ML15030A494
| ML15030A494 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/30/2015 |
| From: | Miller G B Division of Reactor Safety IV |
| To: | Koehl D L South Texas |
| H. Freeman | |
| References | |
| IR 2014010 | |
| Download: ML15030A494 (16) | |
See also: IR 05000498/2014010
Text
"Enclosure transmitted herewith contains SUNSI. When separated from Attachment 1 to the Enclosure, this transmittal document is decontrolled." January 30, 2015
Mr. Dennis President and CEO/CNO STP Nuclear Operating Company PO Box 289 Wadsworth, TX 77483-0289
SUBJECT: SOUTH TEXAS PROJECT, UNITS 1 and 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2014010; 05000499/2014010
Dear Mr. Koehl:
On December 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of the problem identification and resolution biennial inspection at the South Texas Project. On that day, the NRC inspection team discussed the results of this inspection with Mr. D. Rencurrel, Senior Vice President Operations, and other members of your staff. This discussion included a finding for which the NRC had not yet reached a significance determination. On December 18, 2014, the inspection team had completed its review and provided Mr. D. Rencurrel, and other members of your staff, the results of a detailed risk evaluation telephonically. The inspection team documented the results of this inspection in the enclosed inspection report.
Based on the inspection sample, the inspection team determined that South Texas Project's corrective action program, and your staff's implementation of it were adequate to support nuclear safety.
In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your station's performance in each of these areas supported nuclear safety. Finally, the team determined that your station's management maintained a safety-conscious work environment in which your employees were willing to raise nuclear safety concerns through at least one of the several means available.
Nuclear Regulatory Commission inspectors documented one security finding of very low security significance (Green) in Attachment 1 to the enclosed report. This finding involved a violation of Nuclear Regulatory Commission requirements. The Nuclear Regulatory Commission is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy. The deficiency was promptly addressed and the plant complied with applicable physical protection and security prior to the inspectors leaving the site. The finding has a cross-cutting aspect in the human performance area associated with complacency in that security force personnel did not implement appropriate error reduction tools due to the repetitive nature of the activities and the expectation of successful outcomes (H.12). Further, the inspectors also documented one licensee-identified violation determined to be of very low safety significance in this report. The NRC is also treating this violation as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or their significance, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. 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 Regional Administrator, Region IV; and to the NRC resident inspector at the South Texas Project Electric Generating Station, Units 1 and 2, facility. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, and its enclosure (with the exception stated below) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Some of the material contained in the enclosed report therein contains Security-Related Information in accordance with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in Attachment 1 to the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from the PARS component of NRC's ADAMS. If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response "Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390" in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
Sincerely,/RA/
Geoffrey B. Miller, Chief Technical Support Branch Division of Reactor Safety Docket Nos. 50-498, 50-499 License Nos. NPF-76, NPF-80 Nonpublic
Enclosure:
Inspection Report 05000498/2014010; 05000499/2014010
w/Attachments:
1. Security-Related Supplement 2. Supplemental Information 3. Information Request
cc w/
Enclosure:
Mr. John Milliff Manager, Security STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Distribution for South Texas Project Electric Generating Station A2-1 Attachment 2 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel D. Abell, Performance Improvement Specialist R. Aguilera, Manager, Health Physics J. Atkins, Manager, Systems Engineering R. Barr, Supervisor, Corrective Action Program M. Berg, Manager, Design Engineering/Test & Programs C. T. Bowman, General Manager, Nuclear Oversight D. Caraballo, System Engineer J. Crain, Manager, Emergency Response Plant Protection Department Support M. Crutcher, System Engineer R. Dunn Jr, Manager, Nuclear Fuel & Analysis M. Farmer, Security System Engineer T. Frawley, Manager, Plant Protection/Emergency Response C. Gann, Manager, Employee Concerns Program M. Gandt, Engineer, Nuclear Steam Supply Systems R. Gubbs, Manager, Operations Division-Production Support A. Hasan, System Engineer J. Heil, Program Engineer L. Huerta, Supervisor, Security Training G. Hildebrandt, Manager, Operations B. Jenewein, Manager, Performance Improvement L. Knox, Security Compliance Specialist R. Lonazo, System Engineer L. Meier, Project Manager, Regulated Security Solutions A. McGalliard, Manager, Corporate Staff Support & Owner Liaison J. Milliff, Manager, Security M. Murray, Manager, Regulatory Affairs/Licensing G. Powell, Site Vice President D. Rencurrel, Senior Vice President Operations P. Rodgers, System Engineer R. Savage, Licensing Engineering Specialist R. Scarborough, Manager, Quality Assurance M. Schaefer, Plant General Manager R. Stastny, Manager, Maintenance L. Sterling, Supervisor, Licensing T. Upton, Technical Supervisor, Maintenance M. Uribe, Manager, Work Control T. Vajdos, System Engineer D. Whiddon, Supervisor, Quality J. Winters, Lead Investigator D. Zink, Supervisor, Engineering Specialist NRC Personnel N. Hernandez, Resident Inspector G. Miller, Chief, Technical Support Branch G. Replogle, Senior Reactor Analyst A2-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed 05000498/2014010-01 05000499/2014010-01 NCV Failure to Follow Security Procedure Closed 05000499/2014-001-00 LER Standby Diesel Generator 23 Essential Cooling Water Leak Through the Wall of Aluminum-Bronze Pipe Nipple LIST OF DOCUMENTS REVIEWED Condition Reports 08-16140 09-387 09-1736 09-4465 09-5524 09-6591 09-6949 09-8195 09-9594 09-9986 09-11422 09-13142 09-14961 09-16144 09-16155 09-16366 09-18746 09-20129 09-21177 10-227 10-302 10-321 10-543 10-4928 10-6359 10-10425 10-25855 11-483 11-771 11-3584 11-3756 11-3908 11-4895 11-12020 11-15707 11-19073 11-21271 11-21275 11-26455 11-27182 12-483 12-13560 12-14431 12-22937 12-23535 12-24501 12-26558 12-27023 12-27493 12-27569 12-27648 12-28135 12-28186 12-28283 12-28600 12-28689 12-28901 12-29159 12-29161 12-31703 13-102 13-103 13-285 13-317 13-325 13-568 13-2311 13-2551 13-2611 13-3161 13-4566 13-5188 13-6031 13-6145 13-6543 13-7209 13-8786 13-8855 13-8957 13-9440 13-9648 13-9844 13-9932 13-10831 13-10896 13-10898 13-10902 13-10949 13-11358 13-11380 13-11528 13-11729 13-13857 13-15806 13-15904 14-22808* 14-23546* 14-25242* 14-62 14-298 14-514 14-518 14-747 14-1374 14-1712 14-2040 14-3306 14-3686 14-4235 14-4488 14-4501 14-4517 14-4650 14-4762 14-4895 14-5066 14-5383 14-6318 14-7054 14-7985 14-8012 14-8022 14-8213 14-9152 14-9634 14-9637 14-9939 14-11207 14-11266 14-13030 14-13247 14-13252 14-13314 14-13674 14-13925 14-17123 14-17723 14-18263 14-19793 14-20710 14-22328 14-22507 14-22532 14-22639 14-22811 14-22901 14-22976 14-24843 14-25164 14-72222 *Issued as a result of inspection activities. A2-3 Drawings Number Title Revision 00009E0DJAB,Sheet 1 Single Line Diagram, 125V DC Class 1E Distribution Switchboard, E1D11 (Channel II) 22 Miscellaneous Documents Number Title Revision/ Date Life Cycle Management Plan: Rod Control System Life Cycle Management Plan: Nuclear Instrumentation System Life Cycle management Plan: Qualified Display Processing System Solid State Protection System Health Report September 30, 2014 Nuclear Instrumentation System Health Report September 30, 2014 7300 Processor Support System Health Report September 30, 2014 Qualified Display Processing System Health Report September 30, 2014 STP Security System Health Report September 25, 2014 Executive Oversight Board March 2013 June 2103 November 2013 January 2014 May 2014 October 2014 STP Reporting Manual 11 Requal Qualification Checkout Card (RQCC) No. 2164: Conduct Personnel Search A2-4 Miscellaneous Documents Number Title Revision/ Date Requal Qualification Checkout Card (RQCC) No. 2165: Perform Material Search Plan of Action: Increased Trend of NRC Performance Indicator March 24, 2014 Physical Security Quality Audit Reports October 10, 2012 September 18, 2013 September 11, 2014 Safeguards Event Log Conduct of Operations for Radiation Protection - Chapter 9, "Radiation Protection Condition Reporting Guideline" 15 Conduct of Operations for Radiation Protection - Chapter 22, "RP Observations Program" High and Low Head Safety Injection Pumps In-Service Testing Trend for Units 1 and 2 July 2009 through September 2014 13-01 Emergency Preparedness Quality Audit Report March 11, 2013 13-04 Corrective Action Program Supplemental Quality Audit Report July 9, 2013 13-05 Maintenance Quality Control Audit Report August 7, 2013 14-01 Emergency Preparedness Quality Audit Report March 12, 2014 14-02 Radiological Controls Quality Audit Report March 31, 2014 14-03 Testing and Programs Quality Audit Report June 4, 2014 A2-5 Miscellaneous Documents Number Title Revision/ Date MN-14-9-
103668 Quality Monitoring Report November 13, 2014 Preventive Maintenance Tasks PM 1336 PM 1337 PM 1341 PM1342 Procedure Number Title Revision 0PGP03-ZA-0133 Fluid Leak Management Program 3 0PGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks 9 0PGP03-ZE-0133 Boric Acid Corrosion Program 8 0PGP03-ZM-0016 Installed Plant Instrumentation Calibration Verification Program 25 0PGP03-ZO-0054 Operational Decision-Making 4 0PGP03-ZO-9900 Operability Determination and Functionality Assessments Program 6 0PGP03-ZO-9900 Operability Determinations and Functionality Assessments Program 6 0PGP03-ZO-900A Operability Determinations and Functionality Assessments 4 0PGP03-ZX-0002 Condition Reporting Process 50 0PGP03-ZX-002A CAQ Resolution Process 4 0PGP03-ZX-002B Station Cause Analysis Program 5 A2-6 Procedure Number Title Revision 0PGP03-ZX-0008 Conditions Not Adverse to Quality (CNAQ) Resolution Process 0PGP05-ZN-0009 NRC Inspection / Interface Activities 0POP01-ZO-0011 Operability, Functionality, and Reportaility Guidance 9 0POP01-ZO-0011 Operability, Functionality, and Reportability Guidance 9 0PSP03-AF-0001 Auxiliary Feedwater Pump 11(21) Inservice Test 35 0PSP03-AF-0007 Auxiliary Feedwater Pump 14(24) Inservice Test 44 Security Instruction 1005 Security Incidents 6 Security Instruction 2101 Access Control 22 SEG-0008 Printed Circuit Board Maintenance and Replacement Guideline SG-005 Performing and Documenting Evaluations WCG-003 Planner's Guide 36 A2-7 Work Orders 32580862 32592449 32592456 32622205 32657597 32657618 32683168 32746542 32747151 32748096 32762817 32764187 32789036 32819905 32819981 32823335 32848427 32848449 32857451 32874207 32874237 32906926 32951496 32954403 33028547 33196159 33211839 33254140 33329299 33389559 33525272 33559632 33559717 33570188 33587688 33587766 33603766 33616204 33617639 33639146 33639164 33639483 33659703 33659705 33663496 33689554 33689584 33697080 33724501 33724526 33759248 33781745 33784486 33806141 33810329 33816256 33836230 33842544 33851931 33878328 33898174 33910719 33913974 33950398 33959688 33959970 484418 A3-1 Attachment 3 Information Request June 26, 2014 Biennial Problem Identification and Resolution Inspection - November 17 - December 5, 2014 South Texas Project Inspection Report Number 05000498/2014010, 050499/2014010 This inspection will cover the period from October 7, 2012, through the end of the inspection on December 5, 2014. All requested information should be limited to this period or to the date of the request unless otherwise specified. To the extent possible, provide the requested information electronically in Adobe PDF (preferred) or Microsoft Office format. Provide paper copies of any sensitive information during the team's first week on site; do not provide sensitive or proprietary information electronically.
Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable format. Please provide the information on a compact disc (one for each team member), if possible. This information may also be uploaded on the Certrec IMS website if so desired.
Please provide the following no later than October 10, 2014: 1. Document Lists Note: For these summary lists, please include the document/reference number, the document title or description of the issue, the priority, initiation date, status, and long text descriptions of the issues. a. Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period b. Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period c. Summary lists of all corrective action documents which were upgraded or downgraded in priority/significance during the period d. Summary list of all corrective action documents that subsume or "roll up" one or more smaller issues for the period e. Summary lists of operator workarounds, engineering review requests and/or operability evaluations, temporary modifications, and control room and safety system deficiencies opened, closed, or evaluated during the period f. Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent)
g. Summary list of all Apparent Cause Evaluations completed during the period h. Summary list of all Root Cause Evaluations planned or in progress, but not complete at the end of the period A3-2 2. Full Documents with Attachments a. Root Cause Evaluations completed during the period b. Quality assurance audits performed during the period c. All audits/surveillances performed during the period of the Corrective Action Program, of individual corrective actions, and of cause evaluations d. Corrective action activity reports, functional area self-assessments, and non-NRC third party assessments completed during the period (do not include INPO assessments)
e. Corrective action documents generated during the period for the following: i. All Cited and Non-Cited Violations Issued to South Texas Project ii. All Licensee Event Reports Issued by South Texas Project f. Corrective action documents generated for the following, if they were determined to be applicable to South Texas Project (for those that were evaluated but determined not to be applicable, provide a summary list):
i. NRC Information Notices, Bulletins, and Generic Letters issued or evaluated during the period ii. Part 21 reports issued or evaluated during the period iii. Vendor safety information letters (or equivalent) issued or evaluated during the period iv. Other external events and/or Operating Experience evaluated for applicability during the period g. Corrective action documents generated for the following:
i. Emergency planning drills and tabletop exercises performed during the period ii. Maintenance preventable functional failures which occurred or were evaluated during the period iii. Adverse trends in equipment, processes, procedures, or programs which were evaluated during the period iv. Action items generated or addressed by plant safety review committees during the period A3-3 3. Logs and Reports a. Corrective action performance trending/tracking information generated during the period and broken down by functional organization b. Corrective action effectiveness review reports generated during the period c. Current system health reports or similar information d. Radiation protection event logs during the period e. Security event logs and security incidents during the period (sensitive information can be provided by hard copy during first week on site)
f. Employee Concern Program (or equivalent) logs (sensitive information can be provided by hard copy during first week on site)
g. List of Training deficiencies, requests for training improvements, and simulator deficiencies for the period 4. Procedures a. Corrective action program procedures (initiation, evaluation, classification, and disposition of conditions adverse to quality). Include operability determination procedures, root and apparent cause evaluation procedures and any other procedures that implement the corrective action program b. Maintenance rule program and implementing procedures c. Operating experience program d. Employee concerns program e. Self-assessment program f. Degraded/non-conforming condition process (e.g., RIS 2005-20) g. System Health process or equivalent equipment reliability improvement programs h. Operational Decision Making (ODMI) process 5. Other Items a. Scheduled date/time/location of all meetings associated with implementation of the corrective action program, such as screening meetings, corrective action review board meetings, etc. A3-4 b. A list of condition reports generated as a result of identified trends. The list should be sorted by priority and have the following information: number, title/description, date initiated, status, and initiating department. c. A list of outstanding corrective actions, sorted by priority, with the following information: number; priority; system/component affected, initiating date and due date. Please also identify and list any associated due date extensions. d. A chronological list of all nuclear Quality Assurance/Nuclear Oversight audits and department/station self-assessments including their reference number. e. A list of all system health reports. f. All copy of assessments or evaluations (internal or external) regarding station or department safety-culture. g. A list of all operability determinations and ODMIs performed with the following information: date initiated, initiating CR and status (open or closed). h. A list of maintenance preventable functional failures (MPFFs) of risk-significant systems (include actions completed and current status). A list of current Maintenance Rule a(1)
systems and a list of those systems that entered a(1) within the last two years, but which were returned to a(2) status. Include a copy of the current system health report for those systems now in a(1). i. Copy of the latest corrective action program statistics such as the number initiated by department, human performance errors by department, backlog, corrective action timeliness and others as may be available. j. List of industry operating experience evaluated by the site and associated condition report number if applicable. Additionally, list of all NRC generic communications (information notices, generic letters, etc.) evaluated by the site for applicability to the station regardless of the determination of applicability. k. A chronological list of all Licensee Event Reports, with a brief description of the affected components or systems. l. A listing of the top 10 risk-significant systems, components, and/or operator manual actions as appropriate.
Please provided on CDs and/or DVDs sent via overnight carrier to: U.S. NRC Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 Attention: Harry Freeman Please note that the NRC is not currently able to accept electronic documents on thumb drives or other similar digital media. 3 If you choose to provide a response and Security-Related Information is necessary to provide an acceptable response, please mark your entire response "Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390" in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
Sincerely,/RA/ Geoffrey B. Miller, Chief Technical Support Branch Division of Reactor Safety Docket Nos. 50-498, 50-499 License Nos. NPF-76, NPF-80 Nonpublic
Enclosure:
Inspection Report 05000498/2014010; 05000499/2014010
w/Attachments:
1. Security-Related Supplement 2. Supplemental Information 3. Information Request Public
Enclosure:
Inspection Report 05000498/2014010; 05000499/2014010
w/Attachments:
2. Supplemental Information 3. Information Request cc w/
Enclosure:
Mr. John Milliff Manager, Security STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483 Distribution for South Texas Project Electric Generating Station Distribution: See next page ADAMS ACCESSION NUMBER: ML15030A494 Entire Report ADAMS: Publicly Available Non-Sensitive Keyword SUNSI Review By: HAF Yes No Non-Publicly Available Sensitive MD 3.4 Non-Public A.3 Cover Letter ADAMS: Publicly Available Non-Sensitive Keyword SUNSI Review By: HAF Yes No Non-Publicly Available Sensitive RGN-002 OFFICE SRI:TSB RI:EB2 HP:TSB SRI:DRP C:TSB NAME HFreeman SAlferink BBaca ASanchez GMiller/DAllen SIGNATURE /RA/ /RA/ /RA//RA/ /RA/ DATE 1/28/15 1/29/15 1/28/15 1/29/15 1/30/15 OFFICIAL RECORD COPY Letter to Dennis from Geoffrey B. Miller, dated January 30, 2015
SUBJECT: SOUTH TEXAS PROJECT, UNITS 1 & 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2014010; 05000499/2014010 Distribution by RIV w/Nonpublic
Enclosure:
Security Specialist/NSIR (Eric.Wharton@nrc.gov) Security Specialist/NSIR (Niry.Simonian@nrc.gov)
Chief, Security Performance Evaluation Branch/NSIR (Clay.Johnson@nrc.gov)
Security Specialist/NSIR (Douglas.Garner@nrc.gov) Branch Chief, RI DRS/PSB1 (Anthony.Dimitriadis@nrc.gov)
Branch Chief, RII DRS/PSB1 (Binoy.Desai@nrc.gov) Branch Chief, RIII DRS/PSB (Richard.Skokowski@nrc.gov) Senior Resident Inspector (Alfred.Sanchez@nrc.gov)
STP Administrative Assistant (Lynn.Wright@nrc.gov)
Distribution by RIV w/Public
Enclosure:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
Acting DRP Director (Troy.Pruett@nrc.gov)
Acting DRP Deputy Director (Thomas.Farnholtz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov) DRS Deputy Director (Jeff.Clark@nrc.gov) Senior Resident Inspector (Alfred.Sanchez@nrc.gov)
Resident Inspector (Nicholas.Hernandez@nrc.gov)
Branch Chief, DRP (Neil.OKeefe@nrc.gov)
Senior Project Engineer, DRP (David.Proulx@nrc.gov) Project Engineer, DRP (Fabian.Thomas@nrc.gov) Administrative Assistant (Lynn.Wright@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov) Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov) RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov) RIV/ETA: OEDO (Michael.Waters@nrc.gov)