IR 05000498/2016004

NRC Integrated Inspection Report 05000498/2016004 and 05000499/2016004

ML17045A224
Person / Time
Site:	South Texas
Issue date:	02/08/2017
From:	Nick Taylor NRC/RGN-IV/DRP/RPB-B
To:	Gerry Powell South Texas
NICK TAYLOR
References
IR 2016004
Download: ML17045A224 (69)

Text

ruary 13, 2017

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2016004 AND 05000499/2016004

Dear Mr. Powell:

On December 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On January 5, 2017, 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 NRC inspectors did not identify any findings or violations of more than minor significance.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Nicholas H. Taylor, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 05000498, 05000499 License Nos.: NPF-76, NPF-80

G.

Enclosure:

Inspection Report 05000498/2016004 and 05000499/2016004 w/ Attachment 1: Supplemental Information w/ Attachment 2: Information Request for Inservice Inspection Activities w/ Attachment 3: Information Request for O

REGION IV==

Docket: 05000498, 05000499 License: NPF-76, NPF-80 Report: 05000498/2016004, 05000499/2016004 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 1 through December 31, 2016 Inspectors: C. Smith, Acting Senior Resident Inspector A. Sanchez, Senior Resident Inspector N. Hernandez, Resident Inspector R. Azua, Senior Reactor Inspector L. Carson, II, Senior Health Physicist K. Clayton, Senior Operations Engineer S. Graves, Senior Reactor Inspector N. Greene, PhD, Health Physicist J. Melfi, Project Engineer M. Phalen, Senior Health Physicist D. Proulx, Senior Project Engineer Approved Nicholas H. Taylor By: Chief, Project Branch B Division of Reactor Projects Enclosure

SUMMARY

IR 05000498/2016004, 05000499/2016004; 10/01/2016 - 12/31/2016; South Texas Project

Electric Generating Station, Units 1 and 2, Integrated Inspection Report.

The inspection activities described in this report were performed between October 1 and December 31, 2016, by the resident inspectors at the South Texas Project and inspectors from the NRCs Region IV office. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609,

Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

No findings were identified.

PLANT STATUS

Unit 1 began the inspection period at full power and remained there for the remainder of the inspection period.

Unit 2 began the inspection period at full power. On October 1, 2016, the unit commenced coast down for a planned refueling outage. Refueling Outage 2RE18 began with a normal reactor shutdown on October 8, 2016. The unit remained in an outage until November 9, 2016, when the generator breaker was closed and the unit synchronized to the grid. Unit 2 returned to full power on November 14, 2016, and remained at full power for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On November 10, 2016, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous winter season.

The inspectors selected two risk-significant systems that were required to be protected from cold weather:

• Essential cooling water intake structure for Unit 1 and Unit 2

• Boric acid storage tanks for Unit 1 and Unit 2 The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by cold weather. The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the adverse weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On November 17, 2016, the inspectors completed an inspection of the stations readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensees procedures to respond to tornadoes and high winds, and the licensees planned implementation of these procedures. The inspectors evaluated operator staffing, and accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

• November 8, 2016, Unit 2, train A centrifugal charging pump while the positive displacement charging pump was out of service for planned maintenance

• November 30, 2016, Unit 2, train C high head safety injection system while train B high head safety injection system was out of service for planned maintenance The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted two partial system walk-down samples, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk-Down

a. Inspection Scope

On December 12, 2016, the inspectors performed a complete system walk-down inspection of the Unit 1 component cooling water (CCW) system. The inspectors reviewed the licensees procedures and system design information to determine the correct CCW system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety:

• October 18, 2016, Unit 2, reactor containment building, Fire Area 63, Fire Zone Z208

• October 21, 2016, Unit 2, turbine generator building, Fire Area 90, Fire Zone Z708

• November 8, 2016, Unit 1, mechanical auxiliary building, Fire Area 29, Fire Zone Z140

• November 8, 2016, Unit 1, mechanical auxiliary building, Fire Area 2, Fire Zone Z128

• November 22, 2016, Unit 1, electrical auxiliary building, Fire Area 2, Fire Zone Z005 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On November 3, 2016, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components (SSCs) that were susceptible to flooding:

• Unit 1, main control room The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

On December 13, 2016, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors:

(1) observed performance tests for the Unit 2 train A, B, and C, component cooling water heat exchangers;

(2) reviewed the data from a performance test for the component cooling water heat exchangers; and

(3) verified the licensee used the industry standard periodic maintenance method outlined in EPRI NP-7552, Heat Exchanger Performance Monitoring Guidelines, for the component cooling water heat exchangers. Additionally, the inspectors walked down the heat exchangers to observe its performance and material condition and verified that the heat exchangers were correctly categorized under the Maintenance Rule and were receiving the required maintenance.

These activities constituted completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R08 Inservice Inspection Activities

The activities described in subsections 1 through 4 below constitute completion of one inservice inspection sample, as defined in Inspection Procedure 71111.08.

.1 Non-destructive Examination Activities and Welding Activities

a. Inspection Scope

The inspectors directly observed the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Coolant 3-RC-2003-BB1-1 Ultrasonic System Reactor Coolant 4-RC-2126-BB1-3 Ultrasonic System Reactor Coolant 6-RC-2009-NSS-7 Ultrasonic System Reactor Coolant D2RCTE0420Y and Thermowell Penetrant System Reactor Coolant Reactor Coolant System Loop 2B Penetrant System Hot Leg Thermowell (E)

Installation Detail Reactor Coolant Reactor Coolant System Loop 2B Visual 1 System Hot Leg Thermowell (E)

Installation Detail Auxiliary Feedwater GUIDE/AF-2073-HL5002 Visual 3 System Auxiliary Feedwater RIGID RESTRAINT / Visual 3 System AF-2073-HL5004 Auxiliary Feedwater 4-AF-2073-GA2-C (WA1-WA2) Visual 1 and System Magnetic Particle Feedwater System FW2016 (FW-20) Radiograph Feedwater System FW2016 (FW-21) Radiograph The inspectors reviewed records for the following nondestructive examinations:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Main Steam System 30-MS-2001-GA2 (Weld 27) Ultrasonic During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all nondestructive examination technicians performing the inspections to determine whether they were current.

The inspectors directly observed a portion of the following welding activities:

SYSTEM WELD IDENTIFICATION WELD TYPE Reactor Coolant D2RCTE0420Y and Thermowell Gas Tungsten Arc System Welding The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code Section IX requirements.

The inspectors also determined whether that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.

b. Findings

No findings were identified.

.2 Vessel Upper Head Penetration Inspection Activities

No vessel upper head penetration inspection activities were scheduled for the South Texas Project, Unit 2, Outage 2RE18.

.3 Boric Acid Corrosion Control Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in Procedure 0PGP03-ZE-0133, Boric Acid Corrosion Control Program, Revision 10. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and whether engineering evaluation used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code and 10 CFR Part 50, Appendix B requirements.

b. Findings

No findings were identified.

.4 Steam Generator Tube Inspection Activities

No steam generator tube inspection activities were scheduled for the South Texas Project, Unit 2, Outage 2RE18.

.5 Identification and Resolution of Problems

a. Inspection scope

The inspectors reviewed 34 condition reports which dealt with inservice inspection activities and found the corrective actions were appropriate. From this review, the inspectors concluded that the licensee had an appropriate threshold for entering issues into the corrective action program and had procedures that directed a root cause evaluation when necessary. The inspectors also determined the licensee had an effective program for applying industry operating experience. Specific documents reviewed during this inspection are listed in the report attachment.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On October 26, 2016, the inspectors observed just-in-time simulator training of an operations crew preparing for Unit 2 reactor start-up following 2RE18. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the training event.

These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to the following:

• October 8, 2016, Unit 2, plant shutdown for Refueling Outage 2RE18

• October 11, 2016, Unit 2, reduced inventory operations for planned maintenance

• October 17, 2016, Unit 2, core off-load activities for Refueling Outage 2RE18 In addition, the inspectors assessed the operators adherence to plant procedures, including the conduct of operations procedure and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11

b. Findings

No findings were identified.

.3 Annual Inspection (Units 1 and 2)

The licensed operator requalification program involves two training cycles that are conducted over a two year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, the licensee was in the first part of the training cycle.

a. Inspection Scope

The inspector reviewed the results of the operating tests for both units to satisfy the annual inspection requirements.

On November 17, 2016, the licensee informed the lead inspector of the following Unit 1 and 2 operating test results:

• A total of 87 operators took the tests (60 senior reactor operators, 27 reactor operators)

• Fifteen of fifteen crews passed the simulator portion of the operating test

• Eighty-seven of eighty-seven licensed operators passed the simulator portion of the operating test

• Eighty-six of eighty-seven licensed operators passed the job performance measure portion of the examination There are currently four licensed reactor operators in the current initial training class and are administratively restricted from standing watch until receipt of a senior reactor operator license or successful completion of all requirements to go back on shift as a reactor operator. The individual that failed the job performance measure portion of the operating test was remediated, retested, and passed a retake operating test prior to returning to shift.

The inspector completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

.1 Routine Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related SSCs:

• December 14, 2016, Unit 2, power range nuclear instrument 42 declared inoperable due to power supply failure

• December 20, 2016, Unit 2, train A spent fuel pool heat exchanger CCW return pressure relief valve socket weld failure In addition, the inspectors performed a complete system review (a vertical slice inspection) of:

• December 13, 2016, Unit 1, train A, B, and C component cooling water system The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule. For the vertical slice inspection, the inspectors reviewed all of the above and corrective maintenance performed on the component cooling water system during the past year.

These activities constituted completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

.2 Quality Control

a. Inspection Scope

On December 19, 2016, the inspectors reviewed the licensees quality control activities through a review of parts installed in the Unit 1, train A emergency diesel generator fire damper. These parts were purchased commercial-grade but were dedicated prior to installation in a quality-grade application. The inspectors reviewed the licensees control of quality parts during maintenance associated with the fire damper replacement.

These activities constituted completion of one quality control sample, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

On October 16, 2016, the inspectors reviewed the licensees implementation of the Configuration Risk Management Program, the associated risk assessment, and risk management actions. Specifically, for a transformer replacement activity that affected the Unit 1, 4.16 kV emergency safeguards bus E1A, channel 3 and channel 4 undervoltage and degraded voltage relays the inspectors reviewed the licensees actions prior to changes in plant configuration that elevated risk.

The inspectors verified that this risk assessment was performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessment and verified that the licensee implemented appropriate risk management actions based on the result of the assessment.

Additionally, the inspectors also observed portions of one emergent work activity that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity. Specifically, on February 18, 2016, the inspectors observed Unit 2, steam generator feed pump 23 repairs following a failed overspeed test.

The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

These activities constituted completion of two maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed four operability determinations and functionality assessments that the licensee performed for degraded or nonconforming SSCs:

• October 19, 2016, operability determination for the Unit 2 equipment hatch in a configuration that was not fully bolted in Mode 4

• November 2, 2016, operability determination of Unit 2, train C essential chilled water electrical auxiliary building main supply air handling unit 11C bypass temperature control valve due to corrosion

• November 12, 2016, operator workaround for Unit 1 volume control tank hydrogen makeup regulator leakage.

• November 30, 2016, operability determination of the reactor coolant pressure boundary following identification of loose or missing bolts on the Unit 2 reactor vessel water level system heated junction thermocouple Grayloc connectors The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.

The inspectors reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.

These activities constituted completion of four operability and functionality review samples, which included one operator work-around sample, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

a. Inspection Scope

The inspectors reviewed two permanent plant modifications that affected risk-significant SSCs:

• October 12, 2016, installation of test connections at Unit 2 emergency diesel generator train C control panel to facilitate surveillance testing

• December 22, 2016, Unit 1 and Unit 2, trains A, B, and C, installation of a flow orifice in the essential cooling water return line to reduce cavitation and erosion in the piping The inspectors reviewed the design and implementation of the modifications. The inspectors verified that work activities involved in implementing the modifications did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability or functionality of the SSCs as modified.

These activities constituted completion of two samples of permanent modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed seven post-maintenance testing activities that affected risk-significant SSCs:

• October 6, 2016, Unit 2, train C emergency diesel generator circulating water pump discharge check valve replacement

• October 16, 2016, Unit 1, train A, 4.16kV degraded and undervoltage potential transformer replacement following an emergent failure

• November 23, 2016, Unit 2, train A spent fuel pool heat exchanger CCW return pressure relief valve following a weld repair to a through-wall leak

• December 12, 2016, Unit 1, train B, CCW pump common header suction isolation motor operated valve 132 inspection and lubrication

• December 13, 2016, Unit 1, train B steam generator power-operated relief valve 7421 following a drain line repair

• December 15, 2016, Unit 2, reactor coolant system loop 2B hot leg narrow range temperature element following replacement of loop B reactor coolant system thermowell and resistance temperature detector 420Y

• December 22, 2016, Unit 2, train B emergency diesel generator diesel electrical relay testing after blown fuse and dropped start signal The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of seven post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

During the stations Refueling Outage 2RE18 that concluded on November 9, 2016, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:

• Review of the licensees outage plan prior to the outage

• Review and verification of the licensees fatigue management activities

• Monitoring of shut-down and cool-down activities

• Verification that the licensee maintained defense-in-depth during outage activities

• Observation and review of reduced-inventory and mid-loop activities

• Observation and review of fuel handling activities

• Monitoring of heat-up and start-up activities These activities constituted completion of one refueling outage sample, as defined in Inspection Procedure 71111.20.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

• November 16, 2016, Unit 1, component cooling water pump train B in-service test Containment isolation valve surveillance tests:

• October 19, 2016, Unit 2, local leak rate test of the reactor containment building equipment hatch in a fully bolted configuration and in a four-bolt configuration

• November 23, 2016, Unit 2, feedwater isolation actuation and response time test Other surveillance tests:

• October 4, 2016, Unit 2, technical support center diesel generator undervoltage test

• October 31, 2016, Unit 2, train A emergency diesel generator 21 loss-of-offsite power test

• November 9, 2016, Unit 2, main turbine overspeed test The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

a. Inspection Scope

The inspectors evaluated the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. During the inspection, the inspectors interviewed licensee personnel, walked down various areas in the plant, performed independent radiation dose rate measurements, and observed postings and physical controls. The inspectors reviewed licensee performance in the following areas:

• Radiological hazard assessment, including a review of the plants radiological source terms and associated radiological hazards. The inspectors also reviewed the licensees radiological survey program to determine whether radiological hazards were properly identified for routine and non-routine activities and assessed for changes in plant operations.

• Instructions to workers including radiation work permit requirements and restrictions, actions for electronic dosimeter alarms, changing radiological condition, and radioactive material container labeling.

• Contamination and radioactive material control, including release of potentially contaminated material from the radiologically controlled area, radiological survey performance, radiation instrument sensitivities, material control and release criteria, and control and accountability of sealed radioactive sources.

• Radiological hazards control and work coverage. During walk-downs of the facility and job performance observations, the inspectors evaluated ambient radiological conditions, radiological postings, adequacy of radiological controls, radiation protection job coverage, and contamination controls. The inspectors also evaluated dosimetry selection and placement as well as the use of dosimetry in areas with significant dose rate gradients. The inspectors examined the licensees controls for items stored in the spent fuel pool and evaluated airborne radioactivity controls and monitoring.

• High radiation area and very high radiation area controls. During plant walk-downs, the inspectors verified the adequacy of posting and physical controls, including areas of the plant with the potential to become risk-significant high radiation areas.

• Radiation worker performance and radiation protection technician proficiency with respect to radiation protection work requirements. The inspectors determined if workers were aware of significant radiological conditions in their workplace, radiation work permit controls/limits in place, and electronic dosimeter dose and dose rate set points. The inspectors observed radiation protection technician job performance, including the performance of radiation surveys.

• Problem identification and resolution for radiological hazard assessment and exposure controls. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the seven required samples of radiological hazard assessment and exposure control program, as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors performed this portion of the attachment during the refueling outage in order to directly observe the licensees ALARA process activities, including planning, implementation of radiological work controls, execution of work activities, and ALARA review of work-in-progress. During the inspection, the inspectors interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas:

• Implementation of ALARA and radiological work controls. The inspectors observed pre-job briefings, reviewed planned radiological administrative, operational, and engineering controls, and compared the planned controls to field activities.

• Radiation worker and radiation protection technician performance during work activities performed in radiation areas, airborne radioactivity areas, or high radiation areas.

• Problem identification and resolution for ALARA and radiological work controls.

The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of two of the five required samples of occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee to monitor areas, materials, and workers to ensure a radiologically safe work environment. This evaluation included equipment used to monitor radiological conditions related to normal plant operations, anticipated operational occurrences, and conditions resulting from postulated accidents. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance associated with radiation monitoring instrumentation, as described below:

• The inspectors performed walk-downs and observations of selected plant radiation monitoring equipment and instrumentation, including portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors. The inspectors assessed material condition and operability, evaluated positioning of instruments relative to the radiation sources or areas they were intended to monitor, and verified performance of source checks and calibrations.

• The inspectors evaluated the calibration and testing program, including laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors.

• The inspectors assessed problem identification and resolution for radiation monitoring instrumentation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the three required samples of radiation monitoring instrumentation, as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:

• During walk-downs and observations of selected portions of the radioactive gaseous and liquid effluent equipment, the inspectors evaluated routine processing and discharge of effluents, including sample collection and analysis.

The inspectors observed equipment configuration and flow paths of selected gaseous and liquid discharge system components, effluent monitoring systems, filtered ventilation system material condition, and significant changes to effluent release points.

• Calibration and testing program for process and effluent monitors, including National Institute of Standards and Technology (NIST) traceability of sources, primary and secondary calibration data, channel calibrations, set-point determination bases, and surveillance test results.

• Sampling and analysis controls used to ensure representative sampling and appropriate compensatory sampling. Reviews included results of the inter-laboratory comparison program and effluent releases made with inoperable radiation monitors.

• Instrumentation and equipment, including effluent flow measuring instruments, air cleaning systems, and post-accident effluent monitoring instruments.

• Dose calculations for effluent releases. The inspectors reviewed a selection of radioactive liquid and gaseous waste discharge permits and abnormal gaseous or liquid tank discharges, and verified the projected doses were accurate. The inspectors also reviewed 10 CFR Part 61 analyses and methods used to determine which isotopes were included in the source term. The inspectors reviewed land use census results, off-site dose calculation manual changes, and significant changes in reported dose values from previous years.

• Problem identification and resolution for radioactive gaseous and liquid effluent treatment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive gaseous and liquid effluent treatment program, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

• Radioactive material storage, including waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition.

• Radioactive waste system, including walk-downs of the accessible portions of the radioactive waste processing systems and handling equipment. The inspectors also reviewed or observed changes made to the radioactive waste processing systems, methods for dewatering and waste stabilization, waste stream mixing methodology, and waste processing equipment that was not operational or abandoned in place.

• Waste characterization and classification, including radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides, and processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses.

• Shipment preparation, including packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifests.

• Shipping records for LSA I, II, III, SCOI, II, Type A, or Type B radioactive material or radioactive waste shipments.

• Problem identification and resolution for radioactive solid waste processing and radioactive material handling, storage, and transportation. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the six required samples of radioactive solid waste processing, and radioactive material handling, storage, and transportation program, as defined in Inspection Procedure 71124.08.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 Mitigating Systems Performance Index: Residual Heat Removal Systems (MS09)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of April 1, 2015, through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for residual heat removal systems for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index: Cooling Water Support Systems (MS10)

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the period of April 1, 2015, through September 30, 2016, to verify the accuracy and completeness of the reported data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for cooling water support systems for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of April 1, 2015, to September 30, 2016. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the occupational exposure control effectiveness performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual

(ODCM) Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between April 1, 2015, and September 30, 2016, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Semiannual Trend Review

a. Inspection Scope

The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.

• Inspectors reviewed five electrical breaker failures that occurred from March 2016 to October 2016 for a potential trend

• Inspectors reviewed a licensee identified trend in equipment clearance order issues that occurred from July 2016 to December 2016 These activities constituted completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.

b. Observations and Assessments The inspectors review of the potential trend and trend identified above produced the following observations and assessments:

• For the potential trend involving electrical breaker malfunctions that occurred from March 2016 to October 2016, the inspectors reviewed the licensees investigations and causal analysis of each failure. The licensee experienced one instance of a Westinghouse type DS-206 breaker failure to open, two instances of a Siemens HKR breaker failure to close, one instance of a Westinghouse type DS-206 breaker failure to close, and one instance of a Cutler Hammer molded case circuit breaker failed in the tripped open condition. After reviewing these five instances of breaker failures, the licensee concluded that while different types and sizes of breakers had failed for various reasons in various states, no common cause or trend in a particular type of breaker or maintenance practice existed. The licensee did take action to improve maintenance procedures for overhauling Westinghouse type DS-206 breakers and to include additional site acceptance testing for Siemens HKR medium voltage breakers. The inspectors concluded that in response to these breaker failures, the licensee had completed an appropriate evaluation and had developed appropriate planned corrective actions.

• For a negative trend involving equipment clearance orders, the licensee identified five equipment clearance order performance issues that occurred between July 2016 and December 2016. The licensee is conducting a common cause investigation and conducting corrective actions under Condition Report 16-13975. The licensee has intiated action to re-establish the focus on equipment clearance order procedural compliance and strengthening worker engagement. At the end of the inspection period, these actions were ongoing.

Specifically, the licensee performed a safety stand down, briefed crews on safety expectations, and are working on a common cause analysis. The inspectors concluded that in response to this trend, the licensee had developed and planned appropriate corrective actions.

c. Findings

No findings were identified.

.3 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected two issues for an in-depth follow-up:

• On November 14, 2016, inspectors completed an in-depth review of the failure of Unit 1, control rod D-6, to fully insert into the core during control rod drop testing activities on November 18, 2015.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned and completed corrective actions and that these actions were adequate to correct the condition.

The licensee entered the issue into the corrective action program as Condition Report 15-25420. The licensee submitted and received a one-time license amendment to operate Unit 1 without control rod D-6 on December 11, 2015.

The associated safety evaluation report for this issue is available in ADAMS with Accession No. ML15343A128. The licensee removed the control rod, installed a flow restrictor, and modified the digital rod position indicator input and output.

Since reaching full power, Unit 1 has not experienced any issues with the modification. The licensee submitted a license amendment request dated April 7, 2016, to make the change permanent as the licensee has decided to forgo the rapid refuel function, the function in which the control rod drive mechanism was damaged and led to the control failure to operate properly. The licensee received the license amendment on December 21, 2016 to operate Unit 1 with 56 full-length control rods, with no full-length control rod in core location D-6. The associated safety evaluation report for this issue is available in ADAMS with Accession No. ML16319A010.

• During an in-office inspection from November 28 through November 30, 2016, the inspector reviewed the three cyber security-related findings documented in Inspection Report 05000498/2014406 and 05000499/2014406, INSPECTION OF IMPLEMENTATION OF INTERIM CYBER SECURITY MILESTONES 1-7, (ML15033A104) for in-depth follow-up review. The inspectors reviewed a sample of updated program documents and procedures, updated critical digital asset listings, causal evaluations, training documents, and corrective action documents.

The inspectors assessed the licensees extent of condition reviews, causal evaluations, compensatory actions, and pending and completed corrective actions. The inspectors verified that the licensee appropriately prioritized the corrective actions and that these actions were appropriate.

These activities constituted completion of two annual follow-up samples, as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On October 27, 2016, the inspectors presented the in-service inspection results to Mr. G.

Powell, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On October 28, 2016, the inspectors presented the radiation safety inspection results to Mr. G.

Powell, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On November 30, 2016, the inspector presented the annual follow-up of selected issues inspection results to Mr. W. Bankston, General Manager, Corporate Services, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector did not review any proprietary information.

On December 1, 2016, the inspectors presented the radiation safety inspection results to Mr. B. Jefferson, Operations Director and Acting Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

The lead inspector obtained the final annual examination results for licensed operator requalification and telephonically exited with Mr. G. Janak, Operations Training Manager, on December 12, 2016. The inspector did not review any proprietary information during this inspection.

On January 5, 2017, the inspectors presented the inspection results to Mr. G. Powell, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Aguilar, Radiation Protection

R. Aguilera, Manager, Health Physics

J. Atkins, Manager, Systems Engineering

M. Berg, Manager, Design Engineering

J. Berrio, Manager, Operations, Production Support & Programs

C. Bowman, Manager, Nuclear Support

W. Brost, Engineer III

A. Capristo, Executive Vice President and Chief Administrative Officer

C. Clinton, Supervisor, Chemistry

J. Connolly, Site Vice President

I. Duncanson, Chemist, Chemistry

R. Dunn Jr., Manager, Nuclear Fuel and Analysis

G. Ferrigno, General Supervisor, Radiation Protection

T. Frawley, Manager, Plant Protection/Emergency Response

C. Gann, Manager, Employee Concerns Program

T. Gardner, Technician, Chemistry

R. Gibbs, Manager, Operations Division, Unit Operations

R. Gonzales, Senior Licensing Engineer

M. Hellman, Supervisor, Cyber Security Program

G. Hildebrandt, Manager, Operations

K. Hilscher, Manager, Training

G. Janak, Operations Training Manager

B. Jefferson, Director, Operations, and Acting Plant Manager

L. Kauffman, ALARA Supervisor, Radiation Protection

K. Kawabata, Technician, Health Physics

C. Kinman, Radiation Protection

M. Kistler, Inspection Lead

D. Koehl, President and CEO

B. Lane, Manager, Operations Division, Integrated Work Management & Outage

J. Lovejoy, Manager, I&C Maintenance

E. Matejceck, Manager, Mechanical Maintenance

J. McLeod, Analyst, Internet Technology Security

R. McNeil, Manager, Maintenance Engineering

B. Migl, Supervisor, Testing and Programs

J. Milliff, Manager, Security

P. Murphy, Operations

M. Murray, Manager, Regulatory Affairs

K. Nigmatullina, Effluent Primary Chemist, Chemistry

A. Otto, Radiation Protection

M. Page, General Manager, Engineering

C. Pence, Manager, Chemistry

L. Peter, General Manager, Projects

M. Pilgreen, Technical Supervisor, Radiation Protection

G. Powell, Executive Vice President and Chief Nuclear Officer

D. Rencurrel, Senior Vice President, Operations

Licensee Personnel

R. Richardson, Welding Engineer

P. Rodriquez, Radiation Protection

M. Ruvalcaba, Manager, Strategic Projects

R. Savage, Engineer, Licensing Consult Specialist

R. Scarborough, Manager, Quality Assurance

M. Schaefer, Plant General Manager

L. Spiess, Supervisor, Engineering Testing/Programs

R. Stastny, Maintenance Manager

L. Sterling, Supervisor, Licensing

L. Stoicescu, Health Physicist, Radiation Protection

C. Stone, RMC Supervisor, Health Physicist

J. Von Suskil, Owner Rep - NRG South Texas LP

J. Williams, Spec Engineering Consultant Testing/Programs (SE)

P. Williams, Spec Engineering Consultant Testing/Programs (SE)

D. Zink, Supervising Engineering Specialist

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None