IR 05000498/2020003
| ML21042A051 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/17/2021 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP |
| To: | Gerry Powell South Texas |
| References | |
| IR 2020003 | |
| Download: ML21042A051 (28) | |
Text
February 17, 2021
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION,
UNITS 1 AND 2 - REISSUED INTEGRATED INSPECTION REPORT 5000498/2020003 AND 05000499/2020003
Dear Mr. Powell:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. The results of this inspection were originally issued in a report, dated October 27, 2019 (Agencywide Document Access and Management System (ADAMS) Accession No. ML20300A591).
The NRC staff subsequently identified inspection activities that were incorrectly listed and reissued the report on January 15, 2021 (Accession No. ML21014A441). Subsequent to the reissued report, NRC staff identified that the item tracking numbers for the two items listed in the report require correction. This reissued inspection report corrects the tracking number error and is enclosed. This change has no impact on the findings documented in this report, but consistent with NRC processes, this report is being reissued in whole.
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:
Jeffrey Josey Digitally signed by Jeffrey Josey Date: 2021.02.17 08:50:50 -06'00' As stated
Inspection Report
Docket Numbers:
05000498 and 05000499
License Numbers:
Report Numbers:
05000498/2020003 and 05000499/2020003
Enterprise Identifier: I-2020-003-0012
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
Wadsworth, TX 77483
Inspection Dates:
July 1, 2020 to September 30, 2020
Inspectors:
D. Antonangeli, Health Physicist
M. Chambers, Physical Security Inspector
G. George, Senior Reactor Inspector
G. Kolcum, Senior Resident Inspector
J. ODonnell, Senior Health Physicist
D. Reinert, Reactor Inspector
A. Sanchez, Senior Project Engineer
E. Simpson, Health Physicist
C. Stott, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at South Texas Project Electric Generating Station, Units 1 and 2, 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 Remove Plastic Shipping Plug During Auxiliary Feedwater Governor Installation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000498/2020003-02 Open/Closed
[H.7] -
Documentation 71152 A self-revealed non-cited violation (NCV) of Technical Specification 6.8.1.a was identified when the licensee failed to provide an adequate maintenance procedure to check for and remove all vendor installed shipping plugs from the Unit 1 turbine-driven auxiliary feedwater (AFW) pump governor before installation in the plant.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000498,05000499/2020003-01 Part 37 URI 71124.08 Open
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On August 7, 2020, the unit commenced a load reduction following the trip of the low pressure heater drain pump 11 and isolation of the feedwater heaters 15A/16A due to a level switch failure. Reactor power was reduced to 93.5 percent. Unit 1 returned to 100 percent power on August 8, 2020. On August 16, 2020, Unit 1 reduced power to 95.7 percent due to a main generator gas temperature alarm. Unit 1 was returned to 100 percent power later on August 16, 2020.
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 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. 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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion 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 some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (4 Samples)
- (1) The inspectors evaluated readiness for potential impending adverse weather conditions for Hurricane Hanna during the week of July 20, 2020.
- (2) The inspectors evaluated response to increased closed loop cooling temperatures of Units 1 and 2, due to high reservoir temperatures combined with heat exchanger fouling during the week of August 9, 2020.
- (3) The inspectors evaluated response to Hurricanes Laura and Marco during the week of August 24, 2020.
- (4) The inspectors evaluated response to Tropical Storm Beta during the week of September 20, 2020.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, train D auxiliary feedwater pump following system restoration after maintenance on August 5, 2020
- (2) Unit 1, safety injection accumulators configuration during the week of August 30, 2020
- (3) Unit 2, essential cooling water system during the week of August 30, 2020
- (4) Unit 2, train D auxiliary feedwater pump on September 10, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Units 1 and 2, auxiliary feedwater during the week of September 20, 2020.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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 1, train D auxiliary feedwater pump room and penetration area, Fire Area 51 on August 3, 2020
- (2) Auxiliary fuel oil storage tank, Fire Area 99 during the week of August 3, 2020
- (3) Unit 2, mechanical auxiliary building roof, Fire Area 79 on August 21, 2020
- (4) Unit 1, electrical auxiliary building, Fire Area 76 on August 24, 2020
- (5) Fire pump house, Fire Area 59 on August 26, 2020
- (6) Unit 1, train A essential cooling water intake structure pump room, Fire Area 53 on August 27, 2020
- (7) Unit 1, train B essential cooling water intake structure pump room, Fire Area 54 on August 27, 2020
- (8) Unit 1, train C essential cooling water intake structure pump room, Fire Area 55 on August 27, 2020
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 1, auxiliary feedwater pump rooms
- (2) Unit 2, auxiliary feedwater pump rooms
Cable Degradation (IP Section 03.02) (1 Sample)
The inspectors evaluated cable submergence protection in:
- (1) Unit 1, train A manhole AOXYABKEM53 on July 15, 2020 Unit 1, train B manhole BOXYABKEM52 on September 15, 2020 Unit 2, train B manhole BOXYAKKEM54 on September 22, 2020
71111.07T - Heat Sink Performance Triennial Review (IP Section 03.02)
- (1) Unit 1, train A essential cooling water intake structure ventilation
- (2) Unit 1, train B main steam isolation cubicle ventilation
- (3) Unit 2, component cooling water heat exchanger 2B
- (4) Unit 2, residual heat removal heat exchanger 2B
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 and evaluated licensed operator performance in the main control room during auxiliary feedwater turbine governor operation on August 6, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated an operations crews response to a degraded condition that resulted in fuel damage and led to a general emergency on August 18, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 1, train B emergency diesel generator that failed to enter the 5-minute post run cooldown during the week of August 17, 2020
- (2) Diesel fire pump 3 during the week of July 20, 2020
- (3) Unit 1, train A safety injection accumulator level during the week of August 30, 2020
- (4) Units 1 and 2, 125vdc battery cable replacements due to excessive bend radius on September 2, 2020
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Unit 1, train D auxiliary feedwater pump speed drift on July 9, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 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;
- (1) Unit 2, train C 125vdc battery cable maintenance that resulted in the planned entry into the configuration risk management program on August 4, 2020
- (2) Unit 1, train D 125vdc battery cable maintenance that resulted in the planned entry into the configuration risk management program on August 5, 2020
- (3) Unit 2, train D 125vdc battery cable maintenance that resulted in the planned entry into the configuration risk management program on August 13, 2020
- (4) Unit 1, train B 125vdc battery cable maintenance that resulted in the planned entry into the configuration risk management program on August 19, 2020
- (5) Units 1 and 2, auxiliary feedwater system during the week of September 8, 2020
- (6) Unit 2, train A yellow risk during the week of September 14, 2020
- (7) Unit 2, train B 125vdc battery and inverter maintenance that resulted in the planned entry into the configuration risk management program on September 23, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, train D auxiliary feedwater pump speed drift on July 9, 2020
- (2) Unit 1, train B essential chiller was found with an outlet temperature hunting on July 17, 2020
- (3) Unit 1, train A power operated relief valve that was found leaking on August 1, 2020
- (4) Unit 2, auxiliary airlock inner reactor containment building side door with corrosion found near the door seals on August 3, 2020
- (5) Unit 2, train B essential cooling water pump motor due to low oil level found in the sight-glass on August 24, 2020
- (6) Unit 1, train A safety injection accumulator level on August 30, 2020
- (7) Unit 2, train A essential chilled water pump bearing oil levels during the week of September 14, 2020
- (8) Unit 2, quality display processing system link status on September 23, 2020
- (9) Unit 1, train D auxiliary feedwater pump trip and throttle valve leak by on September 30, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 1, train D auxiliary feedwater pump permanent modification of mechanical overspeed connecting rod with additional threads due to previous failure to latch on April 5, 2020
- (2) Temporary modification and restoration for the auxiliary fuel oil storage tank during the week of August 3, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Diesel fire pump 1 during the week of July 1, 2020
- (2) Unit 1, train D auxiliary feedwater pump following discovery of plugged governor valve bellows on July 9, 2020
- (3) Unit 2, train B emergency diesel generator following preventive maintenance performed on the lube oil circulation pump and the standby lube oil pump on July 28, 2020
- (4) Unit 1, train D auxiliary feedwater pump following maintenance on August 3, 2020
- (5) Unit 2, train C 125vdc batteries following cable replacement on August 4, 2020
- (6) Unit 1, train D 125vdc batteries following cable replacement on August 5, 2020
- (7) Unit 1, train B emergency diesel generator following fuel oil circuitry repair on August 17, 2020
- (8) FLEX diesel generator 11 following maintenance on August 18, 2020
- (9) Diesel fire pump 3 during the week of August 20, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2, train D auxiliary feedwater pump on June 18, 2020,
- (2) Unit 1, power range neutron flux channel IV actuating channel operational test on July 7, 2020
- (3) Unit 1, train D auxiliary feedwater pump on August 6, 2020
- (4) Unit 1, train D auxiliary feedwater pump on September 3, 2020
- (5) Unit 2, train D auxiliary feedwater pump on September 10, 2020
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, unidentified leakage on June 18, 2020
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) FLEX diesel generator 22 run on August 27, 2020
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
- (1) The inspectors evaluated the licensee's simulator-based licensed operator requalification training evolution that involved a faulted steam generator, loss of reactor coolant accident, and a leak outside of containment on August 19, 2020.
- (2) The inspectors evaluated the licensee's simulator-based licensed operator requalification training evolution that involved a reactor coolant leak, loss of an emergency bus, and a loss of reactor coolant accident, on September 22, 2020.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Personnel contamination monitoring equipment at the Unit-1 41 access control location: 3 ARGOS-5AB units.
- (2) Personnel monitoring equipment at the Unit-1 41 access control location: 2 GEM-5 units.
- (3) Small article monitoring equipment at the Unit-1 41access control location:
4 SAM-12 units.
- (4) Plant process radiation monitor: Unit 1 Steam Generator Blowdown Detector, 1-RA-RE-8043.
- (5) Plant process radiation monitor: Unit 2 Component Cooling Water Transmitter, 2-RA-RT-8040.
- (6) Plant process radiation monitor: Unit 2 Safety Injection Train-A Cubicle Indicator, 2-RA-RI-8084.
- (7) Radiation monitoring equipment: HP-400-00012-010, Ludlum Model 177 count-rate meter.
- (8) Radiation monitoring equipment: HP-400-00097-005, Eberline RO-20 ion chamber.
- (9) Radiation monitoring equipment: HP-400-00147-001, Ludlum Model 78 Stretch Scope.
- (10) Radiation monitoring equipment: HP-400-00045-002, Ludlum Model 12-4 (neutron)survey meter.
Calibration and Testing Program (IP Section 03.02) (11 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Ludlum Model 177, HP-400-00012-006, November 4, 2019
- (2) Ludlum Model 3, HP-400-00031-059, February 26, 2020
- (3) Ludlum Model 9-3, HP-400-00163-040, March 24, 2020
- (4) Canberra GEM-5, HP-155-00003-001, September 3, 2020
- (5) Canberra Argos-5AB, HP-155-00004-005, December 4, 2019
- (6) Eberline EBR-PCM-1C, HP-155-00105-011, February 5, 2020
- (7) Eberline AMS-4 Particulate Monitor, HP-400-00099-002, May 13, 2020
- (8) Unit 1, Turbine Generator Drain Monitor, 1-RA-RT-8041, November 15, 2019
- (9) Unit 2, Condensate Polishing Area Radiation Transmitter, 2-RA-RT-8093, April 30, 2020
- (10) Unit 1 Steam Generator Blowdown Radiation Transmitter, 1-RA-RT-8043, September 23, 2019
- (11) Unit 1, Containment High Range Area Monitor, 1-RA-RT-8050, April 8-9, 20020
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) WAN 569357, Unit 2 Vent Particulate and Iodine Effluent Monitor, 2-RA-RT-8010A, April 27, 2010
- (2) WAN 554121, Unit 2 Vent Wide Range Gas Monitor, 2-RA-RT-8010B, January 20, 2020
- (3) WAN 573449, Unit 1 Liquid Waste Processing System Monitor, 1-RA-RT-8038, June 24, 2020
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
Inspectors evaluated the licensees performance during walk-downs in the Unit-1 Auxiliary Building, Warehouse-44, Metrology Building, and the Unit-2 Yard for controlling, labelling and securing of selected radioactive materials:
- (1) Onsite storage containers 1, 23, and 36 in the Unit-2 yard
- (2) Sealand containers 529689-1 and 204TLU inside warehouse-44
- (3) Decon Jo-boxes 1 and 2 on the 60' walkway of the Unit-1 auxiliary building
Radioactive Waste System Walkdown (IP Section 03.02 (2 Samples)
Inspectors walked down in the Unit 1 Auxiliary Building accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality for the following systems:
- (1) Spent resin transfer system
- (2) Floor drain system
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the licensees characterization and classification of radioactive waste of the following:
- (1) Dry active waste common 2019
- (2) Unit 2, high activity spent resin 2019
Shipment Preparation (IP Section 03.04)
The inspectors were unable to observe preparation of a shipment containing radioactive material according to requirements.
Shipping Records (IP Section 03.05) (3 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) STP-1-19-015, Type B dewatered bead resin
- (2) STP-2-18-058, LSA -II dewatered bead resin
- (3) STP-1-20-013, Type B dewatered bead resin
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1, July 1, 2019, through June 30, 2020
- (2) Unit 2, July 1, 2019, through June 30, 2020
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1, July 1, 2019, through June 30, 2020
- (2) Unit 2, July 1, 2019, through June 30, 2020
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1, July 1, 2019, through June 30, 2020
- (2) Unit 2, July 1, 2019, through June 30, 2020
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)
- (1) Unit 1, train B emergency diesel generator, Condition Report CR-20-5447
- (2) Unit 1, unidentified leakage on June 18, 2020
- (3) Unit 1, train D auxiliary feedwater pump speed drift on July 9,
INSPECTION RESULTS
Unresolved Item (Open)
Part 37 URI URI 05000498,05000499/2020003-01 71124.08
Description:
The inspectors, while conducting a public radiation safety baseline inspection, identified several issues of concern regarding the implementation of 10 CFR Part 37 requirements during their review of the controls for a Category 2 radioactive source. The inspection was conducted the week of September 14, 2020, using IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation.
The inspectors informed the licensee of the issues of concern regarding the implementation of the 10 CFR Part 37 requirements, specifically associated with 10 CFR 37.23, 37.43, and 37.49.
These issues of concern regarding the implementation of 10 CFR Part 37 for the control of the Category 2 radioactive source observed require additional information and review to determine whether the licensee performance constituted violations of NRC requirements.
Consequently, we are considering this matter as an unresolved item (URI).
Planned Closure Actions: The inspectors plan to continue their review of documentation provided by the licensee, as it is made available. This review will be a comprehensive assessment of all associated violations and/or findings related to these potential issues identified.
Licensee Actions: The licensee placed this matter into their corrective action program for review and implementation of corrective actions. The licensee used the corrective action program to document their corrective actions already taken and planned. The licensee has already addressed perceived gaps the inspectors identified in the implementation of 10 CFR Part 37 requirements.
Corrective Action References: Condition Report CR 2020-9835
Failure to Remove Plastic Shipping Plug During Auxiliary Feedwater Governor Installation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000498/2020003-02 Open/Closed
[H.7] -
Documentation 71152 A self-revealed non-cited violation (NCV) of Technical Specification 6.8.1.a was identified when the licensee failed to provide an adequate maintenance procedure to check for and remove all vendor installed shipping plugs from the Unit 1 turbine-driven auxiliary feedwater (AFW) pump governor before installation in the plant.
Description:
On July 9, 2020, the licensee declared the turbine-driven AFW pump 14 inoperable due to a condition where the pump drifted to slower speeds as the pump was running. Later that same day, the licensee found a vendor plug installed inside the fitting on the pneumatic speed control tubing connection on the governor. The licensee believes the plug was vendor installed and in place until discovery on July 9, 2020. The plug was removed, and a post-maintenance test showed that the turbine-driven AFW pump performed satisfactorily. The pump was then declared operable at 0220 on July 10, 2020.
The governor for AFW pump 14 had been replaced in the spring of 2020 during refueling outage 1RE22. It was tested on April 17, 2020 and put into service. During the test, the pumps speed lowered several rpms. This speed control issue was noted during that initial test but not enough to declare the pump inoperable.
With the plug installed in the turbine-driven AFW governor, air was trapped inside a bellows that could be used for pneumatic speed control. The licensee does not use this pneumatic speed control feature, opting instead for the manual speed setting knob for their speed setpoint control. This setup requires that the bellows for pneumatic speed control be free to pass air as the system runs so the manual speed control knob can properly set the speed vice pneumatic control.
With the bellows plugged, the temperature of the trapped air in the bellows rose which caused increasing air pressure the longer the pump ran. This caused the bellows to depress the speed setting plunger which reduced oil flow to the speed setting piston. This, in turn, changed the spring tension and set a new operating point for the spinning flyweight.
When the licensee found and subsequently removed the plug, they were again able to control the turbine-driven AFW pump with the manual speed setting knob and keep the pump within its normal operating band for speed.
The inspectors reviewed procedure 0PMP04-AF-0002, Auxiliary Feedwater Pump Turbine and Governor Valve Maintenance, Revision 43. The inspectors determined that there was no step in the procedure to remove the vendor plug.
Corrective Actions: The licensee removed the vendor plug from the governor bellows and completed surveillance testing to ensure the governor could maintain pump speed as required. The licensee also found testing documentation from the vendor that shows while the governor with the plug installed would cause the turbine-driven AFW pump to slow down, the pump could still perform its safety function for all accident scenarios.
Corrective Action References: Condition Report CR 2020-7429
Performance Assessment:
Performance Deficiency: The failure to provide adequate procedures for maintenance on safety-related equipment was a performance deficiency. Specifically, the licensee failed to provide an adequate maintenance procedure to check for and remove all vendor installed shipping plugs from the Unit 1 turbine-driven AFW pump governor before installation in the plant.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the plug installed on the turbine-driven AFW governor put the safety-related pump into a degraded condition which limited its speed to a slower speed than required by licensee acceptance criteria. The licensee had to perform calculations using data from previous vendor test reports that the pump was still operable.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the turbine -driven AFW pump was able to maintain its operability and therefore screened as Green.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. The inspectors determined that the finding had a crosscutting aspect in the area of documentation. Specifically, the licensee could have incorporated warnings that were in the operations procedure since 1995 into maintenance procedures on the turbine-driven AFW pump governor to ensure the control air port was not blocked prior to installation. [H.7].
Enforcement:
Violation: Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained in accordance with Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Section 9.a, maintenance that can affect the performance of safety-related equipment should be properly pre-planned. The licensee established procedure 0PMP04-AF-0002, Auxiliary Feedwater Pump Turbine and Governor Valve Maintenance, Revision 43, to meet Regulatory Guide 1.33 requirement.
Contrary to the above, from 1995 to July 9, 2020, the licensee failed to properly pre-plan maintenance that can affect the performance of safety-related equipment. Specifically, procedure 0PMP-AF-0002 fails to include procedures that ensures the replacement turbine- -driven AFW pump governor is free of all vendor installed plugs and is ready to install in the plant.
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 verified no proprietary information was retained or documented in this report.
- On July 23, 2020, the inspectors presented the triennial heat sink performance inspection results to Mr. J. Connolly and other members of the licensee staff.
- On September 21, 2020, the inspectors presented the radiation safety inspection results to Mr. G. Powell and other members of the licensee staff.
- On October 8, 2020, the inspectors presented the integrated inspection results to Mr. J. Connolly and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Severe Weather Plan
Hurricane Plan
ZV-0029
Site Preparation for Tropical Storm or Hurricane
Miscellaneous
Motor Driven AFW Pump
AFW Turbine Steam Inlet Valve
AFW Crossover Valves
AFW Pump No. 14(24) Turbine Trip and Throttle Valve
AFW Turbine Pump Isolation Valve
AFW Pump 14 (24) Turbine Trip Solenoid
5S139F00063
5S141(2)F00024,
Sheets 1 & 2
5S141(2)F22547
Turbine Driven AFW Pump Lube Oil System
5S149MB1016,
5S199F00020
Condensate Storage
Main Stm. Iso. Valve Cubicle Vent Fans
Procedures
0001
Fire Preplan Isolation Valve Cubicle, Pump Room Train D
Fire Preplan Isolation Valve Cubicle Penetration Area, Train
D
Auxiliary Feedwater Turbine Overspeed Trip Test
Pneumatic/Spring Control Valve or Damper Calibration
0POP02-AF-0002 Resetting Auxiliary Feedwater Pump 14(24) Mechanical
Overspeed Trip Device
0POP02-CD-0001 Condensate System
Steam Generator Wet Layup Recirc
Auxiliary Feedwater Pump 14(24) Inservice Test
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Refueling Containment Penetration Status
0PSP05-FW-0501 Steam Generator Wide Range Level Calibration
Procedures
Fire Preplan Auxiliary Fuel Oil Storage Tank
Unit 1 Electrical Auxiliary Building, Fire Area 76
Fire Pump House, Fire Area 59
Fire Preplan Isolation Valve Cubicle, Pump Room Train D
Fire Preplan Isolation Valve Cubicle Penetration Area, Train
D
Unit 2 Mechanical Auxiliary Building Roof, Fire Area 79
0600
Unit 1 Essential Cooling Water Intake Structure Pump Room
Train A, Fire Area 53
0601
Unit 1 Essential Cooling Water Intake Structure Pump Room
Train B, Fire Area 54
0602
Unit 1 Essential Cooling Water Intake Structure Pump Room
Train C, Fire Area 55
Corrective Action
Documents
CR-YYYY-NNNN
20-2479
Procedures
Penetration Seals
Work Process Program
Controlled System or Barrier Impairment
Confined Space Entry Program
Electrical Safety
5E100E2100
General Arrangement Station Underground Duct Banks
Work Orders
Work
Authorization
Number
604560, 593968, 593969
71111.07T Calculations
5V159Z41674
ECW Pump Cub. HVAC Ventilation Fan Logic Diagram
System: HZ
Standby Diesel Generator Transient Response Model
MC-5185
Essential Cooling Water Intake Structure (ECWIS) Pressure
Drop
MC-5430
ECWIS Cooling and Heating Loads
MC-6084
Component Cooling Water Heat Exchanger Tube Plugging
01/24/1994
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MC-6096
Component Cooling Water Heat Exchanger Fouling
MC-6219
MC-6498
Essential Cooling Pond Thermal Performance Analysis
MC05047
Component Cooling Water System Heat Loads and Flows
Following a LOCA
MC05181
System Pressure Drop
MC05479
Component Cooling Water System Heat Loads and Flows
for Normal Plant Cooling
MC05908
Instrument Set Points - Component Cooling Water System
05/25/1999
MC06426
IVC/AFW Cooling Load and Room Heat-Up
ZC07020
Area Room Temperature Switches Instrument Uncertainty
and Setpoint Determination
Corrective Action
Documents
CR-YYYY-NNNN
2018-2162, 2018-2921, 2019-1053, 2019-13222
Corrective Action
Documents
Resulting from
Inspection
CR-YYYY-NNNN
20-7775, 2020-7820, 2020-7872
Drawings
00009
EOHC01#1
1VC AFW Pump Cubicle HVAC Supply Fans FN001,
FNO02, & FN003
5R169F20000
Piping and Instrumentation Diagram Residual Heat Removal
System
5V159V00027
Piping & Instrumentation Diagram HVAC Miscellaneous
Buildings Essential Cooling Water Intake Structure &
Electrical Equipment RM - CWIS
5V159Z41674
ECW Pump Cub. HVAC Ventilation Fan Logic Diagram
System: HZ
5V159Z41675
ECW Pump Cub. HVAC Vent Fans Intake & Exh. Dampers
Logic Diagram System: HZ
9-E-HZ01-01
Elementary Diagram ECW HVAC Pump BLDG Vent Fans
FN001, FN003, & FN005
9-E-HZ02-01
Elementary Diagram, ECW HVAC Pump BLDG Vent Fans
FN002, FN004, & FN006
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
9-E-HZ03-01
Elementary Diagram ECW HVAC Intake & Exhaust Air
Dampers, FV-9894, 9895, 9896, 9894A, 9895A, & 9896A
9-E-HZ03-01
Elementary Diagram, ECW HVAC Intake & Exhaust Air
Dampers FV-9894, 9895, 9896, 9894A, 9895A, & 9896A
9-E-HZ04-01
Elementary Diagram ECW Intake Structure HVAC Unit
HTRS HT035 Thru HT040 & HT155 Thru HT160
Engineering
Changes
DCP 99-13150-2
IVC, ECW, and DGB Area Temperature Switch Set-Point
Changes
2/02/1999
Engineering
Evaluations
FAI/20-0513
Evaluation of Gas Void Potential Effects in STP RHR Piping
Miscellaneous
Flow Vibration Analyses for the South Texas (Unit 1 & 2)
Component Cooling Water Heat Exchangers
10/05/1987
Meeting Report Regarding Component Cooling Water Flow
Induced Vibration Problem
11/18/1987
System Health Report Component Cooling Water
06/30/2020
06000252
Component Cooling Water Heat Exchanger Thermal
Performance Test PM Template
10/29/2018
3V229VS0002
Specification for Safety Class Fans
3V289VS0008
Specification for Safety Class Dampers
5R289MB01006
Design Basis Document Component Cooling Water System
5V150VQ1004
Essential Cooling Water Intake Structure Ventilation System
Design Criteria
HLAE2400
Final Report Concerning Component Cooling Water Heat
Exchangers
11/05/1987
MM-2-CC-
87001592
CCW Heat Exchanger 2B Inspect/Clean Preventative
Maintenance Activity
10/09/1990
Plan of Action 20-
4781
Unit 1 RH 1B and 1C Header Pressurization Following SI
07/02/2020
ST-HL-AE-3341
Service Water System Problems Affecting Safety-Related
Equipment
01/29/1990
ST-HL-AE-3701
Revised Schedule for NRC Generic Letter 89-13, Service
Water System Problems Affecting Safety-Related Equipment
04/03/1991
ST-HL-AE-3720
Correction of Response to NRC Generic Letter 89-13,
Service Water System Problems Affecting Safety-Related
03/27/1991
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Equipment
ST-HL-AE-3761
Supplemental Response to NRC Generic Letter 89-13,
Service Water System Problems Affecting Safety-Related
Equipment
05/15/1991
VTD-R165-0008
Installation, Operation and Care of Duty Master Nuclear
Service Class 1E Nuclear Service Non Class 1E Integral
Horsepower Induction Motors
VTD-W351-0005
Instruction Manual for Westinghouse NSSS Heat
Exchangers
Operability
Evaluations
11-3756-3
07/12/2012
13-9934-18
07/26/2016
Procedures
Plant Chemistry Specifications
Chemical Addition to CW/OC and EW
0001
Performance Test for Essential Cooling Water Heat
Exchangers
Essential Cooling Water System Reliability Program
0PMP04-ZG-0011 Heat Exchanger Cleaning (General Guidelines and
Instructions)
Generic Temperature Switch Calibration (Filled Element)
Extreme Cold Weather Guidelines
0001
Essential Cooling Water Operations
2M1
Annunciator Lampbox 22M01 Response Instructions
0013B
Train B ESF Actuation and Response Time Test
Operator Logs
155
Work Orders
Work Activity
Number
23592, 443937, 454609, 454610, 479776, 497442, 508549,
2811, 522812, 533286, 544989, 572382, 572383, 575864,
595316, 595317, 595318
Calculations
3689, 3680, 3675, 3686
Corrective Action
Documents
CR-YYYY-NNNN
20-1370, 2020-1860, 2019-3905, 2020-1815, 2020-1854,
2019-8208, 2019-7235, 2019-9047, 2020-4561, 2019-14780,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2019-8208, 2020-7429, 2018-8223, 2018-2084, 2017-17317,
2010-21759, 2020-5447, 2020-4958, 2020-8431,
2014-10004, 2020-2379, 2020-2557, 2020-2553, 2020-7892
Miscellaneous
DCN 1501807
DCP 14-10333-1
Vendor Technical
Documents
VTD-C634-0029, VTD-C634-0004
Procedures
Operations Logs - Diesel Generator
Cable Terminations
0PMP02-ZG-0004 Bolted Joint Procedure
0002
Emergency Diesel Generator 12(22)
Standby Diesel 13(23) Operability Test
25 Volt Class 1E Battery Monthly Surveillance Test
25 Volt Class 1E Battery Quarterly Surveillance Test
25 Volt Class 1E Battery Intercell Connection Resistance
Surveillance Test
Work Orders
Work
Authorization
Number
27615, 628622, 614503, 591778, 624890, 624973, 633040,
575409, 605853, 570201, 629593, 629668, 629665, 615379,
636969
Calculations
3689, 3686
Corrective Action
Documents
CR-YYYY-NNNN
20-2557, 2020-2553
Procedures
Cable Terminations
0PMP02-ZG-0004 Bolted Joint Procedure
25 Volt Class 1E Battery Monthly Surveillance Test
25 Volt Class 1E Battery Quarterly Surveillance Test
25 Volt Class 1E Battery Quarterly Surveillance Test
25 Volt Class 1E Battery Intercell Connection Resistance
Surveillance Test
Work Orders
Work
Authorization
Number
605853, 570201, 629593, 629665, 629668, 581426
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-YYYY-NNNN
20-8152, 2020-7429, 2020-4958, 2020-9042, 2020-9197,
2016-1252, 2004-2663, 2020-7508, 2020-8188, 2020-6781,
20-5888, 2020-7714, 2020-9943, 2020-10151
Drawings
C
Miscellaneous
Vendor Manual
VTD-B580-0001
Installation, Operation & Maintenance Instructions for
Essential Chilled Water Pumps
Vendor Manual
VTD-B580-0002
Material of Construction
Vendor Technical
Document VTD-
R165-0029
Instruction Manual for Essential Cooling Water Pump Motor
Vendor Technical
Document VTD-
STP1-0001
Rotating Equipment Oil Level Limits and Labels
Procedures
Fluid Leak Management Program
0001
Essential Cooling Water Pump Motor Inspection
Work Orders
Work
Authorization
Number
575409
Corrective Action
Documents
CR-YYYY-NNNN
2019-975, 2020-8072, 2020-8117, 2020-8339
Drawings
HL-10797-2
04/08/1983
HS-14295-1
04/06/1983
Procedures
Auxiliary Feedwater Turbine Overspeed Trip Test
Resetting Auxiliary Feedwater Pump 14(24) Mechanical
Overspeed Trip Device
Auxiliary Feedwater Pump 14(24) Inservice Test
Work Orders
Work
Authorization
Number
615462, 564212, 611949, 585036, 568084, 629571
Corrective Action
Documents
CR-YYYY-NNNN
20-5447
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0002
Emergency Diesel Generator 12(22)
25 Volt Class 1E Battery Intercell Connection Resistance
Surveillance Test
25 Volt Class 1E Battery Intercell Connection Resistance
Surveillance Test
Work Orders
Work
Authorization
Number
570201, 605853, 633040, 629593, 590341, 608858, 609351,
Corrective Action
Documents
CR-YYYY-NNNN
20-6590, 2020-9196, 2020-9445, 2020-8375, 2019-7521,
2015-5166
Procedures
FLEX Diesel Generator Performance Test
Power Range Neutron Flux Channel IV ACOT (N-0044)
0PSP03-AF-0007 Auxiliary Feedwater Pump 14(24) Inservice Test
Work Orders
Work
Authorization
Number
607089, 572074, 607584, 607595, 607585
Procedures
Emergency Classification
Notifications to Offsite Agencies
0001
Excessive Steam Demand
EO00
Reactor Trip or Safety Injection
EO00
Reactor Trip or Safety Injection
EO10
Loss of Reactor or Secondary Coolant
EO10
Loss of Reactor or Secondary Coolant
EO20
Faulted Steam Generator
ES13
Transfer to Cold Leg Recirculation
Transfer to Cold Leg Recirculation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ES13
IN010ERP01-ZV-
IN02
Notifications to Offsite Agencies
Calibration
Records
File #Z05.01
STPNOC Metrology Laboratory Calibration Form
Numerous
Corrective Action
Documents
CR-YYYY-NNNN
2018-09932, 2018-10097, 2018-10300, 2018-11527
2018-11559, 2018-12026, 2019-01116, 2019-00144
2019-00418, 2019-00936, 2019-01040, 2019-01473
2019-04167, 2019-05107, 2019-06344, 2019-07248
2019-07503, 2019-08688, 2019-08843, 2019-09249
2019-09834, 2019-11503, 2019-12317, 2019-13068
2019-13147, 2020-00943, 2020-02190, 2020-02472
20-03730, 2020-03731, 2020-03732, 2020-03863
20-05735, 2020-05863, 2020-06309, 2020-07101
20-07435, 2020-07834
Procedures
Offsite Protective Action Recommendations
Quality Assurance for Radioanalysis Instrumentation
Quality Assurance for the Radiological Laboratory
8010B
MAB Unit Vent Wide Range Gas Monitor Calibration
Liquid Waste Processing System No.1 Monitor Calibration
RCB High Range Area Monitor Calibration
Calibration of the Eberline 6112 Teletector and the Ludlum
Stretch Scope
Calibration of Counting Instruments
Calibration of Handheld Survey Meters/Ion Chambers
Maintenance Calibration of SAM Series Small Article
Monitors
Monitor Calibration of Canberra Argos-5AB Whole Body
Monitors
Calibration of the Ludlum Model 26-1 Friskers
Calibration of the Mirion Telepole II Telescoping Gamma
Survey Meter
Calibration of Alpha-Beta Probes
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Self-Assessments 0PGP03-ZX-0003
Assessment/Benchmark Report, High Range Radiation and
Effluent Monitor Assessment
07/16/2018
MN-18-0-107381
Quality Monitoring Report
11/29/2018
MN-18-1-107149
Quality Monitoring Report
10/09/2018
MN-18-1-107197
Quality Monitoring Report
10/15/2018
MN-18-1-107205
Quality Monitoring Report
10/15/2018
MN-19-0-107592
Quality Monitoring Report
07/10/2019
MN-19-0-107910
Quality Monitoring Report
11/13/2019
MN-19-2-107700
Quality Monitoring Report
10/05/2019
MN-20-0-108151
Quality Monitoring Report
07/21/2020
Corrective Action
Documents
CR-YYYY-NNNN
2018-05496, 2018-11245, 2018-14956, 2018-14957
2018-14958, 2018-14959, 2018-14963, 2019-04181,
2019-07874, 2019-13300, 2019-13584, 2019-13585,
2019-13586, 2019-14086, 2019-14087, 2020-00407,
20-01683, 2020-02198, 2020-06679
Miscellaneous
Typical Part 61 Sampling and Analysis Waste Stream - DAW
Common
2/12/2019
Typical Part 61 Sampling and Analysis Waste Stream -
HASR
2/26/2019
Jan. 2020 Source Inventory and Leak Testing
July 2020 Source Inventory and Leak Testing
Procedures
Radioactive Waste Process Control Program
Radioactive Material Control Program
0002
High Integrity Container (HIC) Dewatering for Shipment and
Burial
Determination of Radioactive Material Curie Content,
Reportability, DOT Sub-Type, and Waste Classification
Determination of Radioactive Material
Radioactive Waste Shipments
Inventory and Leak Testing of Radioactive Sources
10CFR61 Sampling and Analysis Program
Shipment of Radioactive Material
Onsite Staging Facility Operations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Preparation and Shipment of High Integrity Containers or
Reusable Polyethylene Waste Containers
Radiation
Surveys
Survey #111242
OSSC Quarterly Routine Survey
08/24/2020
Survey #111369
Characterization Survey of Intermodal Container
09/03/2020
Self-Assessments
Snap-Shot SA Inspection Procedure 71124.08
05/21/2020
NRC Snapshot Assessment for Inspection Procedure (IP) 71124-05, 71124-06, 71124-07, and 71124-08
07/30/2020
Audit Report
Number 20-02
(RC)
Radiological Controls Quality Audit Report
03/11/2020
MN-18-0-107403
CFR Part 37 Program Review
2/13/2018
MN-19-0-107916
CFR Part 37 Program Review
11/12/2019
Shipping Records Shipment # STP-
1-19-015
Radioactive Waste Shipment Document Package, Part 1
04/10/2019
Shipment # STP-
1-19-015
Radioactive Waste Shipment Document Package, Part 2
04/10/2019
Shipment # STP-
1-20-013
Radioactive Waste Shipment Document Package
2/26/2020
Shipment # STP-
2-18-058
Radioactive Waste Shipment Document Package
11/28/2018
Corrective Action
Documents
CR-YYYY-NNNN
2018-09932, 2018-10097, 2018-10300, 2018-11527
2018-11559, 2018-12026, 2019-01116, 2019-00144
2019-00418, 2019-00936, 2019-01040, 2019-01473
2019-04167, 2019-05107, 2019-06344, 2019-07248
2019-07503, 2019-08688, 2019-08843, 2019-09249
2019-09834, 2019-11503, 2019-12317, 2019-13068
2019-13147, 2020-00943, 2020-02190, 2020-02472
20-03730, 2020-03731, 2020-03732, 2020-03863
20-05735, 2020-05863, 2020-06309, 2020-07101
20-07435, 2020-07834
Procedures
Offsite Protective Action Recommendations
Miscellaneous
Quality Assurance for Radioanalysis Instrumentation
Procedures
Quality Assurance for the Radiological Laboratory
Procedures
MAB Unit Vent Wide Range Gas Monitor Calibration
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
8010B
Procedures
Liquid Waste Processing System No.1 Monitor Calibration
Work Orders
RCB High Range Area Monitor Calibration
Calibration of the Eberline 6112 Teletector and the Ludlum
Stretch Scope
Calibration of Counting Instruments
Calibration of Handheld Survey Meters/Ion Chambers
Maintenance Calibration of SAM Series Small Article
Monitors
Monitor Calibration of Canberra Argos-5AB Whole Body
Monitors
Calibration of the Ludlum Model 26-1 Friskers
Calibration of the Mirion Telepole II Telescoping Gamma
Survey Meter
Calibration of Alpha-Beta Probes
Self-Assessments 0PGP03-ZX-0003
Assessment/Benchmark Report, High Range Radiation and
Effluent Monitor Assessment
07/16/2018
MN-18-0-107381
Quality Monitoring Report
11/29/2018
MN-18-1-107149
Quality Monitoring Report
10/09/2018
MN-18-1-107197
Quality Monitoring Report
10/15/2018
MN-18-1-107205
Quality Monitoring Report
10/15/2018
MN-19-0-107592
Quality Monitoring Report
07/10/2019
MN-19-0-107910
Quality Monitoring Report
11/13/2019
MN-19-2-107700
Quality Monitoring Report
10/05/2019
MN-20-0-108151
Quality Monitoring Report
07/21/2020