IR 05000498/2020002

Integrated Inspection Report 05000498/2020002 and 05000499/2020002

ML20212L874
Person / Time
Site:	South Texas
Issue date:	07/31/2020
From:	Jeffrey Josey NRC/RGN-IV/DRP/RPB-A
To:	Gerry Powell South Texas
References
IR 2020002
Download: ML20212L874 (36)

Text

July 31, 2020

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000498/2020002 AND 05000499/2020002

Dear Mr. Powell:

On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at South Texas Project Electric Generating Station, Units 1 and 2. On July 9, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

Three findings of very low safety significance (Green), that involved violations of NRC requirements, are documented in this report. We are treating these findings as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

Licensee-identified violations which were determined to be of very low safety significance are 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. 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 Digitally signed by Jeffrey Josey Josey Date: 2020.07.31 11:32:19 -05'00'

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

Inspection Report

Docket Numbers: 05000498 and 05000499 License Numbers: NPF-76 and NPF-80 Report Numbers: 05000498/2020002 and 05000499/2020002 Enterprise Identifier: I-2020-002-0012 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: Wadsworth, TX 77483 Inspection Dates: April 1, 2020 to June 30, 2020 Inspectors: I. Anchondo-Lopez, Reactor Inspector J. Drake, Senior Reactor Inspector M. Holmberg, Senior Reactor Inspector G. Kolcum, Senior Resident Inspector A. Sanchez, Senior Resident Inspector C. Stott, Resident Inspector F. Thomas, Reactor Inspector Approved By: Jeffrey E. Josey, Chief Reactor Projects Branch A Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section 7115

List of Findings and Violations

Inadequate Design Change Modification for Reactor Vessel Head Vent Solenoid Valves Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.17T Systems NCV 05000498/2020002-01 Conservative Open/Closed Bias The inspectors identified a self-revealed, Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion III, Design Control, for the licensees failure to recognize critical differences between the replacement controllers for the new solenoid valves that rendered both trains of the reactor vessel head vent system vulnerable to a common mode failure.

Specifically, the licensee installed a modification in the reactor vessel head vent system that resulted in a loss of the system safety function for greater than the technical specification allowed outage time.

Failure to Follow Procedure During A Surveillance Results in an Inoperable Train of Essential Cooling Water Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.22 Systems NCV 05000498,05000499/2020002-02 Complacency Open/Closed A self-revealed Green non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.m, Service Water System, was documented for the failure to follow the surveillance procedure for the Unit 2, train A, essential cooling water (ECW) which challenged system operability. Specifically, plant equipment operators in the ECW pump room failed to implement step 5.2.2 of Procedure 0PSP03-EW-0017, Essential Cooling Water System Train A Testing, Revision 41, to verify ECW self-cleaning strainer was running, instead, the plant equipment operator performed step 5.4.2 that secured the ECW self-cleaning strainer.

Inadequate Risk Assessment of Switchyard Activities Results in Loss of 345kV South Bus Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.1] - 71153 NCV 05000498,05000499/2020002-03 Resources Open/Closed The inspectors reviewed a self-revealing Green non-cited violation of 10 CFR 50.65(a)(4) for the failure to perform an adequate risk assessment to manage the increase in risk of performing activities in the switchyard. Specifically, on March 24, 2020, the licensee failed to implement risk mitigative actions during switchyard maintenance activities, and the result was the loss of the 345kV south bus, partial loss of offsite power to both Units 1 and 2.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000498,05000499/ LER 2020-001-00 for South 71153 Closed 2020-001-00 Texas Project, Units 1 and 2,

Automatic Actuation of Emergency Diesel Generators due to Lockout of Switchyard Electrical Bus LER 05000499/2019-002-00 LER 2019-002-000 for South 71153 Closed Texas Project, Unit 2,

Incorrect Sequencer Part Replacement Leads to Undervoltage Signal and Valid Actuation of Emergency Diesel Generator.

LER 05000499/2019-001-00 LER 2019-001-00 for South 71153 Closed Texas Project, Unit 2,

Equipment Clearance Order Error Leads to Loss of Primary Containment Integrity LER 05000498/2019-002-00 LER 2019-002-00 for South 71153 Closed Texas Project, Unit 1,

Condition Prohibited by Technical Specifications and Loss of Safety Function due to Inoperable Reactor Head Vent Throttle Valves LER 05000498/2019-002-01 LER 2019-002-01 for South 71153 Closed Texas Project, Unit 1,

Condition Prohibited by Technical Specifications and Loss of Safety Function due to Inoperable Reactor Head Vent Throttle Valves

PLANT STATUS

Unit 1 began the inspection period in Mode 6 during refueling outage 1RE22. The main generator breaker was closed on April 17, 2020, ending the refueling outage. Unit 1 reached rated thermal power on April 22, 2020, and remained there for the rest of the period.

Unit 2 operated at rated thermal power for the entire inspection 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/readingrm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk-significant activities: and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hurricane season for the following systems:

• The Units 1 and 2, essential cooling water pond (ultimate heat sink)

• The South Texas Project 345kV switchyard

(2) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer heat conditions for the following systems:

• Units 1 and 2, standby transformers

• Units 1 and 2, engineered safety features transformers

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding:

Units 1 and 2, essential cooling water intake structure, emergency diesel generator flood panel areas on May 26, 2020, and this closes out the partial sample documented in inspection report STP2020001, Section 71111.01

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1, train C emergency diesel generator following restoration from surveillance activities May 5, 2020

(2) Unit 1, train B low head safety injection while train C equipment was out of service for planned maintenance on May 8, 2020

(3) Unit 2, train B component cooling water while train C was out of service for maintenance on May 12, 2020

(4) Unit 1, train B emergency diesel generator while train C was out of service for maintenance on May 12, 2020

(5) Unit 1, train C main steam system while train D was out of service for planned maintenance May 14, 2020

(6) Unit 2, turbine driven auxiliary feedwater pump while train C emergency diesel generator was out of service for planned maintenance on June 11, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 2 trains A, B, and C emergency diesel generators during the week of June 22, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2, train C component cooling water pump and heat exchanger rooms, Fire Area 27 on May 19, 2020

(2) Unit 2, train B essential cooling water pump and traveling water screen rooms, Fire Area 57, on May 27, 2020

(3) Unit 2, standby transformer, Fire Area 99, on May 27, 2020

(4) Unit 2, electrical auxiliary building train B cable spreading/power cabling area, Fire Area 31 on June 22, 2020

(5) Unit 2, electrical auxiliary building train A electrical penetration area, Fire Area 02 on June 22, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1, train B emergency diesel lube oil and jacket water heat exchangers the week of May 1, 2020, and this closes out the partial sample documented in inspection report STP2020001, Section 71111.07A

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

(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 March 18, to April 3, 2020:

03.01.a - Nondestructive Examination and Welding Activities

• Magnetic Particle Examinations: Main Steam System - Pipe Lug Welds 30-MS-1001-GA2/ 27PL1-27PL8/30-MS-1001-GA2 and Reactor Vessel Closure Head Stud 2A

• Ultrasonic Examinations: Pressurizer Pipe-to-Safe-end Overlay Weld 14-WOL-N2, Pressurizer Spray Nozzle-to-Safe End Weld PRZ-1-N2-SE-WOL, Control Rod Drive Housing No. 68 Lower Weld RRVH-CRD-68L, Reactor Coolant System: Branch Connection-to-Bent Pipe 2-RC-1220-BB1, Reactor Coolant System: Pipe-to-Branch Connection 4-RC-1323-BB1 Weld 4 and Reactor Coolant System:

Pipe-to-Branch Connection 4-RC-1126-BB1 Weld 6

• Visual Examinations (VT-1): Reactor Vessel Closure Head Nuts 1A through 36A

• Gas Tungsten Arc Weld (Manual): Essential Cooling Water System - Pipe welds HFW-1402, 1405, 1408 - Repair Plan 1-18-003, Work Order 6009129 and Work Authorization No. 68994 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.

• Evaluations: 19-3869-3 - Centrifugal Charging Pump 1B Outboard Seal is leaking, 20-62-2 - Leakage from High Head Safety Injection Pump 1C Mechanical Seal and Condition Report Engineering Evaluation (CREE)

No. 17-16232-2 - Code Case N-566-2 Engineering Evaluation Residual Heat Removal System Heat Exchanger 1B Flange

• Corrective Actions: 19-3645 - Wet and Discolored Deposits at the Packing Gland of 1-RH-0067A, 19-7057- Dry and White Deposits at the Tubesheet to Flange of the 1B Residual Heat Removal Heat Exchanger and 19-7066 - Significant Dry and Discolored Deposits at the Packing Gland of 1-SI-FCV-0852 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.

• Eddy current examination of the tubes in the Unit 1 steam generators A, B, C and D

71111.11Q - 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 Unit 1 operations crew respond to a degraded condition which caused an increase of unidentified reactor coolant leakage on June 18, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a Unit 1 operations crew in the simulator for a training scenario involving a steam leak in containment and a loss-of-coolant accident on June 29, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 1, train B emergency diesel generator's status in 10 CFR 50.65(a)(1) due to continued unavailability time as a result of maintenance, scheduling, and equipment issues and closes out the partial sample documented in Inspection Report STP2020001, Section 71111.12

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;

(1) Unit 1, unplanned risk due to train B essential cooling water maintenance resulting in entering the Configuration Risk Management Program (CRMP) on February 9, 2020, and this closes out the partial sample documented in Inspection Report STP2020001, Section 71111.13

(2) Unit 1, unplanned risk due to maintenance on train B emergency diesel generator going longer than expected and resulted in entering the CRMP on February 17, 2020, and this closes out the partial sample documented in Inspection Report STP2020001, Section 71111.13

(3) Unit 1, train D 125vdc battery and inverter maintenance that resulted in the planned entry into the CRMP on February 19-20, 2020, and this closes out the partial sample documented in inspection report STP2020001, Section 71111.13

(4) Unit 1, train A 125vdc battery and inverter maintenance that resulted in the planned entry into the CRMP on February 26-27, 2020, and this closes out the partial sample documented in Inspection Report STP2020001, Section 71111.13

(5) Unit 1, train B 125vdc battery and inverter maintenance that resulted in the planned entry into the CRMP on March 4-5, 2020, and this closes out the partial sample documented in Inspection Report STP2020001, Section 71111.13

(6) Unit 1 entered the CRMP for isolating the 1A safety injection accumulator due to leakage through check valve RH-32A on April 30, 2020

(7) Unit 1, train D battery installation of a temporary modification that jumpered out battery cell number 5 and resulted in entry into the CRMP on June 13, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 1, operability determination of the reactor vessel head studs that exceeded the preload elongation tolerances during reactor vessel head tensioning on April 5, 2020

(2) Unit 1, operability evaluation of train C diesel generator that failed to complete its 5-minute cooldown period after a surveillance run on April 9, 2020

(3) Unit 1, operability evaluation of the train A high head safety injection pump that failed to meet acceptance criteria during comprehensive pump test on March 19, 2020

(4) Unit 1, train A residual heat removal (RHR) and low head safety injection systems due to the train A safety injection accumulator leakage into the RHR heat exchanger

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from May 2017 through May 2020.

(1) 15-22176-3 Use of Speed Crete as welded joint sealant in prestressed concrete embedded cylinder pipe.

(2) 17-118-148 Engineering Evaluation of Parker Fitting 48F-5-2 for use in the Standby Emergency Diesel Generator Starting Air System Air Starting Valve

(3) T1-12-26471-1 Installation of an Upstream Pressure Control Valve to Prevent Cavitation of N1CPPCV5805N (Mixed Bed Service Vessel N Sample Cooler Inlet Pressure Control Valve)

(4) T1-20-45-1 Auxiliary Feedwater Pump 14 Terry Turbine Alternate Drain line

(5) 20-2312-6 Installation of Metal Oxide Varistors (MOV's) For Unit 1 Rx Vessel Head Vent Throttle Valves Positioners HY0601 and HY0602

(6) TL2-18-10183 High Side Tubing Crimp on Unit 2 Reactor Coolant System Loop 2B Flow Transmitter D2RCFT0428

(7) 17-23295-3 Install Pipe Cap Downstream of Safety Injection Accumulator Nitrogen Supply Vent Valve, A1SIHCV0900

(8) 16-128-325 Evaluation of Belleville Washer

(9) 19-872-1 Extend the Quality Life (QL) of the Primary Sampling Systems Target Rock Solenoid Valves and Reed Switches

(10) 18-5242-2 Replacement Valve for Application 2R172TCV0392

(11) 18-11062-2 Update Vendor Drawing and Setpoint List for CCP 1B Lube Oil Pressure Switch

(12) 15-14074-4 Create Environment Data Table for Rosemount Transmitters in EQDB Database

(13) 15-20773-1 Validate and Update Loading for 125 VDC Distribution Panel PL039A

(14) 15-20773-2 Validate and Update Loading for remaining circuits on Class 1E 125 VDC Distribution Panels PL039B, PL039C, PL040A, PL 139A, PL 139B, and PL 139C

(15) 16-128-30 Rosemount Differential Pressure Transmitter 1151DP Replacement Part

(16) 16-128-94 Alternate Replacement Limitorque Actuator for B320-10

(17) 16-2214-10 Revise Environmental Qualification DBD to address QDPS On-going Qualification in Mild Environment

(18) 12-31926-43 Class 1E 4.16 KV Circuit Breaker Replacements

(19) 17-20542-7 Replace Emergency Transformer 138 KV Circuit Switch Operator; ## 81

(20) 17-22335-2 Replace 27C Relay (ITE J13) Associated in Control Circuit for Containment Spray Pump 1B

(21) 15-16599-37 Application of The Mechanical Stress Improvement Process (MSIP) To Reactor Vessel Nozzles

(22) 15-110072-2 Replace Unit 1 Reactor Vessel Head Vent Throttle Valves with Upgraded Bolted Bonnet Design

(23) 14-12285-20 Perform a 50.59 Screen/Evaluation to address concerns raised in NSAL 14-5

(24) 16-5792-13 Update UFSAR 15.1.5 to incorporate revised HZP MSLB core response analysis due to RCCA D-6 removal

(25) 18-2757-11 Temporary Installation of a Portable Heater/Fan Unit in Doorway (Door 307) of Room 321 (E1C11 125 Volt QC Battery Rack Room) on the 60-foot Elevation of the Electrical Auxiliary Building (EAB)

(26) 19-10118-9 Replace Primary Fuses in Aux Relay Panel for Unit 1 Reactor Vessel Head Vent Valve HCV0601 and 602

(27) 18-88-275 Replacement Size 3 and 4 Magnetic Motor Starters for Class 1E Application

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1, implementation of the exigent Technical Specification change to lower pressure in all three trains of safety injection accumulators to stop nitrogen gas accumulation in the train A RHR heat exchanger on May 29, 2020

(2) Unit 1, train D 125Vdc battery cell number 5 jumper due to degraded cell voltage on June 13, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Unit 1, train A steam generator narrow range level set 3 L-0518 following card replacement on February 8, 2020

(2) Unit 1, train C residual heat removal heat exchanger component cooling water return flow valve FV-4565 following solenoid valve replacement on March 11, 2020

(3) Unit 1, auxiliary air lock following hydraulic solenoid valve replacement on April 9, 2020

(4) Unit 1, train A low head safety injection pump discharge to cold leg check valve following repair on April 14, 2020

(5) Unit 1, train C essential chiller 12C following emergent maintenance to replace the temperature element and temperature control module on May 11, 2020

(6) Unit 1, operating crew respond to a degraded condition which caused an increase of unidentified reactor coolant leakage on June 18, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage 1RE22 activities from March 13 through April 17, 2020, which completes the partial sample documented in Inspection Report STP2020001, Section 71111.20

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1, train C emergency diesel generator surveillance test on March 11, 2020, and this closes out the partial sample documented in Inspection Report STP2020001, Section 71111.22

(2) Unit 1, trains A, B, and C emergency diesel interdependence test on April 2, 2020

(3) Unit 1, high pressure turbine load swing test on April 20, 2020.

(4) Unit 1, train B 125Vdc battery monthly surveillance test on May 11, 2020

(5) Unit 2, train S reactor trip breaker testing on May 22, 2020

(6) Unit 1, loop 4 set 4 delta T and T average calibration on June 4, 2020

(7) Unit 1, loop 2 set 2 delta T and T average calibration on June 9, 2020

Inservice Testing (IP Section 03.01) (3 Samples)

(1) Unit 1, train B residual heat removal inservice test on March 11, 2020, and this closes out the partial sample documented in inspection report STP2020001, Section 71111.22

(2) Unit 2, turbine driven auxiliary feedwater pump surveillance test on June 18, 2020

(3) Unit 2, train A essential cooling water in-service surveillance test on June 20, 2020

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Unit 2, auxiliary air lock local leak rate test on May 11,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1, April 1, 2019 through March 31, 2020

(2) Unit 2, April 1, 2019 through March 31, 2020 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1, April 1, 2019 through March 31.2020

(2) Unit 2, April 1, 2019 through March 31, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1, April 1, 2019 through March 31, 2020

(2) Unit 2, April 1, 2019 through March 31, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees 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) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) An electrical supervisor manipulated plant equipment without permission and procedure during walkdown of Unit 1 train C essential chiller as documented in Condition Report CR 2019-10223

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000499/2019-001-00, Equipment Clearance Order Error Leads to Loss of Primary Containment Integrity (ADAMS Accession No.: ML19119A270). This licensee event report is closed.

(2) LER 05000499/2019-002-00, Incorrect Sequencer Part Replacement Leads to Under voltage Signal and Valid Actuation of Emergency Diesel Generator (ADAMS Accession No.: ML19353C818). The circumstances surrounding this LER were previously documented in Inspection Report 05000498/2019004 and 05000499/2019004 in the Inspection Results Section of that report. This licensee event report is closed.

(3) LER 05000498;05000499/2020-001-00 Automatic Actuation of Emergency Diesel Generators due to Lockout of Switchyard Electrical Bus (ADAMS Accession Number ML20143A188). This licensee event report is closed.

(4) LER 05000498/2019-002-01, Condition Prohibited by Technical Specifications and Loss of Safety Function due to Inoperable Reactor Head Vent Throttle Valves (ADAMS Accession No. ML19331A039) The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71111.17T.

INSPECTION RESULTS

Inadequate Design Change Modification for Reactor Vessel Head Vent Solenoid Valves Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.17T Systems NCV 05000498/2020002-01 Conservative Open/Closed Bias The inspectors identified a self-revealed, Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to recognize critical differences between the replacement controllers for the new solenoid valves that rendered both trains of the reactor vessel head vent system vulnerable to a common mode failure.

Specifically, the licensee installed a modification in the reactor vessel head vent system that resulted in a loss of the system safety function for greater than the technical specification allowed outage time.

Description:

On October 30, 2018, the licensee replaced A1RCHCV0601 and B1RCHCV0602, the solenoid operated valves for the reactor vessel head vent system, with a new bolted bonnet design and new positioner controllers. The engineering change package failed to recognize that the new controller circuitry had overvoltage protection system that shorted the power supply to ground when voltage limits for the controller card were exceeded. Additionally, the licensee failed to recognize that the DC power supply in use was not well regulated and was subject to large voltage spikes under varying conditions. On November 2, 2018, the licensee noted that power supply fuses for HCV0601 had again blown.

On December 31, 2018, reactor head vent throttle valve (RHVTV) 'A' (HCV0601)unexpectedly auto transferred to the auxiliary shutdown panel and the control room declared the valve inoperable. With one train of the reactor vessel head system inoperable, the licensee failed to establish additional operator actions to verify the operability of the remaining train.

On July 30, 2019, a training instructor with students discovered that reactor vessel head vent valve 'B' (HCV0602) control unit had a blown fuse and the control room declared valve HCV0602 inoperable. Following a review of records and logs, Engineering determined that the fuse to reactor vessel head vent valve 'B' had blown on or about June 24, 2019. This failure would have prevented the fulfillment of the safety function needed to mitigate the consequences of an accident (both vent valves being declared inoperable at the same time)and exceeded the technical specification action statement allowed outage time of 30 days.

This event is considered a loss of a safety function.

The licensee implemented multiple corrective actions attempting to correct the condition before the underlying cause was fully understood. These included installing higher amperage fuses, replacing the terminal box noise suppressors, installing metal oxide varistor at the positioners, and installing an RC (resistive capacitive) filter across the 125VDC at the positioners HCV0601 and HCV0602 as additional protection. After contacting the vendor, the licensee determined that the underlying cause of the failures was an inadequately regulated DC power supply and decided that installation of a better regulated DC power supply, to filter any voltage transients caused by electromagnetic or radio frequency interference, was necessary to correct the problem.

Corrective Actions: This condition has been entered into the corrective action program as Condition Report CR-2020-5798. As an interim action, the licensee powers down the reactor vessel head vent positioners before any planned start of the emergency diesel generators or their fans and checks the power fuses after any unplanned start of the emergency diesel generators or their fans.

Corrective Action References: Condition Report CR-2020-5798

Performance Assessment:

Performance Deficiency: The licensees failure to recognize critical differences between the replacement controllers overvoltage protection system was a performance deficiency.

Specifically, the failure to understand the differences between the original valve controller and the replacement introduced a common mode failure to both trains. This combined with a failure to implement adequate compensatory measures following inadequate corrective actions resulted in a loss of safety function for greater than technical specification allowed outage time.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the design control 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 consequences.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. This failure could have prevented the fulfillment of the safety function needed to mitigate the consequences of an accident (both vent valves being declared inoperable at the same time) and exceeded the technical specification action statement allowed outage time of 30 days. This event is considered a loss of a safety function, but the finding did not result in a loss of PRA function of a single train, or multiple trains of a technical Specification piece of equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or allowed outage time, and is therefore of very low safety significance, Green.

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision-making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. The licensee failed to fully evaluate the design of the overvoltage protection system for the new controllers and assumed it functioned similar to the overvoltage protection of the original controllers., .

Enforcement:

Violation: Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that the design control measures shall provide for verifying or checking the adequacy of design by the performance of a suitable testing program. The verifying or checking process shall be performed by individuals or groups other than those who performed the original design, but who may be from the same organization. Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualifications testing of a prototype unit under the most adverse design conditions. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.

Contrary to the above, the licensee failed to ensure that the design changes that replaced the reactor vessel head vent valve position controllers were fully evaluated to fully evaluate the design of the overvoltage protection system for the new controllers and assumed it functioned similar to the overvoltage protection of the original controllers. This evaluation should have ensured that the circuitry was compatible with the DC power supply providing power to the valves and controllers.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Follow Procedure During a Surveillance Results in an Inoperable Train of Essential Cooling Water Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.22 Systems NCV 05000498,05000499/2020002-02 Complacency Open/Closed A self-revealed Green non-cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Section 3.m, Service Water System, was documented for the failure to follow the surveillance procedure for the Unit 2, train A, essential cooling water (ECW) which challenged system operability. Specifically, plant equipment operators in the ECW pump room failed to implement step 5.2.2 of procedure 0PSP03-EW-0017, Essential Cooling Water System Train A Testing, Revision 41, to verify ECW self-cleaning strainer was running, instead, the plant equipment operator performed step 5.4.2 that secured the ECW self-cleaning strainer.

Description:

On June 20, 2020, during a Unit 2, train A, ECW surveillance, 0PSP03-EW-0017, Essential Cooling Water System Train A Testing, Revision 41, the control room requested the plant equipment operator to perform step 5.2.2 to verify the ECW strainer was running. The plant equipment operator (PEO1) repeated the request back to the control room operator correctly, to perform Step 5.2.2. With the concurrence of an experienced plant equipment operator (PEO2) in the field peer checking, PEO1 performed step 5.4.2 to remove the strainer from service. A visual and audible alarm immediately sounded in the control indicating that the train was in an abnormal alignment. Operations immediately declared the train A ECW inoperable. Control room operators immediately asked the plant equipment operators (PEO1 and PEO2) to stop any further actions, and using the 0POP02-EW-0001, Essential Cooling Water Operations, Revision 83, promptly restored the ECW train to an operable status.

The license determined that the PEOs (performer and peer checker) were both present at the pre-job brief. During the brief, operations discovered that PEO1 had never performed this surveillance, so PEO2 was assigned to peer-check the evolution. PEO1 was seen highlighting steps to be performed in the field. After the issue, PEO1 stated that it was loud and could not hear very well, the first step highlighted was step 5.4.2, not step 5.2.2, and the peer-checker was rendered useless by not providing appropriate oversight of this activity.

The licensees prompt human performance checklist determined that the PEO1 performed the wrong step, therefore failed to operate the plant in accordance with the procedure and was over reliant on the highlighted portions of the procedure. The high noise level challenged communications.

Corrective Actions: Unit 2 control room operations suspended the surveillance, restored train A ECW to an operable status within 4-minutes per a normal system operating procedure. Following an investigation, a lessons learned was distributed to the rest of the operations department.

Corrective Action References: Condition Report CR 2020-6765

Performance Assessment:

Performance Deficiency: The failure to follow an operations surveillance procedure involving safety-related equipment, which operability, was a performance deficiency. Specifically, while performing a surveillance on the Unit 2 train A ECW, plant equipment operators in the field performed step 5.4.2 of Procedure 0PSP03-EW-0017, Essential Cooling Water System Train A Testing, Revision 41, to secure the essential cooling water self-cleaning strainer instead of the directed step 5.2.2 which was to ensure that the essential cooling water self-cleaning strainer was running. This inappropriate action challenged train A ECW operability. Unit 2 operators restored the train to its original configuration within 4 minutes.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the human 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 consequences. Specifically, the plant equipment operators human performance error resulted in an inoperable ECW train and an unexpected entry into a 7-day Technical Specification action statement.

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 result in a loss of PRA function of a single train, or multiple trains of a technical specification piece of equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or allowed outage time, and is therefore of very low safety significance, Green.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the Unit 2 plant equipment operators did not consider potential undesirable consequences of their actions before performing surveillance procedure steps and did not implement appropriate error-reduction tools.

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.m, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems, of that appendix, requires, in part, that that the instructions for energizing, startup, shutdown, and changing mode of operation should be prepared for the service water system (essential cooling water at South Texas Project). The licensee established 0PSP03-EW-0017, Essential Cooling Water System Train A Testing, Revision 41, to meet the Regulatory Guide requirement. Step 5.2.2 states, Verify ECW SELF CLEANING STRAINER 1A(2A) is running.

Contrary to the above, on June 20, 2020, plant equipment operators failed to follow the step 5.2.2 and actually performed step 5.4.2 which secured the essential cooling water self-cleaning strainer, thereby challenging train A inoperability. This was an unplanned 7-day shutdown action statement of Technical Specification 3.7.7.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Licensee-Identified Non-Cited Violation 71152 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Technical Specification 6.8.1.a, Regulatory Guide 1.33, Appendix A, 1978, Section 9, states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, on September 17, 2019, maintenance (troubleshooting) was performed on the Unit 1 train C essential chiller without written instructions or procedures.

Specifically, an electrical supervisor was contacted by Unit 1 control room and asked to look at the chiller due to apparent drifting chiller output temperature discovered on an operator round. The electrical supervisor actually manipulated the operable and protected safety-related essential chiller and left a temperature control switch in off position.

Operations returned, with the electrical supervisor, a short time later to procedurally verify the temperature control loop operation and discovered the switch out of position. At that time the electrical supervisor voluntarily admitted to manipulating the component without permission or procedure.

Significance/Severity: Green. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, dated December 13, 2019, the inspectors determined that the performance deficiency did not result in a loss of PRA function of a single train, or multiple trains of a technical specification piece of equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or allowed outage time and is therefore of very low safety significance.

Corrective Action References: Condition Report CR 2019-10223 Observation: Semi-Annual Trend Review 71152 The inspectors reviewed the licensees corrective action program entries, maintenance activities, emergent maintenance issues, plant health reports, outage performance reviews, NRC generated condition reports, and NRC inspector walkdowns.

The inspectors noted and documented the following issues and trends:

• As documented in NRC Inspection Report IR 2019-004, there continues to be issues with station personnel consistently and reliably following station procedures. Recent examples are: 1) failure to follow the correct procedure step which resulted in making the Unit 1 train A ECW inoperable (CR 2020-6765), 2) an electrical supervisor failed to get permission or follow any applicable procedure to troubleshoot and manipulate the Unit 1 train C essential chiller temperature control module vein switch and resulted in making the train inoperable (CR 2019-10223), 3) during the Unit 1 train B emergency diesel generator 6-year maintenance electricians wired relays incorrectly, which led to an extra 2 days of unavailability and contributed to an unplanned entry into the Configuration Risk Management Program (CR 2020-1854), and 4) a plant equipment operator performing a restoration procedure on the wrong diesel generator resulted in making the Unit 1 train B emergency diesel generator inoperable (CR 2019-5842). While the licensee has taken action to lower the number of events, the inoperability of equipment with a failure to implement and follow procedures is an unacceptable trend.

• The resident inspectors as well as the licensee, both recognize a trend related to vendor performance due to a lack of adequate vendor oversight. Recent examples to support the trend are: 1) vendor involved in the loss of the 345kV south bus (CR 2020-3665), vendor at the main cooling reservoir river make up facility that leaked hydraulic fluid into the Colorado River which required three notifications to the state of Texas (CR 2020-1924, -3285, -5777), 3) main turbine vendor that inadvertently closed on instrument air valve (which was a near miss for a reactor trip)and issues with high pressure turbine replacement which resulted in an unnecessary heavy lift of plant equipment (CR 2020-5491, -2349), 4) vendor issues with reactor vessel head tensioning which extended the time with reactor coolant system level at head flange level (CR 2020-4352), 5) the vendor maintenance on check valve RH-32 that failed to resolve leak by and resulted in a significant challenge to Unit 1 operation and required a license amendment to temporarily resolve (CR 2020-4781), and 6) vendor failed to fabricate an adequate ECW travelling screen replacement (20-1490). The licensee initiated Condition Reports CR 2020-5829 and 2020-5911 to note the trend and the quality department elevating the trend for additional focus and resolution, respectively.

• The inspectors identified a trend in the number of persistent issues in the emergency diesel generator systems. Recent examples include: 1) multiple issues with emergency diesel generators failing to enter into their cooldown mode - after unloading the diesel and shutting it off, the diesel is, by design, run for 5-minutes before completely securing. This function is not safety-related and failure is indicative of a failed relay, but in order to prove operability the diesel must be fast started, which can impact service life due to unnecessary wear on the diesels, 2) repeated air leaks from the starting air system, 3) issues with remote monitoring of fuel oil tank levels from the control room, 4) maintenance rule unavailability for the Unit 1 train B diesel, which has been in 10 CFR 50.65(a)(1) status since June 2019 due to unavailability hours, but has continued to accumulate unavailability due to a combination of equipment issues, inadequate maintenance scheduling and human performance issues, and 5) a cracked exhaust manifold that has required a significant amount of engineering, maintenance, and operations resources to justify operability, as well as persistent NRC inspector challenges. The licensee failed to take advantage of opportunities to replace the exhaust manifold and have rescheduled the proper repair of the manifold several times and is now scheduled in November 2020 due to summer peak operations and COVID-19. If the schedule holds, the station will have been living with this issue, on a highly risk-significant plant component, for 15 months. The residents had discussions with engineering and maintenance on June 11, 2020, to express the concern of these numerous issues and the possibility that they could cloud and make future issues more difficult to diagnose. The licensee acknowledged the trend and initiated Condition Report CR 2020-7746 to further evaluate and resolve the trend.

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 3.6.1.1, Primary Containment, requires that primary containment integrity shall be maintained.

Contrary to the above, from September 3, 2019, until September 5, 2019, Unit 2 primary containment integrity was not maintained. Specifically, the Unit 2 inside containment hydrogen monitoring sample inlet test valve (2-CM-0005) was open at the same time as outside containment post-accident sampling system (PASS) test vent valve (2-AP-0004).

The outside containment PASS air sample isolation valve (2-AP-2456) located between these two valves was being replaced due to leakage. This configuration provided a pathway through containment penetration M-82D which is comprised of one-inch diameter piping.

Significance/Severity: Green. Using Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, dated April 30, 2020, the inspectors determined that this performance deficiency did not appreciably increase the Large Early Release Frequency for Unit 2 due to the small size of the piping involved. For this reason, the inspectors concluded that the finding is of very low safety significance (Green).

Corrective Action References: Condition Report CR 19-9764 This finding closes LER 05000499/2019001, Equipment Clearance Order Error Leads to Loss of Primary Containment Integrity.

Inadequate Risk Assessment of Switchyard Activities Results in Loss of 345kV South Bus Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.1] - 71153 NCV 05000498,05000499/2020002-03 Resources Open/Closed The inspectors reviewed a self-revealing Green non-cited violation of 10 CFR 50.65(a)(4) for the failure to perform an adequate risk assessment to manage the increase in risk of performing activities in the switchyard. Specifically, on March 24, 2020, the licensee failed to implement risk mitigative actions during switchyard maintenance activities because of an inadequate risk assessment, which resulted in the loss of the 345kV south bus, which was a partial loss of offsite power to both Units 1 and 2.

Description:

On March 24, 2020, Unit 1 was defueled during Refueling Outage 1RE22, while Unit 2 was in Mode 1 at full power. Unit 1 had train B emergency diesel generator (EDG) in operation carrying the 4160kV bus due to planned maintenance. Unit 2 had no Technical Specification components out of service. Transmission and distribution service provider (TDSP) personnel were performing transmission line relay testing on a 345kV line.

At 10:46 a.m., TDSP personnel had a human performance error while performing relay testing caused by applying test equipment to the wrong relay which resulted in the south bus and standby transformer 2 lockouts. The effects on the units are as follows (All equipment responded and functioned as designed without issue.):

Unit 1 Unit 1 experienced an undervoltage condition on trains A and C engineered safety features (ESF) buses, both associated EDGs started and powered the ESF buses. The 1B spent fuel pool cooling pump lost power leaving only the 1A pump in service. The time-to-boil in spent fuel pool was 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. Operators restored full spent fuel pool cooling at 10:56 a.m.,

10 minutes following the loss of one train of cooling, with a non-detectable increase in spent fuel pool temperature. One fuel bundle was also in the process of being moved and was suspended due to the loss of power. On the turbine deck, a small load was suspended over the deck. Unit 1 had all three EDGs in operation carrying all ESF buses, and all outage activities were ceased.

Unit 2 Unit 2 experienced an undervoltage condition on the train B ESF bus and its associated EDG started and powered the ESF bus. The 2A spent fuel pool cooling pump was lost leaving only the 2B pump in service. The time-to-boil in the spent fuel pool was 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />. Full spent fuel pool cooling was restored at 12:31 p.m.

The three ESF buses (Unit 1 trains A and C, and Unit 2 train B) were re-aligned to the Unit 1 standby transformer 1, which is powered by the 345kV north bus, and EDGs were secured.

TDSP replaced the damaged components and the 345 south bus was restored at 9:32 p.m.

The Unit 2 train B ESF bus was then realigned to standby transformer 2 at 10:05 p.m. Both units were completely restored to normal configuration at this time.

The inspectors reviewed the licensees root cause evaluation. The evaluation identified the direct root cause of the event to be a human performance error by TDSP employees in the switchyard. The TDSP employees energized and began testing the wrong relay which resulted in the lockout of the 345kV south bus and the standby transformer 2. Because the human performance error belonged to the TDSP employees and corrective action to prevent recurrence was determined to be unfeasible, corrective actions were focused on South Texas Project programs and processes to correct and prevent a similar issue from re-occurring.

The inspectors determined that the evaluation was thorough and reviewed the long-standing history of issues with switchyard work management going as far back as the early 1990s.

There was a similar event in 2010, in which the 345kV north bus was lost due to a TDSP employee human performance issue. Corrective actions from that event appear to have been mildly effective and short lived. The procedure at the center of the event is 0PGP03-XS-0001, Switchyard Management and its eight revisions since 2010. The procedures purpose is to define and facilitate the process for scheduling and performing maintenance in the switchyard as well assessing the risk for any given work activity. Over the years, the licensee vaguely adhered to the switchyard management procedure and it is evident that South Texas Project management has not supported the procedure and program well enough to consistently maintain a well-qualified switchyard coordinator who can properly implement the program. The initial work that was scheduled during this most recent Unit 1 refueling outage (1RE22) was initially presented by a switchyard coordinator in April 2019.

That switchyard coordinator retired and was replaced with a coordinator that was not fully qualified in August 2019. The switchyard work was reviewed again prior to the outage and the new coordinator determined that the maintenance work by TDSP would not be an Impactive Activity in accordance with the vague definition of an Impactful Activity in the switchboard management procedure. As a result, STP did not implement risk mitigative actions, such as conducting a pre-job brief with TDSP personnel providing direct oversight of the vendor, which failed to prevent the unexpected partial loss of offsite power.

Corrective Actions: Immediate actions were to stand down the TDSP work in the switchyard, to implement human performance error reduction tools to further possible errors in the switchyard, restore spent fuel pool cooling in both units, and to restore the 345kV south bus and normal ESF bus alignments. The corrective actions from the root cause evaluation involve strengthening the 0PGP03-XS-0001, Switchyard Management procedure, specifically focusing on the roles and responsibilities for the Switchyard Coordinator and reinvigorating the South Texas Project management participation in re-establishing a collaborative working relationship with the TDSP.

Corrective Action References: Condition Report CR 2020-3665

Performance Assessment:

Performance Deficiency: The failure to adequately assess maintenance risk for switchyard relay testing was a performance deficiency.

Screening: The inspectors determined that the performance deficiency was more than minor because it was associated with the protection against external factors attribute and adversely affected the Initiating Events Cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations.

Specifically, while TDSP workers were performing maintenance activities in the 345kV switchyard, a human performance error resulted in a loss of the 345kV south bus which was a partial loss of power for both units.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP. A note in the appendix given below:

Note: This guidance does not apply to the following situations:

(1) those licensees who only perform qualitative analyses of plant configuration risk due to maintenance activities, or

(2) performance deficiencies related to maintenance activities affecting SSCs needed for fire or seismic mitigation. When performance deficiencies are identified with either 1 or 2 above, the significance of the deficiencies must be determined by an internal NRC management review using risk insights where possible in accordance with IMC 612, Power Reactor Inspection Reports.

Because the licensee uses qualitative analyses for all switchyard work, Situation 1 above applies. Therefore, the significance of this performance deficiency must be determined by internal NRC management review. It should be noted that the internal management review was an artifact of the early significance determination process that was superseded by Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, issued in December of 2006 after the current revision of Appendix K.

Therefore, the inspectors requested that the senior reactor analyst initiate a review in accordance with Appendix M.

Appendix M, step 4.1, Initial Evaluation, directs the user to determine if there are any significance colors that can reasonably be excluded from further consideration using available quantitative and/or qualitative methods and best available information. The senior reactor analyst reviewed the licensees risk evaluation of the event that occurred on March 24, 2020. While this evaluation was mostly qualitative, it specifically addressed the impact to core damage frequency from the event. The performance deficiency was the failure to perform a risk assessment prior to the work in the switchyard. The analyst noted that, while risk management actions are used to protect redundant equipment, wrong-component events are not explicitly modeled when performing a maintenance rule risk assessment. Therefore, the analyst determined that the licensees assessment would bound the appropriate maintenance rule evaluation. Based on the licensees assessment and other information available to the analyst, the analyst determined that the finding was of, at most, very low safety significance, Green.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Specifically, South Texas Project site management failed to ensure they adequately supported the switchyard management program, procedure and to provide an adequately trained switchyard coordinator without collateral responsibilities to ensure error free maintenance in the 345kV switchyard.

Enforcement:

Violation: 10 CFR 50.65 (a)(4) states, in part, before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The licensee uses Procedure 0PGP03-XS-0001, Switchyard Management, Revision 8, to assess and manage the risk from switchyard maintenance activities.

Contrary to the above, on March 24, 2020, licensee personnel failed to adequately assess and manage the risk from switchyard maintenance activities. Specifically, the failure to recognize the increased risk and take risk mitigative actions for maintenance activities in the 345kV switchyard, which resulted in a loss of the 345kV south bus, which represented a partial loss of offsite power to both units.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On April 3, 2020, the inspectors presented the Inservice inspection results to Mr. J. Connolly, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.

• On May 15, 2020, the inspectors presented the Evaluations of Changes, Tests, and Experiments inspection results to Mr. J. Connolly, Executive Vice President and Chief Nuclear Officer, and other members of the licensee staff.

• On May 21, 2020, the inspectors presented revised results for the Evaluations of Changes, Tests, and Experiments to Mr. L. Sterling, Regulatory Affairs Manager, and other members of the licensee staff.

• On July 9, 2020, the inspectors presented the integrated inspection results to G. T. Powell, President and CEO, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Corrective Action CR-YYYY-NNNN 2020-5447

Documents

71111.04 Procedures 0POP02-CC-0001 Component Cooling Water 52

71111.04 Procedures 0POP02-DG- Emergency Diesel Generator 13(23) 71

0003

71111.04 Procedures 0POP02-MS- Main Steam System 64

0001

71111.04 Procedures 0POP02-SI-0002 Safety Injection Initial Lineup 47

71111.05 Procedures 0EAB02-FP-0006 Fire Preplan Electrical Auxiliary Building, Electrical 2

Penetration Area Train A

71111.05 Procedures 0EAB31-FP-0047 Fire Preplan Electrical Auxiliary Building Cable 7

Spreading/Power Cabling Area, Train B

71111.05 Procedures 0MAB27-FP-0139 Fire Preplan Mechanical Auxiliary Building CCW Pump and 4

Chiller, Train C

71111.05 Procedures 0MAB27-FP-0139 Fire Preplan Mechanical Auxiliary Building CCW Pump and 4

Chiller, Train C

71111.05 Procedures 0MAB27-FP-0142 Fire Preplan Mechanical Auxiliary Building CCW Heat 3

Exchangers

71111.05 Procedures 0MAB27-FP-0142 Fire Preplan Mechanical Auxiliary Building CCW Heat 3

Exchangers

71111.05 Procedures 0PGP03-ZF-0018 Fire Protection System Functionality Requirements 21

71111.05 Procedures 0SBX99-FP-0750 Fire Preplan for the Standby Transformer 1

71111.05 Procedures 0SBX99-FP-0750 Fire Preplan for the Standby Transformer 1

71111.05 Procedures 2ECW57-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5

0604 Room Train B

71111.05 Procedures 2ECW57-FP- Fire Preplan Essential Cooling Water Intake Structure Pump 5

0604 Room Train B

71111.07A Calculations MC-6476

71111.07A Miscellaneous ESF Diesel Generator 12 Lube Oil Cooler Tube Scale 02/2020

Inspections

71111.07A Miscellaneous ESF Diesel Generator 12 Jacket Water Cooler Tube Scale 02/2020

Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Calibration ACTS TGX-001- 0.560 Bobbin @ 80IPS Revision 0

Records 020

71111.08P Calibration ACTS TGX-002- 0.560 Bobbin @ 40IPS Revision 0

Records 020

71111.08P Calibration ACTS TGX-003- 0.540 Bobbin @ 30IPS Revision 0

Records 020

71111.08P Calibration ACTS TGX-004- 3 Coil +PT Revision 0

Records 020

71111.08P Calibration ACTS TGX-006- Single Coil +PT - Non-Mag Biased Revision 0

Records 020

71111.08P Calibration ACTS TGX-007- Single Coil +PT - Mag Biased Revision 0

Records 020

71111.08P Calibration ANTS TGX-A-020 Bobbin Coil Revision 0

Records

71111.08P Calibration ANTS: TGX-B- 3 coil +PT RPC Revision 0

Records 020

71111.08P Calibration ANTS: TGX-C- RPC - U-bend, midrange frequency +PT Revision 0

Records 020

71111.08P Calibration ANTS: TGX-E- Bobbin Coil and Rotating Coil Revision 0

Records 020

71111.08P Calibration UTCAL-2020-012 Ultrasonic Calibration - Examination Report UT-2020-015 03/19/2020

Records

71111.08P Calibration UTCAL-2020-013 Ultrasonic Calibration - Examination Report UT-2020-015 03/19/2020

Records

71111.08P Calibration UTCAL-2020-020 Ultrasonic Calibration - Examination Report UT-2020-021 03/24/2020

Records

71111.08P Calibration UTCAL-2020-021 Ultrasonic Calibration - Examination Report UT-2020-021 03/24/2020

Records

71111.08P Calibration UTCAL-2020-034 Ultrasonic Calibration - Examination Report UT-2020-028 03/27/2020

Records

71111.08P Calibration UTCAL-2020-035 Ultrasonic Calibration - Examination Report UT-2020-028 03/27/2020

Records

71111.08P Calibration UTCAL-2020-036 Ultrasonic Calibration - Examination Report UT-2020-028 03/27/2020

Records

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Calibration UTCAL-2020-037 Ultrasonic Calibration - Examination Report UT-2020-028 03/27/2020

Records

71111.08P Calibration UTCAL-2020-038 Ultrasonic Calibration - Examination Report UT-2020-028 03/27/2020

Records

71111.08P Calibration UTCAL-2020-041 Ultrasonic Calibration - Examination Report UT-2020-036 03/30/2020

Records

71111.08P Calibration UTCAL-2020-042 Ultrasonic Calibration - Examination Report UT-2020-036 03/30/2020

Records

71111.08P Corrective Action CA 19-3869-3 Centrifugal Charging Pump 1B Outboard Seal is Leaking 5/2/2019

Documents Greater than 5 dpm with the Pump Running (Tier 1

Evaluation)

71111.08P Corrective Action CA 20-62-2 Leakage from High Head Safety Injection Pump 1C 01/30/2020

Documents Mechanical Seal Leakage has Accumulated on Pump

Housing Base (Tier 1 Evaluation)

71111.08P Corrective Action CR 18-14004 Enhancements of the Contract Welding Requirements to 11/14/2018

Documents STP

71111.08P Corrective Action CR 18-2694 Increased Trend of Failures with Controllers on the New 03/04/2018

Documents Hydrazine Pumps

71111.08P Corrective Action CR 19-1891 Internal Erosion on the 6 Alum. Bronze Piping Tee and 02/17/2019

Documents Flanges of EW-0189

71111.08P Corrective Action CR 19-1966 WE NSAL-05-2- Steam Generator Secondary Side 2.5 Inch 02/19/2019

Documents or Less Diameter Un-Reinforced Penetration Cover Plate

Stress Report Error

71111.08P Corrective Action CR 19-3645 Wet and Discolored Deposits at the Packing Gland of 1-RH- 03/28/2019

Documents 0067A Indicative of an Active Packing Leak

71111.08P Corrective Action CR 19-4031 DG-12 Crack on Exhaust Piping- Weld Repair Filler 04/05/2019

Documents

71111.08P Corrective Action CR 19-5705 When Boric Acid Conditions are Screened, the 3Q CR 05/21/2019

Documents Action Template is not Being Completed

71111.08P Corrective Action CR 19-7057 Dry and white deposits at the tubesheet to HX flange of RHR 06/27/2019

Documents HX 1B

71111.08P Corrective Action CR 19-7066 Significant Dry and Discolored Deposits at the Packing 06/27/2019

Documents Gland of 1-SI-FCV-0852

71111.08P Corrective Action CR 19-9714 Evaluate Reclassifying Reactor Vessel flange Leak-off Lines 09/04/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents

71111.08P Corrective Action CA 20-3934-1 Condition Report Engineering Evaluation 20-3934-1, IWA- 03/31/2020

Documents 2240 demonstration of PDI-UT-10

Resulting from

Inspection

71111.08P Corrective Action CR 20-3934 Document Usage and Demonstration of Generic Procedure 03/28/2020

Documents PDI-UT-10 in a Condition Report Engineering Evaluation

Resulting from

Inspection

71111.08P Drawings 404490 Construction Drawing Spray Line, STP Unit 1 Revision 2

71111.08P Engineering CREE No. 10- Replacement Reactor Vessel Head (RRVH) Internal Revision 0

Evaluations 21733-1 Disconnect Device (IDD) Penetrations (weld build-up

location), a Technical Position

71111.08P Engineering CREE No. 17- Code Case N-566-2 Engineering Evaluation- System Heat 11/16/2017

Evaluations 16232-2 Exchanger (HX) 1B Flange

71111.08P Miscellaneous South Texas Project 1 RE22 Outage Eddy Current 03/24/2020

Certification Review

71111.08P Miscellaneous NDE-PQ-2015-002, Procedure Qualification (Procedure 10/26/2015

0PEP10-ZA-0017)

71111.08P Miscellaneous Certificate of Qualification- David R. Kleinjan 01/17/2020

71111.08P Miscellaneous Certificate of Qualification- James H. Hoover 01/16/2020

71111.08P Miscellaneous Certificate of Qualification - Mary Matteson 01/30/2020

71111.08P Miscellaneous Certificate of Qualification - Eduardo M. Barrera 01/16/2020

71111.08P Miscellaneous STP Nuclear Operating Company, Certification Record No. 06/27/17

298

71111.08P Miscellaneous STPEGS Units 1 and 2 In-service Inspection Program Plan Revision 9

71111.08P Miscellaneous MRS-TRC-1790 Omni 200 to TC6700 Digital Tester Equivalency 12/18/2006

71111.08P Miscellaneous MRS-TRC-1850 Omni 200 Tester Basis for Equivalency, Appendix H Revision 1

Essential Variable Characterization and ASME Code

Compliance

71111.08P Miscellaneous MRS-TRC-2371 Site Validation of Appendix H / I Inspection Techniques for 03/23/2020

South Texas Unit -1 (1RE22), Spring 2020

71111.08P Miscellaneous PDQS 322 David R. Kleinjan 09/30/2013

71111.08P Miscellaneous PQR 254 Weld Procedure Qualification for WPS P45 (F43)-T-AG 06/14/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Miscellaneous SG-CDMP-19-21 South Texas 1RE22 Steam Generator Degradation Revision 0

Assessment

71111.08P Miscellaneous SG-SGMP-15-18 South Texas Project Unit 1 -Steam Generator Cycle 19 Revision 0

Condition Monitoring and Cycles 20, 21, and 22 Preliminary

Operational Assessment

71111.08P Miscellaneous Welder No. C44 Certification Record 01/25/1996

71111.08P Miscellaneous Welder No. J76 Certification Record 07/06/2011

71111.08P Miscellaneous Welder No. L35 Certification Record 07/06/2011

71111.08P Miscellaneous Work Order No. CMTR - ARCOS Industries - 3/32 X 36 Wire LotNo./ Heat 03/22/2017

96009129 No. CP0447-QU946

71111.08P Miscellaneous Work Order No. CMTR - Energy & Process Corporation - 4 Butt Welded 09-08-2017

96009129 Elbows

71111.08P Miscellaneous Work Order No. CMTR - Energy & Process Corporation - 4 Butt Welded 09-08-2017

96009129 Pipe

71111.08P Miscellaneous Work Order No. Butt Weld Inspection Checklist, Weld HFW1402 08/15/2018

96009129

71111.08P Miscellaneous Work Order No. Butt Weld Inspection Checklist, Weld HFW1405 08/15/2018

96009129

71111.08P Miscellaneous Work Order No. Butt Weld Inspection Checklist, Weld HFW1408 08/15/2018

96009129

71111.08P NDE Reports MT-2020-010 Main Steam Pipe Lugs 27PLl-27PL8/30-MS-1001-GA2 03/16/2020

71111.08P NDE Reports MT-2020-014 RPV Closure Stud 2A 03/24/2020

71111.08P NDE Reports PT-2018-029 Liquid Penetrant Examination - Weld EW-1130-HFW-1408 04/09/ 2018

71111.08P NDE Reports PT-2018-041 Liquid Penetrant Examination - Weld EW-1130-HFW-1402 04/09/ 2018

71111.08P NDE Reports PT-2018-043 Liquid Penetrant Examination - Weld EW-1130-HFW-1405 04/09/2018

71111.08P NDE Reports UT-2020-015 Branch Connection-to-Bent Pipe 2-RC-1220-BB1 03/21/2020

71111.08P NDE Reports UT-2020-020 Pressurizer Pipe to Safe-end Overlay 14-WOL-N2 03/24/2020

71111.08P NDE Reports UT-2020-021 Pressurizer Spray Nozzle to Safe End weld Overlay PRZ-1- 03/24/2020

N2-SE-WOL

71111.08P NDE Reports UT-2020-023 Pipe-to-Branch Connection 4-RC-1126-BB1 Weld 6 03/27/2020

71111.08P NDE Reports UT-2020-032 CRD NO. 68 Housing Lower Weld/ RRVH-CRD-68L 03/27/2020

71111.08P NDE Reports UT-2020-036 Pipe-to-Branch Connection 4-RC-1323-BB1 Weld 4 03/30/2020

71111.08P NDE Reports VTI/3-2020-009 RPV Washers 1A through 36A 03/28/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P NDE Reports WCD No. EW- ASME Section XI Repair/Replacement Activity Pressure 08/16/2018

96009129 Testing - ISLT Post-Maintenance Pressure Test Traveler-

1EWSYSTEM

71111.08P Procedures Steam Generator Eddy Current Testing Data Analysis 03/09/2020

Guidelines

71111.08P Procedures 0PEP10-ZA-0004 General Ultrasonic Examination Revision 8

71111.08P Procedures 0PEP10-ZA-0017 Magnetic Particle Examination (Dry Powder Yoke Method) Revision 6

71111.08P Procedures 0PEP10-ZA-0024 ASME XI Examination for VT-1 and VT-3 Revision 5

71111.08P Procedures 0PGP03-ZE-0027 ASME Section XI Repair/Replacement Activities Revision 31

71111.08P Procedures 0PGP03-ZE-0033 RCS Pressure Boundary Inspection for Boric Acid Leaks Revision 13

71111.08P Procedures 0PGP03-ZE-0133 Boric Acid Corrosion Control Program Revision 12

71111.08P Procedures 0PGP04-ZE-0304 Inservice Inspection Program For Welds and Component Revision 14

Supports

71111.08P Procedures MRS 2.4.2 GEN- Eddy Current Inspection of Pre-service and In-service Heat Revision 19

Exchanger Tubing

71111.08P Procedures MRS-GEN-1127 Guideline for Steam Generator Eddy Current Data Quality Revision 16

Requirements

71111.08P Procedures MRS-GEN-1214 Steam Generator Channel Head Video Inspection Revision 5

71111.08P Procedures MRS-GEN-1240 Position Verification Procedure Revision 7

71111.08P Procedures MRS-SSP-1619- Steam Generator Eddy Current Data Analysis Guidelines for Revision 7

TGX/THX Inservice Inspections at South Texas Units 1 and 2

71111.08P Procedures OPEPIO-ZA-0019 Wet Fluorescent Magnetic Particle Examination For ASME Revision 5

Section XI PSI/ISI

71111.08P Procedures PDI-UT-10 Generic Procedure for the Ultrasonic Examination of Revision G

Dissimilar Metal Welds

71111.08P Procedures PDI-UT-2 Generic Procedure for the Ultrasonic Examination of Revision H

Austenitic Piping Welds

71111.08P Procedures PDI-UT-8 Generic Procedure for the Ultrasonic Examination of Weld Revision I

Overlaid Similar and Dissimilar Metal Welds

71111.08P Procedures UTI-065 Ultrasonic Examination of Small-Diameter Piping Butt Welds Revision 0

and Components for Thermal Fatigue Damage

71111.08P Procedures WPS P45 (F43)- Manual GTAW 06/14/17

T-AG

71111.08P Self-Assessments CR 14-10410 Risk-Informed ISI Periodic Evaluation for South Texas 06/24/14

Inspection Type Designation Description or Title Revision or

Procedure Date

Project Electric Generating Station Units 1 & 2 in

Conjunction with End of the Third Interval, First Period

71111.13 Procedures 0PGP03-ZG-0091 Configuration Risk Management Program 14

71111.13 Procedures 0POP01-ZO-0011 Operability, Functionality, and Responsibility Guidance 11

71111.15 Corrective Action CR-YYYY-NNNN 2010-21759, 2017-17317, 2018-8223, 2018-12121, 2018-

Documents 2084, 2019-7235, 2019-8208, 2019-14780, 2020-4561,

20-5447, 2020-3414, 2020-4352

71111.15 Miscellaneous Unit 1 and 2 Pump and Valve Inservice Test Plan, Third Ten- 71

Year Interval

71111.15 Procedures 0PMP04-RX- Non-Rapid Refueling Mechanical Support 20

0018A

71111.15 Procedures 0POP02-DG- Emergency Diesel Generator 12(22) 79

0002

71111.15 Procedures 0POP02-DG- Emergency Diesel Generator 13(23) 17

0003

71111.15 Work Orders Work 574847, 601789, 601790

Authorization

Numbers

71111.17T Corrective Action CR-YYYY-NNNN 2012-31926, 2014-12285, 2015-14074, 2015-16599,

Documents 2015-20773, 2015-22176, 2015-110072, 2016-00128,

2016-02214, 2016-05792, 2017-00118, 2017-22335,

2017-20542, 2017-23295, 2018-02757, 2018-05242,

2018-11062, 2018-88275, 2019-00872, 2019-10118,

20-02312

71111.17T Corrective Action CR-YYYY-NNNN 2020-5748, 2020-5794, 2020-5795, 2020-5796, 2020-5797,

Documents 2020-5798, 2020-5800, 2020-5801, 2020-5802

Resulting from

Inspection

71111.17T Drawings 204298- Target Rock 810000 G

0100005T3

34577698

71111.17T Drawings 5N129F05016 Piping and Instrumentation Diagram Safety Injection System 15

71111.17T Drawings 79AB-003BB 1 Inch Modulating Valve Assembly And Controller E

71111.17T Drawings 79AB-003BB Target Rock F

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.17T Drawings VTD-T020-0052 Vendor Technical Document For Target Rock 810000-X 0

Positioner Technical And Installation Manual TRP 9375 For

South Texas Project Nuclear Operating Company

71111.17T Engineering 14-12-285 Modify use of WRB-2M DNB Correlation in UFSAR Accident 0

Changes Analyses

71111.17T Engineering 15-22176 Use of Speed Crete as welded joint sealant in prestressed 0

Changes concrete embedded cylinder pipe

71111.17T Engineering 16-128-325 Evaluation of Belleville Washer 01/29/2018

Changes

71111.17T Engineering 16-2214-10 Revise Environmental Qualification DBD to Address QDPS 07/25/2017

Changes On-going Qualification in Mild Environment

71111.17T Engineering 16-5792 Update UFSAR 15.1.5 to Incorporate Revised HZP MSLB 0

Changes Core Response Analysis Due to RCCA D-6 Removal

71111.17T Engineering 17-118-148 Engineering Evaluation of Parker Fitting 48F-5-2 for use in 0

Changes the Standby Emergency Diesel Generator Starting Air

System Air Starting Valve

71111.17T Engineering 17-20542-7 Replace Emergency Transformer 138KV Circuit Switch 05/09/2018

Changes Operator

71111.17T Engineering 17-22335-2 Replace 27C Relay (ITE J13) Associated in Control Circuit 10/19/2017

Changes for Containment Spray Pump 1B

71111.17T Engineering 17-23295-3 Install Pipe Cap Downstream of Safety Injection Accumulator 09/20/2018

Changes Nitrogen Supply Vent Valve, A1SIHCV0900

71111.17T Engineering 18-11062-2 Update Vendor Drawing and Setpoint List for CCP 1B Lube 10/02/2018

Changes Oil Pressure Switch

71111.17T Engineering 18-5242-2 Replacement Valve for Application 2R172TCV0392 04/20/2018

Changes

71111.17T Engineering 18-88-275 Replacement Size 3 & 4 Magnetic Motor Starters for Class 12/05/2019

Changes 1E Application

71111.17T Engineering 19-10118-9 Replace Primary Fuses in Aux Relay Panel for Unit 1 0

Changes Reactor Vessel Head Vent Valve HCV0601 & 602.

71111.17T Engineering 19-872-1 Extend the Quality Life (QL) of the Primary Sampling 04/30/2019

Changes Systems Target Rock Solenoid Valves and Reed Switches

71111.17T Engineering 20-2312-6 Installation Of Metal Oxide Varistors (MOV's) For Unit 1 Rx 03/19/20

Changes Vessel Head Vent Throttle Valves Positioners HY0601 and

Inspection Type Designation Description or Title Revision or

Procedure Date

HY0602

71111.17T Engineering 20-2312-6 Installation of Metal Oxide Varistors (MOVs) for Unit 1 RX 0

Changes Vessel Head Vent Throttle Valves Positioners HY0601 and

HY0602

71111.17T Miscellaneous 10 CFR 50.59 Resource Manual 4

71111.17T Miscellaneous 12-31926-43 Class 1E 4.16KV Circuit Breaker Replacements 11/27/2018

71111.17T Miscellaneous 15-14074-4 Create Environment Data Table for Rosemount Transmitters 01/30/2019

in EQDB database

71111.17T Miscellaneous 15-20773-1 Validate and Update Loading for 125 Volt DC Distribution 09/18/2018

Panel PL039A

71111.17T Miscellaneous 15-20773-2 Validate and Update Loading for Remaining Circuits on 12/17/2019

Class 1E 125 Volt DC Distribution Panels PL039B, PL039C,

PL040A, PL139A, PL139B and PL139C

71111.17T Miscellaneous 16-128-30 Rosemount Differential Pressure Transmitter 1151DP 07/09/2018

Replacement Part

71111.17T Miscellaneous 16-128-94 Alternate replacement Limitorque actuator for B320-10 10/08/2018

71111.17T Miscellaneous 18-2757-11 Temporary Installation of a Portable Heater/Fan Unit in 05/22/2018

Doorway (Door 307) of Room 321 (E1C11 125 Volt QC

Battery Rack Room) on the 60 foot Elevation of the Electrical

Auxiliary Building (EAB)

71111.17T Miscellaneous NSAL-14-5 Lower Than Expected Critical Heat Flux Results Obtained 06/17/2014

During Departure from Nucleate Boiling Testing

71111.17T Miscellaneous QDPS Life 001 QDPS Ongoing 1E Qualification Beyond 5 Years 1

71111.17T Miscellaneous Report No.: 9375 810000-x Positioner Technical And Installation Manual A

71111.17T Miscellaneous TB-17-3 7300 NAL Board Influenced by Voltage Transients Caused 10/23/2017

by Unsuppressed Solid State Protection System Input Relay

Coil

71111.17T Miscellaneous TRP No.: 9918 Design Report For Target Rock Modulating Solenoid A

Operated Valve Model 79AB-003BB

71111.17T Procedures 0PAP01-ZA-0103 License Compliance Review 15

71111.17T Procedures 0PGP03-ZA-0109 Configuration Management Program 19

71111.17T Procedures 0PGP03-ZO-0003 Temporary Modifications 34

71111.17T Procedures 0PGP04-ZE-0309 Design Change Package 38

71111.17T Procedures 0PGP04-ZE-0318 Non-Design Configuration Change 3

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.17T Procedures 0PGP05-ZA-0002 10CFR50.59 Evaluations 18

71111.17T Procedures 0PLP01-ZA-0004 Control of the 10 CFR 50.59 Resource Manual 1

71111.17T Procedures 0POP02-SI-0001 Safety Injection Accumulators 41

71111.17T Procedures 0POP02-SI-0002 Safety Injection System Initial Lineup 47

71111.17T Procedures 0POP02AE0005 138 KV Circuit Switcher Operation 6

71111.17T Procedures 0POP02AF0001 Auxiliary Feedwater 53

71111.17T Procedures 0POP02EE0001 ESF (Class 1E) DC Distribution System 37

71111.17T Procedures 0POP02FW0001 Main Feedwater 106

71111.17T Procedures 0POP02SP0001 Solid State Protection System 21

71111.17T Procedures 0POP07-SI-0002 Safety Injection System Accumulator Valves Functional Test 0

71111.17T Procedures 0POP11DJ0001 Class 1E 125V DC Battery Feeder Breaker Replacement 10

71111.17T Procedures 0POP11DJ0002 Online Class 1E 125V DC Battery and Inverter Removal 15

from Service and Restoration

71111.17T Work Orders 96011079 Safety Injection Accumulator Nitrogen Supply Vent Valve 06/05/18

71111.19 Corrective Action CR-YYYY-NNNN 2020-1334, 2020-1460, 2020-4229, 2020-3700, 2020-5599,

Documents 2018-13641, 2014-10004

71111.19 Miscellaneous VTD-T905-0006 Operating and Maintenance Instructions for Containment 2

Auxiliary Airlock

71111.19 Procedures 0PMP07-ZJ-1013 ASCO Solenoid Valve EQ Replacement 12

71111.19 Procedures 0PSP03-CC-0009 Component Cooling Water System Train 1C(2C) Valve 21

Operability Test

71111.19 Work Orders Work 627539, 592943, 631598, 557157, 519513, 488580, 451089,

Authorization 560852, 554901, 605180, 633202, 546428, 503628

Number

71111.22 Corrective Action CR-YYYY-NNNN 2020-2774, 2020-2889, 2020-5401, 96-14089, 2020-6175,

Documents 2018-3366

71111.22 Procedures 0PGP03-DJ-0001 1E Battery Monitoring and Maintenance Program 2

71111.22 Procedures 0PSP03-DG-0003 Standby Diesel 13(23) Operability Test 64

0PSP03-DG-0022 Standby Diesel Interdependence Verification 16

71111.22 Procedures 0PSP03-RH-0002 Residual Heat Removal Pump 1B(2B) Inservice Test 19

71111.22 Procedures 0PSP03-SP- Train S Reactor Trip Breaker TADOT 39

0006S

71111.22 Procedures 0PSP05-RC-0420 Delta T and T Average Loop 2 Set 2 Calibration (T-0420) 59

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Procedures 0PSP05-RC-0440 Delta T and T Average Loop 4 Set 4 Calibration (T-0440) 55

71111.22 Procedures 0PSP06-DJ-0001 125 Volt Class 1E Battery Monthly Surveillance Test 37

71111.22 Procedures 0PSP06-DJ-0003 125 Volt Class 1E Battery Intercell Connection Resistance 21

Surveillance Test

71111.22 Procedures 1TEP04-HP-0001 Load Swing Test 1

71111.22 Work Orders Work 591405

Authorization

Number

33