ML25093A339

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– Notification of Comprehensive Engineering Team Inspection (05000498/2025011 and 05000499/2025011) and Request for Information
ML25093A339
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/07/2025
From: Dustin Reinert
NRC/RGN-IV/DORS/EB1
To: Harshaw K
South Texas
References
IR 2025011
Download: ML25093A339 (9)


See also: IR 05000498/2025011

Text

April 07, 2025

Kimberly A. Harshaw, Acting President

CEO and Chief Nuclear Officer

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND

2 - NOTIFICATION OF COMPREHENSIVE ENGINEERING TEAM

INSPECTION (05000498/2025011 AND 05000499/2025011) AND REQUEST

FOR INFORMATION

Dear Kimberly A. Harshaw:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

staff will conduct the comprehensive engineering team inspection at South Texas Project

Electric Generating Station, Units 1 and 2, beginning on July 14, 2025. The inspection team will

be composed of six personnel from the NRC Region IV office. The inspection will be conducted

in accordance with NRC inspection procedure (IP) 71111.21M, Comprehensive Engineering

Team Inspection, dated October 7, 2022.

The objectives of the inspection are to verify that risk-significant structures, systems, and

components (SSCs) have been maintained and will operate within their design and licensing

bases requirements; modifications to risk-significant SSCs did not introduce conditions that

adversely impact the ability of SSCs to perform their design and licensing bases functions; the

design basis, licensing basis, and performance capability of SSCs have not been adversely

impacted by changes introduced through degraded conditions and other activities; and that

requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.59 have been

appropriately implemented.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

Onsite Information Gathering Visit: June 2-5, 2025

Offsite Preparation Week: July 7-10, 2025

Onsite Inspection Weeks: July 14-17, 2025, and July 28-31, 2025

The purpose of the information gathering visit is to meet with your staff to become familiar with

South Texas Project Electric Generating Stations SSCs, programs, processes, and procedures

and to ensure the resources needed to support the team, as necessary, to conduct an effective

and efficient inspection. This visit may include a tour of installed plant SSCs associated with

potential inspection samples. During the visit, the team lead will also review the information

K. Harshaw

2

provided in the initial information request to select a list of potential inspection samples. The

team lead may also identify other information needed to support the inspection during this visit.

To minimize the impact on your staff and to ensure an effective and efficient inspection, we

have enclosed two separate requests for information needed prior to the onsite information

gathering visit and offsite inspection preparation week. The first request (Enclosure 1) is

generally for information that will be used to choose the inspection samples or information that

will be applicable to all inspection samples throughout the inspection. This information should be

made available to the team lead prior to the information gathering visit. The second request

(Enclosure 2) is for information that is specific to an individual sample and should be made

available prior to the offsite preparation week.

Additional information requests, interviews with your staff, and/or tours of facilities or installed

plant components will be made by the team throughout the inspection to complete their review

of the selected inspection samples. It is important that all documentation provided to the team is

complete and up to date to minimize the number of additional documents requested during the

preparation and/or the onsite portions of the inspection. Additionally, to facilitate an efficient

inspection, we request that a contact individual be assigned to each inspector to ensure

information requests, questions, and concerns are addressed in a timely manner.

We understand that Zachary Dibbern from your Licensing organization is our contact for this

inspection. If there are any questions about the inspection or the information requested, please

contact the team lead, Wes Cullum, by telephone at 817-200-1563 or by e-mail at

Wes.Cullum@nrc.gov. Enclosure 3 contains additional contact information for the inspection

team.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, under Control Number

3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a

request for information or an information collection requirement unless the requesting document

displays a currently valid Office of Management and Budget control number.

In accordance with 10 CFR 2.390 of the NRC rules and practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC public document

room or from the publicly available records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site.

Sincerely,

Dustin Reinert, Acting Branch Chief

Engineering Branch 1

Division of Operating Reactor Safety

Signed by Reinert, Dustin

on 04/07/25

K. Harshaw

3

Docket Nos. 05000498; 05000499

License Nos. NPF-76; NPF-80

Enclosures:

1.

Documents Requested Prior to

Information Gathering Visit

2.

Documents Requested Prior to

Inspection Preparation Week

3.

Inspection Team Contact Information

cc w/ encl: Distribution via LISTSERV

ML25093A339

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SUNSI Review

By: WLC

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Non-Sensitive

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Sensitive

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Publicly Available

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Non-Publicly Available

OFFICE

SRI:DORS:EB1

BC:DORS:EB1

NAME

WCullum

DReinert

SIGNATURE

/RA/

/RA/

DATE

04/07/25

04/07/25

Enclosure 1

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both on-site and off-site during the information gathering

visit. Electronic format is the preferred media. If electronic media is made available via an

internet based remote document management system, then the remote document access must

allow inspectors to download, save, and print the documents in the NRC's regional office.

Electronic media on compact disc or paper records (hard copy) are acceptable. At the end of

the inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by May 22,2025:

1.

Copy of South Texas Project Electric Generating Stations probabilistic risk

assessment (PRA) summary document for the current internal events, external

events (e.g., fire, flooding, seismic), and shutdown PRA models of record.

2.

From the internal events PRA, a sortable list of structures, systems, and components

(SSCs) with risk achievement worth (RAW) and Birnbaum values for both core

damage frequency (CDF) and large early release frequency (LERF). Include all basic

events with RAW values of 1.3 or greater and Birnbaum values of 1E-6 or greater.

3.

From the external events PRA, a sortable list of SSCs with RAW and Birnbaum

values for both CDF and LERF. Include all basic events with RAW values of 1.3 or

greater and Birnbaum values of 1E-6 or greater.

4.

From the internal events PRA, a sortable list of human failure events (HFEs) with

RAW and Birnbaum values for both CDF and LERF.

5.

From the external events PRA, a sortable list of HFEs with RAW and Birnbaum

values for both CDF and LERF.

6.

Sortable list of SSCs and HFEs sorted by engineering or expert panel judgement

such as those performed to identify risk-significant SSCs for South Texas Project

Electric Generating Stations Maintenance Rule program.

7.

Sortable list of SSCs with known low analytical, operating, maintenance, or

complexity margin, if available.

8.

Sortable list of temporary or permanent modifications that were implemented within

the past four years/since the last triennial NRC design bases inspection, including a

brief description, modification type, and whether the modification is safety-related.

Implemented means accepted or placed into service and declared

functional/operable, as applicable. Modifications may include, but are not limited to,

1-2

equivalency evaluations, commercial grade dedications, and changes to SSCs,

procedures, set points, calculations, designs, and/or the licensing bases.

9.

Sortable list of 10 CFR 50.59 applicability determinations of implemented changes,

tests, and experiments that did not result in a screening within the past four

years/since the last triennial NRC 10 CFR 50.59 inspection.

10.

Sortable list of 10 CFR 50.59 screenings of implemented changes, tests, and

experiments that did not result in an evaluation within the past four years/since the

last triennial NRC 10 CFR 50.59 inspection.

11.

Sortable list of 10 CFR 50.59 evaluations of implemented changes, tests, and

experiments that did not result in an application for a license amendment within the

past four years/since the last triennial NRC 10 CFR 50.59 inspection.

12.

Sortable list of implemented changes, tests, and experiments where an alternate

process or screening criteria was applied within the past four years/since the last

triennial NRC 10 CFR 50.59 inspection.

13.

Copy of the last two submittals of the report containing a brief description of any

changes, tests, and experiments, including a summary of the evaluation of each,

required by 10 CFR 50.59(d)(2).

14.

Sortable list of operating experience evaluations performed within the past four

years/since the last triennial NRC design bases inspection, including whether the

operating experience was applicable. Operating experience sources may include, but

are not limited to, NRC generic communications, licensee event reports, plant

operating experience, 10 CFR Part 21 reports, previous NRC inspection findings,

and vendor communications.

15.

Sortable list of corrective action program documents associated with issues identified

during the last NRC design bases inspection.

16.

Copy of implementing/program procedures, as applicable, for performing

modifications, time critical/sensitive operator actions, 10 CFR 50.59 activities,

operating experience evaluations, and the corrective action program.

17.

Copy of any self-assessments or audits in preparation for this inspection or related to

activities associated with this inspection (i.e., design, modifications, 10 CFR 50.59,

operating experience) performed within the past four years.

18.

Copy of the updated final safety analysis report, technical specifications, technical

requirements manual, surveillance frequency control program, quality assurance

program, and inservice testing program, including applicable bases documents.

19.

Sortable list of normal, abnormal, or emergency procedures.

20.

Sortable list of systems, including identifying designators and corresponding names.

21.

List of personnel who will be assisting with the inspection, including contact

information.

Enclosure 2

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both on-site and

off-site during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hard copy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested for each sample type by June 30, 2025:

1.

Structure, System, and Component (SSC) Samples

a.

Copy of relevant design bases document, system description, etc.

b.

Copy of relevant vendor manuals (i.e., installation, operation, maintenance).

c.

Copy of relevant design calculations, diagrams, and drawings.

d.

Copy of relevant normal, abnormal, or emergency procedures.

e.

List of relevant preventive maintenance activities, including a brief

description, and frequency. Include procedures/instructions and most recently

completed work order/job for each activity.

f.

List of relevant inspections and tests, including a brief description, and

frequency. Include procedures/instructions and most recently completed work

order/job for each inspection/test.

g.

Copy of the relevant PRA system notebook.

h.

Copy of the relevant system health notebook.

i.

Sortable list of relevant corrective action program documents, including a

brief description, within the past four years. Alternatively, if the number of

documents is few, provide complete copies of these documents with any

attachments.

2.

Modification Samples

a.

Copy of the complete change package.

2-2

b.

Copy of the completed implementing work order.

c.

Copy of any post-modification tests, etc.

d.

Copy of any relevant corrective action program documents.

e.

Copy of relevant vendor manuals (i.e., installation, operation, maintenance).

f.

Copy of affected procedures, training materials, preventive maintenance or

inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

3.

10 CFR 50.59 Samples

a.

Copy of the relevant 10 CFR 50.59 applicability determination, screening, or

evaluation.

b.

Copy of training/qualification record/status of personnel who performed the

10 CFR 50.59 activity.

c.

Copy of any relevant corrective action program documents.

d.

Copy of any affected procedures, training materials, preventive maintenance

or inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

4.

Operating Experience Samples

a.

Copy of the complete operating experience evaluation.

b.

Copy of any relevant corrective action program documents.

c.

Copy of any affected procedures, training materials, preventive maintenance

or inspection/testing activities, calculations, design specifications, drawings,

updated final safety analysis report, technical specifications, etc.

Enclosure 3

Enclosure 3

Inspection Team Contact Information

Wes Cullum (Lead)

Senior Reactor Inspector

817-200-1563

Wes.Cullum@nrc.gov

Rayo Kumana

Senior Reactor Inspector

817-200-1426

Rayomand.Kumana@nrc.gov

Fabian Thomas

Reactor Inspector

817-200-1126

Fabian.Thomas@nrc.gov

Dustin Bryen

Reactor Inspector

817-200-1078

Dustin.Bryen@nrc.gov

Beatrice Nwafor

Reactor Inspector

817-200-1462

Beatric.Nwafor@nrc.gov

Kent Chambliss

Senior Resident Inspector

817-200-1981

Kent.Chambliss@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Wes Cullum

1600 East Lamar Blvd.

Arlington, TX 76011-4511