IR 05000498/2013005
| ML14038A368 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/06/2014 |
| From: | O'Keefe N NRC/RGN-IV/DRP/RPB-B |
| To: | Koehl D South Texas |
| O'Keefe C | |
| References | |
| IR-13-005 | |
| Download: ML14038A368 (62) | |
Text
U N IT E D S TA TE S N U C LE AR R E GU LA TOR Y C OM MI S S I ON R E G IO N I V 1600 EAST LAMAR BLVD AR L I NG TO N , TE X AS 7 60 1 1 - 4511 February 6, 2014 Mr. Dennis Koehl President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Subject: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2013005 and 05000499/2013005
Dear Mr. Koehl:
On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On January 9, 2014, the NRC inspectors discussed the results of this inspection with Mr. G. Powell, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the significance of the NCV, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility.
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 Regional Administrator, Region IV, and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management 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/
Neil OKeefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80 Enclosure: Inspection Report 05000498/2013005 and 05000499/2013005 w/ Attachment 1: Supplemental Information w/ Attachment 2: Document Request for Inservice Inspection Activities w/ Attachment 3: Document Request for Occupational Radiation Safety Inspection
SUMMARY
IR 05000498/2013005, 05000499/2013005; 09/29/2013 - 12/31/2013; South Texas Project
Electric Generating Station, Units 1 and 2, Biennial Requalification Inspection.
The inspection activities described in this report were performed between September 29, 2013, and December 31, 2013, by the resident inspectors at the South Texas Project Electric Generating Station, Units 1 and 2, facility and eight inspectors from the NRCs Region IV office and other NRC offices. Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Components Within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Initiating Events
- Green.
The inspectors identified a non-cited violation of Title 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for failure to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, the licensee did not include sufficient criteria to identify and evaluate new critical tasks created for operator performance on the simulator scenario portion of the biennial requalification examination to enable the evaluators to correctly assess licensed operator performance. The licensee has entered this issue into their corrective action program as Condition Report 2013-13857.
The failure to include appropriate qualitative acceptance criteria in Procedure LOR-GL-002, to ensure evaluators can correctly identify and evaluate critical tasks based on operator performance was a performance deficiency. The performance deficiency was more than minor, therefore, a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the failure to include the appropriate criteria to identify and evaluate critical tasks during biennial requalification examinations could result in operators returning to licensed operator duties without being properly remediated and retested on performance deficiencies. Using Manual Chapter 0609, Attachment 0609.04, Appendix I, Operator Requalification Human Performance Significance Determination Process, starting at block 9, the finding was determined to be of very low safety significance (Green) because the finding is associated with licensee administration of an annual requalification operating test. The finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to make safety-significant or risk-significant decisions using a systematic process H.1(a) (Section 1R11.3.b.1).
- Green.
The inspectors identified a finding of very low safety significance for developing and administering an excessive number of flawed job performance measures during the 2012 and 2013 NRC annual operating tests, which resulted in invalidating several operators NRC annual operating tests. The inspectors reviewed all of the job performance measures that were developed and/or administered to the licensed operator staff for their annual operating tests. Greater than 20 percent of the job performance measures reviewed for both 2012 and 2013 were deemed to be flawed and inappropriate for an NRC-required operating test.
This invalidated the operating tests for some of the licensed operators in both years. As part of their corrective action, Condition Report 2013-10673, the licensee retested the operators that were affected after the 2013 test, and analyzed the effect on site-wide human performance errors that the affected operators may have had after the 2012 operating testthere was no increase in human performance errors attributable to taking the flawed 2012 operating test.
Using Inspection Procedure 71111.11, Appendix C, Annual Requalification Operating Test Quality, more than 20 percent of the annual operating test job performance measures developed in 2012 and 2013 were flawed; therefore, this was a performance deficiency. In accordance with Manual Chapter 0612, Power Reactor Inspection Reports, the performance deficiency was more than minor, therefore, a finding because it affected the Initiating Events Cornerstone attribute of Human Performance, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Manual Chapter 0609, Attachment 0609.04, Appendix I, Operator Requalification Human Performance Significance Determination Process, starting at block 6, the finding was determined to be of very low safety significance (Green) because: the finding involved operating test quality; less than 40 percent of the job performance measures were flawed; and less than 40 percent of the simulator scenarios were flawed. In addition, the NRC determined the finding had a human performance cross-cutting aspect associated with decision-making because the licensee did not use conservative assumptions in decision making when developing the flawed job performance measures that invalidated several operators annual operating tests H.1(b) (Section 1R11.3.b.2).
PLANT STATUS
Unit 1 began the inspection period at 86.5 percent power due to multiple failed extraction steam bellows in the condenser. On October 1, 2013, Unit 1 shut down to Mode 3, to effect repair of the extraction steam bellows. On October 18, 2013, Unit 1 reached 100 percent power. On December 27, 2013, Unit 1 reduced power to 99.6 percent due to the discovery that the ultrasonic feedwater flow meter was not within calibration. Unit 1 operated at 99.6 percent power for the remainder of the period.
Unit 2 began the inspection period at 100 percent power. On November 17, 2013, Unit 2 entered Mode 3 to begin Refueling Outage 2RE16. On December 26, 2013, Unit 2 reached 99.6 percent power. Due to the discovery that the ultrasonic feedwater flow meter was not within calibration, Unit 2 was restricted to 99.6 percent power. On December 29, 2013, Unit 2 reduced power to 29 percent in order to re-torque reactor coolant system loop drains inside containment to reduce leakage into the secondary containment sump. On the same day, Unit 2 returned to 99.6 percent power and operated at this power level for the remainder of the period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
On December 30, 2013, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for extreme cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that prior to extreme cold weather; the licensee had corrected weather-related equipment deficiencies identified during the previous winter season.
The inspectors selected two risk-significant systems that were required to be protected from cold weather:
Auxiliary feedwater Electrical auxiliary building The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by extreme cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the adverse weather protection features.
These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
On November 22, 2013, the inspectors completed an inspection of the stations readiness for impending severe thunderstorm conditions. The inspectors reviewed plant design features, the licensees severe weather plan procedures, and the licensees planned implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. The inspectors conducted site walk-down near the main transformers as well as a walk-down of the main switchyard in response to forecasted severe thunderstorms.
These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
November 21, 2013, Unit 2, electrical supplies for containment equipment hatch closure with reactor coolant system inventory at flange level November 26, 2013, Unit 2, standby diesel generators 21 and 22 while the train C, 4160 kV bus was out of service for planned maintenance December 2, 2013, Unit 2, spent fuel pool A and B cooling pumps while all reactor fuel was located in the spent fuel pool and an electrical power temporary modification was in place for the B spent fuel pool cooling pump The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems and trains were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On December 5, 2013, the inspectors performed a complete system walk-down inspection of the train C residual heat removal system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.
These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
November 13, 2013, Unit 2, relay cabinet area, Fire Zone Z032 November 14, 2013, Unit 2, train B engineered safety feature switchgear room, Fire Zone 042 November 17 and November 20, 2013, Unit 2, reactor containment building, Fire Area 63 December 30, 2013, Unit 2, standby diesel generator 22 building, Fire Zones 501, 504, 507, 510, 513 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors
evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
.2 Annual Inspection
a. Inspection Scope
On December 30, 2013, the inspectors completed their annual evaluation of the licensees fire brigade performance. This evaluation included observation of an unannounced fire drill for training on November 8, 2013.
During this drill, the inspectors evaluated the capability of the fire brigade members, the leadership ability of the brigade leader, the brigades use of turnout gear and fire-fighting equipment, and the effectiveness of the fire brigades team operation. The inspectors also reviewed whether the licensees fire brigade met NRC requirements for training, dedicated size and membership, and equipment.
These activities constituted one annual inspection sample, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On December 30, 2013, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:
Unit 2, standby diesel generator 22 building The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals; drains; and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.
These activities constitute completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R08 Inservice Inspection Activities
Completion of Sections
.1 through .5, below, constitutes completion of one sample as
defined in Inspection Procedure 71111.08-05.
.1 Inspection Activities Other Than Steam Generator Tube Inspection, Pressurized Water
Reactor Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control (71111.08-02.01)
a. Inspection Scope
The inspectors observed or reviewed six nondestructive examination activities that included four types of examinations. The inspectors reviewed one examination with relevant indications that had been accepted by licensee personnel for continued service.
The inspectors directly observed and reviewed records of the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Component Component Supports, RR/CC-2109-HL5003 Visual Examination Cooling (VT-3)
Pressurizer Pressurizer support Skirt, PRZ-2-SK Ultrasonic Main Steam Pipe to Weld Cap, 16-MS-2002-GA2 Weld 2 Ultrasonic Main Feed Pipe Lugs, 1PL5-1PL6 Magnetic Particle During the review and observation of each examination, the inspectors verified that activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also verified the qualifications of all nondestructive examination technicians performing the inspections were current.
The inspectors also reviewed records for the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Bottom-Mounted Istrument penetrations 1-58 Visual Examination Vessel (VE)
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Chemical Centrifugal Charging Pump 2B discharge Liquid Penetrant Volume and bypass check valves, FW0076 and FW0077 Control The inspectors observed three welds and reviewed two welds on pressure retaining risk significant systems.
The inspectors directly observed a portion of the following welding activities:
SYSTEM WELD IDENTIFICATION WELD TYPE Reactor RC-0001B body to bonnet seal weld Gas Tungsten Arc Cooling Welding Chemical CV-0004 body to bonnet seal weld Gas Tungsten Arc Volume and Welding Control Chemical CV-0005 body to bonnet seal weld Gas Tungsten Arc Volume and Welding Control The inspectors reviewed records for the following welding activities:
SYSTEM WELD IDENTIFICATION WELD TYPE Chemical Centrifugal Charging Pump 2B Discharge Gas Tungsten Arc Volume and Bypass Check Valve weld numbers FW 0076, Welding Control FW 0077 The inspectors verified that the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX, requirements. The inspectors also verified that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications. Specific documents reviewed during this inspection are listed in the attachment.
These actions constitute completion of the requirements for Section 02.01.
b. Findings
No findings were identified.
.2 Reactor Vessel Upper Head Penetration Inspection Activities (71111.08-02.02)
a. Inspection Scope
There were no inspections of the Unit 2 reactor vessel upper head during Refueling Outage 2RE16. The next visual inspection is scheduled for Unit 2 Refueling Outage 2RE17 in the fall of 2015. The next volumetric inspection is scheduled for Unit 2 Refueling Outage 2RE20.
b. Findings
No findings were identified.
.3 Boric Acid Corrosion Control Inspection Activities (71111.08-02.03)
a. Inspection Scope
The inspectors evaluated the implementation of the licensees boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 6. The inspectors verified that the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and that engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors confirmed that corrective actions taken were consistent with the ASME Code and 10 CFR Part 50, Appendix B, requirements. Specific documents reviewed during this inspection are listed in the attachment.
These actions constitute completion of the requirements for Section 02.03.
b. Findings
No findings were identified.
.4 Steam Generator Tube Inspection Activities (71111.08-02.04)
a. Inspection Scope
The inspectors reviewed the steam generator tube eddy current test examination scope and expansion criteria, and verified that it met technical specification requirements; EPRI guidelines; and commitments made to the NRC. The inspectors also verified that the eddy current test inspection scope included areas of degradations that were known to represent potential eddy current test challenges such as the top of tube sheet, tube support plates, and U-bends. The inspectors confirmed that no repairs were required at the time of the inspection. The scope of the licensees eddy current test examinations included:
One hundred percent full length bobbin testing of the outer peripheral tubes from tube end to tube end Fifty percent full length bobbin testing of all tubes not inspected full length during Unit 2 Refueling Outage 2RE13 Twenty percent plus point inspection of the upper tube support plate hot leg to upper tube support plate cold leg of rows 1 and 2 Plus point inspection of outer three tubes of periphery and divider lane time-temperature sensitization plus 6 inches/minus 3 inches to aid in loose parts detection, including hot leg and cold leg Twenty percent sample plus point inspection of tube sheet hot leg plus 6 inches/minus 3 inches Twenty percent sample plus point inspection of tube sheethot leg plus 6 inches/minus16 inches in tubes with bulges and over expansions Special interest plus point inspection of all previously identified dents and dings greater than five volts Special interest plus point of all prior and Unit 2 Refueling Outage 2RE16 I-code and non-quantifiable indications as determined by bobbin inspection or any previously reported signal that has changed Special interest plus point inspection of previously identified possible loose parts from eddy current inspections Special interest plus point of all loose parts identified by previous secondary side inspections and not removed Special interest plus point of a minimum of two tube locations surrounding any newly identified possible loose part or foreign object identified during Unit 2 Refueling Outage 2RE16 Special interest plus point of all manufacturing burnish mark indications in the U-bend region that are adjacent and at the same elevation as another manufacturing burnish mark indication The inspectors observed portions of the eddy current testing being performed and verified that:
- (1) the appropriate probes were used for identifying the expected types of degradation,
- (2) calibration requirements were adhered, and
- (3) probe travel speed was in accordance with procedural requirements. The inspectors performed a review of the site-specific qualifications for the techniques being used, and verified that eddy current test data analyses were adequately performed per EPRI and site specific guidelines.
Secondary sludge lancing and foreign object search and retrieval inspections were performed in all steam generators. Foreign materials were sized, categorized, and removal attempted. Eddy current testing was performed at the tube sheet for all foreign objects. Foreign objects unable to be retrieved were evaluated analytically based on size and eddy current data.
Finally, the inspectors reviewed selected eddy current test data, and verified that the analytical techniques used were adequate.
These actions constitute completion of the requirements for Section 02.04.
b. Findings
No findings were identified.
.5 Identification and Resolution of Problems (71111.08-02.05)
a. Inspection Scope
The inspectors reviewed 21 condition reports associated with inservice inspection activities and determined that the corrective actions taken were appropriate. The inspectors concluded that the licensee has an appropriate threshold for entering inservice inspection issues into the corrective action program, and has procedures that direct a root cause evaluation when necessary. The licensee also has an effective program for applying inservice inspection industry operating experience. Specific documents reviewed during this inspection are listed in the attachment.
These actions constitute completion of the requirements of Section 02.05.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On October 22, 2013, the inspectors observed simulator training for an operating crew.
The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.
These activities constitute completion of one quarterly licensed-operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to infrequently performed evolutions. The inspectors observed the operators performance of the following activities:
October 1, 2013, Unit 1, reactor shutdown to repair damaged extraction steam bellows in the main condenser October 5, 2013, Unit 1, reactor coolant system cooldown; pressurizer cooldown; and solid plant operations October 15, 2013, Unit 1, reactor startup after a planned outage to repair damaged extraction steam bellows in the main condenser November 16, 2013, Unit 2, reactor shutdown to begin Unit 2 Refueling Outage 2RE16 In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations shift operating practices and other operations department policies.
These activities constitute completion of four quarterly licensed-operator performance samples, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.3 Biennial Review
The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination.
a. Inspection Scope
To assess the performance effectiveness of the licensed operator requalification program, the inspectors reviewed both the operating tests and written examinations and observed ongoing operating test activities.
The inspectors reviewed operator performance on the written examinations and operating tests. These reviews included observations of portions of the operating tests by the inspectors. The operating tests observed included eight job performance measures and two scenarios that were used in the current biennial requalification cycle.
These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content. The inspectors also reviewed medical records of 13 licensed operators for conformance to license conditions and the licensees system for tracking qualifications and records of license reactivation for three operators.
The results of these examinations were reviewed to determine the effectiveness of the licensees appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.
The inspectors interviewed members of the training department and reviewed minutes of training review group meetings to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from both plant and industry events. Examination results were also assessed to determine if they were consistent with the guidance contained in NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process. All operators who failed a portion of the requalification examination were remediated and successfully passed a retake examination before returning to watchstanding duties.
In addition to the above, the inspectors reviewed examination security measures, simulator fidelity, and existing logs of simulator deficiencies.
The inspectors completed one inspection sample of the biennial licensed operator requalification program.
b. Findings
.1 Failure to Include Appropriate Acceptance Criteria in a Quality Procedure
Introduction.
The inspectors identified a Green non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, the licensee did not include sufficient criteria to identify and evaluate new critical tasks created by operator performance during the simulator scenario portion of the biennial requalification examination to enable the evaluators to correctly assess licensed operator performance.
Description.
As part of the inspection, the inspectors reviewed a remediation plan for a crew that was evaluated as having passed the annual operating test, but with performance problems that required remediation. In the course of the review, the inspectors identified a deficiency in the licensees requalification program associated with the identification of new critical tasks created as a result of errors in operator performance during the scenario. Specifically, Procedure LOR-GL-0002, Licensed
Operator Requalification Annual and Biennial Evaluation Guidelines, Revision 16, steps 4.5.1.1 and 4.5.1.2 discussed evaluating the status of all critical tasks and determining whether valid critical tasks were completed successfully. However, the guidance neither discussed how to determine if a critical task was valid nor provided any guidance for identifying a new critical task. In addition to the planned critical tasks developed in the scenario, an operator may, through inappropriate actions that challenged plant safety, create the basis for another critical task. By not having any criteria in the evaluation guidance, the evaluation may not make a valid pass/fail determination.
In requalification, the failure of a critical task during a scenario can result in an overall failure of the scenario portion of the operating test. If the evaluator does not have the guidance necessary to identify a new critical task, this could lead to the evaluator passing rather than failing an operator. If an operator fails the scenario portion of an operating test, he/she must be remediated and properly retested by retaking the entire scenario portion again, which is two scenarios. However, an operator who passes, but the facility decides to remediate is not required to pass two new scenarios. Therefore, by not having the appropriate guidance in the procedure, it could result in an incorrect pass/fail decision, and the operator might not be properly remediated and retested prior to returning to licensed duties. The licensee has entered this issue into their corrective action program as Condition Report 2013-13857.
Analysis.
The failure to include appropriate qualitative acceptance criteria in Procedure LOR-GL-002, to ensure evaluators correctly identify and evaluate critical tasks based on operator performance was a performance deficiency. In accordance with Manual Chapter 0612, Power Reactor Inspection Reports, the performance deficiency was more than minor, therefore, a finding because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern.
Specifically, the failure to include the appropriate criteria to identify and evaluate critical tasks during biennial requalification examinations could result in operators returning to licensed operator duties without being properly remediated and retested on performance deficiencies. The inspectors performed a significance determination using Manual Chapter 0609, because the finding affected the Initiating Events Cornerstone.
0609.04, Initial Characterization of Findings, evaluates the finding using Appendix I, Operator Requalification Human Performance Significance Determination Process. Starting at block 9 of Appendix I, the finding was determined to be of very low safety significance (Green) because the finding is associated with licensee administration of an annual requalification operating test. The finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to make safety-significant or risk-significant decisions using a systematic process H.1(a).
Enforcement.
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, the licensee failed to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, prior to November 25, 2013, the licensee did not include sufficient criteria in
Procedure LOR-GL-002, LOR Annual and Biennial Evaluation Guidelines, Revision 16, to identify and evaluate new critical tasks created by operator performance during the simulator scenario portion of the examination. Therefore, evaluators may have incorrectly assessed, remediated, and retested operator performance. Because this finding was of very low safety significance and was entered into the corrective action program as Condition Report 2013-13857, it is being treated as a non-cited violation in accordance with Section 2.3.2.a of the NRC Enforcement Policy:
NCV 05000498/2013-01, 05000499/2013-01, Failure to Include Appropriate Acceptance Criteria in a Quality Procedure.
.2 Flawed Job Performance Measures
Introduction.
The inspectors identified a finding of very low safety significance for developing and administering an excessive number of flawed job performance measures during the 2012 and 2013 NRC annual operating tests that resulted in invalidating several operators NRC annual operating tests.
Description.
In addition to the onsite observation of one set of job performance measures being administered in 2013, the inspectors performed a 100 percent review of all the job performance measures administered during both annual operating tests of the biennial cycle. The inspectors used NRC Inspection Procedure 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance, Appendix C, Annual Requalification Operating Test Quality, during the review.
For the 2012 and 2013 annual operating tests, the inspectors reviewed 104 job performance measures and determined 32 (17 and 15 in 2012 and 2013, respectively)had flaws that would make the job performance measure unsatisfactory for administration during an NRC operating test. The major flaws are outlined as follows:
The job performance measure was annotated as alternate path, however, the alternate path step(s):
o had no verifiable actions because the step(s):
involved informing the shift manager, chemistry, etc.
involved waiting for a specific amount of time and repeating the previous step o were expected to be performed as indicated in the initial conditions given to the examinee The entire job performance measure had no verifiable actions. For example, during one job performance measure observed onsite, the examinee simply noted and reported meter readings to another operator.
The job performance measure had only one verifiable action
The job performance measure had a low level of difficulty because the task would be expected to be passed by 100 percent of the operators The licensee performed an evaluation using the 15 flawed job performance measures given in 2013 to determine the effect on the licensed operator population. The licensee retested those operators that, based on the evaluation, failed two or more job performance measures in 2013. This action was completed prior to the end of the biennial cycle.
The licensee also performed an evaluation using the 17 flawed job performance measures given in 2012 to determine the effect on the licensed operator population.
Those results were then compared to operational errors attributable to human performance in order to find any statistical increase in errors that could be attributed to taking a flawed annual operating test in 2012. The percentage of the total number of errors that were performed by those licensed operators that were determined to have been given an unsatisfactory annual operating test in 2012 was equal to their percentage of the total licensed operator population. Therefore, there was no increase in errors due to taking the flawed 2012 annual operating test.
Analysis.
Using Inspection Procedure 71111.11, Appendix C, Annual Requalification Operating Test Quality, more than 20 percent of the annual operating test job performance measures developed in 2012 and 2013 were flawed; therefore, this was a performance deficiency. In accordance with Manual Chapter 0612, Power Reactor Inspection Reports, the performance deficiency was more than minor, therefore, a finding because it affected the Initiating Events Cornerstone attribute of Human Performance, and adversely affected the Cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors performed a significance determination using Manual Chapter 0609, because the finding affected the Initiating Events Cornerstone. Attachment 0609.04, Initial Characterization of Findings, evaluates the finding using Appendix I, Operator Requalification Human Performance Significance Determination Process. Starting at block 6 of Appendix I, the finding was determined to be of very low safety significance (Green) because: the finding involved operating test quality; less than 40 percent of the job performance measures were flawed; and less than 40 percent of the simulator scenarios were flawed. In addition, the NRC determined the finding had a human performance cross-cutting aspect associated with decision making because the licensee did not use conservative assumptions in decision making when developing simplistic and/or flawed job performance measures that invalidated several operators annual operating tests H.1(b).
Enforcement.
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee entered this finding into their corrective action program as Condition Report 2013-10673. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000498/2013005-02, 05000499/2013005-02, Flawed Job Performance Measures.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):
December 28, 2013, standby diesel generators, unavailability December 28, 2013, essential cooling water, unavailability The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constitute completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
October 1, 2013, Unit 1, Shutdown Risk Assessment Report for planned outage 1P1302 to repair extraction steam bellows November 15, 2013, Unit 2, Shutdown Risk Assessment Report for Refueling Outage 2RE16 The inspectors verified that these risk assessments were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:
November 20, 2013, Unit 2, Shutdown Risk Assessment Report for swapping train B and train C work windows in refueling outage 2RE16 December 23, 2013, Unit 2, for blocking open main feedwater control valve FCV-2D to troubleshoot the failure of the valve to operate in automatic December 29, 2013, Unit 2, reactor down power reduction to 29 percent to re-torque reactor coolant system loop drain valves The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.
These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed seven operability determinations and functionality assessments that the licensee performed for degraded or nonconforming SSCs:
October 23, 2013, operability determination of standby diesel generator 23 due to decreasing level in the fuel oil storage tanks of approximately 500 gallons over a 3-day period October 27, 2013, operability determination of Unit 1, train C essential chilled water system after loss of expansion tank level indication November 7, 2013, operability determination of Unit 1, train D auxiliary feedwater pump following the discovery of valve MS-0517 flow orifice bypass to the main condenser steam supply line open instead of in the closed position November 14, 2013, operability determination of Unit 2, loop 2D pressurizer spray valve PCV-0655B following the discovery of a body-to-bonnet leak of approximately 70 drops per minute November 18, 2013, operability determination of Unit 1 essential cooling water system sump due to leakage from the essential cooling water sump pump December 2, 2013, functionality assessment of Unit 2 spent fuel cooling pump 2A following the NRC discovery of an outboard seal leak
December 6, 2013, operability determination of Unit 2, train C component cooling water following a failure of valve CC-MOV-0393 to close on a low level surge tank level The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.
These activities constitute completion of seven operability and functionality review samples, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed two temporary plant modifications that affected risk-significant SSCs:
Week of November 4, 2013, Unit 1, temporary spent fuel pool gantry crane December 6, 2013, Unit 2, spent fuel pool cooling pump 2B temporary electrical power The inspectors verified that the licensee had installed and removed these temporary modifications in accordance with technically adequate design documents. The inspectors verified that these modifications did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modifications to verify the licensee maintained configuration control.
These activities constitute completion of two samples of temporary modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
On October 11, 2013, the inspectors reviewed a permanent modification to Unit 2 essential chiller 22 pressure and temperature data recorder.
The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.
These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed seven post-maintenance testing activities that affected risk-significant SSCs:
October 3, 2013, Unit 2, standby diesel generator 22 following repair of essential cooling water piping connection leak October 15, 2013, Unit 1, pressurizer level transmitter LT-0467 lower root valve replacement October 27, 2013, Unit 1, train C essential chiller expansion tank relief valve November 3, 2013, Unit 2, standby diesel generator 22 following replacement of failed relays for voltage and frequency local indication November 23, 2013, Unit 2, train B residual heat removal pump seal rebuild December 13, 2013, Unit 1, drag test of newly installed spent fuel storage racks December 23, 2013, Unit 2, control card replacement to repair automatic function of main feedwater flow control valve FCV-0554 The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests
in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of seven post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors evaluated the licensees outage activities for refueling outage 2RE16, which concluded on December 22, 2013, and Unit 1 planned outage 1P1302 which concluded October 16, 2013. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
Review of the licensees outage plan prior to the outage Monitoring of shut-down and cool-down activities Verification that the licensee maintained defense-in-depth during outage activities Observation and review of reduced-inventory and mid-loop activities Observation and review of fuel handling activities Monitoring of heat-up and startup activities These activities constitute completion of one refueling outage sample and one outage activities sample, as defined in Inspection Procedure 71111.20.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components (SSCs) were capable of performing their safety functions:
In-service tests:
December 10, 2013, Unit 2, residual heat removal valve interlock test during Unit 2 Refueling Outage
Containment isolation valve surveillance tests:
October 2, 2013, Unit 1, local leakage rate test of penetration M-44, containment isolation valves HC-0005 and FV-9777 December 5, 2013, Unit 2, local leak rate test of penetration M-18, containment isolation valves 2-SI-0005A and 2-SI-MOV-0004A December 5, 2013, Unit 2, local leak rate test of penetration M-19, containment isolation valves 2-SI-0030A and 2-SI-MOV-0018A Reactor coolant system leak detection tests:
December 8, 2013, Unit 1, alternate reactor coolant inventory calculation Other surveillance tests:
December 19, 2013, Unit 2, operability of trisodium phosphate storage baskets The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)
a. Inspection Scope
The Nuclear Security and Incident Response headquarters staff performed an in-office review of the latest revisions of various emergency plan implementing procedures and the Emergency Plan located under ADAMS Accession Numbers ML13309A761 and ML13339A340 as listed in the attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the plan, and that the revised plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of two samples as defined in Inspection Procedure 71114.04-05.
Findings No findings were identified.
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on November 6, 2013, to verify the adequacy and capability of the licensees assessment of drill performance.
The inspectors reviewed the drill scenario, observed the drill from the simulator and the emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates; airborne radioactivity; and surface contamination levels
Instructions and notices to workers, including labeling or marking containers of radioactive material; radiation work permits; actions for electronic dosimeter alarms; and changes to radiological conditions Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance; instrument sensitivity; release criteria; procedural guidance; and sealed source accountability Radiological hazards control and work coverage, including the adequacy of surveys; radiation protection job coverage and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne radioactivity monitoring; controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures ALARA. During the inspection, the inspectors interviewed licensee personnel and reviewed the licensee performance in the following areas:
Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average; site-specific trends in collective exposures; and source-term measurements ALARA work activity evaluations/post-job reviews, exposure estimates, and exposure mitigation requirements The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies
Records detailing the historical trends and current status of tracked plant source terms, and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of the one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors verified that the licensee controlled in-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:
The licensees use, when applicable, of ventilation systems as part of its engineering controls The licensees respiratory protection program for use, storage, maintenance, and quality assurance of National Institute for Occupational Safety and Health certified equipment, qualification and training of personnel, and user performance The licensees capability for refilling and transporting self-contained breathing apparatus air bottles to and from the control room and operations support center during emergency conditions, status of self-contained breathing apparatus staged and ready for use in the plant and associated surveillance records, and personnel qualification and training Audits, self-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection These activities constitute completion of one sample of in-plant airborne radioactivity control and mitigation as defined in Inspection Procedure 71124.03.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Mitigating System Performance Index: Emergency AC Power Systems (MS06), High
Pressure Injection Systems (MS07), Heat Removal Systems (MS08), Residual Heat Removal Systems (MS09), and Cooling Water Systems (MS10)
Inspection Scope The inspectors reviewed the licensees mitigating system performance index data for the period of March 2012, through September 2013, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for emergency ac power systems, high pressure injection systems, heat removal systems, residual heat removal systems, and cooling water systems for Units 1 and 2, as defined in Inspection Procedure 71151 (5 samples).
b. Findings
No findings were identified.
.2 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2012, to September 30, 2013. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual
(ODCM) Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between October 1, 2012, and September 30, 2013, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.
These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified. However, the inspectors did note the following negative trends: an increasing number of configuration control issues, inconsistent use of in-hand procedures during control room activities, inconsistent use of peer-checking human performance tools in the control room, the site has not consistently been initiating condition reports at a low threshold, and an increasing number of performance issues during emergency preparedness performance indicator drills and exercises. The licensee is aware of these issues and these issues have been entered into the corrective action program.
.3 Annual Follow-up of Selected Issues
a. Inspection Scope
The inspectors selected three issues for an in-depth follow-up:
On July 24, 2013, Condition Report 2013-8586 was written to address the South Texas Project culture of not initiating condition reports for low level issues for trending and resolution, which has in some cases allowed a gradual deviation from standards that have the potential to adversely affect the plant. This issue was identified by a combination of station personnel, INPO, and the resident inspectors.
On July 20, 2013, Condition Report 2013-8413 was written to correct a series of Unit 2 control rod urgent failure alarms that occurred during turbine governor valve testing. The control rods were able to perform their safety function, but presented operator and station challenges.
On October 22, 2013, Condition Report 2013-12296 was written to address a declining trend in emergency preparedness drill performance.
The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions appear to be adequate to correct the condition.
These activities constitute completion of three annual follow-up samples, as defined in Inspection Procedure 71152.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The inspectors briefed Mr. D. Rencurrel, Senior Vice President, Operations, and other members of the licensee's staff of the results of the licensed operator requalification program inspection on September 12, 2013, and telephonically exited with Mr. G.
Powell, Site Vice President, and other staff members on December 12, 2013. The licensee representatives acknowledged the findings presented. All proprietary information was returned to the licensee.
On December 6, 2013, the inspectors presented the inspection results of the review of inservice inspection activities to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On December 6, 2013, the inspectors presented the radiation safety inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On January 9, 2014, the inspectors presented the inspection results to Mr. G. Powell, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Aguilar, Senior Technician, Health Physics
- R. Aguilera, Manager, Health Physics
- L. Archer, Consulting Causal Analysis Engineer, Health Physics
- M. Berg, Manager, Design Engineering
- C. Bowman, General Manager, Engineering
- W. Brost, Engineer, Licensing
- S. Dubey, Engineer, Steam Generators
- R. Dunn Jr., Manager, Nuclear Fuel and Analysis
- T. Frawley, Manager, Strategic Business Projects
- J. Hartley, Manager, Mechanical Maintenance
- M. Hayes, General Supervisor, Radiation Protection
- J. Heil, Engineer, Boric Acid Corrosion Control
- G. Hildebrandt, Manager, Operations
- T. Hurley, Operations Training Supervisor
- G. Janak, Manager, Unit 1 Operations
- C. Kinman, Supervisor, Radiation Protection
- J. Lovejoy, Manager, I&C Maintenance
- M. Meier, Vice President, Corporate Services
- M. Merritt, Engineer, Welding
- J. Mertink, Nuclear Training Manager
- B. Migl, Manager, Maintenance Engineering (Acting)
- J. Milliff, Manager, Unit 2 Operations
- M. Murray, Manager, Regulatory Affairs
- J. Page, Licensed Operator Requalification Supervisor
- J. Paul, Supervisor, Licensing
- L. Peter, Plant General Manager
- J. Pierce, Operations Training Manager
- G. Powell, Site Vice President
- F. Puleo, Engineer, Licensing
- C. Reddix, Manager, Security
- D. Rencurrel, Senior Vice President, Operations
- G. Rodriguez, Senior Technician, Radiation Protection
- M. Ruvalcaba, Manager, Testing and Programs
- R. Savage, Engineer, Licensing Staff Specialist
- M. Schaefer, Manager, Nuclear Oversight
- S. Shojaei, Engineer, Repair and Replacement
- L. Spiess, Engineer, Inservice Inspection
- R. Stastny, Maintenance Manager
- J. Stauber, Engineer, Inservice Inspection
- K. Taplett, Supervisor, Licensing
Attachment 1
- T. Walker, Manager, Quality Assurance
- K. Wallis, Manager, Systems Engineering
- C. Younger, Supervisor, Engineering Programs
- D. Zink, Supervising Engineering Specialist
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000498/2013005-01 Failure to Include Appropriate Acceptance Criteria in a Quality NCV
- 05000499/2013005-01 Procedure