IR 05000498/2021003
| ML21299A204 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/03/2021 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2021003 | |
| Download: ML21299A204 (38) | |
Text
November 03, 2021
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2021003 AND 05000499/2021003
Dear Mr. Powell:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On October 7, 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.
Two findings of very low safety significance (Green) are documented in this report. Two 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.
Additionally, in the preceding 12 months the NRC issued four Severity Level IV traditional enforcement violations associated with impeding the regulatory process, as described in NRC Inspection Reports 05000498,05000499/2020004, dated January 26, 2021, 05000498,05000499/2021001, dated May 7, 2021, and in this report. While the NRC did note that the identified issues appear to show a gap in the stations process for determining whether prior NRC approval was required for changes being made, the NRC determined that two of the examples were dated and not representative of current plant performance. Based on this, the NRC is not currently planning to perform Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period.
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:
05000498/2021003 and 05000499/2021003
Enterprise Identifier: I-2021-003-0104
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, Texas
Inspection Dates:
July 1, 2021 to September 30, 2021
Inspectors:
R. Alexander, Senior Emergency Preparedness Inspect
B. Baca, Health Physicist
J. Drake, Senior Reactor Inspector
S. Hedger, Emergency Preparedness Inspector
G. Kolcum, Senior Resident Inspector
D. Livermore, Nuclear Systems Engineer
E. Simpson, Health Physicist
C. Stott, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at South Texas Project Electric Generating Station, 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.
List of Findings and Violations
Inadequate Maintenance and Post-Maintenance Test Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000499/2021003-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.19 A self-revealed green finding and associated non-cited violation (NCV) of Technical Specification (TS) 6.8.1.a, for the licensees failure to properly preplan, and implement adequate written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, was identified. Specifically, steps in the work instructions provided for disassembling and reassembling the actuator for Unit 2 steam generator D blowdown containment isolation valve could not be accomplished as written and the post-maintenance test was not adequate to verify that valve FV-4150 was physically able to shut which resulted in the valve failing its subsequent surveillance test.
Failure to Perform Analyses of Changes Made to the Emergency Plan Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000498,05000499/2021003-02 Open/Closed Not Applicable 71114.04 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.54(q)(3), for a change to the licensees emergency plan associated with the emergency classification process for failure to demonstrate that the changes would not reduce the effectiveness of the plan. Specifically, the licensee did not perform an analysis demonstrating that changes made to the emergency action level (EAL) downgrade process described in the EAL technical basis document was not a reduction in effectiveness of the plan.
Failure to Correct Weaknesses During Drills Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000498,05000499/2021003-03 Open/Closed
[H.8] -
Procedure Adherence 71151 The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in emergency response organization performance during control room simulator drills conducted on November 24, 2020,
December 8, 2020, and December 15, 2020. Specifically, the licensee did not identify performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000499/2021-001-00 LER 2021-001-00 for South Texas Project, Unit 2,
Condition Prohibited by Technical Specifications Due to Inoperable Containment Isolation Valve 71111.19 Closed
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On July 2, 2021, the unit reduced power to approximately 94 percent following the trip of heater drip pump 11. Unit 1 returned to 100 percent power on July 3, 2021.
Unit 2 operated at or near 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 (COVID-19), resident, and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; 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 a portion 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 readiness for potential impending adverse weather conditions for Hurricane Nicholas on September 12, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train A emergency core cooling system after maintenance during the week of September 6, 2021
- (2) Unit 1, train A solid state protection system after maintenance during the week of September 6, 2021
- (3) Unit 2, train A emergency diesel generator system after maintenance during the week of September 6, 2021
- (4) Unit 2, train B emergency diesel generator system during the week of September 13, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1, emergency core cooling system pumps train A on the week of September 27, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Fire pump house on September 6, 2021
- (2) Unit 2, train D auxiliary feedwater pump room in the isolation valve cubicle on September 23, 2021
- (3) Unit 2, train C cable spreading room in the electrical auxiliary building on September 23, 2021
- (4) Unit 2, component cooling water heat exchanger and header piping rooms on September 27, 2021
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Units 1 and 2, auxiliary feedwater pump cubicles the week of September 27, 2021
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 Unit 1 downpower for loss of heater drip pump on July 2, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated an operations crew respond to a degraded reactor coolant system condition that resulted in a site area emergency on September 1, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (10 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 C emergency core cooling system scaffolding follow up for scaffold up since March 21, 2021
- (2) Unit 2, white risk for residual heat removal pump 2C maintenance on June 30, 2021
- (3) Unit 2, white risk for sequencer power supply 2A replacement on July 5, 2021
- (4) Unit 2, white risk for high head pump 2A maintenance on July 6, 2021
- (5) Unit 2, white risk for emergency diesel generator 22 maintenance on July 14, 2021
- (6) Unit 1, train B 125vds battery bank E1B11 for entry into the configuration risk management program during battery discharge testing on July 14, 2021
- (7) Unit 2, train C essential chill water maintenance on July 19, 2021
- (8) Unit 1, train C 125vdc battery bank E1C11 for entry into the configuration risk management program during battery discharge testing on July 22, 2021
- (9) Unit 1, white risk for emergency core cooling system maintenance the week of September 6, 2021
- (10) Unit 2, white risk for emergency diesel generator 21 maintenance the week of September 6, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, various auxiliary feedwater isolation valve cubicle temperature alarms on June 24, and July 26, 2021
- (2) Unit 2, train A essential cooling water pump broken anchor bolt on lower seismic attachment point on July 1, 2021
- (3) Unit 1, train C essential chilled water chiller temperature excursions on August 7 and 9, 2021
- (4) Fire water storage tank 1 leak on underground pipe leak the week of September 6, 2021
- (5) Unit 1, steam generator blowdown radiation monitor RT-8022 Hi alarm and declared inoperable on September 6, 2021
- (6) Unit 1, solid state protection system actuation train A 15vdc power supply replacement on September 9, 2021
- (7) Unit 2, emergency diesel generator 22 failure to enter cooldown mode on September 12, 2021
- (8) Unit 2, train B essential service water self-cleaning strainer not rotating on September 23, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Units 1 and 2, emergency core cooling seal drain line on September 27, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2, train D steam generator blowdown outside containment isolation valve found not fully isolating on July 1, 2021
- (2) Unit 1, train C residual heat removal pump following maintenance to replace upper bearing on July 21, 2021
- (3) Fire water storage tank 1 leak on underground pipe leak repaired the week of September 6, 2021
- (4) Unit 1, steam generator A blowdown radiation monitor RT-8022 Hi alarm repaired the week of September 6, 2021
- (5) Unit 2, level transmitter LT-0106 for boric acid tank 2B cracked weld repaired on September 9, 2021
- (6) Unit 1, train A solid state protection system actuation 15vdc power supply replacement on September 9, 2021
- (7) Unit 2, train B essential service water self-cleaning strainer not rotating on September 23, 2021
- (8) Unit 1, steam generator D blowdown radiation monitor on September 26, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2, train B emergency diesel generator 24-hour load test on September 12, 2021
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, train B essential cooling water pump inservice test on September 11, 2021
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors evaluated the biennial emergency plan exercise conducted on July 28 and 29, 2021. The exercise scenario simulated an unexpected increase in reactor coolant system activity, failed automatic and manual trip of the reactor from the control room, stuck open steam generator power operated relief valves, a steam generator tube rupture, and a release of radioactive materials offsite requiring the issuance of Protective Action Recommendations. The exercise also included demonstration of one of the station's extensive damage mitigation guideline strategies per the requirements of 10 CFR 50.155(b)(2).
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The licensee submitted several summaries of emergency plan changes to the NRC:
- South Texas Project Electric Generating Station (STPEGS) EAL Technical Basis Manual, revision 2 (submitted December 17, 2020)
- STPEGS Emergency Plan, Change ICN 20-23 (submitted July 28, 2021)
The inspectors conducted a review of the changes from July 26 to August 5, 2021.
This evaluation does not constitute NRC approval.
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensees radiological work planning and reviewed the following activities:
- (1) Unit 2 Refueling Outage 2RE20 planning and implementation ALARA review package 19-3165-5, Mechanical Stress Improvement Process, dated October 3, 2019, and its associated close out ALARA review package 19-3165-5 dated November 18, 2019
- (2) Unit 2 Refueling Outage 2RE20 ALARA planning and implementation ALARA review package 19-3165-7, Non-Rapid Refuel, dated October 3, 2019, and its associated close out ALARA review package 19-3165-7 dated November 18, 2019
- (3) Unit 1 Refueling Outage 1RE22 ALARA planning and implementation ALARA review package 20-812-5, Steam Generator Inspections, dated March 14, 2020; ALARA review package 20-812-5, revision 1 dated April 6, 2020; and its associated close out ALARA review package 20-812-5 dated June 11, 2020
- (4) Unit 2 Refueling Outage 2RE21 ALARA planning and implementation ALARA review package 21-190-3, Non-Rapid Refuel, dated March 18, 2021; ALARA review package 21-190-3, supplement 1 dated April 8, 2021; ALARA review package 21-190-3, supplement 2 dated April 9, 2021; ALARA review package 21-190-3, supplement 3 dated April 9, 2021; and its associated close out ALARA review package 21-190-3 dated May 10, 2021 Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (4 Samples)
The inspectors evaluated dose estimates and exposure tracking through the following as low as reasonably achievable planning documents and radiological outcome evaluations:
- (1) Unit 2 Refueling Outage 2RE20 ALARA review Package 19-3165-5, Mechanical Stress Improvement Process and its associated close out package:
- Work activity number (WAN) 564157, Implementation of Mechanical Stress Improvement Process, under radiation work permit (RWP) 2019-2-136, 2RE20 Maintenance and Support Work, revision 0 and RWP 2019-2-167, 2RE20 Mechanical Stress Improvement Process Work Activities (High Radiation Area (HRA)), revision 0
- WAN 564158, Remove/Reinstall Mechanical Stress Improvement Process Interferences, under RWP 2019-2-136, 2RE20 Maintenance and Support Work, revision 0 and RWP 2019-2-167, 2RE20 Mechanical Stress Improvement Process Work Activities (HRA), revision 0
- WAN 564159, Mechanical Stress Improvement Process Shim Gap Measurements, under RWP 2019-2-167, 2RE20 Mechanical Stress Improvement Process Work Activities (HRA), revision 0 and RWP 2019-2-170, 2RE20 Mechanical Stress Improvement Process Work Activities (Locked High Radiation Area (LHRA)), revision 0
- (2) Unit 2 Refueling Outage 2RE20 ALARA Review Package 19-3165-7, Non-Rapid Refuel and its associated close out package:
- WAN 4522, Stud Tensioning under RWP 2019-2-145, 2RE20 Maintenance Support for Work in and Around the Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA), revision 0
- WAN 4523, Core Exit Thermocouple Nozzle Assemblies under RWP 2019-2-148, 2RE20 Maintenance Inside Shroud Doors (HRA) - Medium Radiological Risk, revision 0
- (3) Unit 1 Refueling Outage 1RE22 ALARA Review Package 20-815-5, Steam Generator Inspections and its associated close out package:
- WAN 607341, Removal/Install Primary Manways, under RWP 2020-1-103, 1RE22 Maintenance and Support Work, revision 0; RWP 2020-1-132, 1RE22 Steam Generator - Primary Side Support and Equipment Setup/Teardown (HRA)
- Medium Radiological Risk, revision 0; RWP 2020-1-133, 1RE22 Steam Generator - Primary Side Manway/Inserts Removal (LHRA) - High Radiological Risk, revision 0; and RWP 2020-1-136, 1RE22 Steam Generator - Reinstall Primary Side Manways (HRA) - Medium Radiological Risk, revision 0
- WAN 607341, Remove/Install Primary Nozzle Dams/Cover, under RWP 2020-1-057, Maintenance and Inspection of Items >200,000 dpm/100cm2 - Medium Radiological Risk, revision 0; RWP 2020-1-132, 1RE22 Steam Generator - Primary Side Support and Equipment Setup/Teardown (HRA) - Medium Radiological Risk, revision 0; RWP 2020-1-134, 1RE22 Steam Generator - Primary Side-Nozzle Dams (LHRA) - High Radiological Risk, revisions 0, 1, and 2; and RWP 2020-1-165,1RE22 - Steam Generator Primary Side - Nozzle Dam Removal, Install Inserts and Manways (LHRA) - High Radiological Risk, revisions 0 and 1
- WAN 607342, Steam Generator Eddy Current Testing, under RWP 2020-1-132, 1RE22 Steam Generator - Primary Side Support and Equipment Setup/Teardown (HRA) - Medium Radiological Risk, revision 0 and RWP 2020-1-165,1RE22 Steam Generator - Eddy Current Testing (LHRA) - High Radiological Risk, revision 0
- WAN 607343, Steam Generator Sludge Lance, and WAN 607344, Foreign Object Search and Retrieval, under RWP 2020-1-130, 1RE22 Steam Generator
- Secondary Side Inspections - Radiation Area, revision 0 and RWP 2020-1-131, 1RE22 Steam Generator - Secondary Side Inspections (HRA), revision 0
- (4) Unit 2 Refueling Outage 2RE21 ALARA Review package 21-190-3, Non-Rapid Refuel, and ALARA Review Package 21-190-6, 2RE21 Nuclear Instrument Nl-0046 Detector Replacement and their associated close out packages:
- WAN 4500, Reactor Head Disassembly, under RWP 2021-2-103, 2RE21 Maintenance and Support Work, revision 0 and RWP 2021-2-114, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium Radiological Risk, revision 0
- WAN 4504, O-ring Groove Cleaning and Reactor Head Lift/Set, under RWP 2021-2-113, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal - Medium Radiological Risk, revisions 0 and 1; RWP 2021-2-114, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium Radiological Risk, revision 0; RWP 201-2-115, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium Radiological Risk, revision 0; RWP 2021-2-117, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (LHRA) - Medium Radiological Risk, revision 0; RWP 2021-2-121, 2RE21 - Reactor Head Lift Activities (LHRA) - High Radiological Risk, revision 0; and RWP 2021-2-133, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (LHRA) - Medium Radiological Risk, revision 0
- WAN 4518, Reactor Head Reassembly, under RWP 2021-2-103, 2RE21 Maintenance and Support Work, revision 0; RWP 2021-2-104, 2RE21 Maintenance and Support Work - HRA, revision 0; RWP 2021-2-114, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium Radiological Risk, revision 0; RWP 2021-2-115, 2RE21 - Maintenance Support for Work in and Around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium Radiological Risk, revision 0
- WAN 650205, Nuclear Instrument NI-0046 Detector Replacement, under RWP 2021-2-104, 2RE21 Maintenance and Support Work (HRA), revision 0; RWP 2021-2-105, 2RE21 - Maintenance and Support Work (LHRA), revision 0; and RWP 2021-2-147, 2RE21 Replace Extended Range Detector NI-0046 (LHRA) -
High Radiological Risk, revision 0
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the internal dosimetry program implementation.
- (1) Whole-body-count internal dose assessment associated with personnel contamination event number: 7689 dated March 25, 2020
- (2) Whole-body-count internal dose assessment for three individuals associated with personnel contamination event numbers: 7649, 7659, and 7652 dated October 24, 2019
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situation:
- (1) Dose assessments for three declared pregnant workers during the inspection period of March 16, 2019, through September 2, 2021
- (2) Effective dose equivalent for external exposure (EDEX) evaluation for WAN 607341, Remove/Install Steam Generator Nozzle Dams/Covers
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Unit-1 Main Plant Vent Exhaust Monitors, RE-8010A, RE-8010B, RE-8010C, RE-8010D, and RE-8010E
- (2) Unit-2 Liquid Waste Tanks Monitor, RE-8038
- (3) Unit-2 Turbine Building Drain Monitor, RE-8041
- (4) Unit-2 Condensate Polishing System Liquid Effluent Monitor, RE-8042
Sampling and Analysis (IP Section 03.02) (4 Samples)
The inspectors evaluated the following sampling and analyses:
- (1) Liquid effluent sampling and analyses for liquid release permit 2021-3259
- (2) Liquid effluent sampling and analyses for liquid release permit 2021-3271
- (3) Gaseous effluent sampling and analyses for gaseous release permit 2021-0624
- (4) Routine sampling of the Unit 1 vent particulate (VE9111) and iodine (VE9112) effluent monitor RT-8010B on July 21, 2021
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Doses to members of the public associated with liquid effluent release permits: 2021-3259 and 2021-3271
- (2) Doses to members of the public associated with gaseous effluent sampling and analyses for gaseous release permits: 2021-0624 and 2021-0626
Abnormal Discharges (IP Section 03.04)
There were no abnormal discharges during this monitoring period.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
There were no incomplete or discontinued program elements identified.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1 (July 1, 2020, through June 30, 2021)
- (2) Unit 2 (July 1, 2020, through June 30, 2021)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1 (July 1, 2020, through June 30, 2021)
- (2) Unit 2 (July 1, 2020, through June 30, 2021)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1 (July 1, 2020, through June 30, 2021)
- (2) Unit 2 (July 1, 2020, through June 30, 2021)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) October 1, 2020, through June 30, 2021
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) October 1, 2020, through June 30, 2021
EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) October 1, 2020, through June 30, 2021
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000499/2021-001-00, Unit 2, Condition Prohibited by Technical Specifications Due to Inoperable Containment Isolation Valve (ADAMS Accession No.
ML21252A756). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Inadequate Maintenance and Post-Maintenance Test Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green NCV 05000499/2021003-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.19 A self-revealed green finding and associated non-cited violation (NCV) of Technical Specification (TS) 6.8.1.a, for the licensees failure to properly preplan and implement adequate written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, was identified. Specifically, steps in the work instructions provided for disassembling and reassembling the actuator for Unit 2 steam generator D blowdown containment isolation valve could not be accomplished as written, and the post-maintenance test was not adequate to verify that valve FV-4150 was physically able to shut which resulted in the valve failing its subsequent surveillance test.
Description:
Valve FV-4150 is the single containment isolation valve in the steam generator D blowdown line. The steam generator blowdown lines are considered a closed loop per General Design Criteria (GDC) 57, Closed System Isolation Valves. GDC 57 defines a closed loop as lines that penetrate the primary reactor containment that are neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere. The blowdown lines are separated from the reactor coolant pressure boundary by the steam generator u-tubes and separated from the containment atmosphere by the steam generator shell and system piping.
The licensee completed an actuator overhaul on valve FV-4150 on March 29, 2021, during the Unit 2 refueling outage (2RE21). On July 1, 2021, the licensee performed a surveillance test on valve FV-4150 by measuring the flow rate through the steam generator 2D blowdown piping following a closed stroke of valve FV-4150. Flow through the pipe went from 36 klbm/hr to 33 klbm/hr after a closed stroke of the valve. The licensee found that the valve plug did not contact the valve seat allowing nearly full flow through the shut valve.
After discovery that valve FV-4150 was not capable of being shut, the licensee declared the valve inoperable, and entered the applicable action statement in Technical Specification 3.6.3, Containment Isolation Valves. The licensee also submitted License Event Report 05000499/2021001, Condition Prohibited by Technical Specifications Due to Inoperable Containment Isolation Valve.
The first example of an inadequate maintenance procedure (as required by Regulatory Guide 1.33) is the maintenance work instructions in WAN 604821 - the work package that detailed the steps to overhaul the valve FV-4150 actuator. Step 3.4 of the work instructions directs maintenance craft to perform steps on pages 1-8 and 1-9 in the vendor technical document VTD-V037-0001, Valtek Inc Installation, Operation, Maintenance Instructions for Mark One and Two Control Valves.
Per the notes on page 1-8 of VTD-V037-0001 for actuator disassembly, the actuator may be disassembled while still on the valve, and that steps 1 through 4 could be skipped since they prescribe how to remove the actuator from the valve. After the valve is disassembled, the applicable step for verifying the valve plug position during reassembly of the actuator in the same document is not possible to accomplish if the actuator is left in place. Specifically, step 10 of reassembly has the user apply air over the actuator piston, which drives the valve plug down into the seat and forces the yoke away from the bonnet by 1/16 inch. This is the positive check that the valve can be shut. This step cannot be performed if the yoke was never removed or loosened as directed in step 3 of disassembly, one of the steps that is skipped if the actuator is left in place. The licensee did not properly preplan the maintenance in this work instruction.
The second example of an inadequate maintenance procedure (as required by Regulatory Guide 1.33) is procedure 0PSP03-SB-0001, Steam Generator Blowdown System Valve Operability Test, revision 32. Step 5.2.3.2 of the post-maintenance test procedure requires that flow through the blowdown containment isolation valve be recorded with the valve open, and step 5.2.3.6 requires flow to be recorded after the valve indicates shut. Both steps are only required if the unit is in mode 1. After the valve actuator overhaul was complete, the unit was in mode 6 so this portion of the post-maintenance test was not performed. The issue with the valve was not found until the unit was in mode 1 on July 1, 2021, and that portion of the same procedure was performed as a regularly scheduled surveillance test. The post-maintenance test after the overhaul required a valve stroke timing test and a comparison of the remote position indication with the local indication, neither of which ensures that the valve is physically shut. Therefore, the post-maintenance test was inadequate in showing that the valve was operable.
Corrective Actions: The licensee adjusted the valve stem for valve FV-4150 so that the valve plug would make physical contact with the valve seat when the valve was shut. The valve was then tested in mode 1 by measuring the flow rate through valve FV-4150 before and after a closed stroke with satisfactory results and returned to service on July 3, 2021. The licensee initiated corrective actions to correct the steps in the work instructions, so they could be accomplished as written. The licensee also initiated corrective actions to include conducting a valve diagnostic test and reviewing the data in the work instructions to ensure that the steam generator blowdown containment isolation valves physically seat as acceptance criteria in post-maintenance and surveillance tests when flow rates are not possible to obtain.
Corrective Action References: WAN 655533, CR 2021-7397
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to preplan and implement adequate maintenance procedures for valve FV-4150 actuator overhaul and post-maintenance testing was a performance deficiency that was within the licensees ability to foresee and correct and therefore should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier 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, valve FV-4150 could not provide a means of containment isolation after the valve actuator overhaul and subsequent post-maintenance test.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) under Exhibit 3, Barrier Integrity Screening Questions, because the performance deficiency did not represent an actual open pathway in the physical integrity of reactor containment, failure of containment isolation system, failure of containment pressure control equipment, failure of containment heat removal, or an actual reduction in function of hydrogen igniters in the reactor containment.
Specifically, while valve FV-4150 was a barrier that was not able to be shut, the closed loop system acted as the second isolation barrier and remained intact.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The inspectors reviewed IMC 0310, Aspects Within Cross-Cutting Areas, and determined that this finding had a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because individuals failed to stop when faced with uncertain conditions. Specifically, individuals performing maintenance on valve FV-4150 should have stopped when they realized that the procedure could not be performed as written.
Enforcement:
Violation: Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering activities referenced in appendix A of Regulatory Guide 1.33, revision 2. Appendix A, Section 9 of Regulatory Guide 1.33 states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures or documented instructions appropriate to the circumstances.
Contrary to the above, on March 29, 2021, the procedures and work instructions for the valve FV-4150 actuator overhaul and subsequent testing were not properly preplanned and performed in accordance with written procedures or documented instructions appropriate to the circumstances. Specifically, the steps in the work instructions provided in WAN 604821 for disassembling and reassembling the actuator for valve FV-4150 could not be accomplished as written and the post-maintenance test was not adequate to verify that valve FV-4150 was physically capable of being shut. This resulted in the valve failing to shut during a surveillance test on July 1, 2021.
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 Analyses of Changes Made to the Emergency Plan Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000498,05000499/2021003-02 Open/Closed
Not Applicable 71114.04 The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.54(q)(3), for a change to the licensees emergency plan associated with the emergency classification process for failure to demonstrate that the changes would not reduce the effectiveness of the plan. Specifically, the licensee did not perform an analysis demonstrating that changes made to the EAL downgrade process described in the EAL technical basis document was not a reduction in effectiveness of the plan.
Description:
During the review of the recent change to the STPEGS Emergency Action Level Technical Bases Document Revision 3 (effective date March 18, 2021), the inspectors determined that the licensee failed to conduct adequate analysis demonstrating that changes to emergency preparedness documentation did not reduce the effectiveness of the emergency plan.
In the 10 CFR 50.54(q) evaluation for STPEGS Emergency Action Level Technical Bases Document, Revision 3 (CR Number 20-10986, dated February 4, 2021), the licensee did evaluate a proposed removal of the EAL downgrade process in Sections 4.2 and 5.6.
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. Further, evaluation failed to assess the effects of eliminating this part of the EAL process versus South Texas Project Electric Generating Station Emergency Plan (Revision ICN 20-22),
Sections F.8.2 through F.8.4, which states, in part, that the licensee maintains the capability to downgrade/de-escalate from Alert, Site Area Emergency, and General Emergency classification levels as directed by the Emergency Director. This capability is stated separately from that of terminating an emergency classification in effect.
The inspectors review of the licensees 10 CFR 50.54(q) evaluation procedure indicates that that both of these sets of documentation were to be included in the review. Procedure 0PGP05-ZV-0010, Emergency Plan Change, revision 19, Section 3.5, defines the emergency plan for the review, which includes, in part, the plan the NRC originally approved and all subsequent changes made by the licensee with, and without, prior NRC review and approval. Further, to understand the basis for emergency plan changes, licensing amendments related to the plan are to be included in evaluation per Addendum 1, Section 3.4 (the latter references Regulatory Guide 1.219, Section 1.6 which includes related license amendment documentation and commitments in the scope of the review).
Downgrading EALs is part of the EAL classification process. It is described as part of industry standard NEI 99-01, revision 6, which the licensees NRC approved EAL scheme is based upon (license amendments 194 and 206; Accession Number ML15201A195; dated August 20, 2015). Changes to the process have an effect on the information provided to offsite response organizations (OROs) via the notification process. This information can have an effect on actions OROs are required to complete in response procedures. The inspectors asked if this change to the EAL classification process was discussed with the OROs to determine if there would be any negative effects on their response actions. The licensee indicated that this was not discussed with the OROs prior to making the change.
Corrective Actions: The licensee initiated discussions with the OROs regarding the protocol for downgrading EALs to identify and resolve any issues this may cause on July 27, 2021.
Also, the licensee entered these issues into the corrective action program.
Corrective Action References: CR 2021-8130
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency. The NRC determined that this violation was associated with a reactor oversight process minor performance deficiencies for failure to maintain the effectiveness of the plan.
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 is 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. Specifically, the regulatory requirement not met was not related to assessment or notification, in that the licensees 10 CFR 50.54(q)(3) evaluation was not adequate to demonstrate that the change did not reduce the effectiveness of the emergency plan.
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 March 18, 2021, changes were made to the emergency plan without performing and retaining an analysis demonstrating the changes did not reduce the effectiveness of the plan. Specifically, the licensee did not retain an analysis of the change demonstrating that the change would not negatively affect the implementation of all emergency plan and licensing action commitments, nor the ability of OROs to take response actions consistent with their procedures.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Correct Weaknesses During Drills Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness
Green NCV 05000498,05000499/2021003-03 Open/Closed
[H.8] -
Procedure Adherence 71151 The inspectors identified a Green, non-cited violation of 10 CFR 50.47(b)(14) for the licensees failure to identify and correct weaknesses in ERO performance during control room simulator drills conducted on November 24, 2020, December 8, 2020, and December 15, 2020. Specifically, the licensee did not identify performance that would have precluded effective implementation of the emergency plan if it occurred during an actual radiological emergency.
Description:
The inspectors reviewed drill documentation associated with performance opportunities that were inputs into the NRC Drill and Exercise Performance (DEP)performance indicator for the fourth quarter 2020. Report STP 2020 Licensed Operator Requal Cycle 204 EPlan Scenarios Evaluation Report, November 10th - December 16th, 2020, (dated July 1, 2021) indicated that control room crews in the simulator were evaluated for the ability to timely and accurately notify OROs of declared EAL SU1, EAL-1, for loss of all offsite AC power capability to all three AC ESF buses for 15 minutes or longer. In the scenario, the loss of power affected both Units 1 and 2. According to the notification forms, five crews indicated that SU1, EAL-1 was applicable to Unit 1 only (crews 1E and 2E on November 24, 2020; crew 2B on December 15, 2020; crews 1C and 2C on December 8, 2020). Procedure 0PGP05-ZV-0013, Performance Indicator Tracking Guide, (revision 10)addendum 1, section 1.7 defines what is considered an accurate notification related to an emergency classification. One characteristic included which needs to be correct for the notification to considered accurate is which unit(s) (one or both) are affected by the emergency classification.
The inspectors reviewed licensee documentation to determine if corrective action was implemented for the crews inaccurate notification forms. In the previously cited drill report, the licensee indicated that offsite notifications were evaluated as part of the control room simulator sessions (drill objective E-1). Further, it was noted that there were differences in the notification forms with respect to which units were identified as being associated with the emergency, but there was no condition report generated to document any corrective action.
Drill and exercise program procedures were reviewed to see if this approach to the issues was acceptable. Applicable direction was as follows:
Procedure 0PGP05-ZV-0001, Emergency Response Exercises and Drills, (revision 17),defines weakness in Section 2.21. It states that a weakness is a level of performance demonstrated during an exercise, drill, or training that would preclude effective implementation of the E-Plan if it were to occur during an actual radiological emergency.
Further, it says, Drill objectives that are not satisfactorily demonstrated shall be considered a weakness. Weaknesses are a condition adverse to quality in the Stations Corrective Action Program.
- Procedure ZV-0027, Drill and Exercise Performance Objectives and Demonstration Criteria, (revision 6), defines drill objective E-1 as [d]emonstrate the ability to provide an accurate initial offsite notification message within 15 minutes of emergency declaration.
Demonstration criteria 4 for this drill objective states, in part, that [t]he initial offsite notification message was accurate in accordance with 0ERP01-ZV-IN02.
- Procedure 0ERP01-ZV-IN02, Notifications to Site Agencies, (revision 35), Section 5.1.1.a, says to complete offsite notification forms in accordance with Addendum 1.
Addendum 1, step 1.1, item 4, says with regards to Affected Units: Mark the affected Unit. If the event is common to both Units, then mark both.
Therefore, the notification forms in the subject simulator drills did not accurately communicate that EAL SU1 applied to both units. The drill objective was not met, so it should have been identified as a weakness. Conditions adverse to quality have corrective action applied to them, as documented in the corrective action program. There was no corrective action documentation generated to show that corrective action took place after this observed performance.
Discussion with the licensee staff revealed that there were proposed changes to the procedures regarding what defines offsite notification form accuracy being considered at the time of the control room simulator drills. However, those proposed changes had not been evaluated or discussed with OROs prior to these evaluations. Further, the proposed changes were in conflict with requirements in the effective procedures at the time of evaluation.
The inspectors concluded that providing inaccurate information on initial offsite notification forms following an emergency classification is performance that would have precluded effective implementation of the emergency plan during a radiological emergency. This constituted a weakness in ERO performance. However, the licensee graded the performance as satisfactory. The licensees failure to identify the weakness and correct it was a performance deficiency.
Corrective Actions: The licensee entered these issues into the corrective action program.
Corrective Action References: CR 21-8107
Performance Assessment:
Performance Deficiency: The licensees failure to correct weaknesses that occurred during a drill or exercise was a performance deficiency which was within the licensees ability to foresee and correct. A weakness is defined in Section 2.0(o) of Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, (dated September 22, 2015) as ERO performance that would have prevented the effective implementation of the licensees emergency plan had the circumstances occurred. The EROs failure to provide accurate initial offsite notifications during simulator drills conducted on November 24, 2020, December 8, 2020, and December 15, 2020, were weaknesses requiring correction.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the ERO performance cornerstone attribute (training, exercises) and adversely affected the cornerstone objective to ensure the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to ensure that adequate measures will be taken to protect the health and safety of the public is degraded when weak ERO performance is not corrected.
Significance: The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP. Using Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3 worksheets (effective date December 20, 2019);and the corresponding Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2 (issue date September 22, 2015); the performance deficiency was determined have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk significant planning standard function. The finding was not a loss of planning standard function because the issues involved limited facility interaction drills with a limited team of evaluators.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The finding had a cross-cutting aspect in the area of procedure adherence associated with human performance because the licensee failed to follow procedures and processes for evaluating ERO performance to identify weaknesses.
Specifically, the performance evaluations were completed using understanding of future proposed changes that were not vetted and were in contrast to the procedures in effect at the time.
Enforcement:
Violation: 10 CFR 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). 10 CFR 50.47(b)(14)requires, in part, that deficiencies identified as a result of exercises or drills are (will be)corrected.
Contrary to the above, on July 1, 2021, the licensee failed to correct deficiencies identified as a result of exercises or drills. Specifically, the licensee failed to identify ERO performance deficiencies (weaknesses) occurring during simulator drills on November 24, 2020, December 8, 2020, and December 15, 2020, and did not ensure correction of the weaknesses. There was no actual or potential safety significance because the weaknesses in performance occurred during drills.
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 July 22, 2021, the inspectors presented the Public Radiation Safety Inspection results to Mr. G. Powell, President and CEO and other members of the licensee staff.
- On August 31, 2021, the inspectors presented the biennial emergency preparedness exercise inspection results to Mr. G. Powell, President and CEO, and other members of the licensee staff.
- On September 2, 2021, the inspectors presented the Occupational Radiation Safety Inspection results to Mr. G. Powell, President and CEO and other members of the licensee staff.
- On October 7, 2021, the inspectors presented the integrated inspection results to Mr. G. Powell and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
5N129F05013, #1 P&ID, Safety Injection System
5N129F05013, #2
P&ID, Safety Injection System
5N129F05014, #1 6.3.3 P&ID, Safety Injection System
5N129F05014, #2
6.3.3 P&ID, Safety Injection System
5N129F05015, #1
6.3.4 P&ID, Safety Injection System
5N129F05015, #2
6.3.4 P&ID, Safety Injection System
5N129MB01045
Design Basis Document, Safety Injection (SI) System
5Nl29F05016, #1
6.3.5 P&ID, Safety Injection System,
5Nl29F05016, #2
6.3.5 P&ID, Safety Injection System
Procedures
Fire Preplan Electrical Auxiliary Building, Cable
Spreading/Power Cable Area, Train C
Fire Preplan for Fire Pump House
Fire Preplan Isolation Valve Cubicle Pump Room Train D
71111.11Q Procedures
0018A
EOP Generic Guidance
Calculations
Calculation 3884
Calculation 3890
Procedures
Configuration Risk Management Program
Risk Managed Tech Specs Program
0PGP03-ZO-0055 Protected Components
Calculations
Calculation
IVC/AFW Cooling Load and Room Heat-Up
Corrective Action
Documents
CR-YYYY-NNNN
21-8104, 2021-7039, 2021-883, 2016-6143, 2020-11256,
21-9293, 2021-9447, 2021-9789
Engineering
Evaluations
11-14080-1
CREE 16-6143-1,
18-6504-04
Procedures
Fire Protection System Functionality Requirements
0PSP03-DG-0017 Standby Diesel 12(22) Twenty-Four Hour Load Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
Work
Authorization
Number
646840, 539902, 655986
Corrective Action
Documents
CR-YYYY-NNNN
21-7931, 2021-7397, 2021-9376, 2021-9293, 2021-9789,
21-9853
Procedures
Fire Protection System Functionality Requirements
0001
Residual Heat Removal Pump Maintenance
0001
Residual Heat Removal Pump Motor Inspection
0001
Residual Heat Removal Pump Motor Inspection
RHR and CCP Vibration Monitoring Equipment Calibration
Work Orders
Work
Authorization
Number
27886, 655533, 659274, 655986, 659898
Procedures
0PSP03-DG-0017 Standby Diesel 12(22) Twenty-Four Hour Load Test
0018
Essential Cooling Water System Train B Testing
Corrective Action
Documents
CR-YYYY-NNNN
2018-6901, 2018-7645, 2018-7668, 2017-7669, 2018-7737,
2018-8226, 2018-8529, 2018-8648, 2018-9162, 2018-9265,
2018-9618, 2018-10229, 2018-11032, 2018-12701,
2018-13937, 2019-0480, 2019-1602, 2019-1641,
2019-1722, 2019-2103, 2019-2351, 2019-2464, 2019-3566,
2019-4749, 2019-4887, 2019-4944, 2019-6527, 2019-6682,
2019-7274, 2019-10295, 2019-10296, 2020-1203,
20-1908, 2020-2746, 2020-4789, 2020-7088, 2020-7341,
20-8043, 2020-9454, 2020-10909, 2020-10986,
20-10997, 2020-11216, 2020-12159, 2020-12160,
20-12185, 2021-525, 2021-1697, 2021-5165, 2021-5882,
21-6054, 2021-6107, 2021-6794, 2021-6803, 2021-6843,
21-8173, 2021-8219
Corrective Action
CR-YYYY-NNNN
21-8107, 2021-8202, 2021-9144
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Engineering
Changes
DCP 07-755-14
Miscellaneous
Participant records and logs from the July 28 and 29, 2021
EP Exercises (from CR/Simulator, OSC, TSC, EOF, and
JIC)
07/28/2021
South Texas Project Electric Generating Station Emergency
Plan
ICN 20-21
Procedures
0ERP01-ZV-EF01 EOF Director
0ERP01-ZV-EF03 Radiological Director
Emergency Classifications
Notification to Offsite Agencies
Radiological Exposure Guidelines
Offsite Protective Action Recommendations
OS01
OSC Coordinator
OS03
Radiological Coordinator
OS04
Security Coordinator
OS06
Emergency Teams
SH02
Acting Radiological Manager
0ERP01-ZV-TP01 Offsite Dose Calculations
0ERP01-ZV-TS01 TSC Manager
TS011
Engineering Supervisor
0ERP01-ZV-TS03 Operations Manager
0ERP01-ZV-TS04 Radiological Manager
0ERP01-ZV-TS05 Chemical/Radiological Manager
0ERP01-ZV-TS06 Maintenance Manager
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0ERP01-ZV-TS07 Technical Manager
0ERP01-ZV-TS08 Security Manager
Equipment Important to Emergency Response
0POP04-RC-0004 Steam Generator Tube Leakage
EC31
SGTR with Loss of Reactor Coolant - Subcooled Recovery
Desired
EC32
SGTR with Loss of Reactor Coolant - Saturated Recovery
Desired
EO20
Faulted Steam Generator Isolation
EO30
Steam Generator Tube Rupture
EDMG
Extensive Damage Mitigation Guideline
ZV-0027
Drill and Exercise Performance Objectives And
Demonstration Criteria, Eight-Year Objective Master Plan
01/14/2021
Work Orders
CRWO
WAN 578742, WAN 511734, WAN 571664, WAN 565286,
WAN 559773
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
21-8130
Miscellaneous
STPEGS Emergency Action Level Technical Bases
Document
AE-NOC-
20003282
South Texas Project, Units 1 and 2 - Issuance of
Amendments No. 220 and 205 to Revise Technical
Specifications to Adopt TSTF-490, Deletion of E Bar
Definition and Revision to RCS Specific Activity Tech Spec
9/29/2020
AE-NOC-5002695 South Texas Project, Units 1 and 2 - RE: Upgrade to
Emergency Action Level Scheme (TAC Nos. MF4195 and
MF4196)
8/20/2015
CR 20-10997
Apparent Cause Evaluation, Title: Technical Issues
0, 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Associated with the 10 CFR 50.54(q) Screening Process
Form 1, Screen
Evaluation Form
Screen Evaluation Form, Section B of STPEGS Emergency
Plan, CR Tracking Numbers 19-13721 and 20-10207
5/5/2021
Form 1, Screen
Evaluation Form
0PGP05-ZV-0007, Prompt Notification System (CR 20-8182,
20-9902)
4/8/2021
Form 1, Screen
Evaluation Form
STPEGS Emergency Action Level Technical Bases
Document, revision 3 (CR 15-18253)
2/4/2021
Form 1, Screen
Evaluation Form
STPEGS Emergency Action Level Technical Bases
Document, revision 3 (CR 20-10986)
2/4/2021
Form 1, Screen
Evaluation Form
ZV-0006, Letters of Agreement, Evaluation CR Tracking
Number: 19-13721
6/17/2021
Form 2,
Effectiveness
Evaluation Form
0ERP01-ZV-IN01, revision 12 (Emergency Classification) -
Change to Mode Definition & Criteria Table (CR Number 20-
7088)
2/3/2021
Form 2,
Effectiveness
Evaluation Form
0ERP01-ZV-IN01, revision 12 (Emergency Classification) -
Change to Addendums 1 & 5 for IC SU3
2/4/2021
Form 2,
Effectiveness
Evaluation Form
STPEGS Emergency Action Level Technical Bases
Document, revision 3 (CR 20-10986)
2/4/2021
Form 2,
Effectiveness
Evaluation Form
STPEGS Emergency Action Level Technical Bases
Document, revision 3 (CR 15-18253)
2/8/2021
NOC-AE-
14003087
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498, STN 50-499; License Amendment Request for revision
to Unit 1 and Unit 2 Emergency Action Levels
5/15/2014
NOC-AE-
19003677
South Texas Project, Units 1 and 2; Docket Nos. STN 50-
498, STN 50-499; License Amendment Request to Revise
Technical Specifications to Adopt TSTF-490, revision 0,
Deletion of E Bar Definition and revision to RCS Specific
Activity Tech Spec
9/26/2019
NOC-AE-
20003778
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498, STN 50-499, 72-1041; Changes to South Texas Project
Electric Generating Station Emergency Plan
2/17/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOC-AE-
21003799
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498, STN 50-499, 72-1041; Changes to South Texas Project
Electric Generating Station (STPEGS) Emergency Plan
4/15/2021
NOC-AE-
21003826
South Texas Project Units 1 and 2, Docket Nos. STN 50-
498, STN 50-499, 72-1041; Change to South Texas Project
Electric Generating Station Emergency Plan
7/28/2021
Procedures
EOF Director
Emergency Classifications
10, 11, 12
Emergency Plan Change
19, 20
ZV-0006
Letters of Agreement
ALARA Plans
CR 2019-11387
Tracking Condition Report for 2RE20 ALARA In Process
Reviews
2/13/2020
CR 2019-3165
Tracking Condition Report for 2RE20 ALARA Review
Packages
2/13/2020
CR 2020-3367
Tracking Condition Report for 1RE22 In Process Reviews
05/26/2020
CR 2020-812
Tracking Condition Report for 1RE22 ALARA Review
Packages
06/16/2020
CR 2021-190
Tracking Condition Report for 2RE21 ALARA Review
Packages
06/15/2021
CR 2021-3154
Tracking Condition Report for 2RE21 ALARA In Process
Reviews
04/20/2021
Corrective Action
Documents
CR-YYYY-NNNN
2019-11529, 2020-3396, 2020-3407, 2020-3555,
20-4175, 2020-5740, 2020-7173, 2020-9828,
20-11384, 2021-334, 2021-3468, 2021-4120,
21-4140, 2021-4231, 2021-8488, 2021-8490
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
21-9179, 2021-9229
Miscellaneous
Dry Active Waste - Common 2021
1/12/2021
Refuel Outage 2RE20 ALARA Report
08/24/2020
Refuel Outage 1RE22 ALARA Report
09/12/2020
Procedures
ALARA Program
ALARA Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ALARA Engineering and Procedure Review
Radiation Work Permits/Radiological Work ALARA Reviews
Radiological Risk Management
Self-Assessments 20-10240-1
Occupational ALARA Planning and Controls
08/04/2021
CR 2020-8258
Perform Post-Outage Alpha Evaluation In Accordance with
Procedure 0PRP04-ZR-0013 step 6.11.2
08/25/2020
CR 2021-2588
Perform 2RE21 Post-Outage Alpha Evaluation In
Accordance With Procedure 0PRP04-ZR-0013 step 6.11.2.
04/27/2021
Corrective Action
Documents
CR-YYYY-NNNN
2019-03573, 2019-04003, 2019-05107, 2019-05318,
2019-05630, 2019-05943, 2019-08744, 2019-09085,
2019-09176, 2019-11555, 2019-11557, 2019-12399,
2019-12450, 2019-12497, 2019-14321, 2019-14753,
20-01946, 2020-02234, 2020-04331, 2020-09813,
20-09814, 2021-05720, 2021-08571
Miscellaneous
0050, Form 1
Declaration of Pregnancy dated and/or active from March
16, 2019 through September 2, 2021
Personnel
Contamination
Events
7649, 7650, 7652, 7672, 7712, 7717
Procedures
Personnel Dosimetry Program
Job Coverage
Operation of the Canberra Accuscan Whole Body Counting
System
Evaluation of Intakes
Radiological Air Sampling & Analysis
Health Physics Instrumentation Program
Radiological Risk Management
Personnel Decontamination
Standardization and Use of the Ludlum Bonner Spheres for
Neutron Measurements
Quality Assurance for TLD Assessment Activities
Quality Control Checks for Dosimeters of Legal Record
CORP-CHAPTER
Radiation Protection Organization and Responsibilities
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation
Surveys
106003
Shutdown Survey
10/05/2019
106082
Post CRUD Burst
10/06/2019
Self-Assessments 0PGP03-ZX-
0003, Form 2
Snapshot Self Assessment
10/06/2020
Audit Report
Number 20-02
STP Nuclear Operating Company Radiological Controls
Quality Audit Report
03/11/2020
Corrective Action
Documents
CR-YYYY-NNNN
2018-9002, 2018-9619, 2018-9684, 2018-11458,
2018-13256, 2018-14467, 2019-438, 2019-4010,
2019-4701, 2019-4966, 2019-5141, 2019-5143, 2019-5295,
2019-5422, 2019-5423, 2019-5765, 2019-5766, 2019-6591,
2019-6704, 2019-6704, 2019-6993, 2019-6993, 2019-6994,
2019-6995, 2019-7438, 2019-7438, 2019-8376, 2019-8376,
2019-9342, 2019-10699, 2019-10823, 2019-10823,
2019-11030, 2019-12917, 2019-13054, 2019-13662,
2019-13662, 2019-14855, 2019-14940, 2020-3386,
20-3386, 2020-4897, 2020-5863, 2020-6309, 2020-9885,
20-9993, 2020-9993, 2020-10251, 2020-11285,
20-11911, 2020-11911, 2020-12063, 2021-895,
21-1658, 2021-1658, 2021-2083, 2021-2083, 2021-4409,
21-4409, 2021-6100, 2021-6100
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
21-7940, 2021-7976, 2021-7982
Miscellaneous
2018 Land Use Census
11/04/2018
2019 Land Use Censusu
2/05/2019
20 Land Use Census
11/17/2020
2018 Annual Effluent Release Report
April 2019
2019 Annual Effluent Release Report
April 2020
20 Annual Effluent Release Report April 2021
Offsite Dose Calculation Manual (ODCM)
Procedures
Continuous Atmospheric Monitors
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Determination of Radionuclides by Apex Gamma
Off-Normal and Abnormal Radiological Effluent Monitoring
Permit Generation - Chemistry Technician
Permit Generation - Chemistry Staff
Gas Storage Tank Activity Determination
Gaseous Effluent Particulate and Iodine Sampling and
Analysis
Gaseous Effluent Noble Gas and Tritium Sampling and
Analysis
0PSP07-WL-0002 Liquid Effluent Composites
LDP1
Liquid Effluent Permit
LDP2
Liquid Effluent Permit with RT-8038 Inoperable
Offsite Dose
Total Dose
AD-0019
Effluent Monitoring for Reactor Containment Building
Leakage Rate Test
Self-Assessments MN-18-0-107381
Quality Monitoring Report
11/29/2018
MN-19-0-107455
Quality Monitoring Report
2/20/2019
MN-19-0-107533
Quality Monitoring Report
05/09/2019
MN-19-0-107537
Quality Monitoring Report
05/14/2019
MN-19-0-107910
Quality Monitoring Report
11/19/2019
MN-20-0-108100
Quality Monitoring Report
05/30/2020
MN-20-0-108251
Quality Monitoring Report
2/17/2020
MN-21-0-108468
Quality Monitoring Report
05/17/2021
Calibration
Records
23078
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
11/29/2018
29986
Calibration Data Package: Backup Meteorological System
Calibration (10 Meter Tower)
2/05/2018
534472
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
03/21/2019
541512
Calibration Data Package: Backup Meteorological System
05/15/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calibration (10 Meter Tower)
546951
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
08/15/2019
2184
Calibration Data Package: Backup Meteorological System
Calibration (10 Meter Tower)
11/01/2019
557795
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
01/31/2020
563142
Calibration Data Package: Backup Meteorological System
Calibration (10 Meter Tower)
03/11/2020
569380
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
08/12/2020
575140
Calibration Data Package: Backup Meteorological System
Calibration (10 Meter Tower)
09/28/2020
580319
Calibration Data Package: Primary Meteorological System
Calibration (60 Meter Tower)
01/21/2021
586110
Calibration Data Package: Backup Meteorological System
Calibration (10 Meter Tower)
03/10/2021
Corrective Action
Documents
CR-YYYY-NNNN
2018-10710, 2018-11163, 2019-411, 2019-1309,
2019-1804, 2019-1813, 2019-2830, 2019-5722,
2019-6343, 2019-7118, 2019-7711, 2020-39, 2020-1121,
20-5226, 2020-5930, 2020-6009, 2020-9255,
20-10234, 2020-10239, 2020-11256, 2020-11531,
20-11816, 2021-55, 2021-364, 2021-2892, 2021-3317
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
21-7940, 2021-8114
Miscellaneous
STPNOC Measurement Assurance Program (MAP) Report
Package: 2018, 1st Quarter
03/28/2018
STPNOC Measurement Assurance Program (MAP) Report
Package: 2018, 2nd Quarter
07/18/2018
STPNOC Measurement Assurance Program (MAP) Report
Package: 2018, 3rd Quarter
11/28/2018
STPNOC Measurement Assurance Program (MAP) Report
01/10/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Package: 2018, 4th Quarter
STPNOC Measurement Assurance Program (MAP) Report
Package: 2019, 1st Quarter
04/03/2019
STPNOC Measurement Assurance Program (MAP) Report
Package: 2019, 2nd Quarter
07/23/2019
STPNOC Measurement Assurance Program (MAP) Report
Package: 2019, 3rd Quarter
11/13/2019
STPNOC Measurement Assurance Program (MAP) Report
Package: 2019, 4th Quarter
01/08/2020
STPNOC Measurement Assurance Program (MAP) Report
Package: 2020, 1st Quarter
03/21/2020
STPNOC Measurement Assurance Program (MAP) Report
Package: 2020, 2nd Quarter
06/29/2020
STPNOC Measurement Assurance Program (MAP) Report
Package: 2020, 3rd Quarter
10/22/2020
STPNOC Measurement Assurance Program (MAP) Report
Package: 2020, 4th Quarter
01/12/2021
STPNOC Measurement Assurance Program (MAP) Report
Package: 2021, 1st Quarter
05/20/2021
2018 Annual Environmental Operating Report
05/29/2019
2019 Annual Environmental Operating Report
04/23/2020
20 Annual Environmental Operating Report
04/26/2021
2018 Land Use Census
11/04/2018
2019 Land Use Census
2/05/2019
20 Land Use Census
11/17/2020
Inspection Report for STP Nuclear Operating Station at Bay
City, TX for the: 60M Rohn #80 Guyed Tower, Below Grade
Anchor, and TS-2500 Elevator Inspections
03/02/2020
Offsite Dose Calculation Manual (ODCM)
Updated Conceptual Site Model, Groundwater Protection
Initiative, South Texas Project Electric Generating Station,
July 2018
21 Groundwater Protection Plan, South Texas Project
Procedures
Non-Radioactive Spill Response, Cleanup, and Reporting
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Non-Radioactive Spill Response, Cleanup, and Reporting
0PGP03-ZO-0053 Radiological Ground Water Protection Program
Equipment Important to Emergency Response
0001
Alternate Meteorological Instrumentation Data Retrieval
0POP04-ZO-0005 Chemical Spills / Toxic Gas Release
Quality Assurance for the Radiological Laboratory
Sample Receipt, Accountability and Storage
Preparation of Samples for Tritium Analysis by Liquid
Scintillation Counting
Preparation of Samples for Gamma Analysis
Quality Control of Radiological Laboratory Equipment
REMP Interlaboratory Comparison Program
NRMAP Measurement Assurance Program
Interlaboratory Radioassay Measurement Assurance
Program
REMP Sample Collection
Environmental TLD Monitoring
Radiation Protection Fire and Spill Response
Soil and Groundwater Remediation Evaluations
0PSP05-EM-0001 Primary Meteorological System Calibration (60 Meter Tower) 41
0PSP05-EM-0002 Backup Meteorological System Calibration (10 Meter Tower)
EN-0002
Reportable Quantity Determination
Self-Assessments Audit 19-01 (EP)
Emergency Preparedness Audit Report
2/28/2019
Audit 20-01 (EP)
Emergency Preparedness Audit Report
03/11/21
Audit 20-02 (RC)
Radiological Controls Quality Audit Report
03/11/2020
71151
Miscellaneous
STP 2020 Licensed Operator Requal Cycle 204 EPlan
Scenarios Evaluation Report, November 10th -
December 16th, 2020
7/1/2021
South Texas Project Electric Generating Station, Tabletop
Evaluation Report, Red Team - January 21, 2021
7/1/2021
STP 2021 Licensed Operator Requal Cycle 212; EPlan
Scenarios Evaluation Report; May 4th - June 1st, 2021
7/1/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Form 1
Siren Tests or Inspection Results, Date of Test: 10/14/20;
Type of Test: Bi-Weekly Silent
11/16/2020
Form 1
Siren Tests or Inspection Results, Date of Test: 10/28/20;
Type of Test: Bi-Weekly Silent
11/16/2020
Form 1
Siren Tests or Inspection Results, Date of Test: 11/11/20;
Type of Test: Bi-Weekly Silent
2/7/2020
Form 1
Siren Tests or Inspection Results, Date of Test: 11/25/20;
Type of Test: Bi-Weekly Silent
11/30/2020
Form 1
Siren Tests or Inspection Results, Date of Test: 12/9/20;
Type of Test: Bi-Weekly Silent
1/5/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 12/30/20;
Type of Test: Bi-Weekly Silent
1/13/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 12/9/20;
Type of Test: Quarterly Growl
1/5/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 3/31/21;
Type of Test: Quarterly Growl
4/28/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 1/6/21; Type
of Test: Bi-Weekly Silent
1/31/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 1/20/21;
Type of Test: Bi-Weekly Silent
1/31/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 2/3/21; Type
of Test: Bi-Weekly Silent
2/17/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 3/3/21; Type
of Test: Bi-Weekly Silent
3/15/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 3/17/21;
Type of Test: Bi-Weekly Silent
3/23/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 3/31/21;
Type of Test: Bi-Weekly Silent
4/28/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 4/14/21;
Type of Test: Bi-Weekly Silent
4/28/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 4/28/21;
Type of Test: Bi-Weekly Silent
4/28/2021
Form 1
Siren Tests or Inspection Results, Date of Test: 6/23/21;
Type of Test: Bi-Weekly Silent
6/30/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Notifications to Offsite Agencies
Condition Reporting Process
0002A
CAQ Resolution Process
Emergency Response Exercises and Drills
Prompt Notification System
Performance Indicator Tracking Guide
ZV-0027
Drill and Exercise Performance Objectives and
Demonstration Criteria
Corrective Action
Documents
CR-YYYY-NNNN
21-7397
Work Orders
Work
Authorization
Number
655533