A centrifugal charging pump maintenance on July 29, 2019
- (4) Unit 2, turbine-driven auxiliary feedwater pump during train C emergency diesel generator maintenance on August 5, 2019
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
The inspectors evaluated fire brigade performance for the following three fire drills to complete one sample of the annual inspection:
(1)
- An unannounced simulated fire in the make-up demineralizer building on February 22, 2019;
- An unannounced simulated fire in the load center 12G building on August 6, 2019;
- An announced simulated fire in the integrated computer system in the Unit 1 auxiliary shutdown panel area on August 20, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 2, train A and B centrifugal charging pump rooms, Fire Areas 25 and 26 on July 2, 2019
- (2) Unit 2, train C safety-related switchgear room, battery and inverter rooms, and motor generator room, Fire Areas 52 through 54 on July 19, 2019
- (3) Unit 2, turbine generator building 55 foot elevation, Fire Area 90 on August 2, 2019
- (4) Unit 1, train A and B centrifugal charging pump rooms, Fire Areas 25 and 26 on September 1, 2019
- (5) Unit 1, component cooling water common header room, Fire Area 20 on September 26, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Underground Cables (IP Section 02.02c.) (1 Sample)
The inspectors evaluated cable submergence protection in the following locations to complete one sample of the annual inspection:
- (1) Unit 1, train B manhole BOXYAEKEM50 Unit 1, train C manhole COXYABKEM53 Unit 1, train C manhole COXYABKEM58 Unit 1, train A manhole AOXYABKEM51 Unit 1, train A manhole AOXYABKEM50
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed a Unit 1 operating crew respond to a degraded condition of the main feedwater booster pump 12 and the preparation to swap feedwater pumps on August 19, 2019.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during a Unit 1 infrequently performed evolution that involved restoration of normal charging and letdown following isolation due to high differential pressure across both reactor coolant system filters on September 16, 2019.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a Unit 2 operating crew simulator training that involved a nuclear instrumentation failure, moisture separator level control valve failure, large break loss of coolant accident, reactor coolant system cold leg recirculation, and reactor coolant system leakage outside of containment, which resulted in Alert, Site Area Emergency, and General Emergency declarations on August 20, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Units 1 and 2, chemical and volume control system on July 10, 2019
- (2) Units 1 and 2, emergency diesel generator systems on September 5, 2019
- (3) Units 1 and 2, essential chilled water systems on September 30, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1 elevated risk due to train A work week in which the safety injection system work required 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> more than planned and transitioned risk from white to yellow the week of July 15, 2019
- (2) Unit 2 planned risk due to train A component cooling water and emergency diesel generator maintenance the week of July 23, 2019
- (3) Unit 2 planned risk due to train C auxiliary feedwater pump, steam generator power operated relief valve, and emergency diesel generator maintenance the week of August 6, 2019
- (4) Unit 1 planned risk due to train B work week due to extended unavailability of the essential chilled water and auxiliary feedwater maintenance activities the week of August 19, 2019
- (5) Unit 2 planned risk due to train B emergency diesel generator, essential cooling water, essential chilled water, and emergency core cooling system maintenance the week of August 26, 2019
- (6) Unit 1 planned risk due to train A essential cooling water, steam generator power operated relief valve, and emergency diesel generator maintenance the week of September 9, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (6 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 2, turbine-driven auxiliary feedwater pump speed lowering during inservice testing on July 16, 2019
- (2) Unit 1, environmental qualification of safety-significant transmitters in the turbine generator building on July 17, 2019
- (3) Unit 1, train B 125 VDC batteries electrolyte leakage and degrading flame arrestor gasket on July 31, 2019
- (4) Unit 1, cracks identified in the train B emergency diesel generator exhaust bellows on August 23, 2019
- (5) Unit 1, exposed wires in the train C quality display processing system cabinet on August 28, 2019
- (6) Unit 1, grounding of alarm circuitry for train B emergency diesel generator standby jacket water and lube oil pumps on September 12, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Unit 1, train B emergency safeguards features sequencer following key switch module replacement on July 24, 2019
- (2) Unit 2, train B quality display processing system circuit board replacement on July 25, 2019
- (3) Unit 1, train A centrifugal charging pump following flow element maintenance on July 29, 2019
- (4) Units 1 and 2, diesel-driven fire pump No.1 following pump and diesel governor replacement on August 1, 2019
- (5) Unit 1, train B reactor vessel head vent throttle valve following troubleshooting and replacement of a blown fuse on August 1, 2019
- (6) Unit 2, train C emergency diesel generator following welding and sealing activities on the knockout panel on August 7, 2019
- (7) Unit 1, reactor vessel head vent solenoid valve HCV-601 following fuse replacement on August 15, 2019
- (8) Unit 1, train B emergency diesel generator following weld repair of the exhaust manifold on August 24, 2019
- (9) Unit 1, train A emergency diesel generator following repair of two grounds on September 13, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2, chemical and volume control system letdown isolation valve temperature switch calibration on July 15, 2019
- (2) Unit 2, train A containment spray surveillance on July 24, 2019
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system between May 1, 2017, and July 5, 2019.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Response Organization between May 1, 2017, and July 5, 2019. Inspectors also evaluated the licensees ability to staff their emergency response facilities in accordance with emergency plan commitments.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and practices between May 1, 2017, and July 5, 2019. The evaluation reviewed screenings and evaluations documenting the implementation of this process. The reviews of the change process documentation do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program between May 1, 2017, and July 5, 2019. The evaluation reviewed activations of the emergency plan, the conduct of drills and exercises, licensee audits and assessments, and the maintenance of equipment important to emergency preparedness.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The licensee's enhanced emergency plan drill that involved a large break loss of coolant accident (Alert), a reactor coolant system leak outside of containment (Site Area Emergency), and a partial loss of offsite power (General Emergency) on August 27,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12)===
- (1) April 1, 2018, through June 30, 2019
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2018, through June 30, 2019
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) April 1, 2018, through June 30, 2019
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1, July 1, 2018, through June 30, 2019
- (2) Unit 2, July 1, 2018, through June 30, 2019
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1, July 1, 2018, through June 30, 2019
- (2) Unit 2, July 1, 2018, through June 30, 2019
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1, July 1, 2018, through June 30, 2019
- (2) Unit 2, July 1, 2018, through June 30, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unit 1, reactor operator error during main steam governor valve testing that resulted in a load rejection and 3.8 percent decrease in reactor thermal power. The inspectors reviewed the prompt investigation, interviewed operations personnel, and evaluated the corrective actions
INSPECTION RESULTS
Failure to Establish Maintenance Rule (a)(1) Goals for Safety-Related Chillers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000499,05000498/2019003-01 Open/Closed
[P.2] -
Evaluation 71111.12 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50.65(a)(1) for the licensees failure to establish goals commensurate with safety for equipment subject to the Maintenance Rule. Specifically, once the essential chilled water system was placed into Maintenance Rule (a)(1) for a repeat functional failure of the auxiliary oil pump seal, the licensee did not establish performance goals that were different than the existing performance criteria.
Description:
Each unit at South Texas Project has three trains of essential chilled water, each equipped with a chiller which requires an auxiliary oil pump for lubrication of the bearings, shaft, and gears of the chiller compressor. On April 18, 2019, Unit 2 was in steady state full power operation when the control room received an alarm for a train B essential chiller trip due to low oil pressure. A plant operator was dispatched to the chiller and observed an external loss of oil from the train B essential chiller auxiliary oil pump seal. At the same time the train C essential chiller was also inoperable due to planned maintenance, causing Unit 2 to enter Technical Specification 3.7.14 action B, which required within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore at least one essential chiller to operable or apply the Configuration Risk Management Program (CRMP),or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Operators satisfied the technical specification by applying the CRMP with an expiration time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Maintenance later found that the oil came from a failed mechanical seal assembly for the auxiliary oil pump. On April 19, 2019, the mechanical seal for train B essential chilled water auxiliary oil pump was replaced, operators declared the train operable following a post-maintenance test, and the unit exited the conditions of the CRMP.
The inspectors evaluated the seal failure and found this to be the third such failure for the essential chiller auxiliary oil pump seals since October 2017. The licensee considered the second failure in May 2018 to be a repeat functional failure per their Maintenance Rule program and moved the essential chilled water system from Maintenance Rule (a)(2) to (a)(1)status at that time, establishing the (a)(1) status goal to be no more repetitive [maintenance rule functional failures] due to seal failures in the oil pumps. The inspectors determined that this (a)(1) goal failed to meet the requirements of 10 CFR 50.65(a)(1) in that the goal must be commensurate with safety. Specifically, this goal was a restatement of the performance criteria not met that resulted in the essential chilled water system being moved from (a)(2) to (a)(1) status.
The inspectors provided their concerns to the licensee in June 2019, and in July 2019 the Maintenance Rule Expert Panel voted to change the goal for the essential chilled water system to replace the unreliable oil pump shaft mechanical seal assemblies with a more reliable design in order to ensure no additional functional failures of the chillers due to oil leaks. The inspectors assessed the new goal to be justifiable, defensible, and commensurate with safety such that it satisfies the requirements of the Maintenance Rule.
Corrective Actions: In addition to the corrective actions stated above, the licensee established a longer-term corrective action to replace the existing mechanical seals for the essential chilled water auxiliary oil pumps with an improved design by July 2020.
Corrective Action References: Condition Report 2019-4472
Performance Assessment:
Performance Deficiency: The failure to establish goals commensurate with safety for equipment subject to the requirements of the Maintenance Rule was a performance deficiency. Specifically, the goal established for the essential chilled water system was a restatement of the performance criteria not met that resulted in the system transitioning from (a)(2) to (a)(1) status.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish goals commensurate with safety for the essential chilled water system allowed issues with the auxiliary oil pump seals to go unresolved. As a result, the licensee failed to bring about necessary improvements in essential chilled water system performance and on April 18, 2019, the Unit 2 train B essential chiller auxiliary oil pump seal failed resulting in the unit entering into an unplanned 1-hour technical specification shutdown action statement.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance, Green. Specifically, while the system did not maintain its operability, the finding did not represent a loss of system, did not represent an actual loss of function for greater than its technical specification allowed outage time, and did not represent an actual loss of function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The essential chilled water system remained capable of performing its safety function with train A essential chilled water operable and in service.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, engineering personnel failed to thoroughly evaluate the Maintenance Rule (a)(1) goal established for the essential chilled water system issues to ensure that resolutions addressed causes.
Enforcement:
Violation: Title 10 CFR Part 50.65(a)(1), requires, in part, that each holder of an operating license under this part shall monitor the performance or condition of structures, systems, or components, against licensee-established goals and that these goals shall be established commensurate with safety. Contrary to the above, from May 2018 until July 2019, for components associated with the essential chilled water system, the licensee failed to establish goals commensurate with safety. Specifically, the established goal was a restatement of the failed performance criteria that resulted in the system transitioning from (a)(2) to (a)(1) status. As a result, the licensee failed to bring about necessary improvements in essential chilled water system performance and on April 18, 2019, the Unit 2 train B essential chiller auxiliary oil pump seal failed, resulting in the unit entering into an unplanned 1-hour technical specification shutdown action statement.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Follow Procedure Results in Load Rejection Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green FIN 05000498,05000499/2019003-02 Open/Closed
[H.4] -
Teamwork 71152 The inspectors reviewed a Green, self-revealed finding for the licensees failure to implement procedures for a surveillance resulting in a change in reactivity. Specifically, a licensed operator failed to adjust limits on the main steam governor valves during performance of a station test procedure, resulting in an unplanned load rejection of 3.8 percent thermal reactor power.
Description:
Unit 1 at South Texas Project is equipped with four main steam governor valves designed to automatically open and close to control main turbine load. Each governor valve has an adjustable limit to prevent the valve from opening beyond a desired value. On March 2, 2019, Unit 1 was performing surveillance test Procedure 0POP07-MS-0003, Main Turbine Steam Inlet Valve Test, Revision 28, to test the ability of governor valve 1 to fully close, and then fully open, with the unit operating at 90 percent for the test. Step 5.3.3.3 of the procedure states, in part, to set governor control valve limit to greater than 100 percent.
This allows the remaining governor valves 2, 3, and 4 to open as necessary to maintain main turbine load while governor valve 1 is cycled. However, the reactor operator incorrectly marked Step 5.3.3.3 as not applicable. As a result, when governor valve 1 was manually taken to the full closed position, the valve limit for governor valve 4 prevented the valve from opening enough to maintain main turbine load, causing a 3.8 percent decrease in reactor thermal power and a 3.1 °F increase in reactor coolant system temperature.
Operators in the control room monitored plant conditions and allowed the plant to stabilize.
The shift manager then held a crew brief to discuss the transient before exiting the test and restoring reactor power to 100 percent. On April 17, 2019, the licensee completed a performance analysis and determined that the operator performing the step failed to read and evaluate the step prior to marking it not applicable, the operator providing the peer check failed to ensure the correct action was performed at the correct time, and the unit supervisor failed to ensure the procedure was peer reviewed prior to implementation.
Corrective Actions: In addition to the immediate corrective actions taken as noted above, the licensee revised Procedure 0POP07-MS-0003 to address the human factoring of the procedure steps that contributed to the operator error. Operations management has also coached all operating crews and provided a Lessons Learned in training on the importance of procedural adherence, communication, and peer checking.
Corrective Action References: Condition Report 2019-2526
Performance Assessment:
Performance Deficiency: The failure to implement procedures that could affect reactivity was a performance deficiency. Specifically, a licensed operator failed to adjust limits on the main steam governor valves during execution of Procedure 0POP07-MS-0003, Main Turbine Steam Inlet Valve Test, Revision 28. As a result, governor valve 4 failed to open fully when governor valve 1 was taken to full close, causing a load rejection of 3.8 percent thermal reactor power.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensed operator performing the test failed to read and evaluate a step prior to marking it not applicable, preventing governor valve 4 from opening fully during the test. The unit supervisor and the operator providing the peer check in the control room also failed to ensure the procedure was correctly marked before and during implementation. This resulted in an unplanned load rejection of 3.8 percent thermal power.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance, Green. Specifically, the finding did not cause a reactor trip and did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. The inspectors determined that the finding had a cross-cutting aspect in the area of human performance associated with teamwork. Specifically, the unit supervisor and operator providing the peer check in the control room failed to communicate and coordinate activities with the operator performing the valve test procedure. Licensed operators in the control room failed to work as a team to provide peer checks.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 10, 2019, the inspectors presented the integrated inspection results to Mr. A. Capristo, Executive Vice President and Chief Administrative Officer, and other members of the licensee staff.
- On July 11, 2019, the inspectors presented the emergency preparedness program inspection technical debrief inspection results to Mr. J. Enoch, Manager, Emergency Preparedness, and other members of the licensee staff.
- On July 30, 2019, the inspectors presented the emergency preparedness program inspection telephonic exit meeting inspection results to Mr. G. T. Powell, President and Chief Executive Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.04Q Corrective Action
Documents
CR-YYYY-NNNN
2009-5671
71111.04Q Corrective Action
Documents
Work
Authorization
Number
583566
71111.04Q Drawings
5N129F05014#2
Piping and Instrumentation Diagram Safety Injection System
71111.04Q Drawings
5R179F05007#1
Piping and Instrumentation Diagram Chemical and Volume
Control System
71111.04Q Drawings
5R209F05018#2
Piping and Instrumentation Diagram Component Cooling
Water System
71111.04Q Drawings
5R209F05020#2
Piping and Instrumentation Diagram Component Cooling
Water System
71111.04Q Drawings
5S141F00024
Piping & Instrumentation Diagram Auxiliary Feedwater
71111.04Q Drawings
5S142F00024
Piping & Instrumentation Diagram Auxiliary Feedwater
Corrective Action
Documents
CR-YYYY-NNNN
2019-8536
Miscellaneous
Fire Drill Package
19-03-02
Procedures
Fire Preplan for Load Center Building 12G, 12J, 12K, and
2M
Procedures
STPEGS Fire Brigade
71111.05Q Procedures
Fire Preplan Electrical Auxiliary Building ESF Switchgear
Room Train C
71111.05Q Procedures
Fire Preplan Electrical Auxiliary Building, Channel IV Battery
and Distribution Room
71111.05Q Procedures
Fire Preplan Electrical Auxiliary Building, Motor Generator
Room
71111.05Q Procedures
Fire Preplan Mechanical Auxiliary Building CVCS Centrifugal
Charging Pump 1B and Valve Room
71111.05Q Procedures
Fire Preplan Mechanical Auxiliary Building CVCS Centrifugal
Charging Pump 1A and Valve Room
71111.05Q Procedures
0MAMB20-FP-
29
Fire Preplan Mechanical Auxiliary Building Non-Radioactive
Pipe Chase
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.05Q Procedures
Turbine Generator Building Northwest 55 Elevation
71111.05Q Procedures
Fire Preplan Turbine Generator Building Northeast 55
Elevation
71111.05Q Procedures
Fire Preplan Turbine Generator Building South 55 Elevation
71111.11Q Corrective Action
Documents
CR-YYYY-NNNN
2017-23860, 2019-9012
71111.11Q Miscellaneous
Simulator Lesson
Plans
LOR 194, RST 219.11, Enhanced E-Plan
71111.11Q Procedures
0001
Main Feedwater
105
71111.11Q Procedures
CROE 10-10133-
Restoring Normal Letdown with Both RC Filters Removed
from Service due to Clogging
Corrective Action
Documents
CR-YYYY-NNNN
2012-27630, 2017-22981, 2018-3453, 2018-11724, 2019-
3695, 2018-10958, 2019-3869, 2018-20976, 2018-2458
Corrective Action
Documents
Work
Authorization
Numbers
2770, 601369
Miscellaneous
VTD-P025-0002
Centrifugal Charging Pump (CCP) Operation and
Maintenance Manual
Miscellaneous
VTD-U055-0001
Instruction Manual for the Positive Displacement Charging
Pumps
Procedures
0PMP04-CV-0003 Centrifugal Charging Pump Maintenance
Procedures
0PMP04-CV-0004 Positive Displacement Charging Pump Maintenance
Corrective Action
Documents
CR-YYYY-NNNN
2019-7916, 2019-7918, 2019-7919
Miscellaneous
RasCal
Sequences
3396, 3430, 3453
Procedures
0PGP03-ZO-0055 Protected Components
Procedures
0POP01-ZO-0006 Risk Management Actions (RMAs)
Corrective Action
Documents
CR-YYYY-NNNN
2019-7235, 2009-1185, 2019-7521, 2019-7488, 2015-
17339, 2019-8167, 2019-8089, 2019-9904
Miscellaneous
Calculation
Qualified Life of Selected Rosemount Transmitters
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
E43321
Miscellaneous
Calculation EC- 5008
Class 1E DC System Scenario, Battery/Charger/Inverter
Sizing & System Voltage Calculation
Miscellaneous
VTD-W290-0001
PGA Governor
2/01/1994
Procedures
Auxiliary Feedwater Pump 14(24) Inservice Test
Corrective Action
Documents
CR-YYYY-NNNN
2019-7815, 2019-4588, 2019-8213, 2017-614, 2019-
7971, 2019-8052, 2019-8062, 2018-15297, 2019-10118,
2019-9904
Corrective Action
Documents
Work
Authorization
Numbers
616272,
610661,
616722,
555888,
603897, 618941, 573946, 573947
Procedures
21
QDPS APC-B1 Removal From Service
Procedures
0001B
Train B ESF Diesel Sequencer Remote Timing Test
Procedures
0POP02-CV-0004 Chemical and Volume Control System Subsystem
Procedures
0001
Emergency Diesel Generator 11(12)
Procedures
Fire Protection Water System Functional Test
Corrective Action
Documents
Work
Authorization
Numbers
2582,
2593
Drawings
5R179F05005#2
Piping & Instrumentation Diagram Chemical and Volume
Control System
Drawings
5R179Z42410#2
Letdown Isolation Valves Logic Diagram System: CV
Procedures
Generic Temperature Switch Calibration (Filled Element)
Corrective Action
Documents
Condition Reports
18-02701
Miscellaneous
Updated Prompt Notification System Design Report
3, 4
Procedures
Prompt Notification System
Miscellaneous
South Texas Project, Units 1 and 2 - Issuance of
Amendments RE: Emergency Response Organization Time
Augmentation and Staffing Changes to the Emergency Plan
07/19/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
(CAC No. MG0024 and MG0025; EPID L-2017-LLA-0265)
Miscellaneous
0014, Form 19
ENRS Test
07/05/2017
Miscellaneous
0014, Form 19
ENRS Test
08/22/2017
Miscellaneous
0014, Form 19
ENRS Test
11/17/2017
Miscellaneous
0014, Form 19
ENRS Test
03/06/2018
Miscellaneous
0014, Form 19
ENRS Test
07/24/2018
Miscellaneous
0014, Form 19
ENRS Test
09/25/2018
Miscellaneous
0014, Form 19
ENRS Test
2/11/2018
Miscellaneous
0014, Form 19
ENRS Test
03/07/2019
Miscellaneous
0014, Form 19
ENRS Test
07/01/2019
Miscellaneous
NOC-AE-
16003406
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498; STN 50-499; License Amendment Request for Revision
to Staffing and Staff Augmentation Times in the South Texas
Project Electric Generating Station Emergency Plan
07/31/2017
Miscellaneous
NOC-AE-
18003541
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498; STN 50-499; Response to Request for Additional
Information for the License Amendment Request for
Revision to Staffing and Augmentation Times in the South
Texas Project Electric Generating Station Emergency Plan
(TAC Nos. CAC MG0024, MG0025)
2/12/2018
Procedures
Emergency Response Organization Notification
Procedures
Emergency Notification and Response System
Procedures
Emergency Response Activities
16, 19
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP03-ZT-00139 Revision 22
(Emergency Preparedness Training Program (CR Number:
05/15/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
16-8216)
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP03-ZT-00139, Revision 22
(CR Number: 16-10746)
05/15/2017
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP03-ZA-0106, Revision 10
(CR Number: 16-11776)
11/02/2017
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP03-ZT-0139, Revision 24
(CR Number: 17-21379)
2/17/2018
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP03-ZT-0133, Revision 21
(CR Number: 16-15005)
11/08/2018
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP05-ZV-0014, Revision 19
(CR Number: 19-2630)
03/06/2019
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP05-ZV-0007, Revision 12
(CR Number: 18-13132)
04/01/2019
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP05-ZV-0014 Revision 16
(CR Number: 17-13142)
05/02/2017
Miscellaneous
0010, Form 1
Screen Evaluation Form - 0PGP05-ZV-0014 Revision 16
(CR Number: 15-25466)
05/02/2017
Miscellaneous
0010, Form 1
Screen Evaluation Form - Replacement of the Primary and
Backup Meteorological Computer Systems with Met Ones
New Datalogger System (CR Number: 10-22057)
11/06/2017
Miscellaneous
0010, Form 2
Effectiveness Evaluation Form - Replacement of the
Primary and Backup Meteorological Computer Systems with
Met Ones New Datalogger System (CR Number: 10-22057)
11/06/2017
Miscellaneous
0010, Form 2
Effectiveness Evaluation Form - 0PGP05-ZV-0014 Revision
(CR Number: 15-25466)
05/02/2017
Miscellaneous
0010, Form 2
Effectiveness Evaluation Form - 0PGP05-ZV-0014 Revision
(CR Number: 17-13142)
05/02/2017
Miscellaneous
ZV-0023
CFR 50.54(q) Screening Reference Document
Procedures
Emergency Plan Change
Corrective Action
Documents
Condition Reports
17-13348, 17-15868, 17-15956, 17-15971, 17-15974, 17-
17871, 17-18119, 17-19651, 17-19752, 17-20107, 17-
20476, 17-20654, 17-23016, 17-23048, 17-23150, 17-
23153, 17-23340, 17-23812, 17-23936, 18-00021, 18-
00745, 18-02642, 18-02752, 18-02758, 18-05590, 18-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
05947, 18-05948, 18-06280, 18-06387, 18-07599, 18-
07662, 18-07669, 18-07953, 19-01602, 19-02390, 18-
2782, 18-02790, 18-04072, 18-06526, 18-09002, 18-
06610, 19-00803, 19-04749, 19-05986, 19-06149, 19-
06637, 19-07274, 19-07433, 19-07455, 19-07467, 19-
07557, 19-07558
Miscellaneous
Environmental Sampling Drill Final Report, September 28,
2017
11/29/2017
Miscellaneous
Environmental Sampling Drill Final Report, June 13, 2018
11/12/2018
Miscellaneous
2017 Health Physics Drill, Final Report, August 17, 2017
10/02/2017
Miscellaneous
2018 Health Physics Drill, Final Report, December 13, 2018
2/27/2018
Miscellaneous
South Texas Project After Action Report/Improvement Plan,
Drill Date - October 31, 2017, Radiological Emergency
Preparedness (REP) Program
10/31/2017
Miscellaneous
After Action Report/Improvement Plan, Exercise Date -
March 8, 2018, Radiological Emergency Preparedness
(REP) Program
04/25/2018
Miscellaneous
Combined Functional Drill, Final Report, Blue Team, June
21, 2017
09/13/2017
Miscellaneous
Combined Functional Drill, Final Report, Red Team, October
25, 2017
11/29/2017
Miscellaneous
Combined Functional Drill, Final Report, White Team,
November 8, 2017
11/29/2017
Miscellaneous
Combined Functional Drill, Final Report, Blue Team, March
1, 2018
04/09/2018
Miscellaneous
Ingestion Pathway Evaluated Exercise, Final Report, Blue
Team, June 12, 2018
11/08/2018
Miscellaneous
Combined Functional Drill, Final Report, Red Team, August
1, 2018
11/08/2018
Miscellaneous
Combined Functional Drill, Final Report, White Team,
September 19, 2018
11/11/2018
Miscellaneous
Matagorda County/STP Emergency Information
2/28/2017
Miscellaneous
Matagorda County/STP Emergency Information
11/15/2018
Miscellaneous
2017 South Texas Project, Onsite Medical Drill, In
2/14/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Conjunction with the FEMA MS-1 Medical Exercise
Miscellaneous
2017 Health Physics Drill Final Report, November 14, 2017
2/20/2018
Miscellaneous
Emergency Preparedness Training Program
Miscellaneous
0014, Form 16
State of Texas/Matagorda County Annual Review of the
STPEGS Emergency Action Levels
08/15/2017
Miscellaneous
0014, Form 16
State of Texas/Matagorda County Annual Review of the
STPEGS Emergency Action Levels
10/30/2018
Miscellaneous
0014, Form 2
Annual Review of the Eight-Year Exercise Master Plan
05/15/2019
Miscellaneous
Action 18-6526-1
STP DEP Peer Assessment 5/17/2018
05/23/2018
Miscellaneous
Action 19-803-1
19-803 Snapshot Self-Assessment
01/30/2019
Miscellaneous
Audit Report
Number 18-01
(EP)
STP Nuclear Operating Company, Emergency
Preparedness Quality Audit Report
03/20/2018
Miscellaneous
Audit Report
Number 19-01
(EP)
STP Nuclear Operating Company, Emergency
Preparedness Quality Audit Report
03/05/2019
Miscellaneous
CR 17-15956
Apparent Cause Evaluation, Title: 0PGP05-ZV-0010
Procedure Violations
0, 1
Miscellaneous
CR 18-2752
Apparent Cause Evaluation, Title: Combined Functional Drill
Weakness
Miscellaneous
KLD TR-1032
South Texas Project Electric Generating Station, 2018
Population Update Analysis
10/07/2018
Miscellaneous
KLD TR-956
South Texas Project Electric Generating Station, 2017
Population Update Analysis
10/08/2017
Miscellaneous
LOR-GL-0001
LOR Training Program Guidelines
Miscellaneous
Quality Monitoring
Report Number
MN-17-0-106181
2017 ERO Excellence Plan Reviews
05/08/2017
Miscellaneous
Quality Monitoring
Report Number
MN-17-0-106443
Monthly Meeting Between Quality and Emergency
Response Division (ERD) Management
10/31/2017
Miscellaneous
Quality Monitoring
Report Number
ERO Performance at the JIC During the 10/25/2017 Red
Team Combined Function Drill
11/07/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MN-17-0-106445
Miscellaneous
Quality Monitoring
Report Number
MN-17-0-106505
Monitored Activities in the EOF During the 10/25/2018 Red
Team Combined Function Drill
2/12/2017
Miscellaneous
ZV-0019
Scenario Design and Development
Procedures
0ERP01-ZV-TP01 Offsite Dose Calculations
Procedures
0ERP01-ZV-TS01 TSC Manager
Procedures
0ERP02-ZV-TS04 Radiological Manager
Procedures
0PGP03-HU-0001 Human Performance (HU) Program
Procedures
Equipment Important to Emergency Response
Procedures
Condition Reporting Process
Procedures
0002A
CAQ Resolution Process
Procedures
0002B
Station Cause Analysis Program
Procedures
Emergency Response Exercises and Drills
Procedures
00012
Emergency Facility Inventories
Procedures
CAP-0003
Condition Report Screening
2, 3
Procedures
WCG-0002
Work Management Scheduling
Procedures
ZV-0027
Drill and Exercise Performance Objectives and
Demonstration Criteria
Work Orders
Work Orders
479729, 541207, 560754, 570554, 572441, 577844,
584001, 584397, 585912, 589224, 594004, 596357,
599933, 612012
71151
Miscellaneous
09/04/2018
71151
Miscellaneous
08/14/2018
71151
Miscellaneous
Remediation, LOR 184 DEP Drill
08/16/2018
71151
Miscellaneous
03/27/2019
Corrective Action
Documents
CR-YYYY-NNNN
2015-18885, 2017-15182, 2017-23544, 2018-995,
2018-8533, 2018-1108, 2018-12813, 2018-15270,
2018-15273
Drawings
5Q159F00045#1
Piping & Instrumentation Diagram Standby Diesel Generator
Fuel Oil Storage & Transfer System
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
5Q159F00045#1
Piping & Instrumentation Diagram Standby Diesel Fuel Oil
10