ML23310A228
| ML23310A228 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/13/2023 |
| From: | Patricia Vossmar NRC/RGN-IV/DORS/PBA |
| To: | Gerry Powell South Texas |
| References | |
| IR 2023003 | |
| Download: ML23310A228 (34) | |
See also: IR 05000498/2023003
Text
November 13, 2023
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 05000498/2023003 AND
05000499/2023003, AND NOTICE OF VIOLATION
Dear G. T. Powell:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at South Texas Project Electric Generating Station, Units 1 and 2. On October 11,
2023, 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.
The enclosed report discusses a violation associated with a finding of very low safety
significance (Green) for the failure to ensure that conditions adverse to quality involving
essential cooling water expansion joint tolerances, were promptly identified and corrected. The
NRC evaluated this violation in accordance section 2.3.2 of the NRC Enforcement Policy, which
can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The
violation is cited in Enclosure 1, Notice of Violation (Notice). This violation did not meet the
criteria to be treated as a non-cited violation (NCV) because the violation had been previously
identified in 2021 and your corrective actions were inadequately implemented. Expansion joint
tolerances were not restored to their design requirements within a reasonable period of 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. The NRCs review of
your response will also determine whether further enforcement action is necessary to ensure
your compliance with regulatory requirements.
Additionally, 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 an NCV
consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is
documented in this report. We are treating this violation as an NCV consistent with Section 2.3.2
of the Enforcement Policy.
G. Powell 2
If you contest the violations or the significance or severity of the violations 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 Electric Generating Station, Units 1 and 2.
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 Electric Generating Station, Units 1 and 2.
This letter, its enclosures, and your response 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,
Signed by Vossmar, Patricia
on 11/13/23
Patricia J. Vossmar, Chief
Reactor Projects Branch A
Division of Operating Reactor Safety
Docket Nos. 05000498, 05000499
Enclosures:
1) Notice of Violation
2) Inspection Report 05000498/2023003 and 05000499/2023003
cc w/ encl: Distribution via LISTSERV
X SUNSI Review X Non-Sensitive X Publicly Available
RLB
Sensitive Non-Publicly Available
OFFICE RI:DORS/A ASRI:DORS/A ASRI:DORS/A SES:ACES
NAME LFlores NBrown SLichvar JKramer
DATE 11/07/23 11/07/23 11/07/23 11/07/23
OFFICE SPE:DORS/A D:DORS BC:DORS/A
NAME RBywater TClark PVossmar
DATE 11/07/23 11/07/23 11/13/23
NOTICE OF VIOLATION
STP Nuclear Operating Company Docket Nos. 05000498, 05000499
South Texas Project, Units 1 and 2 License Nos. NPF-76, NPF-80
During an NRC inspection conducted from July 1 through September 30, 2023, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation
is listed below:
10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be
established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, and nonconformances are promptly identified and corrected.
Contrary to the above, from November 2021 to September 30, 2023, the licensee failed
to assure that conditions adverse to quality, such as failures, malfunctions, and
nonconformances were promptly identified and corrected. Specifically, the licensee
failed to correct a condition adverse to quality associated with the 1B and 2C essential
cooling water expansion joint tolerances. The expansion joint tie rod nut gap settings
were not set to comply with design documentation due to incorrect work instructions.
This violation is associated with a Green significance determination process finding.
Pursuant to 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,
U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd., Arlington, Texas
76011-4511, and the NRC Resident Inspector at South Texas Project, Units 1 and 2, and email
it to R4Enforcement@nrc.gov within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/2023003, and should include for the violation: (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; 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, the NRC may issue an order or a demand for
information requiring you to explain why your 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 time.
If you contest this enforcement action, you should also provide a copy of your response, with
your basis for denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room and from the NRCs ADAMS, accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any
personal privacy or proprietary information so that it can be made available to the public without
redaction.
Enclosure 1
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 that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (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 13 day of November 2023
2
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000498 and 05000499
License Numbers: NPF-76 and NPF-80
Report Numbers: 05000498/2023003 and 05000499/2023003
Enterprise Identifier: I-2023-003-0004
Licensee: STP Nuclear Operating Company
Facility: South Texas Project Electric Generating Station, Units 1 and 2
Location: Wadsworth, TX 77483
Inspection Dates: July 1, 2023, to September 30, 2023
Inspectors: N. Brown, Senior Resident Inspector
L. Flores, Resident Inspector
S. Hedger, Sr Emergency Preparedness Inspector
S. Lichvar, Senior Resident Inspector
J. Rollins, Senior Physical Security Inspector
D. Willis, Team Leader
Approved By: Patricia J. Vossmar, Chief
Reactor Projects Branch A
Division of Operating Reactor Safety
Enclosure 2
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. A licensee-identified non-cited violation is documented in report section: 71114.05.
List of Findings and Violations
Failure to Maintain Design Control of a Pressurizer Power Operated Relief Valve
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.7] - 71153
Systems NCV 05000498/2023003-01 Documentation
Open/Closed
The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50
Appendix B, Criterion III, Design Control, for the licensees failure to establish measures to
assure the design basis of the Unit 1 pressurizer power operated relief valve (PORV)
PCV-0656A was correctly translated into drawings, procedures, and instructions. Specifically,
for maintenance on the Unit 1 PORV PCV-0656A performed during refueling outage 1RE23,
the licensee failed to ensure that instructions or procedures assured that a critical tolerance
was within limits before the valve was returned to service, and failed to ensure that the correct
solenoid operator, suitable to the design, was installed during maintenance on the PORV. As
a result, PCV-0656A was inoperable for greater than the technical specification allowed
outage time.
Failure to Establish Adequate Corrective Actions for Out-of-Tolerance Essential Cooling
Water System Expansion Joints
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.8] - 71152A
Systems NOV 05000498,05000499/2023003-02 Procedure
Open Adherence
The inspectors identified a Green finding and associated violation of 10 CFR Part 50
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify
and correct a condition adverse to quality. Specifically, the licensee failed to correct essential
cooling water expansion joint configuration in a timely manner to ensure spacing tolerances
complied with design documentation.
2
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000498/2023-001-01 Unit 1, Supplement to 71153 Closed
Pressurizer Power Operated
Valve Failed to Open
LER 05000498/2023-001-00 Unit 1, Pressurizer Power 71153 Closed
Operated Relief Valve Failed
to Open
3
PLANT STATUS
Units 1 and 2 began the inspection period at rated thermal power and remained there 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/reading-
rm/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. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. 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.
REACTOR SAFETY
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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, essential cooling water intake structure pump room train A on July 10, 2023
(2) Unit 2, essential cooling water intake structure pump room train C on July 10, 2023
(3) Unit 1, isolation valve cubicle pump room train A valve cubicle penetration area
train A on July 12, 2023
(4) Unit 1, EAB channel one distribution room on August 1, 2023
(5) Unit 1, EAB train A switchgear and battery room fire boundaries on August 23, 2023
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 control
room in Units 1 and 2 during I&C surveillances the week of September 25, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated operator training on September 6, 2023.
4
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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, EDG train B jacket water leak on July 16, 2023
(2) Unit 2, E2C 'C' ESFAS 4.16kV B-C under voltage on August 14, 2023
(3) Unit 1, planned entry into configuration risk management for train B 125 VDC class
1E battery E1B11 replacement on September 11, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Unit 2, EDG train B jacket water leak on July 16, 2023
(2) Unit 2, rod control automatic insertion events on August 10, 18, and September 1,
2023
(3) Unit 1, containment air lock operability on August 28, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (8 Samples)
(1) Unit 1, train C essential chiller 12 temperature control module replacement on
June 29, 2023
(2) Unit 2, train B emergency diesel generator on July 27, 2023
(3) Unit 1, 125 VDC battery charger E1A11-1 post maintenance test on August 1, 2023
(4) Unit 2, train A control room envelope HVAC on August 2, 2023
(5) Unit 1, personnel airlock on August 3, 2023
(6) Unit 2, B-C ESFAS under voltage relay on August 14, 2023
(7) diesel fire pump 1 on August 17, 2023
(8) Unit 1, train B 125 VDC Class 1E Battery bank replacement on September 13, 2023
Surveillance Testing (IP Section 03.01) (1 Sample)
(1) Unit 1, RHR pump Train A recirculation line MOV surveillance on July 27, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1) Unit 1, safety injection MOV's inservice testing on August 3, 2023
5
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
(1) The inspectors evaluated the licensee's maintenance, testing, and audit program for
the alert and notification system between October 23, 2020, and July 15, 2023.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
(1) The inspectors evaluated the readiness of the Emergency Preparedness
Organization between October 23, 2020, and July 15, 2023. Inspectors also
evaluated the licensee's ability to staff their emergency response facilities in
accordance with emergency plan commitments.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
(1) The inspectors evaluated the 10 CFR 50.54(q) emergency plan change process and
practices between October 23, 2020, and July 15, 2023. The evaluation reviewed
screenings and evaluations documenting implementation of the process. In addition,
the inspectors evaluated changes made to the South Texas Project Electric
Generating Station (STPEGS) Emergency Plan based on NRC notification on May 4,
2022 (ML22124A221). The reviews of the change process documentation or the
emergency plan change do not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
(1) The inspectors evaluated the maintenance of the emergency preparedness program
between October 23, 2020, and July 15, 2023. The evaluation reviewed evidence of
completing various emergency plan commitments, the conduct of drills and exercises,
licensee audits and assessments, and the maintenance of equipment important to
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1) a full site integrated drill that involved a reactor coolant system leak, large break
LOCA, loss of heat sink, radiological release, and a General Emergency on August 2,
2023
6
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
(1) The licensee's simulator-based licensed operator training evolution that involved a
loss of offsite power and a loss of all but one AC power source resulting in an Alert on
May 23, 2023
(2) the licensee's simulator-based operator training evolution that involved an anticipated
transient without scram, reactor coolant system leak and large break LOCA,
containment breach and a General Emergency on September 13, 2023
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
(1) July 1, 2022, through June 30, 2023
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)
(1 Sample)
(1) July 1, 2022, through June 30, 2023
EP03: Alert and Notification System (ANS) Reliability (IP Section 02.14) (1 Sample)
In April 2022, the ANS was changed such that it relies on Integrated Public Alert & Warning
System (IPAWS) as the primary means of public notification. Therefore, the ANS Reliability
PI and associated data is no longer reported by the licensee, and thus is not subject to
further inspection/verification per IP 71151. Evaluation of the licensee's non-siren based
ANS is completed separately per IP 71114.02, Alert and Notification System Evaluation.
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) essential cooling water pump expansion joint ineffective corrective actions
(2) actions taken to address indications of challenges to the safety conscious work
environment in the security organization
(3) actions to address security material conditions, prioritization of security issues within
the corrective action program, and security equipment reliability.
71152S - Semiannual Trend Problem Identification and Resolution
7
Semiannual Trend Review (Section 03.02) (2 Samples)
(1) The inspectors assessed the effectiveness of licensee's corrective actions to address
indications of challenges within the security organization identified during the 2022
Problem Identification and Resolution (PI&R) inspection completed on June 24, 2022.
(2) The inspectors reviewed the licensee's corrective action program for potential
adverse trends in fire watch compliance within the fire protection program. An
associated observation was documented in NRC inspection report
05000498/2023002 and 05000499/2023002 (ML23208A324).
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000498/2023-001-00, "Unit 1, Pressurizer Power Operated Relief Valve Failed
to Open," (ADAMS Accession No. ML23163A248) and LER 05000498/2023-001-01,
"Supplement to Unit 1 Pressurizer Power Operated Relief Valve Failed to Open",
(ADAMS Accession No. ML23207A220). The inspection conclusions associated with
this LER and an associated non-cited violation are documented in this report under
the inspection results section.
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71114.05
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an
emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the
standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(14) requires, in part, that the licensee
conduct periodic drills to maintain key skills. South Texas Project Electric Generating Station
(STPEGS) Emergency Plan EP-0001, revision 0, Section N.4.a, says that STPEGS will
conduct an emergency medical drill once per calendar year. Section F.3 says that
communication tests (drills) will be conducted on various frequencies, one of which is
monthly.
Contrary to the above, from January 1, 2022, to April 1, 2023, the licensee failed to follow an
emergency plan which met the requirements of Appendix E and the standards of
10 CFR 50.47(b). Specifically, in 2022, the licensee failed to conduct the annual emergency
medical drill. In addition, in March 2023, the licensee failed to conduct the monthly
communication test.
8
Significance/Severity: Green. The inspectors assessed the significance of the finding using
IMC 0609 Appendix B, Emergency Preparedness SDP. Using this, the performance
deficiency was determined to have very low safety significance (Green) because it was a
failure to comply with NRC requirements, was not a loss of planning standard function, and
was not a degraded risk significant planning standard function. The planning standard
function was not lost because the licensee did conduct drills and training that addressed
portions of the related emergency plan commitments.
Corrective Action References: Condition Reports 2023-638, 2023-4788 and 2023-7230
Failure to Maintain Design Control of a Pressurizer Power Operated Relief Valve
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.7] - 71153
Systems NCV 05000498/2023003-01 Documentation
Open/Closed
The inspectors identified a Green finding and associated non-cited violation of
10 CFR Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to
establish measures to assure the design basis of the Unit 1 pressurizer power operated relief
valve (PORV) PCV-0656A was correctly translated into drawings, procedures, and
instructions. Specifically, for maintenance on the Unit 1 PORV PCV-0656A performed during
refueling outage 1RE23, the licensee failed to ensure that instructions or procedures assured
that a critical tolerance was within limits before the valve was returned to service, and failed
to ensure that the correct solenoid operator, suitable to the design, was installed during
maintenance on the PORV. As a result, PCV-0656A was inoperable for greater than the
technical specification allowed outage time.
9
Description:
During refueling outage 1RE23 in October of 2021, the licensee performed maintenance on a
leaking Unit 1 pressurizer PORV PCV-0656A. This valve is one of two safety-related valves
used to relieve primary pressure during a primary feed and bleed event scenario. The
licensee contracted with a vendor to perform assessment in accordance with the work orders.
After maintenance activities were completed on the valve during the Unit 1 outage 1RE23,
Unit 1 was returned to full power operation in November 2021. Shortly after startup, PCV-
0656A experienced excessive leakage and its block valve was shut in accordance with
technical specification 3.4.4. The unit continued operation for the rest the cycle in this
condition.
When Unit 1 entered refueling outage 1RE24 in 2023, PCV-0656A failed to open in Mode 4
during the stroke testing surveillance 0PSP03-RC-0010, Pressurizer Power Operated Relief
Valve Operability Test, revision 17, on March 18, 2023. PCV-0656A was declared inoperable
for cold overpressure mitigation and Unit 1 entered technical specification 3.4.9.3, Action C.
About two hours were allowed for equilibrium of temperatures across the valve, and then the
valve was successfully opened during reperformance of 0PSP03-RC-0010.
PORV PCV-0656A was disassembled for corrective maintenance during refueling outage
1RE24. As-found measurements showed the lower portion of the valve cage had minor bore
internal diameters that were out of tolerance resulting in an insufficient gap between the plug
and cage, which could lead to thermal binding. The licensee performed a preliminary Prevent
Recurring Equipment Problems (PREP) evaluation. The PREP evaluation identified that it
was readily apparent that thermal binding caused the failure of PCV-0656A to open when
tested. Inspectors reviewed the maintenance records and determined that during PORV
installation in 2021, the licensee had failed to measure critical dimensions of the valve
internals prior to reassembling the valve and returning it to service. This resulted in a failure
to meet the cage to plug required tolerance of 0.004-0.006 inches.
In addition, after the valves failure to open was investigated, the licensee found that the
incorrect replacement solenoid operator had been installed in 2021. The solenoid operator
included an opening orifice that had been removed through a previous design modification in
1997. Design change package (DCP) 97-02406, June 10, 1997, revised the vendor drawing
to remove the opening orifice from the solenoid operator to allow the valve to meet its stroke
time requirement. When the modification to remove the opening orifice in the solenoid for the
PORV was approved in 1997, the licensee failed to establish a new vendor part number and
purge the existing stock of solenoids to ensure configuration was maintained. As a result,
solenoids had been in stock since 1998 and were never confirmed to be the correct
configuration prior to one being installed in PORV PCV-0656A in 2021.
The licensee performed a root cause evaluation for this issue.
Corrective Actions: The licensee rebuilt pressurizer PORV 656A in 1RE24 and returned the
valve to operable within its required design and proper configuration.
Corrective Action References: CR 2023-2765
10
Performance Assessment:
Performance Deficiency: The licensees failure to adequately maintain the design of Unit 1
pressurizer PORV was a performance deficiency. Specifically, for maintenance on the Unit 1
PORV PCV-0656A performed during 1RE23, the licensee failed to ensure that instructions or
procedures assured that a critical tolerance was within limits before the valve was returned to
service, and that the correct solenoid operator, suitable to the design, was installed during
maintenance on the PORV.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Design Control 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, this design control issue led to a PORV being inoperable for the
entire operating cycle, a condition prohibited by technical specifications.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using
Inspection Manual Chapter 0609 App A, exhibit 2, the inspectors determined that the finding
required a detailed risk evaluation because the degraded condition represented a loss of the
PRA function of one train of a multi-train technical specifications system for greater than its
technical specifications allowed outage time. A senior reactor analyst performed a detailed
risk evaluation.
The analyst conducted a detailed risk evaluation in accordance with IMC 0609 appendix A.
The South Texas Project SPAR Model version 8.80 along with SAPHIRE software
version 8.2.8 were used for the evaluation. The analyst assumed that the performance
deficiency resulted in the Unit 1 pressurizer PORV PCV-0656A being in a condition where it
would have been unable to perform its required function of opening on demand. Based on the
nature and cause of the condition and the timeline of events described above, the analyst
assumed that PORV PCV-0656A was in this condition throughout the operating cycle from
November 2021 to March 2023. Therefore, the analyst determined that an exposure time of
1 year would be appropriate for the analysis. The analyst determined that this condition would
be most appropriately modeled by setting the basic event PPR-PORV-CC-PCV656 (PORV
PCV-656 FAILS TO OPEN ON DEMAND) to TRUE in the Events and Conditions
Assessment (ECA) workspace for an exposure time of 1 year.
The analyst noted that one of the PRA safety functions impacted by this condition was the
ability to perform decay heat removal by a feed-and-bleed approach in which a high-
pressure injection source is aligned to the reactor coolant system (RCS) to provide a source
of coolant inventory while the pressurizer PORVs are opened to provide a pathway for
coolant to flow from the RCS. The analyst noted that the SPAR model included success
criteria in which both (i.e., 2-out-of-2) PORVs were required to be available to perform this
safety function. Through discussions with the licensee, the analyst became aware that the
licensee had an analysis to support the conclusion that this safety function could be
successfully implemented with one PORV instead of two (i.e., a 1-out-of-2 success criteria).
The analyst determined that this information would be consistent with the NRCs guidance to
include consideration of best available information for SDP evaluations. After review of the
licensees analysis regarding this safety function, including facility operating procedures that
existed at the time of the failed condition, the NRC concluded that the success criteria for this
feed-and-bleed safety function would be most appropriately modeled using a 1-out-of-2
11
success criteria with respect to the opening of either of the pressurizer PORVs on demand.
Therefore, a modeling change was implemented in the SPAR model to reflect the revised
failure logic associated with this safety function.
The analyst also noted that another PRA safety function that is dependent on the functioning
of the pressurizer PORVs is present in event sequences involving an anticipated transient
without scram (ATWS) in which the pressurizer PORVs are relied on to provide a function to
open on demand to limit peak pressure in the RCS during the event. The analyst noted that
the existing default success criteria for this RCS pressure limiting safety function in the SPAR
model was a 5-out-of-5 criteria for both pressurizer PORVs and all three pressurizer safety
valves to open on demand. The analyst also noted that alternative success criteria associated
with this safety function was also present (but not activated/effective by default) in the SPAR
model, which reflected that the opening of less than five of these five valves would be
necessary to achieve the required function. The analyst reviewed multiple sources of design
basis information, accident analyses, and operating parameters for the facility and
determined that the most appropriate success criteria for this safety function would be to
require the opening of either: 1) all three pressurizer safety valves, or 2) 2-out-of-3 safety
valves plus both PORVs. The analyst adjusted the logic structure of the existing SPAR model
basic events to reflect this best available information associated with this safety function.
The analyst also noted that another PRA safety function that is typically credited in several
event sequences in SPAR models for Westinghouse pressurized water reactor (PWR)
facilities involves the operation of steam dump valves as part of a decay heat removal
strategy in which steam from the steam generator(s) is routed from the main steam system
header to the main condenser. The analyst noted that this function was not reflected in the
SPAR model for South Texas Project. The analyst reviewed the modeling of this function in a
sampling of other Westinghouse PWR facility models and determined that this function was
consistently modeled at other Westinghouse PWR facilities that are similar in design and
operation to South Texas Project. The analyst reviewed available documentation and
reference sources, as well as engaged personnel involved with SPAR model development, to
determine whether a basis existed for excluding the crediting of this function for South Texas
Project. The analyst reviewed facility design basis information and operating procedures and
determined that including credit for this safety function in the South Texas Project model
would be appropriate. Therefore, a surrogate basic event was incorporated in the SPAR
model fault tree SG-PORVS as an equivalent means of providing credit for this safety
function as compared to the typical modeling approach for the same function at other PWR
facilities. Consistent with the operational and design characteristics of South Texas Project as
compared to other similarly designed and operated PWR facilities, the analyst assumed an
overall failure probability of 5E-3 for this credited function.
With the assumptions and modeling changes described above, using the updated test and
limited use (TLU) SPAR model STP Steam Dump Addition dated June 19, 2023, the analyst
obtained a result of 2.47E-7/year for an increase in average annual core damage frequency
(delta-CDF) associated with internal events. Therefore, the increase in risk associated with
external events was also evaluated. The analyst obtained a result of 3.06E-7/year for a delta-
CDF associated with the external events of hurricane, straight line high winds, tornado, and
seismic events. Since the SPAR model did not include modeling of fire events, the analyst
determined that best available information associated with the risk attributable to fire events
would be obtained from the licensees fire PRA model. The analyst obtained and reviewed
12
the results of the licensees fire PRA modeling of the impact of this condition and concluded
that the increase in risk for this condition associated with fire events was best estimated to be
a delta-CDF of 2.3E-7/year. The dominant sequences involved hurricane and high wind
events with failures of offsite power, auxiliary feedwater, and feed-and-bleed functions; as
well as loss of main feedwater and loss of condenser heat sink events with failures of feed-
and-bleed and either auxiliary feedwater or steam generator PORV functions. One additional
dominant sequence involved a steam generator tube rupture event with a failure of the
secondary side cooldown function.
The risk significance of the finding was also evaluated for impact on large early release
frequency (LERF). The analyst evaluated the increase in LERF using Inspection Manual
Chapter 0609, appendix H, Containment Integrity Significance Determination Process. The
finding was treated as a Type A finding because it could influence the likelihood of accidents
leading to core damage as well as being a contributor to LERF. The analyst reviewed all
sequences contributing to CDF for any elements affecting LERF and screened out all
sequences except those associated with a steam generator tube rupture (SGTR) event. For
the SGTR sequence, the analyst applied the applicable assessment factor from Table 6.2,
Phase 2 Assessment Factors - Type A Findings at Power. This resulted in an increase in
LERF from internal and external events (minus fire events) of 5.0E-8/year. From the
licensees fire risk analysis, the analyst determined the best estimate of increase in LERF due
to fire events was 1.0E-8/year.
The analyst performed an uncertainty analysis using the Monte Carlo method with 3,800 runs
on the internal and external events (minus fire events) results in SAPHIRE. The mean value
result was 5.56E-7/year, and the 5th and 95th percentile results were 8.8E-8/year and 1.7-
6/year, respectively, with 97.3 percent of the results falling within the range of less than 1.0E-
6/year. The analyst considered that the uncertainty distribution associated with the
overall/total result (i.e., with the addition of the fire event results of 2.3E-7/year) would be
shifted upward with a dominant portion of the results remaining below the 1.0E-6/year
threshold.
The analyst determined that the crediting of Diverse and Flexible Coping (FLEX) Strategies
had no impact on the results of this analysis. The analyst also determined that the application
of a 5E-3 failure probability associated with the steam dump safety function was an
appropriately conservative assumption, based on being slightly higher than the failure
probabilities reflected in the modeling of this same function at other similarly designed and
operated facilities. The analyst conducted a sensitivity analysis on this parameter by setting it
to a higher failure probability of 1E-2 and concluded that the corresponding increase in the
resulting total delta-CDF for the analysis was relatively minimal (at approximately 1.1E-
8/year).
The licensees risk significance evaluation yielded results of 1.69E-7/year and 1.06E-9/year
for internal events for delta-CDF and delta-LERF, respectively, as well as results of 2.3E-
7/year and 1.0E-8/year for fire events for delta-CDF and delta-LERF, respectively.
The analyst concluded that the overall risk significance of the finding was determined to be
very low safety significance (Green), based on best estimates of 7.8E-7/year for total
delta-CDF and 6.0E-8/year for total delta-LERF.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains
complete, accurate and up-to-date documentation. Specifically, the licensee failed to create
and maintain complete, accurate, and up-to-date documentation for PCV-0656A.
13
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that
measures shall be established to assure that applicable regulatory requirements and the
design basis are correctly translated into specifications, drawings, procedures, and
instructions. These measures shall include provisions to assure that appropriate quality
standards are specified and included in design documents and that deviations from such
standards are controlled. Measures shall also be established for the selection and review for
suitability of application of materials, parts, equipment, and processes that are essential to
the safety-related functions of the structures, systems and components.
Technical specification 3.4.4, Relief Valves, requires, in part, that both PORVs and their
associated block valves shall be operable in Modes 1, 2, and 3. Technical specification 3.4.4
action statement (b) requires, in part, that with one PORV inoperable due to causes other
than excessive seat leakage, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV to operable status or
close the associated block valve and remove power from the block valve; within the following
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> restore the PORV to operable status or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, from October 2021, the licensee failed to establish measures to
assure that applicable regulatory requirements and the design basis were correctly translated
into specifications, drawings, procedures, and instructions, and failed to establish measures
for the selection and review for suitability of application of materials, parts, equipment, and
processes that are essential to the safety-related functions of the structures, systems and
components. Specifically, for maintenance on the Unit 1, PORV PCV-0656A performed
during 1RE23, the licensee failed to ensure that instructions or procedures assured that a
critical tolerance was within limits before the valve was returned to service, and that the
correct solenoid operator, suitable to the design, was installed during maintenance on the
PORV. As a result, from November 3, 2021, to March 18, 2023, during operating cycle 24,
PORV PCV-0656A was inoperable for greater than the allowed outage time permitted by
technical specification 3.4.4 action (b) for one PORV inoperable due to causes other than
excessive seat leakage, and the unit was not placed in hot standby within the following 6
hours.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Establish Adequate Corrective Actions for Out-of-Tolerance Essential Cooling
Water System Expansion Joints
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.8] - 71152A
Systems NOV 05000498,05000499/2023003-02 Procedure
Open Adherence
The inspectors identified a Green finding and associated violation of 10 CFR Part 50
Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify
and correct a condition adverse to quality. Specifically, the licensee failed to correct essential
cooling water expansion joint configuration in a timely manner to ensure spacing tolerances
complied with design documentation.
14
Description: On August 11, 2022, the NRC issued a Green, non-cited violation 0500498/2022002-02 and 0500499/2022002-02, of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, for the failure to Identify Conditions Adverse to Quality
Within Essential Cooling Water System (ML22215A226). One of the conditions adverse to
quality identified in this finding was out of tolerance expansion joints located at the essential
cooling water pump discharges identified by the NRC on November 10, and 17, 2021 in
condition reports (CR) 2021-12089 and 2021-12337, respectively. To address the condition,
the licensee planned to adjust a total of five expansion joints in upcoming train work outages
under CR 2021-12048.
The essential cooling water expansion joints are designed to absorb longitudinal deformation
of the essential cooling water piping due to thermal expansion and contraction. The tie rods
connecting the flanges of the expansion joint at each end allow longitudinal movement of the
expansion joint within the defined range of expansion and contraction.
On June 22, 2023, during system walkdowns in the essential cooling water intake structure
building, the inspectors noted that the 1B and 2C essential cooling water discharge
expansion joint tie rod nuts appeared to be loose and questioned their configuration. The
licensee conducted walkdowns of all trains of essential cooling water and documented that
that the expansion joint tie rod nut gap settings were not set per the design specification as
shown in vendor drawing 8113-00030TF, 24 inch Expansion Joint Assembly, revision 5.
The inspectors reviewed the corrective actions associated with CR 2021-12048 and noted
that the 1B essential cooling water expansion joint tie rod nut tolerance was corrected under
work authorization number (WAN) 662730 on May 10, 2022, and the 2C essential cooling
water expansion joint tie rod nut tolerance was corrected under WAN 662291 on
November 25, 2021. Step 3.2 of WANs 662730 and 662291 directs resetting the expansion
joint tie rod nut gap settings per vendor drawing 8113-00030TF. The gap settings were
correctly shown on drawing 8113-00030TF and required only a 0.25 gap on both sides of the
outlet side tie plate; however, step 3.2.2 of both WANs also incorrectly stated, in part, to
ensure that the compression stop nuts (inlet side) are set at 0.025 gap.
On September 11, 2014, CR 2014-16257 was initiated when the NRC identified that the
essential cooling water pump expansion joint tie rod nut dimensions were not configured
according to the vendor drawing. The licensee performed a stress analysis to verify
operability and documented this in Condition Report Engineering Evaluation (CREE)
14-16257-1. WANs 502648-502653 were created using WCG-0003, Planners Guide,
revision 35, to disposition CREE 14-16257-1 and adjust the gap settings on all six trains of
essential cooling water to restore compliance with vendor drawing 8113-00030TF. These
work orders contained the same incorrect instructions as those contained in WANs 662730
and 662291 that were written to correct the conditions noted in CR 2021-12048. WCG-0003,
step 5.5.1.3.1 states, in part, that Work Packages SHALL be reviewed by Engineering if the
work instructions involve the disposition of a CREE. Contrary to this step, WANs 502648-
502653 were not reviewed by engineering.
WANs 662730 and 662291 were also prepared using WCG-0003, Planners Guide,
revision 41. Step 5.7.3.14 of WCG-003 states, in part, that the planner SHALL review past
performance work instructions for technical accuracy when preparing work packages. During
the work package development for WANs 662730 and 662291 for 1B and 2C essential
cooling water expansion joint tie rod nut gap setting correction, the planner, during their
review of the previously performed WANs associated with CR 2014-16257, did not identify
15
that the expansion joint tie rod nut gap settings were incorrect in those instructions, resulting
in the error being carried forward into WANs 662730 and 662291.
Corrective Actions: The licensee has initiated CR 2023-6947 to document and correct the
erroneous step in the work instructions.
Corrective Action References: Condition Reports (CR) 2022-6950, 2023-6230, 2023-6231,
2023-6238, 2023-6240, 2023-6241, 2023-6243, 2023-6244. 2014-16257, 2021-12048,
2021-12089, 2021-12337
Performance Assessment:
Performance Deficiency: The licensees failure to correct a condition adverse to quality is a
performance deficiency. Specifically, the licensee failed to correct essential cooling water
expansion joint tolerances due to inadequate implementation of corrective actions to restore
compliance with design documentation.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance 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, incorrect expansion joint gap settings can induce
additional stresses into connected piping, thereby challenging the systems reliability.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
inspectors determined that this finding is of very low safety significance (Green), because the
nonconformance of essential cooling water system expansion joints with design
documentation did not result in inoperability or PRA non-functionality of the essential cooling
water system.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures,
and work instructions. Specifically, the failure to follow appropriate steps in WCG-0003,
Planners Guide, resulted in erroneous work instructions initiated in 2014 to be implemented
on the 1B and 2C essential cooling water discharge expansion joints in 2021 and 2022,
respectively, that were inadequate to correct the conditions adverse to quality associated with
out-of-tolerance essential cooling water expansion joints.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, and nonconformance's are promptly identified and corrected.
Contrary to the above, from November 2021 to September 30, 2023, the licensee failed to
assure that conditions adverse to quality, such as failures, malfunctions, and
nonconformance's were promptly identified and corrected. Specifically, the licensee failed to
correct a condition adverse to quality associated with the 1B and 2C essential cooling water
expansion joint tolerances. The expansion joint tie rod nut gap settings were not set to
comply with design documentation due to incorrect work instructions.
16
Enforcement Action: This violation is being cited because the licensee failed to restore
compliance within a reasonable period after the violation was identified consistent with
Section 2.3.2 of the Enforcement Policy.
Assessment 71152S
Assessment
From July 31, 2023, to August 2, 2023, inspectors completed an onsite inspection at the
South Texas Project Electric Generating Station (STP) to assess the effectiveness of the
licensees corrective actions to address indications of challenges to the safety conscious work
environment (SCWE) in its security organization. These SCWE challenges were first
identified by the NRC during a problem identification and resolution (PI&R) inspection
completed on June 24, 2022, and documented in NRC inspection report 05000498/2022010
and 05000499/2022010 (ML22220A045). In addition to the SCWE challenges identified
during the PI&R inspection, the NRC also identified a notable increase in security-related
allegations from onsite sources at STP in 2022 and documented this increase in the NRCs
2022 Allegation Program Annual Trend Report (ML23110A294). Based on these insights, the
NRC determined that additional SCWE focused inspection activity would be performed to
determine whether the licensees corrective actions to address the security work environment
concerns have been effective.
During this follow-up inspection, NRC inspectors preformed the following activities:
- Obtained a description of the licensees corrective actions and verified the
implementation of these actions during the onsite inspection.
- Reviewed relevant documentation and records such as employee concern program
concerns and corrective action program documents regarding SCWE-related issues in
the security organization, as well as recent safety culture surveys completed by
personnel in the security organization.
- Conducted focus group interviews with approximately 48 randomly selected security
officers and 9 security supervisors across all security shifts.
- Conducted individual interviews with key personnel such as licensee and contractor
employee concerns program managers and security managers, and members of the
licensees security executive oversight committee.
The team noted that the licensee had taken several corrective actions to address the causes
of the challenges to SCWE in the security organization, including measures to promptly
address security material conditions such as dedicating engineering resources to security
systems, revising its corrective action program procedures to ensure security issues are
properly prioritized and promptly addressed, and developing a security equipment reliability
and life cycle management plan. The licensee also took several actions to improve its
security staffing to significantly decrease the amount of overtime that was contributing to low
security force morale at the time of the PI&R inspection in 2022.
Despite these corrective actions, the inspection team found that there are still safety culture
challenges in the security organization under the safety culture traits of environment for
raising concerns, respectful work environment, work processes, and effective safety
communication. During interviews, security officers expressed several negative perceptions in
these areas that, if left unaddressed, may further degrade the level of trust in the security
organization and affect the officers willingness to raise concerns in the future. A full
description of these safety culture traits, including attributes and examples, can be found in
17
NUREG-2165, Safety Culture Common Language (ML14083A200). Applicable examples
found in NUREG-2165 are referenced in the teams findings below.
The safety culture trait of environment for raising concerns (RC) is defined as a safety-
conscious work environment where personnel feel free to raise safety concerns without fear
of retaliation, intimidation, harassment, or discrimination. The inspectors noted that while
most of the officers interviewed stated that they would raise nuclear safety and security
concerns through multiple avenues, some officers did report that they felt that they could be
targeted by security management after they raised the concern [RC 1.1]. While officers were
not able to provide specific examples of discrimination, this perception could cause officers to
hesitate to report when they identify a concern in the future. In addition, most of the officers
stated that while they would continue to raise concerns, they did not believe that
management would address their concerns in a timely or comprehensive manner [RC 1.1,
RC 2.6]. Officers provided several examples of security equipment issues that they felt were
not being corrected in a timely manner or were closed without corrective action.
The safety culture trait of respectful work environment (WE) is defined as a work environment
where trust and respect permeate the organization. The inspectors noted that most officers
interviewed stated that when individual performance issues are identified, management
implements broad corrective actions that apply to all and, as such, are seen as punitive.
Many officers interviewed felt that leaders are not addressing negative performance directly
with individuals [WE 3.5]. Some officers also stated that they do not feel that they are treated
with respect. For example, officers reported multiple interactions with members of
management that were perceived as defensive and dismissive in response to concerns that
were raised [WE 1.2, WE 3.2].
The safety culture trait of work processes (WP) is achieved when the process of planning and
controlling work activities is implemented so that safety is maintained. The inspectors noted
that, in addition to the lack of responsiveness to concerns raised, some officers shared the
perception that security work planning is lacking leading to security material deficiencies or
compensatory measures that could have been prevented. Examples provided by the officers
included preventative maintenance of vehicles, posting of unattended openings created
during outages, and ensuring placement of officer environmental shelters for planned work
[WP 1.1].
The safety culture trait of effective safety communication (CO) is achieved when
communication maintains a focus on safety. The inspectors noted that most security officers
stated that they do not receive feedback on the resolution of concerns in a timely manner, to
include the basis for why decisions are made. Specifically, the majority of security officers
expressed the concern that they did not understand why corrective actions to address
security equipment deficiencies, including equipment issues presenting industrial safety
concerns, take so long to correct [CO 2.5].
The inspectors concluded that while the licensee had taken several corrective actions, more
attention is needed in the areas described above in order to assure that sustainable
improvement would be achieved. The licensee acknowledged the inspection teams
observations and entered them into its corrective action program as CR 23-7389. The NRC
plans to continue to monitor the licensees progress in addressing these challenges to safety
culture in its security organization.
18
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 28, 2023, the inspectors presented the emergency preparedness program
inspection results to K. Harshaw, Executive Vice President and Chief Nuclear Officer,
and other members of the licensee staff.
- On October 11, 2023, the inspectors presented the integrated inspection results to
G. T. Powell, President and CEO, and other members of the licensee staff.
19
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.05 Procedures 0EAB02-FP-0003 Fire Preplan for Electrical Auxiliary Building Channel One 4
Distribution Room
71111.05 Procedures 0EAB02-FP-0004 Fire Preplan for Electrical Auxiliary Building ESF Switchgear 4
Room Train A
71111.05 Procedures 0EAB02-FP-0084 Fire Preplan for Electrical Auxiliary Building Channel I 3
Battery Room
71111.05 Procedures 0IVC50-FP-0401 Fire Preplan Isolation Valve Cubicle Pump Room, Train A 3
71111.05 Procedures 0IVC50-FP-0408 Fire Preplan Isolation Valve Cubicle Penetration Area Train 3
A
71111.05 Procedures 0IVC51-FP-0405 Fire Preplan Isolation Valve Cubicle Pump Room 2
71111.05 Procedures 2ECW56-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5
0603 Room Train C
71111.05 Procedures 2ECW58-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5
0605 Room Train A
71111.13 Corrective Action CR-YYYY-NNNN 2023-6833, 2023-7059, 2023-7626
Documents
71111.13 Procedures 0PGP02-ZA-0003 Comprehensive Risk Management Program 16
71111.13 Procedures 0PGP03-ZO-0055 Protected Components 18
71111.13 Procedures 0POP01-ZO-0006 Risk Management Actions (RMA's) 28
71111.13 Procedures 0POP11-DJ-0002 Online Class 1E 125VDC Battery and Inverter Removal from 20
Service and Restoration
71111.13 Work Orders Work 644467
Authorization
Number
71111.15 Corrective Action CR-YYYY-NNNN 2023-6985, 2023-7042, 2023-8019, 2023-8034, 2023-7149,
Documents 2023-6833, 2023-7059, 2017-22703, 2023-8182, 2007-5177,
2023-7577. 2023-7847
71111.15 Engineering CREE 23-7847-7
Evaluations
71111.15 Miscellaneous VTD-T905-0001 Instruction Manual for Personnel Airlock 4
71111.15 Miscellaneous VTD-W120-0653 7300 Lead/Lag Amplifier Instruction Bulletin 0
71111.15 Procedures 0EPM01-IP-0004 Equipment Important to Emergency Response 0
20
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.15 Procedures 0PMP04-ZG- Personnel Airlock Inspection and Maintenance, RCB End 4
0013A Door
71111.15 Procedures 0POP01-ZO-0011 Operability, Functionality and Reportability Guidance 18
71111.15 Procedures EP-0003-000 Emergency Action Levels Technical Basis Manual 0
71111.15 Work Orders Work 665510, 667076, 687594, 448682
Authorization
Number
71111.24 Corrective Action CR-YYYY-NNNN 2023-6338, 2023-7307, 2023-7149, 2023-8019, 2023-8033,
Documents 2023-7626
71111.24 Miscellaneous Station Unit 1 Logs 07/27/2023
71111.24 Miscellaneous VTD-B350-0001 Operation and Maintenance Manual Electro-hydraulic Rotary 3
Damper Actuator Assembly
71111.24 Miscellaneous VTD-G185-0018 Installation and Operating Instructions Lead-Antimony Types, 2
Lead-Calcium Types
71111.24 Miscellaneous VTD-G185-0021 Nuclear Class-1E GNB Flooded Batteries Type NCN-17S 0
Lead Calcium
71111.24 Procedures 0PGP03-ZM- Post-Maintenance Testing Implementation 7
0025A
71111.24 Procedures 0PMP08-ZI-0136 Borg Warner Electro-Hydraulic Rotary Damper Actuator 10
71111.24 Procedures 0PSP03-DG-0002 Standby Diesel 12(22) Operability Test 67
71111.24 Procedures 0PSP03-RH-0009 Residual Heat Removal System Valve Operability Test 17
71111.24 Procedures 0PSP03-SI-0020 safety injection system miscellaneous and train 1A(2A) valve 23
operability test
71111.24 Procedures 0PSP06-DJ-0003 125 Class 1E Battery Intercell Connection Resistance 21
Surveillance Test
71111.24 Procedures 0PSP06-DJ-0006 Battery Charger 8 Hour Load Verification 31
71111.24 Work Orders Work 691745, 660020, 693431, 633532, 623717, 628964, 636059,
Authorization 637670. 667076, 687594, 665510, 68689, 693869, 644467,
Number 627199, 692507
71114.02 Corrective Action CR-YYYY-NNNN 2023-7167
Documents
Resulting from
Inspection
71114.02 Miscellaneous Form 1 - Siren Test - Quarterly Growl - Date of Test: 12/9/20 01/05/2021
21
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.02 Miscellaneous Form 1 - Siren Test - Bi-Weekly Silent - Date of Test: 11/16/2020
10/14/20
71114.02 Miscellaneous Form 1 - Siren Test - Bi-Weekly Silent - Date of Test: 6/23/21 06/30/2021
71114.02 Miscellaneous Form 1 - Siren Test - Quarterly Growl - Date of Test: 9/22/21 10/06/2021
71114.02 Miscellaneous Form 1 - Siren Test - Quarterly Growl - Date of Test: 3/23/22 03/23/2022
71114.02 Miscellaneous Form 1 - Siren Test - Bi-Weekly Silent - Date of Test: 2/2/22 02/07/2022
71114.02 Miscellaneous Form 1 - Siren Test - Complete Cycle Test - Date of Test: 07/25/2021
6/23/21
71114.02 Miscellaneous RE: Testing Your Alert Radio, Batteries for Alert Radios, and 01/27/2021
Alert Radio Test Schedule
71114.02 Miscellaneous EP-00006 Prompt Notification System Design Report 4
71114.02 Miscellaneous Integrated Public Attachment 7, IPAWS Quality Checklist 03/28/2023
Alert and Warning
System (IPAWS)
Procedure 66
71114.02 Procedures 0PGP05-ZV-0007 Prompt Notification System 13
71114.03 Miscellaneous Form 19 - ENRS Test - Quarterly - Test Date: 12/1/20 12/07/2020
71114.03 Miscellaneous Form 19 - ENRS Test - Quarterly - Test Date: 11/11/21 12/13/2021
71114.03 Miscellaneous Emergency Notification and Response System (ENRS) Tests 10/19/2022
- Quarterly - Test Date: 9/13/22
71114.03 Miscellaneous Emergency Notification and Response System (ENRS) Tests 02/28/2023
- Quarterly - Test Date: 2/22/23
71114.03 Miscellaneous Emergency Notification and Response System (ENRS) Tests 06/22/2023
- Quarterly - Test Date: 6/20/23
71114.03 Miscellaneous Form 19 - ENRS Test - Quarterly - Test Date: 3/1/22 03/09/2022
71114.03 Procedures 0EPR04-UA-0002 ENRS Operation 1
71114.03 Procedures 0ERP01-ZV-IN03 Emergency Response Organization Notification 19
71114.03 Procedures 0PGP05-ZV-0003 Emergency Response Organization 22
71114.04 Corrective Action Condition Reports 23-7171
Documents
Resulting from
Inspection
71114.04 Miscellaneous 0EPR03-FM- Protective Action Recommendation Decision Flowcharts 0
ALL06
22
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.04 Miscellaneous 0EPR03-FM- Classification Public Address Announcements 0, 1
ALL14
71114.04 Miscellaneous 0EPR04-UA-0019 Site Evacuation Routes 0, 1
71114.04 Miscellaneous 0EPR04-UA-0020 STAMPEDE User's Manual 0, 1
71114.04 Miscellaneous 50.54(q) Update to EP0005.000, Protective Action Recommendation 11/18/2021
Effectiveness Basis Document
Evaluation,
Evaluation CR
Tracking Number:
21-8929-2
71114.04 Miscellaneous 50.54(q) EP-0002.000, On-Shift Staffing Analysis (OSA) 09/29/2021
Effectiveness
Evaluation,
Evaluation CR
Tracking Number:
21-8929-3
71114.04 Miscellaneous 50.54(q) Replacement of ARINC Security Computer System Software 04/04/2023
Effectiveness (Condition Report 21-6686)
Evaluation,
Evaluation CR
Tracking Number:
23-78-4
71114.04 Miscellaneous 50.54(q) 0EPR04-UA-0019, Site Evacuation Routes, Revision 1 03/31/2022
Effectiveness
Evaluation,
Evaluation CR
Tracking Number:
CR #20-2575-155
71114.04 Miscellaneous 50.54(q) Screen 0EPR04-UA-0020, STAMPEDE User's Manual, Rev. 1 03/16/2022
Evaluation,
Evaluation CR
Tracking Number:
20-2575-150
71114.04 Miscellaneous 50.54(q) Screen 0EPR02-CK-EOF06, EOF RP Coordinator Checklist, Rev. 1 03/17/2022
23
Inspection Type Designation Description or Title Revision or
Procedure Date
Evaluation,
Evaluation CR
Tracking Number:
20-2575-150
71114.04 Miscellaneous 50.54(q) Screen 0EPM03-FM-ADM11, Quarterly EP Performance Indicator 03/17/2022
Evaluation, Report, Rev. 1
Evaluation CR
Tracking Number:
20-2575-150
71114.04 Miscellaneous 50.54(q) Screen 0EPM03-FM-FAE06, Quarterly Field Monitoring Team Kit 3/17/2022
Evaluation, Inventory, Rev. 1
Evaluation CR
Tracking Number:
20-2575-150
71114.04 Miscellaneous 50.54(q) Screen 0EPR03-FM-ALL14, Classification Public Address 03/29/2022
Evaluation, Announcement, Rev. 1
Evaluation CR
Tracking Number:
20-2575-153
71114.04 Miscellaneous 50.54(q) Screen 0PGP05-ZV-0018, Beyond Design Basis Event Emergency 03/30/2022
Evaluation, Response Organization Activation, Rev. 1
Evaluation CR
Tracking Number:
20-2575-169
71114.04 Miscellaneous 50.54(q) Screen 0EPM01-IP-0006, Emergency Preparedness Drills and 11/18/2021
Evaluation, Exercises, Rev. 0
Evaluation CR
Tracking Number:
21-4440-6
71114.04 Miscellaneous 50.54(q) Screen Offsite Dose Calculation Manual (ODCM), Revision 23 12/06/2022
Evaluation,
Evaluation CR
Tracking Number:
22-5917-18
24
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.04 Miscellaneous NOC-AE- South Texas Project, Units 1 and 2,; Docket Nos. STN 50- 05/04/2022
22003890 498; STN 50-499; 72-1041; Change to South Texas Project
Electric Generating Station (STPEGS) Emergency Plan
71114.04 Procedures 0ERP01-ZV-IN07 Offsite Protective Action Recommendations 19
71114.04 Procedures 0PGP05-ZV-0010 Emergency Plan Change 19, 20
71114.05 Corrective Action CR-YYYY-NNNN 2020-11164, 2020-11806, 2021-4027, 2021-6619,
Documents 2021-9291, 2021-9430, 2021-9436, 2021-10299, 2022-997,
2022-1985, 2022-3555, 2022-4020, 2022-4756, 2022-4857,
2022-5557, 2022-6188, 2022-6303, 2022-7177, 2022-7011,
22-9178, 2022-11207, 2022-12137, 2023-369, 2023-638,
202023-745, 2023-1118, 2023-1581, 2023-1734, 2023-1969,
2023-1978, 2023-4788, 2023-4886, 2023-5773, 2023-6135,
23-6141, 2023-6767, 23-6771, 23-6985
71114.05 Corrective Action CR-YYYY-NNNN 2023-7090, 2023-7168, 2023-7170, 2023-7172, 2023-7174,
Documents 2023-7230
Resulting from
Inspection
71114.05 Miscellaneous 0EPM03-FM-FAE13 - Quarterly Computer Functional Test - 01/31/2023
1st Quarter 2023
71114.05 Miscellaneous Form 18 - Quarterly Computer Functional Test - 1st Quarter 01/31/2022
2022
71114.05 Miscellaneous South Texas Project Electric Generating Station, 10 CFR 04/26/2022
50.155 Evaluation Report, White Team - December 1, 2021
71114.05 Miscellaneous South Texas Project Electric Generating Station; Blue Team 04/5/2022
Tabletop Evaluation Report, February 12th, 2020
71114.05 Miscellaneous South Texas Project Electric Generating Station; New EPlan 04/05/2022
Validation Drill Evaluation Report, White Team - February
9th, 2022
71114.05 Miscellaneous South Texas Project Electric Generating Station; Dress 10/21/2021
Rehearsal Evaluation Report, Red Team - June 16, 2021
71114.05 Miscellaneous Environmental Sampling Drill, Final Report, December 1, 1/20/2022
2021
71114.05 Miscellaneous South Texas Project Electric Generating Station; Exercise 10/21/2021
Evaluation Report, Red Team - July 28 and 29, 2021
25
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.05 Miscellaneous 2021 Health Physics Drill, Final Report, August 17, 2021 10/19/2021
71114.05 Miscellaneous South Texas Project Electric Generating Station; Blue Team 12/29/2022
Combined Functional Drill, November 30, 2022, Evaluation
Report
71114.05 Miscellaneous South Texas Project Electric Generating Station; 2022 07/11/2022
Exercise Dress Rehearsal Evaluation Report, White Team -
June 8th, 2022
71114.05 Miscellaneous South Texas Project Electric Generating Station; 2022 08/17/2022
Exercise Evaluation Report, White Team - July 20, 2022
71114.05 Miscellaneous Environmental Monitoring Drill, Final Report, December 7, 01/19/2023
2022
71114.05 Miscellaneous STP 2022 KeROP Drill 2nd Quarter, EPlan Scenarios 07/06/2022
Evaluation Report, June 16, 2022
71114.05 Miscellaneous STP 2022 KeROP Drill 3rd Quarter, EPlan Scenarios 02/09/2023
Evaluation Report, July 1 - September 30, 2022
71114.05 Miscellaneous South Texas Project Electric Generating Station, 2022 Red 10/21/2022
Team Combined Functional Drill, September 21st, 2022,
Evaluation Report
71114.05 Miscellaneous STP 2022 Shift Manager Up Relief Drills, EPlan Scenarios 07/06/2022
Evaluation Report, February 3 - March 31, 2022
71114.05 Miscellaneous STP 2022 State & County Drills 2nd Quarter, EPlan 07/06/2022
Scenarios Evaluation Report, April 1 - June 20, 2022
71114.05 Miscellaneous STP 2023 State & County Drills 1st Quarter, EPlan 04/26/2023
Scenarios Evaluation Report, January 1 - March 31
71114.05 Miscellaneous STP 2022 KeROP Drill 1st Quarter, EPlan Scenarios 07/06/2022
Evaluation Report, March 30, 2022
71114.05 Miscellaneous STP 2021 Licensed Operator Requal Cycle 212, EPlan 04/20/2022
Scenarios Evaluation Report, May 4 - June 21, 2021
71114.05 Miscellaneous STP 2021 Licensed Operator Requal Cycle 213, EPlan 06/28/2022
Scenarios Evaluation Report, August 10 - September 7,
2021
71114.05 Miscellaneous STP 2022 Licensed Operator Requal Cycle 223, EPlan 07/6/2022
Scenarios Evaluation Report, May 23 - June 20, 2022
71114.05 Miscellaneous STP 2022 Licensed Operator Requal Cycle 225, EPlan 01/19/2023
26
Inspection Type Designation Description or Title Revision or
Procedure Date
Scenarios Evaluation Report, November 13 - December 15,
2022
71114.05 Miscellaneous STP 2023 Licensed Operator Requal Cycle 231, EPlan 05/08/2023
Scenarios Evaluation Report, January 31 - February 28,
2023
71114.05 Miscellaneous South Texas Project Electric Generating Station; 2023 07/10/2023
Onsite Medical Response Capabilities Demonstration May
24th, 2023
71114.05 Miscellaneous Audit Report STP Nuclear Operating Company, Emergency Preparedness 03/03/2020
Number 20-01 Quality Audit Report
(EP)
71114.05 Miscellaneous Audit Report STP Nuclear Operating Company; Emergency Preparedness 03/11/2021
Number 21-01 Quality Audit Report
(EP)
71114.05 Miscellaneous Audit Report STP Nuclear Operating Company; Emergency Preparedness 03/15/2022
Number 22-01 Quality Audit Report
(EP)
71114.05 Miscellaneous Audit Report STP Nuclear Operating Company; Emergency Preparedness 03/23/2023
Number 23-01 Quality Audit Report
(EP)
71114.05 Miscellaneous EP-0004 Evacuation Time Estimate 2012 Revision 0 09/06/2021
71114.05 Miscellaneous KLD TR-1244 South Texas Project Electric Generating Station, 07/29/2022
Development of Evacuation Time Estimates
71114.05 Procedures 0EPM01-IP-0001 Emergency Preparedness Program Administration 0
71114.05 Procedures 0EPM01-IP-0003 Emergency Preparedness Facilities/Equipment Inventories 0
and Surveillances
71114.05 Procedures 0EPM01-IP-0004 Equipment Important to Emergency Response 0
71114.05 Procedures 0EPM01-IP-0005 Emergency Preparedness Training & Qualification 0
71114.05 Procedures 0EPM01-IP-0006 Emergency Preparedness Drills and Exercises 1
71114.05 Procedures 0EPR01-IP-0002 Emergency Notifications 1
71114.05 Procedures 0EPR01-IP-0003 Site Evacuation 0
71114.05 Procedures 0EPR01-IP-0004 Emergency Exposure Controls 0
71114.05 Procedures 0EPR01-IP-0005 Termination and Recovery 0
71114.05 Procedures 0PGP03-ZV-0005 Equipment Important to Emergency Response 7
27
Inspection Type Designation Description or Title Revision or
Procedure Date
71114.05 Procedures 0PGP03-ZX-0002 Condition Reporting Process 53
71114.05 Procedures 0PGP03-ZX- CAQ Resolution Process 16
0002A
71114.05 Procedures 0PGP03-ZX- Station Cause Analysis Program 14
0002B
71114.05 Procedures 0PQP01-ZA-0001 Internal Audits 24
71114.05 Procedures 0PQP01-ZA-0001 Internal Audits 24
71114.05 Procedures 0PQP01-ZA-0015 Oversight Planning and Scheduling Process 37
71114.05 Procedures EP-0003 South Texas Project Electric Generating Station (STPEGS) 0
Emergency Action Level Technical Bases Manual
71114.05 Procedures EP-0005 Protective Action Recommendation (PAR) Strategies 11/19/2021
71114.06 Procedures 0EPR01-IP-0002 Emergency Notifications 1
71114.06 Procedures 0POP05-EO- Reactor Trip or Safety Injection 27
EO00
71151 Corrective Action CR-YYYY-NNNN 2021-8961, 2022-1207, 2022-1983, 2022-1984, 2022-12059,
Documents 2022-12060
71151 Miscellaneous South Texas Project Electric Generating Station, 2022 Red 10/21/2022
Team Combined Functional Drill, September 21st, 2022,
Evaluation Report
71151 Miscellaneous STP 2022 Licensed Operator Requal Cycle 225, EPlan 01/19/2023
Scenarios Evaluation Report, November 13 - December 15,
2022
71151 Miscellaneous STP 2022 Licensed Operator Requal Cycle 231, EPlan 05/08/2023
Scenarios Evaluation Report, January 31 - February 28,
2023
71151 Procedures 0EPM04-UA-0003 EP Performance Indicator Evaluation and Tracking 0
71152A Corrective Action CR-YYYY-NNNN 2021-12048, 2023-6230, 2023-6231, 2023-6244, 2022-6950,
Documents 2022-6238, 2022-6240, 2023-6241, 2023-6243, 2023-6947,
2014-16257, 2021-12089, 2021-12337
71152A Drawings DWG-8113- 24 Expansion Joint Ass'y 5
00030TF
71152A Engineering CREE 21-12048-1, 14-16257-1
Evaluations
71152A Procedures WCG-0003 Planner's Guide 35
28
Inspection Type Designation Description or Title Revision or
Procedure Date
71152A Procedures WCG-0003 Planner's Guide 41
71152A Work Orders Work 662730, 662291
Authorization
Number
71153 Miscellaneous LER Unit 1, Pressurizer Power Operated Relief Valve Failed To 06/12/2023
05000498/2023- Open
001-00
71153 Miscellaneous LER Unit 1, Supplement to Pressurizer Power Operated Valve 07/26/2023
05000498/2023- Failed to Open
001-01
29