IR 05000498/2019004
| ML20029F018 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/29/2020 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2019004 | |
| Preceding documents: |
|
| Download: ML20029F018 (40) | |
Text
January 29, 2020
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2-INTEGRATED INSPECTION REPORT 05000498/2019004 AND 05000499/2019004
Dear Mr. Powell:
On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On January 23, 2020, the NRC inspectors discussed the results of this inspection with Ms. K. Harshaw, Vice President Regulatory Affairs and General Counsel, and other members of your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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 Electric Generating Station, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment 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 Electric Generating Station, Units 1 and 2.
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000498 and 05000499
License Numbers:
Report Numbers:
05000498/2019004 and 05000499/2019004
Enterprise Identifier: 1-2019-004-0004
Licensee:
Facility:
Location:
Inspection Dates:
Inspectors:
Approved By:
STP Nuclear Operating Company
South Texas Project Electric Generating Station, Units 1 and 2
Wadsworth, TX 77483
October 1, 2019, to December 31, 2019
B. Baca, Health Physicist
J. Choate, Resident Inspector
K. Clayton, Senior Operations Engineer
R. Kopriva, Senior Reactor Inspector
J. O'Donnell, Health Physicist
A. Sanchez, Senior Resident Inspector
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
Enclosure 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 Title 10 of the Code of Federal Regulations 2.390, "Public
Inspections, Exemptions, Requests for Withholding."
Docket Nos. 05000498 and 05000499
License Nos. NPF-76 and NPF-80
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Sincerely,
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated 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 NRC's 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 Report a Chanqe in Medical Condition of a Licensed Operator Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable NCV 05000499,05000498/2019004-01 Not Applicable 71111.11 B Open/Closed The inspectors identified a Severity Level IV non-cited violation of 10 CFR 55.25,
"Incapacitation Because of Disability or Illness," for the licensee's failure to notify the NRC within 30 days of a chanqe in a licensed operator's medical condition.
Failure to Perform a Risk Assessment Prior to Performing Maintenance Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green
[H.5] -Work 71152 NCV 05000498/2019004-02 Management Open/Closed The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.65(a)(4) when the licensee failed to perform a risk assessment prior to performing maintenance. Specifically, inspectors identified breaker relay calibrations being performed on protected equipment in Unit 1 during the 345kV North bus outage.
Inadequate Work Instruction Results in Loss of Spent Fuel Pool Cooling Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green
[H.8] -
71152 NCV 05000499/2019004-03 Procedure Open/Closed Adherence A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 9, was identified for the failure to provide adequate work instruction for maintenance associated with an emergency diesel generator sequencer and resulted in a loss of spent fuel pool cooling. Specifically, the licensee failed to identify the correct replacement part for the train C sequencer and once installed, resulted in a loss of all train C electrical loads, including the operating train of spent fuel pool cooling.
Inadequate Work Instructions Result in Reactor Coolant System Leaks Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green
[H.5] -Work 71152 NCV 05000499,05000498/2019004-04 Management
I Open/Closed I
I A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a was identified for the failure to provide adequate work instruction for compression fitting connections that resulted in reactor coolant system leakage. Specifically, the licensee failed to provide adequate work instructions for reconnecting high-pressure RCS instrument tubing compression fittings. This resulted in RCS leaks which required a temporary modification and a high-risk work activity to stop the leaks that threatened stable plant operations.
Failure to Follow Procedure Results in Two Inoperable Emergency Diesel Generators Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green
[H.11] -
71152 Systems NCV 05000499,05000498/2019004-05 Challenge the Open/Closed Unknown A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.s.2.a, was identified for the failure to follow an emergency diesel generator (EOG) testing procedure, which resulted in two EDGs becoming inoperable at the same time. Specifically, the licensee failed to follow Procedure OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 ), " Checklist 1,
"DG Standby Operation Checklist," Revision 70, Step 29.2, such that the train B EOG became inoperable while the train A EOG was inoperable.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire period.
Unit 2 began the inspection period at 98 percent thermal power due to coast down operations.
On October 4, 2019, Unit 2 commenced rector shutdown to being refueling outage 2RE20 and entered Mode 3. Unit 2 entered Mode 1 on November 4, 2019, and reached rated thermal power on November 7, 2019. Unit 2 operated at or near rated power for the rest of the period.
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
External Flooding Sample (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas:
- Units 1 and 2 flood panels for component cooling water heat exchangers
- Unit 1 reactor containment building
- Electrical auxiliary building flood doors
- Essential cooling water intake structure
71111.040 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01 )
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train B essential chilled water system while train C was out of service for planned maintenance on December 16, 2019
- (2) Unit 1, condenser air removal pumps 11 and 13 while condenser air removal pump 12 was out of service due to emergent maintenance on December 17, 2019
- (3) Unit 2, train A component cooling water while train B was out of service for planned maintenance on December 18, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2, train C component cooling water, with train B out of service, while train C was relied upon for decay heat removal during the refueling outage on October 17, 2019.
71111.050 - Fire Protection Quarterly Inspection (IP Section 03.01 )
The inspectors evaluated fire protection program implementation in the following selected areas:
(1)
(2)
(3}
(4}
(5}
Unit 2, reactor containment building, Fire Area 63, on October 18, 2019 Unit 2, train A essential cooling water intake structure, Fire Area 58, on December 30, 2019 I
Unit 1, train A component cooling water, Fire Area 02 and 20, on December 30, 2019 Unit 1, train A essential cooling water intake structure, Fire Area 58, on December 31, 2019 Unit 2, train A component cooling water, Fire Area 02 and 20, on December 31, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) The inspectors evaluated internal flooding mitigation protections in Unit 2, train 8, 4160 volt switchgear room on November 20, 2019
71111.08P - lnservice Inspection Activities (PWR) PWR lnservice Inspection Activities Sample (IP Section 03.01 )
(1}
The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 15 to 28, 2019:
03.01.a - Nondestructive Examination and Welding Activities.
- 1 - Magnetic Particle Examination
- 2 - Dye Penetrant Examinations
- 6 - Ultrasonic Examinations
- 1 - Visual Examination r
On October 16, 2019, during Unit 2 refueling outage 2RE20, inservice inspections of the pressurizer 2A upper head safety nozzle N4C (nozzle designation per ISi Figure A-PRZ-1; see Attachment B) to shell weld discovered one ultrasonic testing (UT) indication. The subject indication was processed in accordance with Addendum 2 of Procedure OPGP04-ZE-0304 "lnservice Inspection Program for Welds and Component Supports." The indication was determined to be a
'
subsurface flaw and subsequently characterized within Ultrasonic Examination Reports UT-2019-031 and UT-2019-032. Article IWB-3000 of Section XI contains the criteria for the acceptance of flaws or other relevant conditions found during examination with the Acceptance Standards summarized within Table IWB-3410-1 "Acceptance Standards." For this particular location, this weld falls into Examination Category B-D (full penetration and welded nozzles in vessels); therefore, IWB-3512 acceptance standards apply. Using the flaw dimensions summarized above, and the Allowable Flaws given in Table IWB-3512-1, the flaw does not meet the acceptance standards for the aspect ratio calculated. Given this, the indication requires the use of IWB-3132.3 requiring an analytical evaluation per IWB-3600. Indications that are rejectable based on IWB-3500 can be evaluated per a detailed fracture mechanics evaluation based on IWB-3600 to demonstrate flaw acceptability.
By Letter LTR-SDA-19-095-P, Westinghouse has performed a detailed fracture mechanics evaluation in accordance with IWB-3612 and Non-Mandatory Appendix A, "Analysis of Flaws," and has shown that the indication found during 2RE20 inservice inspections is acceptable for at least 36 months (two full fuel cycles).
One gas tungsten arc welding activity was observed (control volume and chemical control system valve replacement under Work Orders 96017307 and 598944 for Weld Nos. RW0027 and FW0028).
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
- The bare metal visual inspection of the reactor vessel upper head penetrations was required to be performed during this outage, 2RE20. The inspector reviewed the following reactor head penetration visual examinations: penetration nozzles 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78, including vent pipe and general head area. Also, a direct visual was performed in those areas that had limitations for the crawler. No concerns were identified.
- The bare metal visual inspection of the bottom mounted instrumentation nozzles was performed during this outage, 2RE20. The inspector reviewed the following reactor head penetration visual examinations: Penetration nozzles 1-58. No concerns were identified.
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
- The inspector reviewed the following documents associated with boric acid leaks and evaluations:
- Evaluations: 17-18419-2, 18-11258-2, 18-6471, 19-7578-3, 19-7950
- Corrective Actions: 19-10796, 19-10798, 19-11061, 19-11062, 19-11065, 19-11066, 19-11067, 19-11072, 19-11074, 19-11075, 19-11076, 19-11111, 19-11112, 19-11113, 19-11114, 19-11160, 19-11161, 19-11163, 19-11202, 19-11219, 19-11220, 19-11221, 19-11222, 19-11223,19-11224, 19-11225 03.01.d - Mechanical Stress Improvement Process used on Reactor Vessel Hot and Cold Leg Nozzle to Safe-End Welds.
- During the 2019 Refueling Outage for Unit 2, 2RE20, the inspector witnessed the license's performance of mechanical stress improvement on the reactor vessel hot and cold leg nozzle to safe-end, dissimilar metal welds. This mechanical process helps prevent and mitigate primary water stress corrosion cracking in piping by minimally contracting the pipe on one side of the weldment, replacing residual tensile stresses with compressive stresses.
This removal of as-welded tensile stresses is an effective and permanent means to prevent or mitigate primary water stress corrosion cracking.
71111.11 B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04)
- (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on August 5, 2019.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensee's annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensee's program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensee's control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution The inspectors evaluated the licensee's ability to identify and resolve problems associated with licensed operator performance.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated an operating crew annual exam on November 26, 2019.
===71111.11 Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01 )
=
( 1 )
The inspectors observed a evaluated the performance of a Unit 1 operating crew while in an alternate 13.BkV bus alignment due to an emergent issue with the main generator output breaker preventing automatic trip of that breaker on December 11, 2019.
The inspectors observed and evaluated the performance of a Unit 1 operating crew during a high risk evolution to replace two power supplies in the train R solid state protection system on December 18, 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, essential cooling water systems on November 30, 2019
- (2) Units 1 and 2, component cooling water system on December 30, 2019
- (3) Units 1 and 2, emergency safeguards sequencer on December 30, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01 ) (4 Samples}
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 2, planned risk due to train C essential cooling water, essential chilled water, emergency core cooling, containment spray, and emergency diesel generator maintenance the week of October 1, 2019
- (2) Unit 2, emergent risk due to train C engineered safety feature load sequencer requiring a card replacement on October 28, 2019
- (3) Unit 2, emergent risk due to train A engineered safety feature load sequencer failure during a large train B work week and resulted in the use of the Configuration Risk Management Program on November 20, 2019
- (4) Units 1 and 2, planned risk due to the maintenance on the 345kV south bus and Unit 2, standby transformer and use of the Configuration Risk Management Program the week of December 4, 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 governor stem nut missing on October 21, 2019
- (2) Unit 1, train A essential chilled water due to a degraded temperature control module that failed to keep the output temperature less than 48 degrees Fahrenheit on November 8, 2019
- (3) Unit 2, damaged control room envelope door on November 11, 2019
- (4) Unit 2, train B emergency diesel generator jacket water leak on November 14, 2019
- (5) Unit 1, train A essential cooling water due to a through wall indication on flange EW-1006 due to aluminum bronze dealloying phenomenon on November 20, 2019
- (6) Unit 2, train C high head safety injection pump bearing oil level indicator installed upside down following motor replacement on November 27, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(3 Samples}
The inspectors evaluated the following temporary or permanent modifications:
- (1) Units 1 and 2, temporary diesel-driven fire pump during repair and replacement of diesel-driven fire pump components on April 15, 2019
- (2) Unit 2, temporary modification to power spent fuel pool cooling pump 2A during refueling outage 2RE20 on October 18, 2019
- (3) Units 1 and 2, permanent modification to install a quick exhaust valve to reduce the time required to close the valve on a main steam actuation signal on December 31, 2019
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01 ) (4 Samples)
The inspectors evaluated the following post maintenance tests:
( 1)
Unit 2, local leak rate test of the auxiliary containment airlock following maintenance on the sealing surfaces on October 24, 2019
.
- (2) Unit 2, local leak rate test of the normal containment purge exhaust isolation damper, 2-HC-9, following emergent maintenance following a failed local leak rate test on October 27, 2019
- (3) Unit 2, nuclear instrumentation Nl-35 following the replacement of the log amplifier module on November 3, 2019
- (4) Unit 1, reactor coolant system leak check and flow transmitter FT-0419 following the replacement of the reactor coolant system instrument tubing due to an increasing leak on December 6, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample {IP Section 03.01 ) (1 Sample)
( 1)
The inspectors evaluated refueling outage 2RE20 activities from October 4 through November 5, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01 )
- (1) Unit 1, train C essential cooling water pump surveillance test on December 14, 2019
- (2) Unit 1, train C emergency diesel generator monthly surveillance test on December 17, 2019
- (3) Unit 1, train C auxiliary feedwater pump surveillance test on December 18, 2019
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) Unit 1, FLEX diesel generator surveillance test on December 12, 2019
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample}
- (1) The licensee submitted "South Texas Project Emergency Plan," Revision ICN 20-21, as well as a copy of Revision ICN 20-22, to the NRC on August 8, 2019. The inspectors conducted an in-office review of the changes from November 13 to November 25, 2019. This evaluation does not constitute NRC approval.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 02.01 ) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
(1}
The inspectors reviewed the following:
Radiological Surveys
- Spent Fuel Pool Cell Inventory
- Concentrate Transfer Pump 1 B
- Fuel Transfer Tube Access
- Radwaste Truck Bay
- Reactor Cavity Walkway Risk Significant Radiological Work Activities
- In-Core (Thimble Tube)
- Head Lift
- Lift Rig Air Sample Survey Records
===22373
- 21434
- 21441
- 21468
- 21505 Instructions to Workers (IP Section 02.02)===
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- 2019-2-0165, 2RE20 - Maintenance and Support Work - Room 307 (LHRA)
- 2019-2-0173, 2RE20 - Maintenance on N2CVPSV3100 (LHRA)
- 2019-2-0158, 2RE20 - Reactor Head Lift Activities (LHRA)
Electronic Alarming Dosimeter Alarms
- Dose Rate Alarm - 18-04050
- Dose Rate Alarm -18-04757
- Dose Rate Alarm - 18-11562
- Dose Rate Alarm -18-12585 Labeling of Containers
- Box 300437
- Radwaste Bags
- 55 Gallon Barrel
- Box #20-2466
- OSSC#26
Contamination and Radioactive Material Control (IP Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) The inspectors verified the following sealed sources are accounted for and are intact:
- MS-0042
- MS-0132
- NAM-1335
- NCF-0604
- NCS 0114/0115
- NCS-0008
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:
- Unanticipated airborne radioactivity during 2RE20 flood-up o
RWP 2019-2-0158, 2RE20- Reactor Head Lift Activities (LHRA)o ALARA Review Package 19-3165-7, 2RE20 Non-Rapid Refuel o
DAC-hr Assessment for Condition Report 19-11442 High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)
- (1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 02.06) (1 Sample)
- (1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (IP Section 02.01 ) (1 Sample)
The inspectors evaluated airborne controls and radioactive monitoring.
( 1 )
The inspectors reviewed the following :
Installed Ventilation Systems
- Technical Support Center Temporary Ventilation System Setups
- Radwaste sorting vent hoods and associated HEPA units
- Reactor head HEPA units Portable or Installed Monitoring Systems
- Room specific AMS-4 units: Radwaste sorting room and seal table (thimble)room
- General containment monitoring with AMS-4
- Low volume filter air samples covering reactor head, cavity, and thimble work
Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)
The inspectors evaluated the licensee's use of respiratory protection devices by:
( 1)
Observing in-field applications; verifying the licensee validated the level of protection provided by the devices; inspecting the material condition of devices, reviewing records and certification of devices issued for use; reviewing the qualifications of workers that use the devices; and observing workers' donning, doffing and testing devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)
The inspectors evaluated self-contained breathing apparatus program implementation.
- (1) The inspectors reviewed the following:
Status and Surveillance Records for Self-Contained Breathing Apparatus
- SCBA kit #433
- SCBA kit #434
- SCBA kit #462
- SCBA kit #514
- SCBA kit #551 Self-Contained Breathing Apparatus Fit for On-Shift Operators The inspectors selected two on-shift Unit 2 reactor operators for verification of fit testing, medical approval, donning/doffing practical, and bottle change out protocol.
Self-Contained Breathing Apparatus Maintenance Check
- SCBA kit #434
- SCBA kit #462
- SCBA kit #514
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS09: Residual Heat Removal Systems (IP Section 02.08)===
- (1) Unit 1, October 1, 2018, through September 30, 2019
- (2) Unit 2, October 1, 2018, through September 30, 2019
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1, October 1, 2018, through September 30, 2019
- (2) Unit 2, October 1, 2018, through September 30, 2019
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) January 1, 2018, through September 30, 2019 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) January 1, 2018, through September 30, 2019
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
( 1)
The inspectors reviewed the licensee's corrective action program for potential adverse trends that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (4 Samples)
The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
- (1) The increase in the number of reactor coolant system leaks for high pressure compression fitting leading to reactor coolant system loop flow transmitters in Units 1 and 2
- (2) The failure to assess risk prior to performing maintenance on protected 13.8kV supply breaker to the train B 4.16kV switchgear while the 345kV North bus and the Unit 1 standby transformer were out of service for planned maintenance
- (3) Inadequate work instruction on Unit 2, train C engineered safety feature load sequencer results in the loss of spent fuel pool cooling
- (4) The Unit 1, train B emergency diesel generator was rendered inoperable by a human performance error
INSPECTION RESULTS
Failure to Report a Change in Medical Condition of a Licensed Operator Cornerstone Severity Cross-Cutting Not Applicable Severity Level IV NCV 05000499,05000498/2019004-01 Open/Closed Aspect Not Applicable Report Section 71111.11 B The inspectors identified a Severity Level IV non-cited violation of 10 CFR 55.25, "Incapacitation Because of Disability or Illness," for the licensee's failure to notify the NRC within 30 days of a change in a licensed operator's medical condition.
Description:
On June 19, 2014, a senior reactor operator self-reported to the site medical department the diagnosis of a new medical condition. The licensee recorded the new medical condition in the operator's site medical record and drafted a new NRC Form 396 to report a "no solo". condition was being added on the license. The new Form 396 was lost in the review and approval process on site, and at the time there was not a tracking mechanism in place to ensure the review and approval process was completed. As a result, the new Form 396 was never provided to the NRC.
While reviewing a license renewal application, an inspector identified that a "no solo" restriction that had not previously been reported to the NRC was included on the NRC Form 396 that was submitted with the license renewal application. The NRC notified the licensee of the discrepancy on October 8, 2019. The licensee confirmed that site records reflected a "no solo" condition had been added for the individual. The licensee determined that the senior reactor operator had not been on shift since the condition was reported in 2014.
Corrective Actions: On October 17, 2019, the South Texas Project Nuclear Operating Company submitted a letter to the NRC with a revised NRC Form 396, "Certification of Medical Examination by Facility Licensee," that prohibited solo operation of the controls. The "no solo" condition was required for fitness-for-duty reasons in accordance with the American National Standards Institute (ANSl)-3.4-1983, "Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants,"
Corrective Action References: Condition Report 2019-11414
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency.
Enforcement:
The ROP's significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRC's ability to regulate using traditional enforcement to adequ~tely deter non-compliance.
Severity: The inspectors determined the violation to be a Severity Level IV violation, similar to Example 6.4.d.1.b in the NRC Enforcement Policy because it was a nonwillful compromise of an examination required by 10 CFR Part 55. Specifically, the licensee nonwillfully failed to inform the NRC of a change in an operator's medical condition. The individual did not perform the functions of a senior reactor operation while having a disqualifying medical condition.
Violation: Title 10 CFR 55.25 requires, in part, that if a licensed senior reactor operator develops a permanent physical condition that causes the licensee to fail to meet the requirements of 10 CFR 55.21, the facility shall notify the Commission within 30 days of learning of the diagnosis. For conditions where a license condition is required, the facility licensee must provide medical certification on NRC Form 396, "Certification of Medical Examination by Facility Licensee." Contrary to the above from June 9, 2014, to October 17, 2019, the licensee failed to notify the Commission, within 30 days of learning the diagnosis of a change in medical condition of a licensed senior reactor operator that developed a permanent physical condition that caused the licensed senior reactor operator to fail to meet the requirements of 10 CFR 55.21. Specifically, on June 9, 2014, a senior reactor operator self-reported a new medical condition, the medical department determined that the individual required a "no solo" condition on his license, but the NRC did not receive the revised NRC Form 396 until October 17, 2019.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Perform a Risk Assessment Prior to Performinq Maintenance Cornerstone Significance Cross-Cutting Initiating Events Green NCV 05000498/2019004-02 Open/Closed Aspect
[H.5]-Work Management The inspectors identified a Green finding and associated non-cited violation Report Section 71152 of 10 CFR 50.65(a)(4) when the licensee failed to perform a risk assessment prior to performing maintenance. Specifically, inspectors identified breaker relay calibrations being performed on protected equipment in Unit 1 during the 345kV North bus and Unit 1 standby transformer planned maintenance.
Description:
The South Texas Project 345kV switchyard consists of two 345kV buses, North and South. Each of the buses in the switchyard supplies offsite power to the Units 1 and 2 standby transformers. These transformers constitute an offsite power source. On April 30, 2018, while the North bus and the Unit 1 standby transformer were out of service for planned maintenance activities, which placed the station in the configuration risk management program, the inspectors performed a walkdown of the protected equipment due to the maintenance. Specifically, the inspectors walked down all protected electrical power supplies, including the 13.8kV Standby bus in Unit 1. There, inspectors discovered two electricians performing relay calibrations on the 13.8kV standby bus 1 G to the 4.16kV Aux EAB XFMR E 1 B breaker. The inspectors determined that the work could have resulted in a trip of the breaker and would present a loss of offsite power to the train B 4.
16kV switchgear which would result in an auto start signal to the train B emergency diesel generator. The inspectors observed the work activity for a while to ensure the activity was being performed with quality before heading to the work start desk to inquire why the work was allowed to take place.
The inspector asked if the work start personnel were aware of the current plant condition and the heightened level of awareness for protected equipment due to the maintenance and why the observed relay work was approved. The work start personnel stated that it was in the approved work schedule, so permission was granted. The inspector then spoke with the work week coordinator and presented the situation observed. The work week coordinator stated that the work should not have been given permission to start and that the work activity should not be on the schedule. It had somehow been missed in the work schedule scrub for the work week for the given plant condition. The work week coordinator initiated Condition Report 2018-6019.
The licensee determined that the relay calibration for the supply breaker should not have been allowed and should not have been on the schedule. The work planning schedule reviews (multiple reviews) by maintenance, engineering, planning, and operations failed to identify and remove the activity from the schedule.
Corrective Actions: The licensee held discussions with work control specifically to inform them of the condition report, the NRC observation, and stressed the need to thoroughly review work during the work planning process.
Corrective Action References: Condition Report 2018-6019
Performance Assessment:
Performance Deficiency: The failure to perform a risk assessment prior to performing maintenance activities was a performance deficiency. Specifically, the licensee failed to perform a risk assessment prior to allowing relay work on the Unit 1 13.8kV standby bus 1 G to 4.16kV Aux EAB XFMR E1 B (train B 4.16kV switchgear) while these components were protected for 345kV North bus and Unit 1 standby transformer planned maintenance.
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 failure to perform a risk assessment on the relay calibration activity prevented proper controls to be implemented if the work activity was deemed necessary, as such the licensee unknowingly increased the likelihood of upsetting the stability of the plant.
Significance: The inspectors assessed the significance of the finding using Appendix K, "Maintenance Risk Assessment and Risk Management SDP." In accordance with Step 4.1.1, "Licensee Evaluation of Risk," the inspectors reviewed the licensee's risk evaluation that indicated no additional numerical risk as a result of the additional maintenance activity because the activity was not intended to open the associated breaker. The licensee's risk assessment tools do not include an increase in the probability that equipment being worked on will be lost from a postulated maintenance error. Given this notable limitation with the licensee's configuration risk assessment tool, the inspectors requested the regional senior reactor analyst to independently evaluate the risk. The analyst evaluated the bounding risk related to a loss of offsite power to Bus E1 B. The analyst determined this failure would not result in a plant transient and would not affect the other two Unit 1 trains being supplied by offsite power. The analysis indicated that the availability of other redundant trains, emergency onsite power, and the short period of time that offsite power would have been unavailable given a maintenance error, resulted in a very low risk deficit (incremental core damage probability). Therefore, this finding is of very low safety significance (Green).
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee failed to implement the process of planning, controlling and executing work activities such that nuclear safety is the overriding priority. The work control process did not identify and manage the risk for the 13.8kV standby bus 1 G breaker to the 4.16kV Aux EAB XFMR EIB relay work activity.
Enforcement:
Violation: Title 10 CFR 50.65 (a)(4) states, in part, "before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activiti~s... " Contrary to the above, on April 30, 2018, before performing maintenance, the licensee failed to assess and manage the increase in risk that may result from proposed maintenance activities. Specifically, the inspectors discovered that the licensee performed relay calibration maintenance activities on the Unit 1, 13.8kV standby bus 1 G to 4.16kV Aux EAB XFM R E 1 B (train B 4.16kV switchgear) without a risk assessment as required by 10 CFR 50.65(a)(4).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Work Instruction Results in Loss of Soent Fuel Pool Cooling Cornerstone Significance Cross-Cutting Aspect Barrier Integrity Green
[H
.8 ] -
NCV 05000499/2019004-03 Procedure Ooen/Closed Adherence,
Report Section 71152 A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 9, was identified for the failure to provide adequate work instruction for maintenance associated with an engineered safety feature load sequencer and resulted in a loss of spent fuel pool cooling. Specifically, the licensee failed to identify the correct replacement part for the train C engineered safety feature load sequencer, and once installed resulted in a loss of all train C electrical loads, includinq the operatinq train of spent fuel pool coolinq.
Description:
On October 24, 2019, Unit 2 was in Mode 6 coming out of the refueling outage with the core reloaded and one of two trains of spent fuel pool cooling in service when an annunciator in the control room indicated an issue with the train C engineered safety feature load sequencer. Work Planning developed a work order to remove and replace opto-isolators in the sequencer as part of troubleshooting. Work Planning wrote the work order procedure and ordered the parts from the warehouse to be delivered to the craft in their shop but used the wrong stock code. Per the vendor drawings, opto-isolator model 0DC-24A was supposed to be used (stock code 596-849). Instead, the work order and parts order referenced stock code 596-775 which is for opto-isolator model ODC-24. While the two models appear very similar, 0DC-24A allows an output of 125VDC while the ODC-24 allows only 24VDC.
Instrumentation and control technicians went to the sequencer to replace the opto-isolators as part of troubleshooting. When they removed the original opto-isolators (0DC-24A), the technicians noted the "A" on the original components which were not present on their replacements (ODC-24). Neither of the technicians could recall what the "A" represented, and the work order did not explicitly provide the opto-isolator model (0DC-24A vs. ODC-24),only the stock code which is not printed on the actual parts. The technicians installed the replacement opto-isolator into the enqineered safety feature load sequencer and the sequencer immediately shed all electrical loads from the train C electrical bus. With the train C EDG in pull-to-stop for the sequencer troubleshooting, all train C electrical loads were lost including the single train of spent fuel pool cooling that was in operation at the time.
Annunciators in the control room alerted operators the loads on the train C electrical bus were lost, and one of those loads was spent fuel pool cooling. Operators restored spent fuel pool cooling within 30 minutes with no rise in spent fuel pool water temperature. Operators took the train C EDG out of pull-to-stop the EDG automatically started and loaded the bus without issue. The core never lost residual heat removal as trains A and B were in service at this time. The licensee made an 8-hour report to the NRG on October 25, 2019, at 3:24 a.m. for a valid engineered safety feature actuation signal (Event Notification 54351 ).
The licensee initiated Condition Report 2019-12401 to investigate the event. The apparent cause determined that work control failed to provide adequate work instruction by identifying the wrong part to be installed jn the Unit 2, train C engineered safety feature load sequencer.
The licensee determined that the planners failed to use a reference Procedure, WCG-0003, "Planner's Guide," Revision 39, that would have required this issue to be elevated to an emergent issue requiring multiple stakeholders to meet to review the planned work.
Furthermore, the cause evaluation determined that maintenance technicians failed to follow the maintenance conduct of operations procedure and compare parts and stop work if there are any discrepancies.
Corrective Actions: The licensee counseled the technicians and work planners involved and a lessons learned document was written and discussed with planning and maintenance. The licensee has also included this event as a case study for their mechanical maintenance training with an emphasis on verifying like-for-like parts.
Corrective Action References: Condition Reports 2019-12372 and 2019-12401
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instruction for maintenance associated with an engineered safety feature load sequencer, which resulted in a loss of spent fuel pool cooling, was a performance deficiency. Specifically, the licensee failed to identify and incorporate accurate component information when planning work on the train C engineered safety feature load sequencer.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to properly pre-plan and perform maintenance on the train C engineered safety feature load sequencer caused a loss of all electrical loads associated with the train C electrical bus. As a result, the single operating train of spent fuel pool cooling was lost.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The Significance Determination Process (SDP) for Findings At-Power." Specifically, the finding did not cause the spent fuel pool (SFP) temperature to exceed its maximum analyzed temperature limit, did not result in a detectible release of radionuclides, did not result in a loss of SFP water inventory below the SFP's minimum analvzed level limit, and did not affect the SFP neutron absorber, fuel bundle loading pattern, or soluble boron concentration; therefore, the findings were determined to be of very low safety significance, Green.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, work planning failed to follow appropriate procedures to ensure multi-discipline participation to determine a proper plan of action and in assembling adequate work instructions to repair the Unit 2, train C engineered safety feature load sequencer without challenqing the plant equipment.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires, in part, that written procedures shall be established, implemented, and maintained in accordance with Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9 of Appendix A to Regulatory Guide 1.33, Revision 2, 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 appropriate to the circumstances."
Contrary to the above on October 24, 2019, the licensee failed to properly pre-plan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to identify and request the correct replacement parts for the Unit 2, train C engineered safety feature load sequencer. As a result, Unit 2, lost all train C electrical loads, including the single operating train of spent fuel pool cooling.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Work Instructions Result in Reactor Coolant System Leaks Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green
[H.5] -Work 71152 NCV 05000499,05000498/2019004-04 Management Open/Closed A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a was identified for the failure to provide adequate work instruction for compression fitting connections that resulted in reactor coolant system (RCS) leakage. Specifically, the licensee failed to provide adequate work instructions for reconnecting high-pressure RCS instrument tubing compression fittings. This resulted in RCS leaks which required a temporary modification and a high-risk work activity to stop the leaks that threatened stable plant operations.
Description:
At South Texas Project, each RCS primary loop has three independent flow transmitters that would input into the reactor protection system to trip the reactor if 2 out of 3 flow transmitters in a single loop were to read less than 92 percent. Per Technical Specification 3.3.1, each channel could be bypassed for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> then the channel would have to be restored or placed into a "Trip" condition.
On August 29, 2018, Unit 2, field operators inside containment identified an active RCS leak at RCS flow transmitter RC-FT-0428 (loop B flow transmitter). Specifically, the leak was almost a steady stream of fluid, apparently emanating from a tubing fitting. Condition Report 2018-10183 was written to note the deficiency. Later that year, a temporary modification was installed to encapsulate the leaking tube fitting and injected with leak stop until the leak was arrested. Operations installed a camera to periodically monitor the leak for degradation. The modification was planned to be removed, and tubing and fittings replaced during the next Unit 2, refueling outage in October 2019.
On November 14, 2018, Unit 1 field operators inside containment identified an active RCS leak at RCS flow transmitter RC-FT-0419 (loop A flow transmitter). Specifically, the leak was approximately a two-foot steam plume. Condition Report 2018-13993 was written to note the deficiency. The licensee gained alignment to tighten the tubing connection, which was a high-risk work activity. The tubing connection was successfully tightened, which reduced the steam plume to several milliliters per minute leak. Operations installed a camera to periodically monitor the leak for degradation. In addition, operations collected actual leak rates from this tube connection. Due to the tubing configuration, a temporary modification to install an encapsulating box as was done for the loop B flow transmitter was not feasible and would have to be repaired in the next Unit 1, refueling outage in March 2020. However, prior to the refueling outage, the leak began to get worse and engineering was tasked with developing a repair solution. On December 6, 2019 the licensee successfully replaced the leaking connection and tubing while at 100 percent power without perturbating the Unit. This was a high-risk evolution that could have resulted in a reactor trip.
On November 24, 2018, Unit 1 operators identified that RCS flow transmitter RC-FT-0449 (loop D flow transmitter) would periodically exceed its three percent channel checks with the other two loop D flow transmitters, RC-FT-0447 and RC-FT-0448. Condition Report 2018-14266 was written to document the deficiency. It was determined that the flow transmitter RC-FT-0449 was over ranged following a repair of a fitting leak identified at the end of the refueling outage, while in Mode 3. This issue would have to be addressed in the next Unit 1, refueling outage in March 2020.
The licensee initiated Condition Report 2018-14369 to evaluate the current trend of RCS tubing compression fitting leaks as well as search for tubing leaks for the last four refueling outages. The licensee's evaluation identified approximately 44 compression fitting issues dating back to 2015. The common cause concluded that the leaks were a result of improper assembly of Parker CPI compression fittings due to inadequate guidance in procedure OPGP03-ZE-0056, "Instrumentation Installation," Addendum 7, "Installation Instructions for Compression Fittings." In addition, the licensee determined that there was inconsistent work instruction rigor for re-making these fittings in maintenance packages and some relied on skill of the craft. It was also determined that the procedure did not incorporate vendor recommendations on reassembly and did not use proper gages and other reassembly tools.
Corrective Actions: The licensee enhanced procedure OPGP03-ZE-0056, 'Tubing and Instrumentation" to reflect vendor recommendations for reassembly and the use of proper tools. Training was identified and implemented to those maintenance workers who have this certification. Lastly, the licensee revised portions of the procedure to "in-hand" use to ensure compliance.
Corrective Action References: Condition Reports 2018-10183, 2018-13993, 2018-14266, and 2018-14369.
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instruction for reassembly of tubing compression fittings was a performance deficiency. Specifically, maintenance activities of installing and reinstalling Parker tubing compression fittings without adequate guidance resulted in repetitive RCS tubing leaks, which challenged stable plant operations.
Screening: The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and 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 failure to provide adequate work instructions to repair, remake, replace Parker tubing compression fittings, resulted in RCS tubing leaks and instrument inaccuracies that unduly challenged stable plant operations and high risk work evolutions to mitigate and repair during the operational cycle.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The Significance Determination Process (SOP) for Findings At-Power." Specifically, the finding (1 )could not result in exceeding RCS leak rate for a small LOCA;
- (3) did not cause a reactor trip and the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (Transient Initiators), therefore, the finding was determined to be of very low safety significance, Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the work planning organization failed to ensure that quality work instruction products were provided to the workforce to execute activities such that nuclear safety was the overriding priority.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires in part, that written procedures shall be established, implemented, and maintained in accordance with Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9, "Procedures for Performing Maintenance,"
of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, 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 appropriate to the circumstances. The licensee established procedure OPGP03-ZE-0056, "Instrumentation Installation," Addendum 7, "Installation Instructions for Compression Fittings," to meet that requirement for installing compression fitting on safety-related, reactor coolant system tubing connections. Contrary to the above, from March 23, 2015 to August 14, 2019, the licensee failed provide adequate work instructions to properly install compression fittings on safety-related reactor coolant system tubing connections. As a result, multiple leaks were discovered on both units which challenged stable plant operations.
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 Two Inoperable Emerqencv Diesel Generators Cornerstone Significance Cross-Cutting Report Mitigating Systems Aspect Section Green
[H.11]-
71152 NCV 05000499,05000498/2019004-05 Challenge the Open/Closed Unknown A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.s.2.a, was identified for the failure to follow an emergency diesel generator (EOG) testing procedure, which resulted in two EDGs becoming inoperable at the same time. Specifically, the licensee failed to follow procedure OPOP02-DG-0001, "Emergency Diesel Generator 11(21)," Checklist 1, "DG Standby Operation Checklist," Revision 70, Step 29.2, such that the train B EOG became inoperable while the train A, EOG was inoperable.
Description:
Unit 1 at South Texas Project has three trains of EDGs. On May 23, 2019, operations personnel began restoring the train A, EDG following planned maintenance using OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 )," Checklist 1, "DG Standby Operation Checklist," Revision 70. A non-licensed operator was sent to the train A, EOG local panel to perform step 29.2, which states "DEPRESS both 'EMERGENCY STOP CIRCUIT' RESET pushbuttons." However, the non-licensed operator inadvertently went to the train B, EOG local panel, depressed the "STOP" pushbuttons after depressing the "RESET" pushbuttons, and did not receive an expected response. The control room immediately received unexpected alarms indicating a malfunction with the starting circuit for the train B, EDG and causing the EOG to become inoperable. With both the trains A and B, EDGs inoperable, Unit 1 entered Technical Specification 3.8.1.1.e with a 24-hour LCO action statement to restore at least one inoperable EOG to operable status, or apply the requirements of the Configuration Risk Management Program, 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 />.
The control room staff immediately investigated the unexpected alarms and identified that the issue with the starting circuit for the train B EOG was the result of human error. Another non-licensed operator restored the starting circuit for the train B EOG. The control room declared the train operable within 30 minutes of the train being made inoperable, exiting the 24-hour LCO action statement.
Corrective Actions: Operations counseled the non-licensed operator and issued a site wide Lessons Learned emphasizing the importance of taking the correct action on the correct train.
Corrective Action References: Condition Report 2019-5842
Performance Assessment:
Performance Deficiency: The failure to implement maintenance procedures involving safety-related equipment was a performance deficiency. Specifically, a non-licensed operator failed to implement procedure OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 )," on the correct EOG train and failed to manipulate the correct pushbuttons on the EOG local panel.
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 conseauences. Specificallv, the failure to implement maintenance procedures involving the emergency diesel generators caused a second train of EOG to be made inoperable. As a result, on May 23, 2019, Unit 1 entered into an unplanned 24-hour shutdown action statement for both train A and B emergency diesel generators being inoperable.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The Significance Determination Process (SOP) for Findings At-Power." Specifically, the finding did not cause an actual loss of function of at least a single train for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The train B emergency diesel generator was restored to operable within 30 minutes.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the non-licensed operator failed to stop after depressing the "RESET pushbuttons on the emergency diesel generator local panel and not receiving an expected response. Operations also failed to evaluate and manage the risk of sending a newly qualified non-licensed operator to perform a first-time evolution without supervision or assistance.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires, in part, that written procedures shall be established, implemented, and maintained in accordance with Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 3.s.2.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that instructions for energizing, startup, shutdown, and changing modes of operation should be prepared for emergency power sources (e.g.,
diesel generators). The licensee established OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 }," Revision 70, to meet the Regulatory Guide 1.33 requirement. Checklist 1, "DG Standby Operation Checklist," step 29.2 of the OPOP02-DG-0001 procedure states, "DEPRESS both 'EMERGENCY STOP CIRCUIT' RESET pushbuttons." Contrary to the above, on May 23, 2019, a non-licensed operator depressed both "EMERGENCY STOP CIRCUIT" RESET pushbuttons for the incorrect EOG train and depressed an additional set of pushbuttons after not receiving the expected response from the RESET pushbuttons.
Specifically, the licensee depressed the RESET and STOP pushbuttons for the Unit 1, train B EOG. As a result, the train B, EOG was made inoperable during a time period where train A, EOG was inoperable for maintenance, and operations made an unplanned entry into Technical Specification 3.8.1.1.e, a 24-hour 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.
Observation: Semi-annual Trend Review I 71152 The inspectors reviewed the licensee's corrective action program entries, maintenance activities, emergent maintenance issues, plant health reports, outage performance reviews, NRC generated condition reports, and NRC inspector walk downs.
The inspectors noted and documented the following issues and trends:
- There are site wide issues with procedure use and adherence. Inspectors have identified numerous issues while performing inspections (minor violations). Some of these include signing work order steps complete before the step was complete, equipment for risk significant work requiring entry into the Configuration Risk Management Program were not properly protected, inadequate independent verification of procedure steps, and failure to construct scaffolding in accordance with orocedural quidance. In addition to these observations, the licensee identified similar issues as illustrated in the South Texas Project 2019 mid-cycle review. The licensee completed a common cause evaluation and is in the process of implementing corrective actions.
- There have been several nuclear instrumentation issues and challenges, especially during the last few outages. These issues have resulted in issuance of a Licensee Event Report; an NRG-identified technical specification violation; and several emergent issues that have challenged operations (making technical specification calls), maintenance resources, and outage schedule delays and changes. The licensee has entered the issues into the corrective action program to perform an analysis and prescribe corrective actions, which is scheduled for completion in February 2020.
- The licensee has recently experienced several issues involving engineered safety feature load sequencers. A13art from one self-revealed technical specification violation
( documented in this report in Section 71152), the licensee.handled each issue appropriately and without issue. In conjunction with the inspector observations, the licensee had also identified a possible trend and entered the issue into the corrective action program for analysis. The analysis is scheduled for completion in February
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 24, 2019, the inspectors presented the Occupational Radiation Safety inspection results to Ms. K. Harshaw, Vice President Regulatory Affairs and General Counsel, and other members of the licensee staff.
- On October 28, 2019, the inspectors presented the in service inspection results to Mr. J. Connolly, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.
- On November 25, 2019, the inspectors presented the Emergency Plan In-Office Review inspection results to Mr. J. Enoch, Manager, Emergency Response, and other members of the licensee staff.
- On December 17, 2019, the inspectors presented the failure to report a change in medical condition of a licensed operator inspection results to Mr. L. Sterling, Regulatory Affairs Manager, and other members of the licensee staff.
- On December 19, 2019, the inspectors presented the biennial operator requalification inspection results to Mr. D. Breland, Supervisor, Operations Training, and other members of the licensee staff.
- On January 23, 2020, the inspectors presented the integrated inspection results to Ms. K. Harshaw, Vice President Regulatory Affairs and General Counsel, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
71111.040 Drawings
5R209F05017#2
Piping and Instrumentation Diagram Component Colling
Water System
5R289F05038#1
Piping and Instrumentation Diagram Essential Cooling Water 20
System Train 1 B
5V119V10001#1
Piping and Instrumentation Diagram Essential Chilled Water
System
8T219F00031#1
Piping and Instrumentation Diagram Condenser Air Removal
Procedures
OPOP02-CC-OOO 1 Component CoolinQ Water
OPOP02-CH-OOO 1 Essential Chilled Water System
OPOP02-CR-OOO 1 Main Condenser Air Removal
Corrective Action
CR-YYYY-NNNN
2019-11970
2019-12022
2019-11969
2019-12023
Documents
Drawings
5R209F05019#2
Piping and Instrumentation Diagram Component Cooling
Water System
5R209F05020#2
Piping and Instrumentation Diagram Component Cooling
Water System
Procedures
OMAB02-FP-0128
Fire Preplan Mechanical Auxiliary Building CCW Pump and
Chiller, Train A
OMAB20-FP-0129
Fire Preplan Mechanical Auxiliary Building Non-Radioactive
Pipe Chase
OMAB27-FP-0142
Fire Preplan Mechanical Auxiliary Building CCW Heat
Exchangers
Fire Preplan Essential Cooling Water Intake Structure Pump
0600
Room Train A
71111.050 Procedures
OMAB02-FP-O 128
Fire Preplan Mechanical Auxiliary Building CCW Pump and
Chiller, Train A
OMAB20-FP-O 129
Fire Preplan Mechanical Auxiliary Building Non-Radioactive
Pipe Class
ORCB63-FP-0211
Fire Preplan Reactor Containment Building SW Peripheral
Area
ORCB63-FP-0212
Fire Preplan Reactor Containment Building NW Peripheral
Area
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
ORCB63-FP-0213
Fire Preplan Reactor Containment Building NE Peripheral
Area
Fire Preplan Essential Cooling Water Intake Structure Pump
0605
Room Train A
Calculations
NC9701
Flooding Analysis: Electrical Auxiliary Building
Drawings
Mechanical & Electrical Auxiliary Building Section C-C Area
H
Mechanical Electrical Auxiliary Building Plan @ EL. 35'-0"
Area H
6M189N05024
Mechanical Electrical Auxiliary Building Plan@ E
Area J
Plumbing - M.E.A.B. Floor Plan EL. 35'-0" Area 18 & 19
9M131A01030
Mechanical and Electrical Auxiliary Floor Plan EL. 1 O' -0" Unit 17
9M131A01033
Mechanical and Electrical Auxiliary Building Floor Plan at
Elev. 35'-0" and 41'-0
Corrective Action
CR -YYYY-NNNN
2015-20733, 2017-13869, 2017-18341, 2018-6845,
Documents
2019-6008,
2019-7950,
2019-11368, 2019-11675,
2019-11865, 2019-12194, 2019-12243, 2019-12291,
2019-12444
Drawings
E10025E58
South Texas Units 1 & 2 Closure Head General Assembly
Interface Inf. for RRVCH
SB-9406-HL5007
Snubber and Mountinc::i Supports
Miscellaneous
South Texas Project, Units 1 AND 2 -Request for Relief RR-
04/05/2011
ENG-3-02 from ASME Code Requirements for Reactor
Pressure Vessel Insert Non-Destructive Examination {TAC
NOS. ME4764 AND ME4765)
South Texas Project, Unit 2 - Request for Relief NO. RR-
06/30/2016
ENG-3-20 for Extension of the Inspection Frequency of the
Reactor Vessel Cold-Leg Nozzle to Safe-End Welds with
Flaw Analysis (CAC NO. MF7428)
AE-NOC-
South Texas Project, Units 1 and 2 - Request for Relief RR-
09/10/2012
2002347
ENG-3-04 to Apply Alternative to the American Society of
Mechanical Engineers Boiler and Pressure Vessel Code
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
Section XI Requirements for Examination of Class 1 and
Class 2 Piping Welds (TAC NOS. ME70SS AND ME70S6)
Materials Reliability Program: Boric Acid Corrosion
Guidebook, Revision 2: Managing Boric Acid Corrosion
Issues at PWR Power Stations
PQR-003
Procedure Qualification Record
PQR-016
Procedure Qualification Record. P8-T-Ag-1
PQR-035
Procedure Qualification Record for P8-T-Aq.
PQR-037
Procedure Qualification Record for WPS P8-T-Ag, P8-A, P8-
09/05/1989
AT-Aq
PQR-040
Procedure Qualification Record for WPS P1-A/P1 -A-LLh/P1-
11/17/1989
AT-Lh
PQR-046
Procedure Qualification Record for WPS P8-T-Ag and P8-
01/24/1990
AT-Ag
PQR-087A
Procedure Qualification Record for WPS P1-AT-Lh (CVN)
10/28/1991
PQR-126
Procedure Qualification Record for WPS P1-T (CVN)
03/16/1995
PQR-127
Procedure Qualification Record for WPS P1-T (CVN)
03/16/1995
PQR-197
Procedure Qualification Record for WPS P8-T-Ao
04/10/2003
PQR-199
Procedure Qualification Record for WPS P1-A-Lh
10/14/2003
WPS P1-A-Lh
ASME Welding Procedure Specification (WPS). Single and
Revision 8
Double Welded Groove, Fillet Welds Socket Welds, and
other joint designs specified
In WPS WJD (Weld Joint Desiqn).
WPS P1-T
ASME Welding Procedure Specification (WPS). Single and
Revision 9
Double Welded Groove, Fillet Welds, Socket Welds, and
other joint designs specified
In WPS WJD (Weld Joint Desiqn).
NOE Reports
MT-2019-030
Closure Head Bolting/ Closure Stud 1 B through 368
10/18/2019
through MT-2019-
PT-2019-049
eves Low Pressure Letdown ORC Isolation Test Valve.
10/16/2019
FW0027 (Pipe to VLV CV0391 ).
PT-2019-052
eves Low Pressure Letdown ORC Isolation Test Valve.
10/16/2019
FW0028 (Pipe to Elbow)
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
PT-2019-054
CVCS Low Pressure Letdown ORC Isolation Valve CV-
10/18/2019
0391. FW0009.
PT-2019-057
Flange to Upper Case I SIAPLH-2AOPCW1 / Pump 2A
10/21/2019
PT-2019-059
Upper Case to Lower Case I SIAPLH-2A-PCW2 / Pump 2
10/20/2019
PT-2019-060
Lower Case Seam Weld / SIAPLH-2A-PCW5 / Pump 2A
10/20/2019
PT-2019-061
Nozzle to Upper Case I SIAPLH-2A-PCW4 / Pump 2A
10/21/2019
UT-2019-031
PRZ-2-N4C/Safety Nozzle to Shell
10/16/2019
UT-2019-042
PRZ-2-N4A/Relief Nozzle to Shell
10/19/2019
UT-2019-043
PRZ-2-N2/Spray Nozzle to Shell
10/19/2019
UT ~2019-044
PRZ-2-N3/Safety Nozzle to Shell
10/19/2019
UT-2019-048
RSG-2A-T1 / Tube plate to Lower Shell Barrel A
10/22/2019
VCT-2019-041
EW-2188-HL5001 / U-Strap Support
10/24/2019
VE-2019-001
BMI Penetration/ No. 1-58
10/07/2019
VE-2019-002
Reactor Vessel Closure Head/Bare Metal Visual Penetration
10/15/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-003
Reactor Vessel Closure Head/Bare Metal Visual Penetration
10/16/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-004
Reactor Vessel Closure Head/Bare Metal Visual Penetration
10/17/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-005
Reactor Vessel Closure Head/Bare Metal Visual Penetration
10/18/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VT1/3-2019-094
Lower Case to Bottom Head/ SIAPLH-2A-PCW3 / Pump 2A
10/21/2019
Procedures
OPEP1 O-ZA-0004
General Ultrasonic Examination
OPEP10-ZA-0010
Liquid Penetrant Examination (Color Contrast Solvent
Removable)
OPEP1 O-ZA-0019
Wet Fluorescent Magnetic Particle Examination For ASME
Section XI PSI/ISi
OPEP1 O-ZA-0024
ASME XI Examination for VT-1 and VT-3
OPEP1 O-ZA-0054
ASME Section XI VE Visual Examinations
OPGP03-ZE-0033
RCS Pressure Boundary Inspection for Boric Acid Leaks
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
OPGP03-ZE-0133
Boric Acid Corrosion Control Program
OPM02-ZW-0005
Control of Postweld Heat Treat
OPMP02-0001 C
AWS-HVAC Weldinq Re.quirements
OPMP02-ZW-
General Welding Requirements
0001
OPMP02-ZW-
ASME Repair Replacement Welding Requirements
0001A
OPMP02-ZW-
ASME-ANSI B31.1 Welding Requirements
0001B
OPMP02-ZW-
Welding Documentation Requirements
0001D
OPMP02-ZW-
Welding procedure Specification Preparation and
0002
Qualification
OPMP02-ZW-
Welder Qualification and Certification
0003
OPMP02-ZW-
Control of Filler Materials
0004
OPMP02-ZW-
Arc Wire Thermal Spray Coatings
0006
Self-Assessments
CR 14-10410
Risk-Informed ISi Periodic Evaluation for South Texas
06/24/2014
Project Electric
Generating Station Units 1 & 2 in Conjunction with End of
the Third Interval, First Period.
Work Orders
w.o. 96011721
(1MB) LOOP 2 RCS Flow Transmitter FT-0429 ISOL VLV
w.o. 96011791
eves Letdown Orifice Header Isolation Valve
W.O. 96013680
Main Steam Isolation Valve 2D Above Seat Drain Isolation
W.0.576310
CentrifuQal Charqinq Pump 2A DischarQe Vent Valve
71111.118
Corrective Action
2019-10407
MSIV Operability Surveillance Procedure not followed
09/20/2019
Documents
2019-10562
Totalizer Event on 9/22/2019
09/24/2019
2019-4962
Train A CRE/HVAC Inoperable
05/02/2019
2019-8301
Inoperable Reactor Head Vent Valves
08/01/2019
2019-9357
Inadequate Control Room Loq entries
08/29/2019
Miscellaneous
None
Simulator Differences List
09/10/2019
None
2019 Biennial NRC Written Exams weeks 1 and 3
11/18/2019
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
None
NRC Annual Operatinq Tests Weeks 1 and 3
11/18/2019
TT01
Simulator Transient Test 01 Manual Reactor Trip
11/04/2019
TT02
Simulator Transient Test 2 Trip of all Main Feed Pumps
11/04/2019
Procedures
OPOP01-ZA-0014
Licensed Operator License Maintenance
Revision 30
OPGP03-ZA-
Medical Exams-NRG Regulated
Revision 0
28A
OPGP03-ZT-0132
Licensed Operator Requalification
Revision 13
OPNT01-TQ-1001
Examination Security
Revision 1
OPNT01-ZA-0037
Simulator Confiquration Control
Revision 13
LOR-GL-0001
LOR Training Program Guidelines
Revision 35
LOR-GL-0002
Licensed Operator Requal Annual/Biennial Evaluation
Revision 28
Guidelines
LOR-GL-0006
LOR Conduct of Simulator Training Guidelines
Revision 32
71111.110 Corrective Action
CR-YYYY-NNNN
2019-14056
2014-12615
1995-13955
2004-4336
Documents
Miscellaneous
Maintenance Rule Expert Panel Meeting Minutes, March,
May, June, July, August, Se,ptember November 2019
17-YU-003, 2017
Essential Cooling Pond (ECP) Seepage Calculations
MC-6498
Essential Coolinq Pond Thermal Performance Analysis
VTD-R 165-0029
Instruction Manual for Essential Cooling Water Pump Motor
VTD-STP1-0001
Rotating Equipment Oil Level Limits and Labels
VTD-W 120-0108
Lame AC Motors - Lice Line D Vertical Induction Motors
Procedures
OPMP04-EW-
Essential Cooling Water Pump Maintenance
0001A
OPMP05-EW-
Essential Cooling Water Pump Motor Inspection
0001
OPSP04-ZE-0313
Maintenance Rule Proqram
SEG-0009
Maintenance Rule Basis Document Guideline
Work Orders
Work
574254
2053
585021
2238
Authorization
Numbers
Corrective Action
CR-YYYY-NNNN
2019-1762,
2019-2357, 2019-2393,
2019-4652,
Documents
2019-9269,
2019-8512, 2019-13994, 2019-4359,
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
2019-13709, 2019-8052
Calculations
RA RICTCal
3505
Corrective Action
CR-YYYY-NNNN
2019-14338
Documents
Procedures
OPGP03-Z0-0055
Protected Components
OPOP01-Z0-0006
Risk Management Actions (RMAs)
Corrective Action
CR-YYYY-NNNN
2019-12034, 2019-13137, 2019-13079, 2009-18939
Documents
2019-8731,
2014-8012,
2019-7580,
2019-5498
2019-13150, 2018-6459,
2019-13477
Drawings
50159F22540#2
Piping and Instrumentation Diagram Standby Diesel Jacket
Water
Miscellaneous
VTD-T147-0001
Terry Steam Turbine Manual
VTD-T147-0008
Terry Turbine Maintenance Guide, Auxiliary Feedwater AFW
Application
VTD-W290-0029
Installation and Operation Manual Overspeed Trip Test
Device for PG Governors
Procedures
OPGP03-AZ-0133
Fluid Leak Management Program
OPGP03-ZA-0514
Controlled System or Barrier Impairment
OPGP03-ZE-0030
Control Room Envelope Habitability Program
OPGP03-Z0-0046
RCS Leakage Monitoring
OPMP04-AF-0002
Auxiliary Feedwater Pump Turbine and Governor Valve
~
Maintenance
OPOP02-HE-0001
Electrical Auxiliary Buildinq HVAC System
Work Orders
Work
556056
489463
Authorization
Numbers
Corrective Action
CR-YYYY-NNNN
2019-11901
2019-4165
2019-11971
Documents
Drawinqs
5R219F05028#2
Spent Fuel Pool Coolinq and Cleanup System
Procedures
OPMP09-PM-
Temporary Configuration Changes to Support Class 1 E
OOOB
Train B MCC Outages
Corrective Action
CR-YYYY-NNNN
2019-11348, 2019-11348
Documents
Procedures
OPEP07-ZE-0002
LLRT Rig Operation
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
OPEP07-ZE-0003
Normal/Suoolementarv Purge Valve Failure/Troubleshooting
OPEP07-ZE-0003
Normal/Suoolementarv Purae Valve Failure/Troubleshooting
OPMP04-ZG-0093
Fisher Butterfly 12 and 48 in. Valve Maintenance
OPSP05-RC-
RCS Flow Transmitter Calibration
0417T
OPSP11-HC-0001
LLRT M-41 Normal Containment Purge Exhaust
OPSP11-HC-0001
LLRT M-41 Normal Containment Purge Exhaust
OPSP11-XC-0004
LLRT Penetration: M-91 Auxiliary Airlock Door Seals
Work Orders
Work
23127, 550267, 548433, 601368, 548433
Authorization
Numbers
Miscellaneous
2RE20 Shutdown Risk Assessment Report
08/27/2019
Procedures
OPOP02-RC-0003
Filling and Ventina the Reactor Coolant System
OPOP03-ZG-0006
Plant Shutdown from 100% to Hot Standby
OPOP03-ZG-0007
Plant Cooldown
OPOP03-ZG-0007
Plant Cooldown
OPOP03-ZG-0010
Refuelinci Operations
OPOP08-FH-0001
Refueling Machine Operating Instruction
OPOP08-FH-0009
Core Refuelina
Corrective Action
CR-YYYY-NNNN
2019-9708
2019-14780
2019-3044
Documents
Drawings
00009EODJM#1
Single Line Diagram 125VDC Class IE Distribution SWBD.
E1A11 (Channel 1) (E.A.B.) Sheet 01
Procedures
OPOP07-FR-0006
FLEX Diesel Generator Performance Test
OPOP07-FR-0006
FLEX Diesel Generator Performance Test
OPSP03-AF-0003
Auxiliarv Feedwater Pump 13(23) lnservice Test
OPSP03-DG-0003
Standbv Diesel 13(23) Ooerability Test
OPSP03-EW-
Essential Cooling Water System Train C Testing
0019
Corrective Action
CR-YYYY-NNNN
2019-14047
Documents
Miscellaneous
NOC-AE-
South Texas Project, Units 1 and 2; Docket Nos. STN 50-
8/8/2019
19003676
498; STN 50-499; Supplement to Changes to the South
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
Texas Project Emergency Plan
NOC-AE-
South Texas Project, Units 1 and 2; Docket Nos. STN 50-
8/8/2019
19003678
498; STN 50-499; Changes to the South Texas Project
Procedures
OERP01-ZV-IN10
Administration of Potassium Iodide
Corrective Action
CR-YYYY-NNNN
2018-03911, 2018-03912, 2018-04050, 2018-04527,
Documents
2018-04528, 2018-04757, 2018-04761, 2018-04933,
2018-06016, 2018-08247, 2018-09871, 2018-11562,
2018-11664, 2018-12157, 2018-12381, 2018-12559,
2018-12585, 2018-13229, 2018-14735, 2019-01215,
2019-03426, 2019-03573, 2019-07939, 2019-11659,
2019-12327
Miscellaneous
Stand Fast WB Count Report -.(reportinQ in nCi)
10/23/2019
18-12339
Ag-110 in CVCS during 1RE21
10/16/2018
19-11442-1
DAC-hr Assessment for Condition Report 19-11442
10/18/2019
19-3165-7
ALARA Review Package - 2RE20 Non-Rapid Refuel
10/01/2019
19-3165-9
ALARA Review Package - 2RE20 Room 003 Activities
10/01/2019
Procedures
OPEP02-ZM-0009
Spent Fuel Pool Storage and Work
OPGP03-ZR-0048
Personnel Dosimetry Program
OPGP03-ZR-0050
Radiation Protection Program
OPGP03-ZR-0051
Radiological Access Controls/Standards
OPRP01-ZA-0010
Radiation Protection Task Schedule
OPRP01-ZA-0042
Job Coverage
OPRP04-ZR-OO 13
Radiological Survey Program
OPRP04-ZR-0015
Radiological Postings and Warning Devices
OPRP04-ZR-0019
High Radiation Area Access Controls
OPRP07-ZR-0016
Lockdown and Posting for Transfer of Spent Fuel/Irradiated
Material ThrouQh Transfer Tube
Radiation
21434
Air Sample Data Sheet - Room 4 B/C Enclosure - Change
04/06/2018
Surveys
Out Filter
21441
Air Sample Data Sheet - B/C HEPA Enclosure Pre-Filter
04/07/2018
ChanQe Out
21468
Air Sample Data Sheet - Reactor Cavity Decontamination
04/14/2018
21498
Air Sample Data Sheet - "B" S/G Platform - Job CoveraQe of 04/19/2018
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
Nozzle Dams
21505
Air Sample Data Sheet - "B" SIG Platform - Job Coverage of 04/19/2018
Nozzle Dams
2373
Air Sample Data Sheet - Near S. Stairwell - Verify
10/01/2019
Conditions
Survey#
97442, 98130, 99286, 99321, 102863, 104598, 105041,
105049, 105646, 105785, 105796, 105992, 106223,
106234, 106258, 106397, 106565, 106797, 106801,
106824, 106862
Radiation Work
2019-2-0145
2RE20 - Maintenance Support for Work In and Around
Permits (RWPs)
Reactor Cavity, Spent Fuel Pool, and Transfer Canal (HRA)
2019-2-0158
2RE20 - Reactor Head Lift Activities (LHRA)
2019-2-0164
2RE20 - Retract/ Re-Insert Thimble Tubes (LHRA)
2019"'.2-0165
2RE20 - Maintenance and Support Work - Room 307
(LHRA)
2019-2-0167
2RE20 - Mechanical Stress Improvement Process (MSIP)
Work Activities (HRA)
2019-2-0173
2RE20 - Maintenance on N2CVPSV3100 (LHRA}
Self-Assessments
18-10431
Self-Assessment: FT-0428 Radiological Surveys
10/07/2018
18-11300-1
Self-Assessment: 1 RE21 Survey Snapshot
10/18/2018
19-02643
RP ProQram Formal Self-Assessment
06/06/2019
Corrective Action
CR-YYYY-NNNN
2017-13657, 2017-13733, 2017-15060, 2017-16403,
Documents
2017-16501, 2017-17137, 2017-17894, 2017-19406,
2017-20490, 2017-24212, 2017-24235, 2018-01438,
2018-01607, 2018-01824, 2018-01837, 2018-04227,
2018-06620, 2018-08647, 2018-10747, 2019-05126,
2019-11442
Corrective Action
CR-YYYY-NNNN
2019-12240, 2019-12368
Documents
Resulting from
Inspection
Miscellaneous
AirHawk SCBA Personnel Fit Test, Medical, and Respiratory
Training dates for cost centers 87, 840, 841, 842, and 843
MSA CARE Certification for Darryl Malone (Vallen Freeport)
06/08/2018
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
000107
Vallen Freeport: Bauer Compressor Air Quality from
February 1, 2018-October 23, 2019
2019, 03
Department of Transoortation Audit: Vallen Freeport
09/23/2019
Respirator
453,
537,
569,
574, 606,
Review
210, 3709, 3715, 3716, 3718,
21, 3725, 3727, 3733, 3736
Procedures
OPEP05-ZH-0005
Non-Safety Related Filter Airflow Test
OPEP05-ZH-0008
MAB, TSC and RCB HV AC In-Place* HEPA Filter Leak Test
OPG03-ZE-0004
Plant Surveillance Program
OPGP-ZR-0050
Radiation Protection Proaram
OPGP03-Zl-0015
Control and Use of Industrial Compressed Air and Gases
OPGP03-ZR-0054
Respiratorv Protection Proaram
OPRP04-ZR-OO 16
Radioloaical Air Samplina and Analysis
OPRP05-RA-0007
Grab Sample Collection of the (PIG) Continuous
Atmospheric Monitors
OPRP05-ZR-0030
Portable Air Monitor Instruments (AMS-4)
OPRP06-ZR-0002
Respiratorv Protection Eauipment Issue and Return
OPRP06-ZR-0004
Cleanina and Sanitizina of Respiratory Protection Equipment 9
OPRP06-ZR-0005
Maintenance, Inspection, and Storage of Respiratory
Protection Eauioment
OPRP06-ZR-0008
Air Quality Evaluation for Compressors or Pressurized Gas
Cylinders
OPRP06-ZR-0013
Resoirator Fit Testina
OPRP06-ZR-0016
Charginq Breathinq Air Cylinders
OPSP11-HE-0001
Control Room Envelop Filter Airflow Capacity Test
OPSP11-HF-0001
FHB Exhaust Filter Airflow Capacity Test
OPSP11-ZH-0008
CRE and FHB HVAC In-Place HEPA Falter Leak Test
Radiation
21434
Air Sample Data Sheet: Chanqe Out of HEPA Pre-filter
04/11/2018
Surveys
21441
Air Samele Data Sheet - Pre-filter Chanqe Out
04/11/2018
21468
Air Sample Data Sheet - Cavitv Decontamination
04/14/2018
21498
Air Samele Data Sheet - Nozzle Dam Job Coverage
04/22/2018
21505
Air Sample Data Sheet - Nozzle Dam Job Coverage
05/03/2018
21669
Air Sample Data Sheet - Routine Unit 1 Radwaste Truck Bav 08/28/2018
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
(RWTB)
21882
Air Sample Data Sheet-Unit 1 Reactor Cavity
11/01/2018
21884
Air Sample Data Sheet-Unit 1 Reactor Cavity
11/01/2018
2338
Air Sample Data Sheet-RT-8011 Particulate Channel Alarm
09/23/2019
2373
Air Sample Data Sheet - FT-0419 Leaking Transmitter
10/02/2019
2476
Air Sample Data Sheet - Unit 2 Reactor Building 68' Grab
10/10/2019
Sample
2482
Air Sample Data Sheet - Unit 2 Reactor Building 68' Grab
10/10/2019
Sample
Radiation Work
2018-0-0159
Preventative Maintenance and Repair of Equipment in the
Permits *(RWPs)
FHB Fuel Transfer Canal including RP Surveys and
Decontamination
2019-2-0115
2RE20 - Mini Decontamination of Reactor Cavity and Initial
LISA and Tilt Pit Decontamination (LHRA)
2019-2-0117
2RE20 - Major Decontamination of Reactor Cavity and LISA
(LHRA)
2019-2-0151
2RE20 - Perform Maintenance and Inspection in RCB/FHB
Fuel Transfer Canals (LHRA)
2019-2-0155
2RE20 - Refuel - Inspect/Clean/Measure Upper/Lower 0-
rina Gro_oves (LHRA)
2019-2-0158
2RE20 - Reactor Head Lift Activities (LHRA)
2019-2-0163
2RE20 - Disconnect/Reconnect Seal Table (LHRA)
2019-2-0171
2RE20 - Remove/Reinstall Reactor Cavity Stairwell (HRA)
Self-Assessments
Assessment/Benchmark Report: Respiratory Program 2018
08/29/2018
MN-17-1-105942
Quality Monitoring Report: Radiological
04/02/2017
Instrumentation/Protective Equipment
MN-18-1-107276
Quality Monitoring Report: Radiological Surveys
10/23/2018
Work Orders
WAN 546352
EAB and FHB HVAC In-Place Adsorber Leak Test: Unit 2 -
09/24/2019
CRE TRN "A" Clean Up Filter 21A/ 3V112VXV001
WAN 546353
EAB and FHB HVAC In-Place Adsorber Leak Test: Unit 2
09/24/2019
CRE TRN "A" Clean Up Filter 21A / 3V112VXV001
71151
Procedures
OPGP05-ZN-0007
Preparation and Submittal of NRC Performance Indicators
Chaptijr 23
Conduct of Operations for Radiation Protection: Radiation
Protection Performance Improvement Guideline
Inspection
Type
Designation
Description or Title
Revision or
Procedure
Date
Corrective Action
CR-YYYY-NNNN
2010-13994, 2019-13709, 2019-8052,
2019-4359,
Documents
2017-1786,
2017-17817, 2018-1529,
2018-3276,
2018-14380, 2019-9018,
2019-9019,
2019-7971,
2019-7483,
2019-12401, 2019-6155,
2019-5150,
2019-376,
2019-13709, 2019-8062,
2019-8052,
2019-4359,
2019-14697, 2019-13386, 2019-13436,
2019-14208, 2019-14736, 2019-14208, 2019-14743,
2019-13614, 2019-13950, 2019-14279, 2019-12597,
2019-9119,
2019-10504, 2019-11054, 2018-11855,
2018-3518,
2018-3559,
2019-7508,
2015-18703,
2017-15034, 2019-10837, 2019-2558,
2019-4575
38