ML20029F018
| ML20029F018 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/29/2020 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Gerry Powell South Texas |
| References | |
| IR 2019004 | |
| Download: ML20029F018 (40) | |
See also: IR 05000498/2019004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 EAST LAMAR BOULEVARD
ARLINGTON, TEXAS 76011-4511
January 29, 2020
Mr. G. T. Powell
President and CEO
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, TX 77483
SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1
AND 2- INTEGRATED INSPECTION REPORT 05000498/2019004
AND 05000499/2019004
Dear Mr. Powell:
On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at South Texas Project Electric Generating Station, Units 1 and 2. On
January 23, 2020, the NRC inspectors discussed the results of this inspection with
Ms. K. Harshaw, Vice President Regulatory Affairs and General Counsel, and other members of
your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Four of
these findings involved violations of NRC requirements. One Severity Level IV violation without
an associated finding is documented in this report. We are treating these violations as non-cited
violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector
at South Texas Project Electric Generating Station, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC Resident Inspector at South Texas Project Electric Generating Station, Units 1 and 2.
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000498 and 05000499
License Numbers: NPF-76 and NPF-80
Report Numbers: 05000498/2019004 and 05000499/2019004
Enterprise Identifier: 1-2019-004-0004
Licensee: STP Nuclear Operating Company
Facility: South Texas Project Electric Generating Station, Units 1 and 2
Location: Wadsworth, TX 77483
Inspection Dates: October 1, 2019, to December 31, 2019
Inspectors: B. Baca, Health Physicist
J. Choate, Resident Inspector
K. Clayton, Senior Operations Engineer
R. Kopriva, Senior Reactor Inspector
J. O'Donnell, Health Physicist
A. Sanchez, Senior Resident Inspector
Approved By: Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
Enclosure
G. Powell 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, "Public
Inspections, Exemptions, Requests for Withholding."
Sincerely,
Jeffrey E. Josey, Chief
Reactor Projects Branch A
Division of Reactor Projects
Docket Nos. 05000498 and 05000499
License Nos. NPF-76 and NPF-80
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's
performance by conducting an integrated inspection at South Texas Project Electric Generating
Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor
Oversight Process is the NRC's program for overseeing the safe operation of commercial
nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more
information.
List of Findings and Violations
Failure to Report a Chanqe in Medical Condition of a Licensed Operator
Cornerstone Significance Cross-Cutting Report
Aspect Section
Not Applicable NCV 05000499,05000498/2019004-01 Not Applicable 71111.11 B
Open/Closed
The inspectors identified a Severity Level IV non-cited violation of 10 CFR 55.25,
"Incapacitation Because of Disability or Illness," for the licensee's failure to notify the NRC
within 30 days of a chanqe in a licensed operator's medical condition.
Failure to Perform a Risk Assessment Prior to Performing Maintenance
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green [H.5] -Work 71152
NCV 05000498/2019004-02 Management
Open/Closed
The inspectors identified a Green finding and associated non-cited violation of
10 CFR 50.65(a)(4) when the licensee failed to perform a risk assessment prior to performing
maintenance. Specifically, inspectors identified breaker relay calibrations being performed on
protected equipment in Unit 1 during the 345kV North bus outage.
Inadequate Work Instruction Results in Loss of Spent Fuel Pool Cooling
Cornerstone Significance Cross-Cutting Report
Aspect Section
Barrier Integrity Green [H.8] - 71152
NCV 05000499/2019004-03 Procedure
Open/Closed Adherence
A self-revealed Green finding and associated non-cited violation of Technical
Specification 6.8.1.a, Regulatory Guide 1.33, Section 9, was identified for the failure to
provide adequate work instruction for maintenance associated with an emergency diesel
generator sequencer and resulted in a loss of spent fuel pool cooling. Specifically, the
licensee failed to identify the correct replacement part for the train C sequencer and once
installed, resulted in a loss of all train C electrical loads, including the operating train of spent
fuel pool cooling.
Inadequate Work Instructions Result in Reactor Coolant System Leaks
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green [H.5] -Work 71152
NCV 05000499,05000498/2019004-04 Management
2
I Open/Closed I I
A self-revealed Green finding and associated non-cited violation of Technical
Specification 6.8.1.a was identified for the failure to provide adequate work instruction for
compression fitting connections that resulted in reactor coolant system leakage. Specifically,
the licensee failed to provide adequate work instructions for reconnecting high-pressure RCS
instrument tubing compression fittings. This resulted in RCS leaks which required a
temporary modification and a high-risk work activity to stop the leaks that threatened stable
plant operations.
Failure to Follow Procedure Results in Two Inoperable Emergency Diesel Generators
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11] - 71152
Systems NCV 05000499,05000498/2019004-05 Challenge the
Open/Closed Unknown
A self-revealed Green finding and associated non-cited violation of Technical
Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.s.2.a, was identified for the failure to
follow an emergency diesel generator (EOG) testing procedure, which resulted in two EDGs
becoming inoperable at the same time. Specifically, the licensee failed to follow
Procedure OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 ), " Checklist 1,
"DG Standby Operation Checklist," Revision 70, Step 29.2, such that the train B EOG became
inoperable while the train A EOG was inoperable.
Additional Tracking Items
None.
3
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire period.
Unit 2 began the inspection period at 98 percent thermal power due to coast down operations.
On October 4, 2019, Unit 2 commenced rector shutdown to being refueling outage 2RE20 and
entered Mode 3. Unit 2 entered Mode 1 on November 4, 2019, and reached rated thermal
power on November 7, 2019. Unit 2 operated at or near rated power for the rest of the period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection
Program - Operations Phase." The inspectors performed plant status activities described in
IMC 2515, Appendix D, "Plant Status," and conducted routine reviews using IP 71152, "Problem
Identification and Resolution." The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
(1) The inspectors evaluated readiness to cope with external flooding for the following
areas:
- Units 1 and 2 flood panels for component cooling water heat exchangers
- Unit 1 reactor containment building
- Electrical auxiliary building flood doors
- Essential cooling water intake structure
71111.040 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01 ) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1, train B essential chilled water system while train C was out of service for
planned maintenance on December 16, 2019
(2) Unit 1, condenser air removal pumps 11 and 13 while condenser air removal
pump 12 was out of service due to emergent maintenance on December 17, 2019
(3) Unit 2, train A component cooling water while train B was out of service for planned
maintenance on December 18, 2019
4
71111.04S - Equipment Alignment
Com plete Walkdown Sam ple (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
Unit 2, train C component cooling water, with train B out of service, while train C was
relied upon for decay heat removal during the refueling outage on October 17, 2019.
71111.050 - Fire Protection
Quarterly Inspection (IP Section 03.01 ) (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Unit 2, reactor containment building, Fire Area 63, on October 18, 2019
(2) Unit 2, train A essential cooling water intake structure, Fire Area 58, on
December 30, 2019 I
(3} Unit 1, train A component cooling water, Fire Area 02 and 20, on December 30, 2019
(4} Unit 1, train A essential cooling water intake structure, Fire Area 58, on
December 31, 2019
(5} Unit 2, train A component cooling water, Fire Area 02 and 20, on December 31, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (I P Section 02.02a. ) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1) The inspectors evaluated internal flooding mitigation protections in Unit 2, train 8,
4160 volt switchgear room on November 20, 2019
71111.08P - lnservice Inspection Activities (PWR)
PWR lnservice Inspection Activities Sample (I P Section 03.01 ) (1 Sample)
(1} The inspectors verified that the reactor coolant system boundary, steam generator
tubes, reactor vessel internals, risk-significant piping system boundaries, and
containment boundary are appropriately monitored for degradation and that repairs
and replacements were appropriately fabricated, examined and accepted by
reviewing the following activities from October 15 to 28, 2019:
03.01.a - Nondestructive Examination and Welding Activities.
- 1 - Magnetic Particle Examination
- 2 - Dye Penetrant Examinations
- 6 - Ultrasonic Examinations
- 1 - Visual Examination
5
On October 16, 2019, during Unit 2 refueling outage 2RE20, inservice inspections
of the pressurizer 2A upper head safety nozzle N4C (nozzle designation
per ISi Figure A-PRZ-1; see Attachment B) to shell weld discovered one ultrasonic
testing (UT) indication. The subject indication was processed in accordance with
Addendum 2 of Procedure OPGP04-ZE-0304 "lnservice Inspection Program for
Welds and Component Supports." The indication was determined to be a '
subsurface flaw and subsequently characterized within Ultrasonic Examination
Reports UT-2019-031 and UT-2019-032. Article IWB-3000 of Section XI contains the
criteria for the acceptance of flaws or other relevant conditions found during
examination with the Acceptance Standards summarized within Table IWB-3410-1
"Acceptance Standards." For this particular location, this weld falls into Examination
Category B-D (full penetration and welded nozzles in vessels); therefore, IWB-3512
acceptance standards apply. Using the flaw dimensions summarized above, and the
Allowable Flaws given in Table IWB-3512-1, the flaw does not meet the acceptance
standards for the aspect ratio calculated. Given this, the indication requires the use
of IWB-3132.3 requiring an analytical evaluation per IWB-3600. Indications that are
rejectable based on IWB-3500 can be evaluated per a detailed fracture
mechanics evaluation based on IWB-3600 to demonstrate flaw acceptability.
By Letter LTR-SDA-19-095-P, Westinghouse has performed a detailed fracture
mechanics evaluation in accordance with IWB-3612 and Non-Mandatory Appendix A,
"Analysis of Flaws," and has shown that the indication found during 2RE20 inservice
r
inspections is acceptable for at least 36 months (two full fuel cycles).
One gas tungsten arc welding activity was observed (control volume and chemical
control system valve replacement under Work Orders 96017307 and 598944 for Weld
Nos. RW0027 and FW0028).
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination
Activities .
- The bare metal visual inspection of the reactor vessel upper head
penetrations was required to be performed during this outage, 2RE20. The
inspector reviewed the following reactor head penetration visual
examinations: penetration nozzles 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72,
75-78, including vent pipe and general head area. Also, a direct visual was
performed in those areas that had limitations for the crawler. No concerns
were identified.
- The bare metal visual inspection of the bottom mounted instrumentation
nozzles was performed during this outage, 2RE20. The inspector reviewed
the following reactor head penetration visual examinations: Penetration
nozzles 1-58. No concerns were identified.
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
- The inspector reviewed the following documents associated with boric acid
leaks and evaluations:
- Evaluations: 17-18419-2, 18-11258-2, 18-6471, 19-7578-3, 19-7950
6
- Corrective Actions: 19-10796, 19-10798, 19-11061, 19-11062, 19-11065,
19-11066, 19-11067, 19-11072, 19-11074, 19-11075, 19-11076,
19-11111, 19-11112, 19-11113, 19-11114, 19-11160, 19-11161,
19-11163, 19-11202, 19-11219, 19-11220, 19-11221, 19-11222,
19-11223,19-11224, 19-11225
03.01.d - Mechanical Stress Improvement Process used on Reactor Vessel Hot and
Cold Leg Nozzle to Safe-End Welds.
- During the 2019 Refueling Outage for Unit 2, 2RE20, the inspector witnessed
the license's performance of mechanical stress improvement on the reactor
vessel hot and cold leg nozzle to safe-end, dissimilar metal welds. This
mechanical process helps prevent and mitigate primary water stress
corrosion cracking in piping by minimally contracting the pipe on one side of
the weldment, replacing residual tensile stresses with compressive stresses.
This removal of as-welded tensile stresses is an effective and permanent
means to prevent or mitigate primary water stress corrosion cracking.
71111.11 B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
(1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification
written examination administered on August 5, 2019.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensee's annual requalification
operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering
requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility
licensee is effectively evaluating their licensed operators for mastery of training
objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination
material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the
licensee, and reviewed the adequacy of re-examinations for licensed operators who
did not pass a required requalification examination.
7
Operator License Conditions
The inspectors evaluated the licensee's program for ensuring that licensed operators
meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensee's control room
simulator in modeling the actual plant, and for meeting the requirements contained in
Problem Identification and Resolution
The inspectors evaluated the licensee's ability to identify and resolve problems
associated with licensed operator performance.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated an operating crew annual exam on
November 26, 2019.
71111.11 Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01 )
(1 Sample)
( 1) The inspectors observed a evaluated the performance of a Unit 1 operating crew
while in an alternate 13.BkV bus alignment due to an emergent issue with the main
generator output breaker preventing automatic trip of that breaker on
December 11, 2019.
The inspectors observed and evaluated the performance of a Unit 1 operating crew
during a high risk evolution to replace two power supplies in the train R solid state
protection system on December 18, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01 } (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with
the following equipment and/or safety significant functions:
(1) Units 1 and 2, essential cooling water systems on November 30, 2019
(2) Units 1 and 2, component cooling water system on December 30, 2019
(3) Units 1 and 2, emergency safeguards sequencer on December 30, 2019
8
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01 ) (4 Sam ples}
The inspectors evaluated the risk assessments for the following planned and emergent work
activities:
(1) Unit 2, planned risk due to train C essential cooling water, essential chilled water,
emergency core cooling, containment spray, and emergency diesel generator
maintenance the week of October 1, 2019
(2) Unit 2, emergent risk due to train C engineered safety feature load sequencer
requiring a card replacement on October 28, 2019
(3) Unit 2, emergent risk due to train A engineered safety feature load sequencer failure
during a large train B work week and resulted in the use of the Configuration Risk
Management Program on November 20, 2019
(4) Units 1 and 2, planned risk due to the maintenance on the 345kV south bus and
Unit 2, standby transformer and use of the Configuration Risk Management Program
the week of December 4, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (I P Section 02.02) (6 Sam ples}
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Unit 2, turbine-driven auxiliary feedwater governor stem nut missing on
October 21, 2019
(2) Unit 1, train A essential chilled water due to a degraded temperature control module
that failed to keep the output temperature less than 48 degrees Fahrenheit on
November 8, 2019
(3) Unit 2, damaged control room envelope door on November 11, 2019
(4) Unit 2, train B emergency diesel generator jacket water leak on November 14, 2019
(5) Unit 1, train A essential cooling water due to a through wall indication on
flange EW-1006 due to aluminum bronze dealloying phenomenon on
November 20, 2019
(6) Unit 2, train C high head safety injection pump bearing oil level indicator installed
upside down following motor replacement on November 27, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02 )
(3 Samples}
The inspectors evaluated the following temporary or permanent modifications:
(1) Units 1 and 2, temporary diesel-driven fire pump during repair and replacement of
diesel-driven fire pump components on April 15, 2019
(2) Unit 2, temporary modification to power spent fuel pool cooling pump 2A during
refueling outage 2RE20 on October 18, 2019
9
(3) Units 1 and 2, permanent modification to install a quick exhaust valve to reduce the
time required to close the valve on a main steam actuation signal on
December 31, 2019
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sam ple (I P Section 03.01 ) (4 Sam ples)
The inspectors evaluated the following post maintenance tests:
( 1) Unit 2, local leak rate test of the auxiliary containment airlock following maintenance
on the sealing surfaces on October 24, 2019 .
(2) Unit 2, local leak rate test of the normal containment purge exhaust isolation damper,
2-HC-9, following emergent maintenance following a failed local leak rate test on
October 27, 2019
(3) Unit 2, nuclear instrumentation Nl-35 following the replacement of the log amplifier
module on November 3, 2019
(4) Unit 1, reactor coolant system leak check and flow transmitter FT-0419 following the
replacement of the reactor coolant system instrument tubing due to an increasing
leak on December 6, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sam ple {IP Section 03.01 ) (1 Sam ple)
( 1) The inspectors evaluated refueling outage 2RE20 activities from October 4 through
November 5, 2019.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01 ) (3 Sam ples)
(1) Unit 1, train C essential cooling water pump surveillance test on December 14, 2019
(2) Unit 1, train C emergency diesel generator monthly surveillance test on
December 17, 2019
(3) Unit 1, train C auxiliary feedwater pump surveillance test on December 18, 2019
FLEX Testing (IP Section 03.02) ( 1 Sam ple)
(1) Unit 1, FLEX diesel generator surveillance test on December 12, 2019
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (I P Section 02.01-02.03 ) (1 Sample}
(1) The licensee submitted "South Texas Project Emergency Plan," Revision ICN 20-21,
as well as a copy of Revision ICN 20-22, to the NRC on August 8, 2019. The
inspectors conducted an in-office review of the changes from November 13 to
November 25, 2019. This evaluation does not constitute NRC approval.
10
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 02.01 ) (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
(1} The inspectors reviewed the following :
Radiological Surveys
- Spent Fuel Pool Cell Inventory
- Concentrate Transfer Pump 1B
- Fuel Transfer Tube Access
- Radwaste Truck Bay
- Reactor Cavity Walkway
Risk Significant Radiological Work Activities
- In-Core (Thimble Tube)
- Head Lift
- Lift Rig
Air Sample Survey Records
- 22373
- 21434
- 21441
- 21468
- 21505
Instructions to Workers (IP Section 02.02 ) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to
access high radiation areas.
(1) The inspectors reviewed the following:
Radiation Work Packages
- 2019-2-0165, 2RE20 - Maintenance and Support Work - Room 307 (LHRA)
- 2019-2-0173, 2RE20 - Maintenance on N2CVPSV3100 (LHRA)
- 2019-2-0158, 2RE20 - Reactor Head Lift Activities (LHRA)
Electronic Alarming Dosimeter Alarms
- Dose Rate Alarm - 18-04050
- Dose Rate Alarm -18-04757
- Dose Rate Alarm - 18-11562
- Dose Rate Alarm -18-12585
11
Labeling of Containers
- Box 300437
- Radwaste Bags
- 55 Gallon Barrel
- Box #20-2466
- OSSC#26
Contamination and Radioactive Material Control (I P Section 02.03) (1 Sample)
The inspectors evaluated licensee processes for monitoring and controlling contamination
and radioactive material.
(1) The inspectors verified the following sealed sources are accounted for and are intact:
- MS-0042
- MS-0132
- NAM-1335
- NCF-0604
- NCS 0114/0115
- NCS-0008
Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and
observation of radiological work activities.
(1) The inspectors also reviewed the following radiological work package for areas with
airborne radioactivity:
- Unanticipated airborne radioactivity during 2RE20 flood-up
o RWP 2019-2-0158, 2RE20- Reactor Head Lift Activities (LHRA)
o ALARA Review Package 19-3165-7, 2RE20 Non-Rapid Refuel
o DAC-hr Assessment for Condition Report 19-11442
High Radiation Area and Very High Radiation Area Controls (IP Section 02.05 ) (1 Sam ple )
(1) The inspectors evaluated risk-significant high radiation area and very high radiation
area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 02.06) (1 Sample)
(1) The inspectors evaluated radiation worker performance and radiation protection
technician proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (IP Section 02.01 ) (1 Sample)
The inspectors evaluated airborne controls and radioactive monitoring .
12
( 1) The inspectors reviewed the following :
Installed Ventilation Systems
Temporary Ventilation System Setups
- Radwaste sorting vent hoods and associated HEPA units
- Reactor head HEPA units
Portable or Installed Monitoring Systems
- Room specific AMS-4 units: Radwaste sorting room and seal table (thimble)
room
- General containment monitoring with AMS-4
- Low volume filter air samples covering reactor head, cavity, and thimble work
Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)
The inspectors evaluated the licensee's use of respiratory protection devices by:
( 1) Observing in-field applications; verifying the licensee validated the level of protection
provided by the devices; inspecting the material condition of devices, reviewing
records and certification of devices issued for use; reviewing the qualifications of
workers that use the devices; and observing workers' donning, doffing and testing
devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)
The inspectors evaluated self-contained breathing apparatus program implementation.
(1) The inspectors reviewed the following :
Status and Surveillance Records for Self-Contained Breathing Apparatus
- SCBA kit #433
- SCBA kit #434
- SCBA kit #462
- SCBA kit #514
- SCBA kit #551
Self-Contained Breathing Apparatus Fit for On-Shift Operators
The inspectors selected two on-shift Unit 2 reactor operators for verification of fit
testing, medical approval, donning/doffing practical, and bottle change out protocol.
Self-Contained Breathing Apparatus Maintenance Check
- SCBA kit #434
- SCBA kit #462
- SCBA kit #514
13
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Sam ples )
(1) Unit 1, October 1, 2018, through September 30, 2019
(2) Unit 2, October 1, 2018, through September 30, 2019
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Sam ples )
(1) Unit 1, October 1, 2018, through September 30, 2019
(2) Unit 2, October 1, 2018, through September 30, 2019
OR01: Occu pational Exposure Control Effectiveness Sam ple (IP Section 02.15) (1 Sample)
(1) January 1, 2018, through September 30, 2019
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM ) Radiological Effluent Occurrences Sam ple
(IP Section 02.16 ) (1 Sam ple)
(1) January 1, 2018, through September 30, 2019
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
( 1) The inspectors reviewed the licensee's corrective action program for potential
adverse trends that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (4 Sam ples)
The inspectors reviewed the licensee's implementation of its corrective action program
related to the following issues:
(1) The increase in the number of reactor coolant system leaks for high pressure
compression fitting leading to reactor coolant system loop flow transmitters in Units 1
and 2
(2) The failure to assess risk prior to performing maintenance on protected 13.8kV supply
breaker to the train B 4.16kV switchgear while the 345kV North bus and the Unit 1
standby transformer were out of service for planned maintenance
(3) Inadequate work instruction on Unit 2, train C engineered safety feature load
sequencer results in the loss of spent fuel pool cooling
(4) The Unit 1, train B emergency diesel generator was rendered inoperable by a human
performance error
14
INSPECTION RESULTS
Failure to Report a Change in Medical Condition of a Licensed Operator
Cornerstone Severity Cross-Cutting Report
Aspect Section
Not Severity Level IV Not 71111.11 B
Applicable NCV 05000499,05000498/2019004-01 Applicable
Open/Closed
The inspectors identified a Severity Level IV non-cited violation of 10 CFR 55.25,
"Incapacitation Because of Disability or Illness," for the licensee's failure to notify the NRC
within 30 days of a change in a licensed operator's medical condition .
Description: On June 19, 2014, a senior reactor operator self-reported to the site medical
department the diagnosis of a new medical condition. The licensee recorded the new
medical condition in the operator's site medical record and drafted a new NRC Form 396 to
report a "no solo". condition was being added on the license. The new Form 396 was lost in
the review and approval process on site, and at the time there was not a tracking mechanism
in place to ensure the review and approval process was completed. As a result, the new
Form 396 was never provided to the NRC.
While reviewing a license renewal application, an inspector identified that a "no solo"
restriction that had not previously been reported to the NRC was included on the NRC
Form 396 that was submitted with the license renewal application. The NRC notified the
licensee of the discrepancy on October 8, 2019. The licensee confirmed that site records
reflected a "no solo" condition had been added for the individual. The licensee determined
that the senior reactor operator had not been on shift since the condition was reported
in 2014.
Corrective Actions: On October 17, 2019, the South Texas Project Nuclear Operating
Company submitted a letter to the NRC with a revised NRC Form 396, "Certification of
Medical Examination by Facility Licensee," that prohibited solo operation of the controls. The
"no solo" condition was required for fitness-for-duty reasons in accordance with the American
National Standards Institute (ANSl)-3.4-1983, "Medical Certification and Monitoring of
Personnel Requiring Operator Licenses for Nuclear Power Plants,"
Corrective Action References: Condition Report 2019-11414
Performance Assessment: The inspectors determined this violation was associated with a
minor performance deficiency.
Enforcement: The ROP's significance determination process does not specifically consider
the regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation which impedes the NRC's ability to regulate using
traditional enforcement to adequ~tely deter non-compliance.
Severity: The inspectors determined the violation to be a Severity Level IV violation, similar
to Example 6.4.d.1.b in the NRC Enforcement Policy because it was a nonwillful compromise
of an examination required by 10 CFR Part 55. Specifically, the licensee nonwillfully failed to
inform the NRC of a change in an operator's medical condition. The individual did not
perform the functions of a senior reactor operation while having a disqualifying medical
condition.
15
Violation: Title 10 CFR 55.25 requires, in part, that if a licensed senior reactor operator
develops a permanent physical condition that causes the licensee to fail to meet the
requirements of 10 CFR 55.21, the facility shall notify the Commission within 30 days of
learning of the diagnosis. For conditions where a license condition is required, the facility
licensee must provide medical certification on NRC Form 396, "Certification of Medical
Examination by Facility Licensee." Contrary to the above from June 9, 2014, to
October 17, 2019, the licensee failed to notify the Commission, within 30 days of learning the
diagnosis of a change in medical condition of a licensed senior reactor operator that
developed a permanent physical condition that caused the licensed senior reactor operator to
fail to meet the requirements of 10 CFR 55.21. Specifically, on June 9, 2014, a senior reactor
operator self-reported a new medical condition, the medical department determined that the
individual required a "no solo" condition on his license, but the NRC did not receive the
revised NRC Form 396 until October 17, 2019.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Perform a Risk Assessment Prior to Performinq Maintenance
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green [H.5]-Work 71152
NCV 05000498/2019004-02 Management
Open/Closed
The inspectors identified a Green finding and associated non-cited violation
of 10 CFR 50.65(a)(4) when the licensee failed to perform a risk assessment prior to
performing maintenance. Specifically, inspectors identified breaker relay calibrations being
performed on protected equipment in Unit 1 during the 345kV North bus and Unit 1 standby
transformer planned maintenance.
Descri ption: The South Texas Project 345kV switchyard consists of two 345kV buses, North
and South. Each of the buses in the switchyard supplies offsite power to the Units 1 and 2
standby transformers. These transformers constitute an offsite power source. On
April 30, 2018, while the North bus and the Unit 1 standby transformer were out of service for
planned maintenance activities, which placed the station in the configuration risk
management program, the inspectors performed a walkdown of the protected equipment due
to the maintenance. Specifically, the inspectors walked down all protected electrical power
supplies, including the 13.8kV Standby bus in Unit 1. There, inspectors discovered
two electricians performing relay calibrations on the 13.8kV standby bus 1G to the
4.16kV Aux EAB XFMR E 1B breaker. The inspectors determined that the work could have
resulted in a trip of the breaker and would present a loss of offsite power to the train B 4.
16kV switchgear which would result in an auto start signal to the train B emergency diesel
generator. The inspectors observed the work activity for a while to ensure the activity was
being performed with quality before heading to the work start desk to inquire why the work
was allowed to take place.
The inspector asked if the work start personnel were aware of the current plant condition and
the heightened level of awareness for protected equipment due to the maintenance and why
the observed relay work was approved. The work start personnel stated that it was in the
approved work schedule, so permission was granted. The inspector then spoke with the
work week coordinator and presented the situation observed. The work week coordinator
stated that the work should not have been given permission to start and that the work activity
16
should not be on the schedule. It had somehow been missed in the work schedule scrub for
the work week for the given plant condition. The work week coordinator initiated Condition
Report 2018-6019.
The licensee determined that the relay calibration for the supply breaker should not have
been allowed and should not have been on the schedule. The work planning schedule
reviews (multiple reviews) by maintenance, engineering, planning, and operations failed to
identify and remove the activity from the schedule.
Corrective Actions: The licensee held discussions with work control specifically to inform
them of the condition report, the NRC observation, and stressed the need to thoroughly
review work during the work planning process.
Corrective Action References: Condition Report 2018-6019
Performance Assessment:
Performance Deficiency: The failure to perform a risk assessment prior to performing
maintenance activities was a performance deficiency. Specifically, the licensee failed to
perform a risk assessment prior to allowing relay work on the Unit 1 13.8kV standby bus 1G
to 4.16kV Aux EAB XFMR E1 B (train B 4.16kV switchgear) while these components were
protected for 345kV North bus and Unit 1 standby transformer planned maintenance.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the human performance 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 failure to perform a risk assessment on the relay
calibration activity prevented proper controls to be implemented if the work activity was
deemed necessary, as such the licensee unknowingly increased the likelihood of upsetting
the stability of the plant.
Significance: The inspectors assessed the significance of the finding using Appendix K,
"Maintenance Risk Assessment and Risk Management SDP." In accordance with Step 4.1.1,
"Licensee Evaluation of Risk," the inspectors reviewed the licensee's risk evaluation that
indicated no additional numerical risk as a result of the additional maintenance activity
because the activity was not intended to open the associated breaker. The licensee's risk
assessment tools do not include an increase in the probability that equipment being worked
on will be lost from a postulated maintenance error. Given this notable limitation with the
licensee's configuration risk assessment tool, the inspectors requested the regional senior
reactor analyst to independently evaluate the risk. The analyst evaluated the bounding risk
related to a loss of offsite power to Bus E1 B. The analyst determined this failure would not
result in a plant transient and would not affect the other two Unit 1 trains being supplied by
offsite power. The analysis indicated that the availability of other redundant trains,
emergency onsite power, and the short period of time that offsite power would have been
unavailable given a maintenance error, resulted in a very low risk deficit (incremental core
damage probability). Therefore, this finding is of very low safety significance (Green).
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Specifically,
17
the licensee failed to implement the process of planning, controlling and executing work
activities such that nuclear safety is the overriding priority. The work control process did not
identify and manage the risk for the 13.8kV standby bus 1G breaker to the 4.16kV Aux EAB
XFMR EIB relay work activity.
Enforcement:
Violation: Title 10 CFR 50.65 (a)(4) states, in part, "before performing maintenance activities,
the licensee shall assess and manage the increase in risk that may result from the proposed
maintenance activiti~s ... " Contrary to the above, on April 30, 2018, before performing
maintenance, the licensee failed to assess and manage the increase in risk that may result
from proposed maintenance activities. Specifically, the inspectors discovered that the
licensee performed relay calibration maintenance activities on the Unit 1, 13.8kV standby bus
1G to 4.16kV Aux EAB XFM R E 1B (train B 4.16kV switchgear) without a risk assessment as
required by 10 CFR 50.65(a)(4).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Inadequate Work Instruction Results in Loss of Soent Fuel Pool Cooling
Cornerstone Significance Cross-Cutting Report
Aspect Section
Barrier Integrity Green [H .8] - 71152
NCV 05000499/2019004-03 Procedure
Ooen/Closed Adherence ,
A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 9, was identified for the failure to
provide adequate work instruction for maintenance associated with an engineered safety
feature load sequencer and resulted in a loss of spent fuel pool cooling. Specifically, the
licensee failed to identify the correct replacement part for the train C engineered safety
feature load sequencer, and once installed resulted in a loss of all train C electrical loads,
includinq the operatinq train of spent fuel pool coolinq.
Description: On October 24, 2019, Unit 2 was in Mode 6 coming out of the refueling outage
with the core reloaded and one of two trains of spent fuel pool cooling in service when an
annunciator in the control room indicated an issue with the train C engineered safety feature
load sequencer. Work Planning developed a work order to remove and replace opto-isolators
in the sequencer as part of troubleshooting. Work Planning wrote the work order procedure
and ordered the parts from the warehouse to be delivered to the craft in their shop but used
the wrong stock code. Per the vendor drawings, opto-isolator model 0DC-24A was
supposed to be used (stock code 596-849). Instead, the work order and parts order
referenced stock code 596-775 which is for opto-isolator model ODC-24. While the two
models appear very similar, 0DC-24A allows an output of 125VDC while the ODC-24 allows
only 24VDC.
Instrumentation and control technicians went to the sequencer to replace the opto-isolators
as part of troubleshooting. When they removed the original opto-isolators (0DC-24A), the
technicians noted the "A" on the original components which were not present on their
replacements (ODC-24). Neither of the technicians could recall what the "A" represented,
and the work order did not explicitly provide the opto-isolator model (0DC-24A vs. ODC-24),
only the stock code which is not printed on the actual parts. The technicians installed the
replacement opto-isolator into the enqineered safety feature load sequencer and the
18
sequencer immediately shed all electrical loads from the train C electrical bus. With the train
C EDG in pull-to-stop for the sequencer troubleshooting, all train C electrical loads were lost
including the single train of spent fuel pool cooling that was in operation at the time.
Annunciators in the control room alerted operators the loads on the train C electrical bus were
lost, and one of those loads was spent fuel pool cooling. Operators restored spent fuel pool
cooling within 30 minutes with no rise in spent fuel pool water temperature. Operators took
the train C EDG out of pull-to-stop the EDG automatically started and loaded the bus without
issue. The core never lost residual heat removal as trains A and B were in service at this
time. The licensee made an 8-hour report to the NRG on October 25, 2019, at 3:24 a.m. for a
valid engineered safety feature actuation signal (Event Notification 54351 ).
The licensee initiated Condition Report 2019-12401 to investigate the event. The apparent
cause determined that work control failed to provide adequate work instruction by identifying
the wrong part to be installed jn the Unit 2, train C engineered safety feature load sequencer.
The licensee determined that the planners failed to use a reference Procedure, WCG-0003,
"Planner's Guide," Revision 39, that would have required this issue to be elevated to an
emergent issue requiring multiple stakeholders to meet to review the planned work.
Furthermore, the cause evaluation determined that maintenance technicians failed to follow
the maintenance conduct of operations procedure and compare parts and stop work if there
are any discrepancies.
Corrective Actions: The licensee counseled the technicians and work planners involved and
a lessons learned document was written and discussed with planning and maintenance. The
licensee has also included this event as a case study for their mechanical maintenance
training with an emphasis on verifying like-for-like parts.
Corrective Action References: Condition Reports 2019-12372 and 2019-12401
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instruction for maintenance
associated with an engineered safety feature load sequencer, which resulted in a loss of
spent fuel pool cooling, was a performance deficiency. Specifically, the licensee failed to
identify and incorporate accurate component information when planning work on the train C
engineered safety feature load sequencer.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the SSC performance attribute of the Barrier Integrity
cornerstone and adversely affected the cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases caused
by accidents or events. Specifically, the failure to properly pre-plan and perform maintenance
on the train C engineered safety feature load sequencer caused a loss of all electrical loads
associated with the train C electrical bus. As a result, the single operating train of spent fuel
pool cooling was lost.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The
Significance Determination Process (SDP) for Findings At-Power." Specifically, the finding
did not cause the spent fuel pool (SFP) temperature to exceed its maximum analyzed
temperature limit, did not result in a detectible release of radionuclides, did not result in a loss
of SFP water inventory below the SFP's minimum analvzed level limit, and did not affect the
19
SFP neutron absorber, fuel bundle loading pattern, or soluble boron concentration; therefore,
the findings were determined to be of very low safety significance, Green .
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures,
and work instructions. Specifically, work planning failed to follow appropriate procedures to
ensure multi-discipline participation to determine a proper plan of action and in assembling
adequate work instructions to repair the Unit 2, train C engineered safety feature load
sequencer without challenqing the plant equipment.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires, in part, that written procedures shall be
established, implemented, and maintained in accordance with Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978. Section 9 of Appendix A to Regulatory Guide 1.33,
Revision 2, requires that "maintenance that can affect the performance of safety-related
equipment should be properly pre-planned and performed in accordance with written
procedures, documented instructions, or drawings appropriate to the circumstances."
Contrary to the above on October 24, 2019, the licensee failed to properly pre-plan
maintenance that can affect the performance of safety-related equipment. Specifically, the
licensee failed to identify and request the correct replacement parts for the Unit 2, train C
engineered safety feature load sequencer. As a result, Unit 2, lost all train C electrical loads,
including the single operating train of spent fuel pool cooling.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Inadequate Work Instructions Result in Reactor Coolant System Leaks
Cornerstone Significance Cross-Cutting Report
Aspect Section
Initiating Events Green [H.5] -Work 71152
NCV 05000499,05000498/2019004-04 Management
Open/Closed
A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a was identified for the failure to provide adequate work instruction for compression
fitting connections that resulted in reactor coolant system (RCS) leakage. Specifically, the
licensee failed to provide adequate work instructions for reconnecting high-pressure RCS
instrument tubing compression fittings. This resulted in RCS leaks which required a
temporary modification and a high-risk work activity to stop the leaks that threatened stable
plant operations.
Descri ption: At South Texas Project, each RCS primary loop has three independent flow
transmitters that would input into the reactor protection system to trip the reactor if 2 out of 3
flow transmitters in a single loop were to read less than 92 percent. Per Technical Specification 3.3.1, each channel could be bypassed for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> then the channel
would have to be restored or placed into a "Trip" condition.
On August 29, 2018, Unit 2, field operators inside containment identified an active RCS leak
at RCS flow transmitter RC-FT-0428 (loop B flow transmitter). Specifically, the leak was
almost a steady stream of fluid, apparently emanating from a tubing fitting. Condition
Report 2018-10183 was written to note the deficiency. Later that year, a temporary
modification was installed to encapsulate the leaking tube fitting and injected with leak stop
until the leak was arrested. Operations installed a camera to periodically monitor the leak for
20
degradation. The modification was planned to be removed, and tubing and fittings replaced
during the next Unit 2, refueling outage in October 2019.
On November 14, 2018, Unit 1 field operators inside containment identified an active RCS
leak at RCS flow transmitter RC-FT-0419 (loop A flow transmitter). Specifically, the leak was
approximately a two-foot steam plume. Condition Report 2018-13993 was written to note the
deficiency. The licensee gained alignment to tighten the tubing connection, which was a
high-risk work activity. The tubing connection was successfully tightened, which reduced the
steam plume to several milliliters per minute leak. Operations installed a camera to
periodically monitor the leak for degradation. In addition, operations collected actual leak
rates from this tube connection. Due to the tubing configuration, a temporary modification to
install an encapsulating box as was done for the loop B flow transmitter was not feasible and
would have to be repaired in the next Unit 1, refueling outage in March 2020. However, prior
to the refueling outage, the leak began to get worse and engineering was tasked with
developing a repair solution. On December 6, 2019 the licensee successfully replaced the
leaking connection and tubing while at 100 percent power without perturbating the Unit. This
was a high-risk evolution that could have resulted in a reactor trip.
On November 24, 2018, Unit 1 operators identified that RCS flow transmitter RC-FT-0449
(loop D flow transmitter) would periodically exceed its three percent channel checks with the
other two loop D flow transmitters, RC-FT-0447 and RC-FT-0448. Condition
Report 2018-14266 was written to document the deficiency. It was determined that the flow
transmitter RC-FT-0449 was over ranged following a repair of a fitting leak identified at the
end of the refueling outage, while in Mode 3. This issue would have to be addressed in the
next Unit 1, refueling outage in March 2020.
The licensee initiated Condition Report 2018-14369 to evaluate the current trend of RCS
tubing compression fitting leaks as well as search for tubing leaks for the last four refueling
outages. The licensee's evaluation identified approximately 44 compression fitting issues
dating back to 2015. The common cause concluded that the leaks were a result of improper
assembly of Parker CPI compression fittings due to inadequate guidance in
procedure OPGP03-ZE-0056, "Instrumentation Installation," Addendum 7, "Installation
Instructions for Compression Fittings." In addition, the licensee determined that there was
inconsistent work instruction rigor for re-making these fittings in maintenance packages and
some relied on skill of the craft. It was also determined that the procedure did not incorporate
vendor recommendations on reassembly and did not use proper gages and other reassembly
tools.
Corrective Actions: The licensee enhanced procedure OPGP03-ZE-0056, 'Tubing and
Instrumentation" to reflect vendor recommendations for reassembly and the use of proper
tools. Training was identified and implemented to those maintenance workers who have this
certification. Lastly, the licensee revised portions of the procedure to "in-hand" use to ensure
compliance.
Corrective Action References: Condition Reports 2018-10183, 2018-13993, 2018-14266,
and 2018-14369.
21
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instruction for reassembly of
tubing compression fittings was a performance deficiency. Specifically, maintenance
activities of installing and reinstalling Parker tubing compression fittings without adequate
guidance resulted in repetitive RCS tubing leaks, which challenged stable plant operations.
Screening: The performance deficiency was determined to be more than minor because it
was associated with the equipment performance attribute of the Initiating Events cornerstone
and 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 failure to provide adequate work instructions to repair, remake, replace
Parker tubing compression fittings, resulted in RCS tubing leaks and instrument inaccuracies
that unduly challenged stable plant operations and high risk work evolutions to mitigate and
repair during the operational cycle.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The
Significance Determination Process (SOP) for Findings At-Power." Specifically, the finding
(1 )could not result in exceeding RCS leak rate for a small LOCA; (2) could not have affected
other systems used to mitigate a LOCA (LOCA Initiator); and (3) did not cause a reactor trip
and the loss of mitigating equipment relied upon to transition the plant from the onset of the
trip to a stable shutdown condition (Transient Initiators), therefore, the finding was determined
to be of very low safety significance, Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Specifically,
the work planning organization failed to ensure that quality work instruction products were
provided to the workforce to execute activities such that nuclear safety was the overriding
priority.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires in part, that written procedures shall be
established, implemented, and maintained in accordance with Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978. Section 9, "Procedures for Performing Maintenance,"
of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that
can affect the performance of safety-related equipment should be properly pre planned and
performed in accordance with written procedures, documented instructions, or drawings
appropriate to the circumstances. The licensee established procedure OPGP03-ZE-0056,
"Instrumentation Installation," Addendum 7, "Installation Instructions for Compression
Fittings," to meet that requirement for installing compression fitting on safety-related, reactor
coolant system tubing connections. Contrary to the above, from March 23, 2015 to August
14, 2019, the licensee failed provide adequate work instructions to properly install
compression fittings on safety-related reactor coolant system tubing connections. As a result,
multiple leaks were discovered on both units which challenged stable plant operations.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
22
Failure to Follow Procedure Results in Two Inoperable Emerqencv Diesel Generators
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11]- 71152
Systems NCV 05000499,05000498/2019004-05 Challenge the
Open/Closed Unknown
A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.s.2.a, was identified for the failure to
follow an emergency diesel generator (EOG) testing procedure, which resulted in two EDGs
becoming inoperable at the same time. Specifically, the licensee failed to follow procedure
OPOP02-DG-0001, "Emergency Diesel Generator 11(21)," Checklist 1, "DG Standby
Operation Checklist," Revision 70, Step 29.2, such that the train B EOG became inoperable
while the train A, EOG was inoperable.
Description: Unit 1 at South Texas Project has three trains of EDGs. On May 23, 2019,
operations personnel began restoring the train A, EDG following planned maintenance using
OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 )," Checklist 1, "DG Standby
Operation Checklist," Revision 70. A non-licensed operator was sent to the train A, EOG
local panel to perform step 29.2, which states "DEPRESS both 'EMERGENCY STOP
CIRCUIT' RESET pushbuttons." However, the non-licensed operator inadvertently went to
the train B, EOG local panel, depressed the "STOP" pushbuttons after depressing the
"RESET" pushbuttons, and did not receive an expected response. The control room
immediately received unexpected alarms indicating a malfunction with the starting circuit for
the train B, EDG and causing the EOG to become inoperable. With both the trains A and B,
EDGs inoperable, Unit 1 entered Technical Specification 3.8.1.1.e with a 24-hour LCO action
statement to restore at least one inoperable EOG to operable status, or apply the
requirements of the Configuration Risk Management Program, or be in at least hot standby
within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The control room staff immediately investigated the unexpected alarms and identified that the
issue with the starting circuit for the train B EOG was the result of human error. Another non-
licensed operator restored the starting circuit for the train B EOG. The control room declared
the train operable within 30 minutes of the train being made inoperable, exiting the 24-hour
LCO action statement.
Corrective Actions: Operations counseled the non-licensed operator and issued a site wide
Lessons Learned emphasizing the importance of taking the correct action on the correct train.
Corrective Action References: Condition Report 2019-5842
Performance Assessment:
Performance Deficiency: The failure to implement maintenance procedures involving safety-
related equipment was a performance deficiency. Specifically, a non-licensed operator failed
to implement procedure OPOP02-DG-0001, "Emergency Diesel Generator 11 (21 )," on the
correct EOG train and failed to manipulate the correct pushbuttons on the EOG local panel.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the equipment performance attribute of the Mitigating
Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable conseauences. Specificallv, the failure to implement maintenance procedures
23
involving the emergency diesel generators caused a second train of EOG to be made
inoperable. As a result, on May 23, 2019, Unit 1 entered into an unplanned 24-hour shutdown
action statement for both train A and B emergency diesel generators being inoperable.
Significance: The inspectors assessed the significance of the finding using Appendix A, "The
Significance Determination Process (SOP) for Findings At-Power." Specifically, the finding
did not cause an actual loss of function of at least a single train for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The train B emergency diesel generator was restored to operable within 30 minutes.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the
non-licensed operator failed to stop after depressing the "RESET pushbuttons on the
emergency diesel generator local panel and not receiving an expected response. Operations
also failed to evaluate and manage the risk of sending a newly qualified non-licensed
operator to perform a first-time evolution without supervision or assistance.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires, in part, that written procedures shall be
established, implemented, and maintained in accordance with Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978. Section 3.s.2.a of Appendix A to Regulatory
Guide 1.33, Revision 2, requires, in part, that instructions for energizing, startup, shutdown,
and changing modes of operation should be prepared for emergency power sources (e.g.,
diesel generators). The licensee established OPOP02-DG-0001, "Emergency Diesel
Generator 11 (21 }," Revision 70, to meet the Regulatory Guide 1.33 requirement. Checklist 1,
"DG Standby Operation Checklist," step 29.2 of the OPOP02-DG-0001 procedure states,
"DEPRESS both 'EMERGENCY STOP CIRCUIT' RESET pushbuttons." Contrary to the
above, on May 23, 2019, a non-licensed operator depressed both "EMERGENCY STOP
CIRCUIT" RESET pushbuttons for the incorrect EOG train and depressed an additional set of
pushbuttons after not receiving the expected response from the RESET pushbuttons.
Specifically, the licensee depressed the RESET and STOP pushbuttons for the Unit 1, train B
EOG. As a result, the train B, EOG was made inoperable during a time period where train A,
EOG was inoperable for maintenance, and operations made an unplanned entry into
Technical Specification 3.8.1.1.e, a 24-hour shutdown action statement.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: Semi-annual Trend Review I 71152
The inspectors reviewed the licensee's corrective action program entries, maintenance
activities, emergent maintenance issues, plant health reports, outage performance reviews,
NRC generated condition reports, and NRC inspector walk downs.
The inspectors noted and documented the following issues and trends:
- There are site wide issues with procedure use and adherence. Inspectors have
identified numerous issues while performing inspections (minor violations). Some of
these include signing work order steps complete before the step was complete,
equipment for risk significant work requiring entry into the Configuration Risk
Management Program were not properly protected, inadequate independent
verification of procedure steps, and failure to construct scaffolding in accordance with
orocedural quidance. In addition to these observations, the licensee identified similar
24
issues as illustrated in the South Texas Project 2019 mid-cycle review. The licensee
completed a common cause evaluation and is in the process of implementing
corrective actions.
- There have been several nuclear instrumentation issues and challenges, especially
during the last few outages. These issues have resulted in issuance of a Licensee
Event Report; an NRG-identified technical specification violation; and several
emergent issues that have challenged operations (making technical specification
calls), maintenance resources, and outage schedule delays and changes. The
licensee has entered the issues into the corrective action program to perform an
analysis and prescribe corrective actions, which is scheduled for completion in
February 2020.
- The licensee has recently experienced several issues involving engineered safety
feature load sequencers. A13art from one self-revealed technical specification violation
(documented in this report in Section 71152), the licensee.handled each issue
appropriately and without issue. In conjunction with the inspector observations, the
licensee had also identified a possible trend and entered the issue into the corrective
action program for analysis. The analysis is scheduled for completion in
February 2020.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 24, 2019, the inspectors presented the Occupational Radiation Safety
inspection results to Ms. K. Harshaw, Vice President Regulatory Affairs and General
Counsel, and other members of the licensee staff.
- On October 28, 2019, the inspectors presented the in service inspection results to
Mr. J. Connolly, Executive Vice President and Chief Nuclear Officer, and other members
of the licensee staff.
- On November 25, 2019, the inspectors presented the Emergency Plan In-Office Review
inspection results to Mr. J. Enoch, Manager, Emergency Response, and other members
of the licensee staff.
- On December 17, 2019, the inspectors presented the failure to report a change in
medical condition of a licensed operator inspection results to Mr. L. Sterling, Regulatory
Affairs Manager, and other members of the licensee staff.
- On December 19, 2019, the inspectors presented the biennial operator requalification
inspection results to Mr. D. Breland, Supervisor, Operations Training, and other
members of the licensee staff.
- On January 23, 2020, the inspectors presented the integrated inspection results to
Ms. K. Harshaw, Vice President Regulatory Affairs and General Counsel, and other
members of the licensee staff.
25
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.040 Drawings 5R209F05017#2 Piping and Instrumentation Diagram Component Colling 20
Water System
5R289F05038#1 Piping and Instrumentation Diagram Essential Cooling Water 20
System Train 1B
5V119V10001#1 Piping and Instrumentation Diagram Essential Chilled Water 35
System
8T219F00031#1 Piping and Instrumentation Diagram Condenser Air Removal 26
Procedures OPOP02-CC-OOO 1 Component CoolinQ Water 51
OPOP02-CH-OOO 1 Essential Chilled Water System 57
OPOP02-CR-OOO 1 Main Condenser Air Removal 71
71111.04S Corrective Action CR-YYYY-NNNN 2019-11970 2019-12022 2019-11969 2019-12023
Documents
Drawings 5R209F05019#2 Piping and Instrumentation Diagram Component Cooling 18
Water System
5R209F05020#2 Piping and Instrumentation Diagram Component Cooling 17
Water System
71111.05A Procedures OMAB02-FP-0128 Fire Preplan Mechanical Auxiliary Building CCW Pump and 4
Chiller, Train A
OMAB20-FP-0129 Fire Preplan Mechanical Auxiliary Building Non-Radioactive 3
Pipe Chase
OMAB27-FP-0142 Fire Preplan Mechanical Auxiliary Building CCW Heat 3
Exchangers
1ECW53-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5
0600 Room Train A
71111.050 Procedures OMAB02-FP-O 128 Fire Preplan Mechanical Auxiliary Building CCW Pump and 4
Chiller, Train A
OMAB20-FP-O 129 Fire Preplan Mechanical Auxiliary Building Non-Radioactive 3
Pipe Class
ORCB63-FP-0211 Fire Preplan Reactor Containment Building SW Peripheral 3
Area
ORCB63-FP-0212 Fire Preplan Reactor Containment Building NW Peripheral 3
Area
26
Inspection Type Designation Description or Title Revision or
Procedure Date
ORCB63-FP-0213 Fire Preplan Reactor Containment Building NE Peripheral 3
Area
2ECW58-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5
0605 Room Train A
71111.06 Calculations NC9701 Flooding Analysis: Electrical Auxiliary Building 5
Drawings 6M-18-9-N-5039 Mechanical & Electrical Auxiliary Building Section C-C Area 2
H
6M18-9-N-5023 Mechanical Electrical Auxiliary Building Plan @ EL. 35'-0" 6
Area H
6M189N05024 Mechanical Electrical Auxiliary Building Plan@ EL. 35'-0", 6
Area J
9M-06-9-B-0155 Plumbing - M.E.A.B. Floor Plan EL. 35'-0" Area 18 & 19 6
9M131A01030 Mechanical and Electrical Auxiliary Floor Plan EL. 1O' -0" Unit 17
1
9M131A01033 Mechanical and Electrical Auxiliary Building Floor Plan at 17
Elev. 35'-0" and 41'-0
71111.08P Corrective Action CR -YYYY-NNNN 2015-20733, 2017-13869, 2017-18341, 2018-6845,
Documents 2019-6008, 2019-7950, 2019-11368, 2019-11675,
2019-11865, 2019-12194, 2019-12243, 2019-12291,
2019-12444
Drawings E10025E58 South Texas Units 1 & 2 Closure Head General Assembly 4
Interface Inf. for RRVCH
SB-9406-HL5007 Snubber and Mountinc::i Supports 2
Miscellaneous South Texas Project, Units 1 AND 2 -Request for Relief RR- 04/05/2011
ENG-3-02 from ASME Code Requirements for Reactor
Pressure Vessel Insert Non-Destructive Examination {TAC
NOS. ME4764 AND ME4765)
South Texas Project, Unit 2 - Request for Relief NO. RR- 06/30/2016
ENG-3-20 for Extension of the Inspection Frequency of the
Reactor Vessel Cold-Leg Nozzle to Safe-End Welds with
Flaw Analysis (CAC NO. MF7428)
AE-NOC- South Texas Project, Units 1 and 2 - Request for Relief RR- 09/10/2012
12002347 ENG-3-04 to Apply Alternative to the American Society of
Mechanical Engineers Boiler and Pressure Vessel Code
27
Inspection Type Designation Description or Title Revision or
Procedure Date
Section XI Requirements for Examination of Class 1 and
Class 2 Piping Welds (TAC NOS. ME70SS AND ME70S6)
MRP-058 Materials Reliability Program: Boric Acid Corrosion 2
Guidebook, Revision 2: Managing Boric Acid Corrosion
Issues at PWR Power Stations
PQR-003 Procedure Qualification Record 0
PQR-016 Procedure Qualification Record. P8-T-Ag-1 0
PQR-035 Procedure Qualification Record for P8-T-Aq. 2
PQR-037 Procedure Qualification Record for WPS P8-T-Ag, P8-A, P8- 09/05/1989
AT-Aq
PQR-040 Procedure Qualification Record for WPS P1-A/P1 -A-LLh/P1- 11/17/1989
AT-Lh
PQR-046 Procedure Qualification Record for WPS P8-T-Ag and P8- 01/24/1990
AT-Ag
PQR-087A Procedure Qualification Record for WPS P1-AT-Lh (CVN ) 10/28/1991
PQR-126 Procedure Qualification Record for WPS P1-T (CVN ) 03/16/1995
PQR-127 Procedure Qualification Record for WPS P1-T (CVN ) 03/16/1995
PQR-197 Procedure Qualification Record for WPS P8-T-Ao 04/10/2003
PQR-199 Procedure Qualification Record for WPS P1-A-Lh 10/14/2003
WPS P1-A-Lh ASME Welding Procedure Specification (WPS). Single and Revision 8
Double Welded Groove, Fillet Welds Socket Welds, and
other joint designs specified
In WPS WJD (Weld Joint Desiqn).
WPS P1-T ASME Welding Procedure Specification (WPS). Single and Revision 9
Double Welded Groove, Fillet Welds, Socket Welds, and
other joint designs specified
In WPS WJD (Weld Joint Desiqn).
NOE Reports MT-2019-030 Closure Head Bolting/ Closure Stud 1B through 368 10/18/2019
through MT-2019-
65
PT-2019-049 eves Low Pressure Letdown ORC Isolation Test Valve. 10/16/2019
FW0027 (Pipe to VLV CV0391 ).
PT-2019-052 eves Low Pressure Letdown ORC Isolation Test Valve. 10/16/2019
FW0028 (Pipe to Elbow)
28
Inspection Type Designation Description or Title Revision or
Procedure Date
PT-2019-054 CVCS Low Pressure Letdown ORC Isolation Valve CV- 10/18/2019
0391. FW0009.
PT-2019-057 Flange to Upper Case I SIAPLH-2AOPCW1 / Pum p 2A 10/21/2019
PT-2019-059 Upper Case to Lower Case I SIAPLH-2A-PCW2 / Pump 2 10/20/2019
PT-2019-060 Lower Case Seam Weld / SIAPLH-2A-PCW5 / Pum p 2A 10/20/2019
PT-2019-061 Nozzle to Upper Case I SIAPLH-2A-PCW4 / Pump 2A 10/21/2019
UT-2019-031 PRZ-2-N4C/Safety Nozzle to Shell 10/16/2019
UT-2019-042 PRZ-2-N4A/Relief Nozzle to Shell 10/19/2019
UT-2019-043 PRZ-2-N2/Spray Nozzle to Shell 10/19/2019
UT~2019-044 PRZ-2-N3/Safety Nozzle to Shell 10/19/2019
UT-2019-048 RSG-2A-T1 / Tube plate to Lower Shell Barrel A 10/22/2019
VCT-2019-041 EW-2188-HL5001 / U-Strap Support 10/24/2019
VE-2019-001 BMI Penetration/ No. 1-58 10/07/2019
VE-2019-002 Reactor Vessel Closure Head/Bare Metal Visual Penetration 10/15/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-003 Reactor Vessel Closure Head/Bare Metal Visual Penetration 10/16/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-004 Reactor Vessel Closure Head/Bare Metal Visual Penetration 10/17/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VE-2019-005 Reactor Vessel Closure Head/Bare Metal Visual Penetration 10/18/2019
Nozzles, 1-9, 14-23, 25-27, 29-61, 66, 68, 70, 72, 75-78,
including vent pipe and general head area.
VT1/3-2019-094 Lower Case to Bottom Head/ SIAPLH-2A-PCW3 / Pum p 2A 10/21/2019
Procedures OPEP1 O-ZA-0004 General Ultrasonic Examination 8
OPEP10-ZA-0010 Liquid Penetrant Examination (Color Contrast Solvent 6
Removable)
OPEP1 O-ZA-0019 Wet Fluorescent Magnetic Particle Examination For ASME 4
Section XI PSI/ISi
OPEP1 O-ZA-0024 ASME XI Examination for VT-1 and VT-3 5
OPEP1 O-ZA-0054 ASME Section XI VE Visual Examinations 2
OPGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks 13
29
Inspection Type Designation Description or Title Revision or
Procedure Date
OPGP03-ZE-0133 Boric Acid Corrosion Control Program 12
OPM02-ZW-0005 Control of Postweld Heat Treat 5
OPMP02-0001 C AWS-HVAC Weldinq Re.quirements 1
OPMP02-ZW- General Welding Requirements 12
0001
OPMP02-ZW- ASME Repair Replacement Welding Requirements 2
0001A
OPMP02-ZW- ASME-ANSI B31.1 Welding Requirements 2
0001B
OPMP02-ZW- Welding Documentation Requirements 2
0001D
OPMP02-ZW- Welding procedure Specification Preparation and 8
0002 Qualification
OPMP02-ZW- Welder Qualification and Certification 11
0003
OPMP02-ZW- Control of Filler Materials 19
0004
OPMP02-ZW- Arc Wire Thermal Spray Coatings 2
0006
Self-Assessments CR 14-10410 Risk-Informed ISi Periodic Evaluation for South Texas 06/24/2014
Project Electric
Generating Station Units 1 & 2 in Conjunction with End of
the Third Interval, First Period.
Work Orders w.o. 96011721 (1MB) LOOP 2 RCS Flow Transmitter FT-0429 ISOL VLV 0
w.o. 96011791 eves Letdown Orifice Header Isolation Valve 0
W .O. 96013680 Main Steam Isolation Valve 2D Above Seat Drain Isolation 0
W.0.576310 CentrifuQal Charqinq Pump 2A DischarQe Vent Valve 0
71111.118 Corrective Action 2019-10407 MSIV Operability Surveillance Procedure not followed 09/20/2019
Documents 2019-10562 Totalizer Event on 9/22/2019 09/24/2019
2019-4962 Train A CRE/HVAC Inoperable 05/02/2019
2019-8301 Inoperable Reactor Head Vent Valves 08/01/2019
2019-9357 Inadequate Control Room Loq entries 08/29/2019
Miscellaneous None Simulator Differences List 09/10/2019
None 2019 Biennial NRC Written Exams weeks 1 and 3 11/18/2019
30
Inspection Type Designation Description or Title Revision or
Procedure Date
None NRC Annual Operatinq Tests Weeks 1 and 3 11/18/2019
TT01 Simulator Transient Test 01 Manual Reactor Trip 11/04/2019
TT02 Simulator Transient Test 2 Trip of all Main Feed Pumps 11/04/2019
Procedures OPOP01-ZA-0014 Licensed Operator License Maintenance Revision 30
OPGP03-ZA- Medical Exams-NRG Regulated Revision 0
0128A
OPGP03-ZT-0132 Licensed Operator Requalification Revision 13
OPNT01-TQ-1001 Examination Security Revision 1
OPNT01-ZA-0037 Simulator Confiquration Control Revision 13
LOR-GL-0001 LOR Training Program Guidelines Revision 35
LOR-GL-0002 Licensed Operator Requal Annual/Biennial Evaluation Revision 28
Guidelines
LOR-GL-0006 LOR Conduct of Simulator Training Guidelines Revision 32
71111.110 Corrective Action CR-YYYY-NNNN 2019-14056 2014-12615 1995-13955 2004-4336
Documents
Miscellaneous Maintenance Rule Expert Panel Meeting Minutes, March,
May, June, July, August, Se,ptember November 2019
17-YU-003, 2017 Essential Cooling Pond (ECP) Seepage Calculations 0
MC-6498 Essential Coolinq Pond Thermal Performance Analysis 1
VTD-R 165-0029 Instruction Manual for Essential Cooling Water Pump Motor 1
VTD-STP1-0001 Rotating Equipment Oil Level Limits and Labels 4
VTD-W 120-0108 Lame AC Motors - Lice Line D Vertical Induction Motors 5
Procedures OPMP04-EW- Essential Cooling Water Pump Maintenance 30
0001A
OPMP05-EW- Essential Cooling Water Pump Motor Inspection 13
0001
OPSP04-ZE-0313 Maintenance Rule Proqram 9
SEG-0009 Maintenance Rule Basis Document Guideline 6
Work Orders Work 574254 592053 585021 612238
Authorization
Numbers
71111.12 Corrective Action CR-YYYY-NNNN 2019-1762, 2019-2357, 2019-2393, 2019-4652,
Documents 2019-9269, 2019-8512, 2019-13994, 2019-4359,
31
Inspection Type Designation Description or Title Revision or
Procedure Date
2019-13709, 2019-8052
71111.13 Calculations RA RICTCal 3505
Corrective Action CR-YYYY-NNNN 2019-14338
Documents
Procedures OPGP03-Z0-0055 Protected Components 13
OPOP01-Z0-0006 Risk Management Actions (RMAs) 27
71111.15 Corrective Action CR-YYYY-NNNN 2019-12034, 2019-13137, 2019-13079, 2009-18939
Documents 2019-8731, 2014-8012, 2019-7580, 2019-5498
2019-13150, 2018-6459, 2019-13477
Drawings 50159F22540#2 Piping and Instrumentation Diagram Standby Diesel Jacket 22
Water
Miscellaneous VTD-T147-0001 Terry Steam Turbine Manual 2
VTD-T147-0008 Terry Turbine Maintenance Guide, Auxiliary Feedwater AFW 7
Application
VTD-W290-0029 Installation and Operation Manual Overspeed Trip Test 0
Device for PG Governors
Procedures OPGP03-AZ-0133 Fluid Leak Management Program 6
OPGP03-ZA-0514 Controlled System or Barrier Impairment 17
OPGP03-ZE-0030 Control Room Envelope Habitability Program 4
OPGP03-Z0-0046 RCS Leakage Monitoring 11
OPMP04-AF-0002 Auxiliary Feedwater Pump Turbine and Governor Valve 42
~
Maintenance
OPOP02-HE-0001 Electrical Auxiliary Buildinq HVAC System 40
Work Orders Work 556056 489463
Authorization
Numbers
71111.18 Corrective Action CR-YYYY-NNNN 2019-11901 2019-4165 2019-11971
Documents
Drawinqs 5R219F05028#2 Spent Fuel Pool Coolinq and Cleanu p System 31
Procedures OPMP09-PM- Temporary Configuration Changes to Support Class 1E 0
OOOB Train B MCC Outages
71111.19 Corrective Action CR-YYYY-NNNN 2019-11348, 2019-11348
Documents
Procedures OPEP07-ZE-0002 LLRT Rig Operation 10
32
Inspection Type Designation Description or Title Revision or
Procedure Date
OPEP07-ZE-0003 Normal/Suoolementarv Purge Valve Failure/Troubleshooting 7
OPEP07-ZE-0003 Normal/Suoolementarv Purae Valve Failure/Troubleshooting 7
OPMP04-ZG-0093 Fisher Butterfly 12 and 48 in. Valve Maintenance 6
OPSP05-RC- RCS Flow Transmitter Calibration 13
0417T
OPSP11-HC-0001 LLRT M-41 Normal Containment Purge Exhaust 17
OPSP11-HC-0001 LLRT M-41 Normal Containment Purge Exhaust 17
OPSP11-XC-0004 LLRT Penetration: M-91 Auxiliary Airlock Door Seals 16
Work Orders Work 523127, 550267, 548433, 601368, 548433
Authorization
Numbers
71111.20 Miscellaneous 2RE20 Shutdown Risk Assessment Report 08/27/2019
Procedures OPOP02-RC-0003 Filling and Ventina the Reactor Coolant System 45
OPOP03-ZG-0006 Plant Shutdown from 100% to Hot Standby 74
OPOP03-ZG-0007 Plant Cooldown 88
OPOP03-ZG-0007 Plant Cooldown 80
OPOP03-ZG-0010 Refuelinci Operations 81
OPOP08-FH-0001 Refueling Machine Operating Instruction 53
OPOP08-FH-0009 Core Refuelina 50
71111.22 Corrective Action CR-YYYY-NNNN 2019-9708 2019-14780 2019-3044
Documents
Drawings 00009EODJM#1 Single Line Diagram 125VDC Class IE Distribution SWBD. 20
E1A11 (Channel 1) (E.A.B.) Sheet 01
Procedures OPOP07-FR-0006 FLEX Diesel Generator Performance Test 12
OPOP07-FR-0006 FLEX Diesel Generator Performance Test 12
OPSP03-AF-0003 Auxiliarv Feedwater Pump 13(23) lnservice Test 43
OPSP03-DG-0003 Standbv Diesel 13(23) Ooerability Test 64
OPSP03-EW- Essential Cooling Water System Train C Testing 56
0019
71114.04 Corrective Action CR-YYYY-NNNN 2019-14047
Documents
Miscellaneous NOC-AE- South Texas Project, Units 1 and 2; Docket Nos. STN 50- 8/8/2019
19003676 498; STN 50-499; Supplement to Changes to the South
33
Inspection Type Designation Description or Title Revision or
Procedure Date
Texas Project Emergency Plan
NOC-AE- South Texas Project, Units 1 and 2; Docket Nos. STN 50- 8/8/2019
19003678 498; STN 50-499; Changes to the South Texas Project
Procedures OERP01-ZV-IN10 Administration of Potassium Iodide 0
71124.01 Corrective Action CR-YYYY-NNNN 2018-03911, 2018-03912, 2018-04050, 2018-04527,
Documents 2018-04528, 2018-04757, 2018-04761, 2018-04933,
2018-06016, 2018-08247, 2018-09871, 2018-11562,
2018-11664, 2018-12157, 2018-12381, 2018-12559,
2018-12585, 2018-13229, 2018-14735, 2019-01215,
2019-03426, 2019-03573, 2019-07939, 2019-11659,
2019-12327
Miscellaneous Stand Fast WB Count Report - .(reportinQ in nCi) 10/23/2019
18-12339 Ag-110 in CVCS during 1RE21 10/16/2018
19-11442-1 DAC-hr Assessment for Condition Report 19-11442 10/18/2019
19-3165-7 ALARA Review Package - 2RE20 Non-Rapid Refuel 10/01/2019
19-3165-9 ALARA Review Package - 2RE20 Room 003 Activities 10/01/2019
Procedures OPEP02-ZM-0009 Spent Fuel Pool Storage and Work 10
OPGP03-ZR-0048 Personnel Dosimetry Program 21
OPGP03-ZR-0050 Radiation Protection Program 14
OPGP03-ZR-0051 Radiological Access Controls/Standards 43
OPRP01-ZA-0010 Radiation Protection Task Schedule 16
OPRP01-ZA-0042 Job Coverage 1
OPRP04-ZR-OO 13 Radiological Survey Program 39
OPRP04-ZR-0015 Radiological Postings and Warning Devices 37
OPRP04-ZR-0019 High Radiation Area Access Controls 0
OPRP07-ZR-0016 Lockdown and Posting for Transfer of Spent Fuel/Irradiated 10
Material ThrouQh Transfer Tube
Radiation 21434 Air Sample Data Sheet - Room 4 B/C Enclosure - Change 04/06/2018
Surveys Out Filter
21441 Air Sample Data Sheet - B/C HEPA Enclosure Pre-Filter 04/07/2018
ChanQe Out
21468 Air Sample Data Sheet - Reactor Cavity Decontamination 04/14/2018
21498 Air Sample Data Sheet - "B" S/G Platform - Job CoveraQe of 04/19/2018
34
Inspection Type Designation Description or Title Revision or
Procedure Date
Nozzle Dams
21505 Air Sample Data Sheet - "B" SIG Platform - Job Coverage of 04/19/2018
Nozzle Dams
22373 Air Sample Data Sheet - Near S. Stairwell - Verify 10/01/2019
Conditions
Survey# 97442, 98130, 99286, 99321, 102863, 104598, 105041,
105049, 105646, 105785, 105796, 105992, 106223,
106234, 106258, 106397, 106565, 106797, 106801,
106824, 106862
Radiation Work 2019-2-0145 2RE20 - Maintenance Support for Work In and Around 0
Permits (RWPs) Reactor Cavity, Spent Fuel Pool, and Transfer Canal (HRA)
2019-2-0158 2RE20 - Reactor Head Lift Activities (LHRA) 0
2019-2-0164 2RE20 - Retract/ Re-Insert Thimble Tubes (LHRA) 0
2019"'.2-0165 2RE20 - Maintenance and Support Work - Room 307 0
(LHRA)
2019-2-0167 2RE20 - Mechanical Stress Improvement Process (MSIP) 0
Work Activities (HRA)
2019-2-0173 2RE20 - Maintenance on N2CVPSV3100 (LHRA} 0
Self-Assessments 18-10431 Self-Assessment: FT-0428 Radiological Surveys 10/07/2018
18-11300-1 Self-Assessment: 1RE21 Survey Snapshot 10/18/2018
19-02643 RP ProQram Formal Self-Assessment 06/06/2019
71124.03 Corrective Action CR-YYYY-NNNN 2017-13657, 2017-13733, 2017-15060, 2017-16403,
Documents 2017-16501, 2017-17137, 2017-17894, 2017-19406,
2017-20490, 2017-24212, 2017-24235, 2018-01438,
2018-01607, 2018-01824, 2018-01837, 2018-04227,
2018-06620, 2018-08647, 2018-10747, 2019-05126,
2019-11442
Corrective Action CR-YYYY-NNNN 2019-12240, 2019-12368
Documents
Resulting from
Inspection
Miscellaneous AirHawk SCBA Personnel Fit Test, Medical, and Respiratory
Training dates for cost centers 87, 840, 841, 842, and 843
MSA CARE Certification for Darryl Malone (Vallen Freeport) 06/08/2018
35
Inspection Type Designation Description or Title Revision or
Procedure Date
000107 Vallen Freeport: Bauer Compressor Air Quality from
February 1, 2018- October 23, 2019
2019, 03 Department of Transoortation Audit: Vallen Freeport 09/23/2019
Respirator 453, 537, 569, 574, 606,
Review 1210, 3709, 3715, 3716, 3718,
3721, 3725, 3727, 3733, 3736
Procedures OPEP05-ZH-0005 Non-Safety Related Filter Airflow Test 8
OPEP05-ZH-0008 MAB, TSC and RCB HV AC In-Place* HEPA Filter Leak Test 9
OPG03-ZE-0004 Plant Surveillance Program 29
OPGP-ZR-0050 Radiation Protection Proaram 14
OPGP03-Zl-0015 Control and Use of Industrial Com pressed Air and Gases 6
OPGP03-ZR-0054 Respiratorv Protection Proaram 17
OPRP04-ZR-OO 16 Radioloaical Air Samplina and Analysis 32
OPRP05-RA-0007 Grab Sample Collection of the (PIG) Continuous 16
Atmospheric Monitors
OPRP05-ZR-0030 Portable Air Monitor Instruments (AMS-4) 24
OPRP06-ZR-0002 Respiratorv Protection Eauipment Issue and Return 27
OPRP06-ZR-0004 Cleanina and Sanitizina of Respiratory Protection Equipment 9
OPRP06-ZR-0005 Maintenance, Inspection, and Storage of Respiratory 16
Protection Eauioment
OPRP06-ZR-0008 Air Quality Evaluation for Compressors or Pressurized Gas 5
Cylinders
OPRP06-ZR-0013 Resoirator Fit Testina 9
OPRP06-ZR-0016 Charginq Breathinq Air Cylinders 7
OPSP11-HE-0001 Control Room Envelop Filter Airflow Capacity Test 12
OPSP11-HF-0001 FHB Exhaust Filter Airflow Capacity Test 13
OPSP11-ZH-0008 CRE and FHB HVAC In-Place HEPA Falter Leak Test 21
Radiation 21434 Air Sample Data Sheet: Chanqe Out of HEPA Pre-filter 04/11/2018
Surveys 21441 Air Samele Data Sheet - Pre-filter Chanqe Out 04/11/2018
21468 Air Sample Data Sheet - Cavitv Decontamination 04/14/2018
21498 Air Sam ele Data Sheet - Nozzle Dam Job Coverage 04/22/2018
21505 Air Sample Data Sheet - Nozzle Dam Job Coverage 05/03/2018
21669 Air Sample Data Sheet - Routine Unit 1 Radwaste Truck Bav 08/28/2018
36
Inspection Type Designation Description or Title Revision or
Procedure Date
(RWTB)
21882 Air Sample Data Sheet- Unit 1 Reactor Cavity 11/01/2018
21884 Air Sample Data Sheet- Unit 1 Reactor Cavity 11/01/2018
22338 Air Sample Data Sheet- RT-8011 Particulate Channel Alarm 09/23/2019
22373 Air Sample Data Sheet - FT-0419 Leaking Transmitter 10/02/2019
22476 Air Sample Data Sheet - Unit 2 Reactor Building 68' Grab 10/10/2019
Sample
22482 Air Sample Data Sheet - Unit 2 Reactor Building 68' Grab 10/10/2019
Sample
Radiation Work 2018-0-0159 Preventative Maintenance and Repair of Equipment in the 3
Permits *(RWPs) FHB Fuel Transfer Canal including RP Surveys and
Decontamination
2019-2-0115 2RE20 - Mini Decontamination of Reactor Cavity and Initial 0
LISA and Tilt Pit Decontamination (LHRA)
2019-2-0117 2RE20 - Major Decontamination of Reactor Cavity and LISA 0
(LHRA)
2019-2-0151 2RE20 - Perform Maintenance and Inspection in RCB/FHB 0
Fuel Transfer Canals (LHRA)
2019-2-0155 2RE20 - Refuel - Inspect/Clean/Measure Upper/Lower 0- 0
rina Gro_
oves (LHRA)
2019-2-0158 2RE20 - Reactor Head Lift Activities (LHRA) 0
2019-2-0163 2RE20 - Disconnect/Reconnect Seal Table (LHRA) 0
2019-2-0171 2RE20 - Remove/Reinstall Reactor Cavity Stairwell (HRA) 0
Self-Assessments Assessment/Benchmark Report: Respiratory Program 2018 08/29/2018
MN-17-1-105942 Quality Monitoring Report: Radiological 04/02/2017
Instrumentation/Protective Equipment
MN-18-1-107276 Quality Monitoring Report: Radiological Surveys 10/23/2018
Work Orders WAN 546352 EAB and FHB HVAC In-Place Adsorber Leak Test: Unit 2 - 09/24/2019
CRE TRN "A" Clean Up Filter 21A/ 3V112VXV001
WAN 546353 EAB and FHB HVAC In-Place Adsorber Leak Test: Unit 2 09/24/2019
CRE TRN "A" Clean Up Filter 21A / 3V112VXV001
71151 Procedures OPGP05-ZN-0007 Preparation and Submittal of NRC Performance Indicators 9
Chaptijr 23 Conduct of Operations for Radiation Protection: Radiation 0
Protection Performance Improvement Guideline
37
Inspection Type Designation Description or Title Revision or
Procedure Date
71152 Corrective Action CR-YYYY-NNNN 2010-13994, 2019-13709, 2019-8052, 2019-4359,
Documents 2017-1786, 2017-17817, 2018-1529, 2018-3276,
2018-14380, 2019-9018, 2019-9019, 2019-7971,
2019-7483, 2019-12401, 2019-6155, 2019-5150,
2019-376, 2019-13709, 2019-8062, 2019-8052,
2019-4359, 2019-14697, 2019-13386, 2019-13436,
2019-14208, 2019-14736, 2019-14208, 2019-14743,
2019-13614, 2019-13950, 2019-14279, 2019-12597,
2019-9119, 2019-10504, 2019-11054, 2018-11855,
2018-3518, 2018-3559, 2019-7508, 2015-18703,
2017-15034, 2019-10837, 2019-2558, 2019-4575
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