IR 05000498/2025002
| ML25218A226 | |
| Person / Time | |
|---|---|
| Site: | South Texas, 07201041  |
| Issue date: | 08/12/2025 |
| From: | Patricia Vossmar NRC/RGN-IV/DORS/PBA |
| To: | Kharrl C South Texas |
| References | |
| EAF-RIV-2025-0134 IR 2025002, IR 2024001 | |
| Download: ML25218A226 (27) | |
Text
August 12, 2025
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2025002 AND 05000499/2025002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION 07201041/2024001 AND EXERCISE OF ENFORCEMENT DISCRETION
Dear Charles Kharrl:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On July 10, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
The NRC identified a violation of 10 CFR 72.48 and 72.212 associated with South Texas Project use of the Holtec HI-STORM FW spent fuel storage cask. Enforcement discretion is being granted as authorized by Enforcement Guidance Memorandum (EGM) 25-001, Enforcement Guidance for Dispositioning Noncompliances Related to a General Licensees Use of Certain Non-Qualified Spent Fuel Casks, (see Agencywide Documents Access and Management System [ADAMS] Accession No. ML24303A436). The NRC will take additional enforcement action if compliance is not restored following the expiration date of this EGM. However, in your case compliance has been restored and no additional enforcement action is warranted.
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 violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at South Texas Project Electric Generating Station, Units 1 and 2. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at South Texas Project Electric Generating Station, Units 1 and 2.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Patricia J. Vossmar, Chief Reactor Projects Branch A Division of Operating Reactor Safety Docket Nos. 05000498; 05000499; 07201041 License Nos. NPF-76 and NPF-80
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000498; 05000499; 07201041
License Numbers:
Report Numbers:
05000498/2025002; 05000499/2025002 and 07201041/2024001
Enterprise Identifier:
I-2025-002-0012 and 1-2024-001-0119
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, TX 77483
Inspection Dates:
April 1, 2025, to June 30, 2025
Inspectors:
L. Brookhart, Senior Spent Fuel Storage Inspector
R. Bywater, Senior Project Engineer
P. Elkmann, Sr Emergency Preparedness Inspector
L. Flores, Resident Inspector
J. Freeman, Spent Fuel Storage Inspector
V. Lee, Project Engineer
S. Lichvar, Technical Assistant
L. Moore, Emergency Preparedness Inspector
B. Nwafor, Reactor Inspector
J. Vera, Senior Resident Inspector
Approved By:
Patricia J. Vossmar, Chief
Reactor Projects Branch A
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at South Texas Project Electric Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Promptly Identify and Correct a Condition Adverse to Quality on Emergency Core Cooling System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498/2025002-01 Open/Closed
[P.2] -
Evaluation 71153 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the licensees failure to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to correct a previously identified leak coming from a Unit 1 train B safety injection sampler tee connection. Subsequently, while the emergency core cooling system train C was out of service for maintenance, the train B leak was found to exceed an administrative limit when operating the safety injection pump.
This led operators to place the safety injection pump in pull-to-lock, causing the emergency core cooling system train B to be inoperable while train C was also inoperable.
Additional Tracking Items
Type Issue Number Title Report Section Status EDG EAF-RIV-2025-0134 Noncompliance Related to a General Licensees Use of Non-Qualified Spent Fuel Casks (EGM 25-001)60855 Closed LER 05000498/2025-001-00 Unit 1, Two Inoperable Emergency Core Cooling System Trains Resulting in Potential Loss of Safety Function 71153 Closed LER 05000499/2024-002-01 Unit 2, Two Control Room Envelope HVAC Trains Inoperable Resulting in a Condition That Could Have Prevented Fulfillment of a Safety Function 71153 Closed
PLANT STATUS
Both units began the inspection period at rated thermal power and operated at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train C essential cooling water system on April 8, 2025
- (2) Unit 2, train A, essential cooling water system on May 9, 2025
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, alternate shutdown panel room on April 7, 2025
- (2) Unit 2, alternate shutdown panel room on April 7, 2025
- (3) Unit 1, train A auxiliary feedwater pump room on April 15, 2025
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on April 3, 2025.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 1 control rod operability surveillance test on April 26, 2025, and during Unit 2 control rod testing on May 3, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator requalification training involving a reactor startup and steam generator tube rupture scenario on April 2, 2025.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2, yellow risk due to train B essential cooling water, component cooling water, essential chilled water, and emergency diesel generator planned outage on May 19, 2025
- (2) Unit 2, white risk and planned configuration risk management program entry for battery breaker on May 30, 2025
- (3) Unit 2, yellow risk for train B control room HVAC planned maintenance on June 13, 2025
- (4) Unit 1, white risk for train D auxiliary feedwater pump planned maintenance on June 27, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2, non-class 1E battery room temperature high on May 23, 2025
- (2) Unit 2, erosion found in aluminum bronze piping near train B component cooling water heat exchanger on June 20, 2025
- (3) Unit 1, train A emergency diesel generator overspeed switch not actuating on June 30, 2025
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
- (1) Unit 2, train D steam generator power-operated relief valve test following replacement of servo amplifier pigtails on April 23, 2025
- (2) Unit 2, train B of essential cooling water after planned maintenance outage on May 9, 2025
- (3) Unit 1, train A of essential cooling water after planned maintenance on June 6, 2025
- (4) Unit 2, train B emergency diesel generator after essential cooling water piping replacement on June 13, 2025
- (5) Unit 1, train D of auxiliary feedwater pump after planned maintenance on June 23, 2025
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) Unit 2, train D auxiliary feedwater quarterly inservice test on April 24, 2025
- (2) Unit 1, control rod operability test on April 26, 2025
- (3) Unit 2, train A diesel generator surveillance test on April 29, 2025
Inservice Testing (IST) (IP Section 03.01) (2 Samples)
- (1) Unit 2, train A containment spray system code pressure test on April 28, 2025
- (2) Unit 2, train A component cooling water system code pressure test on April 29, 2025
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
The inspectors reviewed licensee procedures for maintaining and testing their offsite emergency alert and notification system.
- (1) The inspectors evaluated the testing of the IPAWS in the emergency planning zone and reviewed the 2023 and 2024 joint licensee-offsite response organization IPAWS audits.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
The inspectors reviewed emergency response organization rosters from the Third Quarter 2023 through the First Quarter 2025 to determine whether the licensee had sufficient responders to fill all required emergency response organization positions. The inspectors reviewed a sample of emergency response organization member training records to determine whether people assigned to the emergency response organization were properly trained for their assigned positions. The inspectors reviewed the licensee's procedures for testing their ability to staff the emergency response organization during an off-hours event, and reviewed results from augmentation tests performed between July 2023 and March 2025.
- (1) The inspectors reviewed the results of call-in surveillances conducted quarterly from the Third Quarter 2023 through the First Quarter 2025, to determine whether the licensee could reliably contact emergency response organization personnel to staff the licensee's emergency response facilities in the event of radiological emergency.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
The inspectors reviewed the licensee's procedures for evaluating changes to the licensee's emergency plan and emergency plan implementing procedures. The inspectors reviewed a sample of changes to the licensee's emergency plan and emergency plan implementing procedures performed by the licensee between July 2023 and March 2025 that were determined by the licensee not to require NRC review, to determine the effectiveness of the licensee's procedures for conducting analyses of the effects of those changes.
- (1) The inspectors reviewed 10 CFR 50.54(q) reviews for the Offsite Dose Calculation Manual, Revisions 18 through 22.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
The inspectors toured the licensee's emergency response facilities to evaluate how the facilities have been maintained. The inspectors reviewed documents related to the licensee's maintenance of their emergency preparedness program originated between July 2023 and March 2025 to determine the effectiveness of the licensee's emergency response program. These documents included the licensee's critiques of drills and exercises conducted by the licensee, critiques of licensee emergency response organization training, the content of lesson plans for emergency response organization training, audits and assessments of the licensee's emergency preparedness program conducted by the licensee, records of inventories conducted in the licensee's emergency response facilities, records of facility and equipment surveillances conducted by the licensee of equipment important to emergency preparedness, annual Evacuation Time Estimate studies, and evaluations of the interface between the licensee and offsite authorities. The inspectors reviewed the licensee's procedures for identifying issues and entering them into the licensee's corrective action program, reviewed a list of issues related to the licensee's emergency preparedness program entered into the licensee's corrective action program between July 2023 and March 2025, and reviewed a sample of emergency preparedness issues documented in the licensee's corrective action program to determine the effectiveness of the licensee's activities to corrective problems in the emergency preparedness program. The inspectors reviewed a sample of weaknesses and deficiencies identified by the licensee between July 2023 and March 2025 and entered into the licensee's corrective action program to determine whether the licensee had corrected the identified weaknesses in accordance with program requirements and NRC regulations.
- (1) The inspectors evaluated the licensee's maintenance of the emergency preparedness program through audits and surveillances, walkdowns of emergency response facilities, reviews of the licensee's evaluation of proposed changes to their emergency preparedness program, reviews of the licensee's ability to coordinate with offsite response organizations, and a review of the licensee's correction of issues identified with the emergency preparedness program.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (April 1, 2024, through March 31, 2025)
- (2) Unit 2 (April 1, 2024, through March 31, 2025)
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)
- (1) Unit 1 (April 1, 2024, through March 31, 2025)
- (2) Unit 2 (April 1, 2024, through March 31, 2025)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2024, through March 31, 2025)
- (2) Unit 2 (April 1, 2024, through Mach 31, 2025)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
The inspectors reviewed the data submitted by the licensee for the Drill and Exercise Performance (DEP) performance indicator for the Third and Fourth Quarter 2024, and for the First Quarter 2025. The inspectors reviewed a sample of the supporting data for the performance indicator, including drill and exercise scenarios, logs and other documents generated by the emergency response organization during drills and exercises evaluated for the performance indicator during the inspection period, and the licensee's critique of the emergency response organization's performance during drills and exercises evaluated for the performance indicator.
- (1) July 1, 2024, through December 2024. The DEP performance indicator for the First Quarter 2025 was not available for review.
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
The inspectors reviewed rosters of licensee personnel assigned to the emergency response organization during the Third Quarter 2024 through the First Quarter 2025. The inspectors verified that the DEP opportunities existed for a sample of drills and exercises conducted between the Second Quarter 2022 and the First Quarter 2025 for which performance credit was given between the Third Quarter 2024 and the First Quarter 2025. The inspectors verified that a sample of licensee emergency response personnel were correctly assigned DEP successes and failures during the inspection period.
- (1) July 1, 2024, through December 2024. The Emergency Response Organization Drill Participation performance indicator for the First Quarter 2025 was not available for review.
EP04: Emergency Response Facility and Equipment Readiness (ERFER) (IP Section 02.14) (1 Sample)
The inspectors reviewed the licensee's reported Emergency Response Facility and Equipment Readiness performance indicator for the First Quarter 2025. The inspectors reviewed licensee maintenance and facility records to determine the number of hours licensee emergency response facilities were unavailable during the First Quarter 2025 and compared this information with performance indicator requirements to evaluate the accuracy of the licensee's performance indicator report.
The inspectors reviewed the licensee's reported Alert and Notification System (ANS)
Reliability performance indicator for the Third Quarter 2024 and the Fourth Quarter 2024.
The inspectors reviewed records of the licensee's silent and audible tests of the alert and notification system to determine the accuracy of the licensee's report of the ANS performance indicator for the inspection period.
- (1) The Emergency Response Facility and Equipment Readiness performance indicator for the First Quarter 2025 was not available for review.
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in obsolescence that might be indicative of a more significant safety issue. The inspectors identified a trend of various components in several systems that are obsolete, no longer produced, or no longer able to be refurbished. The observation was shared with the licensee.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000498/2025-001-00, "Unit 1, Two Inoperable Emergency Core Cooling System Trains Resulting in Potential Loss of Safety Function" (ADAMS Accession No. ML25097A252). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is closed.
- (2) LER 05000499/2024-002-01, "Unit 2, Supplement to Two Control Room Envelope HVAC Trains Inoperable Resulting in a Condition That Could Have Prevented Fulfillment of a Safety Function" (ADAMS Accession No. ML25132A132). The inspection conclusions associated with this LER are documented in Inspection Report 05000498/2024004 and 05000499/2024004, dated January 30, 2025, under Inspection Results Section 71153. This LER is closed.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation Of An ISFSI The inspectors performed a review of the licensees independent spent fuel storage installation (ISFSI) activities to verify compliance with requirements of the certificate of compliance (CoC) 72-1032, license amendment 2 and the HI-STORM FW final safety analysis report (FSAR), Revision 5. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the Certificate's technical specifications, requirements in the FSAR, and NRC regulations.
Operation Of An ISFSI===
- (1) In accordance with inspection procedure 60855, Section 04.03, inspectors performed an in-office follow-up review which identified a violation for STP's acceptance and use of Holtec canisters with the continuous basket system (CBS) variant design change.
Inspectors evaluated the licensees dry cask storage operations from May 12-15, 2025, during an on-site inspection. The STP ISFSI consisted of one concrete pad that was designed to hold 90 HI-STORM FW Version XL overpacks each containing a Multi-Purpose Canister with 37 fuel assemblies (MPC-37). At the time of the routine inspection, the ISFSI pads contained a total of 29 overpacks and the licensee was in the process of loading canister 30.
During the on-site inspection, the inspectors evaluated and observed the following activities:
- loading and verification of spent fuel into canister No. 30
- walkdown of the ISFSI pad
- heavy load lifts using the cask handling crane to place the canister lid, while under water in spent fuel pool cask loading pit
- heavy load lift to remove the loaded canister and transfer cask from the pool to the cask washdown pit
- canister welding and non-destructive testing activities
- canister hydrostatic pressure testing
- canister drying
- canister helium backfill The inspectors reviewed and evaluated the following documentation during the inspection:
- fuel selection evaluations for the canisters loaded since the last NRC ISFSI inspection (canisters 22-30)
- radiation surveys for radiological doses at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for years 2021 - 2024
- selected ISFSI-related condition reports issued since the last NRC ISFSI inspection
- quality assurance program implementation, including recent audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations
- compliance with technical specifications for operational surveillance activities and FSAR required annual maintenance activities
- documentation of annual maintenance activities for the sites cask handling crane, vertical cask transporter, and special lifting devices
- selected licensee design changes and program changes to the ISFSI performed under the site's 10 CFR 72.48 program
- changes that had been made by the licensee to the site's 10 CFR Part 72.212 Evaluation report from the last inspection (revisions 3 and 4)
INSPECTION RESULTS
Enforcement Discretion Enforcement Action EAF-RIV-2025-0134: Noncompliance Related to a General Licensees Use of Non-Qualified Spent Fuel Casks (EGM 25-001)60855
Description:
Using the 10 CFR 72.48 change control process, Holtec International (Holtec)made a change to the design of its multi-purpose canisters (casks) that contain spent nuclear fuel inside of a honeycombed fuel basket. Holtec designated the basket design change as the Continuous Basket Shim (CBS) variant, and assessed how the design change from a welded to a bolted shim design impacted the cask structural performance during a hypothetical cask tip-over event. Holtec failed to consider the cumulative impacts from changes made to multiple elements of the method of evaluation (MOE) that were not consistent with the licensing basis. Additionally, Holtec adopted aspects of several different approved MOEs and did not apply these evaluation aspects in the same manner as the original MOE. As such, NRC found Holtec in violation of 10 CFR 72.48 requirements and issued three Severity Level IV violations for:
- (1) implementation of design changes to NRC approved spent fuel cask systems that resulted in departures from MOEs described in the final safety analysis report (FSAR);
- (2) failure to maintain adequate evaluations that provided the bases for determining that the design changes did not require a CoC amendment; and,
- (3) not subjecting the changes to design control measures that were commensurate with those applied to the original design (for more information see NRC inspection reports ML23145A175, ML24016A190 (Notice of Violation) and ML24060A214 (Holtecs response to Notice of Violation).
These violations affected 21 general licensees because they had already loaded the noncompliant casks with the CBS variant.
In addition to applying to Holtec, the requirements of 10 CFR 72.48 also apply to the 21 general licensees who had purchased and used the casks discussed above. Specifically, pursuant to 10 CFR 72.48(c), a licensee or certificate holder may make changes to a spent fuel storage cask design without obtaining a CoC amendment so long as those changes meet certain criteria defined in 10 CFR 72.48(c). Under 10 CFR 72.48(c)(2)(viii), if the change would result in a departure from the method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses, a general licensee must request that the certificate holder obtain a CoC amendment prior to implementing the proposed change. Accordingly, a general licensee seeking to adopt a change that a CoC holder made to a cask design must perform an evaluation to determine the suitability of the change itself. Further, 10 CFR 72.48(d)(1) requires a general licensee to maintain records of a change in the cask design made pursuant to 10 CFR 72.48(c). These records must include a written evaluation that provides the bases for the determination that the change does not require a CoC amendment pursuant to 10 CFR 72.48(c)(2). Prior to loading the noncompliant casks obtained from Holtec, 21 general licensees did not identify Holtecs cask modification (i.e., changing the basket shim from a welded to a bolted design) utilized MOEs that departed from the MOE described in the FSAR (as updated) that was used in establishing the design bases or in the safety analyses. Because of the noncompliant modification, the general licensees were required to request that the CoC holder submit an amendment request to the NRC to comply with 10 CFR 72.48(c)(2). Contrary to this requirement, none of the general licensees requested that the CoC holder submit an amendment request.
Additionally, pursuant to 10 CFR 72.212(b)(3), a general licensee must also ensure that each cask used by the general licensee conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214. The casks with the CBS variant did not conform to the CoC due to the changes that the CoC holder made. Consequently, the 21 general licensees who used the casks did not comply with 10 CFR 72.212(b)(3), because the casks did not conform to a CoC or amended CoC when the general licensees loaded them.
Corrective Actions: The licensee followed the guidance actions as described in the Enforcement Guidance Memorandum (EGM) 25-001, Noncompliance Related to a General Licensees Use of Certain Non-Qualified Spent Fuel Casks, dated February 11, 2025, (ML24303A436). The issue was entered into the corrective action program (CAP) and the licensee had already restored compliance for 12 CBS canisters onsite through an NRC approved exemption request in NRC letter titled Federal Register Notice: Issuance of Exemption for South Texas Project Electric Generating Station Units 1 and 2 and ISFSI Exemption Request, Dated June 9, 2024 (ML24086A423). The CAP actions included steps to address the cause of the violation and possibly performing a 10 CFR 72.48 evaluation to adopt the tip-over method of evaluation that was authorized by the NRC in Holtec HI-STORM FW System, amendment 7 (ML24199A236) if licensee decides to load additional CBS canisters beyond the 12 canisters that were exempted.
Corrective Action References: CR-23-10225, CR-25-4389
Enforcement:
Significance/Severity: This violation was dispositioned in accordance with the traditional enforcement process using section 2.3 of the NRCs Enforcement Policy. Consistent with the guidance in section 1.2.6.D of the NRC's Enforcement Manual, if a violation does not fit an example in the enforcement policy violation examples, it should be assigned a severity level:
- (1) commensurate with its safety significance; and
- (2) informed by similar violations addressed in the violation examples. The violation was evaluated to be similar to a Severity Level IV violation in Enforcement Policy section 6.1.d.2.
Violation: Title 10 CFR 72.48(d)(1) requires, in part, that the licensee shall have a written evaluation which provides the bases for the determination that the change does not require a CoC amendment pursuant to 72.48(c)(2).
Title 10 CFR 72.48(c)(2) requires, in part, a general licensee shall request that the certificate holder obtain a CoC amendment, prior to implementing a proposed change, if the change would: (viii) Result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses.
Title 10 CFR 72.212(b)(3) requires, in part, a general licensee must ensure that each cask used by the general licensee conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214.
Contrary to the above, from February 15, 2022 to June 9, 2024, the licensee failed to maintain records of changes in the spent fuel storage cask design made pursuant to 72.48(c)that include a written evaluation which provided the bases for the determination that the change did not require a CoC amendment. The licensee failed to request that the certificate holder obtain a CoC amendment, prior to implementing a proposed change, if the change would: (viii) Result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses. Further, the licensee failed to ensure each cask conformed to the terms, conditions, and specifications of a CoC or amended CoC listed in 72.214. Specifically, STP's 10 CFR 72.48 titled 10 CFR 72.212 Report, Revision 2, failed to identify that the CBS variant design change resulted in a departure from a method of evaluation described in the FSAR used in establishing the design bases, failed to request the certificate holder obtain a CoC amendment pursuant to 10 CFR 72.244, and failed to ensure each cask conformed to the terms conditions, and specifications of a CoC or an amended CoC listed in 72.214, prior to using the canisters.
Basis for Discretion: A general licensees loading of a non-compliant Holtec cask (i.e.,
MPC 37-CBS, MPC 89-CBS, MPC 68M-CBS, and MPC 32M-CBS) under the circumstances presented here has been designated as having very low safety significance. The NRC performed an Immediate Safety Determination to confirm that general licensee use of the CBS basket design does not pose a risk to public health and safety, which stated:
A potential consequence of the unapproved design change is a cask tip-over event that results in damaged fuel assemblies. The staff assigned a significance of Severity Level IV (i.e., violations that are less serious, but are of more than minor concern) because Holtecs failure to obtain an amendment is deemed as having very low safety significance (see Section 6.1.d.2 of the Enforcement Policy). The staffs safety significance determination is summarized in memorandum, Safety Determination of a Potential Structural Failure of the Fuel Basket During Accident Conditions for the HI-STORM 100 and HI-STORM Flood/Wind Dry Cask Storage Systems (ML24018A085).
In accordance with the NRC Enforcement Policy, Section 3.5, Violations Involving Special Circumstances, the NRC may refrain from issuing a violation based on the merits of the case after considering factors such as the clarity of the requirement and associated guidance, as well as other relevant circumstances. The NRC-endorsed industry guidance lacks clarity concerning the level of review required by general licensees of changes made by CoC holders pursuant to 10 CFR 72.48 that include a modified, new, or different MOE. The significant number of general licensees that failed to comply with the applicable regulations in this instance also indicates a lack of clarity. Accordingly, the staff will exercise enforcement discretion for general licensees violations of 10 CFR 72.48 and 10 CFR 72.212 because of the lack of clarity in the guidance.
Since this violation was identified during the discretion period covered by EGM 25-001, the licensee has taken the necessary conditions specified in the EGM to place the issue into their CAP, and taken actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation.
Observation: Semi-Annual Trend Review - Obsolete components with potential to affect safe operations 71152S The inspectors reviewed the licensees corrective action program, performance indicators, condition reports (CR), and other documentation available to help identify performance trends that might indicate the existence of a more significant safety issue. The inspectors identified a trend of various components in several systems that are obsolete, no longer produced, or no longer able to be refurbished.
CR 2023-6224: E-Plan has obsolete dose rate meters and few spares.
CR 24-4605: Polar crane auxiliary hoist brakes are obsolete.
CR 24-12270: Certain motherboards have been determined to be unrepairable by cyber security.
CR 25-3566: Non-obsolete spares for rod control system transformers need to be identified.
CR 25-5318: Certain molded case circuit brakers will be phased out and replaced in the next 18 months.
CR 25-6138: Data link boards for Qualified Display Processing System are no longer being refurbished, and replacements are not currently available.
CR 25-6182: Plasma displays in the Qualified Display Processing System are obsolete, and replacements do not meet human factor requirements.
The licensee has entered these issues into the corrective action program. However, the inspectors noted that some of these issues have been progressing for years, and actions to resolve them have been delayed. Simultaneous failure of multiple obsolete components could impair plant operations and leave no time for prompt resolution.
Failure to Promptly Identify and Correct a Condition Adverse to Quality on Emergency Core Cooling System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498/2025002-01 Open/Closed
[P.2] -
Evaluation 71153 The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the licensees failure to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to correct a previously identified leak coming from a Unit 1 train B safety injection sampler tee connection.
Subsequently, while the emergency core cooling system train C was out of service for maintenance, the train B leak was found to exceed an administrative limit when operating the safety injection pump. This led operators to place the B safety injection pump in pull-to-lock, causing the emergency core cooling system train B to be inoperable while train C was also inoperable.
Description:
The emergency core cooling system (ECCS) consists of, in part, three subsystems, each train containing a low head safety Injection pump, residual heat removal heat exchanger, and a high head safety injection (HHSI) pump. During a design basis loss of coolant accident, one unaffected ECCS train delivers make-up water to the affected reactor coolant system (RCS) train with the pipe break while the second unaffected ECCS train provides additional cooling capabilities to reactor core. The HHSI pumps supply borated water into the RCS following a design-based accident for short term cooling and to recirculate borated water from the containment sump to the RCS hot or cold legs during long-term cooling/recirculation phase.
On February 18, 2025, South Texas Project, Unit 1 was performing planned maintenance on essential chilled water train C, which has a cascading effect that renders ECCS train C inoperable. While this maintenance was ongoing, station personnel became aware of a leak on ECCS train B, which was found at a pipe tee downstream of valve SI-0126B, which is on a sample line. The licensee determined the leak to be approximately 3.73 ml/min and proceeded to start HHSI pump 1B as part of their response to the leakage. Following the start of HHSI pump 1B, the leakage increased and became two pencil-sized streams. The licensee determined that the leakage was more than the allowance of their procedure 0PSP11-SI-0017 Safety Injection System Train 1B/2B Contaminated System Leakage Test, Revision 24. On February 19, 2025, at 0324 hours0.00375 days <br />0.09 hours <br />5.357143e-4 weeks <br />1.23282e-4 months <br />, the licensee declared train B of ECCS and train B of control room makeup and cleanup filtration system inoperable due to the excessive leakage.
On February 19, 2025, at 0749 hours0.00867 days <br />0.208 hours <br />0.00124 weeks <br />2.849945e-4 months <br />, operations placed the HHSI Pump 1B control room handswitch in "Pull-to-Lock" to comply with Technical Specification (TS) 3.7.7, Action "e.1" to immediately initiate action to implement mitigating actions for one or more inoperable control room makeup and cleanup filtration systems. The licensee continued to take actions to address the leak until 1405, when all maintenance and post-maintenance testing was completed and train B ECCS and control room makeup and cleanup filtration system were declared operable.
On February 25, 2025, the licensee determined after further evaluation that both train B of ECCS and train B of control room makeup and cleanup filtration system had remained capable of fulfilling their safety functions even when considering the effects of the leak.
However, by taking the action of placing HHSI pump 1B in "Pull-to-Lock," operators had made train B of ECCS inoperable while train C ECCS was also inoperable.
The inspectors reviewed the Licensee Event Report 2025-001-00, Two Inoperable Emergency Core Cooling System Trains, Resulting in Potential Loss of Safety Function, the licensees completed procedures and calculations regarding leakage, as well as past leakage calculations and recent communications with operations. The inspectors noted that the boric acid buildup around valve SI-0126B, as well as the abnormal water accumulation around and below it, had been brought up to the Unit 1 control room after an NRC inspector walkdown on February 11, 2025. The inspectors identified that the Unit 1 control room staff had not written a condition report to address the inspectors concerns. The inspectors received a response from Operations stating that it appeared that it is ground water weeping through the wall.
After the event, inspectors were informed that non-licensed equipment operators had also reported the condition (on February 4, 2025) prior to the inspectors doing so, however, a condition report was not written at that time either, and no action was taken to initiate corrective actions. The inspectors noted that if the licensee had taken corrective actions when the issue was initially discovered, there would have been no loss of safety function because the other two ECCS trains were operable at that time.
Corrective Actions: The licensee adjusted the tee fitting where the leakage was active until the leakage was eliminated. Additionally, the licensee implemented an extent of condition review that involved testing for leakage on corresponding valves in other trains.
Corrective Action References: Condition Reports 2025-1705, 2025-1707, 2025-1832
Performance Assessment:
Performance Deficiency: The failure to promptly identify and correct a condition adverse to quality on the emergency core cooling system was a performance deficiency. Specifically, the licensee did not take actions (such as generating a condition report) to address leakage of a pipe tee fitting downstream of normally closed HHSI sample valve SI-0126B, even after the condition was identified multiple times. This subsequently led the licensee to declare the B train of ECCS inoperable while the C train of ECCS was also inoperable.
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. Specifically, the failure to promptly identify and correct the ECCS leakage degraded condition led to two simultaneously inoperable ECCS system trains and resulted in a potential loss of safety function.
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 used Exhibit 2, Mitigating Systems Screening Questions, and determined the finding to be of very low safety significance (Green) because it:
- (1) was not a deficiency affecting design or qualification of a mitigating system,
- (2) did not represent a loss of the probabilistic risk assessment (PRA) function of a single train TS system for greater than allowed outage time,
- (3) did not represent a loss of PRA function of one train of a multi-train TS system for greater than its TS allowed outage time,
- (4) did not represent a loss of the PRA function of two separate TS 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 PRA system and/or function as defined by the plant risk information e-book or the licensees PRA 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 maintenance rule risk-significant, non-TS train for greater than three days. Specifically, ECCS trains B and C were simultaneously inoperable for less than 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. Additionally, the finding did not involve external event mitigating systems, the reactor protection system, fire brigade, or flexible coping strategies.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to thoroughly evaluate the identified leakage condition past valve SI-0126B when it was discovered. This led operators to place the train B safety injection pump in pull-to-lock while train C was under maintenance, causing the ECCS train B to be inoperable while ECCS train C was also inoperable.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from February 4 to 19, 2025, measures did not assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances were promptly identified and corrected. Specifically, a leak existed in a safety injection sample line with no action from the licensee to place the degraded condition in the corrective action program or correct the condition. This led to two simultaneously inoperable ECCS system trains resulting in a potential loss of safety function.
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 April 17, 2025, the inspectors presented the Emergency Preparedness Program Inspection exit meeting inspection results to Kimberly Harshaw, Acting President, Chief Executive Officer, and Chief Nuclear Officer and other members of the licensee staff.
- On May 15, 2025, the inspectors presented the ISFSI Triennial exit meeting inspection results to Jason Tomlinson, Site Vice President and other members of the licensee staff.
- On July 10, 2025, the inspectors presented the integrated inspection results to Charles Kharrl, President, Chief Executive Officer, and Chief Nuclear Officer and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-YYYY-NNNN
2001-16799, 2022-10505, 2022-5699, 2022-6019,
22-52, 2022-3656, 2022-6377, 2022-5680,
24-6624, 2024-4736, 2024-5730, 2024-5730,
24-7004, 2025-1469, 2025-2482, 2025-2492,
25-2539, 2025-2613, 2025-22637, 2025-2786,
25-2888, 2025-3159, 2025-3815, 2025-3854,
25-3960, 2025-4389, 2023-10225
Corrective Action
Documents
Resulting from
Inspection
CR 2025-4507
During the hydrogen monitoring portion of MPC lid to
shell welding, that the setup of the hydrogen sampler
was not sampling only the volume beneath the weld
but was intaking outside air.
CFR 72.48
For 10 CFR 72.212 Report Revision 3 and 4
24-2886-9
Issuing Holtec HI-STORM and MPC-37 Licensing
Drawings for 2025 Campaign
25-2482-6
Approve alternate part for the HI-TRAC VW Thermal
Expansion Relief Device (TERD) and use of the
diverter tool
Engineering
Evaluations
EC 24-2886-8
Adopt New Design of HI-TRAC VW Fire Accident
Relief Device
2757
Technical Requirements Manual - South Texas
Project Unites 1 & 2
24 Radioactive Effluent Release Report
STEX_COC_SFSC
STP's certificate of compliance 1032
STEX_FSAR_HI-
STORM_FW-MPC
STP's final safety analysis report for HI-STORM XL
Miscellaneous
STEX_ISFSI_72.212EVAL
STP's 212 report
CFR 72.48 Screening and Evaluations
ISFSI surveillance inspections
Fuel Assembly and Fuel Insert Transfer Program
0PGP03ZX0002_CR
Process
Corrective action program procedure
60855
Procedures
Fuel Handling Machine
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation
Surveys
SURVEY
Radiological survey of ISFSI pad area.
Self-
Assessments
HOLTEC Quality
Surveillance Report 24-
005
Licensee audit of Holtec quality assurance program
Work Orders
7F101NCB102A
Cask handling overhead 150-ton crane annual
inspection
Corrective Action
Documents
CR-YYYY-NNNN
25-3342
Drawings
5R289F05038#1, Sh 3
Essential Cooling Water System Train 1C
Procedures
Essential Cooling Water Operations
Fire Preplan Electrical Auxiliary Building, Auxiliary
Shutdown Area
Fire Plans
Fire Preplan Isolation Valve Cubicle, Pump Room
Train A
Fire Preplan for Lube Oil Skid - Turbine Oil Storage
Area
Procedures
STPEGS Fire Brigade
Reactor Startup
Steam Generator Tube Rupture
Reactor Trip or Safety Injection
Reactor Trip Response
Procedures
Control Rod Operability
Configuration Risk Management Program
Protected Components
Procedures
Class 1E 125V DC Battery Feeder Breaker
Replacement
Calculations
EW-2205-13VP
Fitness for Service Analysis Results
Corrective Action
Documents
CR-YYYY-NNNN
25-4223, 2025-5218, 2025-4199
Work Orders
Work Authorization
Numbers
640782, 693197, 726831
Corrective Action
CR-YYYY-NNNN
25-3824
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
ASME Section XI Repair/Replacement Activities
Control Rod DRPI Transition Data Collection
Auxiliary Feedwater Pump 14(24) Inservice Test
Standby Diesel 12(22) Operability Test
Essential Cooling Water System Train A Testing
Essential Cooling Water System Train B Testing
Procedures
Control Rod Operability
Work Orders
Work Authorization
Numbers
714964, 705697, 672341, 678935, 285726, 632958,
634925, 686805, 689287, 710538, 710559, 639335,
639339, 612763, 685295, 685296, 685297, 703379,
26444
Integrated Public Alert and Warning System,
Matagorda County Procedure 66, IPAWS Quality
Checklist
03/26/2024
Self-
Assessments
Integrated Public Alert and Warning System,
Matagorda County Procedure 66, IPAWS Quality
Checklist
March 2025
Key Positions Pre EONS 09_25_24
Miscellaneous
Key Positions Post EONS 09_25_24
Corrective Action
Documents
CR 23-78-26,
CR 23-78-27,
CR 23-78-28,
CR 23-78-29,
CR 23-78-30
Corrective Action Reports to track the following:
ODCM Rev 18 50.54(q) Screening
ODCM Rev 19 50.54(q) Screening
ODCM Rev 20 50.54(q) Screening
ODCM Rev 21 50.54(q) Screening
ODCM Rev 22 50.54(q) Screening
Operations Scenario Briefing Guidance
Miscellaneous
CR-YYYY-NNNN
24-9158, Trending Report, Equipment Important to
Emergency Response, Biannual Trend, June 2022 to
May 2024
CR-YYYY-NNNN
25-3644, 2025-3720, 2025-3813, 2025-3814
Corrective Action
Documents
Apparent Cause
Evaluation:
Unit 2 Shift Manager inappropriately entered EPlan
for Unit 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2024-7310,
CR-YYYY-NNNN
24-7216-25, 2024-11655-37, 2025-1730, 2025-
1731, 2025-1732, 2025-1733, 2025-1735, 2024-277-
28, 2024-277-30, 2024-277-22, 2024-277-13, 2023-
6137, 2023-6767, 2023-6771, 2023-6136, 2023-
7090,
23-7170, 2023-7171, 2023-7230, 2023-7491,
23-7399, 2023-8094, 2023-9096, 2023-9381,
23-9760, 2023-11193, 2024-805, 2024-1162,
24-3298, 2024-4344, 2024-4758, 2024-5724,
24-7042, 2024-7051, 2024-8417, 2024-9263,
25-1013
CR-2024-9159
Trending Report, Equipment Important to Emergency
Response, First Biennial Trend 2024
PMWO RO-1-04000606, Unit 1 SCBA Drill,
05/14/2024
PMWO RO-2-04000607, U2 SCBA Drill,
05/04/2024
Letter dated 1/20/2025, Marc Hill, Manager,
Emergency Preparedness, to Mr.
Division of Emergency Management, Subject: Annual
Letter of Certification for the South Texas Electric
Generating Station for Calendar Year 2024
01/20/2025
Shift Manager Key PI - Eplan Scenarios Evaluation
Report
08/24/2024
Senior Management Team Issues,
09/04/2024
Senior Management Team Issues,
11/13/2024
Senior Management Team Issues,
03/26/2025
KLD-TR 24-1429
24 Population Update Analysis
07/27/2024
ERT Functional Assessment, Temporary Loss of
Power at the Joint Information Center, 05/09/2024
ERT Functional Assessment, Loss of Onsite Power
causing a loss of IT Equipment in the Emergency
Miscellaneous
5054(q) Screen Evaluation, 23-78-29, Changes to
the ODCM 2012 to 2023, 11/14/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Annual Public Information Content Review and
Update, 03/27/2024
Annual Evacuation Time Estimate Study Review,
07/29/2023
Drill and Exercise Feedback Form, First Quarter
25 Red Team Tabletop, 02/12/2025
Drill and Exercise Feedback Form, First Quarter
25 White Team Tabletop, 02/19/2025
Drill and Exercise Feedback Forms, Blue Team
Tabletop, 05/29/2024
Control Room Emergency Plan Inventory, Third
Quarter 2023, Units 1 and 2, 10/09/2023
Control Room Emergency Plan Inventory, Second
Quarter 2024, Units 1 and 2, 05/20/2024
Control Room Emergency Plan Inventory, Fourth
Quarter 2023, Units 1 and 2, 12/14/2023
Control Room Emergency Plan Inventory, Third
Quarter 2024, Units 1 and 2, 09/30/2024
Quarterly EOF and Alternate TSC-OSC Inventory,
First Quarter 2024, 03/25/2024
Quarterly EOF and Alternate TSC-OSC Inventory,
First Quarter 2023, 04/13/2023
Quarterly Environmental Sampling Kit Inventory,
Third Quarter 2024, 10/1/2024
Quarterly Environmental Sampling Kit Inventory, First
Quarter 2025, 04/01/2025
Quarterly Environmental Sampling Kit Inventory,
Third Quarter 2024, 10/01/2024
Quarterly Hospital Inventory, First Quarter 2025
(MCRMC and PCMC), 03/31/2025
Emergency Notification and Response System Tests,
Third Quarter 2023, 09/19/2023
Emergency Notification and Response System Tests,
Fourth Quarter 2023, 12/06/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency Notification and Response System Tests,
First Quarter 2024, 03/14/2024
Emergency Notification and Response System Tests,
Second Quarter 2024, 06/12/2024
Emergency Notification and Response System Tests,
Third Quarter 2024, 08/22/2024
Emergency Notification and Response System Tests,
Fourth Quarter 2024, 12/04/2024
Emergency Notification and Response System Tests,
First Quarter 2025, 03/05/2025
Monthly Communications Tests, September 2023,
10/15/23
Monthly Communications Tests, January 2024,
01/22/2024
Monthly Communications Tests, April 2024,
04/24/2024
Monthly Communications Tests, November 2024,
2/04/2024
Annual Communications Tests, 2023, 11/15/2023
Annual EP Staff Training Review, 12/05/2025
Annual EP Staff Training Review, 1/14/25
ODCM Impact Assessment, 12/5/22
EPLL-23-JIC-04,
EP Lessons Learned, CR-23-6137
09/2820/23
EPLL-24-EOF-03
EP Lessons Learned, CR-23-6136
01/03/2024
EPLL-25-EOF-02, 24-
8417-1
EP Lessons Learned, ERO Enhancement item
identified in the EOF
Lessons Learned Bulletin,
Blue CFD Inaccurate STAMPEDE Assessment
24 Blue Team Dress Rehearsal Critique
06/05/2024
Environmental Sampling Drill Critique
10/11/2023
23 Emergency Medical Drill Critique
09/07/2023
23 Blue Team Combined Functional Drill Critique
08/02/2023
24 Annual Environmental Monitoring Drill Critique
08/14/2024
Procedures
24 Emergency Medical Drill Critique
09/11/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Unit 1 Loss of Offsite Power and Unusual Event
Critique
07/24/2024
23 Gold Team Combined Functional Drill Critique
06/14/2023
24 Blue Team Exercise Critique, 07/17/2024,
Condition not Adverse to Quality Resolution Process
24 White Team Combined Functional Drill Critique
09/28/2024
23 Red Team Combined Functional Drill Critique
09/13/2023
23 Blue Team Combined Functional Drill Critique
09/02/2023
23 Onsite Medical Response Capabilities
Demonstration Critique
05/24/2023
Emergency Preparedness Program Administration
Emergency Preparedness Document Changes
Emergency Preparedness Facilities/Equipment
Inventories and Surveillances, 09/25/2024
Emergency Preparedness Facilities and Equipment
Maintenance and Surveillances
Emergency Preparedness Training and Qualification,
09/25/2024
Emergency Drills and Exercises, 07/02/2024
5054(q) Screen Evaluation
5053(q) Effectiveness Evaluation
EAL Change Evaluation
Drill and Exercise Development
Drill and Exercise Conduct and Evaluation
2/13/2017
Audit Report 24-01
Quality Audit Report, Emergency Preparedness
Audit Report 25-01
Quality Audit Report, Emergency Preparedness
South Texas Electric Generating Station Emergency
Plan
Prompt Notification System Design Report
09/29/2021
EP0003.001
EAL Technical Basis Manual
09/25/2024
EP0004.001
(STI35364239, KLD TR-
STPEGS Evacuation Time Estimate Study using the
20 Decennial Census
7/29/2022)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
244
Matagorda County
Procedure 66
IPAWS Quality Checklist
03/12/2025
Matagorda County
Procedure 66,
IPAWS Quality Checklist
03/26/2024
3rd Quarter 2024 EP Performance Indicator Report
4th Quarter 2024 EP Performance Indicator Report
1st Quarter 2025 EP Performance Indicator Report
Miscellaneous
SSFF data sheets and Barrier integrity (RCS specific
activity and RCS Leakage) Performance Indicator
reports
71151
Procedures
EP Performance Indicator Evaluation and Tracking
Corrective Action
Documents
CR-YYYY-NNNN
25-6182, 2025-6138, 2025-5681, 2025-3566,
25-2295, 2024-4605
Corrective Action
Documents
CR-YYYY-NNNN
25-1705, 2025-1707, 2025-1832, 2024-8068,
21-8518
Operability
Evaluations
Tier 3 Past Operability
Review
Tier 3 Past Operability Review for CR 25-1707-04
Procedures
Safety Injection System Train 1B/2B Contaminated
System Leakage Test
24