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, Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Signed by Gaddy, Vincent on 08/31/22 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:
05000498/2022012 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
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 Aspect Report Section Mitigating Systems Green NCV 05000498,05000499/2022012-01 Open/Closed None (NPP)71111.21M 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
- (2) ICES 456078, Unscheduled Power Reduction Due to Feedwater Heater Tube Leak
- (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 Aspect Report Section Mitigating Systems Green NCV 05000498,05000499/2022012-01 Open/Closed None (NPP)71111.21M 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
Procedure
Type
Designation
Description or Title
Revision or
Date
289NS0012
Specification for Essential Cooling Water Pumps
3R289MC5633
Essential Cooling Water Pump Submergence
Voltage Regulation Study
Fault Analysis
Class 1E DC System Scenario, Battery / Charger / Inverter
Sizing & System Voltage Calculation
Maximum Length of Control Cables / Class 1E and Non-
Class 1E
4.16 KV Switchgear Relay Setting
Protection 480 Volt Load Centers
Control Cable Voltage Drop Verification
Addendum 1
Degraded and Undervoltage Protection and 120/208 VAC
Panelboard Voltage Analysis
Cathodic Protection System
MC-6288
Essential Cooling Water Pump Trip Forcing Functions with
Vacuum Breakers
Calculations
MC-6472
DVAC [Degraded Voltage Actuator Capability] Calculation
AC [Alternating Current] Motor MOVs
Corrective Action
Documents
Condition Record
97-4379, 12-29374, 12-29477, 12-31926, 17-14971, 19-
7373, 19-7401, 19-7402, 19-7423, 19-9655, 19-9825, 20-
5598,21-775, 19-291-208, 20-7869-3
Corrective Action
Documents
Resulting from
Inspection
2-6891, 22-6894, 22-6895, 22-6945, 22-6948, 22-6951,
2-6952, 22-6964, 22-6965, 22-6966, 22-6967, 22-6968,
2-6970, 22-6972, 22-6990,22-7027, 22-7053, 22-7185, 22-
236, 22-7366, 22-7367, 22-7368, 22-7404, 22-7408
00000E0AAAA
Single Line Diagram Main One Line Diagram Unit No. 1 & 2
00009E0CC25#2,
Sheet 01
Elementary Diagram Reactor, Containment Fan Coolers
21A & 21C, CCW [Component Cooling Water] Inlet MOV's
0064 & 0204
00009E0CC33#2,
Sheet 01
Elementary Diagram, Reactor Containment Fan Coolers,
MOV's 0067 and 0207
Drawings
00009E0CS01#1,
Elementary Diagram, Containment Spray Pumps PA101B &
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Sheet 02
PA101C
00009E0HF06#2,
Sheet 01
Elementary Diagram, F.H.B. [Fuel Handling Building] HVAC
[Heating, Ventilation, and Air Conditioning], Exhaust Booster
Fans FN007, 008, & 009
00009E0PK01#1,
Sheet 01
Elementary Diagram, 4.16KV ESF [Engineered Safety
Feature] Bus E1A, E1B & E1C Supply Breaker Control
00009E0PK04#1
Elementary Diagram ESF Transformer & 4.16KV Bus E1A,
E1B, & E1C Protection and Metering
00009E0PKAB#1
Single Line Diagram 4.16 KV Class 1E Switchgear E1B
00009E0PMAH#2,
Sheet 01
Single Line Diagram 480V Class 1E Motor E2C2 Control
Center (EAB)
00009E0VAAA #1
Single Line Diagram Vital 120v AC Distribution Panels
DP001, DP1201 Channel I (EAB)
4040-01075HY
Essential Cooling Water Pump General Arrangement
D
4168-00066VA
NBD-53 Backdraft Damper
F
5E030E00100,
Sheet 3A
Electrical General Notes And Details General Notes
5R289F05038
Sheet 1
Essential Cooling Water System Train A
5V159V00027
Sheet 1
Heating Ventilation Air Conditioning Miscellaneous Buildings
Essential Cooling Water Intake Structure & Electrical
Equipment Room
6D019M00020
General Arrangement Diesel Generator Building Plans &
Sections
Essential Cooling Water Intake & Discharge Structures
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
2-31926-359
Replacement of Unit 1 Class IE Switchgear E1C Circuit
Breakers During 1R23 Outage
2-31926-43,
Supplement 0
Class IE 4. 16 KV Circuit Breaker Replacements
04/01/2015
2-31926-43,
Supplement 1
Class 1E 4.16 KV Circuit Breaker Replacements
07/28/2016
Engineering
Changes
2-31926-43,
Class 1E 4.16 KV Circuit Breaker Replacements
03/22/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Supplement 3
17-14971-1
Installation of Cathodic Protection System Deep Anode
Groundbed For Auxiliary Feedwater Area
17-22335
Replace 27C Relay (ITE J13) Associated in Control Circuit
for Containment Spray Pump 1B
CN-3125
DCPs 12-31926-2 and 12-31926-3 are allowing either the
existing air magnetic
circuit breakers or replacement vacuum circuit breakers to
be used.
2/26/2015
001-002-496, 24
VSN Centrifugal Pump Installation and Operation Manual
Design Criteria Class 1E AC Power Distribution
3E159ES0065
Specification for 5KV Class-1E Medium Voltage Breaker
Replacement
3V139VQ1002
Diesel Generator Building Emergency Ventilation System
Design Criteria
4E510EQ1005
Design Criteria Class 1E AC Power Distribution System
4E519EB1108
Class 1E 4.16 kV AC Power (PK) System
4E549EB01110
Design Basis Document Class 1E Vital 120Vac System
5Q159MB1023
Design Basis Document Standby Diesel Generator System
5R289MB01006
Design Basis Document Essential Cooling Water System
5V139VQ103
Diesel Generator Building Heating and Normal Ventilation
System Design Criteria
B05757-00008T4
34149238
Third Party Qualification (TPQ) Dedication Plan For
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
POND Project
Number: 1210768
Investigation of Low Potential Measurements at Concrete
Water Tank
2/2021
PRO055669PKG-
Commercial Grade Dedication Package - Siemens 5HKR-
250-1200-58 Circuit Breaker, 4.67 kV, Horizontal Draw-out,
with Type 3EF1-048-0A Surge Limiters
2/24/2017
Miscellaneous
VTD-B455-0042
Vendor Technical Document, Installation/Maintenance
Instructions (Medium Voltage Power Circuit Breakers Type
5HK 1200 Thru 3000 Amperes 5000 Volts
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
VTD-B455-0094
Vendor Technical Document - Liquid Insulated Primary and
Secondary Unit Substation Transformers
VTD-B455-0108
Vendor Technical Document - ABB OnLoad Tap
Chargers, Type UZE and UZF With Motor Drive
Mechanism, Type BU3
VTD-C634-0001
STPNOC Site Specific Engineered Safety Features Diesel
Generator Engine Manual
VTD-C963-0009
Vendor Technical Document - Operating Manual for
SRAYS, SRAYT Series Rectifiers
03/24/2016
VTD-G080-0328
Vendor Technical Document for General Electric Series 300
Magnetic Contactors
VTD-H108-0017
Vendor Technical Document - Receiving, Handling, Storage,
And Maintenance Instructions For Class 1E AC And DC
Distribution Panels
VTD-P292-0001
Instruction Manual Operation, Maintenance and Parts List
for A.C. Synchronous Generator
VTD-S125-0023
Vendor Technical Document - Siemens Medium Voltage
Replacement Breakers
03/26/2015
VTD-S125-0024
Vendor Technical Document, Siemens 5HKR-250-1200
TOC [Truck-Operated Contact] Bracket Installation
VTD-S345-0020
Vendor Technical Document - Installation And Maintenance
Instructions QMB Fusible Switches
VTD-W120-0216
Vendor Technical Document - Cutler-
Hammer/Westinghouse AB De-Ion Circuit Breakers
VTD-W120-0220
Vendor Technical Document - K-FRAME MOLDED CASE
CIRCUIT BREAKERS TYPE DK: 250-400 AMPERES
TYPES KDB, KD, HKD, KWC: 100-400 AMPERES TYPES
Plant Yard Cathodic Protection Potential Survey
Preventative Maintenance Program
0002A
CAQ [Condition Adverse to Quality] Resolution Process
4160V Gould Breaker Tests
Molded Case Breaker Test
Procedures
Siemens HKR Vacuum Breaker Maintenance and Tests
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Class 1E Vital 120V Distribution Panel Tests
Loss Of 120 VAC Class Vital Distribution
Molded Case Breaker Functional Test and Inspection
4.16KV Class 1E Degraded Voltage Relay Channel
Calibration/TADOT [Trip Actuation Device Operational Test]
- Channel 4
MG-0006
Work Execution and Closeout Guideline
OPSP03-DG-0001
Standby Diesel 11(21) Operability Test
OPSP03-EW-
0017
Essential Cooling Water System Train A Testing
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