IR 05000498/2017008

STP - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000498/2017008; 05000499/201

ML17354A799
Person / Time
Site:	South Texas
Issue date:	12/22/2017
From:	Alexander R D, Taylor N H NRC/RGN-IV/DRP/RPB-A
To:	Powell G T South Texas
Taylor N H
References
IR 2017008
Download: ML17354A799 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511 December 2 2, 2017 Mr. G. Executive Vice President and CNO STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/ STAFFING/MU LTI-UNIT DOSE ASSESSMENT PLANS

- INSPECTION REPORT 05000498/2017008; 05000499/2017008

Dear Mr. Powell:

On October 27 , 2017, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of an inspection at the South Texas Project Electric Generating Station. On December 20, 2017 , the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA

-12-049 and EA-12-051) and Emergency Preparedness Communication , Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commission's rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance associated with this inspection

. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public

G. Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Nicholas H. Taylor

, Branch Chief Project Branch B Division of Reactor Projects Dockets: 50

-498; 50-499 Licenses: NPF

-76; NPF-80 Enclosure:

Inspection Report 05000498/2017008

and 05000499/2017008 w/ Attachment

Supplemental Information cc w/ encl: Electronic Distribution

1 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2017008 and 05000499/2017008 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: October 23

- December 20 , 2017 Inspectors:

R. Alexander, Sr. Project Engineer (Team Leader)

S. Anderson , Health Physicist N. Hernandez, Resident Inspector

- South Texas Project M. Stafford, Resident Inspector

- Cooper Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects

2

SUMMARY

IR 05000498/2017008, 05000499/201700 8; 10/23/2017

- 12/20/2017; South Texas Project Electric Generating Station, Units 1 and 2; Temporary Instruction 2515/191, Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans

, issued December 23, 2015.

The inspection covered a one week inspection onsite by the resident inspector and three inspectors from the Region IV office. No findings were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

None 3

REPORT DETAILS

4. Other Activities

4OA5 Other Activities

(TI 2515/191)

The objective of Temporary Instruction (TI) 2515/191 "Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi

-Unit Dose Assessment Plans" is to verify that licensees have adequately implemented the mitigation strategies as described in the licensee's Final Integrated Plan (ADAMS Accession No s. ML16067A088 and ML17062A303

) and the NRC's plant safety evaluation (ADAMS Accession No. ML16340A009) and to verify that the licensees installed reliable water

-level measurement instrumentation in their spent fuel pools. The purpose of this TI is also to verify the licensees have implemented Emergency Preparedness (EP) enhancements as described in their site

-specific submittals and NRC safety assessments, including multi

-unit dose assessment capability and enhancements to ensure that staffing is sufficient and communications can be maintained during such an event.

The inspection verified that plans for complying with NRC Orders EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond

-Design-Basis External Events (ADAMS Accession No. ML12229A174) and EA 051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No. ML12056A044) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012 request for information letter and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262). The team discussed the plans and strategies with plant staff, reviewed documentation, and where appropriate, performed plant walk downs to verify that the strategies could be implemented as stated in the licensee's submittals and the NRC staff

-prepared safety evaluation. For most strategies, this included verification that the strategy was feasible, procedures and/or guidance had been developed, training had been provided to plant staff, and required equipment had been identified and staged. Specific details of the team's inspection activities are described in the following sections.

1. Mitigation Strategies for Beyond

-Design-Basis External Events

a. Inspection Scope

The team examined the licensee's established guidelines and implementing procedures for the beyond

-design-basis mitigation strategies. The team assessed how the licensee coordinated and documented the interface/transition between existing off

-normal and Emergency Operating Procedures with the newly developed mitigation strategies. The 4 team selected a number of mitigation strategies and conducted plant walk downs with licensed operators and responsible plant staff to assess: the adequacy and completeness of the procedures; familiarity of operators with the procedure objectives and specific guidance; staging and compatibility of equipment; and the practicality of the operator actions prescribed by the procedures, consistent with the postulated scenarios.

The team verified that a preventive maintenance program had been established for the FLEX portable equipment and that periodic equipment inventories were in place and being conducted. Additionally, the team examined the introductory and planned periodic/refresher training provided to the Operations and other station staff most likely to be tasked with implementation of the FLEX mitigation strategies. The team also reviewed the introductory and planned periodic training provided to the Emergency Response Organization personnel.

b. Assessment Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 049. The inspectors verified that the licensee satisfactorily:

Developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events

Integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs are clear when using existing plant procedures

Protected FLEX equipment from site

-specific hazards

Developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability

Trained their staff to assure personnel proficiency in the mitigation of beyond-design-basis events; and Developed means to ensure that the necessary off

-site FLEX equipment will be available from off

-site locations

. The inspectors verified that any n on-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

5 2. Spent Fuel Pool (SFP) Instrumentation

a. Inspection Scope

The team examined the licensee's newly installed spent fuel pool instrumentation. Specifically, the inspectors verified the sensors were installed as described in the plant specific submittals and the associated safety evaluation

, and that the cabling for the power supplies and the indications for each channel are physically and electrically separated. Additionally, environmental conditions and accessibility of the instruments were evaluated. Documents reviewed are listed in the attachment.

b. Assessment Based on samples selected for review, the inspectors determined that the licensee satisfactorily installed and established control of the SFP instrumentation as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is generally in compliance with NRC Order EA 051. The inspectors verified that the licensee satisfactorily:

Installed the SFP instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittal and safety evaluation

Installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; and Trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation.

The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

3. Staffing and Communication Request for Information

a. Inspection Scope

Through discussions with plant staff, review of documentation and plant walk downs, the team verified that the licensee has implemented required changes to staffing, communications equipment and facilities to support an extended loss of all AC power (ELAP) scenario as described in the licensee's staffing assessment and the NRC safety assessment. The team also verified that the licensee has implemented dose assessment (including releases from spent fuel pools) capability using the licensee's 6 site-specific dose assessment software and approach as described in the licensee's dose assessment submittal. Documents reviewed are listed in the attachment.

b. Assessment The inspectors reviewed information provided in the licensee's multi

-unit dose submittal and in response to the NRC's March 12, 2012, request for information letter and verified that the licensee satisfactorily implemented enhancements pertaining to Near

-Term Task Force Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to the site and impedes access to the site.

The inspectors verified the following:

Licensee satisfactorily implemented required staffing change(s) to support an ELAP scenario; Emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP scenario; and Implemented dose assessment capabilities (including releases from spent fuel pools) using the licensee's site

-specific dose assessment software and approach.

The inspectors verified that any non-compliances with current licensing requirements, and other issues identified during the inspection were entered into the licensee's corrective action program.

c. Findings

No findings identified.

4OA6 Exit Exit Meeting Summary

On October 27, 2017, the inspectors presented the on-site inspection results in a management debrief with Mr. G.T. Powell, Chief Nuclear Officer, and other members of the site staff. The inspectors confirmed that proprietary information examined during the inspection had been returned. The inspectors completed an exit meeting conducted with Mr. G.T. Powell, Chief Nuclear Officer , a nd other members of the site staff, via telephone on December 20, 2017 , to discuss the final results of the inspection.

ATTACHMENT: SUPPLEMENTA L INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aguilera, Manager, Plant Protection/Emergency Response

P. Alier, Operations Performance Analysis & Investigations

W. Brost, Senior Engineer, Licensing

K. Brune, Plant Operator

A. Capristo, Executive VP & Chief Administrative Officer

J. Connolly, Site Vice President

M. Coughlin, Operations Support, Procedures

K. Elliott, Plant Operator

G. Ferrigno, General Supervisor, Health Physics

Z. Mielscht, Plant Operator

M. Murray, Manager, Regulatory Affairs/Licensing

G. Powell, Chief Nuclear Officer

S. Rodgers, Supervisor, Emergency Response

M. Ruvalcaba, Manager, Beyond Design Basis Response

M. Schaefer, Plant General Manager

T. White, Electrician

NRC Personnel

A. Sanchez, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed

2515/191 TI Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi

-Unit Dose Assessment Plans

, issued December 23, 2015

LIST OF DOCUMENTS REVIEWED

Section 4OA5

Other Activities Corrective Action Documents

2012-11658, Action

111 2012-11658, Action

547 2012-12320, Action

2012-12320, Action 90

2014-13084 2014-16065 2015-02513 2015-03238 2015-07745 2015-09561 2015-10251 2015-10731 2015-10732 2015-10801 2015-11016 2015-11017 2015-11161 2015-11172 2015-12085 2015-16311 2015-21140 2015-22393 2015-24648 2015-24899 2015-26727 2016-05077 2016-05083 2016-05796 2016-07339 2016-09278 2016-09785 2016-15370, Action 6

2017-15976 2017-17538 2017-19034 2017-19908 2017-20925 2017-20926 *2017-22544 *2017-22586 *2017-22589 *2017-22590 *2017-22592 *2017-22613 *2017-22640 * - indicates corrective action document written by the licensee as a result of the NRC inspection

Drawings

Number Title Revision 00001E0FRAA #1

Single Line Diagram Unit 1 FLEX Onsite Auxiliary Power 480V FR Load Distribution Panel DP1000

00002E0FRAA #1

Single Line Diagram Unit 2 FLEX Onsite Auxiliary Power 480V FR Load Distribution Panel DP1000

00009E0DAAB #1

Single Line Diagram 125 V DC Distribution Panels PL125C, PL125G, (MAB) PL125D, PL125H, (EAB) 26 00009E0DAAE #1

Single Line Diagram 125 V DC Power Distribution Swbd 1B (EAB) 14 3M15-9-C-34004 Concrete Mechanical and Electrical Aux. Bldg. Isolation Valve Cubicle Section A

819-M-27286 MTU Onsite Energy: AC Diagram for FLEX Diesel Generato rs April 14, 2014

Procedures

Number Title Revision 0ERP01-ZV-TP01 Offsite Dose Calculations

0PEP01-ZE-0003 Core Reload Design Process Reload Safety Evaluation

0PGP03-ZO-0056 FLEX Equipment Functionality Program

0PGP03-ZO-FLEX FLEX Support Guideline Program

0PGP03-ZT-0139 Emergency Preparedness Training Program

0PGP05-ZV-0003 Emergency Response Organization

0PGP05-ZV-0009 Emergency Facility Inventories and Inspections

0PGP05-ZV-0014 Emergency Response Activities

0POP01-ZA-0001 Plant Operations Department Administrative Guidelines

0POP01-ZA-0001 Plant Operations Department Administrative Guidelines

0POP04-AE-0007 Loss of All AC Power While on Shutdown Cooling

0POP04-FC-0001 Loss of Spent Fuel Pool Level or Cooling

0POP04-ZO-0002 Natural or Destructive Phenomena Guidelines

0POP04-ZO-0004 Extreme Cold Weather Guidelines

0POP05-EO-EC00 Loss of All AC Power

0POP05-EO-EC00 Loss of All AC Power

0POP07-FR-0006 FLEX Diesel Generator Performance Test

0POP12-ZO-FSG01 Long Term RCS Inventory Control

0POP12-ZO-FSG03 Alternate Low Pressure Feedwater

0POP12-ZO-FSG04

ELAP DC Bus Load Shed/Management

0POP12-ZO-FSG05 Initial Assessment and FLEX Equipment Staging

0POP12-ZO-FSG06 Alternate AFWST Makeup

0POP12-ZO-FSG08 Alternate RCS Boration

0POP12-ZO-FSG09 Low Decay Heat Temperature Control

0POP12-ZO-FSG10 RCS Accumulator Injection Isolation

0POP12-ZO-FSG11

Alternate SFP Makeup and Cooling

0POP12-ZO-FSG12 Alternate Containment Cooling

0POP12-ZO-FSG13 Transition from FLEX Equipment

Procedures

Number Title Revision 0POP12-ZO-FSG14 Shutdown RCS Makeup

0POP12-ZO-FSG17 Portable Pump Fill of RWST

0POP12-ZO-FSG19 480V Flex Diesel Generator Operation

0POP12-ZO-FSG21 NSRC Turbine Generator 1

FLEX-0002 Final Integrated Plan

IMT-0001 Integrated Maintenance Team Guideline Security Instruction

1007 Security Severe Weather Plan

ZV-0001 Emergency Response Desktop Guide Instruction: STAMPEDE User's Manual

ZV-0028 Emergency Response Desktop Guide Instruction: SAFER Response Plan Parent/Model Work Orders Number Title Revision / Date

14000140 Portable Diesel Driven Pump Inspect/Lubricate

14000141 Portable Diesel Driven Pump Inspect/Lubricate

14000142 Portable Diesel Driven Pump Inspect/Lubricate

14000143 Portable Diesel Driven Pump Flow Test

14000144 FLEX Emergency Portable Diesel Driven Pump

14000145 Portable Diesel Driven Pump Flow Test

15000127 Unit 2 Calibrate SFPI

15000130 Perform Mechanical Inspection, Lubrication, and Function Testing of the FLEX Tractor

15000133 FLEX RCS Makeup Pump 26 Hand Rotation/Inspect

15000141 FLEX RCS Makeup Pump 23 Clean/Lubricate/Inspect

15000143 FLEX RCS Makeup Pump 24 Clean/Lubricate/Inspect

15000144 FLEX RCS Makeup Pump 26 Clean/Lubricate/Inspect

15000169 Replace Drive Coupling for FLEX Steam Generator Makeup Pump #22

15000181 FLEX Diesel Generator #22 Clean/Inspect/Test

15000186 FLEX RCS Makeup Pump 13 Pump Bearing Oil Change

Parent/Model Work Orders Number Title Revision / Date

15000213 Unit 2 Replace SFPI Back Up Power Supply Batteries

15000253 Unit 2 Replace SFPLI Sensor (Model Work Order)

15000437 Hand Rotate and Visually Inspect FLEX Steam Generator Makeup Pump #11

15000445 Change Pump Bearing Oil and Replace Drive Coupling for FLEX Steam Generator Makeup Pump #11

15000447 Clean, Inspect, Lubricate and Run FLEX Steam Generator Makeup Pump #12

15000451 Replace all hoses for FLEX Steam Generator Makeup

15000597 Inspect/Inventory FLEX Storage Boxes (Unit 2)

15000776 FLEX RCS Makeup Pump 16 Clean/Lubricate/Inspect

15000787 FLEX RCS Makeup Pump 14 Pump Bearing Oil Change

15000861 FLEX Diesel Generator #11 Output Breaker

15000944 Unit 1 Replace SFPI Back Up Power Supply Batteries

15000946 Unit 1 Calibrate SFPI 0

15000948 Unit 1 Replace SFPLI Sensor (Model Work Order)

15000949 FLEX SFP Makeup Pump #15

15000985 FLEX Diesel Generator #11 Vibration Data Collection

15000993 Inspect/Inventory FLEX Storage Boxes (Unit 1)

Calculations

15-FR-014 15-FR-020

Miscellaneous

Documents/Reports Number Title Revision / Date

South Texas Project Units 1 and 2 Flood Analysis

EC00 Validations from 4

-30-15, 11-9-15 and 10-25-16 {None} 12-11658-741 Condition Report Engineering Evaluation (CREE)

EMC 151.02

Electrical Maintenance Continuing Training: FLEX Modification Familiarization

ICC 151.02

I&C 2015 Cycle Continuing Training: FLEX

IMT 303.01

I&C Training and Qualifications: Level Measurement Fundamentals

Miscellaneous

Documents/Reports Number Title Revision / Date

LOR-POR 145.01

FLEX Strategies for ELAP {None} LOT 508.01

FLEX Guidelines Presentation

MMC 151.04

Mechanical Maintenance Continuing Training: FLEX Mods and MM

NOC-AE-14003189 Insights from the Fukushima Dai

-ichi Accident

- Phase 2 Staffing Assessment November 25, 2014

NOC-AE-150003255 Supplement to Insights from the Fukushima Dai

-ichi Accident - Phase 2 Staffing Assessment July 2, 2015

NOC-AE-16003328 Second Supplement to Insights from the Fukushima Dai-ichi Accident

- Phase 2 Staffing Assessment June 30, 2016

NOC-AE-16003421 Supplemental Information

- Final Integrated Plan February 20, 2017 POR 145.07

Plant Operator FLEX Training Presentation

ST-UB-NOC-17003573 STPNOC Cycle 21 Redesign Final Reload Evaluation

U1C21-1 Unit 1 Cycle 21 Reload Safety Evaluation and Core Operating Limits Report

VTD-C970-0001 Vendor Technical Document: CASE Hi Agriculture Operator's Manual

XC-16003-N-R-001 Compliance Matrix Report

000

ML17354A799

SUNSI Review By:

RDA/rdr ADAMS

Yes

No

Non-Sensitive

Sensitive

Publicly Available Non-Publicly Available Keyword:

NRC-002 OFFICE SPE:DRP/A RI:DRP/C HP:DNMS RI:DRP/B BC:DRP/B

NAME RAlexander

MStafford SAnderson NHernandez

NTaylor

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

DATE 12/20/17 12/20/17 12/20/17 12/20/17 12/22/17