IR 05000498/2020004
| ML21025A436 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/26/2021 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2020004 | |
| Download: ML21025A436 (23) | |
Text
January 26, 2021
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2020004 AND 05000499/2020004
Dear Mr. Powell:
On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On January 14, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. Additionally, 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.
Licensee-identified violations which were determined to be of very low safety significance are 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. 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.
Sincerely, 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:
05000498/2020004 and 05000499/2020004
Enterprise Identifier: I-2020-004-0012
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, TX 77483
Inspection Dates:
October 1, 2020 to December 31, 2020
Inspectors:
H. Freeman, Senior Project Engineer
S. Hedger, Emergency Preparedness Inspector
N. Hernandez, Operations Engineer
G. Kolcum, Senior Resident Inspector
J. Reynoso, Project Engineer
C. Stott, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Br 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, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Licensee-identified non-cited violations are documented in report section:
71114.0
List of Findings and Violations
Failure to Perform Analyses of Changes Made to the Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Not Applicable NCV 05000498,05000499/2020004-01 Open Not Applicable 71114.04 The inspectors identified multiple examples of a Severity Level IV non-cited violation of 10 CFR 50.54(q)(3), for changes to the licensees emergency plan associated with protective action recommendation (PAR) and emergency classification procedures, for failures to demonstrate that the changes would not reduce the effectiveness of the plan. Specifically, the licensee did not perform an analysis to demonstrate that changes to the public PARs within the 5-mile emergency planning zone (EPZ) during a hostile based General Emergency were not a reduction in effectiveness of the plan. Additionally, the licensee did not perform an analysis demonstrating that changes made to the emergency action level (EAL) downgrade process or the plant mode definitions described in the emergency classification procedure were not reductions in effectiveness of the plan.
Failure to Provide Adequate Procedures for Check Valve Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498/2020004-02 Open/Closed
[H.5] - Work Management 71152 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 6.8.1.a when the licensee failed to provide adequate procedures for check valve maintenance. Specifically, the licensee failed to provide adequate procedures to the vendor to complete check valve maintenance before installation in the plant.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On November 14, 2020, the unit commenced a load reduction following a failure of the temperature control valve between the main steam system and moisture separator reheater 11 south. Reactor power was reduced to 98.5 percent. Unit 1 returned to 100 percent power on November 17, 2020. On November 21, 2020, the unit commenced another load reduction following a failure of the temperature control valve between the main steam system and moisture separator reheater 12 north. Reactor power was reduced to 98.5 percent. Unit 1 returned to 100 percent power later on November 21, 2020.
Unit 2 operated at rated thermal power for the entire inspection 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 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk--significant systems from impending severe weather to Tropical Storm Delta during week of October 5, 2020.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train A emergency diesel generator during week of October 5, 2020
- (2) Unit 1, train B emergency diesel generator during week of October 5, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, train A emergency diesel generator, Fire Areas 38 and 44 on October 5, 2020
- (2) Unit 1, train C emergency diesel generator, Fire Areas 36 and 42 on October 29, 2020
- (3) Unit 1, main control room, Fire Area 01 and Fire Zone 34 on October 21, 2020
- (4) Unit 2, main control room, Fire Area 01 and Fire Zone 34 on October 22, 2020
- (5) Unit 1, relay cabinet area, Fire Area 01 and Fire Zone 32 on October 21, 2020
- (6) Unit 2, relay cabinet area, Fire Area 01 and Fire Zone 32 on October 22, 2020
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the annual requalification operating exam that was administered from September 21, 2020 to October 29, 2020.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during moisture separator reheater temperature control valve maintenance on Unit 1 during week of November 16, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated training and operations crew debrief to a rapid primary leak, anticipated transient without scram, and a small break loss of coolant accident on October 15, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1, train D auxiliary feedwater pump speed drift on July 9, 2020
- (2) Unit 2, qualified display parameter system link status on September 23, 2020
- (3) Unit 1, train B high head safety injection pump circuit breaker on December 29, 2020
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 1, leakage past emergency core cooling system check valves on November 10, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2, train A 125vdc battery maintenance that resulted in the planned entry into the configuration risk management program on October 14, 2020
- (2) Unit 1, white risk for work on train B of circulating water pump and open loop pump for the week of October 12, 2020
- (3) Unit 2, white risk for work on train C of essential cooling water for the week of October 12, 2020
- (4) Unit 2, white risk for work on train C of emergency diesel generator for the week of November 23, 2020
- (5) Unit 1, white risk for work on train C of emergency core cooling systems for the week of November 23, 2020
- (6) Unit 2, white risk for work on train D of steam generator power operated relief valve on November 30, 2020
- (7) Unit 2, white risk for work on train D of auxiliary feedwater pump on November 30, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2, train B essential cooling water strainer leaking from shaft on August 31, 2020
- (2) Unit 2, train C control room envelope air handler unit drain line on September 2, 2020
- (3) Unit 1, train B essential chiller daily purge count on September 22, 2020
- (4) Unit 2, train A component cooling water system indications on September 24, 2020
- (5) Unit 2, E2C11 battery sample straw fell to bottom of battery cell on October 1, 2020
- (6) Unit 1, train B emergency diesel generator start time degradation on October 15, 2020
- (7) Unit 1, train B high head safety injection pump circuit breaker on December 29, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Design Change Package 18-9664-5, fire protection pressure reducing valve hose reel modification on October 15, 2020
- (2) Design Change Package 12-31926-43, replacing existing 4.16 KV ABB type HK circuit breakers in the 1E engineered safety feature 4.16KV buses due to obsolescence and reliability issues on November 10, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2, train B, essential cooling water pump strainer and piping maintenance during the week of October 19, 2020
- (2) Unit 1, train B emergency diesel generator start time degradation on October 16, 2020
- (3) Unit 1, train D auxiliary feedwater pump on October 23, 2020
- (4) Unit 1, train B emergency diesel generator after exhaust manifold work during the week of November 16, 2020
- (5) Unit 1, train C circulating water pump after motor rewind on December 3, 2020
- (6) Unit 1, train D of steam generator power operated relief valve on December 3, 2020
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 from July 5, 2019 to October 22, 2020.
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 Preparedness Organization from July 5, 2019, to October 22, 2020. Inspectors also evaluated the licensee's 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 July 5, 2019, and October 22, 2020. This involved review of licensee screening and evaluation documentation. 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 July 5, 2019, and October 22, 2020. The evaluation reviewed the conduct of drills and exercises, licensee audits and assessment, and the maintenance of equipment important to emergency preparedness.
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) Unit 1 (July 1, 2019, though September 30, 2020)
- (2) Unit 2 (July 1, 2019, through September 30, 2020)
EP02: ERO Drill Participation (IP Section 02.13) (2 Samples)
- (1) Unit 1 (July 1, 2019, through September 30, 2020)
- (2) Unit 2 (July 1, 2019, through September 30, 2020)
EP03: Alert & Notification System Reliability (IP Section 02.14) (2 Samples)
- (1) Unit 1 (July 1, 2019, through September 30, 2020)
- (2) Unit 2 (July 1, 2019, through September 30, 2020)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1 (October 1, 2019, through September 30, 2020)
- (2) Unit 2 (October 1, 2019, through September 30, 2020)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1 (October 1, 2019, through September 30, 2020)
- (2) Unit 2 (October 1, 2019, through September 30, 2020)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in fire protection hose inspection 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 licensees implementation of its corrective action program related to the following issues:
- (1) Unit 1, leakage past emergency core cooling system check valves
- (2) Unit 2, leakage past emergency core cooling system check valves
- (3) Unit 1, train B of high head safety injection pump circuit breaker
- (4) Qualified display parameter system failures
INSPECTION RESULTS
Failure to Perform Analyses of Changes Made to the Emergency Plan Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000498,05000499/2020004-01 Open/Closed
Not Applicable 71114.04 The inspectors identified multiple examples of a Severity Level IV non-cited violation of 10 CFR 50.54(q)(3), for changes to the licensees emergency plan associated with protective action recommendation (PAR) and emergency classification procedures, for failures to demonstrate that the changes would not reduce the effectiveness of the plan. Specifically, the licensee did not perform an analysis to demonstrate that changes to the public PARs within the 5-mile emergency planning zone (EPZ) during a hostile based General Emergency were not a reduction in effectiveness of the plan. Additionally, the licensee did not perform an analysis demonstrating that changes made to the emergency action level (EAL) downgrade process or the plant mode definitions described in the emergency classification procedure were not reductions in effectiveness of the plan.
Description:
The inspectors identified the following three examples where the licensee failed to conduct adequate analysis demonstrating that changes to emergency implementing procedures did not reduce the effectiveness of the emergency plan.
Example 1: In the 50.54(q) evaluation for Procedure 0ERP01-ZV-IN07, Offsite Protective Action Recommendations, Revision 18 (dated November 21, 2019), the licensee did not identify that a proposed change was being made to Addendum 1 changing the PARs for the 5-mile radius. Therefore, no evaluation of whether it reduced the effectiveness of the plan was completed (procedure change made effective August 5, 2020).
Example 2: In the 50.54(q) evaluation for Procedure 0ERP01-ZV-IN01, Emergency Classification, Revision 10 (dated November 25, 2019), the licensee did not identify that a proposed change was being made to the Modes Definitions and Criteria table so that it would be different than the NRC approved EAL scheme, as well as licensee Technical Specifications. No evaluation of whether it reduced the effectiveness of the plan was completed (procedure change made effective June 24, 2020).
Example 3: In the same 50.54(q) evaluation in Example 2, the licensee did evaluate a proposed removal of the EAL downgrade process in Section 5.2. However, the evaluation focused on whether the change would provide alignment with other site procedures, vice evaluating whether the process removal would have a negative effect on the EAL process as defined in the EAL license amendment approval from 2015.
Corrective Actions: The licensee entered these issues in their corrective action program.
Corrective Action References: Condition Reports 20-0788 and 20-10997
Performance Assessment:
None
Enforcement:
The ROPs 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 NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: This issue was determined to be a Severity Level IV violation using the NRC Enforcement Policy, dated January 15, 2020, Section 6.6.d.1 of the Enforcement Policy because it involves the licensees ability to meet or implement a regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan is reduced.
Violation: Title 10 CFR 50.54(q)(3) states, that the licensee may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that changes do not reduce the effectiveness of the plan.
Contrary to the above, on June 24, 2020, and August 5, 2020, changes were made to the emergency plan without performing and retaining an analysis demonstrating the changes did not reduce the effectiveness of the plan.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71114.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 50.54(q)(2) requires, in part, a holder of a license under this part shall maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 50.47(b). Planning standard 10 CFR 50.47(b)(4)requires, in part, that a standard emergency classification and action level scheme is in use by the nuclear facility licensee.
Contrary to the above, from January 28, 2016, to June 24, 2020, the licensee failed to maintain the effectiveness of an emergency plan which met the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to maintain a standard emergency classification scheme as required by 10 CFR 50.47(b)(4)because procedure 0ERP01-ZV-IN01, "Emergency Classification," Revision 10, failed to include accurate emergency action level thresholds associated with containment high range monitors, which were associated with losses of the fuel clad, reactor coolant system, and the containment barrier.
Significance/Severity: Green. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process,"
issued September 22, 2015, and determined to be of very low safety significance (Green)because it was a failure to comply with NRC requirements, was associated with a risk-significant planning standard, and was not a lost or degraded planning standard function.
Corrective Action References: Condition Report 19-01722
Licensee-Identified Non-Cited Violation 71114.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 50.54(q)(2) requires, in part, a holder of a license under this part shall maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 50.47(b). Planning standard 10 CFR 50.47(b)(10)requires, in part, that a range of protective actions has been developed for the plume exposure pathway emergency planning zone for the public.
Contrary to the above, from August 8, 2020, to October 22, 2020, the licensee failed to develop a range of protective actions for the plume exposure pathway emergency planning zone for the public. Specifically, procedure 0ERP01-ZV-IN07, "Offsite Protective Action Recommendation," Revision 18, reduced the PARs for the public located in the 2-mile radius of the plant, as well as for any public downwind 5 miles, during a hostile action based General Emergency. This change was not discussed or agreed to with offsite response organizations prior to implementing this change.
Significance/Severity: Green. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, "Emergency Preparedness Significance Determination Process,"
issued September 22, 2015, and determined to be of very low safety significance (Green)because it was a failure to comply with NRC requirements, was associated with a risk--significant planning standard, and was not a lost or degraded planning standard function.
Corrective Action References: Condition Report 20-10909
Failure to Provide Adequate Procedures for Check Valve Maintenance Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000498/2020004-02 Open/Closed
[H.5] - Work Management 71152 The inspectors identified a Green finding and associated non-cited violation of Technical Specification 6.8.1.a when the licensee failed to provide adequate procedures for check valve maintenance. Specifically, the licensee failed to provide adequate maintenance procedures to the vendor to complete check valve maintenance before installation in the plant.
Description:
On March 22, 2020, through March 28, 2020, the licensee performed planned maintenance on four 8-inch Westinghouse safety-related check valves. The licensee established work activity numbers (WANs) 503628, 605180, and 574439 to control the maintenance. The licensee contracted with a vendor to perform the seat lapping in accordance with the WANs. Additional procedures in the WANs included:
- 0PMP04-ZG-0071, Westinghouse Swing Check Valve Maintenance, Revision 15
- 0PSP11-ZE-0001, Check Valve Inspection, Revision 13
- 0PMP04-ZG-0133, General Guidelines for Valve Lapping, Revision 0
- 0PGP04-ZA-0328, DG Nuclear QP-SVC-01 Seat Contact Area Reduction and Re-Establishment, Revision 0
The vendor completed summary reports for each check valve that was lapped. The check valves included:
- 1-RH-0032A
- 2-RH-0032A - spare valve
- 1-SI-0010A
- 1-SI-0010B
After maintenance activities were complete on the check valves during the Unit 1 outage, the unit was returned to full power operation and one check valve, 1-RH-0032A, experienced excessive leakage. Consequently, the licensee had to obtain a license amendment to continue operation at a reduced accumulator system pressure to stop the excessive leakage on 1-RH-0032A.
The inspectors reviewed the work order packages for acceptance criteria. The licensee was unable to retrieve the following documents:
- 0PSP11-ZE-0001, Check Valve Inspection, Revision 13
- 0PGP04-ZA-0328, DG Nuclear QP-SVC-01 Seat Contact Area Reduction and Re-Establishment, Revision 0
The inspectors determined that acceptance criteria for maintenance on the check valves were not clearly defined and not derived from the supporting technical bases to demonstrate operational readiness consistent with the licensees design basis. In addition, acceptance criteria were not reviewed by the licensee until after the valves were installed. Examples included:
Vendor report for the 1-RH-0032A valve shows a critical dimension for the disc--to--arm-to-collar clearance that was out of specification from the Westinghouse tolerance. This acceptance criterion was not reviewed by the licensee until after the valve was installed. In fact, the licensees procedure only required full dimensional review if parts are replaced and the valve fully disassembled. None of the valves were fully disassembled, therefore no dimensional acceptance review was required.
The licensee procedures did not provide acceptance criteria.
Documented finish and acceptance by the licensee for the disc and seat for all the check valves was a dull gray finish as documented in the applicable WAN packages for the different valves. The licensee procedure requires a mirror finish for the disc and a dull gray finish for the seat. Review of the vendor reports shows the disc was in fact lapped to a mirror finish while the seat was a dull gray finish.
The vendor procedure notes that before proceeding, contact the customer engineering support to determine whether seat width and relief measurements are within valve manufacturers (Westinghouse) allowable tolerances. No documentation could support that this was performed.
The vendor reports an erroneous dimension for the seat width of 0.0250 inches for all check valves. The vendor was contacted and stated the actual dimension was 0.250 inches. Neither the vendor nor licensee identified this error.
The vendor procedure and the licensee procedure required a compound to be used for lapping the seats. The vendor stated that only adhesive backed discs were used for lapping the seats. Neither the vendor nor licensee identified this discrepancy.
Corrective Actions: The licensee conducted an apparent cause evaluation for the failure to provide adequate maintenance procedures and obtained a license amendment to continue operation at a reduced accumulator system pressure to stop the excessive leakage on 1-RH-0032A.
Corrective Action References: Condition Reports 2020-4781, 2020-5576, 2020-3701
Performance Assessment:
Performance Deficiency: The failure to provide adequate procedures for maintenance on safety-related equipment was a performance deficiency. Specifically, WANs 503628, 605180, and 574439, failed to provide adequate maintenance procedures during check valve maintenance before installation in the plant.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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, WANs 503628, 605180, and 574439, failed to provide adequate maintenance procedures during check valve maintenance before installation in the plant.
This resulted in the licensee having to obtain a license amendment to continue operation at a reduced accumulator system pressure to stop the excessive leakage on 1RH00032A.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the 1RH00032A was able to maintain its operability and therefore screened as 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, during the inspection, the NRC observed weaknesses in the licensees processes for planning, controlling, and executing the work orders related to maintenance on safety-related check valves assuring nuclear safety is 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.a, maintenance that can affect the performance of safety-related equipment should be properly pre-planned. The licensee established WANs 503628, 605180, and 574439 to meet Regulatory Guide 1.33 requirements.
Contrary to the above, from March 22, 2020 to March 29, 2020, the licensee failed to properly pre-plan maintenance that could affect the performance of safety-related equipment.
Specifically, WANs 503628, 605180, and 574439, failed to provide adequate procedures during check valve maintenance - a maintenance activity that affected the performance of safety-related equipment.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 29, 2020, the inspectors presented the Emergency Preparedness Program inspection technical debrief to Mr. A. Capristo, Executive Vice President and Chief Administrative Officer and other members of the licensee staff.
- On December 10, 2020, the inspectors presented the Emergency Preparedness Program inspection results to Mr. A. Capristo, Executive Vice President and Chief Administrative Officer and other members of the licensee staff.
- On January 14, 2021, the inspectors presented the integrated inspection results to Mr. G. T. Powell and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Fire Preplan for Diesel Generator Building, Train A
ODGB39-FP-
0503
Fire Preplan Diesel Generator Building Diesel Fuel Oil
Storage Tank, Train C
71111.11A Miscellaneous
20 Annual Requalification Operating Exam Results
11/17/2020
Corrective Action
Documents
CR-YYYY-NNNN
20-4781, 2020-7429, 2020-4958, 2020-6817, 2017-20444,
20-9979, 2020-9943
Work Orders
Work Activity
Number
640465, 575409
Calculations
3680
Procedures
25 Volt Class 1E Battery Monthly Surveillance Test
25 Volt Class 1E Battery Quarterly Surveillance Test
Work Orders
Work Activity
Number
21271
Corrective Action
Documents
CR-YYYY-NNNN
20-9332, 2020-10763, 2020-4169, 2020-10181,
20-9206, 2020-6817, 2017-20444, 2020-9921,
20-9979
Work Orders
Work Activity
Number
2779, 602581
Corrective Action
Documents
CR-YYYY-NNNN
20-10763, 2020-4169,
Work Orders
Work Activity
Number
568030, 641655
Procedures
FLEX Diesel Generator Performance Test
Miscellaneous
South Texas Project Electric Generating Station, Updated
Prompt Notification System Design Report
2, 3
Procedures
Prompt Notification System
Miscellaneous
0014, Form 19
ENRS Test
08/21/2019
0014, Form 19
ENRS Test
2/04/2019
0014, Form 19
ENRS Test
01/28/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0014, Form 19
ENRS Test
05/07/2020
Procedures
Emergency Response Organization Notification
Miscellaneous
STPEGS Emergency Action Level Technical Bases
Document
0010, Form 1,
Screen Evaluation
Form
0PGP03-ZT-0139 Revision 35
08/14/2019
0010, Form 1,
Screen Evaluation
Form
CR Number: 19-8084; 0PGP03-ZA-0106, Revision 12
08/14/2019
0010, Form 1,
Screen Evaluation
Form
0ERP01-ZV-TS02, Revision 6
06/23/2020
0010, Form 1,
Screen Evaluation
Form
0PGP03-ZV-0002, Revision 10
05/14/2020
0010, Form 1,
Screen Evaluation
Form
0PGP05-ZV-0010, Revision 19
10/17/2019
0010, Form 1,
Screen Evaluation
Form
0PGP05-ZV-0012, Revision 19
06/25/2020
0010, Form 1,
Screen Evaluation
Form
Changes to 0ERP01-ZV-IN07, CR Number 18-10203
11/21/2019
Changes to 0ERP01-ZV-IN01, Classification
11/25/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0010, Form 1,
Screen Evaluation
Form
0010, Form 2,
Effectiveness
Evaluation Form
Changes to 0ERP01-ZV-IN01, Emergency Classification
11/25/2019
0010, Form 2,
Effectiveness
Evaluation Form
0ERP01-ZV-IN07, CR Number: 18-10203
11/21/2019
0010, Form 2,
Effectiveness
Evaluation Form
CR Number: 19-8084; 0PGP03-ZA-0106, Revision 12
08/14/2019
0010, Form 2,
Effectiveness
Evaluation Form
0PGP03-ZT-0139 Revision 35
08/14/2019
Procedures
Emergency Classification
10, 11
Emergency Medical Response Plan
Emergency Preparedness Training Program
Emergency Plan Change
Calculations
Calculation
Number 03-ZE-
003
RT8050/RT8051 Contingency Conversion Constant for Post-
Accident Failed Fuel Monitoring
Calculation
Number 15-RA-
011
Fission Product Barrier Failure for Emergency Action Level
Thresholds
Corrective Action
Documents
CR-YYYY-NNNN
2017-23016, 2018-08506, 2018-09203, 2019-01722,
2019-03370, 2019-08483, 2019-08484, 2019-10255,
2019-11498, 2019-14923, 2020-02587, 2020-02674,
20-04237, 2020-04789, 2020-05776, 2020-0788,
20-07292, 2020-08465, 2020-09787, 2020-10256,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20-10909, 2020-10989, 2020-10997
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
20-10986, 2020-10997, 2020-11238, 2020-11185,
20-11226, 2020-12185
Miscellaneous
Exercise Evaluation Areas and Extent of Play Agreement,
Matagorda County Emergency Medical Service and
Matagorda Regional Medical Center, February 13, 2019
2/19/2018
Environmental Sampling Drill, Final Report, October 6, 2020
10/27/2020
Combined Functional Drill Final Report, Red Team, June 12,
2019
2/4/2019
2019 South Texas Project Onsite Medical Drill, In
Conjunction with the FEMA MS-1 Medical Exercise
09/11/2019
After Action Report/Improvement Plan, South Texas Project
Medical Services Drill, Exercise Date - February 12, 2019,
Radiological Emergency Preparedness (REP) Program
03/16/2019
Environmental Sampling Drill, Final Report, August 15, 2019
2/5/2019
South Texas Project Electric Generating Station, CFD
Evaluation Report, Blue Team - March 4, 2020
09/14/2020
STP Personnel Decontamination Event/Semi-Annual Health
Physics Drill, 10 October 2019, Final Report
2/11/2019
Combined Functional Drill Final Report, White Team,
September 11, 2019
2/05/2019
0014, Form 2
Annual Review of the Eight-Year Exercise Master Plan
2/11/2019
0014, Form 3
Communication Tests
03/17/2020
0014, Form 3
Communication Tests
07/09/2020
0014, Form 3
Communication Tests
07/10/2019
0014, Form 3
Communication Tests
2/11/2019
Communication Tests
10/09/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0014, Form 3
Audit Report
Number 20-01
(EP)
STP Nuclear Operating Company, Emergency
Preparedness Quality Audit Report
03/03/2020
KLD TR-1115
South Texas Project Electric Generating Station, 2019
Population Update Analysis
10/06/2019
NOC-AE-
14003087
South Texas Project, Units 1 and 2, Docket No. STN 50-498;
STN 50-499, License Amendment Request for Revision to
Unit 1 and Unit 2 Emergency Action Levels
05/15/2014
NOC-AE-
15003214
South Texas Project, Units 1 and 2, Docket Nos. STN 50-
498; STN 50-499; Response to Request for Additional
Information - South Texas Project (STP), Units 1 and 2
License Amendment Request for Emergency Action Level
Scheme Change (TACs MD4195 and MF4196)
2/11/2015
NOC-AE-
15003226
South Texas Project, Units 1 and 2, Docket Nos. STN 50-
498; STN 50-499; Response to Request for Additional
Information - South Texas Project (STP), Units 1 and 2
License Amendment Request for Emergency Action Level
Scheme Change (TACs MD4195 and MF4196)
2/26/2015
NOC-AE-
15003265
South Texas Project, Units 1 and 2, Docket Nos. STN 50-
498; STN 50-499; Response to Request for Additional
Information and Supplement to South Texas Project (STP),
Units 1 and 2 License Amendment Request for Emergency
Action Level Scheme Change (TACs MD4195 and MF4196)
07/01/2015
Procedures
Protective Action Recommendations
Offsite Protective Action Recommendations
14, 17, 18,
Equipment Important to Emergency Response
Condition Reporting Process
0002A
CAQ Resolution Process
0002B
Station Cause Analysis Program
Emergency Response Activities Schedule
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency Response Program
Emergency Facility Inventories and Inspections
Emergency Facility Inventories
18, 19
Emergency Response Activities
Work Orders
Work Order
Documents
590531, 594004, 620292, 630931, 631688, 634581, 634755
71151
Miscellaneous
STP DEP Evaluation Worksheet, Event Name: Shift
Manager Up Relief Qualification, Date: 2/5/2020
2/25/2020
STP DEP Evaluation Worksheet, Event Name: Shift
Manager Up Relief Qualification, Date: 4/20/2020
04/23/2020
STP DEP Evaluation Worksheet, Event Name: State &
County Mini Drills, Date: 9/23/2020
09/30/2020
STP DEP Evaluation Worksheet, Event Name: Plant
Operator Initial - EPT-11, Date: 10/14/2019
11/21/2019
0007, Form 1
Siren Test or Inspection Results, Date of Test: 9/30/2020
10/14/2020
0007, Form 1
Siren Test or Inspection Results, Date of Test: 9/25/2019
10/09/2019
Corrective Action
Documents
CR-YYYY-NNNN
20-7652, 2020-5711, 2020-5710, 2020-6193, 2020-6257,
2018-9664, 1999-7428, 1994-2793, 2020-4781, 2019-13222,
20-6817, 2017-20444, 2020-8411, 2020-8483, 2020-8650,
20-9412, 2020-9632, 2020-9874, 2020-9943, 2020-10458,
20-10541, 2020-10836, 2020-10916, 2020-11191,
20-11341, 2020-11747, 2020-12071
Procedures
Fire Protection System Functionality Requirements
Fire Protection System Operation
Design Basis
Document
7A369MB01033
Fire Hazards System
Design Criteria
5Q270MQ1055
Fire Protection and Detection System
Design Document
270MD0100
System Description for Fire Detection
Work Orders
Work Activity
2671
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Number