IR 05000498/2014002

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IR 05000498-14-002, 05000499-14-002; 01/01/2014 - 04/04/2014; South Texas Project Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up
ML14140A134
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/19/2014
From: O'Keefe N F
NRC/RGN-IV/DRP/RPB-B
To: Koehl D
South Texas
F. Sanchez
References
IR-14-002
Download: ML14140A134 (59)


Text

May 19, 2014

Mr. Dennis Koehl President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2014002 AND 05000499/2014002

Dear Mr. Koehl:

On April 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the South Texas Project Electric Generating Station, Units 1 and 2, facility. On April 10, 2014, the NRC inspectors discussed the results of this inspection with Mr. G. Powell, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. The NRC inspectors documented two findings of very low safety significance (Green) in this report. Both of these findings involved violations of the NRC's requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest these violations or significance of the NCVs, 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 or a finding not associated with a regulatory requirement 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 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, its enclosure, and your response (if any) 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).

Sincerely,/RA/

Neil O'Keefe, Branch Chief Project Branch B Division of Reactor Projects Docket Nos.: 50-498, 50-499 License Nos.: NPF-76, NPF-80

Enclosure:

Inspection Report 05000498/2014002 and 05000499/2014002 w/Attachment 1: Supplemental Information 2: Document Request for Occupational Radiation Safety Inspection 3: Document Request for Inservice Inspection Activities Electronic Distribution to South Texas Project

SUMMARY

IR 05000498/2014002, 05000499/2014002; 01/01/2014 - 04/04/2014; South Texas Project Electric Generating Station, Units 1 and 2, Inservice Inspection Activities; Problem Identification and Resolution; Event Follow-Up.

The inspection activities described in this report were performed between January 1 and April 4, 2014, by the resident inspectors at the South Texas Project and inspectors from the NRC's Region IV office. Two findings of very low safety significance (Green) are documented in this report. These findings involved a violation of NRC requirements. 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, "Components Within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Initiating Events

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for an inadequate procedure associated with the boric acid corrosion control program (BACCP). Specifically, Procedure 0PGP03-ZE-0133, "Boric Acid Corrosion Control Program," Revision 7, failed to provide adequate screening criteria for boric acid leaks. As a result, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account all the characteristics of the leak commensurate to the affected component. The licensee entered the finding into the corrective action program as Condition Report 14-5393. The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," Exhibit 1, the finding was determined to be of very low safety significance (Green)because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable [H.14]. (Section 1R08)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for an inadequate procedure because train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to require a system fill and vent in Procedure 0PMP05-CH-003, "York Chiller Inspection & Maintenance 300 Tons," Revision 6, following maintenance on the essential chilled water system. The condition was placed into the corrective action program as Condition Report 13-12492. The licensee has modified the essential chilled water maintenance procedure to require a full system fill and vent following maintenance. The failure to require filling and venting of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air left in the system rendered the train inoperable. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensee's Maintenance Rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that the cause of the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that this procedure was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1] (Section 4OA2.2). B. Licensee Identified None

PLANT STATUS

Unit 1 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter used to provide high-accuracy measurement of feedwater flow to the calorimetric power calculation. On January 17, 2014, Unit 1 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. On March 15, 2014, Unit 1 entered Mode 3 to begin Refueling Outage 1RE18. The unit remained shut down for the remainder of the period of inspection.

Unit 2 began the period at 99.6 percent power due to a non-functional ultrasonic flow meter. On January 10, 2014, Unit 2 returned to 100 percent power following restoration and calibration of the ultrasonic flow meter. The unit remained at 100 percent power for the remainder of the period of inspection.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On January 9 and January 16, 2014, the inspectors completed an inspection of the station's readiness for extreme cold temperatures and possible ice accumulation. The inspectors reviewed the licensee's adverse weather procedures for extreme cold weather conditions and evaluated the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant. The inspectors walked down the electrical components exposed to the cold weather, area heat trace circuits, and verified the site's compensatory measures were implemented.

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

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial Walkdown

a. Inspection Scope

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

  • January 22, 2014, Units 1 and 2, fire protection system train B while the train C fire protection diesel pump was out of service for planned maintenance
  • February 26, 2014, Unit 1, train A spent fuel pool cooling pump during welding activities on train B spent fuel pool cooling system
  • March 5, 2014, Unit 1, train C essential cooling water during an emergent repair of the train B essential cooling water self-cleaning discharge strainer
  • April 3, 2014, Unit 1, electrical supplies for containment equipment hatch closure with reactor coolant system inventory at reactor vessel head flange level
  • April 3, 2014, Unit 1, spent fuel pool cooling pumps while reactor fuel was located in the spent fuel pool, and an electrical power temporary modification was in place for spent fuel pool cooling pump 1A The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems and trains were correctly aligned for the existing plant configuration.

These activities constituted seven partial system walk-down samples, 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 licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:

  • January 22, 2014, Units 1 and 2, fire protection pump house, Fire Areas 59, 60, and 61
  • February 24, 2014, Unit 1, essential cooling water system, Fire Zones Z603, Z604, and Z605
  • February 26, 2014, Unit 1, fuel handling building, Fire Area 35
  • March 4, 2014, Unit 1, mechanical auxiliary building, Fire Area 27
  • March 18, 2014, Unit 1, reactor containment building, Fire Area 63 For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's 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 six quarterly inspection samples, as defined in Inspection Procedure 71111.05.

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 Nondestructive Examination (NDE) Activities and Welding Activities

a. Inspection Scope

The inspectors directly observed the following nondestructive examinations: SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Coolant System Elbow to pipe, 12-RC-1112-BB1, Weld 10 (Record UT-2014-012) Ultrasonic Feedwater System Feedwater Pipe Lugs, 18-FW-1030-AA1, 1PL1 through 1PL4 (Record MT-2014-009) Magnetic Particle Component Cooling Water System Guide support, CC-1103-HL-5006 (Record VTC-2012-011) Visual Examination (VT-3) Component Cooling Water System Guide support, CC-9103-HL-5010 (Record VTC-2012-012) Visual Examination (VT-3) Reactor Vessel Closure Head Penetration Nozzles (Record VE-2014-001 & 002) Bare Metal Visual (VE)

The inspectors reviewed records for the following nondestructive examinations: SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Coolant System Elbow to pipe, 12-RC-1112-BB1, Weld 6 (Record UT-2014-020) Ultrasonic Reactor Coolant System Elbow to pipe, 12-RC-1112-BB1, Weld 7 (Record UT-2014-021) Ultrasonic Pressurizer Guide Support, RC-9003-HS5064 (Record VTC-2014-034) Visual Examination (VT-3) 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 EXAMINATION TYPE Pressurizer Pressurizer spray line pipe to RC0103 vent valve (Weld FW 0013) Gas Tungsten Arc Welding (GTAW) The inspectors reviewed records for the following welding activities:

SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Pressurizer PC11 Support U-strap to PC12 Support Plate (Weld NF) Gas Tungsten Arc Welding (GTAW) 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 Reactor Vessel Upper Head Penetration Inspection Activities

a. Inspection Scope

The inspectors reviewed the results of the licensee's bare metal visual inspection of the reactor vessel upper head penetrations to determine whether the licensee identified any evidence of boric acid challenging the structural integrity of the reactor head components and attachments. The inspectors also verified that the required inspection coverage was achieved and limitations were properly recorded. The inspectors reviewed whether the personnel performing the inspection were certified examiners to their respective nondestructive examination method.

b. Findings

No findings were identified.

.3 Boric Acid Corrosion Control (BACC) Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensee's 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 licensee's boric acid corrosion control walk-down as specified in Procedure 0PGP03-ZE-0133, "Boric Acid Corrosion Control Program," Revision 7, and Procedure 0PGP03-ZE-0033, "RCS Pressure Boundary Inspection for Boric Acid Leaks," Revision 12. 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

Introduction.

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for an inadequate procedure associated with the boric acid corrosion control program (BACCP). Specifically, Procedure 0PGP03-ZE-0133, "Boric Acid Corrosion Control Program," Revision 7, fails to provide adequate screening criteria for boric acid leaks.

Description.

The inspectors reviewed Procedure 0PGP03-ZE-0133 to verify that degraded or non-conforming conditions were being properly addressed to include identification, screening, and evaluation of boric acid leaks. Section 2.18 of the procedure defines SCREENING as "Activity to determine if leakage evidence could reasonably result in degradation of component function or qualification which would necessitate a BACCP Evaluation AND to recommend a cleaning, monitoring, insulation removal and/or repair schedule."

Section 4.1.3.1 states, "The purpose of the screening is to determine if the leakage is attributable to normal plant operation or to a degraded condition, to determine if a BACCP Evaluation is required, and to recommend a cleaning, monitoring, insulation removal and/or repair schedule. This activity is performed in parallel with normal Work Control Screening processes for material conditions." Section 4.1.3.2 c. states, "No qualification is required for this activity because of the rule-based, procedure-driven nature of the screening."

Procedure 0PGP03-ZE-0133, Section 4.1.3.7, includes the screening criteria for determining if a leak requires an evaluation. The procedure states that if any one of the following criteria is met, then the leak does not require an evaluation:

  • Leakage deposit is dry with no evidence of corrosion products.
  • Leakage deposits are from Expected Leakage.
  • Leakage deposits are dry and only on components normally at room temperature.
  • Leakage is Minor Leakage. The inspectors noted that the screening process is nonconservative because it is exclusive rather than inclusive, requiring only one of the boric acid leak criteria to be met to screen the leak out of an evaluation. However, failing to meet any of these conditions should require additional evaluation. Since the procedure requires no qualifications for the screening personnel, the potential exists that risk significant leaks could be inadvertently screened out. The inspectors noted that accepted industry standards, including the standard referenced by the licensee's procedure, recommend a process in which each of the defined criteria must be met to be able to screen out of an evaluation, rather than the less conservative method of meeting any one of the criteria.

The inspectors reviewed a sample of condition reports documenting previously identified boric acid leaks that had screened out of an evaluation. The review identified three instances where boric acid leaks screened out of the process but the visual condition, as seen in photos of the identified condition included in the condition report, did not support the description provided. The inspectors determined the licensee had inadequately screened the following leaks:

  • CR 12-1898 - Leakage at residential heat removal Pump 1C casing drain flange. Dry deposits confined to flange area.
  • CR 12-28378 - Residue buildup at the valve stem and inlet threaded connection for 1-RC-0214, reactor coolant system loop. Deposits are dry, white, and non-excessive and do not contact susceptible material.
  • CR 13-5786 - Seat leakage past RC-0103 and RC-0163 to quick disconnect inlet. Deposits are dry, white and confined to joint.

The inspectors concluded that the boric acid leak documented in CR 12-1898 was not confined to the flange; the photos clearly showed the leak had moved down to a suction flange bolt of the RHR Pump 1C. Applying accepted industry standards, the inspectors determined that the leak documented in CR 12-28378 should have been classified as being excessive. Additionally, the inspectors concluded that the leak documented in CR 13-5786 was not confined to the joint, was excessive, and came into contact with a safety related carbon steel support. The inspectors discussed CR 13-5786 with the licensee and determined the leakage past values RC-0103 and RC-0163 had come into contact with a carbon steel support without being evaluated. As a result of the discussion, the licensee performed a visual examination (VT-3) of support RC 1003-HS5064 and determined that it was not degraded.

Based on these three examples, the inspectors determined that the licensee's screening process was not consistent with the industry standards as cited by the procedure and failed to identify potentially risk significant leaks for further evaluation that impacted safety-related structures, systems, and components.

Analysis.

The inspectors determined that the failure to establish adequate screening criteria for boric acid leaks in Procedure 0PGP03-ZE-0133 was a performance deficiency. The finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inspectors identified multiple instances where the licensee inadequately screened boric acid leaks by failing to take into account the characteristics of the leak commensurate to the affected component, and therefore could potentially affect the structural integrity of the affected or adjacent structure, system or component. Using Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," Exhibit 1, the finding is determined to be of very low safety significance because the assessment of degradation did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function. The inspectors determined the finding has a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, the screening methodology established in Procedure 0PGP03-ZE-0133 resulted in multiple potentially risk significant leaks not receiving further evaluation [H.14].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, the licensee failed to implement procedural guidance of a type appropriate to the circumstances for screening boric acid leaks, an activity affecting quality. Specifically, Procedure 0PGP03-ZE-0133, "Boric Acid Corrosion Control Program," Revision 7, fails to provide adequate screening criteria for boric acid leaks. Because this violation is of very low safety significance and was placed in the corrective action program as CR 14-5383, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000498/2014002-01 and 05000499/2014002-01, "Failure to establish adequate screening criteria in the Boric Acid Corrosion Control Program."

.4 Steam Generator Tube Inspection Activities

a. Inspection Scope

The licensee did not perform any steam generator activities during Refueling Outage 1R18.

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 February 27, 2014, the inspectors observed simulator training for an operating crew.

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.

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

c. 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 plant's main control room. At the time of the observations, the plant was in a period of heightened risk due to infrequently performed activities. The inspectors observed the operators' performance of the following activities:

  • March 15, 2014, Unit 1, reactor shutdown to begin Unit 1 Refueling Outage 1RE18
  • March 20, 2014, Unit 1, reactor coolant system drain to reduced inventory for refueling operations In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies.

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

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

  • Week of January 10, 2014, Unit 1, planned train A work week maintenance
  • February 27, 2014, Unit 2, planned work week maintenance and the installation of a temporary instrument air compressor 24 The inspectors verified that these risk assessments were 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 licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments. The inspectors also observed portions of four emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:
  • January 11, 2014, Unit 1, troubleshooting of an electrical ground on the train A vital AC bus
  • Week of February 17, 2014, Unit 2, following the failure of instrument air compressor 24 and the planned work week maintenance activities
  • March 6, 2014, Unit 2, following the failure of train A emergency diesel generator to remotely shut down due to failure of an air cylinder
  • March 18, 2014, Unit 1, extended operation with the reactor coolant system in a solid water condition due to issues with not being able to lock out control rod D-6 for rapid refueling 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 structures, systems, and components.

These activities constitute completion of six 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 five operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components (SSCs):

  • January 20, 2014, Unit 1, operability determination of the personnel air lock due to an acrid smell and light smoke coming from an electrical relay
  • February 19, 2014, Unit 1, operability determination of nuclear source range channel NI-31 due to startup rate output being erratic
  • March 19, 2014, Unit 2, operability determination of train B emergency diesel generator due to 200 dpm leak of essential cooling water to the intercooler The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensee's 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. These activities constitute completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed one temporary plant modification that affected risk-significant structures, systems, and components. On April 3, 2014, the inspectors reviewed a temporary modification that supplied power to the Unit 1 spent fuel pool cooling pump 1A during the train B electrical work window that removed normal power to the pump.

The inspectors verified that the licensee had installed and removed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs. The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

On April 2, 2014, the inspectors reviewed a permanent modification to Units 1 and 2 for the post-accident sampling system to delete system requirements from Technical Specification and to develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere.

The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification 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 of the SSC as modified. These activities constitute completion of one sample 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 eight post-maintenance testing activities that affected risk-significant structures, systems, or components:

  • January 8, 2014, Unit 1, essential chiller 12A essential cooling water return valve EW-1002 following emergent replacement
  • January 17, 2014, Unit 2, train A emergency cooling water pump traveling screen following planned replacement of screen baskets
  • January 20, 2014, Unit 1, containment personnel airlock door following replacement of a relay
  • January 21, 2014, Unit 1, steam generator power operated relief valve PV-7431 following planned maintenance
  • January 22, 2014, Unit 2, train B emergency diesel generator fire water sprinkler deluge solenoid valve following emergent maintenance
  • February 5, 2014, Unit 1, essential cooling water liquid dye penetrant test following planned maintenance
  • March 11, 2014, Unit 2, train A emergency diesel generator following corrective maintenance to replace an air cylinder 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 constitute completion of eight 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 station's Refueling Outage 1RE18 that began on March 15, 2014, the inspectors evaluated the licensee's 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 licensee's outage plan prior to the outage
  • 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
  • Observation and review of fuel handling activities These activities constitute 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 structures, systems, and components were capable of performing their safety functions: In-service tests:

  • January 11, 2014, Unit 1, train A component cooling water pump
  • March 22, 2014, Unit 1, train A low head safety injection pump
  • March 22, 2014, Unit 1, train A high head safety injection pump
  • April 3, 2014, Unit 2, train D auxiliary feedwater pump Containment isolation valve surveillance tests:
  • March 12, 2014, Unit 2, main steam system valve testing 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 constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone:

Emergency Preparedness

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on February 19, 2014, to verify the adequacy and capability of the licensee's assessment of drill performance. The inspectors reviewed the drill scenario, observed the drill from the training simulator and the emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensee's emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

a. Inspection Scope

The inspectors verified the accuracy and operability of the radiation monitoring equipment used by the licensee: (1) to monitor areas, materials, and workers to ensure a radiologically safe work environment; and (2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

  • Selected instrumentation, including effluent monitoring instrument; portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks
  • Calibration and testing of process and effluent monitors, 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
  • Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constitute completion of one sample 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 verified that 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 licensee's 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 or observed the following items:

  • Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection
  • Effluent program implementing procedures, including sampling, monitor setpoint determinations, and dose calculations
  • Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews
  • Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)
  • Controls used to ensure representative sampling and appropriate compensatory sampling
  • Effluent stack flow rates
  • Part 61 analyses and methods used to determine which isotopes are included in the source term
  • Meteorological dispersion and deposition factors
  • Groundwater monitoring results
  • Changes to the licensee's written program for identifying and controlling contaminated spills/leaks to groundwater
  • Identified leakage or spill events and entries made into 10 CFR 50.75 (g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term
  • Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results
  • Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constitute completion of one sample of radioactive gaseous and liquid effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

a. Inspection Scope

The inspectors verified that the licensee's radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment, and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program.

The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensee's technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensee's radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:

  • Selected air sampling and dosimeter monitoring stations
  • Collection and preparation of environmental samples
  • Operability, calibration, and maintenance of meteorological instruments
  • Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement
  • Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach groundwater
  • Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection
  • Calibration and maintenance records for selected air sample equipment and environmental sample radiation measurement instrumentation
  • Inter-laboratory comparison program results
  • Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program, as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

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

a. Inspection Scope

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

  • The solid radioactive waste system description, process control program, and the scope of the licensee's audit program
  • Control of radioactive waste storage areas, including container labeling/marking and monitoring containers for deformation or signs of waste decomposition
  • Changes to the liquid and solid waste processing system configuration, including a review of waste processing equipment that is not operational or abandoned in place
  • Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
  • Processes for waste classification, including use of scaling factors and 10 CFR Part 61 analysis
  • Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest
  • Audits, self-assessments, reports and corrective action reports, radioactive solid waste processing and radioactive material handling, storage, and transportation performed since the last inspection Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one sample of radioactive solid waste processing and radioactive material handling, storage, and transportation, 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 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

The inspectors reviewed licensee event reports for the period of July 2012, through December 2013, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. 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 data reported. These activities constituted verification of the unplanned scrams per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of July 2012, through December 2013, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. 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 data reported.

These activities constituted verification of the unplanned power outages per 7000 critical hours performance indicator for Units 1 and 2, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors reviewed the licensee's basis for including or excluding in this performance indicator each scram that occurred between July 2012, and December 2013. 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 data reported. These activities constituted verification of the unplanned scrams with complications performance indicator for Units 1 and 2, 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 licensee's corrective action program and periodically attended the licensee's 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 licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

  • On October 27, 2013, Unit 1, train C essential chilled water system expansion tank level dropped below the minimum indication upon a start of the system. The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions appear to be adequate to correct the condition.

These activities constitute completion of one annual follow-up sample, as defined in Inspection Procedure 71152.

b. Findings

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for an inadequate procedure because the train C essential chilled water system was rendered inoperable by failing to remove air from the system following maintenance. Specifically, the licensee failed to incorporate a fill and vent step into their procedures after conducting maintenance on the essential chilled water system.

Description.

On October 27, 2013, while running essential chilled water pump 11C for nightly logs, the control room also received an essential chiller water expansion tank level LO alarm. An operator was dispatched to check the expansion tank level, but did not see any level in the sight glass. The control room operators secured the pump, and declared train C essential chilled water system inoperable and entered Technical Specification 3.7.14.

The licensee did not find any signs of a leak from the system. However, when operators went to vent the system as part of their troubleshooting efforts, they found significant amounts of air being vented from multiple locations. Operators reported vent times from as long as 35 seconds. The licensee conducted a fill and vent of the system and a satisfactory surveillance test before returning the system to an operable status. The licensee determined that air was introduced into the system and was trapped in a high point in the piping. When the pump was turned on, the air was swept through the system and into the expansion tank which caused the sudden drop in the expansion tank level.

The licensee's evaluation determined that this system had a history of similar issues, which sometimes caused the expansion tank to have an increased level, and operators would respond to the symptom by draining water to lower level; sometimes this later resulted in a low level on a subsequent system run. This evaluation concluded that air was being introduced through a leaking relief valve. Testing showed that the setpoint had drifted significantly lower than the required setpoint. However, the inspectors noted that this type of problem would not explain all the symptoms of the current example, and challenged the licensee's conclusions.

In response to the inspectors' questions, the licensee conducted a tier 2 apparent cause investigation to determine the source of the air. The licensee concluded that the lack of venting after testing the chiller unit with a hot water pack led to the introduction of air into the system. The licensee found that during major work on the system, a system venting is normally performed prior to returning the system to service. The most recent system venting for this train occurred on January 26, 2013, after a major train work week.

However, for smaller scope work, system venting may not be performed. On July 8, July 10, and October 3 of 2013, the licensee performed planned maintenance limited to the chiller unit. In each case, the final step was to conduct a refrigerant leak check using a hot water pack. The hot water pack is connected to the chilled water side via the drains while the isolation valves are shut. In accordance with chiller maintenance Procedure 0PMP05-CH-003, "York Chiller Inspection & Maintenance 300 Tons,"

Revision 6, once the testing is completed, the hot water pack is disconnected and the isolation valves are opened without any local venting. On October 4, 2013, the essential chilled water system was run and tested in accordance with Procedures 0PMP05-CH-003, and 0PGP03-ZM-0025A, "Post-Maintenance Testing Implementation," Revision 5. This test verified proper system acceptance criteria were met. There were no issues identified. The train C essential chilled water system was successfully run on October 25, 2013. On October 26, 2013, the control room received a chiller expansion tank HI level alarm. Operators responded and drained tank level.

On October 27, 2013, the chiller was again run for normal rotations when surge tank levels dropped below the indicating range. The chiller was secured and the system was vented. Operators discovered a fairly long vent time which suggested an abnormal amount of air in the system. The train C essential chilled water system was declared inoperable.

The inspectors concluded that this finding was appropriately categorized as being NRC-identified based on the inspectors' questions driving further evaluation of the cause after the licensee had reached their initial conclusions of the cause of the problems.

Analysis.

The failure to require a fill and vent of the essential chilled water system following maintenance that may introduce air into the system is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, air left in the essential chilled in the system following maintenance rendered the train inoperable following system venting that discovered an unexpected higher than normal volume of air in the system. Using the Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of the structure, system, and component; did not represent a loss of system or function; did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensee's Maintenance Rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The inspectors determined that the finding had a cross-cutting aspect in the resources area of human performance because the licensee did not ensure that the affected procedure was was adequate to support nuclear safety by ensuring that the essential chilled water system was operable when it was returned to service [H.1].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Contrary to the above, maintenance Procedure 0PMP05-CH 003, "York Chiller Inspection & Maintenance 300 Tons,"

Revision 6, used on July 8, July 10 and October 3, 2013, which directed activities affecting quality, was not appropriate to the circumstances. Specifically, Procedure 0PMP05-CH-003 did not include a step to fill and vent the essential chilled water system following maintenance. The failure to fill and vent the system resulted in the introduction of air into the system and the loss of expansion tank level indication.

This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensee's corrective action program as Condition Report 13-12492. (NCV 05000498/2014002-02 , "Failure to Perform a Fill and Vent Results in an Inoperable Essential Chilled Water Train")

4OA3 Follow-up of Events and Notices of Enforcement Discretion

.1 (Discussed) Licensee event Report 05000498/2014-001-00: Overpower Condition Relating to the Ultrasonic Flow Measurement System In December 2013, engineering was investigating a negative trend in the correction factors for the ultrasonic flowmeter and discovered that both units had experienced feedwater pipe wall thinning that were outside the software allowances for accuracy of

the ultrasonic flowmeter. Power was reduced in both Unit 1 and Unit 2 to 99.6 percent power. The average feedwater pipe erosion near the ultrasonic flowmeter sensors was 60-80 mils (thousandths of an inch), compared to a nominal pipe wall thickness of 1.375 inches. In conjunction with the vendor, new transduces were fabricated, installed, and tested and both units were returned to 100 percent power. The licensee's initial evaluation determined that both units were operated in excess of licensed thermal power limits (1.8 percent for Unit 1 and 1.4 percent for Unit 2) for approximated 2.5 years. The licensee further determined that Technical Specification 3.3.1 allowed outage time was exceeded. The licensee submitted Licensee Event Report 2014-001-00, "Overpower Condition Relating to the Ultrasonic Flow Measurement System," on March 24, 2014.

Inspectors continue to evaluate the issue, and will track this item under Licensee Event Report 2014-001-00 and any subsequent revisions to this report. The inspectors discussed the licensee's ongoing evaluations to further assess the maximum power level achieved, which was expected to be lower than the initial evaluation. No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On February 6, 2014, the inspectors presented the radiation safety inspection results to Mr. G. Powell, Site Vice President, 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 March 27, 2014, the inspectors presented the inspection results of the inservice inspection to Mr. G. Powell, Site Vice President, 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 April 10, 2014, the inspectors presented the resident inspection results to Mr. G. Powell, Site Vice President, 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 will be destroyed.

A1-

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aguilera, Manager, Health Physics
L. Archer, Consulting Health Physicist, Health Physics
M. Berg, Manager, Design Engineering/Testing and Programs
C. Bowman, General Manager, Engineering
W. Brost, Engineer, Licensing
D. Bryant, Manager, Chemistry
R. Dunn Jr., Manager, Nuclear Fuel and Analysis
P. Estrada, Engineer, Equipment Reliability
T. Frahm, Manager, Unit 2 Operations Division
T. Frawley, Manager, Strategic Business Projects
C. Gann, Manager, Corporate Staff Support and Owner Liaison
E. Hardcastle, Environmental Staff, Radiological Services
J. Hartley, Manager, Mechanical Maintenance
M. Hayes, General Supervisor, Radiation Protection
G. Hildebrandt, Manager, Operations
G. Janak, Operations Training Manager
R. Jones, Met Lab Staff Lead Specialist, Metrology and Radiological Laboratories
G. Kelton, Supervisor, Radioactive Material Control
D. Koehl, President and CEO
D. Lange, Supervisor, I&C Maintenance
H. Le, Engineering Licensing Consultant
J. Lovejoy, Manager, I&C Maintenance
F. Marroquin, Radiation Monitoring System Engineer, Engineering
R. McNeil, Manager, Maintenance Engineering
M. Merritt, Engineer, Work Control Supervisor
J. Milliff, Manager, Operations Support
J. Morris, Acting Supervisor, Licensing
M. Murray, Manager, Regulatory Affairs
A. Otto, Senior Radiation Protection Technician, Health Physics
A. Passafuma, Environmental Staff, Radiological Services
C. Pence, Unit Supervisor, Operations
L. Peter, Plant General Manager
J. Pierce, Manager, Unit 1 Operations
G. Powell, Site Vice President
C. Reddix, Manager, Security
K. Reynolds, Effluent Chemist, Chemistry
R. Savage, Engineer, Licensing Staff Specialist
M. Schaefer, Manager, Nuclear Oversight
M. Schoonover, Consulting Engineer, Equipment Reliability
S. Shojaei, Engineer, Repair and Replacement
L. Spiess, Engineer, Inservice Inspection
R. Stastny, Maintenance Manager
J. Stauber, Engineer, Inservice Inspection
L. Sterling, Supervisor, Licensing
L. Stoicescu, Health Physicist, Radiation Protection
M. Sumrall, Instrumentation Health Physicist
M. Svetlik, Consulting Engineer, Rapid Response Team
K. Wallis, Manager, Systems Engineering
D. Whiddon, Manager, Quality Assurance
P. Williams, Boric Acid Corrosion Control
C. Younger, Supervisor, Engineering Programs
D. Zink, Supervising Engineering Specialist

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000498/2014002-01
05000499/2014002-01 NCV Failure to Establish Adequate Screening Criteria in the Boric Acid Corrosion Control Program
05000498/2014002-02 NCV Failure to Perform a Fill and Vent Results in an Inoperable Essential Chilled Water Train

Discussed

05000498/2014-001-00 LER Overpower condition relating to the Ultra Sonic Flow Measurement system

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision 0PGP03-ZV-0004 Adverse Weather 5 0POP04-ZO-0002 Natural or Destructive Phenomena Guidelines 45 0PGP03-ZV-0004 Freezing Weather Plan 5
0POP01-ZO-0004 Extreme Cold Weather Guidelines 33
0POP02-CH-0005 Essential Chiller Operation 71
0POP02-CH-0005 Essential Chiller Operation 72

Calculations

Number Title Revision
MC-6429 Essential Chiller Operational Analysis 3

Condition Reports

Engineering Evaluation 12-14152-4 06-16539-9
Work Authorization Number (WAN) 438676

Section 1R04: Equipment Alignment

Procedures

Number Title Revision 0PGP03-ZF-0018 Fire Protection System 16
0POP02-AF-0001 Auxiliary Feedwater 37 0POP02-DG-0002 Emergency Diesel Generator 12(22) 65

Condition Reports

14-1897 14-4235 13-10831
Work Authorization Number (WAN) 437075

Section 1R08: Inservice Inspection Activities

Procedures

Number Title Revision 0PGP03-ZE-0133 Boric Acid Corrosion Control Program 7
0PGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks 12
0PEP10-ZA-0023 Visual Examination of Component Supports For ASME Section XI Inservice Inspection 7 0PEP10-ZA-0017 Magnetic Particle Examination (Dry Powder Yoke Method) 5 0PEP10-ZA-0024 ASME XI Examination for
VT-1 and
VT-3 4
0PEP10-ZA-0054 ASME Section XI VE Visual Examination 2
0PGP04-ZE-0304 Inservice Inspection Program for Welds and Component Support 12 OPSP11-RC-0015 ASME Section XI Inservice Inspection 17
UTI-PDI-UT-2 PDI Generic Procedure for the Ultrasonic Examination of Austenitic Pipe Welds 5
UTI-056 Manual Ultrasonic Examination of Replacement Steam Generator Primary Inlet/Outlet Nozzle Inner Radius Sections 1

Condition Reports

12-29220 12-31649 12-03460 12-30827 12-01898 12-29160 12-28378 12-30368 13-05786 12-11358 13-01805 13-11383 06-08983 08-04947 10-13376 07-14987 08-07413 07-14889 09-00643 14-05025
14-05383

Work Orders

514370

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Miscellaneous

Number Title Revision
RST 214.01 Misaligned Rod Recovery 0
RST 214.02 Down Power Exercise 0

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision 0POP01-ZO-0011 Operability, Functionality, and Reportability Guidance 7
0POP03-DG-0001 Emergency Diesel (21) Operability Test 49

Condition Reports

14-4745 14-6520 10-11740
Work Authorization Number (WAN) 480063

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision 0OOI01-OL-0005 Operations Logs - Diesel Generator 15 0POP03-DG-0001 Emergency Diesel (21) Operability Test 49 0PSP03-MS-0001 Main Steam System Valve Operability Test 41

Procedures

Number Title Revision 0POP01-ZO-0011 Operability, Functionality, and Reportability Guidance 7 0PGP03-ZO-9900A Operability Determinations and Functionality Assessments Implementation 2 0PGP03-ZA-0091 Configuration Risk Management 12 0PCP01-ZA-0038 Plant Chemistry Specifications 52 Condition Reports
14-6520 14-5236 14-5237 14-2046 14-0595 14-5321 14-0010 14-3277 13-5304 14-3277
13-5304 14-2040
Work Authorization Number (WAN)
491655 464437

Section 1R18: Plant Modifications

Procedures

Number Title Revision 0POP02-FC-0001 Spent Fuel Pool Cooling and Cleanup System 74
0PGP03-ZO-0003 Temporary Modifications 26
0PCP08-AP-0003 Post-Accident Sampling of Liquids and RCB Atmosphere at PASS 7

Miscellaneous

Number Title Date T1-13-2100-76 Provide Temporary Power to SFP Cooling Water Pump 1A January 21, 2014 Letter License Amendment Request Post Accident Sampling System
August 2, 2001 Letter Issuance of Amendments on the Elimination of Requirements for Post Accident Sampling November 7, 2001

Condition Reports

14-3785 14-2376

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision 0PMP04-ZG-0105 Traveling Water Screen Maintenance 5
0PEP10-ZA-0010 Liquid Penetrant Examination 5
0PEP10-ZA-0030 Visual Examination of Welds and Base Metal 3
0PSP03-MS-0001 Main Steam System Valve Operability Test 41
0PGP03-ZM-0025A Post-Maintenance Testing Implementation 6

Condition Reports

14-0595 12-22486 14-997 12-14152 14-2676
Work Authorization Number (WAN)
448645
489734
483488
442109
491331
492249 481123

Section 1R20: Refueling and Other Outage Activities

Procedures

Number Title Revision 0POP03-ZG-0007 Plant Cooldown 73
0PSP03-CV-0014 CVCS Equipment Verification 22
0PGP03-ZA-0014 Foreign Material Exclusion Program 26
0PGP03-ZA-0091 Configuration Risk Management 12 0POP03-ZA-0114 Fatigue Rule Program 5 0PMP04-RX-0018A Non-Rapid Refueling Mechanical Support 10
0PGP03-ZA-0069 Control of Heavy Loads 23

Miscellaneous

Title Date 1RE18 Shutdown Risk Assessment Report March 6, 2014 1RE18 Shutdown Risk Assessment Report, Amendment 1, Transition to Non-Rapid Refuel March 20, 2014
Title Revision Equipment Clearance Order A 74603: "0PSP03-CV-0014 Lineup 1 to secure boron dilution paths" 3

Condition Reports

14-6025 14-6476 14-6407 14-6423 14-6456 13-5304 14-6025 14-5941 14-5974 14-5983
14-5690 14-5737

Section 1R22: Surveillance Testing

Procedures

Number Title Revision 0PSP03-AF-0007 Auxiliary Feedwater Pump (24) Inservice Test 41 0PSP03-MS-0001 Main Steam System Valve Operability Test 41 0PSP03-CV-0001 Centrifugal Charging Pump 1A(2A) Inservice Test 36, 37
0PSP03-CC-0001 Component Cooling Water Pump 1A(2A) Inservice Test 17
0PSP03-SI-0039 Low Head Safety Injection Pump 1A(2A) Comprehensive Pump Test 6 0PSP03-SI-0042 High Head Safety Injection Pump 1A(2A) Comprehensive Pump Test 5

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision 0ERP01-ZV-IN01 Emergency Classification
0ERP01-ZV-SH01 Shift Mananger Unusual Event Checklist 29
0SDP01-ZS-0011 Implementing Procedures for Safeguards Events
0POP04-ZO-SEC2 Response to a Credible Threat of Sabotage or Tampering Guideline

Condition Reports

14-4222 14-3355 14-3356 14-3874

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number Title Revision 0PCP01-ZQ-0007 Quality Assurance for Radioanalysis Instrumentation 4
0PGP03-ZC-0001 Radiological Instrumentation Control Program 8
0PRP05-ZR-0010 Health Physics Instrumentation Program 23
0PSP05-RA-8010B MAB Unit Vent Wide Range Gas Monitor Calibration 14
0PSP05-RA-8038 Liquid Waste Process System No. 1 Monitor Calibration 14 0PSP05-WL-4078 Plant Liquid Waste Discharge Flow Calibration 6 0PSP05-RA-8050 RCB High Range Area Monitor Calibration 13
0PTP04-ZC-0036 Calibration of the Eberline
AMS-4 Air Monitoring System 5
0PTP04-ZC-0044 Calibration of Counting Instruments 9
0PTP04-ZC-0053 Calibration of Handheld Survey Meters/Ion Chambers 1 0PTP04-ZC-0054 Calibration of Area Monitors and Underwater Meters 0 0PTP04-ZC-0057 Maintenance Calibration of Eberline
PCM-1C Personnel Contamination Monitors 0 0PTP04-ZC-0058 Maintenance Calibration of Eberline
PM-7 Portal Monitors 0 0PTP04-ZC-0061 Maintenance Calibration of National Nuclear Corporation
ITM-2H Series Tool Monitors 0 0PTP04-ZC-0062 Maintenance Calibration of SAM Series Small Article Monitors 0 0PTP04-ZC-0064 Calibration of Canberra Argos-5AB Whole Body Monitor 0 0PTP04-ZC-0065 Calibration of Canberra
GEM-5 Gamma Exit Monitor 0
PMI-IC-RA-8043 Steam Generator Blowdown Liquid Monitor 4

Condition Reports

12-05853 12-06196 12-13004 12-32086 13-04997 12-13563
Audits and Self-Assessments Number Title Date 12-02 Radiological Controls Quality Audit Report March 29, 2012
STP8054 Health Physics Instrumentation Snapshot Self-Assessment (CR 12-31295) July 2013
Audits and Self-Assessments Number Title Date
MN-12-1-96436 Quality Monitoring Report November 12, 201212-31302 STPNOC Radiation Protection Formal Self-Assessment July 24, 2013
Effluent Instrument Calibration Number Title Date
RT-8010A Unit 2 Vent Particulate and Iodine Effluent Monitor March 3, 2013
RT-8010B Unit 2 Vent Wide Range Gas Monitor January 28, 2014
RT-8010B Unit 2 Vent Wide Range Gas Monitor July 25, 2012
RT-8010F Unit 2 Flow Rate Monitor January 28, 2014
RT-8038 Unit 1 Liquid Waste Processing Discharge Monitor May 22, 2013
F-4078 Unit 1 Liquid Waste Discharge Flow Monitor January 13, 2013
Area Radiation Monitor Calibration Number Title Date
NIRA-RI-8052 Incore Instrumentation Area Monitor January 9, 2012
Post-Accident Monitor Calibration Number Title Date 8050 Unit 2 Reactor Containment Building High Range Monitor December 12, 2013
Radiation Protection Instrument Calibrations Number Title Date 1306-149 Canberra Argos 5AB Whole Body Monitor November 25, 2013 1306-155 Canberra
GEM-5 Gamma Exit Monitor September 23, 2013 3919 Eberline
RO-20 Ion Chamber August 6, 2013
0990 Eberline
RO-20 Ion Chamber August 22, 2013
57109 Ludlum 3 Survey Meter October 22, 2013
53923 Ludlum 1000 Decade Scaler November 7, 2012
29 Thermo Electronic Corporation Small Article Monitor June 17, 2013 1009-2440 Hopewell Designs, INC
BXA-A Calibration Source February 8, 2011

Miscellaneous

Title Revision/Date South Texas Project Electric Generating Station Scaling Continuation Sheet January 15, 2014 Offsite Dose Calculation Manual 17 National Source Tracking Transaction Report January 6, 2011

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision 0PSP07-VE-0002 Gaseous Effluent Sampling and Analysis 15
0PSP07-WLLDP3 Liquid Effluent Permit Condensate Polisher Regen Waste 9
0PSP07-WLLDP2 Liquid Effluent Permit with
RT-8038 Inoperable 10
0PCP01-ZQ-0007 Quality Assurance for Radioanalysis Instrumentation 4 0PRP10-ZL-0030 Interlaboratory Radioassay Measurement Assurance Program 3 0PCP09-ZR-0016 Off-Normal and Abnormal Radiological Effluent Monitoring 2 0PSP07-WLLDP1 Liquid Effluent Permit 16
0PSP07-VE-0005 Gaseous Effluent Dose Assessment 6
0PCP09-ZR-0019 Guidelines for Radiological Effluent Off-Normal Conditions 3 0PSP07-VE-0004 Gaseous Effluent Strontium Composites 5 0PSP07-WL-0002 Liquid Effluent Composites 12
0PSP07-VE-0003 Gaseous Effluent Alpha Composites 13
0PSP11-HE-0001 Control Room Envelope Filter Airflow Capacity Test 12
0PGP03-ZO-0053 Radiological Groundwater Protection Program 3 0PSP11-HF-0001 FHB Exhaust Filter Airflow Capacity Test 12 0PSP11-ZH-0008 CRE and FHB HVAC In-Place HEPA Filter Leak Test 19
0PEP05-ZH-0001 Nuclear Air-Cleaning Systems Visual Inspection 9
0PSP05-RA-8010A Unit Vent Particulate and Iodine Effluent Monitor Calibration 14 0PCP09-ZO-0002 Liquid Scintillation Counting System - Analysis, Operation and Calibration 14 0PRP10-ZL-0029 NRMAP Measurement Assurance Program 2 0PCP01-ZA-0038 Plant Chemistry Specifications 52

Procedures

Number Title Revision 0PCP09-ZO-0004 Operation and Calibration of Canberra Gamma Spectrometer 15

Condition Reports

13-9622 12-8738 12-9735 12-10882 12-29951 12-30095 13-2799 13-10531 13-5865 13-31018
13-12129 13-9179 13-3749

Miscellaneous

Number Title Revision/Date 2011 Radioactive Effluent Release Report April 2012
2012 Radioactive Effluent Release Report April 2013
Offsite Dose Calculation Manual 17 2011 Annual Environmental Operating Report April 2012
2012 Annual Environmental Operating Report April 2013
Corrective Action Query Report - New 10
CFR 50.75(g) Entries since February 2, 2012 January 20, 2014
33702847 STPNOC MAP Report Package January 8, 2013
33396726 STPNOC MAP Report Package January 23, 2012 MN120101448 Quality Monitoring Report May 7, 2013
MN13099987 Quality Monitoring Report February 28, 2013
MN12089446 Quality Monitoring Report May 10, 2012
MN12197076 Quality Monitoring Report November 20, 2012 12-02 STPNOC Radiological Controls Quality Audit Report March 8, 2012

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number Title Revision 0PGP03-ZA-0097 Changes To The ODCM 0
0PGP03-ZO-0053 Radiological Ground Water Protection Program 3
0PGP03-ZR-0039 Radiological Environmental Monitoring Program 18

Procedures

Number Title Revision 0POP02-EM-0001 Alternate Meteorological Instrumentation Data Retrieval 3 0PRP10-ZL-0002 Quality Assurance For The Radiological Laboratory 13 0PRP10-ZL-0006 Sample Receipt, Accountability And Storage 13
0PRP10-ZL-0023 REMP Interlaboratory Comparison Program 10
0PRP10-ZL-0029 NRMAP Measurement Assurance Program 2
0PRP10-ZL-0030 Interlaboratory Radioassay Measurement Assurance Program 3 0PRP10-ZU-0001 REMP Sample Collection 7 0PRP10-ZU-0007 Environmental TLD Monitoring 10
0PSP05-EM-0001 Primary Meteorological System Calibration (60 Meter Tower) 33 0PSP05-EM-0002 Backup Meteorological System Calibration (10 Meter Tower) 20
Audits And Self-Assessments Number Title Date 12-02 (RC) Radiological Controls Quality Audit Report March 29, 2012
MN-12-0-89446 Quality Monitoring Report May 10, 2012
MN-13-0-101471 Quality Monitoring Report May 13, 2013
MN-13-0-100691 Quality Monitoring Report March 21, 2013
MN-12-0-92283 Quality Monitoring Report July 26, 2012
MN-12-0-89439 Quality Monitoring Report May 8, 2012
33687499 NVLAP Onsite Assessment April 4, 2013

Condition Reports

12-5856 12-9310 12-12896 13-6318 13-6944 13-10329 13-13307 13-14692 14-374 14-2244
Radiological Survey Records Number Title Date 55643 OSF Yard July 27, 2011
54894 OSF Yard June 9, 2011
Calibration And Maintenance Records Number Title Date
33748403 Backup Meteorological System Calibration (10 Meter Tower) August 22, 2013
33793295 Backup Meteorological System Calibration (10 Meter Tower) November 21, 2013
33707447 Primary Meteorological System Calibration (60 Meter Tower) May 24, 2013
33789341 Primary Meteorological System Calibration (60 Meter Tower) November 14, 2013
Gamma Geometry Standardization Package Detector 4:
WAT4-0 September 18, 2013
Gamma Geometry Standardization Package Detector 4:
CART-0 December 3, 2013
Gamma Geometry Standardization Package Detector 4:
AMPOULE-4 September 10, 2013
32309707 Gamma Geometry Standardization Package Detector 1:
FILT-0 April 16, 2008
33567277 Gamma Geometry Standardization Package Detector 1:
WAT4-0 April 4, 2012
33583359 Gamma Geometry Standardization Package Detector 1:
IOD1-0 April 19, 2012
33780608 RADECO Air Flow Calibrator (Model C-812) October 9, 2013
RL Liquid Scintillation System Calibration - H3 November 30, 2013
Tennelec Geometry Calibration REMP Air Filter - Gross Beta January 19, 2011

Miscellaneous

Number Title Revision/Date 2011 Annual Environmental Operating Report April 2012
2012 Annual Environmental Operating Report April 2013 QA Memo:
2013-01 Certificate of Participation for the year 2013 from the National Institute of Standards and Technology June 3, 2013
Corrective Action Program Query Report 4QQ for 10
CFR 50.75(g) Entries January 20, 2014
33396745 Land Use Census (2011) November 5, 2011
33689580 Land Use Census (2012) November 8, 2012

Miscellaneous

Number Title Revision/Date
Land Use Census (2013) December 3, 2013
Meteorological Tower Inspection Report June 2013
Offsite Dose Calculation Manual 17
2011 Radioactive Effluent Release Report April 2012
2012 Radioactive Effluent Release Report April 2013
SRMN-02119 USCEA/NIST MAP Report Package 47 mm
Particulate Filter May 16, 2012
SRMN-02490 USCEA/NIST MAP Report Package Solution in
5 ml Ampule August 6, 2013

Section 2RS8: Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Procedures

Number Title Revision 0PGP03-ZO-0017 Radioactive Waste Process Control Program 7
0PGP03-ZR-0053 Radioactive Material Control Program 16
0POP02-WS-0002 High Integrity Container (HIC) Dewatering for Shipment and Burial 14 0PRP03-ZR-0002 Radioactive Waste Shipments 22 0PRP03-ZR-0009 10
CFR 61 Sampling and Analysis Program 8
0PRP03-ZR-0010 Sorting and Processing of Radioactive Material 15
0PRP03-ZR-0011 Shipment of Radioactive Material 18 0PRP03-ZR-0012 Processing, Tracking and Loading of Spent Radioactive Filters 7 0PRP07-ZR-0025 Preparation and Shipment of High Integrity Containers or Reusable Polyethylene Waste Containers 7
Audits And Self-Assessments Number Title Date 12-02 (RC) Radiological Controls Quality Audit Report March 29, 2012
MN-12-1-96470 Quality Monitoring Report November 4, 2012
MN-13-2-98569 Quality Monitoring Report January 7, 2013
MN-13-2-99639 Quality Monitoring Report February 7, 2013
Audits And Self-Assessments Number Title Date
MN-13-1-100673 Quality Monitoring Report March 5, 2013
MN-13-2-102644 Quality Monitoring Report December 1, 2013

Condition Reports

12-5457 12-5853 13-9464 13-1995 12-29556 12-11240 12-13641 12-10814 13-10860 13-2105
2-29861 13-1920 12-29473 12-11119 13-11330 13-6459
Shipments
STP-0-12-005
STP-0-12-008
STP-0-12-025
STP-0-13-029
STP-1-12-034
STP-1-13-013
STP-2-12-029
STP-2-13-008
STP-2-13-036
STP-2-13-038
Radiological Survey Records Number Title Date 64804 Old Steam Generator Storage Facility December 17, 2012
71588 Old Steam Generator Storage Facility December 23, 2013
71717 U1 Radwaste Truck Bay and Radwaste Yard January 4, 2014 71818 U2 ORVH Slab January 13, 2014 72080 Warehouse 44 January 28, 2014
2163 41' Unit 2 MAB - Task Group 02 February 4, 2014

Miscellaneous

Number Title Revision/Date
STPGES UFSAR - Ch. 11.4 and 12.2 13
2011 Annual Radioactive Effluent Release Report April 2012
2012 Annual Radioactive Effluent Release Report April 2013
2011-2013 Radioactive Material/Waste Shipment Index February 04, 2014
RP916.01.LP 49CFR172 Subpart H Training Materials October 28, 2013
WMG
RC-102 and
RC-300 Transportation of RAM Training Certificates August 29, 2013
10 CFR Part 61 Waste Stream Analyses: Unit 1
SFP Resin September 5, 2012

Miscellaneous

Number Title Revision/Date
10 CFR Part 61 Waste Stream Analyses:
DAW Decayed 24 Months Waste Stream Update August 27, 2012
10 CFR Part 61 Waste Stream Analyses: DAW Common Waste Stream Update May 29, 2013

Section 4OA1: Performance Indicator Verification

Procedures

Number Title Revision
PI-0002 NRC & INPO Performance Indicator: Initiating Events Cornerstone (by Unit) and Barrier Integrity Cornerstone (by Unit) Desktop Guidelines 6 0PGP05-ZN-007 Preparation and Submittal of NRC Performance Indicators 8

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision 0PGP03-ZX-002 Condition Reporting Process 48 0PGP03-ZX-002A Condition Reporting Process Implementation 2
0PGP03-ZX-002B Root Cause Investigations 4
0PGP03-ZX-002C Common Cause Analysis and AFI Investigations 3
0PGP03-ZX-002D Apparent Cause Evaluations 2 0PGP03-ZX-002E Effectiveness Review Process 1

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Miscellaneous

Number Title Revision
TP-STP-2014-001 South Texas Project Performance Assessment 0
Attachment 2
The following items are requested for the Occupational Radiation Safety Inspection at South Texas Project (February 3 - 7, 2014) Integrated Report
2014002
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 20, 2014.
Please submit this information using the same lettering system as below.
For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

"1- A," applicable organization charts in file/folder "1- B," etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.
Enter a note explaining in which file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817)200-1154 or Natasha.Greene@nrc.gov.
Currently, the other inspectors will be Larry Ricketson, John O'Donnell, and Pete Hernandez.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.
5.
Radiation Monitoring Instrumentation (71124.05) Date of Last Inspection: February 2, 2012
A. List of contacts and telephone numbers for the following areas: 1. Effluent monitor calibration
2. Radiation protection instrument calibration
3. Installed instrument calibrations
4. Count room and Laboratory instrument calibrations B. Applicable organization charts C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and LERs, written since date of last inspection, related to:
1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, or whole body counters
2. Installed radiation monitors D. Procedure index for: 1. Calibration, use and operation of continuous air monitors, criticality monitors, portable survey instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry, personnel contamination monitors, and whole body counters. 2. Calibration of installed radiation monitors E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
1. Calibration of portable radiation detection instruments (for portable ion chambers) 2. Whole body counter calibration 3. Laboratory instrumentation quality control F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, whole body counters,
2. Installed radiation monitors,
3. Effluent radiation monitors
4. Count room radiation instruments NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Offsite dose calculation manual, technical requirements manual, or licensee controlled specifications which lists the effluent monitors and calibration requirements. H. Current calibration data for the whole body counter's.
I. Primary to secondary source calibration correlation for effluent monitors.
J.
A list of the point of discharge effluent monitors with the two most recent calibration dates and the work order numbers associated with the calibrations.
6. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
Date of Last Inspection: February 2, 2012
A. List of contacts and telephone numbers for the following areas: 1. Radiological effluent control 2. Engineered safety feature air cleaning systems B. Applicable organization charts
C. Audits, self assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1.
Radioactive effluents 2.
Engineered Safety Feature Air cleaning systems D. Procedure indexes for the following areas 1.
Radioactive effluents
2.
Engineered Safety Feature Air cleaning systems E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
1. Sampling of radioactive effluents
2. Sample analysis
3. Generating radioactive effluent release permits 4. Laboratory instrumentation quality control 5. In-place testing of HEPA filters and charcoal adsorbers
6. New or applicable procedures for effluent programs (e.g., including ground water monitoring programs) F. List of corrective action documents (including corporate and subtiered systems) written since date of last inspection, associated with: 1.
Radioactive effluents
2.
Effluent radiation monitors
3.
Engineered Safety Feature Air cleaning systems NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. 2011 and 2012 Annual Radioactive Effluent Release Report H. Current Copy of the Offsite Dose Calculation Manual
I. Copy of the 2011 and 2012 interlaboratory comparison results for laboratory quality control performance of effluent sample analysis
J. Effluent sampling schedule for the week of the inspection K. New entries into 10
CFR 50.75(g) files since date of last inspection L. Operations Dept (or other responsible dept) log records for effluent monitors removed from service or out of service M. Listing or log of liquid and gaseous release permits since date of last inspection N.
For technical specification-required air cleaning systems, the most recent surveillance test results of in-place filter testing (of HEPA filters and charcoal adsorbers) and laboratory testing (of charcoal efficiency)
7. Radiological Environmental Monitoring Program (71124.07)
Date of Last Inspection: February 2, 2012
A. List of contacts and telephone numbers for the following areas: 1. Radiological environmental monitoring
2. Meteorological monitoring B. Applicable organization charts
C. Audits, self assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1. Radiological environmental monitoring program (including contractor environmental laboratory audits, if used to perform environmental program functions) 2. Environmental TLD processing facility
3. Meteorological monitoring program D. Procedure index for the following areas: 1. Radiological environmental monitoring program 2. Meteorological monitoring program E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
1. Environmental Program Description 2. Sampling, collection and preparation of environmental samples
3. Sample analysis (if applicable)
4. Laboratory instrumentation quality control
5. Procedures associated with the Offsite Dose Calculation Manual
6. Appropriate QA Audit and program procedures, and/or sections of the station's QA manual (which pertain to the REMP) F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection, related to the following programs: 1. Radiological environmental monitoring
2. Meteorological monitoring NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Wind Rose data and evaluations used for establishing environmental sampling locations H. Copies of the 2 most recent calibration packages for the meteorological tower instruments
I. Copy of the 2011 and 2012 Annual Radiological Environmental Operating Report and Land Use Census, and current revision of the Offsite Dose Calculation Manual J. Copy of the environmental laboratory=s interlaboratory comparison program results for 2011 and 2012, if not included in the annual radiological environmental operating report
K. Data from the environmental laboratory documenting the analytical detection sensitivities for the various environmental sample media (i.e., air, water, soil, vegetation, and milk) L. Quality Assurance audits (e.g., NUPIC) for contracted services
M. Current NEI Groundwater Initiative Plan and status
8. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08)
Date of Last Inspection: February 2, 2012
A. List of contacts and telephone numbers for the following areas: 1. Solid Radioactive waste processing
2. Transportation of radioactive material/waste B. Applicable organization charts (and list of personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials) C. Copies of audits, department self-assessments, and LERs written since date of last inspection related to:
1. Solid radioactive waste management
2. Radioactive material/waste transportation program D. Procedure index for the following areas: 1. Solid radioactive waste management 2. Radioactive material/waste transportation
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
1. Process control program 2. Solid and liquid radioactive waste processing
3. Radioactive material/waste shipping
4. Methodology used for waste concentration averaging, if applicable
5. Waste stream sampling and analysis F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection related to: 1. Solid radioactive waste
2. Transportation of radioactive material/waste
NOTE: The lists should indicate the significance level of each issue and the search criteria used. G. Copies of training lesson plans for 49CFR172 subpart H, for radwaste processing, packaging, and shipping. H. A summary of radioactive material and radioactive waste shipments made from date of last inspection to present I. Waste stream sample analyses results and resulting scaling factors for 2011 and 2012 J. Waste classification reports if performed by vendors (such as for irradiated hardware) Although it is not necessary to compile the following information, the inspector will also review: K. Training, and qualifications records of personnel responsible for the conduct of radioactive waste processing, package preparation, and shipping Attachment 3 PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011. Information Request January 22, 2014 Notification of Inspection and Request for Information South Texas Project Unit 1 NRC Inspection Report 05000498/2014002
On March 17, 2014, reactor inspectors from the Nuclear Regulatory Commission's (NRC) Region IV office will perform the baseline inservice inspection at South Texas Project Unit 1, using NRC Inspection Procedure 71111.08, "Inservice Inspection Activities."
Experience has shown that this inspection is a resource intensive inspection both for the NRC inspectors and your staff.
In order to minimize the impact to your onsite resources and to ensure a productive inspection, we have enclosed a request for documents needed for this inspection.
These documents have been divided into two groups.
The first group (Section A of the enclosure) identified information to be provided prior to the inspection to ensure that the inspectors are adequately prepared.
The second group (Section B of the enclosure) identifies the information the inspectors will need upon arrival at the site.
It is important that all of these documents are up to date and complete in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection. We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Robyn Savage of your licensing organization.
The tentative inspection schedule is as follows:
Preparation week: March 3, 2014
Onsite weeks: March17-21, 2014 and March 24-28, 2014 Our inspection dates are subject to change based on your updated schedule of outage activities.
If there are any questions about this inspection or the material requested, please contact the lead inspector Wayne Sifre at 817-200-1193 [wayne.sifre@nrc.gov]. A. Information Requested for the In-Office Preparation Week The following information should be sent to the Region IV office in hard copy or electronic format (ims.certrec.com preferred), in care of Wayne Sifre, by March 3, 2014, to facilitate the selection of specific items that will be reviewed during the onsite inspection week.
The inspector will select specific items from the information requested below and then request from your staff additional documents needed during the onsite inspection week (Section B of this enclosure).
We ask that the specific items selected from the lists be available and ready for review on the first day of inspection.
Please provide requested documentation electronically if possible.
If requested documents are large and only hard copy formats are available, please inform the inspector(s), and provide subject documentation during the first day of the onsite inspection.
If you have any questions regarding this information request, please call the inspector as soon as possible. A.1 ISI/Welding Programs and Schedule Information a) A detailed schedule (including preliminary dates) of: i. Nondestructive examinations planned for ASME Code Class Components including containment, performed as part of your ASME Section XI, risk informed (if applicable), and augmented inservice inspection programs during the upcoming outage.
Provide a status summary of the nondestructive examination inspection activities vs. the required inspection period percentages for this interval by category per ASME,Section XI,
IWX-2400.
Do not provide separately if other documentation requested contains this information. ii. Reactor pressure vessel head examinations required by 10CFR50.55a(g)(6)(ii)(D) and Code Case N-729-1. iii. Examinations planned for Alloy 82/182/600 components that are not included in the Section XI scope (if applicable). iv. Examinations planned as part of your boric acid corrosion control program (mode 3 walk downs, bolted connection walk downs, etc.). v. Welding activities that are scheduled to be completed during the upcoming outage (ASME Class 1, 2, or 3 structures, systems, or components).
Include the weld identification number, description of weld, category, class, type of exam and procedure number, and date of examination. vi. Work packages for Check valve repairs associated with ASME Section XI work on removal of Seal Cap welds, replacement of
Bonnet, and the seal welding of bonnet/ valve body on Chemical Volume & Control (CVCS)

check valves and Safety Injection (SI) Check Valve.

b) A copy of ASME Section XI, Code Relief Requests and associated NRC safety evaluations applicable to the examinations identified above.

This would include the NRC approved relief request for implementing a risk informed ISI program (if applicable). i.
A list of ASME Code Cases currently being used to include the system and/or component the Code Case is being applied to. c) A list of nondestructive examination reports which have identified relevant indications on any ASME Code Class components since the beginning of the last refueling outage.

d) A list including a brief description (e.g., system, code class, weld category, nondestructive examination performed) associated with the repair/replacement activities of any ASME Code Class components since the beginning of the last outage and/or planned this refueling outage. e) If reactor vessel weld examinations required by the ASME Code are scheduled to occur during the upcoming outage, provide a detailed description of the welds to be examined and the extent of the planned examination.

Please also provide reference numbers for applicable procedures that will be used to conduct these examinations. f) Copy of any 10 CFR Part 21 reports applicable to structures, systems, or components within the scope of Section XI of the ASME Code that have been identified since the beginning of the last refueling outage. g) A list of any temporary noncode repairs in service (e.g., pinhole leaks). h) Please provide copies of the most recent self-assessments for the inservice inspection, welding, and Alloy 600 programs. i) List with description of ISI related issues such as piping damage (e.g., cracks, wall thinning, wear, MIC) or errors identified during examinations that have been entered into your corrective action system since the beginning of the last refueling outage.
Also, include a list of corrective action records associated with foreign material introduced/identified in the reactor vessel, primary coolant system, steam generator, or feed systems since the beginning of the last refueling outage.
A.2 Reactor Pressure Vessel Head a) Provide a detailed scope of the planned bare metal visual examinations (e.g., volume coverage, limitations, etc.) of the vessel upper head penetrations and/or any nonvisual nondestructive examination of the reactor vessel head including the examination procedures to be used.

i. Provide the records recording the extent of inspection for each penetration nozzle including documents which resolved interference or masking issues that confirm that the extent of examination meets 10

CFR 50.55a(g)(6)(ii)(D). ii. Provide records that demonstrate that a volumetric or surface leakage path examination assessment was performed. b) Copy of current calculations for EDY, and RIY as defined in Code Case N-729-1 that establish the volumetric and visual inspection frequency for the reactor vessel head and J-groove welds.
A.3 Boric Acid Corrosion Control Program a) Copy of the procedures that govern the scope, equipment and implementation of the inspections required to identify boric acid leakage and the procedures for boric acid leakage/corrosion evaluation.

b) Please provide a list of leaks (including code class of the components) that have been identified since the last refueling outage and associated corrective action documentation.

If during the last cycle, the unit was shut down, please provide documentation of containment walk down inspections performed as part of the boric acid corrosion control program. A.4 Steam Generator Tube Inspections a) A detailed schedule of: i. Steam generator tube inspection, data analyses, and repair activities for the upcoming outage (if occurring). ii. Steam generator secondary side inspection activities for the upcoming outage (if occurring). b) Copy of SG history documentation given to vendors performing eddy current (ET) testing of the SGs during the upcoming outage.

c) Copy of procedure containing screening criteria used for selecting tubes for in-situ pressure testing and the procedure to be used for in-situ pressure testing. d) Copy of previous outage SG tube operational assessment completed following ET of the SGs.

Also include a copy of the following documents as they become available:

i. Degradation assessment ii. Condition monitoring assessment e) Copy of the document defining the planned SG ET scope (e.g., 100 percent of unrepaired tubes with bobbin probe and 20 percent sample of hot leg expansion transition regions with rotating probe) and identify the scope expansion criteria, which will be applied.

Also identify and describe any deviations in this scope or expansion criteria from the EPRI Guidelines. f) Copy of the document describing the ET acquisition equipment to be applied including ET probe types.
Also identify the extent of planned tube examination coverage with each probe type (e.g. rotating probe -0.080 inches, 0.115 inches pancake coils and mid-range +point coil applied at the top-of-tube-sheet plus 3 inches to minus 12 inches). g) Identify and quantify any SG tube leakage experienced during the previous operating cycle.
Also provide documentation identifying which SG was leaking and corrective actions completed and planned for this condition.

h) Copy of steam generator eddy current data analyst guidelines and site validated eddy current technique specification sheets.

Additionally, please provide a copy of EPRI
Appendix H, "Examination Technique Specification Sheets," qualification records. i) Provide past history of the condition and issues pertaining to the secondary side of the steam generators (including items such as loose parts, fouling, top of tube sheet condition, crud removal amounts, etc.). j) Indicate where the primary, secondary, and resolution analyses are scheduled to take place. A.5 Additional Information Related to all Inservice Inspection Activities a) A list with a brief description of inservice inspection, boric acid corrosion control program, and steam generator tube inspection related issues (e.g., condition reports)

entered into your corrective action program since the beginning of the last refueling outage.

For example, a list based upon data base searches using key words related to piping or steam generator tube degradation such as: inservice inspection, ASME
Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion, boric acid, or errors in piping/steam generator tube examinations.

b) Provide training (e.g. Scaffolding, Fall Protection, FME, Confined Space) if they are required for the activities described in A.1 through A.4. c) Please provide names and phone numbers for the following program leads:

Inservice inspection (examination, planning) Containment exams Reactor pressure vessel head exams Snubbers and supports Repair and replacement program Licensing Site welding engineer Boric acid corrosion control program Steam generator inspection activities (site lead and vendor contact) B. Information to be Provided Onsite to the Inspector(s) at the Entrance Meeting (March 17, 2014): B.1 Inservice Inspection / Welding Programs and Schedule Information a) Updated schedules for inservice inspection/nondestructive examination activities, including steam generator tube inspections, planned welding activities, and schedule showing contingency repair plans, if available. b) For ASME Code Class welds selected by the inspector from the lists provided from section A of this enclosure, please provide copies of the following documentation for each subject weld: i. Weld data sheet (traveler).

ii. Weld configuration and system location. iii. Applicable Code Edition and Addenda for weldment. iv. Applicable Code Edition and Addenda for welding procedures. v. Applicable welding procedures used to fabricate the welds. vi. Copies of procedure qualification records (PQRs) supporting the weld procedures from B.1.b.v. vii. Copies of welder's performance qualification records (WPQ). viii. Copies of the nonconformance reports for the selected welds (If applicable).

ix. Radiographs of the selected welds and access to equipment to allow viewing radiographs (if radiographic testing was performed). x. Copies of the preservice examination records for the selected welds. xi. Readily accessible copies of nondestructive examination personnel qualifications records for reviewing. c) For the inservice inspection related corrective action issues selected by the inspectors from section A of this enclosure, provide a copy of the corrective actions and supporting documentation.

d) For the nondestructive examination reports with relevant conditions on ASME Code Class components selected by the inspectors from Section A above, provide a copy of the examination records, examiner qualification records, and associated corrective action documents. e) A copy of (or ready access to) most current revision of the inservice inspection program manual and plan for the current interval. f) For the nondestructive examinations selected by the inspectors from section A of this enclosure, provide a copy of the nondestructive examination procedures used to perform the examinations (including calibration and flaw characterization/sizing procedures).

For ultrasonic examination procedures qualified in accordance with ASME Code,Section XI, Appendix VIII, provide documentation supporting the procedure qualification (e.g. the EPRI performance demonstration qualification summary sheets).
Also, include qualification documentation of the specific equipment to be used (e.g., ultrasonic unit, cables, and transducers including serial numbers) and nondestructive examination personnel qualification records. B.2 Reactor Pressure Vessel Head (RPVH) a) Provide drawings showing the following (if performing any RPVH inspection activities): i. RPVH and control rod drive mechanism nozzle configurations.

ii. RPVH insulation configuration. Note: The drawings listed above should include fabrication drawings for the nozzle attachment welds as applicable. b) Copy of the documents which demonstrate that the procedures to be used for volumetric examination of the reactor vessel head penetration J-groove welds were qualified by a blind demonstration test in accordance with 10

CFR 50.55a(g)(6)(ii)(D).

c) Copy of volumetric, surface and visual examination records for the prior inspection of the reactor vessel head and head penetration J-groove welds.

B.3 Boric Acid Corrosion Control Program a) Please provide boric acid walk down inspection results, an updated list of boric acid leaks identified so far this outage, associated corrective action documentation, and overall status of planned boric acid inspections.

b) Please provide any engineering evaluations completed for boric acid leaks identified since the end of the last refueling outage.

Please include a status of corrective actions to repair and/or clean these boric acid leaks.
Please identify specifically which known leaks, if any, have remained in service or will remain in service as active leaks.
B.4 Steam Generator Tube Inspections a) Copies of the Examination Technique Specification Sheets and associated justification for any revisions.

b) Please provide a copy of the eddy current testing procedures used to perform the steam generator tube inspections (specifically calibration and flaw characterization/sizing procedures, etc.). c) Copy of the guidance to be followed if a loose part or foreign material is identified in the steam generators. d) Identify the types of SG tube repair processes which will be implemented for defective SG tubes (including any NRC reviews/evaluations/approvals of this repair process).

Provide the flaw depth sizing criteria to be applied for ET indications identified in the SG tubes. e) Copy of documents describing actions to be taken if a new SG tube degradation mechanism is identified. f) Provide procedures with guidance/instructions for identifying (e.g. physically locating the tubes that require plugging) and plugging SG tubes. g) List of corrective action documents generated by the vendor and/or site with respect to steam generator inspection activities.
B.5 Codes and Standards a) Ready access to (i.e., copies provided to the inspector(s) for use during the inspection at the onsite inspection location, or room number and location where available):

i. Applicable Editions of the ASME Code (Sections V, IX, and XI) for the inservice inspection program and the repair/replacement program. ii. EPRI and industry standards referenced in the procedures used to perform the steam generator tube eddy current examination. b) Copy of the performance demonstration initiative (PDI) generic procedures with the latest applicable revisions that support site qualified ultrasonic examinations of piping welds and components (e.g.,

PDI-UT-1,
PDI-UT-2,
PDI-UT-3,
PDI-UT-10, etc.).

c) EPRI and industry standard references in the site procedures used to perform the SG tube eddy current examination, which includes EPRI documents:

TR-107621-R1, "Steam Generator Integrity Assessment Guidelines,"
TR-107620-R1, "Steam Generator In-Situ Pressure Test Guidelines," Steam Generator Management Program:
Steam Generator Integrity
Assessment Guidelines, Part 10, and
1003138,

"Pressurized Water Reactor Steam Generator Examination Guidelines." d) Boric Acid Corrosion Guidebook Revision 1 - EPRI Technical Report 1000975.