Text

IR 05000498-12-007 and 05000499-12-007; September 17, 2012 - October 4, 2012; South Texas Project Electric Generating Station, Units 1 and 2, Biennial Baseline Inspection of the Identification and Resolution of Problems; and Notice of Viola
	ML12325A789
Person / Time
Site:	South Texas
Issue date:	11/20/2012
From:	Ray Kellar; Division of Reactor Safety IV
To:	Koehl D; South Texas
References
	EA-12-227 IR-12-007
	Download: ML12325A789 (34)
	v • d • e

UNITE D S TATE S

NUC LEAR RE GULATOR Y C OMMI S SI ON

R E G IO N I V

1600 EAST LAMAR BLVD

AR L I NGTON , TEXAS 7 601 1- 4511

November 20, 2012

EA-12-227

ML12325A789

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

PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT

05000498/2012007 AND 05000499/2012007 AND NOTICE OF VIOLATION

Dear Mr. Koehl:

On October 4, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem

Identification and Resolution biennial inspection at your South Texas Project Electric Generating

Station, Units 1 and 2, facility. The enclosed inspection report documents the inspection results,

which the inspection team discussed on October 4, 2012, with Mr. G. Powell, Vice President,

Generation, Units 1 and 2, and other members of your staff. The lead inspector discussed an

update to these results on October 31, 2012, with Mr. M. Murray, Manager Regulatory Affairs.

This inspection was an examination of activities conducted under your license as they relate to

problem identification and resolution and to compliance with the Commissions rules and

regulations and the conditions of your license. Within these areas, the inspection involved

examination of selected procedures and representative records, observations of activities, and

interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the

corrective action program and the overall performance related to identifying, evaluating, and

resolving problems at South Texas Project was effective. Your staff generally identified

problems and entered them into the corrective action program at a low threshold, though the

team noted some exceptions that are described in the attached report. The team noted some

weaknesses in your prioritization and evaluation processes, but in most cases your staff

effectively prioritized and evaluated commensurate with their safety significance, resulting in the

identification of appropriate corrective actions for most problems. Your staff generally

implemented these actions in a timely manner, commensurate with the safety significance of the

problems. Most corrective actions addressed the causes of identified problems. The station

generally reviewed and applied lessons learned from industry operating experience. The

stations audits and self-assessments effectively identified problems and appropriate corrective

actions, though in some cases these actions were delayed or deferred. Finally, the team

determined that your stations management maintains a safety-conscious work environment

where employees feel free to raise nuclear safety concerns without fear of retaliation.

D. Koehl -2-

The NRC identified one violation during this inspection. The associated performance deficiency,

which the NRC evaluated under the risk significance determination process as having very low

safety significance (Green), did not meet the criteria to be treated as a non-cited violation. The

violation associated with this issue was evaluated in accordance with the NRC Enforcement

Policy. The current version of this Policy is available on the NRC website at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. This violation is cited in

the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in

detail in the subject inspection report. The violation is being cited in the Notice in accordance

with Section 2.3.2 of the Enforcement Policy because after the violation was previously

identified as a non-cited violation, you failed to restore compliance within a reasonable time.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

Additionally, a licensee-identified violation that was determined to be of very low safety

significance is listed in this report. The NRC is treating this violation as a non-cited violation

(NCV), consistent with Section 2.3.2 of the Enforcement Policy.

If you contest either of these violations, you should provide a response within 30 days of the

date of this inspection report, with the basis for your denial, to the Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the

Regional Administrator, Region IV; the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at

South Texas Project.

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

South Texas Project.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRC's Agencywide Document 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). To the extent possible, your response should not include any

personal privacy or proprietary information so that it can be made available to the Public without

redaction.

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief

Technical Support Branch

Division of Reactor Safety

D. Koehl -3-

Docket No.: 50-498, 50-499

License No.: NPF-76, NPF-80

Enclosures:

1. Notice of Violation

2. Inspection Report 05000498/2012007 and

05000499/2012007

w/ Attachments

Electronic Distribution to South Texas Project

D. Koehl -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Art.Howell@nrc.gov)

DRP Director (Kriss.Kennedy@nrc.gov)

Acting DRP Deputy Director (Barry.Westreich@nrc.gov)

Acting DRS Director (Tom.Blount@nrc.gov)

Acting DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (John.Dixon@nrc.gov)

Resident Inspector (Binesh.Tharakan@nrc.gov)

Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (David.Proulx@nrc.gov)

Project Engineer, DRP/A (Jason.Dykert@nrc.gov)

STP Administrative Assistant (Lynn.Wright@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Senior Technical Analyst, DRS/TSB (Dale.Powers@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

Senior Enforcement Specialist (Rachel.Browder@nrc.gov)

Enforcement Specialist (Christi.Maier@nrc.gov)

Senior Reactor Inspector, DRS/TSB (Eric.Ruesch@nrc.gov)

OEMail Resource

ROPreports

RIV/ETA: OEDO (Cayetano.Santos@nrc.gov)

R:\REACTORS\STP\STP 2012007 PI&R-EAR ADAMS ML 12325A789

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials EAR

Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials

DRP/PBA DRS/EB2 DRP/PBA C:DRS/TSB C:DRP/PBA ORA/ACES RIV/DRS/TSB

MOHayes SRAchen BKTharakan RLKellar WCWalker RSBrowder EARuesch

/RA-E/ /RA-E/ /RA-E/ /RA/ /RA/ /RA/ /RA/

11/9/12 11/9/12 11/9/12 11/20/12 11/13/12 11/14/12 11/14/12

OFFICIAL RECORD COPY

NOTICE OF VIOLATION

STP Nuclear Operating Company Docket No: 50-498, 50-499

South Texas Project Nuclear Generating Station, Units 1 and 2 License No: NPF-76, NPF-80

EA-12-227

During an NRC inspection conducted from September 17 through October 4, 2012, a violation

of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the

violation is listed below:

License Condition 2.E requires, in part, that the licensee implement and maintain in

effect all provisions of the approved fire protection program as described in the Final

Safety Analysis Report through Amendment 55 and the Fire Hazards Analysis Report

through Amendment 7 and as approved in the Safety Evaluation Report (NUREG-0781)

dated April 1986 and its supplements. Section 9.5.1 of the Final Safety Analysis Report

states the Operations Quality Assurance Plan ensures that regulatory requirements and

commitments concerning fire protection are satisfied during plant operations. The

Operations Quality Assurance Plan further states that procedures shall provide

administrative controls that include taking actions to assure timely corrective action on

conditions adverse to quality.

Contrary to the above, from May 18, 2006 to October 4, 2012, the licensee failed to

implement and maintain in effect all provisions of the approved fire protection program.

The licensee failed to implement timely corrective actions to correct conditions adverse

to the fire protection provisions of its Operations Quality Assurance Plan in order to

ensure that regulatory requirements and commitments concerning fire protection were

satisfied during plant operations. Specifically, the licensee did not meet the license

basis requirement to be able to shut down the plant by taking a single operator action in

the control room and it failed to assure timely corrective action was taken following

identification of this condition on May 18, 2006. The licensee entered this deficiency into

its corrective action program as CR 12-27648.

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, STP Nuclear Operating Company is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at South Texas

Project Electric Generating Station, Units 1 and 2, within 30 days of the date of the letter

transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to

Notice of Violation EA-12-227," and should include: (1) the reason for the violation, or, if

contested, the basis for disputing the violation or severity level, (2) the corrective steps that

have been taken and the results achieved, (3) the corrective steps that will be taken to avoid

further violations, and (4) the date when full compliance will be achieved. Your response may

reference or include previous docketed correspondence, if the correspondence adequately

addresses the required response. If an adequate reply is not received within the time specified

in this Notice, an order or a Demand for Information may be issued as to why the license should

not be modified, suspended, or revoked, or why such other action as may be proper should not

be taken. Where good cause is shown, consideration will be given to extending the response

-1- Enclosure 1

time. If you contest this enforcement action, you should also provide a copy of your response,

with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC website at www.nrc.gov/reading-rm/pdr.html or www.nrc.gov/reading-rm/adams.html, to

the extent possible, it should not include any personal privacy, proprietary, or safeguards

information so that it can be made available to the public without redaction. If personal privacy

or proprietary information is necessary to provide an acceptable response, then please provide

a bracketed copy of your response that identifies the information that should be protected and a

redacted copy of your response that deletes such information. If you request withholding of

such material, you must specifically identify the portions of your response that you seek to have

withheld and provide in detail the basis for your claim of withholding (e.g., explain why the

disclosure of information will create an unwarranted invasion of personal privacy or provide the

information required by 10 CFR 2.390(b) to support a request for withholding confidential

commercial or financial information).

Dated this 20th day of November, 2012.

-2-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-498, 50-499

License: NPF-76, NPF-80

Report: 05000498/2012007 and 05000499/2012007

Licensee: STP Nuclear Operating Company

Facility: South Texas Project Electric Generating Station, Units 1 and 2

Location: FM 521 - 8 miles west of Wadsworth

Wadsworth, Texas 77483

Dates: September 17 through October 4, 2012

Team Leader: E. Ruesch, Senior Reactor Inspector

Inspectors: S. Achen, Reactor Inspector

M. Hayes, Resident Inspector

B. Tharakan, Resident Inspector

Approved By: R.L. Kellar, P.E., Chief

Technical Support Branch

Division of Reactor Safety

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000498/2012008 and 05000499/2012008; September 17, 2012 - October 4, 2012; South

Texas Project Electric Generating Station, Units 1 and 2, Biennial Baseline Inspection of the

Identification and Resolution of Problems

The team inspection was performed by one senior reactor inspector, one reactor inspector, and

two resident inspectors. One violation of Green significance was identified during this

inspection. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter 0609, "Significance Determination Process". Findings

for which the significance determination process does not apply may be Green or be assigned a

severity level after NRC management review. The NRC's program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor

Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems

The team reviewed approximately 210 condition reports, including associated work orders,

engineering evaluations, root and apparent cause evaluations, and other supporting

documentation. The purpose of this review, focused on documentation of higher-significance

issues, was to determine if problems were being properly identified, characterized, and entered

into the corrective action program for evaluation and resolution. The team reviewed a sample of

system health reports, self-assessments, trending reports and metrics, and various other

documents related to the corrective action program. The team concluded that with limited

exceptions, the licensee maintained a corrective action program in which issues were generally

identified at an appropriately low threshold. Issues entered into the corrective action program

were appropriately evaluated and timely addressed, commensurate with their safety

significance. Corrective actions were generally effective, addressing the causes and extents of

condition of problems.

The licensee appropriately evaluated industry operating experience for relevance to the facility

and entered applicable items in the corrective action program. The licensee used industry

operating experience when performing root cause and apparent cause evaluations. The

licensee performed effective quality assurance audits and self-assessments, as demonstrated

by its self-identification of some needed improvements in corrective action program

performance and of ineffective corrective actions.

The licensee maintained a safety-conscious work environment in which personnel felt free to

raise nuclear safety concerns without fear of retaliation. All individuals interviewed by the team

were willing to raise these concerns by at least one of the several methods available.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green. The team identified a violation of License Condition 2.E for the failure to

correct a noncompliance. Procedure 0POP04-ZO-0001, Control Room Evacuation,

Revision 35, was not consistent with the post-fire safe shutdown analysis in that it

failed to ensure the actions met critical time requirements. The licensee failed to

implement timely corrective actions to correct this deficiency. Inspection

Report 05000498/2011006 and 05000499/2011006 documented a violation involving

-2-

the failure to implement and maintain in effect all provisions of the approved fire

protection program. During this inspection, the team identified that the licensee had

failed to restore compliance with its license condition within a reasonable time.

The licensees failure to implement timely corrective actions to correct conditions

adverse to fire protection as required by its Operations Quality Assurance Plan is a

performance deficiency. This performance deficiency was of more than minor safety

significance because it was associated with the mitigating systems cornerstone and

adversely affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events (such as fire) to prevent

undesirable consequences. Specifically, the licensee failed to ensure reliability of its

post-fire safe shutdown systems by demonstrating that it could achieve safe

shutdown following a fire in the control room by using approved actions. The

significance of this finding could not be evaluated using Inspection Manual

Chapter 0609, Appendix F, Fire Protection Significance Determination Process,

because the performance deficiency involved a control room fire that led to control

room evacuation. A senior reactor analyst determined that the upper bound for the

overall change in core damage frequency that resulted from this performance

deficiency was 2.702E-7/yr and was not significant with respect to large early release

frequency. The analyst therefore determined that this performance deficiency was of

very low risk significance (Green). The team determined that the performance

deficiency had a cross-cutting aspect in the corrective action component of the

problem identification and resolution cross-cutting area because the licensee did not

thoroughly evaluate the problem such that resolutions addressed the cause.

Specifically, the licensee failed to take adequate corrective actions to ensure that

operators could perform all necessary manual actions as approved prior to

exceeding the regulatory requirements (P.1(c)). (Section 4OA2.5)

B. Licensee-Identified Violations

A violation of very low safety significance that had been identified by the licensee was

reviewed by the team during this inspection. Corrective actions taken or planned by the

licensee were entered into the licensees corrective action program. This violation and the

associated corrective action tracking numbers are listed in Section 4OA7 of this report.

-3-

REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The team based the following conclusions on a sample of corrective action documents

that were open during the assessment period, which ranged from September 16, 2010,

to the end of the on-site portion of this inspection on October 4, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 210 condition reports (CRs), including associated root

cause, apparent cause, and direct cause evaluations, from approximately 28,000 that

had been initiated between September 16, 2010, and October 5, 2012. This review,

which focused on higher-tier CRs, was to determine if problems were being properly

identified, characterized, and entered into the corrective action program for evaluation

and resolution. The team reviewed a sample of system health reports, operability

determinations, self-assessments, trending reports and metrics, and various other

documents related to the corrective action program. The team evaluated the licensees

efforts in establishing the scope of problems by reviewing selected logs, work orders,

self-assessment results, audits, system health reports, action plans, and results from

surveillance tests and preventive maintenance tasks. The team reviewed daily CRs, and

attended the licensees weekly Condition Review Group meetings to assess the

reporting threshold, prioritization efforts, and significance determination process, and to

observe the interfaces with the operability assessment and work control processes when

applicable. The teams review included verification that the licensee considered the full

extent of cause and extent of condition for problems, as well as a review of how the

licensee assessed generic implications and previous occurrences. The team assessed

the timeliness and effectiveness of corrective actions, completed or planned, and looked

for additional examples of similar problems. The team conducted interviews with plant

personnel to identify other processes that may exist where problems may be identified

and addressed outside the corrective action program.

The team reviewed corrective action documents that addressed past NRC-identified

violations to ensure that corrective actions addressed the issues described in the

inspection reports. The team reviewed a sample of corrective actions closed to other

corrective action documents to ensure that corrective actions remained appropriate and

timely.

The team considered risk insights from both the NRCs and South Texas Projects risk

assessments to focus the sample selection and plant tours on risk-significant systems

and components. The team focused its sample on emergency core cooling systems,

emergency diesel generators, and the Class-1E 4160V electrical distribution system,

which the team selected for a five-year in-depth review. The samples reviewed by the

team focused on but were not limited to these systems. The team conducted walk-

downs of these systems to assess whether the licensee identified problems and entered

them into the corrective action program.

-4-

b. Assessments

1. Effectiveness of Problem Identification

The team concluded that in most cases, the licensee identified issues and adverse

conditions in accordance with its corrective action program procedures and with NRC

requirements. The team determined that the licensee generally identified these

problems at a low threshold and entered them into the corrective action program.

However, the team found several examples of deficiencies and received several

comments during interviews that indicated a reluctance of some plant personnel to

use the corrective action program to evaluate and resolve problems that they

perceived as minor.

During the 25-month inspection period, licensee staff generated approximately

28,000 condition reports. The licensees CR generation rate of approximately 15,000

per year had been relatively constant over the previous four years. The team

identified that most conditions that required generation of a CR by 0PGP03-ZX-0002,

Condition Reporting Process, and CAP-0001, CR Classification Guide, were

being appropriately entered into the corrective action program. However, the team

noted several exceptions:

During the focus groups interviews conducted by the team to evaluate the

licensees safety conscious work environment (SCWE), several personnel

stated that they did not write CRs for potential personnel-safety issues. This

observation is further discussed in section 4OA2.4.b of this report.

To identify adverse trends in lower-level conditions, the licensee relied on CRs

that were automatically generated by the condition reporting system when the

number of CRs containing the same trend codes passed a preset threshold.

However, the team identified several instances of CRs identifying similar

conditions but tagged with different trend codes. The team determined that this

could lead to evolving trends of low-level events not being timely identified.

Ten of the twelve QA audits reviewed by the team identified misclassification of

CRs. However, CR misclassification was not identified by the licensee as a

condition requiring evaluation until the licensees CAP assessment, which was

conducted in preparation for this inspection. This is further discussed in

sections 4OA2.3 and 4OA7 of this report.

The team identified transient combustible material in the Unit 1 and Unit 2

component cooling water heat exchanger rooms that exceeded the limits

specified in 0PGP03-ZF-0019, Control of Transient Fire Loads and Use of

Combustibles and Flammable Liquids and Gases, Revision 9, and was not

being controlled by a transient combustible permit. Further, the team identified

that rubber hoses, which were permanently stored in the component cooling

water heat exchanger rooms, had not been approved for permanent storage in

Addendum 4 of 0PGP03-ZF-0019. The additional combustible material

adversely impacted the fire loading calculation for the CCW heat exchanger

room. However, because the impact on the available margin was minimal, this

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failure to comply with fire loading procedures is a minor performance deficiency

that is not subject to enforcement action in accordance with the NRCs

Enforcement Policy. The licensee documented this deficiency

in CRs 12-27640 and 12-27641.

On August 14, 2011, extended range nuclear instrument 46A (NI-46A) drifted

low, indicating 34 percent power while Unit 1 was actually at 100 percent

power. The licensee documented the failure in CR 11-13155, declared NI-46A

inoperable, and performed troubleshooting and repairs. During the repair

activity the AT1 isolator card failed. The licensee replaced the failed card, but

did not initiate a new condition report as required by 0PGP03-ZX-0002,

Condition Reporting Process, Revision 43. The team determined that the

failure to initiate a condition report as required by procedure was a minor

performance deficiency that was not subject to enforcement action in

accordance with NRCs Enforcement Policy. The licensee wrote Condition

Report 12-27667 to address this minor violation.

The team noted that CAP-0001, CR Classification Guideline, Revision 4,

directed that personnel initiate a new condition report to document an

improperly classified CR. Licensee personnel explained to the team that this

requirement only applied after the initial CR screening was complete; prior to

the initial CR classification being finalized, the classification could be changed

with no CR initiated to document the change. However, the licensee had no

clear guidance describing at what point the CR screening process was

complete and the initial CR classification was finalized.

The team concluded that despite these exceptions, the licensee maintained a low

threshold for the formal identification of problems and entry into the corrective action

problem for evaluation. With the exception of some industrial safety issues noted

above and in section 4OA2.4 of this report, the team noted that most problems were

adequately addressed through the licensees corrective action program.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

The team concluded that once the licensee entered issues into its corrective action

program, most issues were appropriately evaluated and prioritized. The licensee

screened approximately one third of the 28,000 CRs generated during the inspection

period as conditions adverse to quality (CAQs) or significant conditions adverse to

quality (SCAQs). The balance were evaluated to be conditions not adverse to quality

(CNAQs), the lowest-significance tier in the licensees condition reporting system.

Except as discussed below, the team determined that the screening of these

conditions was performed in accordance with the licensees procedures. While the

team noted some issues with the timeliness of corrective actions, particularly for the

fire protection manual actions issue discussed below, actions were generally

completed by their due dates; due date extensions were generally reasonable and

were not overused. However, the team noted some weaknesses in the licensees

evaluation of some identified adverse conditions and, as also noted above, in its

implementation of its program to identify trends:

The licensee lacks a uniform process for screening condition reports.

Procedurally, individual CAP Supervisors determine the significance of each

-6-

identified condition. There is no required review or second check of the

screening results. The team determined that this had resulted in inconsistent

screening of issues. The licensee documented these observations

in CR 12-27600.

o CAP Supervisors must be qualified through a formal training program, but

this program has no requirements for continued proficiency. Further,

despite multiple revisions to the licensees CAP and its screening criteria,

the licensee had performed no formally documented refresher training for

CAP Supervisors since 2008.

o In some cases, CAP Supervisors CR screening was supplemented with

workgroup screening meetings. These screening meetings were not

proceduralizedsome workgroups held these meetings; some did not.

Among the workgroups that held them, the conduct and attendance of the

meetings varied. The team noted that in some cases, ad hoc processes

used by individual workgroups enhanced the CR screening performed by

that workgroup. But because these processes were not covered by

procedures and thus varied group-by-group, they did not improve

consistency of screening site-wide.

o The licensees process allows a condition report to be initiated, classified,

screened, and then closed by one individual. In one quality assurance

audit, the licensee had identified a case where three condition reports had

been initiated and screened by the same individual. All had been

misclassified. The licensee documented the NRCs observation of this

deficiency in CR 12-26700.

o For lower-level conditions adverse to quality (CAQ-Ds), the licensee relies

on two methods to identify potential adverse trends. The team identified

that the licensees inconsistent screening process may adversely affect

each of these methods. The first method is based on the number of CRs

having the same trend code reach a predetermined threshold. When this

threshold is crossed, the system automatically generates a CR. The

licensee then evaluates the CR to determine if an adverse trend exists.

However, the large number of available trend codes available to CAP

Supervisors had, in at least one case identified by the team, resulted in

multiple similar conditions being assigned different trend codes. The

team noted that this could result in the licensees failure to identify an

emerging adverse trend due to a decrease in the number of CRs

assigned a particular code. The licensee also identifies trends using

qualitative criteriasupervisors or managers identifying that certain

conditions had recurred. However, the team noted that adverse trends

may be missed by this method as well because different individuals may

review CRs identifying similar issues.

In ten of the twelve quality assurance audits reviewed by the team, the licensee

had identified CRs that had been incorrectly classified at a lower significance

than required by procedure. These misclassified CRs accounted for

approximately 2% of the CRs reviewed by the auditors. The licensees self-

assessment of its problem identification and resolution processes identified that

-7-

approximately 2.7% of the CRs initiated over the previous two-year period had

been initially classified incorrectly by the CAP Supervisor. This issue is

documented in section 4OA7 as a licensee-identified violation of an NRC

requirement.

During the in-depth review of Class 1E electrical systems, the team noted that

the licensee generally identified issues important to safety and took corrective

actions to address the issues in a timely manner commensurate with safety.

Although conditions affecting Class 1E equipment were generally identified and

corrected in a timely manner, inspectors noted that the licensee did not timely

implement corrective actions for other deficiencies associated with some other

systems. One example is further discussed in section 4OA2.5.

Additionally, during another inspection conducted during the inspection period, the

NRC documented one finding that was evaluated to have a P.1(c) cross-cutting

aspect. This assigned cross-cutting aspect indicated a potential deficiency in the

licensees prioritization and evaluation of problems:

NCV 2011002-03 documented a self-revealing finding for the licensees failure

to assure that corrective actions were timely implemented. On June 2, 2008,

steam generator power operated relief valve 1A failed to stroke fully closed

during surveillance testing. The licensees operability determination concluded

that the steam generator power operated relief valves were operable but

nonconforming. On August 25, 2010, steam generator power operated relief

valve 1D again failed to stroke closed as part of surveillance testing. This new

prompt operability determined that the previous operability determination had

been flawed. The inspector determined that this finding had a P.1(c) cross-

cutting aspect because the licensee had not thoroughly evaluated the problem

such that the resolution addressed the cause, and had not properly evaluated

the condition for operability.

Overall, the team determined that the licensee had an adequate process for

screening and prioritizing issues that had been entered into the corrective action

program, though the process was not uniform across the site.

3. Assessment - Effectiveness of Corrective Actions

Overall, the team concluded that the licensee implemented effective corrective

actions for problems identified and evaluated in the corrective action program. The

team reviewed nine corrective action effectiveness reviews for significant conditions

adverse to quality (SCAQs) and determined that the licensee had implemented

effective corrective actions for the conditions. However, the team noted several

instances where corrective actions had not been effective, had not been complete, or

had not been timely reviewed to ensure their effectiveness:

On November 23, 2010, the licensee inadvertently drained reactor coolant

system water to the normal containment sump during refueling operations

because a drain valve was left open during the evolution. The licensee

documented this condition in CR 10-25309 and performed a root cause

evaluation. One of the two root causes the licensee identified was that the

drain valve had not been properly aligned by a baseline valve lineup prior to the

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evolution. The licensee revised the baseline lineup to ensure the drain valve

was listed in the closed position. However, the licensee failed to evaluate the

extent of this cause to determine if other similar drain valves were correctly

listed as closed in other baseline lineups. After the team discussed this

concern with the licensee, the licensee assessed whether the extent of cause

should have been evaluated. The licensee determined that, because the drain

valve was on a temporary manifold that is only connected to the reactor coolant

system during cold shutdown and refueling modes, the extent of cause was not

applicable to baseline lineups of permanently installed piping.

On March 27, 2012, the licensee initiated CR 12-13333, documenting the

failure of Unit 1 extended range nuclear instrument 45A to pass its surveillance

requirements. The licensee determined that this was a significant condition

adverse to quality, performed a root cause evaluation, and identified corrective

actions to prevent recurrence as required by 0PGP03-ZX-0002B, Root Cause

Investigations, Revision 0. However, the licensee failed to identify

compensatory actions pending completion of the corrective actions to prevent

recurrence as also required by 0PGP03-ZX-0002B. During the week of

October 1, 2012, the licensee satisfactorily completed the corrective actions to

prevent recurrence by implementing preventative maintenance procedures that

tested all of the extended range nuclear instruments; all tested satisfactorily.

The team determined the failure to identify compensatory actions as required

by procedure was a minor performance deficiency that was not subject to

enforcement action in accordance with the NRCs Enforcement Policy. The

licensee initiated CR 12-27666 to address this minor violation. This issue is

further discussed in section 4OA3 of this report.

In a corrective action program audit completed on September 6, 2012, the

licensee identified that 37 effectiveness reviews for CAPRs were open, that the

actions to perform these reviews had been extended an average of five times,

and that there were two overdue actions, one of which was overdue by nine

months.

With the exception of the fire protection issue discussed in Section 4OA2.5, the team

noted that corrective actions to address the sample of NRC non-cited violations and

findings since the last problem identification and resolution inspection had been

timely and effective. Overall, the team concluded that the licensee generally

developed appropriate corrective actions to address identified problems.

The licensee generally implemented these corrective actions in a timely manner,

commensurate with their safety significance, and reviewed the effectiveness of the

corrective actions appropriately.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The team examined the licensees program for reviewing industry operating experience,

including reviewing the governing procedure and self-assessments. The team reviewed

a sample of industry operating experience communications to assess whether the

licensee had appropriately evaluated the communications for relevance to the facility.

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The team also reviewed assigned actions to determine whether they were appropriate.

The team reviewed a sample of root and apparent cause evaluations to ensure that the

licensee had appropriately included industry operating experience.

b. Assessment

Overall, the team determined that the licensee appropriately evaluated industry

operating experience for its relevance to the facility. Of the operating experience items

reviewed by the team, the licensee had entered all applicable items into the corrective

action program and had evaluated these items in accordance with station procedures.

During the 2010 problem identification and resolution inspection, documented in

inspection report 05000498/2010006 and 05000499/2010006 (ML103010543), the NRC

identified a programmatic concern with the licensees prioritization and classification of

operating experience reports. In CR 12-25361, the licensee documented changes it had

made to its operating experience program since the 2010 inspection. These changes

included a recent revision to 0PGP03-ZX-0013, Operating Experience Program, which

established an effective methodology for entering and tracking site and industry

operating experience into the corrective action program. The licensee incorporated the

same timeliness and management review requirements as those described in station

procedure 0PGP03-ZX-0002, Condition Reporting Process. The team reviewed these

changes and, based on its review, concluded that the licensee had effectively resolved

the programmatic concern.

The team further determined that the licensee appropriately evaluated industry operating

experience when performing root cause investigations and apparent cause evaluations.

The licensee appropriately incorporated both internal and external operating experience

into lessons-learned for training and pre-job briefs.

In addition, the team reviewed twelve NRC bulletins and information notices issued

during the inspection period and found that in all cases, the licensee wrote a condition

report and evaluated the applicability of the bulletin or information notice to their facility.

The team found the assessments were clearly documented and were appropriate for the

circumstances.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The team reviewed a sample of licensee self-assessments and audits to assess whether

the licensee was regularly identifying performance trends and effectively addressing

them. The team also reviewed audit reports to assess the effectiveness of assessments

in specific areas. The specific self-assessment documents and audits reviewed are listed

in Attachment 1.

b. Assessment

The team concluded that the licensee generally had an effective self-assessment

process. Attention was given to assigning team members with the proper skills and

experience to perform effective self-assessments and Audits and to include people from

outside organizations. Audits were self-critical, thorough, and identified new

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performance deficiencies in addition to evaluating known performance deficiencies

across key functional areas. The licensee generated CRs to document deficiencies and

improvement opportunities identified through audits. However, the team identified that

the corrective actions for findings from the audits and self-assessments were not always

successful. The team identified two weaknesses associated with trending of findings

from the audit process:

During reviews of audit reports, the team identified inconsistencies in the tracking

and trending of misclassified condition reports. In a majority of the audits

reviewed by inspectors, the licensee had identified examples of misclassified

condition reports over different functional areas. However, the licensee had not

identified the misclassification of condition reports as a trend. The licensee

documented this concern as CR 12-27789. This is further discussed in

section 4OA2.1.b.1 and 4OA7 of this report.

Similar to an observation discussed in section 4OA2.1.b.1, the team noted that

the licensee had no threshold defining what constituted a trend when Quality

Assurance identified similar findings in multiple audits of different functional

areas.

Overall, the team determined that the licensee had generally developed appropriate

corrective actions to address findings from audits and self-assessments, though these

were not always effectively implemented. Except for the trending of misclassified

condition reports, the licensee generally identified adverse performance trends through

self-assessments and audits; the licensee effectively addressed these trends.

The team noted that over the past several years, the licensee had performed and

documented multiple audits and formal and informal self-assessments that identified

programmatic problems with its corrective action program. However, the deficiencies

identified in these reports had not been effectively corrected. The team concluded that

the corrective actions identified in the most recent self-assessments, including the

licensees Organizational Effectiveness Improvement Plan of the Plan, dated July 23,

2012, and its Corrective Action Program (CAP) Improvement Review Team Report,

dated July 24, 2012, had identified corrective actions that, if fully implemented, would

likely remedy these programmatic issues.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The team interviewed forty-five individuals in six focus groups. The purpose of these

interviews was (1) to evaluate the willingness of licensee staff to raise nuclear safety

issues, either by initiating a condition report or by another method, (2) to evaluate the

perceived effectiveness of the corrective action program at resolving identified problems,

and (3) to evaluate the licensees safety-conscious work environment (SCWE). The

focus group participants were from the Operations, Maintenance, Engineering, Health

Physics, and Work Control groups. The individuals were selected blindly from these

work groups, based partially on availability. To supplement these focus group

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discussions, the team interviewed the Employee Concerns Program (ECP) manager to

assess his perception of the site employees willingness to raise nuclear safety

concerns. The team also reviewed selected ECP documents to assess the licensees

SCWE.

b. Assessment

1. Willingness to Raise Nuclear Safety Issues

The individuals interviewed indicated they had no hesitancy in raising nuclear safety

issues. Most feel that their management is receptive to nuclear safety concerns,

and is willing to address them. Most of the interviewees also stated that if they were

not satisfied with the response from their immediate supervisor, they would feel free

to escalate the concern. In most cases, interviewees had raised issues and

concerns to their supervisors and then followed the supervisors recommendation,

which often involved entering the issue into the corrective action program. Most

expressed positive experiences after raising issues to their supervisors or

documenting issues in condition reports, though some expressed concerns with

supervisors ability to modify, without consulting the condition report initiator, issues

that had been documented in the corrective action program.

Approximately 15 percent of the focus group participants felt that supervisors were

not receptive to some concerns involving personnel safety. These personnel

generally believed that while their supervision and management would address

nuclear safety concerns regardless of impact on production, potential problems with

personnel safety did not receive the same attention. Several of these personnel

stated that they no longer raised personnel safety concerns to their supervisors

because they felt that the concerns would not be addressed.

2. Employee Concerns Program

Most interviewees were aware of the Employee Concerns Program. Most explained

that they have heard about the program through various means, such as posters,

training, presentations, and discussion by supervisors or management at meetings.

Most did not have any personal experience with the ECP because, as noted above,

they felt free to raise safety concerns to their supervisors; they did not need to use

the ECP in these cases. However, everyone interviewed stated that they would use

the program if they felt it was necessary. None of the interviewed personnel had

heard of any issues dealing with breaches of confidentiality by the ECP staff.

3. Preventing or Mitigating Perceptions of Retaliation

When asked if there have been any instances where individuals experienced

retaliation or other negative reaction for raising issues, all individuals interviewed

stated that they had neither experienced nor heard of an instance of retaliation,

harassment, intimidation or discrimination at the site. The team determined that

processes in place to mitigate these issues were being successfully implemented.

.5 Finding

Failure to Timely Correct Conditions Adverse to Fire Protection

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Introduction. The team identified a violation of License Condition 2.E for the failure to

correct a noncompliance. Procedure 0POP04-ZO-0001, Control Room Evacuation,

Revision 35, was not consistent with the post-fire safe shutdown analysis in that it failed

to ensure the actions met critical time requirements. The licensee failed to implement

timely corrective actions to correct this deficiency. Inspection Report 05000498/2011006

and 05000499/2011006 (ML11223A193) documented a violation involving the failure to

implement and maintain in effect all provisions of the approved fire protection program.

During this inspection, the team identified that the licensee had failed to restore

compliance with its license condition within a reasonable period of time.

Description. In 2005, the NRC identified that South Texas Project was crediting

unapproved manual actions in its safe shutdown analysis for control room fires. Since

then, the NRC has issued two non-cited violations associated with this condition. The

team reviewed the licensees actions, completed and planned, to address these

violations.

BACKGROUND AND TIMELINE

On July 14, 2005, during a triennial fire protection inspection, NRC inspectors identified

an unresolved item (URI) associated with the licensees potential failure to maintain an

adequate written evaluation for a control room fire scenario (URI 05000498/2005006-03

and 05000499/2005006-03). Specifically, the licensee had credited the performance of

eight operator manual actions in the control room prior to evacuation; the licensee had

not obtained the required NRC approval for these manual actions.

On May 18, 2006, the NRC closed this URI, issuing a non-cited violation of the

licensees fire protection license condition. This violation was associated with the

licensees failure to demonstrate that the additional control room actions met applicable

requirements in its approved post-fire safe shutdown analysis (NCV 05000498/2006002-

05 and 05000499/2006002-05).

On February 4, 2008, shortly before the 2008 triennial fire protection inspection, the

licensee submitted a license amendment request to the NRC requesting approval to

credit the eight additional control room actions in the approved fire protection program.

On June 19, 2008, the NRC completed the on-site portion of its triennial inspection. Also

on June 19, 2008, the licensee withdrew its request.

On June 2, 2011, the licensee submitted a second license amendment request. In this

request, submitted shortly before the 2011 triennial fire protection inspection, the

licensee requested approval of revised steps in its procedure for combating a fire in the

control room. These revised steps included the additional operator actions.

On August 10, 2011, following the 2011 triennial fire protection inspection, the NRC

documented another non-cited violation of the licensees fire protection license condition.

This violation was associated with the licensees failure to implement timely corrective

actions to correct the performance deficiency identified in the 2006 non-cited violation

(NCV 05000498/2011006-01 and 05000499/2011006-01). The licensee documented

this deficiency in its corrective action program as CR 11-10905.

On July 31, 2012, the licensee withdrew its second license amendment request.

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REVIEW OF CORRECTIVE ACTIONS

In its review of the licensees corrective actions associated with the 2006 and 2011 non-

cited violations, the team identified that the licensee continued to credit the unapproved

manual actions. The licensee had implemented no additional compensatory measures

or otherwise restored compliance with its license condition since the NRC issued the

2011 non-cited violation. The team determined that because the licensee still had not

implemented timely corrective actions to correct the performance deficiency identified in

the 2006 non-cited violation, the violation documented in 2011 continued to exist; the

licensee had failed to restore compliance in a timely manner.

The licensee entered this deficiency into its corrective action program as CR 12-27648.

Analysis. The licensees failure to implement timely corrective actions to correct

conditions adverse to fire protection as required by its Operations Quality Assurance

Plan was a performance deficiency. This performance deficiency was of more than

minor safety significance because it was associated with the mitigating systems

cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events (such as fire) to

prevent undesirable consequences. Specifically, the licensee failed to ensure the

reliability of its post-fire safe shutdown systems by demonstrating that it could achieve

safe shutdown following a fire in the control room using approved actions.

The significance of this finding could not be evaluated using Inspection Manual

Chapter 0609, Appendix F, Fire Protection Significance Determination Process,

because the performance deficiency involved a potential control room fire leading to

control room evacuation. Following the NRCs initial identification of this violation in

2011, a senior reactor analyst performed a Phase 3 bounding evaluation. The analyst

determined that the upper bound for the overall change in core damage frequency that

resulted from this performance deficiency was 2.702x10-7/yr and was not significant with

respect to large early release frequency. The analyst therefore determined that this

performance deficiency was of very low risk significance (Green). Because the licensee

had made no changes to its facility or procedures that affected the assumptions of the

analysts evaluation, the bounding evaluation performed for that 2011 violation,

documented as NCV 05000498/2011006-01 and 05000499/2011006-01 (see

ML11223A193), remained valid.

The team determined that the performance deficiency had a cross-cutting aspect in the

corrective action component of the problem identification and resolution cross-cutting

area because the licensee did not thoroughly evaluate the problem such that resolutions

addressed the cause. Specifically, the licensee failed to take adequate corrective

actions to ensure that operators could perform all necessary manual actions as

approved prior to exceeding the regulatory requirements (P.1(c)).

Enforcement. License Condition 2.E requires, in part, that the licensee implement and

maintain in effect all provisions of the approved fire protection program as described in

the Final Safety Analysis Report through Amendment 55 and the Fire Hazards Analysis

Report through Amendment 7 and as approved in the Safety Evaluation Report

(NUREG-0781) dated April 1986 and its supplements. Section 9.5.1 of the Final Safety

Analysis Report states the Operations Quality Assurance Plan ensures that regulatory

requirements and commitments concerning fire protection are satisfied during plant

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operations. The Operations Quality Assurance Plan further states that procedures shall

provide administrative controls that include taking actions to assure timely corrective

action on conditions adverse to quality.