IR 05000498/2020010

Biennial Problem Identification and Resolution Inspection Report 05000498/2020010 and 05000499/2020010

ML20349A331
Person / Time
Site:	South Texas
Issue date:	12/14/2020
From:	Ami Agrawal Division of Nuclear Materials Safety IV
To:	Gerry Powell South Texas
References
IR 2020010
Download: ML20349A331 (12)

Text

December 14, 2020

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2020010 AND 05000499/2020010

Dear Mr. Powell:

On November 5, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project, Units 1 and 2 and discussed the results of this inspection with yourself and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action 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 corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

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 on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. 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, Digitally signed by Ami Ami Agrawal Agrawal Date: 2020.12.14 16:39:25-06'00'

Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000498 and 05000499 License Numbers: NPF-76 and NPF-80 Report Numbers: 05000498/2020010 and 05000499/2020010 Enterprise Identifier: I-2020-010-0001 Licensee: STP Nuclear Operating Company Facility: South Texas Project, Units 1 and 2 Location: Wadsworth, TX Inspection Dates: October 21, 2020 to November 5, 2020 Inspectors: R. Azua, Senior Reactor Inspector A. Sanchez, Senior Project Engineer J. Braisted, Reactor Inspector L. Flores, Reactor Inspector R. Grover, Observer Approved By: Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety Enclosure

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, 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(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 approximately 170 condition reports as well as their associated Root Cause and Apparent Cause Evaluations. The team also conducted a 5-year review of the plant's essential cooling water systems and associated chillers.

• Operating Experience, Self-Assessments, and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.

• Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B 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 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 Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the South Texas Project 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 plant's essential cooling water systems and associated chillers for a focused review within the corrective action program. For these systems, 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 also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of these systems. However, the team did not identify any concerns with this system.

Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.

Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the South Texas Project, 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.

Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. 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. In the area of trend analysis, the team did identify that the licensee had not taken full advantage of established processes to perform trend analyses in each department twice a year. The licensee indicated that they presently perform a computer-generated analysis using an algorithm to identify trends plant-wide, and that they are looking into performing future departmental trends using the same process.

Assessment 71152B Safety-Conscious Work Environment: The team interviewed ten individuals. 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 focus group participants were from the Security organization. Due to the challenges brought on by the COVID-19 pandemic, and the South Texas Project's performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the South Texas Project has an adequate Safety Conscious Work Environment.

Willingness to Raise Nuclear Safety Issues: In the assessed focus group, the team found no evidence of challenges to SCWE. Individuals in this group expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.

Overall, the team concluded that the South Texas Project maintained a healthy SCWE.

Employee Concerns Program: The team looked at the South Texas Project's Employee Concerns Program (ECP). The team interviewed the ECP manager and discussed her cases. The team reviewed the ECPs investigative packages. Overall, the team did not identify any concerns with the program.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On November 5, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr G. Powell, President and CEO, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action Condition Reports 04-9487, 06-8526, 07-8567, 10-1209, 10-21452, 12-23776,

Documents (CRs) 15-25511, 16-3594, 16-3641, 16-5305, 16-11257, 16-11346,17-691, 17-17659, 17-22801, 18-1488, 18-2396, 18-3296,

18-3967, 18-4094, 18-4480, 18-5434, 18-6597, 18-6871, 18-

7183, 18-7184, 18-7185, 18-7186, 18-7193, 18-7195, 18-

209, 18-7842, 18-8061, 18-8454, 18-8858, 18-9456, 18-

9599, 18-9846, 18-10113, 18-10118, 18-10183, 18-10326,

18-11154, 18-11155, 18-12152, 18-13551, 18-13635, 18-

13638, 18-13993, 18-14266, 18-14369, 18-14473, 18-14474,

18-14475, 18-14476, 18-14937, 18-15029,19-241, 19-799,19-876, 19-957, 19-1009, 19-1101, 19-1225, 19-1916, 19-

1954, 19-1966, 19-2023, 19-2357, 19-2526, 19-2725, 19-

2836, 19-3431, 19-3611, 19-4076, 19-4187, 19-4323, 19-

4367, 19-4368, 19-4472, 19-4561, 19-4623, 19-4745, 19-

5470, 19-5569, 19-5666, 19-5669, 19-5670, 19-5671, 19-

5674, 19-5680, 19-5689, 19-5693, 19-5694, 19-5842, 19-

6437, 19-6440, 19-7019, 19-7043, 19-7164, 19-7441, 19-

7486, 19-7535, 19-8088, 19-8257, 19-8507, 19-8510, 19-

9050, 19-9764, 19-9800, 19-10133, 19-10210, 19-10223, 19-

289, 19-10487, 19-10643, 19-11414, 19-11467, 19-12074,

19-12135, 19-12372, 19-12401,20-705, 20-849,20-917, 20-

935, 20-1017, 20-1205, 20-1361, 20-1381, 20-1474, 20-

1490, 20-1507, 20-1589, 20-1643, 20-1828, 20-1939, 20-

2174, 20-2861, 20-3665, 20-3814, 20-3815, 20-3933, 20-

4910, 20-5103, 20-5149, 20-5798, 20-6283, 20-6310, 20-

6765, 20-6797, 20-7052, 20-7429, 20-7524, 20-7563, 20-

7564, 20-7714, 20-8188, 20-8590, 20-9405, 20-9748, 20-

9762, 20-10932, 20-11113, 20-11265

Miscellaneous Quality Periodic Report 02/04/2019

Quality Periodic Report 07/24/2019

Quality Periodic Report 01/29/2020

Quality Periodic Report 08/17/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Unit 1 Operator Burden Working Report 11/04/2020

Unit 2 Operator Burden Working Report 11/4/2020

2019 Maintenance Observations

20 Maintenance Observations

Executive Oversight Board Report of Site Visit 02/13/2020

STP Executive Oversight Board Report 11/2018

STP Executive Oversight Board Report 03/2019

STP Executive Oversight Board Report 02/2020

Executive Oversight Board Report of Site Visit 09/19/2019

18-0-107397 Audit of CAP for Plant Operations

19-0-107556 Audit of CAP for Plant Operations

20-0-108142 Audit of CAP for Plant Operations

2019-06 CAP Health Program 06/2019

2019-12 CAP Health Program 12/2019

20-04 CAP Health Program 04/2020

20-08 CAP Health Program 08/2020

PRA-19-009 Risk Assessment to Provide Risk Information to Support 0

LER 2-19-001 as Required by Procedure 0PGP03-ZX-0002B

Procedures 0PGP03-HU- Human Performance (HU) Program 12

0001

0PGP03-IP-0001 Integrated Performance Improvement Program 8

0PGP03-ZA-0090 Work Process Program 42

0PGP03-ZM- Preventive Maintenance Program 40

0002

0PGP03-ZO- Protected Components 14

0055

0PGP03-ZO- Equipment Clearance Order Instructions 31

ECO1A

0PGP03-ZX-0002 Condition Report Process 53

0PGP03-ZX- CAQ Resolution Process 13

0002A

0PGP03-ZX- Station Cause Analysis Program 12

0002B

Inspection Type Designation Description or Title Revision or

Procedure Date

0PGP03-ZX-0003 Station Self-Assessment Program 15

0PGP03-ZX-0003 Station Self-Assessment Program 15

0PGP03-ZX-0008 Condition Not Adverse to Quality (CNAQ) Resolution 2

Process

0PGP03-ZX-0016 Trending Process Procedure 5

0PGP04-ZA-0002 Condition Report Engineering Evaluation 27

0POP01-ZA-0049 Condition Report Operations Evaluation Program 10

0POP01-ZO- Operability, Functionality, and Reportability Guidance 14

0011

0POP01-ZO- Operability, Functionality & Reportability Guidance 12

0014

0PQP02-ZA-0003 Quality Surveillance and Performance Monitoring 12

0PSP10-RC-0002 Core Exit Thermocouple or Resistance Temperature 10, 25, 26

Detector Cross Calibration

0PSP11-XC-0004 LLRT Penetration: M-91 Auxiliary Airlock Door Seals 17

CAP-002 Causal Analysis Guideine 5

CAP-003 Condition Report Screening 4

COM-0001 Conduct of Maintenance 19

Conduct of Operations Organization and Responsibilities 30

Operations

Chapter 1

Conduct of Operations Departmental Business Practices 20

Operations

Chapter 11

Conduct of Shift Operating Practices 80

Operations

Chapter 2

Conduct of Communications 13

Operations

Chapter 3

Conduct of Performance Monitoring and Self Assessment 31

Operations

Chapter 7

Inspection Type Designation Description or Title Revision or

Procedure Date

SLG-CPI1 Management Performance Improvement Committee 10

Activities

WCG-0002 Work Management Scheduling 43

WCG-0002 Work Management Scheduling 43

WCG-0003 Planner's Guide 40

Self-Assessments 19-05 Maintenance/Work Control Quality Audit 06/10/2019

19-10 Accredited Training Audit

CR 18-3296 Maintenance and Technical Training Programs 2

CR 19-7019 Mid-Cycle Self-Assessment Report 07/2019

CR 19-7164 Maintenance and Technical Training Training Programs 08/26/2019

CR 19-8088 Maintenance Fundamentals and Technical Skills 08/19/2019

9