IR 05000498/2009301
| ML100332234 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/27/2010 |
| From: | Garchow S Operations Branch IV |
| To: | Halpin E South Texas |
| References | |
| 50-498/09-301, 50-499/09-301 | |
| Download: ML100332234 (17) | |
Text
January 27, 2010
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - NRC EXAMINATION REPORT 05000498/2009301; 05000499/2009301
Dear Mr. Halpin:
On December 11, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at South Texas Project Electric Generating Station, Units 1 and 2.
The enclosed report documents the examination findings and licensing decisions. The preliminary examination findings were discussed on December 11, 2009, with Mr. Tim Bowman, General Manager Oversight, and other members of your staff. A telephonic exit meeting was conducted on December 17, 2009, with Mr. Ken Struble, who was provided the NRC licensing decisions.
The examination included the evaluation of seven applicants for reactor operator licenses, one applicant for instant senior reactor operator license and four applicants for upgrade senior reactor operator licenses. The license examiners determined that eleven of the twelve applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were three post examination comments submitted by your staff.
Enclosure 1 contains details of this report and Enclosure 2 summarizes post examination comment resolution.
During the examination, a self-revealing finding was identified and evaluated under the Significance Determination Process as having very low safety significance (Green). The NRC has also determined that a violation is associated with the finding. Consistent with Section VI.A of the Enforcement Policy, the violation is being treated as a non-cited violation because it has been entered into your corrective action program. The violation is described in the subject inspection report. If you contest the violation or its significance, 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, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd., Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident UNITED STATES NUCLEAR REGULATORY COMMISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125
STP Nuclear Operating Company
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Inspector at the South Texas Project Electric Generating Station. In addition, if you disagree with the characterization of the finding 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 Regional Administrator, Region IV, and the NRC Resident Inspector at South Texas Project Electric Generating Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Steve Garchow, Acting Chief Operations Branch
Division of Reactor Safety
STP Nuclear Operating Company
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Dockets: 50-498; 50-499 Licenses: NPF-76; NPF-80
Enclosure:
1. NRC Examination Report 05000498/2009301; 05000499/2009301 2. NRC Post Examination Comment Resolution
REGION IV==
Dockets:
50-498, 50-499 Licenses:
05000498/2009301; 05000499/2009301 Licensee:
STP Nuclear Operating Company Facility:
South Texas Project Electric Generating Station, Units 1 and 2 Location:
FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates:
December 3 - 17, 2009 Inspectors:
Brian Larson, Senior Operations Engineer Kelly Clayton, Senior Operations Engineer Clyde Osterholtz, Senior Operations Engineer Mike Bielby, Senior Operations Engineer (Region III)
Approved By:
Steve Garchow, Acting Chief Operations Branch Division of Reactor Safety
Enclosure 1
SUMMARY OF FINDINGS
ER05000498/2009301; 05000499/2009301; December 4, 2009; South Texas Project Electric
Generating Station, Units 1 and 2; Initial Operator Licensing Examination Report.
NRC examiners evaluated the competency of seven applicants for reactor operator licenses, one applicant for instant senior reactor operator license and four applicants for upgrade senior reactor operator licenses at South Texas Project Electric Generating Station, Units 1 and 2.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on December 3, 2009. NRC examiners administered the operating tests during the week of December 7, 2009.
The examiners determined that eleven of the twelve applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. One self-revealing Green non-cited finding was identified. The significance of this finding is indicated by its color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
A self-revealing non-cited violation of Technical Specification 6.8.1 was identified for failing to properly implement Emergency Operating Procedures required by section 6.8.1a. Specifically, four crews out of five did not take actions as directed in 0POP05-EO-FRC2, Response to Degraded Core Cooling, Step 2. Specifically,
Step 2 directs the Operators to "Verify SI Flow in All trains." If flow in all High Head Safety Injection trains is not present, the Response Not Obtained column of the procedure directs a manual start of High Head Safety Injection pumps that are not running. If it is determined that flow has still not been established in all trains, the subsequent Response Not Obtained steps direct the operators to establish maximum charging flow. Three applicant crews failed to identify Safety Injection flow did not exist in all trains and continued with the procedure without performing Response Not Obtained actions. One licensed crew recognized Safety Injection did not exist in all trains, but failed to establish maximum charging. The licensee has entered this issue into their corrective action program as Condition Report 09-20312.
This finding was more than minor because it affected the mitigating systems cornerstone attributes of procedure quality and human performance of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Also, using Inspection Manual Chapter 0612,
"Power Reactor Inspection Reports," Appendix B, Section 1-3, "Screen for More than Minor - ROP," question 2, the finding is more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Using the Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Worksheets, the finding was determined to have very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a Technical Specification allowed outage time, and did not affect external event mitigation. The finding had a crosscutting aspect in the area of Problem Identification and Resolution associated with the corrective action program because the licensee failed to identify and correct deficiencies associated with the training program and procedures for degraded and inadequate core cooling at a threshold commensurate with the safety significance P.1(a).
Licensee-Identified Violations
None.
REPORT DETAILS
OTHER ACTIVITIES (OA)
Cornerstone: Mitigating Systems
4OA2 Identification and Resolution of Problems
a. Examination Scope
The examiners observed procedure implementation and operator performance during the initial license examination validation with licensed operators and during the initial license examination administration with applicants.
b. Findings
Introduction.
A self-revealing non-cited violation of Technical Specification 6.8.1 was identified for failing to properly implement Emergency Operating Procedures.
Specifically, four crews out of five did not take actions as directed in 0POP05-EO-FRC2, Response to Degraded Core Cooling, Step 2. Specifically, Step 2 directs the Operators to "Verify SI Flow in All trains." If flow in all High Head Safety Injection (HHSI) trains is not present, the Response Not Obtained (RNO) column of the procedure directs a manual start of HHSI pumps that are not running. If it is determined that flow has still not been established in all trains, the subsequent RNO steps direct the operators to establish maximum charging flow.
Description.
During the scenario portion of the examination, crews were given a scenario with a design basis Loss of Coolant Accident (LOCA) with one train of Low Head Safety Injection (LHSI) and HHSI under clearance. During the scenario, an additional LHSI pump failed to start on SI actuation and could not be restarted. At Step 2 of 0POP05-EO-FRC2, three out of four applicant crews incorrectly evaluated this step as being met and continued in the procedure without performing the appropriate RNO actions to establish maximum charging flow. One licensed operator crew correctly evaluated the step and entered the RNO column but failed to establish maximum charging. At this decision point, core exit thermocouple temperatures were greater than 1000 °F and slowly rising. The chief examiner consulted with licensee staff, which included an operations manager and training manager, and concluded that both the procedure and training on these topics needed improvements.
Analysis.
The failure of applicants and licensed operators to correctly implement 0POP05-EO-FRC2 was a performance deficiency. The finding is more than minor because the failure of operations personnel to implement emergency operating procedures was associated with the mitigating systems cornerstone human performance and procedure qualities attributes of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Also, using Inspection Manual Chapter 0612, "Power Reactor Inspection Reports," Appendix B, Section 1-3, "Screen for More than Minor - ROP," question 2, the finding is more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the examiners concluded the significance of this finding is of very low safety significance because the finding was not a design or qualification deficiency, did not result in the loss of equipment operability or functionality, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because the licensee failed to identify and correct deficiencies associated with the training program and procedures for degraded and inadequate core cooling at a threshold commensurate with the safety significance P.1(a).
Enforcement.
Technical Specification 6.8.1.b required the licensee to implement the Emergency Operating Procedures. 0POP05-EO-FRC2 required that the procedure be implemented such that procedure steps are interpreted and followed correctly to address degraded core cooling issues during emergency conditions. Contrary to the above, applicants and licensed operators did not implement Emergency Operating Procedure 0POP05-EO-FRC2 correctly during initial examinations that occurred during the week of December 7-11, 2009, and during validation the week of November 16, 2009. Because this finding is of very low safety significance and was entered into the corrective action program as Condition Report 09-20312, this violation is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000498;05000499/2009301-01, Failure to Correctly Implement Emergency Operating Procedures.
4OA5 Other Activities (Initial Operator License Examination)
.1 License Applications
a. Scope
NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b. Findings
No findings of significance were identified.
.2 Examination Development
a. Scope
NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.
b. Findings
NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
NRC examiners determined that the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
.3 Operator Knowledge and Performance
a. Scope
On December 3, 2009, the licensee proctored the administration of the written examinations to all twelve applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post examination comments to the NRC on December 10, 2009.
The NRC examination team administered the various portions of the operating tests to all twelve applicants during the week of December 7, 2009.
b. Findings
No findings of significance were identified.
All of the applicants passed all parts of the operating test. Eleven applicants passed the written examination. One reactor operator failed the written examination. The final written examinations and post-examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in the attachment.
The examination team noted the following generic weaknesses: 1) Applicants failed to demonstrate good situational awareness. 2) Most SRO applicants did not identify a one hour Technical Specification action statement. 3) All four applicant crews failed to initially diagnose a failed steam pressure transmitter. 4) Seven of eight applicants failed to recognize Tref is not in service with the Main Turbine secured.
.4 Simulation Facility Performance
a. Scope
The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.
b. Findings
No findings of significance were identified.
.5 Examination Security
a. Scope
The NRC examiners reviewed examination security during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
The chief examiner presented the preliminary examination results to Messrs. Jim Calvert, Tim Frawley, Wayne Harrison, Jon Pierce, Ken Struble, and other members of the staff on December 11, 2009. A telephonic exit was conducted on December 17, 2009, between Messrs. Brian Larson, Chief Examiner, and Ken Struble.
The licensee did not identify any information or materials used during the examination as proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
Jon Pierce
Ken Struble
NRC Personnel
Binesh Tharakan, RI