IR 05000498/2022012
| ML22229A089 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/31/2022 |
| From: | Vincent Gaddy NRC/RGN-IV/DORS |
| To: | Gerry Powell South Texas |
| Sifre W | |
| References | |
| IR 2022012 | |
| Download: ML22229A089 (15) | |
Text
August 31, 2022
SUBJECT:
SOUTH TEXAS PROJECT - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000498/2022012 AND 05000499/2022012
Dear Mr. Powell:
On August 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at South Texas Project.
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, Signed by Gaddy, Vincent on 08/31/22 Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000498 and 05000499 License Numbers: NPF-76 and NPF-80 Report Numbers: 05000498/2022012 and 05000499/2022012 Enterprise Identifier: I-2022-012-0004 Licensee: STP Nuclear Operating Company Facility: South Texas Project Location: Wadsworth, TX Inspection Dates: July 18, 2022 to August 08, 2022 Inspectors: W. Cullum, Reactor Inspector S. Graves, Senior Reactor Inspector W. Sifre, Senior Reactor Inspector F. Thomas, Reactor Inspector Approved By: Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) inspection at South Texas Project, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to fully implement procedures to install and maintain vital electrical panels.
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000498,05000499/2022012-01 Open/Closed The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, with two examples for the failure to ensure that activities affecting quality associated with Vital 120Vac Distribution Panels were accomplished in accordance with documented instructions, procedures, or drawings.
Example 1: Prior to July 18, 2022, the licensee failed to ensure that penetrations for electrical cables routed through the top of the panels were appropriately sealed to prevent water or dust intrusion; and Example 2: Between January 2003 and July 18, 2022, the licensee inappropriately closed a preventive maintenance activity resulting in the failure to complete a required preventive maintenance action on the fused disconnect for steam generator 1A power-operated relief valve (PORV) servo amplifier.
Additional Tracking Items
None.
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.
REACTOR SAFETY
===71111.21M - Design Bases Assurance Inspection (Teams) The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (5 Samples)
- (1) Unit 1 120 Vac Vital Panel 1201 Design basis calculations Electrical drawings Vendor technical documentation Corrective actions associated with vital 120Vac panel Preventative maintenance records to verify panel maintained within design basis Maintenance work orders to verify panel maintained within design basis
- (2) Unit 1 4160 VAC Bus 1E1C Design basis documents Electrical drawings Maintenance, inspection, and testing procedures Vendor operating and maintenance requirements Corrective actions associated with 4160 VAC bus Short circuit calculations, coordination studies, voltage drop calculations, and switchgear maintenance activities to ensure they were appropriate for the design of the Unit 1 4160 VAC Bus 1E1C
- (3) Unit 2 480 VAC E1C2 Motor Control Center (MCC):
Design basis documents Electrical drawings Maintenance, inspection, and testing procedures Vendor operating and maintenance requirements Corrective actions associated with 480 VAC MCC Short circuit calculations, coordination studies, and maintenance activities to ensure they were appropriate for the design of the Unit 2 480 VAC E1C2 MCC
- (4) Unit 1 Emergency Diesel Generator DG11 Fuel Oil Storage Tank and associated fuel delivery system Air Starting System design and capabilities Emergency fan and associated damper ratings and start criteria Jacket water heat exchanger testing
- (5) Unit 1 Pressurizer PORV 656A Piping and instrument diagrams Environmental qualification Maintenance Design basis differential pressure Design flowrate Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)
Unit 1 Essential Cooling Water Pump 1A System drawings to determine flow directions, flow diversions and flow rate to specific loads Vendor certified pump Head Capacity curves, to ascertain that the pump satisfies the specified values as well as the most limiting conditions Pump Net Positive Suction Head curve, to verify that the available head to satisfy the requirements for the various flow rates System normal operating procedures, to verify proper system line-up and operator capabilities System abnormal operating procedures to assure that essential equipment is protected In-service testing procedures for pumps and check valves Modification Review - Permanent Mods (IP Section 02.03) ===
- (1) EC 12-31926-359, Replacement of Unit 1 Class IE Switchgear E1C Circuit Breakers During 1R23 Outage
- (2) EC 17-14971-1, Installation of Cathodic Protection System Deep Anode Groundbed For Auxiliary Feedwater Area
- (4) EC 17-22335-2, Replace 27C Relay (ITE J13) - Containment Spray Pump 1B Control Circuit
- (5) EC 17-12897-Weld Plates on Exterior of Diesel Generator Building to Prevent Water
Intrusion Review of Operating Experience Issues (IP Section 02.06) (3 Samples)
- (1) NEI 03-08, Guideline for the Management of Materials Issues, Revision 4
- (3) SOER 07-02, Recent Intake Cooling Water Blockage, Revision
INSPECTION RESULTS
Failure to fully implement procedures to install and maintain vital electrical panels.
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000498,05000499/2022012-01 Open/Closed The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, with two examples for the failure to ensure that activities affecting quality associated with Vital 120Vac Distribution Panels were accomplished in accordance with documented instructions, procedures, or drawings.
Example 1: Prior to July 18, 2022, the licensee failed to ensure that penetrations for electrical cables routed through the top of the panels were appropriately sealed to prevent water or dust intrusion; and Example 2: Between January 2003 and July 18, 2022, the licensee inappropriately closed a preventive maintenance activity resulting in the failure to complete a required preventive maintenance action on the fused disconnect for steam generator 1A power-operated relief valve (PORV) servo amplifier.
Description:
For a selected Component during the Design Basis Assurance inspection, the team performed a walkdown of the Unit 1 safety-related 120Vac Vital AC Panel DP1201. As part of the walkdown, the inspectors questioned the licensee staff about the design of the panel, including the NEMA Enclosure type, and about any sealing requirements for cable penetrations through the top plate. Because the height of the enclosure prevented a visual inspection of the penetrations, the team requested photographs of the top to determine if the enclosure cable penetrations were appropriately sealed against potential moisture and dust intrusion. The team identified that these enclosures were categorized as NEMA 12 type enclosures designed for indoor use and typically constructed to protect against common hazards such as falling dirt and dripping fluids.
The photographs revealed that the top plate had several cable penetrations which appeared to be open and unsealed. After further inspection, the team determined that the licensee normally used the instructions in electrical drawing 5E030E00100, Sheet 3A, to configure and install dust and moisture seals for cable penetrations into the top of electrical equipment, including these enclosures. The team identified that the two penetrations had conduit bushings installed to protect the cable jackets from abrasion, but no sealing mechanism to prevent dust or moisture from entering the enclosure. The team subsequently requested the licensee to extend their review and photograph the penetrations in the other 120Vac vital panels across both units, which identified four additional panels with unsealed penetrations.
The team also reviewed maintenance history for panel DP1201, including the last completed preventive maintenance procedure and work order for the cleaning and inspection of the panel. The work order, completed in November 2012 identified that circuit #17 had been tagged out and removed from service at the time of maintenance, and had remained tagged out when the other work instruction steps completed. This circuit feeds steam generator 1A PORV servo amplifier. The team asked for documentation showing when this specific circuit had been subsequently maintained. The licensee researched this question and eventually determined that maintenance of the specific circuit had not been performed during the expected period because the work instruction had been inappropriately closed. When asked about subsequent performance of maintenance on the incomplete circuit, the last example of completed testing for this circuit was in 2003, resulting in a period of approximately 18 years without the preventive maintenance on the circuit being performed. Further discussions with the licensee identified that the 2012 preventive maintenance activity should have been marked as a partial by the Work Supervisor upon closeout as required by station Procedure MG-0006, Work Execution and Closeout Guideline, Revision 27, section 8.2.2, which also directs the user to 0PGP03-ZM-0002 Preventative Maintenance Program, Revision 42, section 4.9, for guidance on partial completion of a preventive maintenance activity. This guidance requires, in part, that for partially completed preventive maintenance activities with effective end of grace periods (such as the described preventive maintenance), they shall be rescheduled and performed, or deferred or waived prior to the end of the grace period.
Neither of these additional actions occurred for this activity.
Corrective Actions: This finding was entered into the licensees corrective action program as Condition Report 22-7368 for the unsealed penetrations, and Condition Report 22-7389 for the delayed preventive maintenance on the fused disconnect, which recommends scheduling performance of the maintenance during the next outage under work order 615485.
Performance Assessment:
Performance Deficiency: The failure to install required dust and moisture seals for penetrations in vital 120Vac distribution panels, and inappropriately closing an incomplete maintenance activity resulting in failure to perform required periodic maintenance on a fused disconnect link in panel DP1201 as required by station drawings and procedures is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Minor/MTM Screening - The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, South Texas Project staff failed to follow station guidance on installing dust and moisture seals on penetrations in electrical equipment and failed to follow plant procedural requirements by inappropriately closing a maintenance activity before it was complete.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Significance Determination - The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power dated 11/20/2020. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding to be of very low safety significance (Green) because the finding affected the design or qualification of a mitigating system, structure, or component it did not affect its operability or PRA functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to this requirement for vital 120Vac distribution panels, the licensee failed to ensure that activities affecting quality were accomplished in accordance with appropriate instructions, procedures or drawings. Specifically, prior to July 18, 2022, the licensee failed to ensure that penetrations for electrical cables routed through the top of vital panels were appropriately sealed after installation to prevent water or dust intrusion as required by station instructions and drawings, and between January 2003 and July 18, 2022, the licensee inappropriately closing a maintenance activity resulting in failure to perform required periodic maintenance on a fused disconnect link in Unit 1 panel DP1201.
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 August 8, 2022, the inspectors presented the Exit Meeting inspection results to Mr.
G. T. Powell, President and CEO, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21M Calculations 38289NS0012 Specification for Essential Cooling Water Pumps 2
3R289MC5633 Essential Cooling Water Pump Submergence 2
EC 5000 Voltage Regulation Study 16
EC 5001 Fault Analysis 9
EC-5008 Class 1E DC System Scenario, Battery / Charger / Inverter 15
Sizing & System Voltage Calculation
EC05014 Maximum Length of Control Cables / Class 1E and Non- 5
Class 1E
EC05029 4.16 KV Switchgear Relay Setting 6
EC05031 Protection 480 Volt Load Centers 8
EC05039 Control Cable Voltage Drop Verification 6
EC05052, Degraded and Undervoltage Protection and 120/208 VAC 7
Addendum 1 Panelboard Voltage Analysis
EC5013 Cathodic Protection System 4
MC-6288 Essential Cooling Water Pump Trip Forcing Functions with 1
Vacuum Breakers
MC-6472 DVAC [Degraded Voltage Actuator Capability] Calculation 3
AC [Alternating Current] Motor MOVs
Corrective Action Condition Record 97-4379, 12-29374, 12-29477, 12-31926, 17-14971, 19-
Documents 7373, 19-7401, 19-7402, 19-7423, 19-9655, 19-9825, 20-
5598,21-775, 19-291-208, 20-7869-3
Corrective Action 22-6891, 22-6894, 22-6895, 22-6945, 22-6948, 22-6951,
Documents 22-6952, 22-6964, 22-6965, 22-6966, 22-6967, 22-6968,
Resulting from 22-6970, 22-6972, 22-6990,22-7027, 22-7053, 22-7185, 22-
Inspection 7236, 22-7366, 22-7367, 22-7368, 22-7404, 22-7408
Drawings 00000E0AAAA Single Line Diagram Main One Line Diagram Unit No. 1 & 2 30
00009E0CC25#2, Elementary Diagram Reactor, Containment Fan Coolers 11
Sheet 01 21A & 21C, CCW [Component Cooling Water] Inlet MOV's
0064 & 0204
00009E0CC33#2, Elementary Diagram, Reactor Containment Fan Coolers, 11
Sheet 01 MOV's 0067 and 0207
00009E0CS01#1, Elementary Diagram, Containment Spray Pumps PA101B & 9
Inspection Type Designation Description or Title Revision or
Procedure Date
Sheet 02 PA101C
00009E0HF06#2, Elementary Diagram, F.H.B. [Fuel Handling Building] HVAC 12
Sheet 01 [Heating, Ventilation, and Air Conditioning], Exhaust Booster
Fans FN007, 008, & 009
00009E0PK01#1, Elementary Diagram, 4.16KV ESF [Engineered Safety 10
Sheet 01 Feature] Bus E1A, E1B & E1C Supply Breaker Control
00009E0PK04#1 Elementary Diagram ESF Transformer & 4.16KV Bus E1A, 14
E1B, & E1C Protection and Metering
00009E0PKAB#1 Single Line Diagram 4.16 KV Class 1E Switchgear E1B 14
00009E0PMAH#2, Single Line Diagram 480V Class 1E Motor E2C2 Control 21
Sheet 01 Center (EAB)
00009E0VAAA #1 Single Line Diagram Vital 120v AC Distribution Panels 27
DP001, DP1201 Channel I (EAB)
4040-01075HY Essential Cooling Water Pump General Arrangement D
4168-00066VA NBD-53 Backdraft Damper F
5E030E00100, Electrical General Notes And Details General Notes 10
Sheet 3A
5R289F05038 Essential Cooling Water System Train A 20
Sheet 1
5V159V00027 Heating Ventilation Air Conditioning Miscellaneous Buildings 12
Sheet 1 Essential Cooling Water Intake Structure & Electrical
Equipment Room
6D019M00020 General Arrangement Diesel Generator Building Plans & 9
Sections
6P-20-0-M-0031 Essential Cooling Water Intake & Discharge Structures 5
88956--00040L4 ONAN/ONAF XFMR W/ABB UZERT 200/600 LTC A
9-E-PKAC-01#1 Single Line Diagram 4.16 KV Class 1E Switchgear E1C 13
Engineering 12-31926-359 Replacement of Unit 1 Class IE Switchgear E1C Circuit 1
Changes Breakers During 1R23 Outage
2-31926-43, Class IE 4 . 16 KV Circuit Breaker Replacements 04/01/2015
Supplement 0
2-31926-43, Class 1E 4.16 KV Circuit Breaker Replacements 07/28/2016
Supplement 1
2-31926-43, Class 1E 4 .16 KV Circuit Breaker Replacements 03/22/2017
Inspection Type Designation Description or Title Revision or
Procedure Date
Supplement 3
17-14971-1 Installation of Cathodic Protection System Deep Anode 1
Groundbed For Auxiliary Feedwater Area
17-22335 Replace 27C Relay (ITE J13) Associated in Control Circuit 0
for Containment Spray Pump 1B
CN-3125 DCPs 12-31926-2 and 12-31926-3 are allowing either the 02/26/2015
existing air magnetic
circuit breakers or replacement vacuum circuit breakers to
be used.
Miscellaneous 001-002-496, 24 VSN Centrifugal Pump Installation and Operation Manual 6
0PGP04-ZA-0328 Design Criteria Class 1E AC Power Distribution 9
3E159ES0065 Specification for 5KV Class-1E Medium Voltage Breaker 0
Replacement
3V139VQ1002 Diesel Generator Building Emergency Ventilation System 3
Design Criteria
4E510EQ1005 Design Criteria Class 1E AC Power Distribution System 9
4E519EB1108 Class 1E 4.16 kV AC Power (PK) System 5
4E549EB01110 Design Basis Document Class 1E Vital 120Vac System 2
5Q159MB1023 Design Basis Document Standby Diesel Generator System 4
5R289MB01006 Design Basis Document Essential Cooling Water System 9
5V139VQ103 Diesel Generator Building Heating and Normal Ventilation 4
System Design Criteria
B05757-00008T4 Third Party Qualification (TPQ) Dedication Plan For
34149238 Siemens Type 5HKR-250-1200-58 4.76 KV Horizontal
Drawout Circuit Breaker
BC-TOP-3-A Tornado and Extreme Wind Design Criteria for Power Plants 3
POND Project Investigation of Low Potential Measurements at Concrete 12/2021
Number: 1210768 Water Tank
PRO055669PKG- Commercial Grade Dedication Package - Siemens 5HKR- 02/24/2017
250-1200-58 Circuit Breaker, 4.67 kV, Horizontal Draw-out,
with Type 3EF1-048-0A Surge Limiters
VTD-B455-0042 Vendor Technical Document, Installation/Maintenance 4
Instructions (Medium Voltage Power Circuit Breakers Type
5HK 1200 Thru 3000 Amperes 5000 Volts
Inspection Type Designation Description or Title Revision or
Procedure Date
VTD-B455-0094 Vendor Technical Document - Liquid Insulated Primary and 0
Secondary Unit Substation Transformers
VTD-B455-0108 Vendor Technical Document - ABB OnLoad Tap 0
Chargers, Type UZE and UZF With Motor Drive
Mechanism, Type BU3
VTD-C634-0001 STPNOC Site Specific Engineered Safety Features Diesel 1
Generator Engine Manual
VTD-C963-0009 Vendor Technical Document - Operating Manual for 03/24/2016
SRAYS, SRAYT Series Rectifiers
VTD-G080-0328 Vendor Technical Document for General Electric Series 300 1
Magnetic Contactors
VTD-H108-0017 Vendor Technical Document - Receiving, Handling, Storage, 0
And Maintenance Instructions For Class 1E AC And DC
Distribution Panels
VTD-P292-0001 Instruction Manual Operation, Maintenance and Parts List 5
for A.C. Synchronous Generator
VTD-S125-0023 Vendor Technical Document - Siemens Medium Voltage 03/26/2015
Replacement Breakers
VTD-S125-0024 Vendor Technical Document, Siemens 5HKR-250-1200 0
TOC [Truck-Operated Contact] Bracket Installation
VTD-S345-0020 Vendor Technical Document - Installation And Maintenance 0
Instructions QMB Fusible Switches
VTD-W120-0216 Vendor Technical Document - Cutler- 1
Hammer/Westinghouse AB De-Ion Circuit Breakers
VTD-W120-0220 Vendor Technical Document - K-FRAME MOLDED CASE 0
CIRCUIT BREAKERS TYPE DK: 250-400 AMPERES
TYPES KDB, KD, HKD, KWC: 100-400 AMPERES TYPES
Procedures 0PEP07-NM-0003 Plant Yard Cathodic Protection Potential Survey 11
0PGP03-ZM-0002 Preventative Maintenance Program 42
0PGP03-ZX- CAQ [Condition Adverse to Quality] Resolution Process 15
0002A
0PMP05-NA-0002 4160V Gould Breaker Tests 30
0PMP05-NA-0004 Molded Case Breaker Test 41
0PMP05-NA-0011 Siemens HKR Vacuum Breaker Maintenance and Tests 3
Inspection Type Designation Description or Title Revision or
Procedure Date
0PMP05-VA-0001 Class 1E Vital 120V Distribution Panel Tests 12
0POP04-VA-0001 Loss Of 120 VAC Class Vital Distribution 34
0PSP06-NZ-0006 Molded Case Breaker Functional Test and Inspection 30
0PSP06-PK-0008 4.16KV Class 1E Degraded Voltage Relay Channel 34
Calibration/TADOT [Trip Actuation Device Operational Test]
- Channel 4
MG-0006 Work Execution and Closeout Guideline 27
OPSP03-DG-0001 Standby Diesel 11(21) Operability Test 62
OPSP03-EW- Essential Cooling Water System Train A Testing 42
0017
Work Orders 196895, 407320, 485062, 501703, 501704, 501705,
501706, 505497, 535355, 553796, 555898, 555899,
555901, 555902, 555903, 555906, 567567, 567568,
575354, 577197, 599771, 606112, 613505, 626635, 629097
2