IR 05000498/2011008

NRC Temporary Instruction 2515/183 Inspection Report 05000498/2011008 and 05000499/2011008

ML11133A128
Person / Time
Site:	South Texas
Issue date:	05/13/2011
From:	Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A
To:	Halpin E Southern Nuclear Operating Co
References
IR-11-008
Download: ML11133A128 (22)

Text

UNIT ED STAT ES NU C LE AR RE G UL AT O RY C O M M I S S I O N May 13, 2011

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000498/2011008 AND 05000499/2011008

Dear Mr. Halpin:

On April 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station facility, Units 1 and 2, using Temporary Instruction 2515/183, Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

The enclosed inspection report documents the inspection results, which were discussed on April 26, 2011, with Mr. C. Bowman, General Manager, Nuclear Safety Assurance, and other members of your staff.

The objective of this inspection was to assess the adequacy of actions taken at South Texas Project Electric Generating Station facility, Units 1 and 2, in response to the Fukushima Daiichi Nuclear Station fuel damage event. The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the United States nuclear industrys readiness to respond to a similar event.

These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

STP Nuclear Operating Company -2-

Sincerely,

/RA/ By David L. Proulx Wayne Walker, Chief Project Branch A Division of Reactor Projects Dockets: 50-498 50-499 Licenses: NPF-76 NPF-80

Enclosure:

NRC Inspection Report 05000498/2011008 AND 05000499/2011008 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2011008 and 05000499/2011008 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM521 - 8 miles West of Wadsworth Wadsworth, Texas 77483 Dates: March 23, 2011 through April 26, 2011 Inspectors: J. Dixon, Senior Resident Inspector B. Tharakan, CHP, Resident Inspector Approved By: Wayne Walker, Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000498/2011008 and 05000499/2011008, 03/23/2011 - 04/26/2011; South Texas Project

Electric Generating Station, Units 1 and 2, Temporary Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event This report covers an announced temporary instruction inspection. The inspection was conducted by Resident inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the temporary instruction is to be a high-level look at the industrys preparedness for events that may exceed the design basis for a plant. The focus of the temporary instruction was on

(1) assessing the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats;

(2) assessing the licensees capability to mitigate station blackout conditions;

(3) assessing the licensees capability to mitigate internal and external flooding events required by station design; and

(4) assessing the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

The following table documents the NRC inspection at South Texas Project Electric Generating Station, Units 1 and 2, facility, performed in accordance with Temporary Instruction 2515/183.

The numbering system in the table corresponds to the inspection items in the temporary instruction.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh).

Use Inspection Procedure 71111.05T, Fire Protection (Triennial), Section 02.03 and 03.03 as a guideline. If Inspection Procedure 71111.05T was recently performed at the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or inspection The licensee tested active equipment, and walked down and inspected passive equipment.

that equipment is available and The licensee performed these activities in accordance with existing station procedures and functional. Active equipment preventive maintenance work orders. Some items were verified to be complete, if shall be tested and passive performed within the last month, through a review of completion paperwork; activities not equipment shall be walked accomplished within the last month were re-performed.

down and inspected. It is not expected that permanently installed equipment that is Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, tested under an existing reviewed test results, discussed actions, reviewed records, etc.).

regulatory testing program be retested.

The inspectors reviewed the test results and observed some tests (normal fire water This review should be done for pumps). The inspectors independently walked down the passive equipment and verified a reasonable sample of that the contents of the licensees emergency lockers were in accordance with station mitigating strategies/equipment.

procedures. The inspectors discussed with plant and licensed operators how the active and passive equipment is tested, maintained, and stored, and training is conducted on its use. Additionally, the inspectors walked down several of the procedures with a plant operator to ensure familiarity with the operation of the equipment, storage locations of portable equipment, and locations of permanently installed equipment.

Discuss general results including corrective actions by licensee.

The licensee determined that, with minor exceptions, equipment to mitigate beyond design basis events was available and functional. Condition reports were written to document that some of the passive equipment checklists did not include all of the required items. The licensee does not have a routine maintenance activity to measure portable fire pump flow.

The portable fire pump was flow tested as part of initial purchase. However, the pump has since been overhauled due to damage during a dewatering activity in the turbine building.

The licensee performed a flow verification test on April 21, 2011; the results were satisfactory.

Describe the licensees actions to verify that procedures are in place and can be executed Licensee Action (e.g. walkdowns, demonstrations, tests, etc.).

b. Verify through walkdowns or The licensee determined that procedures to mitigate beyond design basis events were in demonstration that procedures place and executable. The licensees procedures to implement strategies associated with to implement the strategies B.5.b and 10 CFR 50.54(hh) are verified during refresher training on a periodic basis. The associated with B.5.b and licensee is currently in the process of performing this refresher training. The licensee 10 CFR 50.54(hh) are in place performed walkdowns of some procedures. For some of the procedures, the licensee and are executable. Licensees staged the equipment to ensure that the procedures could be followed correctly. In the may choose not to connect or case of equipment that is also used for other activities, the licensee has verified through operate permanently installed those other activities that the systems work and operators are familiar with how to operate equipment during this the equipment.

verification.

This review should be done for Describe inspector actions and the sample strategies reviewed. Assess whether a reasonable sample of procedures were in place and could be used as intended.

mitigating strategies/equipment.

The inspectors reviewed all the severe accident procedures and guidelines to ensure that the appropriate equipment, training, and staging were in place and those actions could be accomplished in accordance with the established timelines. The inspectors determined that the licensees procedures were in place, effective, had been recently trained on, and could be implemented as intended. The inspectors walked down several strategies with plant operators to ensure that the operators knew where the equipment was located, how to

operate the equipment, and the ease of use of the equipment.

Discuss general results including corrective actions by licensee.

The licensees procedures were effective in ensuring that the desired action could be accomplished. The procedures were logically organized, clearly written, and could be accomplished by the most junior plant operator. Several key pieces of equipment are pre-staged, and several are designed to function without continuous operator coverage. The licensee wrote condition reports to ensure that hard copies of the latest revisions of the procedures were in the required locations. Even though the licensee does not have a specific test to ensure the discharge flow from the portable fire pump, they use it sufficiently for other activities that there is a high confidence that it will provide the required amount of flow. The licensee is in the process of obtaining the equipment and developing a procedure to test the discharge flow of the pump. The licensee performed a flow verification test on April 21, 2011; the results were satisfactory.

Describe the licensees actions and conclusions regarding training and qualifications of Licensee Action operators and support staff.

c. Verify the training and Plant operators receive initial training on these severe accident procedures through qualifications of operators and walkdowns with qualified operators, which is required prior to initial watch standing.

the support staff needed to Continuing training for plant operators, accomplished in accordance with the plant operator implement the procedures and requalification 4-year plan, includes classroom and walkthroughs. Licensed operators work instructions are current for receive initial training on these severe accident procedures along with all emergency activities related to Security operating and off normal operating procedures as part of initial licensed operator Order Section B.5.b and severe qualification. Continuing training for licensed operators is accomplished in accordance with accident management the licensed operator requalification 2-year plan and emergency planning continuation guidelines as required by training. The emergency response organization training requirements are proceduralized in 10 CFR 50.54 (hh).

the emergency preparedness-training program and personnel on the emergency response roster must complete training/requalification every three years. Security has an annual requirement to read and discuss in security officer requalification and in all initial security officer training, the actions required to implement the severe accident procedures.

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.

The inspectors reviewed the training records of all plant and licensed operators and of all emergency response roster personnel to ensure that they were still within their training window. The inspectors walked down and discussed several strategies with plant and licensed operators to ensure that the operators knew where the equipment was located, how to operate the equipment, the ease of use of the equipment, and could complete the procedures as written.

Discuss general results including corrective actions by licensee.

The licensees procedures were effective in ensuring that the desired action could be accomplished. The procedures were logically organized, clearly written, and could be accomplished by the most junior plant operator.

Describe the licensees actions and conclusions regarding applicable agreements and Licensee Action contracts are in place.

d. Verify that any applicable The licensee reviewed their Letters of Agreement with state and local entities, required by agreements and contracts are in NUREG 0654, Emergency Support and Resources, to verify their adequacy and currency.

place and are capable of Annually, in accordance with the licensees emergency response procedures, the licensee meeting the conditions needed reviews the Letters of Agreement for each offsite organization and ensure that all letters are to mitigate the consequences of current or are updated as necessary. This review was recently accomplished in November these events.

2010.

This review should be done for a reasonable sample of For a sample of mitigating strategies involving contracts or agreements with offsite entities, mitigating strategies/equipment. describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current).

The inspectors reviewed the licensees procedures for requiring the Letters of Agreement to be maintained current. Additionally, the inspectors reviewed a sample of Letters of Agreement to verify that they were current.

Discuss general results including corrective actions by licensee.

The licensee had difficulty contacting two agencies to update the Letters of Agreement.

They have since made contact and signed new Letters of Agreement.

Document the corrective action report number and briefly summarize problems noted by Licensee Action the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open corrective The licensee is capturing all items associated with the Fukushima event in Condition action documents to assess Report 11-4827. The licensee identified the following discrepancies: old revisions of problems with mitigating procedures in the fields, incomplete inventory checklists, excess items in emergency strategy implementation lockers, not periodically flow testing the portable fire pump, not periodically testing some identified by the licensee.

removable maintenance panels, and other miscellaneous items. None of the identified Assess the impact of the gaps or deficiencies would be expected to impact the success of any severe accident problem on the mitigating action.

capability and the remaining capability that is not impacted.

03.02 Assess the licensees capability to mitigate station blackout conditions, as required by 10 CFR 50.63, Loss of All Alternating Current Power, and station design is functional and valid. Refer to Temporary Instruction 2515/120, Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22, as a guideline. It is not intended that Temporary Instruction 2515/120 be completely re-inspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Describe the licensees actions to verify the adequacy of equipment needed to mitigate a Licensee Action station blackout event.

a. Verify through walkdowns and The licensee reviewed 10 CFR 50.63, Regulatory Guide 1.155, NUMARC 87-00, its inspection that all required Updated Final Safety Analysis Report, and the NRCs Safety Evaluation Report in response materials are adequate and to the Updated Final Safety Analysis Report to ensure the basis for actions for a station properly staged, tested, and blackout. Because the licensee is credited as an alternate ac source plant, any one of the maintained.

three engineered safety features standby diesel generators is fully capable of providing power to one complete train of engineered safety features equipment during and after a station blackout event. Therefore, the licensee does not need special equipment or tools to mitigate station blackout conditions. The licensee verified through surveillance test review

and condition report searching that all standby diesel generators were operable. In addition, the licensee verified that all required equipment contained in the emergency lockers was present.

Describe inspector actions to verify equipment is available and useable.

The inspectors reviewed the licensees Updated Final Safety Analysis Report to understand the implementation and required equipment for station blackout and alternate ac source plant criteria. The inspectors walked down each standby diesel generator looking for deficiencies that might call into question the operability of the diesel. The inspectors reviewed the most recent surveillance test data for each diesel generator and the emergency locker inventory checklist. Additionally, the inspectors searched through the corrective action program database for items that could impact the operability of the standby diesel generators.

Discuss general results including corrective actions by licensee.

No operability concerns were identified during the inspectors walkdown of the standby diesel generators. The inspectors identified some additional items that had been stored in the emergency lockers that should not have been; however, the quantity was small and did not impact the accessibility of the emergency items. The licensee has captured this in a condition report and is removing the excess items.

Licensee Action Describe the licensees actions to verify the capability to mitigate a station blackout event.

b. Demonstrate through The licensee recently completed a combined function drill during which the Loss of All AC walkdowns that procedures for Power, Procedure 0POP05-E0-EC00 was executed. The licensee also walked down the response to a station blackout procedure to ensure that all sections of the procedure could be completed in the event are executable.

where all sections had not been reviewed/performed during the combined function drill.

Finally, the licensee verified that the operations simulator training incorporated training scenarios that included various losses of all ac power situations. The most recent training scenario for loss of all ac was conducted from September to October 2010.

Describe inspector actions to assess whether procedures were in place and could be used as intended.

The inspectors verified the licensing basis to ensure that the facility is an alternate ac source plant. The inspectors verified that the licensees surveillance procedures were up to date, could be performed, and had been accomplished within the last month on all standby diesel generators. The inspectors verified that the operators had been trained periodically as required. Additionally, the inspectors observed the combined function drill and verified that the licensee was capable of completing the procedure as written.

Discuss general results including corrective actions by licensee.

The licensee has an open unresolved item from the 2010 Component Design Basis Inspection dealing with whether STP uses a 4-hour coping strategy or is an alternate ac source plant. The current wording to the Updated Final Safety Analysis Report includes both phrases. As a result, the Component Design Basis Inspection team could not determine which criterion to follow. The licensee captured this issue in a condition report and has revised the Updated Final Safety Analysis Report to remove the coping strategy and only list the alternate ac source plant criterion.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design. Refer to Inspection Procedure 71111.01, Adverse Weather Protection, Section 02.04, Evaluate Readiness to Cope with External Flooding, as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged.

These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Describe the licensees actions to verify the capability to mitigate existing design basis Licensee Action flooding events.

a. Verify through walkdowns and The licensee determined that, with some exceptions, equipment and materials required to inspection that all required mitigate internal and external flooding was adequate, staged, tested and maintained. The materials are adequate and licensee reviewed the design calculations for external and internal flooding, reviewed properly staged, tested, and instrumentation, sump pump capabilities, and alarms used for detection of flooding to maintained.

ensure they were functional. The licensee walked down flood seals and penetrations to ensure they were properly sealed and in good material condition. The licensee generated the population of seals and penetrations to inspect by reviewing civil (construction and architectural), and as built drawings.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors performed independent walkdowns of exterior and interior flood seals and penetrations. The inspectors observed material conditions of instrumentation and pumps used to detect and mitigate flooding. The inspectors reviewed logs to identify emergent issues with flooding mitigation equipment or barriers. The inspectors reviewed the Updated Final Safety Analysis Report, external and internal flooding design calculations, and flood seal and penetration design drawings. The inspectors observed the licensee perform walkdowns of exterior and interior flood seals and penetrations. The inspectors reviewed records of the licensees preventive maintenance program to ensure installed flood mitigation equipment was properly maintained. The inspectors reviewed the corrective

action program to ensure the licensee had taken corrective action on issues that were identified during the walkdowns and reviews.

Discuss general results including corrective actions by licensee.

Results indicate that the licensee has adequately implemented controls to prevent flooding of systems, structures, and components necessary for safely shutting down the reactors, maintaining core cooling, and removing decay heat. The walkdowns identified minor material conditions, which have been entered into the corrective action program for repair, including degraded seals on access shafts, coatings and seals on flood panels, and chipped grout and concrete around pipe support plates. None of these conditions would have prevented the barriers from functioning resulting in flooding the area, with the exception of a cluster of penetrations in the Unit 1 and 2 mechanical auxiliary building that had one unsealed 2-inch cable penetration below the flood line. The licensee determined that if the design flood of the main cooling reservoir breach were to occur, then water would have entered into the buildings. The licensee determined that the 2-inch diameter penetration would not result in enough water to flood or cause damage to any safety related equipment.

This vulnerability was entered into the corrective action program and the penetration was sealed shortly after discovery. The licensee is evaluating implementing additional preventive maintenance work orders to inspect seals, doors, and penetrations that are not already inspected as part of work orders.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it into the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use Inspection Procedure 71111.21, Component Design Basis Inspection, Appendix 3, Component Walkdown Considerations, as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Describe the licensees actions to assess the potential impact of seismic events on the Licensee Action availability of equipment used in fire and flooding mitigation strategies.

Verify through walkdowns that all The licensee identified equipment that would be used for mitigation of fire and flooding required materials are adequate events. The licensee determined whether this equipment was seismically qualified or if it and properly staged, tested, and could be evaluated as seismically rugged. All of the fire suppression systems were walked maintained.

down by a qualified fire protection engineer, all of the fire protection program procedures were reviewed for any potential impacts/vulnerabilities, and all portable firefighting equipment was examined for any potential impacts. All flood mitigating equipment was walked down to the extent allowable, and all flooding procedures were reviewed for any potential impacts/vulnerabilities. The licensee also reviewed the Letters of Agreement with State and local entities that specifically dealt with providing support functions needed to mitigate an event and contacted each entity by phone to ensure the agreement was still in effect and to confirm that support would be provided. The licensee also performed an aggregate review of all the vulnerabilities identified to determine if any cumulative effects presented additional vulnerabilities.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the Updated Final Safety Analysis Report to determine the maximum flood level for the site and the required equipment to combat fires and floods.

The inspectors reviewed the licensees fire protection program and flooding mitigation procedures, including natural and destructive phenomena procedures. The inspectors independently walked down the licensees equipment to ensure it was available and usable and to ensure that the procedures could be accomplished as written. These walk downs included contingency response equipment, all external watertight doors, the walls of all external buildings for signs of degradation, the fire protection system diesel pumps, and the fire main header. The inspectors also observed the licensee perform flow testing on the portable fire pump and daily monitoring of the main cooling reservoir.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee because of their reviews.

The licensee determined that all the fire protection systems were designed and installed in accordance with the National Fire Protection Association Codes. Consequently, none of the fire protection systems are seismically qualified. The licensee is considering mitigating strategies to address this vulnerability and has entered the concern into the corrective action program. The following items were noted to be stored in a non-seismic building: portable fire pump, aqueous film forming foam, fire brigade van, portable fire fighting monitor, and the fire brigade assembly area. The licensee is considering mitigating strategies to address these vulnerabilities, and has entered the concern into the corrective action program.

Additionally, the licensee had not performed periodic flow measurement testing of the portable fire pump; it is currently tested unloaded. The licensee has captured this issue in its corrective action program, has purchased equipment to allow flow testing, and is generating preventive maintenance procedures for periodic testing of the portable fire pump in a loaded condition (flow measurement). The licensee performed a flow verification test on April 21, 2011; the results were satisfactory. The licensee is developing strategies to inspect the seals and penetrations that were determined to be inaccessible and to inspect the floor drain system for the safety-related structures; currently, there is no active preventive maintenance plan that verifies the function of the check valves in the system.

Both of these items have been entered into the corrective action program.

EXIT MEETING SUMMARY The inspectors presented the inspection results to Mr. C. Bowman, General Manager, Nuclear Safety Assurance, and other members of licensee management at the conclusion of the inspection on April 26, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Berg, Manager, Design Engineering

C. Bowman, General Manager, Nuclear Safety Assurance

J. Calvert, Manager, Training

R. Dunn Jr., Manager, Fuels and Analysis

R. Engen, Site Engineering Director

T. Frawley, Manager, Operations

R. Gangluff, Manager, Knowledge Transfer

E. Halpin, President and Chief Executive Officer

W. Harrison, Manager, Licensing

G. Hildebrant, Manager, Plant Protection

G. Janak, Manager, Operations Division, Unit 1

B. Jenewein, Manager, Systems Engineering

W. Jump, Senior Manager, Safety Review Team

R. McNiel, Manager, Maintenance Engineering

J. Milliff, Manager, Operations Division, Unit 2

M. Murray, Manager, Safety Review Team

J. Paul, Engineer, Licensing Consultant

L. Peter, Plant General Manager

J. Phelps, Manager, Safety Review Team

J. Pierce, Manager, Operations Training

G. Powell, Vice President, Technical Support and Oversight

M. Reddix, Manager, Security

D. Rencurrel, Senior Vice President, Units 1 and 2

M. Ruvalcaba, Manager, Testing and Programs

R. Savage, Engineer, Licensing Staff Specialist

M Svetlik, Rapid Response Team

R. Westmoreland, Rapid Response Team

D. Wiegand, Engineer, Fire Protection