IR 05000498/2022004

Integrated Inspection Report 05000498/2022004 and 05000499/2022004

ML23031A093
Person / Time
Site:	South Texas
Issue date:	02/02/2023
From:	Patricia Vossmar NRC/RGN-IV/DORS/PBA
To:	Gerry Powell South Texas
References
IR 2022004
Download: ML23031A093 (28)

Text

February 02, 2023

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2022004 AND 05000499/2022004

Dear G. T. Powell:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On January 12, 2023, 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.

Three findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. 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, Patricia J. Vossmar, Chief Projects Branch A Division of Operating Reactor Safety Docket Nos. 05000498, 05000499 License Nos. NPF-76, NPF-80

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000498 and 05000499

License Numbers: NPF-76 and NPF-80

Report Numbers: 05000498/2022004 and 05000499/2022004

Licensee: STP Nuclear Operating Company

Facility: South Texas Project Electric Generating Station, Units 1 and 2

Location: Wadsworth, Texas 77483

Inspection Dates: October 1, 2022, to December 31, 2022

Inspectors: D. Antonangeli, Health Physicist B. Baca, Health Physicist N. Hernandez, Senior Operations Engineer G. Kolcum, Senior Resident Inspector J. Mejia, Reactor Inspector J. O'Donnell, Senior Health Physicist C. Stott, Resident Inspector

Approved By: Patricia J. Vossmar, Chief Projects Branch A Division of Operating Reactor Safety

Enclosure

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:

71124.0

List of Findings and Violations

Failure to Follow Procedure During Tensioning of Reactor Vessel Head Studs Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.13] - 71111.15 NCV 05000499/2022004-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 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. Specifically, the licensee performed actions that were outside the reactor head stud tensioning procedure. The licensee fully de-tensioned and re-tensioned a single reactor head stud which was not prescribed by the procedure and had not been evaluated.

Failure to inform workers of current radiological conditions prior to entry into a high radiation area.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.4] - 71124.01 Radiation Safety NCV 05000498,05000499/2022004-02 Teamwork Open/Closed A self-revealed Green, non-cited violation of technical specification 6.8.1(a) was identified for the licensees failure to follow radiation procedure 0PGP03-ZR-0050, Radiation Protection Program, revision 17, step 6.7.2 which stated appropriate radiological instruction shall be provided to all individuals with access to the restricted area commensurate with potential radiological protection hazards in the area to be entered. Specifically, the welding crew was not appropriately briefed prior to entering a high radiation area (HRA).

Failure to follow a radiological work permit (RWP) requirement.

Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.12] - Avoid 71124.01 Radiation Safety NCV 05000499/2022004-03 Complacency Open/Closed A self-revealed Green, non-cited violation of technical specification 6.8.1(a) was identified for the licensees failure to follow radiation procedure 0PGP03-ZR-0051, Radiological Access Controls/ Standards, revision 48, step 7.1.1 which stated a workers responsibility is to comply with the requirements set forth in their radiological work permit. Specifically, the worker failed to comply with requirements of RWP 2022-2520, task 22, revision 2 which required a powered air purifying respirator (PAPR) to be worn if entering the lower internals storage area (LISA) for installation/removal of the blind flanges and support.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000499/2021-002-01 Supplement to Condition 71153 Closed Prohibited by Technical Specifications Due to Inoperable Train of Essential Core Cooling System and Containment Spray System LER 05000499/2021-002-00 Condition Prohibited by 71153 Closed Technical Specifications Due to Inoperable Train of Essential Core Cooling System and Containment Spray System

PLANT STATUS

Unit 1 began the inspection period at rated thermal power and remained there for the inspection period.

Unit 2 began the inspection period at rated thermal power and commenced a reactor shutdown on October 7, 2022, to begin refueling outage 2RE22. The main generator breaker was closed on November 10, 2022, ending the refueling outage. Unit 2 reached rated thermal power on November 14, 2022 and remained there for the rest of the period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

emergency diesel generators the week of November 7, 2022 steam generator feedwater pumps the week of November 7, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 2, containment on October 9, 2022

(2) Unit 1, main control room, fire area 01, and fire zone 34 on November 7, 2022

(3) Unit 1, relay cabinet area, fire area 01 and fire zone 32 on November 7, 2022

(4) Unit 2, main control room, fire area 01 and fire zone 34 on November 8, 2022

(5) Unit 2, relay cabinet area, fire area 01 and fire zone 32 on November 8, 2022

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) essential cooling water system piping the week of November 7, 2022

===71111.08P - Inservice Inspection Activities (PWR)

PWR Inservice Inspection Activities Sample (IP Section 03.01)===

(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 11, 2022 to November 3, 2022:

03.01.a - Nondestructive Examination and Welding Activities.

ultrasonic examination, 4-RC-2126-BB1, pipe to elbow ultrasonic examination, 12-RC-2112-BB1, elbow to pipe ultrasonic examination, 16-MS-2002-GA2, pipe to cap ultrasonic examination, 6-MS-2001-GA2(E), extrusion to flange dye penetrant examination, RTD scoop surface preparation, C2RCTE0440Y visual examination, RHR Pump 2B discharge relief valve, N2RHPSV3852 visual examination, -11' elevation containment liner and moisture barrier The inspector reviewed weld package 651702 for the reactor coolant system loop 2D pressurizer spray valve packing leak off line and weld package 669390 for thermowell C2RCTE0440Y online RC-2401-NSS.

03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.

The inspector reviewed boric acid evaluations and screenings associated with the following condition reports: 2022-2479, 2022-5129, 2022-9729, 2022-9741, 2022-9744, 2022-10054, 2022-10059, 2022-10063, 2022-10064, 2022-10198, 2022-10201, 2022-10330, 2022-10331, 2022-10512, 2022-10516, 2022-10518, 2022-10520, 2022-10521, 2022-10524, 2022-10525, 2022-10526.

03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.

The inspector reviewed the results of the 100 percent full length bobbin coil eddy current inspection of the steam generator tubes.

No tubes exhibited degradation exceeding the tube integrity criteria provided in the degradation assessment (DA).

No tubes required in situ pressure testing to support the condition monitoring (CM) assessment based on the DA and Electric Power Research Institute (EPRI) In Situ Pressure Test Guidelines.

No tube leakage was reported during this operating interval.

Problem Identification and Resolution review of Inservice items The inspector evaluated a sample of two condition reports associated with in service inspection activities. No findings or violations of more than minor significance were identified.

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 requalification annual operating exam administered on September 8, 2022 - September 29, 2022.

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 the plant shutdown in preparation for a scheduled refueling outage on October 7, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed training and evaluated an operations crew respond to various plant alarm scenarios on October 6, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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 2, train A essential cooling water pump breaker indication the week of November 14, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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, white risk due to emergent maintenance on train A essential cooling water pump breaker during the week of November 14, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2, pressurizer power-operated relief valve block valve limit switch on October 12, 2022

(2) Unit 2, head stud elongation measurement on October 30, 2022

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 2, leakage from reactor head inner O-ring on October 13, 2022

(2) Unit 1, electro-hydraulic control alternate model pump on November 18, 2022

(3) electrical monitoring of freeze protection circuits on December 5, 2022

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site SAMGs were updated in accordance with the PWR generic sever accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Unit 2, train A essential cooling water pump on November 16, 2022

(2) Unit 2, train A steam generator feedwater pump on November 17, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the Unit 2 refueling outage from October 7, through November 10, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) Unit 1, train B component cooling water pump on September 14, 2022

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, reactor head vent isolation valves and normal containment purge exhaust valves on November 3,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) licensee surveying material as it was exiting via the Unit 2 equipment hatch

(2) workers exiting the radiologically controlled area during the Unit 2 refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) vent line replacement located within the Unit 2 pressurizer cubicle

(2) steam generator valve position indicator calibration located within Unit 2 bioshield

(3) steam generator access to remove strongbacks and manway inserts/diaphragms

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Unit 2, regenerative heat exchanger room

(2) Unit 2, room 004 radioactive trash storage located within the reactor containment building

(3) Unit 2, steam generator C cold leg manhole cover

(4) Unit 2, room 003 leading to seal table area

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP

Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (2 Samples)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Unit 1, technical support center ventilation system

(2) Unit 2, control room emergency ventilation

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Unit 2, steam generator manway and insert removal for trains A, B, C, and D

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Shipment Preparation (IP Section 03.04)

(1) The inspector observed the preparation of radioactive shipment STP-1-22-041 on November 16, 2022. This was an exclusive use shipment of a high integrity container of low specific activity (LSA-II) dewatered bead resin (Class B) transported in a Type A shipping cask.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicator submittals listed below:

MS09: Residual Heat Removal Systems (IP Section 02.08)===

(1) Unit 1 (October 1, 2021, through September 30, 2022)

(2) Unit 2 (October 1, 2021, through September 30, 2022)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 (October 1, 2021, through September 30, 2022)

(2) Unit 2 (October 1, 2021, through September 30, 2022)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) Unit 1 (January 1, 2021 - September 30, 2022)

Unit 2 (January 1, 2021 - September 30, 2022)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) Unit 1 (January 1, 2021 - September 30, 2022)

Unit 2 (January 1, 2021 - September 30, 2022)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Unit 2, head stud elongation measurement on October 30, 2022

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in foreign material issues on the week of December 16, 2022.

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 05000499/2021-002-00, Condition Prohibited by Technical Specifications due to Inoperable Train of Essential Core Cooling System and Containment Spray System, (ADAMS Accession No. ML21355A278). The inspection conclusions associated with this LER are documented in report South Texas Project Electric Generating Station, Units 1 and 2 - Integrated Inspection Report 05000498/2021004 AND 05000499/2021004 under Inspection Results Section 71152.

(2) LER 05000499/2021-002-01, Supplement to Condition Prohibited by Technical Specifications due to Inoperable Train of Essential Core Cooling System and Containment Spray System, (ADAMS Accession No. ML22186A228). The inspection conclusions associated with this LER are documented in report South Texas Project Electric Generating Station, Units 1 and 2 - Integrated Inspection Report 05000498/2021004 AND 05000499/2021004 under Inspection Results Section

INSPECTION RESULTS

Failure to Follow Procedure During Tensioning of Reactor Vessel Head Studs Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.13] - 71111.15 NCV 05000499/2022004-01 Consistent Open/Closed Process The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 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. Specifically, the licensee performed actions that were outside the reactor head stud tensioning procedure. The licensee fully de-tensioned and re-tensioned a single reactor head stud which was not prescribed by the procedure and had not been evaluated.

Description:

On October 30, 2022, the licensee began the process of tensioning the reactor head after the refueling process was complete during the Unit 2 refueling outage 2RE22.

Using procedure 0PMP04-RX-0018A, Non-Rapid Refueling Mechanical Support, revision 24, the licensee completed the steps required for the head stud tensioning first pass and second pass.

To determine if a subsequent adjusting pass was needed, the licensee took elongation measurements of each reactor stud to ensure proper elongation force was applied. The elongation measurements were recorded in table III of the procedure.

Head stud 12 appeared to have elongation readings which were outside of what was achievable during the test. The licensee decided they would need to take head stud 12 back to a de-tensioned state to repeat the initial elongation readings.

Normally, all 36 head studs are de-tensioned or tensioned in 12 predetermined sets. Each set consists of three head studs evenly spaced 120 degrees apart. In this instance, the licensee only de-tensioned head stud 12. A second initial elongation measurement was recorded with the subsequent first and second pass elongations reperformed only for head stud 12. The new elongation measurements were within the acceptance criteria and remained in-band after several other head studs were adjusted during the subsequent adjusting pass.

The inspectors noted that the procedure does not allow for a complete relaxation of head studs in the manner that was performed. During initial de-tensioning of the reactor head, head stud sets are de-tensioned over the course of two passes with varying amounts of de-tensioning per set. During the tensioning portion of the procedure, the licensee is instructed to tension the head in two passes with an adjusting pass as needed. This adjusting pass is only to raise or lower the tension on each stud that has elongation readings outside of acceptance criteria, and only enough to get the elongation within band. Instead, the licensee de-tensioned a single head stud all the way back to zero to start the process over. This was performed outside the bounds of procedure 0PMP04-RX-0018A.

Corrective Actions: The licensee performed engineering evaluations and received memos from the refueling support vendor that supported that head stud 12 did not experience an over-torque condition and that the process of de-tensioning a single head stud followed by re-tensioning would not adversely impact the reactor head tensioning process.

Corrective Action References: Condition Reports (CR) 2022-11112 and CR 2022-11138

Performance Assessment:

Performance Deficiency: The licensee failed 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. Specifically, the licensee performed actions that were not prescribed by the reactor head stud tensioning procedure. The licensee fully de-tensioned and re-tensioned a single reactor head stud which was not specifically allowed by the procedure and had not been evaluated.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee performed actions that were not evaluated per the approved procedure for de-tensioning and tensioning of reactor head studs. The licensee had not evaluated and formalized procedural steps for the actions that were performed to assemble the reactor in a manner that was analyzed to withstand normal and accident conditions.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix G, Shutdown Safety SDP. the inspectors determined that this finding is of very low safety significance (Green), because it did not involve protection of the reactor pressure vessel against fracture, involve fuel bundle misplacement or misorientation in the reactor core, did not affect low temperature over pressurization, did not affect freeze seals, did not affect steam generator nozzle dams, did not affect criticality, did not affect drain down paths, and did not affect the containment barrier.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. The licensee failed to use one of their systematic approaches to make procedural changes.

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 requires 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 October 30, 2022, the procedure for tensioning the reactor head studs was not properly preplanned and performed in accordance with written procedures or documented instructions appropriate to the circumstances. Specifically, the licensee performed actions that were not prescribed in procedure 0PMP04-RX-0018A, without evaluation and documentation of the activity.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Inform Workers of Current Radiological Conditions Prior to Entry into a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.4] - 71124.01 Radiation Safety NCV 05000499/2022004-02 Teamwork Open/Closed A self-revealed Green, non-cited violation of technical specification 6.8.1(a) was identified for the licensees failure to follow radiation procedure 0PGP03-ZR-0050, Radiation Protection Program, revision 17, step 6.7.2 which stated appropriate radiological instruction shall be provided to all individuals with access to the restricted area commensurate with potential radiological protection hazards in the area to be entered. Specifically, the welding crew was not appropriately briefed prior to entering a high radiation area (HRA).

Description:

On June 2, 2022, a welder entered the unit 2 cask decontamination area (CDA)after the removal of the forced helium drying remote operated valve assembly and pie shielding from the multi-purpose canister and received a dose rate alarm upon entering the CDA.

The welder was part of a welding crew that was briefed at the containment access facility so they could begin to set up for their work at the CDA under radiation worker permit 22-0307 task 71. The workers were briefed to a similar cask from unit 1 via survey No.119234. This survey was not of the cask that the welding crew would be working on for the job. However, Unit 1's CDA survey showed dose rates can change significantly after removal of the forced helium drying remote operated valve assembly and the pie shielding.

Radiation protection informed the welding crew to get a more up to date brief in the field from the field technician before entering the area.

Prior to the workers entering the CDA, a radiation protection technician completed radiation surveys of the area to identify any radiological changes after the assembly and pie shielding were removed. The radiation protection technician left the CDA to finish counting contamination smears that were collected during these surveys. The actual radiological conditions had changed and a peak dose rate of nearly two times higher than what the workers were briefed to was identified. A peak dose rate of 800 millirem per hour at 30 cm was identified.

When the welding crew arrived in the CDA, they could not locate the radiation protection technician in the area. A welding crew worker believed they had been fully briefed at the containment access facility and entered the high radiation area of the CDA. The individual received a dose rate alarm once inside the area. The workers dose rate alarm setpoint was 350 millirem per hour. Upon receiving the dose rate alarm, the work crew promptly exited the area.

Corrective Actions: The licensee entered the issue into the corrective action program to determine appropriate actions.

Corrective Action References: CR 2022-05491

Performance Assessment:

Performance Deficiency: The failure to inform workers of current radiological conditions prior to entry into an HRA was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the worker entered the CDA and received a dose rate alarm after entering the area. The finding was like example 6.a in Inspection Manual Chapter 0612, Power Reactor Inspection Reports -

Examples of Minor Issues, appendix E. Specifically, the welding crew workers were not informed of the current radiological conditions before they entered a high radiation area for work. In this case, the failure to properly inform the workers of radiological conditions from a recent survey resulted in a worker entering unknown radiological conditions and receiving a dose rate alarm.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had very low safety significance (Green) because:

(1) it was not associated with ALARA planning and work controls,

(2) it was not an overexposure,

(3) there was no substantial potential for overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, there was a breakdown in communication between radiation protection technicians in the field and the containment access facility radiation protection technicians, who were allowing individuals to enter the radiological controlled area, regarding the status of the project, availability of radiation protection at the location, and radiological conditions at the cask contributed to this performance deficiency.

Enforcement:

Violation: Technical specifications 6.8.1(a) requires, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33, appendix A, section 7.e. required procedures for Access Control to Radiation Areas Including a Radiation Work Permit (RWP) System. The licensee established procedure 0PGP03-ZR-0050, Radiological Access Controls/Standards, revision 48, which established basic radiation protection requirements and expectations for workers with the potential to be exposed or actually exposed to radiation or radioactive material.

Procedure 0PGP03-ZR-0050, section 6.7.2 stated appropriate radiological instruction shall be provided to all individuals with access to the restricted area commensurate with potential radiological protection hazards in the area to be entered.

Contrary to the above, radiation protection technicians failed to provide appropriate radiological instruction to all individuals with access to the restricted area commensurate with potential radiological protection hazards in the area to be entered. Specifically, on June 2, 2022, a welding crew was not briefed to the current radiological conditions of the CDA before they entered and as a result, one worker received a dose rate alarm.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Follow a Radiological Work Permit Requirement Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.12] - Avoid 71124.01 Radiation Safety NCV 05000499/2022004-03 Complacency Open/Closed A self-revealed Green, non-cited violation of technical specification 6.8.1(a) was identified for the licensees failure to follow radiation procedure 0PGP03-ZR-0051, Radiological Access Controls/ Standards, revision 48, step 7.1.1 which stated a workers responsibility is to comply with the requirements set forth in their radiological work permit. Specifically, the worker failed to comply with requirements of radiological work permit (RWP) 2022-2520, task 22, revision 2, which required a powered air purifying respirator (PAPR) to be worn if entering the lower internals storage area (LISA) for installation/removal of the blind flanges and support.

Description:

On October 9, 2022, a contract worker alarmed the personal contamination monitors as they were exiting the unit 2 radiological controlled area (RCA). The individual was instructed to shower and proceeded to get a whole-body count where it was determined to be skin contamination. The skin contamination resulted in the worker receiving approximately 283 millirem (mrem) skin dose.

The worker had entered the RCA to complete a task of installing a blind flange within the LISA located inside the reactor cavity. After the individual completed their work, they exited the RCA where the personnel contamination monitor alarm occurred detecting the contamination. Radiation work permit 2022-2502, task 22, had a requirement for workers to wear a PAPR when entering the LISA due to the risk of possible contamination and exposure to discrete radiation particles. This requirement to wear a PAPR was set in place from ALARA review package No. 22-6653-6 due to the review of historical surveys identifying the potential risk of contamination and discrete particles when entering the fuel cavity. However, the worker wore a face shield during the job because they and the radiation protection technician failed to see this requirement within the RWP.

The worker did not see the requirement for a PAPR when accessing the LISA as they reviewed the RWP prior to entering the RCA. In addition, when the worker was briefed at RCA access by radiation protection, the radiation protection technician failed to fully scroll down on the computer screen to see the requirement to wear a PAPR when working in the LISA. As a result, the radiation protection technician did not correct the worker from wearing a face shield.

Corrective Actions: The licensee entered the issue into the corrective action program to determine appropriate actions.

Corrective Action References: CR 2022-10150

Performance Assessment:

Performance Deficiency: The failure to follow a radiological work permit requirement was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the worker within the LISA received unintended skin exposure from a radioactive particle. The finding was not like examples in Inspection Manual Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues, appendix E. However, the preamble of the health physics chapter 6 describes the significance of a failed radiological barrier in determining whether an issue is minor or more than minor. A radiation protection barrier is a program element that serves a specific radiation safety function. This performance deficiency was determined to be more than minor because the failure to follow a radiological work permit requirement was a failed radiological barrier. Specifically, the PAPR was an RWP requirement due to an identified risk of potential radioactive particles present for the job. In this case, the failure to wear the required PAPR resulted in a workers unintended skin exposure of 283 mrem.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had very low safety significance (Green) because:

(1) it was not associated with ALARA planning and work controls,

(2) it was not an overexposure,

(3) there was no substantial potential for overexposure, and

(4) the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the opportunity to identify the workers mistake to fully understand their RWP requirement was available when the radiation protection reviewed the RWP with the worker prior to the workers entry into the RCA. However, they both failed to fully scroll down in the RWP to see all the RWP requirements themselves.

Enforcement:

Violation: Technical specification 6.8.1(a) requires, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33, appendix A, section 7.e. required procedures for Access Control to Radiation Areas Including a Radiation Work Permit (RWP) System. The licensee established procedure 0PGP03-ZR-0051, Radiological Access Controls/Standards, revision 48, which established basic radiation protection requirements and expectations for radiation workers engaged in radiological work that included the use of radiological work permits.

Procedure 0PGP03-ZR-0051, section 7.1.1 stated, in part, workers will comply with all requirements of the RWP used for RCA entry. The worker was assigned RWP 2022-2520, task 22, Reactor Head Disassembly/Assembly, revision 2, which required a PAPR to be worn if entering the LISA for the installation/removal of the blind flanges and support.

Contrary to the above, a worker failed to comply with the RWP requirement which required a PAPR to be worn if entering the LISA for the installation/removal of the blind flanges and support. Specifically, on October 9, 2022, a worker wore a face shield and did not wear the required PAPR. As a result, the worker obtained skin contamination on their face which resulted in an unintended skin exposure of 283 mrem.

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 71124.01 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: Technical specification 6.12.2 states, in part, that areas accessible to individuals with radiation levels greater than 1,000 millirem per hour (mrem/hr) at 30 centimeters but less than 500 rads in one hour at one meter from the radiation source shall be provided with locked or continuously guarded doors to prevent unauthorized entry.

Contrary to the technical specification requirements, the licensee did not provide locked or continuously guarded doors for an area accessible to individuals with radiation levels greater than 1,000 millirem per hour (mrem/hr) at 30 centimeters but less than 500 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at one meter.

On October 28, 2022, after the reactor cavity was surveyed to brief workers for decontamination activities on the night shift, radiation protection staff changed the radiological postings and controls of the reactor cavity from a technical specification 6.12.2 high radiation area (LHRA) to a high radiation area, which also changed the postings and controls for the lower internal storage area (LISA) to a high radiation area. The LISA had not been separately posted or controlled as an LHRA. A prior survey (No. 121906 dated October 28, 2022)established the entire reactor cavity as an LHRA, and a LISA confirmatory/pre-decontamination survey (No. 121939 dated October 29, 2022) supported LHRA conditions in the LISA with a specific area recorded as 4,000 mrem/hr on contact and 3,000 mrem/hr at 30 centimeters. The ladder used to access the LISA was not recognized as needing LHRA controls until a supervisor reviewing the prior shifts activities noticed the changed posting and controls which left the LISA not controlled or posted as an LHRA. The supervisor sent an individual to guard the reactor cavity access until the ladder at the LISA entry was secured and properly posted. The area was not correctly posted or controlled for approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> and 30 minutes. A review of activities after the posting and controls were changed revealed no entries were made into the LISA during this period.

Significance/Severity: Green. The significance of the finding was assessed using IMC 0609, Appendix C, Occupational Radiation Safety SDP, and because the finding was not: (1)related to as low as is reasonably achievable (ALARA) planning,

(2) did not involve an overexposure,

(3) did not involve a substantial potential for overexposure, and

(4) the ability to assess dose was not compromised, the finding was determined to be of very low safety significance (Green).

Corrective Action References: Condition Report (CR) 2022-11057 Licensee-Identified Non-Cited Violation 71124.01 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: Technical specifications 6.8.1(a) required, in part, that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33, appendix A, section 7.e. required procedures for Implementation of ALARA Program. The licensees procedure 0PGP03-ZR-0052, ALARA Program, revision 20, section 5.8 established basic ALARA program requirements in plant design and procedures that shall be met before implementing engineering and design changes within the radiological controlled area (RCA). Engineering procedure 0PGP04-ZE-0409, Standard Design Process Interface was the procedure used to ensure the ALARA program requirements were met.

During revision 4 of the procedure, which went into effect on June 25, 2020, the following language was removed from step 7.3.3.2 which required a radiation protection/ALARA review: for any changes inside the RCA. The purpose of this type of review was to control the licensees source term by reviewing potential changes which may cause an increase in radiological activity resulting in possible increased dose to occupational workers

Contrary to the above, the licensee failed to perform a radiation protection/ALARA review for engineering and design changes within the RCA in accordance with their ALARA program. Specifically, during a self-assessment, the licensee identified a failure to perform ALARA reviews/evaluations from June 25, 2020, to May 26, 2022, before implementing engineering changes within the RCA. In condition report CR 2022-01816, the licensee identified procedure 0PGP04-ZE-0409, Standard Design Process Interface, revision 4 as a cause of this failure due to ALARA reviews being removed from the procedure.

The licensee initiated corrective actions to perform a cause evaluation and develop corrective actions to address the conditions for all associated procedures and affected engineering changes.

Significance/Severity: Green. The significance of the finding was assessed using IMC 0609, Appendix C, Occupational Radiation Safety SDP, and because the finding was not: (1)related to ALARA planning,

(2) did not involve an overexposure,

(3) did not involve a substantial potential for overexposure, and

(4) the ability to assess dose was not compromised, the finding was determined to be of very low safety significance (Green).

Corrective Action References: The condition was entered into the corrective action program as CR 2022-01816.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On November 3, 2022, the inspectors presented the Unit 2 inservice inspection exit meeting inspection results to G. Powell, President & CEO, and other members of the licensee staff.

On November 7, 2022, the inspectors presented the occupational radiation safety inspection results to G. Powell, President and CEO, and other members of the licensee staff.

On November 15, 2022, the inspectors presented the 2022 ARQ exit meeting inspection results to S. Shea, Licensed Operator Requalification Supervisor, and other members of the licensee staff.

On November 17, 2022, the inspectors presented the public radiation safety inspection results to S. Cornelius, Vice President, Finance and Accounting, and other members of the licensee staff.

On January 12, 2023, the inspectors presented the integrated inspection results to G. Powell, President and CEO, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07A Corrective Action CR-YYYY-NNNN 2020-12391, 2020-11006, 2020-10863, 2022-2063

Documents

71111.08P Corrective Action CR-YYYY-NNNN 2021-4885, 2021-5954, 2022-4727, 2022-9729, 2022-9741,

Documents 2022-9744, 2022-10054, 2022-10059, 2022-10063,

22-10064, 2022-10198, 2022-10201, 2022-10330,

22-10331, 2022-10512, 2022-10516, 2022-10518,

22-10520, 2022-10521, 2022-10524, 2022-10525,

22-10526, 2022-10588

Corrective Action CR-YYYY-NNNN 2022-10459, 2022-10460, 2022-10536

Documents

Resulting from

Inspection

Engineering Boric Acid 22-2479, 22-5129

Evaluations Evaluations

Miscellaneous Inservice Inspection Program Plan for the South Texas Project 10

Electric Generating Station Units 1 and 2

NOC-AE-Request for Relief from ASME Boiler and Pressure Vessel 07/10/2000

00000868 Code Section XI Requirements for Containment Tendon

Examination and Inspection

NOC-AE-Amended Request for Relief from ASME Boiler and Pressure 09/14/2000

00000921 Vessel Code Section XI Requirements for Containment

Tendon Examination and Inspection

NOC-AE-Proposed Alternative to ASME Boiler & Pressure Vessel Code 09/26/2019

19003684 Section Xl Requirements for Repair/Replacement of Essential

Cooling Water (ECW) System Class 3 Buried Piping in

accordance with 10 CFR 50.55a(z)(1)

NOC-AE-Supplemental Information for Proposed Alternative to ASME 11/26/2019

19003696 Code Requirements for the Repair/Replacement of Essential

Cooling Water System Class 3 Buried Piping

NDE Reports PT-2022-060 Liquid Penetrant Examination. Reactor Coolant System Loop 10/21/2022

2D Hot Leg Narrow Range Temperature Element

UT-2022-008 Ultrasonic Examination, Thermal Fatigue-Pipe to Elbow, 10/13/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Elbow to Pipe / 4-RC-2323-BB1 Weld 2, 4-RC-2323-BB1 Weld

UT-2022-011 Ultrasonic Examination, Elbow to Pipe, Elbow to Pipe, Pipe to 10/17/2022

Pipe / 12-RC-2112-BB1 Weld 7, 12-RC-2112-BB1 Weld 10,

2-RC-2112-BB1 Weld 8

UT-2022-011 Ultrasonic Examination, Shell F to Lower Head, Shell F 10/17/2022

Longitudinal Weld

UT-2022-012 Ultrasonic Examination, Shell F to Lower Head, Shell F 10/17/2022

Longitudinal Weld, PRZ-2-C7, PRZ-2-L6

UT-2022-013 Ultrasonic Examination, Elbow to Pipe, Pipe to Elbow, Pipe to 10/20/2022

Branch Connection / 12-RC-2125-BB1 Weld 12, 13, & 14

UT-2022-060 Ultrasonic Examination, Thermal Fatigue-Pipe to Elbow / 4-10/17/2022

RC-2126-BB1 Weld 2

VT1/3-006 RHR Pump 2B Discharge Relief Valve 10/12/2022

VTIWE-2022-003 Visual Examination, Containment Liner (240-360 DEG) /CC-10/19/2022

LINER-MB-1

VTIWE-2022-014 Visual Examination, Containment Liner (335-340 DEG) /CC-10/29/2022

LINER-MB-1

Procedures 0PEP10-ZA-0010 Liquid Penetrant Examination (Color Contrast Solvent 9

Removable)

0PEP10-ZA-0024 ASME XI Examination for VT-1 and VT-3 6

0PGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks 14

0PMP02-ZW-General Welding Requirements 12

0001

0PMP02-ZW-ASME Repair/Replacement Welding Requirements 2

0001A

0PMP02-ZW-ASME/ANSI B31.1 Welding Requirements 2

0001B

0PMP02-ZW-Welding Documentation Requirements 2

0001D

0PMP02-ZW-Welding Procedure Specification Preparation and Qualification8

0002

0PMP02-ZW-Welder Qualification and Certification 12

0003

Inspection Type Designation Description or Title Revision or

Procedure Date

0PMP02-ZW-Control of Filler Materials 20

0004

0PMP02-ZW-Arc Wire Thermal Spray Coatings 2

0006

OPGP03-ZE-RCS Pressure Boundary Inspection for Boric Acid Leaks 13

0033

PDI-UT-2 Generic Procedure for the Ultrasonic Examination of Austenitic H

Pipe Welds

PDI-UT-4 Generic Procedure for the Ultrasonic Examination of Bolts and F

Studs from the Bore

PQR-016 Procedure Qualification Record, Gas Tungsten Arc Welding 06/20/1988

(WPS P8-T-Ag-1)

PQR-035 Procedure Qualification Record, Gas Tungsten Arc Welding 06/09/1993

(WPS P8-T-Ag)

PQR-037 Procedure Qualification Record, Gas Tungsten Arc Welding 09/05/1989

(WPS P8-T-Ag, P8-A, AND P8-AT-Ag)

PQR-046 Procedure Qualification Record, Gas Tungsten Arc Welding 01/24/1990

(WPS P8-T-Ag, P8-AT-Ag)

PQR-197 Procedure Qualification Record, Gas Tungsten Arc Welding 04/10/2003

(WPS P8-T-Ag)

UTI-065 Ultrasonic Technical Instruction, Ultrasonic Examination of 0

Small-Diameter Piping Butt Welds and

Components for Thermal Fatigue Damage

WPS P8-T-Ag Weld Procedure Specifications, Gas Tungsten Arc Welding 11/11/2015

Self-Assessments 0PGP03-ZX-0003 Snapshot Self-Assessment Plan 8

Work Orders Work 615668, 651702, 669390, 678624

Authorization

Number (WAN)

71111.11A Miscellaneous 2022 Annual Licensed Operator Requalification Examination 0

Results

71111.12 Corrective Action CR-YYYY-NNNN 2022-11716, 2022-11764

Documents

71111.15 Corrective Action CR-YYYY-NNNN 2022-00012

Documents

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Corrective Action CR-YYYY-NNNN 2022-10201, 2021-11372, 2021-4756

Documents

71111.19 Corrective Action CR-YYYY-NNNN 2022-11709, 2022-11764

Documents

71111.22 Corrective Action CR-YYYY-NNNN 2022-11259, 2022-10818, 2022-10891, 2022-10938,

Documents 2014-2704, 2015-1103, 2021-13023, 2022-9062, 2022-9065

Procedures 0PSP03-CC-0002 Component Cooling Water Pump 1B(2B) Inservice Test 19

71124.01 Corrective Action CR-YYYY-NNNN 2021-4336, 2021-4365, 2021-4970, 2021-5142, 2021-5832,

Documents 2021-6465, 2021-7132, 2021-8488, 2021-10316, 2021-10326,

21-10528, 2021-10839, 2021-10873, 2021-11184,

21-11384, 2021-11548, 2022-0987, 2022-1488, 2022-1504,

22-1816, 2022-1818, 2022-1820, 2022-1821, 2022-1822,

22-2215, 2022-3159, 2022-3672, 2022-3918, 2022-3919,

22-4088, 2022-4525, 2022-5086, 2022-5491, 2022-5492,

22-6713, 2022-6886, 2022-7498, 2022-8936, 2022-9234,

22-9928

Miscellaneous 0PEP02-ZM-0009 Attachment 1, spent fuel pool inventory form 07/28/2022

Procedures 0DCS03-ZO-0003 MPC Loading Operations 16

0PEP02-ZM-0009 Spent Fuel Pool Storage and Work 10

0PGP03-ZR-0044 Contamination Control Program 20

0PGP03-ZR-0050 Radiation Protection Program 17

0PGP03-ZR-0051 Radiological Access Controls/Standards 48

0PGP03-ZR-0052 ALARA Program 20

0PGP04-ZE-0409 Standard Design Process Interface 4, 5

0PRP04-ZR-0004 Release of Materials from Radiologically Controlled Areas 31

0PRP04-ZR-0013 Radiological Survey Program 41

0PRP04-ZR-0015 Radiological Postings and Warning Devices 40

0PRP04-ZR-0019 High Radiation Area Access Controls 3

0PRP07-ZR-0001 ALARA Engineering and Procedure Review 4

0PRP07-ZR-0010 Radiation Work Permits/ Radiological Work ALARA Reviews 41

0PRP07-ZR-0033 Radiological Briefings 8

0PRP07-ZR-0036 Radiological Controls for Dry Cask Storage 4

Radiation Surveys Survey # 103217, 114450, 114477, 116369, 119234, 119250, 119434,

119441, 119580, 119580, 119581, 120152, 120600, 121105,

Inspection Type Designation Description or Title Revision or

Procedure Date

21601, 121608, 121609, 121618, 121659

Radiation Work RWP 22-2501 2RE22 - routine and planned maintenance and plant support 2

Permits (RWPs) activities

RWP 22-2502 Radiation protection activities 0

RWP 22-2522 2RE22 - reactor head disassembly/ assembly, high 0

radiological risk

Self-Assessments 22-02(RC) STP Nuclear Operating Company Radiological Controls 03/10/2022

Quality Audit Report

71124.03 Corrective Action CR-YYYY-NNNN 2020-6628, 2021-3504, 2021-3791, 2021-4176, 2021-4802,

Documents 2021-4860, 2021-6723, 2021-6769, 2021-8110, 2021-8541,

21-8681, 2021-9407, 2021-9935, 2021-9968, 2021-10603,

21-10855, 2021-10940, 2021-11047, 2021-11344,

21-12343, 2022-213, 2022-1238, 2022-1361, 2022-1816,

22-6077, 2022-6756, 2022-6849, 2022-7364, 2022-7697,

22-8289, 2022-8430, 2022-8577, 2022-8608, 2022-9103,

22-9105, 2022-9355, 2022-9711, 2022-10626, 2022-10823

Procedures 0PEP05-ZH-0008 MAB, TSC and RCB HVAC In-Place HEPA Filter Leak Test 9

0PGP03-ZI-0015 Control and Use of Industrial Compressed Air and Gases 7

0PGP03-ZR-0054 Respiratory Protection Program 23

0PRP04-ZR-0016 Radiological Air Sampling & Analysis 35

0PRP05-ZR-0030 Portable Air Monitoring Instruments (AMS-4) 26

0PRP06-ZR-0002 Respiratory Protection Equipment Issue and Return 32

0PRP06-ZR-0004 Cleaning and Sanitizing of Respiratory Protection Equipment11

0PRP06-ZR-0005 Maintenance, Inspection, and Storage of Respiratory 19

Protection Equipment

0PRP06-ZR-0007 Use of Supplied Air Respiratory Equipment 10

0PRP06-ZR-0008 Air Quality Evaluation for Compressors or Pressurized Gas 6

Cylinders

OPSP11-ZH-0008 CRE and FHB HVAC In-Place HEPA Filter Leak Test 21

OPSP11-ZH-0008 CRE and FHB HVAC In-Place HEPA Filter Leak Test 22

Self-Assessments CR 22-7418 Snapshot Self-Assessment: In-Plant Airborne Monitoring Pre-10/6/2022

Inspection Simple Self-Assessment

Work Orders Work 546355, 546657, 546659, 547232, 557078, 557080, 557974,

Authorization 557979, 569852, 569853, 583664, 583668, 584089, 584091,

Inspection Type Designation Description or Title Revision or

Procedure Date

Number (WAN) 588577, 588581,590746, 594967, 595889, 595894, 605288,

605300

71124.08 Miscellaneous PO704362-24 Waste characterization for STP-1-22-041 waste shipment 11/06/2022

Procedures 0PRP03-ZR-0002 Radioactive Waste Shipments 28

Shipping Records STP-1-22-041 Class B dewatered bead resin (LSA-II), in a high integrity 11/16/2022

container, PO704362-24

71151 Calculations Gas Release Permit Reports: Unit 1 Unit Vent and Reactor

Control Building - January through September 2022

Calibration 400-00099-XXX AMS-4 Calibration Report and Records: March 29, 2021

Records through September 28, 2022

Corrective Action CR-YYYY-NNNN 2021-2083, 2021-5500, 2021-6100, 2021-7387, 2021-7655,

Documents 2021-9056, 2021-9618, 2021-9975, 2021-10084, 2021-11774,

21-13234, 2022-3173, 2022-5726

71152A Corrective Action CR-YYYY-NNNN 2022-00012

Documents

71152S Corrective Action CR-YYYY-NNNN 2022-10710, 2022-5388, 2022-11102, 2022-8684, 2022-6910,

Documents 2022-10667, 2022-6911

25