ML20121A239
| ML20121A239 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/30/2020 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2020001 | |
| Download: ML20121A239 (23) | |
See also: IR 05000498/2020001
Text
April 30, 2020
Mr. G. T. Powell
President and CEO
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, TX 77483
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION,
UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2020001
AND 05000499/2020001
Dear Mr. Powell:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at South Texas Project Electric Generating Station, Units 1 and 2. On April 16, 2020, the NRC
inspectors discussed the results of this inspection with you and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited
violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector
at South Texas Project.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC Resident Inspector at South Texas Project.
G. Powell
2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
Docket Nos. 05000498 and 05000499
License Nos. NPF-76 and NPF-80
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE SRI:DRP/A
RI:DRP/A
C:DRS/EB1
C:DRS/EB2
C:DRS/OB
NAME
ASanchez
CStott
VGaddy
NTaylor
GWerner
DATE
04/28/2020
04/24/2020
04/24/2020
04/24/2020
04/23/2020
OFFICE C:DRS/RCB
C:DNMS/RxIB
TL:DRS/IPAT
SPE:DRP/A
C:DRP/A
NAME
MHaire
GWarnick
AAgrawal
HFreeman
JJosey
DATE
04/23/2020
04/24/2020
04/23/20
04/21/2020
04/30/2020
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000498 and 05000499
License Numbers:
Report Numbers:
05000498/2020001 and 05000499/2020001
Enterprise Identifier: I-2020-001-0012
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project
Location:
Wadsworth, TX 77483
Inspection Dates:
January 1, 2020 to March 31, 2020
Inspectors:
B. Baca, Health Physicist
T. DeBey, Resident Inspector
J. Ellegood, Senior Resident Inspector
L. Flores, Project Engineer
J. O'Donnell, Senior Health Physicist
A. Sanchez, Senior Resident Inspector
C. Stott, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at South Texas Project, in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Perform an Operability Determination for the Unit 2 Reactor Containment Building
Side Auxiliary Air Lock Door
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
[H.11] -
Challenge the
Unknown
The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings associated with the licensees failure to
follow the operability procedure, 0POP01-ZO-0011, Operability, Functionality, and
Reportability Guidance, Revision 12, and perform an operability determination on degraded
equipment. Specifically, the operations personnel failed to assess the operability for the
Unit 2 reactor containment building auxiliary air lock door that degraded from exposure to
environmental (atmospheric) conditions while performing maintenance on the interlock
mechanism. This reactor contain building auxiliary air lock door was relied upon to meet
Technical Specification 3.6.1.3 for containment integrity during the maintenance activity.
Additional Tracking Items
None.
3
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On March 13, 2020, Unit 1
commenced a reactor shutdown to begin refueling outage 1RE22 and entered Mode 3. Unit 1
remained in refueling outage 1RE22 for the reminder of the inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection
procedures (IPs) in effect at the beginning of the inspection unless otherwise noted.
Currently approved IPs with their attached revision histories are located on the public
website at http://www.nrc.gov/readingrm/doc-collections/insp-manual/inspection-
procedure/index.html. Samples were declared complete when the IP requirements
most appropriate to the inspection activity were met consistent with Inspection Manual
Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase.
From January 1-March 19, 2020, the inspectors performed plant status activities
described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews
using IP 71152, Problem Identification and Resolution. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel to
assess licensee performance and compliance with Commission rules and regulations,
license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the
President of the United States on the public health risks of the coronavirus (COVID-19),
resident inspectors were directed to begin telework and to remotely access licensee
information using available technology. During this time the resident inspectors
performed periodic site visits each week and during that time conducted plant status
activities as described in IMC 2515, Appendix D; and observed risk-significant activities
when warranted. In addition, resident and regional baseline inspections were evaluated
to determine if all or portions of the objectives and requirements stated in the IP could
be performed remotely. If the inspections could be performed remotely, they were
conducted per the applicable IP. In the cases where it was determined the objectives
and requirements could not be performed remotely, management elected to postpone
and reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to
the onset of seasonal cold temperatures for the following systems:
Unit 2 Essential Cooling Water Intake Structure room temperature control and alarm
functions on February 20, 2020
4
External Flooding Sample (IP Section 03.03) (1 Partial Sample)
(1)
(Partial)
The inspectors evaluated external flooding activities in accordance with
Sections 03.03.a, 03.03.b, and 03.03.c as it pertained to the Units 1 and 2 essential
cooling water intake structure and all emergency diesel generator flood panel areas
on January 29, 2020.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 1, train D auxiliary feedwater system during train B emergency diesel generator
maintenance on February 7, 2020
(2)
Unit 2, train C essential cooling water intake structure during train B essential cooling
water maintenance on February 12, 2020
(3)
Unit 1, feedwater booster pumps while the startup feedwater pump maintenance on
March 10, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Unit 2, train C essential cooling water pump room, Fire Area 55, on February 11,
2020
(2)
Unit 1, containment building, Fire Area 63, on March 16, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade performance during a simulated fire
in the Unit 2 mechanical auxiliary building on January 14, 2020.
71111.07A - Heat Sink Performance
Annual Review (IP Section 03.01) (1 Partial Sample)
(1)
(Partial)
The inspectors evaluated heat sink activities in accordance with Sections 02.01.b and
02.01.d as it pertained to the Unit 1 train B emergency diesel generator 6-year
maintenance that opened and inspected the lube oil and jacket water heat
exchangers on February 4, 2020.
5
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1)
The inspectors observed a Unit 1 operating crew during plant shutdown on
March 13, 2020, in preparation for a refueling outage 1RE22.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated a Unit 2 operations crew in the simulator for a
training scenario involving an excessive steam demand, essential cooling water
strainer clogging, and a loss-of-coolant accident on February 27, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Partial Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
(Partial)
The inspectors evaluated the effectiveness of maintenance in accordance with
Section 03.01.a as it pertained to the Unit 1 train B emergency generator replacement
of K1 relay resulted in miswiring of the relay and failed post-maintenance testing of
the emergency diesel generator on February 20, 2020.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample 5 Partial Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed. For the five partial samples documented below,
the inspectors evaluated risk assessment and management in accordance with
Sections 03.01.a, and 03.01.c.
(1)
Unit 1, planned risk due to train C 125Vdc battery and inverter maintenance and use
of the Configuration Risk Management Program on January 16, 2020
(2)
(Partial)
Unit 1, unplanned risk due to train B essential cooling water maintenance resulting in
entering the Configuration Risk Management Program on February 9, 2020
(3)
(Partial)
Unit 1, unplanned risk due to maintenance on train B emergency diesel generator
going longer than expected and resulted in entering the Configuration Risk
Management Program on February 17, 2020
(4)
(Partial)
Unit 1, train D 125vdc battery and inverter maintenance that resulted in the planned
entry into the Configuration Risk Management Program on February 19-20, 2020
6
(5)
(Partial)
Unit 1, train A 125vdc battery and inverter maintenance that resulted in the planned
entry into the Configuration Risk Management Program on February 26-27, 2020
(6)
(Partial)
Unit 1, train B 125vdc battery and inverter maintenance that resulted in the planned
entry into the Configuration Risk Management Program on March 4-5, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Unit 2, train A sequencer due to sequencer trouble alarm received in control room on
January 9, 2020
(2)
Unit 2, auxiliary air lock inner (reactor containment building) door that experienced a
significant step change in the allowable leakage during interlock maintenance on
January 30, 2020
(3)
Unit 1, train B emergency diesel generator buildup of joint sealant material observed
in the wrinkle belly joints in two cylinders on February 4, 2020
(4)
Unit 1, turbine driven auxiliary feedwater pump governor valve corrosion and pitting
found on March 19, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance test activities to verify system
operability and functionality:
(1)
Unit 2, train A essential chilled water chiller following preventive maintenance
between January 6-9, 2020
(2)
Unit 2, train A engineered safeguards feature sequencer testing following
replacement of a DC input module opto-isolator on January 10, 2020
(3)
Unit 1, train B emergency diesel generator testing following a 5-year maintenance
activity on February 16, 2020
(4)
Unit 2, auxiliary air lock reactor containment building side door following seal
replacement due to degradation on February 7, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial Sample)
(1)
The inspectors evaluated refueling outage 1RE22 activities in accordance with
Sections 03.01.a, 03.01.b, 03.01.c(1), 03.01.c(5), 03.01.c(6), 03.01.c(8), 03.01.c(9),
and 03.01.d(2) on March 31, 2020.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
7
Surveillance Tests (other) (IP Section 03.01) (2 Samples, 2 Partial Samples)
(1)
Unit 1, train B emergency diesel generator monthly surveillance test on January 8,
2020
(2)
Unit 1, train B emergency diesel generator surveillance test on February 16 and 17,
2020
The inspectors evaluated the surveillance testing activities in accordance with
Sections 03.01(1), 03.01(2):
(3)
(Partial)
Unit 1, train B residual heat removal pump surveillance test on March 11, 2020
(4)
(Partial)
Unit 1, train C emergency diesel generator surveillance test on March 11, 2020
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1)
The inspectors observed the licensee's enhanced emergency plan drill that involved
failed fuel, a reactor coolant leak greater that the capacity of one charging pump, a
large break loss-of-coolant accident, and a containment breach which exercised all
emergency classification levels on March 4, 2020.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination
and radioactive material. The inspectors observed the following activities:
(1)
Radiation protection technicians surveyed items in which workers brought for free
release from the radiologically controlled area, as well as items which did not clear
the small article monitors. Workers surveyed hand held items with available small
article monitors and exiting the radiologically controlled area.
(2)
Radiation protection technician established a High Efficiency Particulate Air (HEPA)
unit for control of contamination during maintenance work on a residual heat
removal 1A pump valve and reactor vessel water level indicator system probe
8
removal. In addition, the inspector observed the use of the HEPA units by the
technicians and workers for these activities.
(3)
Radiation protection technicians surveyed and controlled the levels of contamination
on workers' gloves and equipment during the thimble tube retraction activity.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and
observation of radiological work activities. The inspector observed the following activities
with regard to radiological hazard control and work coverage:
(1)
Reactor head lift activities which involved a moving technical specification high
radiation area, high contamination levels, and the potential for an airborne area to be
generated (Radiation Work Permit 2020-1-0121, "1RE22 - Reactor Head Lift Activities
(Locked High Radiation Area (LHRA)) - High Radiological Risk", Revision 0)
(2)
Reactor vessel water level indicator system activities with irradiated components and
potentially elevated contamination levels (Radiation Work Permit 2020-1-115,
"1RE22 - Maintenance Support For Work in and around Reactor Cavity, Spent Fuel
Pool and Transfer Canal (High Radiation Area (HRA)) - Medium Radiological Risk,"
Revision 0)
(3)
Residual heat removal 1A pump maintenance with discrete high radiation areas
within the work area and high contamination level with the system breached
(Radiation Work Permit 2020-1-0147, "1RE22 - Repair/Replace Residual Heat
Removal (RHR) 1A Pump Seal (HRA) - Medium Radiological Risk," Revision 0)
(4)
Thimble tube retraction activities with high radiation areas from irradiated components
and high contamination levels (Radiation Work Permit 2020-1-0123, "1RE22 -
Retract/Re-Insert Thimble Tubes (LHRA) - High Radiological Risk," Revision 0)
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very
(1)
Unit 1, refuel 22 reactor head lift activities which involved access to the reactor cavity
and the reactor head movement
(2)
Unit 1, refuel 22 thimble tube retraction activities
(3)
Unit 1, refuel 22 reactor vessel water level indicator system activities
(4)
Unit 1, mechanical auxiliary building - Letdown Heat Exchanger room, Solid Waste
Process Aisle, Chemical and Volume Control System (CVCS) Volume Control Tank
room, and Mezzanine to Room 218J
Radiation Worker Performance and Radiation Protection Technician Proficiency
(IP Section 03.06) (1 Sample)
(1)
The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
9
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors evaluated the licensees communication of as low as is reasonably
achievable ALARA and radiological work controls for the following work activities:
(1)
Radiation Work Permit 2020-1-115, "1RE22 - Maintenance Support For Work in and
around Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) - Medium
Radiological Risk," Revision 0, specifically covering Reactor Vessel Water Level
Indicator System probe removal
(2)
Radiation Work Permit 2020-1-0121, "1RE22 - Reactor Head Lift Activities (LHRA) -
High Radiological Risk," Revision 0
(3)
Radiation Work Permit 2020-1-0123, "1RE22 - Retract/Re-Insert Thimble
Tubes (LHRA) - High Radiological Risk," Revision 0
(4)
Radiation Work Permit 2020-1-0147, "1RE22 - Repair/Replace Residual Heat
Removal (RHR) 1A Pump Seal (HRA) - Medium Radiological Risk," Revision 0
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance.
The inspectors observed and evaluated the implementation of as low as is reasonably
achievable techniques for the following selected work activities:
(1)
Reactor head lift activities
Reactor Vessel Water Level Indicator System probe removal
Thimble tube retraction activities
Residual Heat Removal 1A pump maintenance activities
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 1, January 2019 through December 2019
(2)
Unit 2, January 2019 through December 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
(2 Samples)
(1)
Unit 1, January 2019 through December 2019
(2)
Unit 2, January 2019 through December 2019
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 1, January 2019 through December 2019
(2)
Unit 2, January 2019 through December 2019
10
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1)
October 1, 2019 through December 31, 2019
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample
(IP Section 02.16) (1 Sample)
(1)
October 1, 2019 through December 31, 2019
71153 - Follow-up of Events and Notices of Enforcement Discretion
Event Follow-up (IP Section 03.01) (1 Sample)
Event Follow-up for Loss of Both the 345kV South Bus and Standby Transformer 2
(1)
On March 24, 2020, while Unit 1 was defueled in refueling outage 1RE22 and Unit 2
was at full rated power, the station experienced a loss of the 345kV south bus and
standby transformer 2 at 10:46 a.m. Unit 1 experienced an undervoltage on train A
and C engineered safety features (ESF) buses, which resulted in an emergency start
of each of the train A and C diesel generators, as designed. Unit 1 also lost one of
two trains of spent fuel pool cooling. At the time, time-to-boil in the spent fuel pool
was 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> with the full core offloaded. Spent fuel pool cooling in Unit 1 was
restored in 10 minutes. Unit 1 also had a suspended bundle in the spent fuel pool.
The spent fuel pool fuel handling bridge failed in a safe condition and afterward
secured the bundle with no issues.
Unit 2 experienced an undervoltage on the train B ESF bus, which resulted in an
emergency start of that trains emergency diesel generator as designed. Unit 2 also
lost one of two trains of spent fuel pool cooling and the time-to-boil in the spent fuel
pool was 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />. Unit 2 spent fuel pool cooling was restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. All
safety equipment responded as designed without any issues or operator intervention.
The lockout relays for both the 345kV south bus and standby transformer two were
reset and power restored to those components at 9:07 p.m. All electrical alignments
and equipment restorations were completed at 10:05 p.m. for both units.
Due to the COVID-19 pandemic and NRC directives for inspectors to practice social
distancing to the maximum extent possible, inspectors monitored and confirmed
information via phone and through face-to-face briefings in the outage control center
for Unit 1 outage. The inspectors had no concerns for equipment or operator
performance during the event. The inspectors also kept abreast of restoration
activities throughout the day of the event until full restoration with no concerns. The
inspectors also reviewed the initial notification to verify it met the requirements
specified in NUREG-1022, Event Reporting Guidelines, Revision 3.
No findings were identified.
11
INSPECTION RESULTS
Failure to Perform an Operability Determination for the Unit 2 Reactor Containment Building
Side Auxiliary Air Lock Door
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
[H.11] -
Challenge the
Unknown
The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings associated with the licensees failure to
follow the operability procedure, 0POP01-ZO-0011, Operability, Functionality, and
Reportability Guidance, Revision 12, and perform an operability determination on degraded
equipment. Specifically, the operations personnel failed to assess the operability for the
Unit 2 reactor containment building (RCB) auxiliary air lock door that degraded from exposure
to environmental (atmospheric) conditions while performing maintenance on the interlock
mechanism. This RCB auxiliary air lock door was relied upon to meet Technical
Specification 3.6.1.3 for containment integrity during the maintenance activity.
Description:
On November 27, 2019, following the Unit 2 refueling outage 2RE20, the auxiliary air lock
reactor containment building (RCB) door was tested via a local leak rate test (LLRT) with a
20 sccm leak rate -- well below the acceptance criteria of 7584 sccm. Once every seven
days the auxiliary air lock is inspected to determine if the tamper seal is still present,
indicating the air lock has not been opened. If the seal is intact, no LLRT surveillance would
be required. On January 23, 2020, performance technicians were testing the air lock interlock
when the mechanism failed. Condition Report 20-849 was written to document the failure.
The air lock was immediately declared inoperable and the licensee met Technical
Specification 3.6.1.3.b by ensuring the RCB (inner) side auxiliary air lock door was closed and
locked by an equipment clearance order. The yard (outer) side door would be opened to
effect repairs on the interlock.
One week later, on January 30, 2020, an LLRT was required on both inner and outer doors of
the auxiliary air lock. The inner door experienced a step increase in allowable leak rate to
approximately 7550 sccm, which was 99.7 percent of the allowable leak rate. Condition
Report 20-1205 was written and coded as closed to trend based on requesting that the
preventative maintenance activity to replace the O-rings and clean the sealing surfaces
ASAP following the repair of the interlock. This condition received no operability
determination because, although close to the acceptance limit, the licensee determined that it
met the surveillance requirement. At this time the residents began asking questions about
the sudden and dramatic step change in the LLRT leak rate. In a meeting with engineering
on February 6, 2020, the residents discovered that the most likely cause of the change in the
LLRT results for the inner air lock door was its exposure to the environmental conditions as a
result of having to open the outer auxiliary air lock door while working on the air lock interlock.
The residents asked why the inner air lock door, which was being relied on to meet technical
specifications, was operable considering that the door continued to be exposed to
environmental condition over the balance of the following week. Engineerings answer was
that it met its technical specification surveillance test and that the program and procedure was
being followed by initiating a condition report and requesting seal replacement after the
interlock was repaired.
12
Maintenance performed a seal replacement and a cleaning of the sealing areas on the inner
auxiliary air lock door. The door was then tested via the LLRT satisfactorily at 20 sccm. The
auxiliary air lock and the inner and outer doors were declared operable in accordance with
technical specifications. Unit 2 declared the auxiliary air lock door operable and exited all
technical specifications on February 7, 2020.
On March 4, 2020, the residents again met with engineering, operations and licensing to
review the sequence of events, past LLRTs of the inner and outer auxiliary air lock doors and
discussed the potential cause(s) of the RCB door leakage. Again, engineering and licensing
took the position that the inner door was operable because it met its surveillance
requirements, even if when given that an apparent despite that an apparent degrading
mechanism, the environment, was still present on the inner door.
The residents determined that the unexpected step change in the LLRT leak rate for the inner
auxiliary air lock door coupled with the most likely cause of the degrading mechanism being
the environmental conditions, which were going to continue to exist over the following week to
repair the auxiliary air lock interlock mechanism, cast doubt on the reasonable assurance for
operability. The licensee failed to recognize that reasonable assurance was lost and failed to
enter the operability determination program and procedure. The inspectors determined that
Procedure 0POP01-ZO-0011, Operability, Functionality, and Reportability Guidance,
Revision 12, contained the following guidance:
- Section 6.1.2 Technical Specification surveillances are performed periodically to verify
that SSCs are operable. Satisfactory performance of a surveillance is usually considered
sufficient to demonstrate operability. However, IF conformance to the Current License
Basis (CLB) criteria requirements are questionable due to a possible degraded or
nonconforming condition, AND reasonable expectation of component operability is unclear,
THEN performance of the surveillance may be INSUFFICIENT to demonstrate operability.
An example of when a surveillance would NOT be sufficient to establish operability is the
satisfactory completion of Technical Specification surveillance, but with results that show a
degrading trend and indicate that acceptance criteria might NOT be met before the next
surveillance test. In this case, the surveillance actually identifies the conditions when the SSC
will become inoperable and an operability evaluation would be warranted.
- 7.1.2 The Operability Determinations process is entered upon discovering any of the
following:
Notification to the Control Room of a condition potentially affecting functionality.
Inspectors determined that the licensee became myopic and only considered the surveillance
performance as the input into the operability decision. The inspectors determined that the
licensee failed to challenge the circumstances surrounding the significant step change in the
inner doors LLRT leak rate and thus recognize that the presumption of operability was
compromised by the environmental condition, that was most likely degrading the door, and
that the operability determination process should have been entered.
Corrective Actions: The licensee has the taken corrective action to enter the issue into the
corrective action program, as Condition Report 20-1589, and is in the process of evaluating it.
The Unit 2 auxiliary air lock and its inner and outer doors are currently operable, and no
immediate safety issue exists.
13
Corrective Action References: Condition Reports: 2020-1589, 2020-1205, 2020-849
Performance Assessment:
Performance Deficiency: The failure to implement the operability determination procedure for
a degraded condition was a performance deficiency. Specifically, on January 30, 2020, the
Unit 2 control room operations failed to implement the operability determination procedure,
0POP01-ZO-0011, Operability, Functionality, and Reportability Guidance, Revision 12 for a
degraded condition of the Unit 2 reactor containment building (inner) auxiliary air lock door.
This degraded condition represented a loss of reasonable expectation of operability and
should have been evaluated for operability. The inspectors determined that the performance
deficiency was within the licensees ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the human performance attribute of the Barrier Integrity
cornerstone and adversely affected the cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases caused
by accidents or events. The performance deficiency was determined to be more than minor
because it was associated with the Human Performance attribute of the Containment Barrier
Integrity Cornerstone objective and adversely affected the cornerstone objective to provide
reasonable assurance that physical barriers protect the public from radionuclide releases
caused by accident or events. Specifically, the license failed to enter and use the operability
determination procedure for a degraded RCB side auxiliary air lock door while it was being
relied upon to meet technical specification for reactor containment boundary while the air lock
interlock was being repaired.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. The inspectors used
IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, issued
December 13, 2019 to determine the finding was of very low safety significance, Green.
Specifically, the finding did not represent an actual open pathway in the physical integrity of
reactor containment and did not involve an actual reduction in function of hydrogen igniters in
the reactor containment, therefore screened to Green.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically,
operations relied on the satisfactory surveillance and did not question the circumstances
around the significant step change in LLRT leak rates for the Unit 2 auxiliary air lock inner
door and thus did not recognize the operability determination procedure should have been
entered.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, requires, in part, activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with those instructions, procedures, or drawings The
licensee developed procedure, 0POP01-ZO-0011, Operability, Functionality, and
Reportability Guidance, Revision 12, to comply with determining operability of safety-related,
technical specification equipment and to be in compliance with the above stated regulation.
Specifically, step 6.1.2 (under Presumption of Operability), states, in part, IF conformance
14
to the Current Licensing Basis (CLB) criteria requirements are questionable due to a possible
degraded or nonconforming condition, AND reasonable expectation of component operability
is unclear, THEN performance of the surveillance may be INSUFFICIENT to demonstrate
operability.and an operability evaluation would be warranted.
Contrary to the above, on January 30, 2020, an activity affecting quality prescribed by
procedures of a type appropriate to the circumstances was not accomplished in accordance
with procedures appropriate to the circumstances. The licensee failed enter the operability
determination process when a condition when the conformance of the current licensing basis
requirements was questionable due to a possible degraded or nonconforming condition, and
reasonable expectation of component operability was unclear. Specifically, the licensee did
not enter the operability determination process when a significant step change in the local
leak rate (consumed 99.7 percent of the allowable leakage rate) on the Unit 2 inner auxiliary
air lock door was identified and the degrading mechanism, atmospheric environment,
remained present for approximately one week while being relied upon to meet technical
specifications.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure.
On March 30, 2020, the inspectors presented the results for the occupational radiation
safety 71124.01, 71124.02, and 71151 inspections to Mr. J. Connolly, Executive Vice
President and Chief Nuclear Officer, and other members of the licensee staff.
On April 16, 2020, the inspectors presented the integrated inspection results to
Mr. G. Powell, President and Chief Executive Officer, and other members of the
licensee staff.
15
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-YYYY-NNNN
2020-1493 2020-1494 2020-1495 2020-1496 2020-
1497
2020-1498 2020-1499 2020-1500 2020-1612 2020-
1613
2020-1614
Drawings
5R289F05038
P&ID Essential Cooling Water, Sheet 2
5R289F05039
P&ID Essential Cooling Water, Sheet 1
5S141F00024
P&ID Auxiliary Feedwater, Sheet 1
13
Procedures
0016
Installed Plant Instrumentation Calibration Verification
Program
30
Generic Temperature Switch Calibration
22
52
0001
Essential Cooling Water Operations
82
Work Orders
Work
Authorization
Numbers
572373 572367
Corrective Action
Documents
CR-YYYY-NNNN
2020-872
Fire Plans
20-01-02
Procedures
Fire Pre-plan Mechanical Auxiliary Building Service Areas
and BRS Recycle Holdup Tanks
5
STPEGS Fire Brigade
18
Fire Protection System Functionality Requirements
21
0602
Fire Preplan Essential Cooling Water Intake Structure Pump
Room Train C
4
Miscellaneous
STPNOC Blue team Combined Functional Drill Scenario
Manual
03/04/2020
Procedures
0004
Bolted Joint Procedure
18
Work Orders
Work
569663 569664
16
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Authorization
Numbers
71111.11Q Miscellaneous
RST 220.16 RCS
LOCA to ES12
Simulator Lessons Plan
Procedures
0POP03-ZG-0006 Plant Shutdown From 100% to Hot Standby
75
Corrective Action
Documents
CR-YYYY-NNNN
2020-1854
Procedures
0PMP02-NZ-0013 Cable Terminations
32
Work Orders
Work
Authorization
Numbers
627615
Corrective Action
Documents
CR-YYYY-NNNN
2019-1665 2018-14454 2018-14772 2019-1989
2017-23022 2019-4852 2018-11467 2019-3947
2019-4404 2019-1494
CREE-YYYY-
NNNN
2019-3905-3 2019-9047-2 2020-1860-1
Miscellaneous
Refresher
Communicating
Risk
Licensed Operator Training
RictCal Sequence
3546 3560
Station log
1/15/20 09:31,
10:31
Logs
Procedures
0PGP03-ZG-0091 Configuration Risk Management Program
14
0POP01-ZO-0011 Operability, Functionality, and Responsibility Guidance
11
Online Class 1E 125V DC Battery and Inverter Removal
from Service and Restoration
15
Work Orders
Work Activity Risk
(WAR)
2768
1 and 2
Work
Authorization
Numbers
626074 582691
17
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-YYYY-NNNN
2020-300 2020-849 2020-1205 2020-1589
Procedures
0PGP03-ZO-9900 Operability Determinations and Functionality Assessments
Program
8
0014A
Auxiliary Air Lock Inspection and Maintenance, RCB End
Door
4
0POP01-ZO-0011 Operability, Functionality, and Reportability Guidance
12
0POP01-ZO-0011 Operability, Functionality, and Reportability Guidance
13
03M3
Annunciator Lampbox 3M03 Response Instructions
34
LLRT Penetration: M-91 Auxiliary Door Airlock Door Seals
16
Work Orders
Work
Authorization
Numbers
626878 607399
Corrective Action
Documents
CR-YYYY-NNNN
2020-1184 2020-1196 2020-1197 2020-1815 2020-
1860
2020-1589 2020-1205
Work
Authorization
Numbers
578147 563085 581863 583884 617585 582691
581621 626828 607399
Procedures
0023
Standby Diesel Generator Governor Oil Change and
Overspeed Trip Test
12
0014A
Auxiliary Air Lock Inspection and Maintenance, RCB End
Door
4
0003
York Chiller Inspection and Maintenance 300 Tons
13
0PSP03-DG-0002 Standby Diesel 12(22) Operability Test
65
LLRT Penetration: M-91 Auxiliary Door Airlock Door Seals
16
Work Orders
Work Activity Risk
(WAR)
2768
1 and 2
Miscellaneous
Shutdown Risk Assessment Group (SRAG) Report,
Amendment 1
03/09/2020
1RE22 Level II Schedule
04/03/2020
Shutdown Risk Assessment Group (SRAG) Report
02/27/2020
18
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Operations Logs - Diesel Generator (Diesel Generator 12
(22) Operating Log Sheet
16
Standby Diesel 12 (22) Operability Test
65
Corrective Action
Documents
CR-
2019-06705 2019-11422 2019-1209 2019-12400
2019-12590 2019-13299 2019-13305 2020-00270
2020-01410 2020-01857 2020-02910 2020-03096
2020-03188 2020-03214 2020-03377 2020-03768
Miscellaneous
WAN 545822
Radioactive Source Surveillance
07/30/2019
WAN 556980
Radioactive Source Surveillance
01/23/2020
Procedures
Radiation Protection Program
14
Radiological Access Controls/Standards
43
Inventory and Leak Testing of Radioactive Sources
9
Radiological Survey Program
39
Radiological Postings and Warning Devices
38
High Radiation Area Access Controls
0
Conduct Of
Operations for
Radiation
Protection:
Chapter 25
Locked High Radiation Area (LHRA) Unique Locking
Mechanisms
0
Radiation
Surveys
108732
1-RCB+068: Shut Down Survey, Ladders Down Posted
03/13/2020
108756
1-RCB+068-501: Vibration checks on CRDM vent fan
motors
03/14/2020
108884
1-RCB-011-003: Initial Room 003 entry for disconnect of
seal table from valve rack and lift valve rack
03/16/2020
108919
1-RCB-011-003: Thimble Retraction Job Coverage
03/17/2020
109259
1-RCB+019-201: Routine verification of conditions on
walkways after Generators were opened
03/25/2020
109274
1-RCB+019-201: Routine Survey of B & C bullpen
03/25/2020
109285
1-MAB+060: Routine Shiftly RCB Egress
03/25/2020
109286
1-RCB-011: Contamination Survey of RCB-011' ONLY, due
to Airborne activity in RCB
03/25/2020
109287
1-RCB+019: Follow-up survey during period of elevated
03/25/2020
19
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
airborne radioactivity
Radiation Work
Permits (RWPs)
2019-2-203
2RE20-Remove / Reinstall Reactor Cavity Stairwell (LHRA) -
Medium Radiological Risk
5
2020-1-114
1RE22 - Maintenance Support for Work in And Around
Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA)
0
2020-1-115
1RE22 - Maintenance Support for Work in And Around
Reactor Cavity, Spent Fuel Pool and Transfer Canal (HRA) -
Medium Radiological Risk
0
2020-1-121
1RE22 - Reactor Head Lift Activities (LHRA) - High
Radiological Risk
0
2020-1-123
1RE22 - Retract / Re-Insert Thimble Tubes (LHRA) - High
Radiological Risk
0
2020-1-147
1RE22 - Repair/Replace RHR 1A Pump Seal (HRA) -
Medium Radiological Risk
0
ALARA Plans
20-812-4
1RE22 Room 003 Activities
3/12/2020
20-812-5
1RE22 Steam Generator Inspections
3/14/2020
20-812-7
1RE22 Non-Rapid Refuel
3/13/2020
Corrective Action
Documents
CR-YYYY-NNNN
2018-12157 2018-01339 2019-12668 2019-182339,
2020-00696 2020-01857 2020-01878 2020-02539
2020-03370
Miscellaneous
Action Number
19-4004-5
Perform industry peer benchmark on Rad-Worker
engagement and accountability for dose projections,
performance, and goal in high performing with low source
term reactors
10/31/2019
Action Number
19-8524-1
Determine Gaps in Understanding [ALARA]
02/27/2020
March 16 - 18,
2020
Daily Operations Report
Procedures
Radiation Protection Program
14
ALARA Program
18
Radiation Work Permits/Radiological Work ALARA Reviews
40
Radiological Briefings
7
Radiological Risk Management
5
Conduct of
ALARA Planning
4
20
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operations for
Radiation
Protection,
Chapter 18
Radiation Work
Permits (RWPs)
2020-1-122
1RE22 - FHB Fuel Transfer Tube Area Entry (LHRA)
0
2020-1-135
1RE22 - SG-Eddy Current Testing (LHRA) - High
Radiological Risk
0