IR 05000498/2024010
| ML24221A269 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/08/2024 |
| From: | Ami Agrawal NRC/RGN-IV/DORS/PBA |
| To: | Harshaw K South Texas |
| Azua R | |
| References | |
| IR 2024010 | |
| Download: ML24221A269 (12) | |
Text
August 08, 2024
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2024010 AND 05000499/2024010
Dear Kimberly A. Harshaw:
On June 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project Electric Generating Station, Units 1 and 2 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.
The NRC inspection team reviewed the stations problem identification and resolution program to confirm that the station was complying with NRC regulations and licensee standards. Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
The team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs.
Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Finally, the team performed an additional effort to evaluate the safety-conscious work environment for the security department. The team has found that the work environment in the Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this transmittal document and Enclosure 1 are decontrolled security department is experiencing a sustained improvement. However, the recent significant shift to in-house operations is very recent and is expected to continue affecting their work environment. Whether these effects will be positive or negative remains uncertain.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. One Severity Level IV violation is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. The specifics of the Severity Level IV violation are discussed in Enclosure 2.
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, Ami N. Agrawal, Team Lead Inspection Programs & Assessment Team Division of Operating Reactor Safety Docket Nos. 05000498; 05000499 License Nos. NPF-76; NPF-80
Enclosure:
As stated
Inspection Report
Docket Nos.
05000498; 05000499
License Nos.
Report Nos.
05000498/2024010; 05000499/2024010
Enterprise Identifier:
I-2024-010-0009
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, TX
Inspection Dates:
June 02, 2024 to June 28, 2024
Inspectors:
R. Azua, Senior Reactor Inspector
R. Bywater, Senior Project Engineer
S. Mendez-Gonzalez, Allegations Specialist
W. Tejada, Security Specialist
J. Vera, Senior Resident Inspector
S. Thapa, Reactor Inspector in Training
Approved By:
Ami N. Agrawal, Team Lead
Inspection Programs & Assessment Team
Division of Operating Reactor Safety
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this
transmittal document and Enclosure 1 are decontrolled 2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at South Texas Project Electric Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Ensure Revised Procedures Were Issued When Implementing Engineering Change on Essential Chillers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498,05000499/2024010-01 Open/Closed
[H.12] - Avoid Complacency 71152B The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion VI, Document Control, for the licensees failure to control the issuance of procedures which prescribe activities affecting quality. Specifically, from November 11, 2023, to January 31, 2024, the licensee did not control the issuance of the procedure for Essential Chiller operation. As a result, the procedures addressing operation of new components in the safety-related Essential Chillers were not distributed and used where activities were to be performed.
Failure to Enter Applicable Technical Specifications When Conditions Rendered Essential Chiller Inoperable Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000498,05000499/2024010-02 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green, non-cited violation of renewed license NPF-80 condition 2.C.(2), which requires, in part, that the South Texas Project (STP) shall operate the facility in accordance with the Technical Specifications. Specifically, on August 27, 2022, the licensee failed to recognize a condition which made Essential Chiller 22B inoperable, and, by following an inadequate applicable procedure in effect, failed to enter Technical Specification 3.7.14 for one inoperable essential chilled water system train.
Failure to Make a Timely 1-Hour Report to the Headquarters Operation Center Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Security Severity Level IV NCV 05000498,05000499/2024010-03 Open/Closed None 71152B The inspectors identified a Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 73, Appendix G,(I)(c), Reportable Safeguards Events, for the licensees failure to report to the NRC Operations Center within one hour of discovery of any 3 failure, degradation, or the discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to a protected area (PA), material access area (MAA), controlled access area (CAA), vital area (VA), or transport for which compensatory measures have not been employed. This non-cited violation is described in of this report.
Additional Tracking Items
None. 4
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Essential Chilled Water System and the associated Essential Chillers.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee, in general, correctly characterized 5 condition reports as to whether they represented conditions adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. The licensee generally developed effective corrective actions for the problems evaluated in the corrective action program. They generally implemented these corrective actions in a timely manner, commensurate with their safety significance. Finally, it was determined that the licensee reviewed the effectiveness of these corrective actions appropriately.
- As part of this inspection, the team selected the Essential Chilled Water System and the associated Essential Chillers for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system.
- The material condition of this system appeared to be adequate. However, inspectors noted several examples of repeat minor issues revealed in multiple condition reports.
For example, oil levels dropping below normal ranges, outlet temperature being over the limit, and eductor lines being frozen over, were all issues that had multiple condition reports describing the same issue at different points in time. Several condition reports outlined equipment issues that resulted in chiller inoperability, which is consistent with the stations recent history of essential chiller equipment issues and current maintenance rule monitoring approach under 10 CFR 50.65 (a)(1). The inspectors identified a few issues related to design control and appropriate rollout of design changes in the field. These issues were not widespread or repetitive.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards. The licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience, Self-Assessment and Audit Assessment Operating Experience: The team reviewed a variety of sources of operating experience including 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including INPO and EPRI. The team determined that STPs staff is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team 6 concluded that the licensee had an effective departmental self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment (SCWE) Assessment Safety-Conscious Work Environment: The team interviewed approximately 40 individuals in group sessions of varying sizes. The interviews were conducted in person. The purpose of these interviews was to evaluate the willingness of the licensee's staff to raise nuclear safety issues, either by initiating a condition report or by another method, to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and to evaluate STPs safety-conscious work environment (SCWE). The focus group participants included personnel from Radiation Protection, Electrical/Mechanical Maintenance, and Instrumentation and Controls. Overall, STP was found to have an adequate SCWE.
The team performed an additional effort to evaluate SCWE for the security department.
During this assessment, the team conducted focus groups and interviews and reviewed corrective actions associated with the SCWE in the security department. Approximately 30 officers were interviewed in this process. In the area of environment for raising concerns, the majority of the officers interviewed stated that they would raise nuclear safety and security concerns though multiple avenues. Compared to last year, fewer personnel concerns were raised this year, but there were still issues regarding promptly addressing issues (personnel safety matters) and a perception that these issues might not be resolved in a timely manner.
Many of the examples cited this year were identical to those raised last year, such as issues with bullet resistant enclosure doors, handrails, and door handles.
In the area of effective safety communication, the majority of security officers stated that there were issues with communication regarding the transition to in-House, particularly concerning what the process would entail afterwards. The comments were about the procedures that would be implemented and how activities such as vacation and sick leave would be managed. However, there were no concerns expressed about the day-to-day operations.
Another example of communication issues during the in-House transition, was with regard to feedback that was sought from the officers regarding uniforms. The officers felt frustrated because some were not afforded an opportunity to provide their input due to time limitations that did not allow all shifts to participate. This frustration was exacerbated when the final decision was not included amongst the options presented. The officers perceived that the feedback solicitation was a token gesture to make them feel included, despite the decision already having been made beforehand.
Other communication issues raised regarding the in-House transition was in the area of Leadership Safety Values and Actions. Specifically, the officers were confused regarding the management chain and stated that they were unaware of who were the security management staff between the security shift supervisor (SSS) and the security manager.
In the area of respectful work environment, the majority of officers interviewed stated that they felt that they were being treated with respect and they felt supported and trusted by management.
The team concluded that the work environment amongst the security staff is experiencing a sustained improvement. However, the recent significant shift to in-House operations is very recent and is expected to continue affecting their work environment. Whether these effects 7 will be positive or negative remains uncertain.
Willingness to Raise Nuclear Safety Issues: In all the interviews, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
Overall, the team concluded that all work groups at the South Texas Project maintained a healthy safety-conscious work environment.
Employee Concerns Program: The team looked at the South Texas Project's Employee Concerns Program (ECP). The team interviewed the ECP coordinator and reviewed several investigations. Overall, the team determined that the investigation packages were of excellent quality clearly demonstrating steps taken and basis for conclusions. In addition, the ECP investigators demonstrated detailed knowledge of all the cases that were reviewed. The team noted that through the discussions that the Team had with the plant staff, most, if not all, felt comfortable raising concerns through their own supervision and did not feel the need to use the Employee Concerns Program.
Failure to Ensure Revised Procedures Were Issued When Implementing Engineering Change on Essential Chillers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498,05000499/2024010-01 Open/Closed
[H.12] - Avoid Complacency 71152B The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion VI, Document Control, for the licensees failure to control the issuance of procedures which prescribe activities affecting quality. Specifically, from November 11, 2023, to January 31, 2024, the licensee did not control the issuance of the procedure for Essential Chiller operation. As a result, the procedures addressing operation of new components in the safety-related Essential Chillers were not distributed and used where activities were to be performed.
Description:
On December 21, 2023, STP Unit 2 licensee operators performing a pre-task walkdown in preparation of train swap activities for the next day, noticed that Essential Chiller 22C controls labelled MAX LOAD ADJUSTMENT IN % and TEMPERATURE CONTROL POINT, which were known to be control knobs, had been replaced with potentiometers.
Operators noted that STEP 8.11 of procedure 0POP02-CH-0005, Essential Chiller Operation, Rev. 78, directed operators to ensure that the "MAX LOAD ADJUSTMENT IN %"
control knob be placed in the 100 percent position for the chiller unit being started. The operators found that the multi-turn potentiometer did not correlate to the required 100 percent scale described in the procedure. This was documented in condition report (CR) 23-11370, with a recommendation to restore knob to original equipment or update the 0POP02-CH-0005 to direct setting for new potentiometer. This CR was closed to action 12 of previous CR 21-8518.
During interviews with licensee personnel, inspectors determined that the engineering change (EC) 21-8518-8, which was initiated in 2021, indicated that the changes to the knobs had been approved but not implemented due to supply chain issues. The EC did consider the impact on procedure 0POP02-CH-0005, and CR action 21-8518-12 was created to track 8 procedure revision. However, the licensee failed to implement the procedure revision upon installing an updated temperature current module (TCM) in Essential Chiller 12B. On November 10, 2023, Essential Chiller 12B needed outlet temperature adjustments in accordance with 0POP02-CH-0005, and subsequently was declared inoperable after failing to maintain outlet temperature below 52 °F. During initial troubleshooting, none of the components in the temperature control loop were found to be failed or erratic. However, due to Essential Chiller 12C also being declared inoperable several hours after Essential Chiller B was declared inoperable, the licensee decided to replace two components with a known history of degradation: a motor operated valve for the hot gas bypass motor, and the TCM.
The TCM that was used to replace the existing one in Essential Chiller 12B was one that had been modified to use upgraded 10-turn potentiometers and lockable turn counting dials per EC 21-8518-8. The licensee installed the upgraded TCM per WAN 698374. This was done because no unmodified TCMs were available at the time. While it was recognized that the TCM to be installed had been modified per EC 21-8518-8, no actions were taken to inform the other operator crews, accelerate issuance of the revised 0POP02-CH-0005 procedure or implement any action to aid operators in performing actions requiring use of the potentiometers. This was the first documented instance of the EC being implemented that the inspectors found. This means that from November 11, 2023, when a modified TCM was installed on Essential Chiller 12B, to January 31, 2024, when the revised procedure 0POP02-CH-0005 became effective, the licensee had inadequate procedures in effect for essential chiller operation.
Corrective Actions: The licensee addressed the issues raised in CR 23-11370 by implementing the planned actions of CR 21-8518. The revised procedure was effective January 31, 2024.
Corrective Action References: Corrective Action References: The licensee entered these issues into the corrective action program with condition report 24-6506.
Performance Assessment:
Performance Deficiency: The licensees failure to control the issuance of procedures which prescribe activities affecting quality was a performance deficiency. Specifically, on November 11, 2023, the licensee failed to ensure that a revised version of Procedure 0POP02-CH-0005 was issued after an early implementation of Engineering Change EC 21-8518-8. As a result, until January 31, 2024, the licensee had inadequate procedures in effect for essential chilled water trains.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, from November 11, 2023, when a modified TCM was installed on Essential Chiller 12B, to January 31, 2024, when the revised procedure 0POP02-CH-0005 became effective, the licensee had inadequate procedures in effect for essential chiller operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be very low safety significance (Green)because it:
- (1) was not a design deficiency,
- (2) did not represent a loss of system and/or function,
- (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time,
- (4) did not represent a loss of the probabilistic assessment (PRA) function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
- (5) did not represent a loss of a PRA system and/or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
- (6) did not result in the loss of a high safety-significant, nontechnical specification train.
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, when deciding to implement EC 21-8518-8 to install modified TCMs early due to part unavailability, the licensee failed to recognize the potential impact on operators. Because of this, no actions were taken to accelerate issuance of the revised 0POP02-CH-0005 procedure after the EC was implemented in the field.
Enforcement:
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion VI, Document Control, requires, in part, that measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality, and that these measures shall assure that documents, including changes, are distributed to and used at the location where the prescribed activity is performed.
Contrary to the above, from November 11, 2023, to January 31, 2024, the licensee did not control the issuance of the procedure for Essential Chiller operation. As a result, the procedures addressing operation of new components in the safety-related Essential Chillers were not distributed and used where activities were to be performed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Enter Applicable Technical Specifications When Conditions Rendered Essential Chiller Inoperable Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems NCV 05000498,05000499/2024010-02 Open/Closed
[P.1] -
Identification 71152B The inspectors identified a Green, non-cited violation of renewed license NPF-80 condition 2.C.(2), which requires, in part, that STP shall operate the facility in accordance with the Technical Specifications. Specifically, on August 27, 2022, the licensee failed to recognize a condition which made Essential Chiller 22B inoperable, and, by following an inadequate applicable procedure in effect, failed to enter Technical Specification 3.7.14 for one inoperable essential chilled water system train.
Description:
On August 27, 2022, the STP Unit 2 control room received 2 alarms indicating issues with essential chilled water temperature. An operator was dispatched and found Essential Chiller 22B outlet temperature out of band high at 61 °F. Per licensee procedure 0POP02-CH-0005, Essential Chiller Operation, essential chillers are considered inoperable when the outlet temperature is above 52 °F, however, the procedure includes two exceptions to this. One is a 30-minute allowance for temperature transients when chillers are started.
The other allowance is a 15-minute allowance for other temperature transients. Essential Chiller 22B had been in service for days, however, the operator noticed that temperature decreased to under 52 °F in 12 minutes. Based on this, Essential Chiller 22B was determined to remain operable.
To determine the cause of the outlet temperature increase, the licensee performed maintenance on Essential Chiller 22B under WAN 675069. The licensee found multiple broken strands of wires connected to the temperature control point potentiometer, and resistance readings on hot gas bypass and pre-rotational vanes were sporadic. The licensee performed repairs on the chiller, completing satisfactory post-maintenance monitoring on September 2, 2022.
The inspectors reviewed control room log records, applicable work orders, applicable procedures and the timeline of the events. The inspectors noted that, while Essential Chiller 22B had increased temperature after a supplemental purge of containment to the level of causing an alarm, no such alarm was received for Essential Chiller 22A also in operation at the time, even though any change in heat load conditions would be expected to affect both trains in similar fashion. The licensees subsequent maintenance after the alarm revealed degradation in Essential Chiller 22B. The inspectors concluded that the temperature increase that caused the control room alarm was not due to a normal outlet temperature transient which would fall under the exception in Procedure 0POP02-CH-0005, but due to equipment issues with the chiller itself. Therefore, the chiller should have been declared inoperable and Technical Specification 3.7.14 entered for an inoperable Essential Chilled Water System train.
Corrective Actions: The licensee entered these issues into the corrective action program.
Corrective Action References: CR 24-6379 11
Performance Assessment:
Performance Deficiency: The licensees failure to provide a procedure that allowed accurate operability determinations was a performance deficiency. Specifically, Procedure 0POP02-CH-0005 contained an inadequate operability determination table that allowed chillers to be declared operable when recovering from outlet temperature transients within 15 minutes, without specifying that such recoveries must be due to temperature transients, and not include equipment failures. As a result, on August 27, 2022, the licensee failed to enter TS 3.7.14 when the chiller should have been declared inoperable.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on August 27, 2022, the licensee failed to recognize a condition which made Essential Chiller 22B inoperable, and, by following an inadequate applicable procedure in effect, failed to enter Technical Specification 3.7.14 for one inoperable essential chilled water system train.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be very low safety significance (Green)because it:
- (1) was not a design deficiency,
- (2) did not represent a loss of system and/or function,
- (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time,
- (4) did not represent a loss of the probabilistic assessment (PRA) function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,
- (5) did not represent a loss of a PRA system and/or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and
- (6) did not result in the loss of a high safety-significant, nontechnical specification train.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee failed to identify the latent possibility of a chiller inoperability being masked by an operability determination made in accordance with inadequate guidance. As a result, procedure 0POP02-CH-0005 did not address circumstances in which the chiller should be declared inoperable.
Enforcement:
Violation: Renewed Facility Operating License NPF-80 condition 2.C.(2) requires, in part, that STP shall operate the facility in accordance with the Technical Specifications.
Contrary to the above, on August 27, 2022, the licensee failed to recognize a condition which made Essential Chiller 22B inoperable by following an inadequate applicable procedure in effect. As a result, Essential Chiller was not declared inoperable and the licensee failed to 12 enter Technical Specification 3.7.14 for one inoperable essential chilled water system train between August 27, 2022 and September 2, 2022.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Make a Timely One-Hour Report to the Headquarters Operation Center Cornerstone Significance/Severity Cross-Cutting Aspect Report Section Security Severity Level IV NCV 05000498,05000499/2024010-03 Open/Closed None 71152B The inspectors identified a Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 73, Appendix G,(I)(c), Reportable Safeguards Events, for the licensees failure to report to the NRC Operations Center within one hour of discovery of any failure, degradation, or the discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to a protected area (PA), material access area (MAA),controlled access area (CAA), vital area (VA), or transport for which compensatory measures have not been employed. This non-cited violation is described in Enclosure 2 of this report.
Description:
This non-cited violation is described in Enclosure 2 of this report.
Corrective Actions: The licensee entered this issue into the site corrective action program for evaluation and development of corrective actions.
Corrective Action References: CR-24-6421
Performance Assessment:
Performance Deficiency: The failure to make a timely one-hour report to the NRC Operations Center is a performance deficiency. It is a performance deficiency because the licensee failed to meet a requirement that was within its ability to foresee and correct and should have been prevented. This non-cited violation is described in Enclosure 2 of this report.
Severity: The event does not rise to a SL III violation, as noted in the Enforcement Policy Section 6.9 (c)(2)(b), because the licensee made report to NRC Headquarters Operations Center approximately five hours and 7 minutes later, followed by the 60-day on September 27, 2023, in accordance with 10 CFR 73.71(a)(4). Therefore, the NRC determined that this violation screens as a Severity Level IV in accordance with Section 6.9 (d)(1) of the NRC Enforcement Policy, dated January 12, 2024, since the failure to comply with reporting requirements can negatively impact the ability of the NRC to perform its regulatory oversight function.
Significance: The ROPs significance determination process does not specifically consider the regulatory process impact for a 10 CFR Part 73, Appendix G (I)(c) in its assessment of licensee performance. Therefore, it is necessary to address this violation using traditional enforcement in accordance with IMC 0609, Appendix B, Block TE2, 1.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is 13 necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Violation: Title10of the Code of Federal Regulations, Part 73, Appendix G,(I)(c), Reportable Safeguards Events, for the licensee failure to report to the NRC Operations Center within one hour of discovery any failure, degradation, or the discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to a PA, MAA, CAA, VA, or transport for which compensatory measures have not been employed.
Contrary to the above, the licensee failed to report to the NRC Operations Center within one hour of discovery as required by 10 CFR, Part 73, Appendix G,(I)(c), any failure, degradation, or the discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to a PA, MAA, CAA, VA, or transport for which compensatory measures have not been employed. The details of this non-cited violation is described in Enclosure 2 of this report.
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 June 27, 2024, the inspectors presented the Exit Meeting inspection results to Aldo Capristo, Executive Vice President and Chief Administrative Officer and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
STPNOC-CR-
11-1612, 20-6368, 20-7289, 21-3850, 21-8118, 21-9693,
21-10157, 21-10382, 21-10677, 22-2063, 22-2063, 22-4161,
2-5386, 22-5772, 22-5888, 22-6010, 22-6071, 22-6089,
2-6095, 22-6197, 22-6220, 22-6248, 22-6335, 22-6375,
2-6473, 22-6498, 22-6530, 22-6617, 22-6650, 22-6670,
2-6794, 22-6826, 22-6829, 22-6838, 22-6849, 22-6950,
2-7275, 22-7377, 22-7401, 22-7410, 22-7445, 22-7452,
2-7530, 22-7576, 22-7825, 22-7956, 22-8157, 22-8250,
2-8336, 22-8344, 22-8452, 22-8571, 22-8694, 22-8818,
2-8851, 22-9476, 22-9617, 22-9760, 22-9800, 22-9871,
2-10150, 22-10199, 22-10301, 22-10348, 22-10705,
2-11057, 22-11120, 22-11122, 22-11138, 22-11437,
2-11438, 22-11800, 22-11897, 22-11933, 22-12288,
2-12407, 22-12641, 22-12648, 22-12935, 22-13044,
2-13056, 22-13085, 23-0029, 23-0206, 23-0294, 23-0298,
23-0301, 23-0406, 23-0451, 23-0596, 23-0611, 23-0860,
23-0864, 23-0873, 23-1009, 23-1083, 23-1130, 23-1228,
23-1271, 23-1499, 23-1500, 23-1571, 23-1747, 23-1900,
23-1978, 23-2079, 23-1985, 23-2046, 23-2121, 23-2212,
23-2304, 23-2340, 23-2382, 23-2416, 23-2426, 23-2434,
23-2557, 23-2762, 23-2765, 23-2863, 23-2924, 23-2954,
23-3034, 23-3345, 23-3499, 23-3997, 23-4792, 23-4948,
23-5007, 23-5008, 23-5172, 23-5652, 23-5992, 23-6338,
23-6359, 23-6448, 23-6766, 23-6814, 23-6823, 23-6834,
23-6836, 23-6928, 23-6947, 23-6972, 23-6988, 23-6989,
23-7001, 23-7311, 23-7469, 23-7581, 23-7736, 23-7845,
23-7918, 23-8000, 23-8073, 23-8241, 23-8249, 23-8298,
23-8625, 23-8664, 23-8691, 23-8694, 23-8707, 23-8725,
23-8828, 23-8929, 23-9097, 23-9170, 23-9224, 23-9322,
23-9446, 23-9447, 23-9459, 23-9491, 23-9502, 23-9543,
23-9667, 23-9674, 23-9689, 23-9701, 23-9775, 23-9781, 15
23-9850, 23-9975, 23-9987, 23-9994, 23-10139, 23-10194,
23-10252, 23-10345, 23-10345, 23-10350, 23-10352,
23-10368, 23-10379, 23-10423, 23-10460, 23-10490,
23-10508, 23-10538, 23-10552, 23-10571, 23-10573,
23-10577, 23-10766, 23-10770, 23-10842, 23-10873,
23-10947, 23-10965, 23-11001, 23-11186, 23-11252,
23-11234, 23-11254, 23-11256, 23-11370, 2311418,
23-11419, 24-0102, 24-0122, 24-0123, 24-0233, 24-0303,
24-0333, 24-0359, 24-0396, 24-0403, 24-0442, 24-0605,
24-0683, 24-0766, 24-0927, 24-1106, 24-1162, 24-1241,
24-1252, 24-1337, 24-1352, 24-1353, 24-1356, 24-1357,
24-1539, 24-1552, 24-1581, 24-1696, 24-1729, 24-1759,
24-1779, 24-1798, 24-1811, 24-1851, 24-1932, 24-1942,
24-1984, 24-2002, 24-2037, 24-2127. 24-2138, 24-2328,
24-2383, 24-2403, 24-2511, 24-2514, 24-2546, 24-2551,
24-2810, 24-2856, 24-2888, 24-3176, 24-3548, 24-3690,
24-3692, 24-3693, 24-3696, 24-3722, 24-3800, 24-3936,
24-3996, 24-4028, 24-4478, 24-4561, 24-6029, 24-8452
Corrective Action
Documents
Resulting from
Inspection
STPNOC-CR-
24-3690, 24-6009, 24-6022, 24-6029, 24-6095, 24-6099,
24-6275, 24-6332, 24-6338, 24-6343, 24-6361, 24-6378,
24-6379, 24-6380, 24-6417, 24-6421
Miscellaneous
Operations Quality Assurance Plan
Miscellaneous
Controlled System or Barrier Impairment
Miscellaneous
MN-23-0-109196
Annual Evaluation Report Admin Controls (AC)
23
Miscellaneous
MN-24-0-109455
Annual Evaluation Report Fire Protection (FP)
24
Miscellaneous
NIS197
Condition Reporting Program Training
2/2017
Miscellaneous
STP-0430
Conduct of Company Investigations
01/22/2019
Miscellaneous
STP-0723
Employee Concerns Program
01/22/2019
Miscellaneous
STP-411
Administrative Policy Manual
09/16/2013
Miscellaneous
STP-717
Reporting, Investigation, and Disposition of Ethical or Legal
Concerns Under the Corporate Compliance Program
01/20/2014
Miscellaneous
STP370
Concern Report Form
05/2010
Procedures
Human Performance (HU) Program
16
0001
Procedures
Integrated Performance Improvement Program
Procedures
Integrated Performance Improvement Program
Procedures
Work Process Program
Procedures
Employee Concerns Program
Procedures
Employee Concerns Program
Procedures
0048
Operability determination for Components Removed from the
IST Program
Procedures
0054
Operational Decision Making
Procedures
9900
Operability Determinations and Functionality Assessments
Program
Procedures
Condition Reporting Process Procedure
Procedures
0002A
CAQ Resolution Process
Procedures
0002B
Root Cause Investigations
Procedures
Station Self-Assessment Program
Procedures
Condition Not Adverse to (CNAQ) Resolution Process
Procedures
Operating Experience Program
Procedures
0013A
Processing Industry Operating Experience
Procedures
Trending Process Procedure
Procedures
Condition Report Engineering Evaluation
Procedures
0PGPG03-ZX-
0002A
Condition Reporting Process Implementation
Procedures
Condition Report Operations Evaluation Program
Procedures
0011
Operability, Functionality, and Reportability Guidance
Procedures
CAP-0002
Causal Analysis Guideline
Procedures
CAP-0003
Condition Report Screening
Procedures
OQAP04
Qualification Training and Certification of Personnel
Procedures
SLG-CPI1
Management Performance Improvement Committee
Activities
Procedures
WCG-0001
Work Screening and Processing
17
Procedures
WCG-0002
Work Management Scheduling
49