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{{#Wiki_filter:OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION August 05, 2022 Mr. G. T. Powell President and CEO STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 | {{#Wiki_filter:OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | ||
August 05, 2022 | |||
Mr. G. T. Powell President and CEO STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 | |||
==SUBJECT:== | ==SUBJECT:== | ||
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==Dear Mr. Powell:== | ==Dear Mr. Powell:== | ||
On June 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project Electric Generating Station, Units 1 and 2. On June 30, 2022 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 report is comprised of two enclosures. Enclosure 1 contains the publicly available version of the inspection report and Enclosure 2 contains the Official Use Only - | On June 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project Electric Generating Station, Units 1 and 2. On June 30, 2022 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 report is comprised of two enclosures. Enclosure 1 contains the publicly available version of the inspection report and Enclosure 2 contains the Official Use Only - | ||
Security Related Information portions of the inspection report. | Security Related Information portions of the inspection report. | ||
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs. | The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs. | ||
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. The specifics of the weakness are discussed in Enclosure 2. | Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. The specifics of the weakness are discussed in Enclosure 2. | ||
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. | The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments. | ||
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. | Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION G. Powell | Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based upon the interviews and document reviews, the team found that your organization had a safety conscious work environment where individuals felt free to raise safety | ||
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this transmittal document and Enclosure 1 are decontrolled. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION G. Powell 2 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATIONconcerns without fear of retaliation. All individuals interviewed indicated that they would not hesitate to raise safety concerns through at least one of the means available. However, the team identified that multiple individuals in the Security department indicated a strong hesitancy in bringing up concerns to some members of management at the site and that some of these individuals also expressed mixed experiences raising issues through the corrective action program and the employee concerns program. The team also noted that multiple individuals in the Security department described low morale concerns, that if not addressed, could erode the individuals willingness to bring up nuclear safety or security concerns in the future. | |||
One finding of very low safety significance (Green) is documented in this report (Enclosure 2). | One finding of very low safety significance (Green) is documented in this report (Enclosure 2). | ||
This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. | This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. | ||
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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. | 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 enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. | This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. | ||
Sincerely, | Sincerely, Ami N. Agrawal, Inspection Programs & Assessment Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80 | ||
==Enclosures:== | ==Enclosures:== | ||
As stated cc w/ encl: Distribution via LISTSERV Signed by Agrawal, Ami on 08/05/22 | |||
ML22210A099 Public Designation Category: (Cover Letter and Enclosure 1) | |||
ADAMS ACCESSION NUMBER: ML22220A045 | |||
Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available | |||
OFFICE TA:ORA SPSI:PSB SRI:STP C:PBB TL:ACES SRI:IPAT TL:IPAT | |||
NAME L. Flores J. Rollins G.Kolcum R. Deese J. Groom F.Ramirez A. Agrawal | |||
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ | |||
DATE 7/29/2022 7/29/2022 8/1/2022 8/3/2022 8/1/2022 8/2/2022 8/5/2022 | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | U.S. NUCLEAR REGULATORY COMMISSION Inspection Report | ||
Docket Numbers: 05000498 and 05000499 | |||
License Numbers: NPF76 and NPF80 | |||
Report Numbers: 05000498/2022010 and 05000499/2022010 | |||
Enterprise Identifier: I-2022-010-0004 | |||
Licensee: STP Nuclear Operating Company | |||
Facility: South Texas Project Electric Generating Station, Units 1 and 2 | |||
Location: Wadsworth, TX | |||
Inspection Dates: June 06, 2022 to June 24, 2022 | |||
Inspectors: F. Ramirez Munoz, Senior Reactor Inspector (Lead) | |||
L. Flores, Technical Assistant G. Kolcum, Senior Resident Inspector J. Rollins, Senior Physical Security Inspector | |||
Approved By: Ami N. Agrawal, Inspection Programs & Assessment Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety | |||
Enclosure 1 | |||
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, the transmittal document and Enclosure 1 are decontrolled. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
==SUMMARY== | ==SUMMARY== | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at South Texas Project Electric Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. | |||
List of Findings and Violations | |||
Failure to use the site corrective action program to correct failures and deficiencies in the physical protection program. | |||
Cornerstone Significance Cross-Cutting Report Aspect Section Security Green [H.1] - 71152B NCV 05000498,05000499/2022010-01 Resources Open/Closed The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the failure to use the site corrective action program to correct and prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in Enclosure 2 of this report. | |||
Additional Tracking Items | |||
None. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 2 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 2 | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
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 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. | |||
OTHER ACTIVITIES - BASELINE | |||
OTHER ACTIVITIES - BASELINE 71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04) (1 Sample) | |||
(1) | 71152B - Problem Identification and Resolution | ||
Biennial Team Inspection (IP Section 03.04) (1 Sample) | |||
(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment. | |||
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled over 240 condition reports and their associated cause evaluations, if applicable. The inspectors also conducted a five-year review of the component cooling water system, which included review of failures, maintenance issues, surveillances, corrective and preventive maintenance, reliability, and maintenance rule performance. In addition, the inspectors reviewed 17 NRC findings and violations issued during the biennial period. | Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled over 240 condition reports and their associated cause evaluations, if applicable. The inspectors also conducted a five-year review of the component cooling water system, which included review of failures, maintenance issues, surveillances, corrective and preventive maintenance, reliability, and maintenance rule performance. In addition, the inspectors reviewed 17 NRC findings and violations issued during the biennial period. | ||
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments. The sample included industry operating experience communications like 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups, and site evaluations. The sample also included reviews of licensee self-assessments and internal audits. | Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments. The sample included industry operating experience communications like 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups, and site evaluations. The sample also included reviews of licensee self-assessments and internal audits. | ||
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment. The team interviewed 65 individuals, observed interactions between licensee employees and management during routine meetings, interviewed the employee concerns program manager and reviewed employee concerns files. | Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment. The team interviewed 65 individuals, observed interactions between licensee employees and management during routine meetings, interviewed the employee concerns program manager and reviewed employee concerns files. | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 3 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 3 | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
INSPECTION RESULTS | |||
Assessment 71152B Corrective Action Program Assessment | |||
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions adequately supported nuclear safety. | |||
Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. | Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety. | ||
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team generally found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance. | Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team generally found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance. | ||
However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. This weakness is described further in Enclosure 2 to this report. | However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. This weakness is described further in Enclosure 2 to this report. | ||
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the STP Nuclear Operating Company developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants component cooling water system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs. | Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the STP Nuclear Operating Company developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants component cooling water system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs. | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION The team reviewed a variety of sources of operating experience including part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups. The team determined that STP Nuclear Operating Company is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received. | Assessment 71152B Use of Self-Assessment & Audits | ||
Assessment | |||
The team reviewed a sample of STP Nuclear Operating Company's departmental self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process. | |||
Assessment 71152B Use of Operating Experience | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 4 | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
The team reviewed a variety of sources of operating experience including part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups. The team determined that STP Nuclear Operating Company is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received. | |||
Assessment 71152B Safety Conscious Work Environment (SCWE) | |||
The team conducted safety conscious work environment interviews with 65 employees from five different disciplines that included operations, security, mechanical maintenance, electrical maintenance and instrumentations and controls maintenance. The purpose of these interviews was (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method, (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and (3) to evaluate the licensee's safety conscious work environment (SCWE). The team also observed interactions between employees during routine condition report screening committee meetings, plant management alignment meetings, management performance improvement committee meetings, and plant health committee meetings. The team interviewed the employee concerns program manager and reviewed the results of the latest safety culture surveys and a sample of case files that may relate to safety conscious work environment. | The team conducted safety conscious work environment interviews with 65 employees from five different disciplines that included operations, security, mechanical maintenance, electrical maintenance and instrumentations and controls maintenance. The purpose of these interviews was (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method, (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and (3) to evaluate the licensee's safety conscious work environment (SCWE). The team also observed interactions between employees during routine condition report screening committee meetings, plant management alignment meetings, management performance improvement committee meetings, and plant health committee meetings. The team interviewed the employee concerns program manager and reviewed the results of the latest safety culture surveys and a sample of case files that may relate to safety conscious work environment. | ||
Based upon the interviews and document reviews, the team found that the licensee had a safety conscious work environment where individuals felt free to raise safety concerns without fear of retaliation. However, the team identified that multiple individuals in the Security department indicated a strong hesitancy in bringing up concerns to some members of management at the site. In addition, some of these individuals expressed mixed experiences raising issues through the corrective action program and the employee concerns program. All individuals indicated that they would not hesitate to raise safety concerns through at least one of the means available. The team also noted that the individuals in the Security department described low morale concerns, which appear to be caused by factors such as low staffing levels, perceived inconsistencies in management actions, long time security equipment material condition issues, and an uneasiness toward managements reaction to their concerns. The team concluded that if not addressed, these morale concerns could erode the individuals willingness to bring up safety or security concerns in the future. | Based upon the interviews and document reviews, the team found that the licensee had a safety conscious work environment where individuals felt free to raise safety concerns without fear of retaliation. However, the team identified that multiple individuals in the Security department indicated a strong hesitancy in bringing up concerns to some members of management at the site. In addition, some of these individuals expressed mixed experiences raising issues through the corrective action program and the employee concerns program. All individuals indicated that they would not hesitate to raise safety concerns through at least one of the means available. The team also noted that the individuals in the Security department described low morale concerns, which appear to be caused by factors such as low staffing levels, perceived inconsistencies in management actions, long time security equipment material condition issues, and an uneasiness toward managements reaction to their concerns. The team concluded that if not addressed, these morale concerns could erode the individuals willingness to bring up safety or security concerns in the future. | ||
Failure to use the site corrective action program to correct failures and deficiencies in the physical protection program. | Failure to use the site corrective action program to correct failures and deficiencies in the physical protection program. | ||
Cornerstone | Cornerstone Significance Cross-Cutting Report Aspect Section Security Green [H.1] - 71152B NCV 05000498,05000499/2022010-01 Resources Open/Closed The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the failure to use the site corrective action program to correct and prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in of this report. | ||
== | == | ||
Description:== | Description:== | ||
This non-cited violation is described in Enclosure 2 of this report. | This non-cited violation is described in Enclosure 2 of this report. | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 5 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 5 | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
Corrective Actions: Immediate corrective actions included evaluating each of the examples discussed in the non-cited violation and addressing the rigor or timeliness of each of the corrective actions. Long term corrective action will include revising the site corrective action program procedure to provide more guidance on the treatment and dispositioning of security related conditions such that they are more consistently evaluated when entered into the corrective action program. | |||
Corrective Action | Corrective Action | ||
==References:== | ==References:== | ||
CR-22-6335 Performance Assessment: | CR-22-6335 Performance Assessment: | ||
Performance Deficiency: The failure to use the site corrective action program to correct failures and deficiencies in the physical protection program is a performance deficiency. It is a performance deficiency because the licensee failed to meet 10 CFR 73.55(b)(10), and it was within the licensees ability to reasonably foresee and correct and should have been prevented. | Performance Deficiency: The failure to use the site corrective action program to correct failures and deficiencies in the physical protection program is a performance deficiency. It is a performance deficiency because the licensee failed to meet 10 CFR 73.55(b)(10), and it was within the licensees ability to reasonably foresee and correct and should have been prevented. | ||
Screening and Significance: The screening for and significance of this non-cited violation are documented in Enclosure 2 of this report. | Screening and Significance: The screening for and significance of this non-cited violation are documented in Enclosure 2 of this report. | ||
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. | Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. | ||
Specifically, the site corrective action procedures did not adequately define security conditions adverse to quality. | Specifically, the site corrective action procedures did not adequately define security conditions adverse to quality. | ||
Enforcement: | Enforcement: | ||
Violation: 10 CFR 73.55(b)(10) states, The licensee shall use the site corrective action program to track, trend, correct and prevent recurrence of failures and deficiencies in the physical protection program. The violation details are documented in Enclosure 2 of this inspection report. | Violation: 10 CFR 73.55(b)(10) states, The licensee shall use the site corrective action program to track, trend, correct and prevent recurrence of failures and deficiencies in the physical protection program. The violation details are documented in Enclosure 2 of this inspection report. | ||
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. | ||
Observation: Failure to properly categorize security-related issues as conditions | |||
Observation: Failure to properly categorize security-related issues as conditions 71152B adverse to quality As part of the weakness associated with evaluating adverse conditions in security-related issues described in the Assessment in this inspection report, the inspectors identified multiple examples where condition reports associated with security material condition issues were mischaracterized as conditions not adverse to quality. | |||
This Observation is described in Enclosure 2 of this report. | This Observation is described in Enclosure 2 of this report. | ||
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report. | |||
EXIT MEETINGS AND DEBRIEFS | |||
The inspectors verified no proprietary information was retained or documented in this report. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 6 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 6 | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
On June 30, 2022, the inspectors presented the biennial problem identification and resolution inspection results to G. T. Powell and other members of the licensee staff. | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 7 | OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 7 | ||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION | |||
DOCUMENTS REVIEWED | |||
Inspection Type Designation Description or Title Revision or Procedure Date 71152B Corrective Action CR-YY-XXXXX 10-12459, 14-13753, 14-6987, 16-12163, 17-17236, 17-Documents 17661, 17-17881, 17-18548, 17-20797, 17-22418, 17-24388, 18-10057, 18-10999, 18-11196, 18-12007, 18-12083, 18-12088, 18-14530, 18-2162, 18-2348, 18-2411, 18-2895, 18-3130, 18-3789, 18-4057, 18-769, 19-10766, 19-1112,19-11395, 19-11396, 19-12209, 19-1754, 19-4392, 19-4450, 19-55, 19-5912, 19-7052, 19-9128, 19-9764, 20-10764, 20-10853, 20-10997, 20-11051, 20-11052, 20-11191, 20-11192, 20-11210, 20-11211, 20-11240, 20-11268, 20-11272, 20-11309, 20-11316, 20-11416, 20-11427, 20-11501, 20-11761, 20-11881, 20-12242, 20-12244, 20-12485, 20-12486, 20-12592, 20-12625, 20-12654, 20-12749, 20-12750, 20-12778, 20-12783, 20-1281, 20-12816, 20-1472, 20-1939, 20-2387,20-2965,20-3068,20-3678,20-423,20-4381,20-4781,20-5027,20-5114,20-5192,20-5583,20-5619,20-5756, 20-5779, 20-5822, 20-6001, 20-6508, 20-7550, 20-8130, 20-8186, 20-8187, 20-8434, 20-8449, 20-8648, 20-8991, 20-9464, 20-9820, 21-06, 21-10102, 21-10157, 21-1019, 21-1028, 21-1052, 21-10824, 21-10846, 21-10847, 21-10848, 21-10932, 21-10971, 21-11317, 21-11535, 21-11536, 21-11537, 21-11582, 21-1184, 21-12577, 21-12872, 21-12873, 21-12874, 21-13005, 21-13049, 21-13050, 21-13051, 21-13086, 21-1319, 21-1338, 21-1460, 21-1834, 21-2611, 21-2739, 21-284, 21-2888, 21-2897, 21-3118, 21-3144, 21-3181, 21-3239, 21-3626, 21-3681, 21-3908, 21-4011, 21-4104, 21-4603, 21-4845, 21-4991, 21-5111, 21-54, 21-545, 21-5663, 21-6004, 21-609, 21-6109, 21-624, 21-6507, 21-7054, 21-7105, 21-7106, 21-7107, 21-7108, 21-7306, 21-7397, 21-7457, 21-7460, 21-7482, 21-7605, 21-7651, 21-7923, 21-8238, 21-8248, 21-860, 21-8763, 21-8767, 21-9038, 21-9059, 21-9143, 21-9370, 21-9743, 21-9789, 21-9892, 21- | |||
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 8 | |||
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Inspection Type Designation Description or Title Revision or Procedure Date 9893, 21-9938, 21-9991, 22-1004, 22-1301, 22-1622, 22-1690, 22-1830, 22-2230, 22-2344, 22-2345, 22-2346, 22-2399, 22-248, 22-2776, 22-280, 22-281, 22-282, 22-2865, 22-2947, 22-3131, 22-3204, 22-3205, 22-3208, 22-3916, 22-4160, 22-4319, 22-4328, 22-4329, 22-4347, 22-4356, 22-4368, 22-4574, 22-4602, 22-4621, 22-4632, 22-4636, 22-4644, 22-4655, 22-4729, 22-4741, 22-4753, 22-4757, 22-4760, 22-4766, 22-4773, 22-4774, 22-4783, 22-4784, 22-4811, 22-4816, 22-4821, 22-4822, 22-4825, 22-4837, 22-4865, 22-493, 22-5297, 22-5524, 22-5549, 22-673, 22-799 Corrective Action CR YY-NNNN 22-5717, 22-5834, 22-5944, 22-6040, 22-6068, 22-6069, 22-Documents 6076, 22-6095, 22-6145, 22-6146, 22-6335, 22-6338, 22-Resulting from 6340, 22-6342, 22-5660, 22-5661, 22-5662, 22-5664, 22-Inspection 5665, 22-5669, 22-5670, 22-5671,19-9764, 21-6004, 21-1834, 22-4757, 22-4760, 22-4766, 22-4773, 22-4774, 22-4783, 22-4811, 22-4821, 22-4822, 22-4825, 22-4837, 20-11268, 20-11309, 20-03, 21-03, 22-4319, 22-4328, 22-4347, 22-4368, 22-4574, 22-4621, 22-4632, 22-4636, 22-4644, 22-4655, 22-4741, 22-4753, 22-4784, 22-4816, 22-4865,19-9128, 21-7923, 21-8767, 20-12783, 21-10971, 21-860, 22-4602, 21-2888, 21-3118, 21-7605, 22-248, 21-4104, 22-4160 Drawings 21246 Duo-Check Valve Installation DIMS and Parts List 03/09/1995 Engineering 21-7397-10 Revise VTD-V037-0001 based on the ACE 21-7397-8 0 Changes Miscellaneous STP NOC 2021 Plant Wide Employee Survey 1 CAP Health Reports from November 2020 through May 2022 5R209MB01018 Design Basis Document Component Cooling Water System 4 5Z689ZS1027 Specification for Instrument Construction 14 65054 Model Work Instruction CC-Q2-2021 System Health Report Component Cooling Water System 12/31/2021 CC-Q2-2021 System Health Report Component Cooling Water System 07/01/2021 CP13-0217 Chemical Permit for NALCO 1359 plus 07/10/2013 SOER 86-3 RHR Supply Containment Isolation Trains A, B, and C 04/24/1989 | |||
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Inspection Type Designation Description or Title Revision or Procedure Date Recommendations, Pg. 110 VTD-L253-0002 Vendor Technical Document Lovejoy Couplings Jaw Type 1 Operability STP-411 Reporting of Safety-Related Quality Concerns 6 Evaluations Procedures 0PGP03-ZA-0010 Performing and Verifying Station Activities 42 0PGP03-ZA-0014 Foreign Material Exclusion Program 39 0PGP03-ZA-0090 Work Process Program 45 0PGP03-ZA-0091 Configuration Risk Management Program 14 0PGP03-ZA-0140 Plant Status Control 16 0PGP03-ZA-0504 Employee Concerns Program 16 0PGP03-ZA-0514 Controlled System or Barrier Impairment 20 0PGP03-ZC-0002 Circuit Board Repair Control Program 6 0PGP03-ZE-0083 License Renewal Implementation & Operating Experience 2 Review 0PGP03-ZE-0133 Boric Acid Corrosion Control Program 13 0PGP03-ZM-0002 Preventive Maintenance Program 42 0PGP03-ZM-0021 Control of Configuration Changes 22 0PGP03-ZO-0042 Reactivity Management Program 23 0PGP03-ZO-0054 Operational Decision-Making 12 0PGP03-ZO-9900 Operability Determinations Program 9 0PGP03-ZP-0014 Commercial Grade Item Dedication / Technical Evaluation 6 0PGP03-ZV-0004 Winter Readiness Program 10 and 11 0PGP03-ZX-0002 Condition Reporting Process 52 0PGP03-ZX-Condition Adverse to Quality (CAQ) Resolution Process 15 0002A 0PGP03-ZX-Root Cause Investigations 13 0002B 0PGP03-ZX-Station Cause Analysis Program 13 0002B 0PGP03-ZX-0003 Station Self-Assessment Program 15 0PGP03-ZX-0008 Condition Not Adverse to Quality (CNAQ) Resolution 2 Process | |||
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Inspection Type Designation Description or Title Revision or Procedure Date 0PGP03-ZX-0013 Operating Experience Program 15 0PGP03-ZX-Processing Industry Operating Experience 1 0013A 0PGP03-ZX-0016 Trending Process Procedure 5 0PGP04-ZE-0313 Maintenance Rule Program 9 0PGP05-ZA-0002 10CFR50.59 Evaluations 18 0PLP01-ZA-0004 Control of the 10CFR50.59 Resource Manual 1 0PMP04-EW-Essential Cooling Water Self Cleaning Strainer Maintenance24 0003 0PMP08-ZI-0134 Generic QDPS Loop Calibration 16 0POP01-ZO-0004 Extreme Cold Weather Guidelines 42 and 43 0POP02-CC-0001 Component Cooling Water 54 0PQP01-ZA-0001 Internal Audits 23 0PQP02-ZA-0003 Quality Surveillance and Performance Monitoring Programs12 0PSP03-CC-0002 Component Cooling Water Pump 1B(2B) Inservice Test 18 0PTP02-ZC-0003 Metrology Laboratory Security Zone Requirements 4 CAP-0002 Causal Analysis Guideline 5 CAP-0003 Condition Report Screening 4 SEG-0005 System Health Reporting Guideline 12 SEG-0009 Maintenance Rule Basis Document Guideline 6 SEG-0014 Maintenance Rule Program Users Guideline 3 STP-0411 Reporting of Safety-Related Quality Concerns 6 STP-0430 Conduct of Company Investigations 2 STP-0723 Employee Concerns Program 2 VTD-A585-0010 Instruction Manual for Dual Plate Check Valves 6 VTD-V037-0001 Installation, Operation, Maintenance Instructions for Mark 8 One and Two Control Valves WCG-0002 Work Management Scheduling 47 Self-Assessments 21-06 Maintenance Work Control Quality Audit Report 09/16/2021 STI: 35197061 Quality Oversight Performance Assessment Report May-12/09/2021 October 2020 Work Orders WO-XXXXXX 660213, 660214, 660215, 660216, 660217, 406249, 435794, | |||
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Inspection Type Designation Description or Title Revision or Procedure Date 515317, 529848, 620113, 621731, 568647, 583463, 655533, 566336, 568647, 604333, 621731, 649575 | |||
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Revision as of 05:56, 16 November 2024
| ML22220A045 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/08/2022 |
| From: | Ami Agrawal NRC/RGN-IV/DORS |
| To: | Gerry Powell South Texas |
| Ramirez F | |
| References | |
| IR 2022010 | |
| Download: ML22220A045 (15) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
August 05, 2022
Mr. G. T. Powell President and CEO STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2022010 AND 05000499/2022010
Dear Mr. Powell:
On June 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project Electric Generating Station, Units 1 and 2. On June 30, 2022 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 report is comprised of two enclosures. Enclosure 1 contains the publicly available version of the inspection report and Enclosure 2 contains the Official Use Only -
Security Related Information portions of the inspection report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety. However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. The specifics of the weakness are discussed in Enclosure 2.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based upon the interviews and document reviews, the team found that your organization had a safety conscious work environment where individuals felt free to raise safety
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, this transmittal document and Enclosure 1 are decontrolled.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION G. Powell 2 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATIONconcerns without fear of retaliation. All individuals interviewed indicated that they would not hesitate to raise safety concerns through at least one of the means available. However, the team identified that multiple individuals in the Security department indicated a strong hesitancy in bringing up concerns to some members of management at the site and that some of these individuals also expressed mixed experiences raising issues through the corrective action program and the employee concerns program. The team also noted that multiple individuals in the Security department described low morale concerns, that if not addressed, could erode the individuals willingness to bring up nuclear safety or security concerns in the future.
One finding of very low safety significance (Green) is documented in this report (Enclosure 2).
This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at South Texas Project 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 enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami N. Agrawal, Inspection Programs & Assessment Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80
Enclosures:
As stated cc w/ encl: Distribution via LISTSERV Signed by Agrawal, Ami on 08/05/22
ML22210A099 Public Designation Category: (Cover Letter and Enclosure 1)
ADAMS ACCESSION NUMBER: ML22220A045
Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available
OFFICE TA:ORA SPSI:PSB SRI:STP C:PBB TL:ACES SRI:IPAT TL:IPAT
NAME L. Flores J. Rollins G.Kolcum R. Deese J. Groom F.Ramirez A. Agrawal
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 7/29/2022 7/29/2022 8/1/2022 8/3/2022 8/1/2022 8/2/2022 8/5/2022
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
U.S. NUCLEAR REGULATORY COMMISSION Inspection Report
Docket Numbers: 05000498 and 05000499
License Numbers: NPF76 and NPF80
Report Numbers: 05000498/2022010 and 05000499/2022010
Enterprise Identifier: I-2022-010-0004
Licensee: STP Nuclear Operating Company
Facility: South Texas Project Electric Generating Station, Units 1 and 2
Location: Wadsworth, TX
Inspection Dates: June 06, 2022 to June 24, 2022
Inspectors: F. Ramirez Munoz, Senior Reactor Inspector (Lead)
L. Flores, Technical Assistant G. Kolcum, Senior Resident Inspector J. Rollins, Senior Physical Security Inspector
Approved By: Ami N. Agrawal, Inspection Programs & Assessment Team Leader Inspection Programs & Assessment Team Division of Operating Reactor Safety
Enclosure 1
Enclosure 2 transmitted herewith contains SUNSI. When separated from Enclosure 2, the transmittal document and Enclosure 1 are decontrolled.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at South Texas Project Electric Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to use the site corrective action program to correct failures and deficiencies in the physical protection program.
Cornerstone Significance Cross-Cutting Report Aspect Section Security Green [H.1] - 71152B NCV 05000498,05000499/2022010-01 Resources Open/Closed The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the failure to use the site corrective action program to correct and prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in Enclosure 2 of this report.
Additional Tracking Items
None.
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution
Biennial Team Inspection (IP Section 03.04) (1 Sample)
(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled over 240 condition reports and their associated cause evaluations, if applicable. The inspectors also conducted a five-year review of the component cooling water system, which included review of failures, maintenance issues, surveillances, corrective and preventive maintenance, reliability, and maintenance rule performance. In addition, the inspectors reviewed 17 NRC findings and violations issued during the biennial period.
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments. The sample included industry operating experience communications like 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups, and site evaluations. The sample also included reviews of licensee self-assessments and internal audits.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment. The team interviewed 65 individuals, observed interactions between licensee employees and management during routine meetings, interviewed the employee concerns program manager and reviewed employee concerns files.
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INSPECTION RESULTS
Assessment 71152B Corrective Action Program Assessment
Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions adequately supported nuclear safety.
Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team generally found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
However, the team identified a weakness associated with evaluating adverse conditions associated with security-related issues. This weakness is described further in Enclosure 2 to this report.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the STP Nuclear Operating Company developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants component cooling water system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with this system that were not already being addressed by the station's monitoring and corrective action programs.
Assessment 71152B Use of Self-Assessment & Audits
The team reviewed a sample of STP Nuclear Operating Company's departmental self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.
Assessment 71152B Use of Operating Experience
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
The team reviewed a variety of sources of operating experience including part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups. The team determined that STP Nuclear Operating Company is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Assessment 71152B Safety Conscious Work Environment (SCWE)
The team conducted safety conscious work environment interviews with 65 employees from five different disciplines that included operations, security, mechanical maintenance, electrical maintenance and instrumentations and controls maintenance. The purpose of these interviews was (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method, (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and (3) to evaluate the licensee's safety conscious work environment (SCWE). The team also observed interactions between employees during routine condition report screening committee meetings, plant management alignment meetings, management performance improvement committee meetings, and plant health committee meetings. The team interviewed the employee concerns program manager and reviewed the results of the latest safety culture surveys and a sample of case files that may relate to safety conscious work environment.
Based upon the interviews and document reviews, the team found that the licensee had a safety conscious work environment where individuals felt free to raise safety concerns without fear of retaliation. However, the team identified that multiple individuals in the Security department indicated a strong hesitancy in bringing up concerns to some members of management at the site. In addition, some of these individuals expressed mixed experiences raising issues through the corrective action program and the employee concerns program. All individuals indicated that they would not hesitate to raise safety concerns through at least one of the means available. The team also noted that the individuals in the Security department described low morale concerns, which appear to be caused by factors such as low staffing levels, perceived inconsistencies in management actions, long time security equipment material condition issues, and an uneasiness toward managements reaction to their concerns. The team concluded that if not addressed, these morale concerns could erode the individuals willingness to bring up safety or security concerns in the future.
Failure to use the site corrective action program to correct failures and deficiencies in the physical protection program.
Cornerstone Significance Cross-Cutting Report Aspect Section Security Green [H.1] - 71152B NCV 05000498,05000499/2022010-01 Resources Open/Closed The NRC identified a Green non-cited violation of 10 CFR 73.55(b)(10) for the failure to use the site corrective action program to correct and prevent recurrence of failures and deficiencies in the physical protection program. This non-cited violation is described in of this report.
==
Description:==
This non-cited violation is described in Enclosure 2 of this report.
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Corrective Actions: Immediate corrective actions included evaluating each of the examples discussed in the non-cited violation and addressing the rigor or timeliness of each of the corrective actions. Long term corrective action will include revising the site corrective action program procedure to provide more guidance on the treatment and dispositioning of security related conditions such that they are more consistently evaluated when entered into the corrective action program.
Corrective Action
References:
CR-22-6335 Performance Assessment:
Performance Deficiency: The failure to use the site corrective action program to correct failures and deficiencies in the physical protection program is a performance deficiency. It is a performance deficiency because the licensee failed to meet 10 CFR 73.55(b)(10), and it was within the licensees ability to reasonably foresee and correct and should have been prevented.
Screening and Significance: The screening for and significance of this non-cited violation are documented in Enclosure 2 of this report.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, the site corrective action procedures did not adequately define security conditions adverse to quality.
Enforcement:
Violation: 10 CFR 73.55(b)(10) states, The licensee shall use the site corrective action program to track, trend, correct and prevent recurrence of failures and deficiencies in the physical protection program. The violation details are documented in Enclosure 2 of this inspection report.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Failure to properly categorize security-related issues as conditions 71152B adverse to quality As part of the weakness associated with evaluating adverse conditions in security-related issues described in the Assessment in this inspection report, the inspectors identified multiple examples where condition reports associated with security material condition issues were mischaracterized as conditions not adverse to quality.
This Observation is described in Enclosure 2 of this report.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
On June 30, 2022, the inspectors presented the biennial problem identification and resolution inspection results to G. T. Powell and other members of the licensee staff.
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DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or Procedure Date 71152B Corrective Action CR-YY-XXXXX 10-12459, 14-13753, 14-6987, 16-12163, 17-17236, 17-Documents 17661, 17-17881, 17-18548, 17-20797, 17-22418, 17-24388, 18-10057, 18-10999, 18-11196, 18-12007, 18-12083, 18-12088, 18-14530, 18-2162, 18-2348, 18-2411, 18-2895, 18-3130, 18-3789, 18-4057,18-769, 19-10766, 19-1112,19-11395, 19-11396, 19-12209, 19-1754, 19-4392, 19-4450, 19-55, 19-5912, 19-7052, 19-9128, 19-9764, 20-10764, 20-10853, 20-10997, 20-11051, 20-11052, 20-11191, 20-11192, 20-11210, 20-11211, 20-11240, 20-11268, 20-11272, 20-11309, 20-11316, 20-11416, 20-11427, 20-11501, 20-11761, 20-11881, 20-12242, 20-12244, 20-12485, 20-12486, 20-12592, 20-12625, 20-12654, 20-12749, 20-12750, 20-12778, 20-12783, 20-1281, 20-12816, 20-1472, 20-1939, 20-2387,20-2965,20-3068,20-3678,20-423,20-4381,20-4781,20-5027,20-5114,20-5192,20-5583,20-5619,20-5756, 20-5779, 20-5822, 20-6001, 20-6508, 20-7550, 20-8130, 20-8186, 20-8187, 20-8434, 20-8449, 20-8648, 20-8991, 20-9464, 20-9820, 21-06, 21-10102, 21-10157, 21-1019, 21-1028, 21-1052, 21-10824, 21-10846, 21-10847, 21-10848, 21-10932, 21-10971, 21-11317, 21-11535, 21-11536, 21-11537, 21-11582, 21-1184, 21-12577, 21-12872, 21-12873, 21-12874, 21-13005, 21-13049, 21-13050, 21-13051, 21-13086, 21-1319, 21-1338, 21-1460, 21-1834, 21-2611, 21-2739,21-284, 21-2888, 21-2897, 21-3118, 21-3144, 21-3181, 21-3239, 21-3626, 21-3681, 21-3908, 21-4011, 21-4104, 21-4603, 21-4845, 21-4991, 21-5111, 21-54,21-545, 21-5663, 21-6004,21-609, 21-6109,21-624, 21-6507, 21-7054, 21-7105, 21-7106, 21-7107, 21-7108, 21-7306, 21-7397, 21-7457, 21-7460, 21-7482, 21-7605, 21-7651, 21-7923, 21-8238, 21-8248,21-860, 21-8763, 21-8767, 21-9038, 21-9059, 21-9143, 21-9370, 21-9743, 21-9789, 21-9892, 21-
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Inspection Type Designation Description or Title Revision or Procedure Date 9893, 21-9938, 21-9991, 22-1004, 22-1301, 22-1622, 22-1690, 22-1830, 22-2230, 22-2344, 22-2345, 22-2346, 22-2399,22-248, 22-2776,22-280, 22-281,22-282, 22-2865, 22-2947, 22-3131, 22-3204, 22-3205, 22-3208, 22-3916, 22-4160, 22-4319, 22-4328, 22-4329, 22-4347, 22-4356, 22-4368, 22-4574, 22-4602, 22-4621, 22-4632, 22-4636, 22-4644, 22-4655, 22-4729, 22-4741, 22-4753, 22-4757, 22-4760, 22-4766, 22-4773, 22-4774, 22-4783, 22-4784, 22-4811, 22-4816, 22-4821, 22-4822, 22-4825, 22-4837, 22-4865,22-493, 22-5297, 22-5524, 22-5549,22-673, 22-799 Corrective Action CR YY-NNNN 22-5717, 22-5834, 22-5944, 22-6040, 22-6068, 22-6069, 22-Documents 6076, 22-6095, 22-6145, 22-6146, 22-6335, 22-6338, 22-Resulting from 6340, 22-6342, 22-5660, 22-5661, 22-5662, 22-5664, 22-Inspection 5665, 22-5669, 22-5670, 22-5671,19-9764, 21-6004, 21-1834, 22-4757, 22-4760, 22-4766, 22-4773, 22-4774, 22-4783, 22-4811, 22-4821, 22-4822, 22-4825, 22-4837, 20-11268, 20-11309, 20-03, 21-03, 22-4319, 22-4328, 22-4347, 22-4368, 22-4574, 22-4621, 22-4632, 22-4636, 22-4644, 22-4655, 22-4741, 22-4753, 22-4784, 22-4816, 22-4865,19-9128, 21-7923, 21-8767, 20-12783, 21-10971,21-860, 22-4602, 21-2888, 21-3118, 21-7605,22-248, 21-4104, 22-4160 Drawings 21246 Duo-Check Valve Installation DIMS and Parts List 03/09/1995 Engineering 21-7397-10 Revise VTD-V037-0001 based on the ACE 21-7397-8 0 Changes Miscellaneous STP NOC 2021 Plant Wide Employee Survey 1 CAP Health Reports from November 2020 through May 2022 5R209MB01018 Design Basis Document Component Cooling Water System 4 5Z689ZS1027 Specification for Instrument Construction 14 65054 Model Work Instruction CC-Q2-2021 System Health Report Component Cooling Water System 12/31/2021 CC-Q2-2021 System Health Report Component Cooling Water System 07/01/2021 CP13-0217 Chemical Permit for NALCO 1359 plus 07/10/2013 SOER 86-3 RHR Supply Containment Isolation Trains A, B, and C 04/24/1989
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Inspection Type Designation Description or Title Revision or Procedure Date Recommendations, Pg. 110 VTD-L253-0002 Vendor Technical Document Lovejoy Couplings Jaw Type 1 Operability STP-411 Reporting of Safety-Related Quality Concerns 6 Evaluations Procedures 0PGP03-ZA-0010 Performing and Verifying Station Activities 42 0PGP03-ZA-0014 Foreign Material Exclusion Program 39 0PGP03-ZA-0090 Work Process Program 45 0PGP03-ZA-0091 Configuration Risk Management Program 14 0PGP03-ZA-0140 Plant Status Control 16 0PGP03-ZA-0504 Employee Concerns Program 16 0PGP03-ZA-0514 Controlled System or Barrier Impairment 20 0PGP03-ZC-0002 Circuit Board Repair Control Program 6 0PGP03-ZE-0083 License Renewal Implementation & Operating Experience 2 Review 0PGP03-ZE-0133 Boric Acid Corrosion Control Program 13 0PGP03-ZM-0002 Preventive Maintenance Program 42 0PGP03-ZM-0021 Control of Configuration Changes 22 0PGP03-ZO-0042 Reactivity Management Program 23 0PGP03-ZO-0054 Operational Decision-Making 12 0PGP03-ZO-9900 Operability Determinations Program 9 0PGP03-ZP-0014 Commercial Grade Item Dedication / Technical Evaluation 6 0PGP03-ZV-0004 Winter Readiness Program 10 and 11 0PGP03-ZX-0002 Condition Reporting Process 52 0PGP03-ZX-Condition Adverse to Quality (CAQ) Resolution Process 15 0002A 0PGP03-ZX-Root Cause Investigations 13 0002B 0PGP03-ZX-Station Cause Analysis Program 13 0002B 0PGP03-ZX-0003 Station Self-Assessment Program 15 0PGP03-ZX-0008 Condition Not Adverse to Quality (CNAQ) Resolution 2 Process
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Inspection Type Designation Description or Title Revision or Procedure Date 0PGP03-ZX-0013 Operating Experience Program 15 0PGP03-ZX-Processing Industry Operating Experience 1 0013A 0PGP03-ZX-0016 Trending Process Procedure 5 0PGP04-ZE-0313 Maintenance Rule Program 9 0PGP05-ZA-0002 10CFR50.59 Evaluations 18 0PLP01-ZA-0004 Control of the 10CFR50.59 Resource Manual 1 0PMP04-EW-Essential Cooling Water Self Cleaning Strainer Maintenance24 0003 0PMP08-ZI-0134 Generic QDPS Loop Calibration 16 0POP01-ZO-0004 Extreme Cold Weather Guidelines 42 and 43 0POP02-CC-0001 Component Cooling Water 54 0PQP01-ZA-0001 Internal Audits 23 0PQP02-ZA-0003 Quality Surveillance and Performance Monitoring Programs12 0PSP03-CC-0002 Component Cooling Water Pump 1B(2B) Inservice Test 18 0PTP02-ZC-0003 Metrology Laboratory Security Zone Requirements 4 CAP-0002 Causal Analysis Guideline 5 CAP-0003 Condition Report Screening 4 SEG-0005 System Health Reporting Guideline 12 SEG-0009 Maintenance Rule Basis Document Guideline 6 SEG-0014 Maintenance Rule Program Users Guideline 3 STP-0411 Reporting of Safety-Related Quality Concerns 6 STP-0430 Conduct of Company Investigations 2 STP-0723 Employee Concerns Program 2 VTD-A585-0010 Instruction Manual for Dual Plate Check Valves 6 VTD-V037-0001 Installation, Operation, Maintenance Instructions for Mark 8 One and Two Control Valves WCG-0002 Work Management Scheduling 47 Self-Assessments 21-06 Maintenance Work Control Quality Audit Report 09/16/2021 STI: 35197061 Quality Oversight Performance Assessment Report May-12/09/2021 October 2020 Work Orders WO-XXXXXX 660213, 660214, 660215, 660216, 660217, 406249, 435794,
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Inspection Type Designation Description or Title Revision or Procedure Date 515317, 529848, 620113, 621731, 568647, 583463, 655533, 566336, 568647, 604333, 621731, 649575
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