IR 05000498/2018001

NRC Integrated Inspection Report 05000498/2018001 and 05000499/2018001

ML18131A014
Person / Time
Site:	South Texas
Issue date:	05/14/2018
From:	Nick Taylor NRC/RGN-IV/DRP/RPB-B
To:	Gerry Powell South Texas
Taylor N
References
EA-17-135 IR 2018001
Download: ML18131A014 (35)

Text

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000498/2018001 AND 05000499/2018001

Dear Mr. Powell:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On May 7, 2018, 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.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. Further, inspectors documented licensee-identified violations which were determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the South Texas Project Electric Generating Station.

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 the South Texas Project Electric Generating Station. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Nicholas H. Taylor, Chief Project Branch B Division of Reactor Projects Docket Nos. 50-498 and 50-499 License Nos. NPF-76 and NPF-80 Enclosure:

Inspection Report 05000498/2018001 and 05000499/2018001 w/Attachment 1: Supplemental Information 2: Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000498, 05000499 License Numbers NPF-76, NPF-80 Report Numbers: 05000498/2018001; 05000499/2018001 Enterprise Identifier: I-2018-001-0004 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: Wadsworth, TX 77483 Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: A. Sanchez, Senior Resident Inspector N. Hernandez, Resident Inspector D. Proulx, Senior Project Engineer S. Graves, Senior Reactor Inspector L. Carson II, Senior Health Physicist P. Hernandez, Health Physicist Approved By: Nicholas H. Taylor Chief, Project Branch B Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a quarterly integrated inspection at South Texas Projects 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. NRC and self-revealed findings, violations, and additional items are summarized in the table below.

Licensee-identified non-cited violations are documented in report section 71111.05.

List of Findings and Violations Failure to Perform a Maintenance Risk Assessment Prior to Conducting Maintenance Cornerstone Significance Cross-cutting Report Aspect Section Initiating Events Green [H.1] -Human 71111.13 NCV 05000498/2018-01 Performance, Maintenance Closed Resources Risk Assessments and Emergent Work Control Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4) for the failure to perform a maintenance risk assessment prior to performing maintenance that could have resulted in a reactor shutdown. Specifically, maintenance performed to install bird netting on the Unit 1 deaerator structure above the balance of plant 13.8 kV transformers was not evaluated or identified as being a threat to stable power operations.

Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with Reactor Containment Fan Coolers Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.1] -Human 71152 Systems NCV 050004992018-02 Performance, Problem Closed Resources Identification and Resolution Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI for the failure to promptly identify and correct a condition adverse to quality.

Specifically, the backdraft damper of the Unit 2, train B reactor containment fan cooler failed to close, as designed, due to a failed closing spring. The backdraft damper had undergone a preventative maintenance activity one month prior to the failure, but the closing spring degradation was not identified.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power. On March 12, 2018, the unit entered coast down operations for refueling outage 2RE19, which began on March 24, 2018. The unit remained in a refueling outage for the remainder of the 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/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.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm weather and the increased likelihood of tornados on February 21, 2018.

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for

(1) Extreme cold weather and ice on January 16, 2018

71111.04 - Equipment Alignment Partial Walkdown

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

(1) Unit 1, train B steam generator power operated relief valve while train C was out of service for planned maintenance on January 18, 2018

(2) Unit 2, train C 125 Vdc battery while train B battery was out of service for planned maintenance on January 19, 2018

(3) Unit 2, train B auxiliary feedwater while train C was out of service for planned maintenance on January 22, 2018

(4) Unit 1, train B control room envelope Heating, Ventilation, and Air Conditioning while train C was out of service for planned maintenance on February 13, 2018

(5) Unit 1, train A diesel generator while train C emergency diesel generator was out of service for planned maintenance on February 28, 2018

(6) Unit 2, train C low head safety injection while train A was out of service for planned maintenance on March 6, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Turbine generator building 4.16kV and electrical equipment rooms, Unit 1, Fire Area: 90, Fire Zone Z702 on January 2, 2018

(2) Electrical auxiliary building relay cabinet area of control room, Unit 1, Fire Area: 01, Fire Zone Z032 on January 18, 2018

(3) Electrical auxiliary building motor generator room, Unit 2, Fire Area: 04, Fire Zone: Z054 on January 22, 2018

(4) Fuel handling building, emergency core cooling cubicle, train B, Unit 1, Fire Area: 35, Fire Zone: Z306 on January 29, 2018

(5) Fuel handling building, emergency core cooling cubicle, train B, Unit 2, Fire Area: 35, Fire Zone: Z306 on February 23, 2018

71111.06 - Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protection:

(1) Emergency core cooling pump rooms Unit 1 and Unit 2 on January 30, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated simulator training exercises on February 22, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Unit 1, Containment particulate radiation monitor, RT-8011, failed on February 7, 2018

(2) Unit 2, Reactor shutdown to Mode 3 for refueling outage on March 24, 2018

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1 technical support center diesel generator following failure of the output breaker to close during a post maintenance test on March 29, 2018

(2) Unit 1 train A instrument air compressor following high vibrations and a failed post maintenance test on March 30, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 2, elevated risk due to train A 125 Vdc battery testing that required entry into the configuration risk management program on January 10-11, 2018

(2) Unit 1, elevated risk due to train D auxiliary feedwater pump room HVAC supply fan that failed during surveillance testing on January 23, 2018

(3) Unit 2, elevated risk due to train D 125 Vdc battery testing that required entry into the configuration risk management program on January 31, 2018

(4) Unit 1, elevated risk due to train C emergency diesel generator and control room envelope HVAC maintenance exceeding planned maintenance window, on February 14, 2018

(5) Unit 2, elevated risk due to qualified display processing system APC-B1 analog-to-digital card replacement on February 14, 2018

(6) Unit 1, elevated risk due to low head safety injection sump isolation valve failing to open from the control room on March 8, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 balance of plant (BOP) diesel generator and the G5 480Vac bus functionality assessment following a blown fuse during the BOP diesel automatic alignment

(2) Unit 1, train B emergency core cooling system operability assessment following failure of a control room hand switch for the containment sump to safety injection suction header isolation valve

(3) Unit 1, secondary containment sump level transmitter historical operability assessment following failure to indicate sump level

(4) Unit 1, train A auxiliary feedwater pump room floor drains due to debris

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Unit 1, instrument air compressor 11 after replacement of the air end unit and pneumatic valve on January 22, 2018

(2) Unit 2, loop 3 reactor coolant system flow channel power supply card replacement on January 26, 2018

(3) Unit 1, train D turbine-driven auxiliary feedwater pump following planned preventative maintenance on January 26, 2018

(4) Unit 2, BOP diesel generator following planned preventative maintenance on January 30, 2018

(5) Unit 1, train C control room envelope makeup damper following corrective maintenance on February 15, 2018

(6) Unit 1, train C 125 Vdc battery room heater following corrective maintenance on February 15, 2018

(7) Unit 2, train C control room makeup fan following corrective maintenance February 23, 2018

==71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated refueling outage 2RE19 activities from March 24-31, 2018. The inspectors competed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine==

(1) 0PSP11-CS-0008, Unit 2, containment spray system, train C, contaminated system leakage test, on January 23, 2018

(2) 0PSP05-MS-0505T, Unit 2, turbine impulse chamber pressure (P-13) transmitter calibration on January 29, 2018

(3) 0PSP02-NI-0041, Unit 2, NI-41 power range channel surveillance test on February 7, 2018

(4) 2PSP03-ZG-007B, Unit 2, train B remote shutdown system operability test on

February 14, 2018 In-service (4 Samples)

(1) 0PSP03-FC-0003, Unit 2, train B spent fuel pool cooling pump, inservice test on January 24, 2018

(2) 0PSP03-SI-0003, Unit 1, train C low head safety injection pump inservice test on February 15, 2018

(3) 0PSP11-MS-0001, Unit 2, train D main steam safety valve inservice test on March 20, 2018

(4) 0PSP03-SI-0039, Unit 2, train B, emergency core cooling system comprehensive pump tests

71114.06 - Drill Evaluation Emergency Planning Drill

The inspectors evaluated the licensees emergency response drill involving a loss of residual heat removal, small break loss-of-coolant accident, and general emergency on March 1,

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment

===The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers===

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Implementation of ALARA and Radiological Work Controls

The inspectors reviewed ALARA practices and radiological work controls by reviewing the following activities:

(1) RWP 2017-2-0196 Transfer of filters from room 333 to room 218J to on-site storage container (OSSC)

(2) RWP 2017-1-0159 Transfer of filters from room 333 to room 218J to OSSC

(3) RWP 2018-0111 2RE19 reactor head vessel upper internal movement

(4) RWP-2018-0118 2RE19 - Disconnect/re-connect seal table (LHRA)

(5) RWP 2018-0119 2RE19 Retract/re-insert thimble tubes

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

OTHER ACTIVITIES - BASELINE

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

=

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (Units 1 and 2, January -

December 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample ( Units 1 and 2, January-December 2017)

(3) IE04: Unplanned Scrams with Complications Sample (Units 1 and 2, January-December 2017)

(4) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (May 1-December 31, 2017)

(5) OR01: Occupational Exposure Control Effectiveness Sample (May 1-December 31, 2017)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

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

(1) Review of continued water intrusion into the diesel generator rooms, which periodically resulted in moisture accumulating on the control panels, specifically for Unit 2, train B emergency diesel generator

(2) Failed reactor containment fan cooler, 21B, backdraft damper due to a failed closing spring

INSPECTION RESULTS

Licensee Identified Non-Cited Violation, EA-17-135

71111.05AQ - Fire Protection

Annual/Quarterly 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.

Violation: Title 10 CFR 50.48, Fire Protection, requires, in part, that licensees have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of damage.

STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.E.

Fire Protection states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1 Administrative Controls states, in part, that the operability/functional capability of the fire protection systems required to protect safe shutdown capability is assured through the implementation of an administrative program. This program includes compensatory actions for systems out-of-service.

Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 4.7.2.14, requires, in part, hourly fire watch personnel must pass through the areas covered by the fire watch and then sign and enter the time on the fire watch log, using the bar code reader, at least once every clock hour.

Contrary to the above, on May 25 and 26, 2016, the licensees fire watch personnel failed to pass through the areas covered by the fire watch and then sign and enter the time on the fire watch log, using the bar code reader, at least once every clock hour. Specifically, two fire watch individuals documented conducting Unit 2 Fire Watch 10118 for Room 105 starting on May 25, 2016, at 1928 and finishing on May 26, 2016, at 0504 when in fact the individuals did not enter Room 105.

Significance/Severity Level: Although this violation is willful, it was brought to the NRCs attention by the licensee, it involved isolated acts of low-level individuals, and it was addressed by appropriate remedial action. Therefore, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Corrective Action References: Condition Reports 16-7305, 16-7089, 16-7344, and 16-9077 Licensee Identified Non-Cited Violation, EA-17-135

71111.05AQ - Fire Protection

Annual/Quarterly 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.

Violation: Title 10 CFR 50.9, Completeness and accuracy of information, requires, in part, that information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects.

STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.E.

Fire Protection states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1 Administrative Controls states, in part that the operability/functional capability of the fire protection systems required to protect safe shutdown capability is assured through the implementation of an administrative program. This program includes compensatory actions for systems out-of-service.

Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 7.3 requires, in part, that completed fire watch logs Form 4 or their equivalent shall be retained for 3 years.

Contrary to the above, the licensee failed to maintained information required by the Commissions regulations, orders, or license conditions that was complete and accurate in all material respects as evidenced by the following two examples:

1. On May 25, 2016, the written fire watch log, documented on Form 4, for Unit 2 Fire Watch 10118, for Room 105, for the hours of 1928 and 2015, indicated that the hourly fire watches were conducted by passing through the areas covered by the fire watch.

However, the fire watch never entered Room 105 for these 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The hourly fire watch patrol data is material to the NRC in that it provides sufficient evidence of compliance with regulatory requirements.

2. On May 25-26, 2016, the electronic fire watch scanned logs for Unit 2 Fire Watch 10118, for Room 105 between the hours of 2105 on May 25, 2016, to 0504 on May 26, 2016, show that the 9 hourly fire watches were conducted by passing through the areas covered by the fire watch. However, a temporary scan point was placed at the base of the ladder in Room 002 to scan for Room 105. The hourly fire watch individuals never entered Room 105. The hourly fire watch patrol data is material to the NRC in that it provides sufficient evidence of compliance with regulatory requirements.

Significance/Severity Level: Although this violation is willful, it was brought to the NRCs attention by the licensee, it involved isolated acts of low-level individuals, and it was addressed by appropriate remedial action. Therefore, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Corrective Action Reference: Condition Report 18-0948 Failure to Perform a Maintenance Risk Assessment Prior to Conducting Maintenance Cornerstone Significance Cross-cutting Report Aspect Section Initiating Events Green [H.1] -Human 71111.13 NCV 05000498/2018-01 Performance, Maintenance Closed Resources Risk Assessments and Emergent Work Control

Introduction:

The inspectors identified Green, non-cited violation of 10 CFR 50.65(a)(4) for the failure to perform a maintenance risk assessment prior to performing maintenance that could have resulted in a reactor shutdown. Specifically, maintenance performed to install bird netting on the Unit 1 deaerator structure above the balance of plant 13.8 kV transformers was not evaluated or identified as being a threat to stable power operations.

Description:

On November 3, 2017, the inspectors observed work being performed on the deaerator structure on the roof of the Unit 1 turbine building. The workers were in the process of installing bird netting over the entire structure to help alleviate the bird feces problem on and under that structure. The inspectors observed the use of a man basket machine lift (JLG) to accomplish this work. At the time, the JLG was in operation over two 13.8kV to 4160V transformers 1D1 and 1D2, known as the balance of plant transformers. The transformers provide electrical power to buses that provide power to various loads including open loop cooling pumps. Unit 1 has three open loop cooling pumps. The open loop cooling pumps provide main cooling reservoir water to cool secondary plant loads, most importantly, turbine generator hydrogen coolers. The inspectors inquired as to the risk assessment for the activity over the transformers. After realizing that the control room operators were not aware of the work, the shift manager went out to the work site and stopped the activity and initiated Condition Report 17-22934. The corrective action for issue was to notify the control room prior to beginning work above the transformers until the project was complete.

On November 7, 2017, the inspectors again observed work activities to install bird netting over the Unit 1 balance of plant transformers. The inspectors asked the Unit 1 shift manager about a risk assessment for the maintenance activity. Again, the control room operators were not aware of the work activity. Contrary to the corrective action for the November 3 issue, the facilities work group mistakenly called the security department instead of the control room to communicate their work activities. The work activity was shut down by the Unit 1 shift manager, who then initiated Condition Report 17-23022. Operations subsequently put together a very specific plan, with diagrams, expectations, and specific contact information for the facilities department to follow work the bird netting installation until completion of the project. Facilities reviewed and accepted the plan and no other incidents were noted.

The inspectors reviewed the prompt investigation and the human performance checklist. The prompt investigation named several flawed or missing tools, such as situational awareness and questioning attitude. The prompt human performance checklist concluded lack of communication between departments and the failure to recognize risk resulted in work being performed without a risk assessment or operations knowledge.

Corrective Action: The main corrective action included a question in the facilities work order process (when an individual fills out a work order request on line) to prompt consideration of plant impact and plant status control and to approval through the work start authority when identified.

Corrective Action References: Condition Reports 18-4707, 17-23022, 17-22934

Performance Assessment:

Performance Deficiency: The failure to assess and manage the increase in risk for planned maintenance that could have affected stable plant operations was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because it can be viewed as a precursor to a more significant event. Specifically, not performing a risk assessment for maintenance activities to install bird netting on the deaerator structure, which involved the use of a man basket (JLG) over the balance of plant (BOP)transformers could have caused a loss of one or both BOP transformers and would have resulted in a plant shutdown without operations being aware of the vulnerability or being able to take risk mitigating actions. In this case the licensee would not have allowed the work without extra precautions on the work platform to protect from foreign material falling off the platform and into the transformers. Furthermore, operations would not have allowed the work activity on November 7, 2017, because open loop pump 11 was out of service for maintenance, which was a loss in redundancy, and would result in a reactor trip if one pump were to have failed.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609 Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance. This process involved working with the Senior Reactor Analyst (SRA) and your probabilistic risk assessment (PRA)group to perform a risk assessment to determine the incremental core damage probability (ICDP), or in this case, the risk deficit because a risk assessment was not initially performed.

The analyst determined that the ICDP was roughly equivalent to a turbine trip (7 x 10-7), which at full reactor power, would also result in a reactor trip. The analyst noted that this value was bounding because a turbine trip did not actually occur; the duration of the condition was not taken into account; and the zero-maintenance core damage frequency was not deducted from the risk deficit. The dominant core damage sequences for a plant transient involved anticipated transient without scram combined with either: 1) a failure to relieve reactor coolant system; 2) successful pressure control with failure of the main feedwater system and reactor coolant system boration; or a consequential failure of offsite power. Because the bounding ICDP was less than 1 x 10-6, in accordance with Appendix K, Flowchart 1, Assessment of Risk Deficit, the finding was determined to be of very low safety significance, Green.

Cross-cutting Aspect: The inspectors determined that the finding had a cross-cutting aspect in the area of human performance associated with resources. Licensee personnel failed to ensure that procedures were available and adequate to support nuclear safety. Specifically, the maintenance work activity performed on November 3 and November 7, 2017 was not recognized as affecting plant operations because the facilities work order process did not prompt planners to consider plant impact [H.1].

Enforcement:

Violation: Title 10 CFR 50.65(a)(4) states, in part, that the licensee shall assess and manage the increase in risk that may result from proposed maintenance activity.

Contrary to the above, on November 3 and 7, 2017, the licensee failed to assess and manage the increase in risk that resulted from a maintenance activity. Specifically, the licensee failed to assess and manage the risk of the maintenance activity to install bird netting on the deaerator structure, which involved the use of a man basket (JLG) over the balance of plant transformers. The loss of one or both BOP transformers would have resulted in a plant shutdown without operations being aware of the vulnerability or being able to take risk mitigating actions.

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

Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with Reactor Containment Fan Coolers Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.1] -Human 71152 Systems NCV 05000499/2018-02 Performance, Problem Closed Resources Identification and Resolution

Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI for the failure to promptly identify and correct a condition adverse to quality.

Specifically, the backdraft damper of the Unit 2, train B reactor containment fan cooler failed to close, as designed, due to a failed closing spring. The backdraft damper had undergone a preventative maintenance activity one month prior to the failure, but the closing spring degradation was not identified.

Description:

The reactor containment fan coolers (RCFC) are safety related containment cooling systems that are designed to remove heat from the containment building in normal and design basis accidents. Each containment building contains three trains of coolers and each train is comprised of two cooling fans. Each fan has a backdraft damper on the exhaust side of the fan. This damper is designed to automatically close to prevent cooled air from flowing through the secured fan and reducing the cooling efficiency in containment. The backdraft damper is designed with a coiled ribbon spring to provide the initial momentum to close under the weight of the damper blades themselves.

On August 2, 2017, a preventative maintenance activity (work authorization number 526002)to lube and inspect the backdraft damper for the RCFC Fan 21B was completed with no discrepancies noted. On August 30, 2018, Unit 2 control room operators identified a discrepancy in the inlet temperature for RCFC Fan 21C reading approximately 20 degrees lower than all other similar temperature indicators. The shift manager declared the temperature indicator inoperable and removed it from the calculation to determined average containment temperature, a technical specification surveillance (Technical Specification 4.6.1.5). On September 5, 2018 Unit 2 operators wrote a condition report concerning RCFC Fan 21B backdraft damper remaining open based on an engineering evaluation of the inlet temperature for the RCFC Fan 21C. The Unit 2 shift manager declared RCFC Fan 21B operable but degraded based on a 2014 condition report engineering evaluation (CREE).

On September 8, 2017, the inspectors accompanied the mechanics into containment as they re-performed the lube and inspect preventative maintenance. A troubleshooting work order was not developed. During the inspection of RCFC Fan 21B and backdraft damper, the cause for the failure to close was determined to be a failed ribbon spring. After the maintenance technicians completed their inspection, the inspectors felt the spring and confirmed that the spring had lost all tension and was not capable of applying the required closing force on the backdraft damper. The inspectors communicated the observations to the control room and following notification by the mechanics who performed the maintenance, operations declared the RCFC Fan 21B inoperable due to the failed spring. The inspectors reviewed the preventative maintenance instructions and interviewed the mechanics that had performed the maintenance on August 2, 2017 and asked if they had noticed the backdraft damper in the open position or if the spring was identified as degraded. The mechanics did not note any abnormalities. The inspectors focused on the instructions, and based on the inspectors field observations, questioned the adequacy of the instructions provided for the preventative maintenance. The preventative maintenance did not mention inspecting or testing the spring to look for degradation, did not specifically prescribe observing the shutdown of the fan to observe that the backdraft damper would close, and did not prescribe a post maintenance test to ensure that the maintenance did not affect the function of the backdraft damper to close.

Corrective Actions: The failed spring was discovered on September 8, 2017, and was replaced on September 13, 2017. The licensee modified the preventative maintenance instructions to include inspection of the closing spring, and performed a series of lesson learned discussions with the maintenance, engineering and operations departments.

Corrective Action References: Condition Reports 18-4708, 17-20917, 17-20798, 17-20764, 17-21176

Performance Assessment:

Performance Deficiency: The failure to promptly identify a condition adverse to quality associated with degraded backdraft closing springs was a performance deficiency.

Specifically, the preventative maintenance activity performed on the RCFC 21B fan backdraft damper failed to identify a degraded closing spring on the damper that did not ensure that the damper would perform its safety function to close when the fan was secured to ensure that the air coolers were cooling containment in a design basis accident.

Screening: The performance deficiency was determined to be more than minor because it is associated with the Mitigating System cornerstone attribute of equipment performance and adversely affect the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events, and therefore a finding.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, Exhibit 3 Barrier Integrity, the finding was determined to be very low safety significance, Green. Specifically, the finding was not a deficiency that represented an open pathway from containment and did not affect the function of the hydrogen recombiners.

Cross-cutting Aspect: The inspectors determined that the finding had a cross-cutting aspect in the area of human performance associated with resources. Licensee personnel failed to ensure that procedures were available and adequate to support nuclear safety. Specifically, the instructions for the preventative maintenance work activity performed on August 2, 2017, lacked sufficient guidance to ensure the identification of the failed ribbon spring that caused the failure of the RCFC backdraft damper on September 8, 2017 [H.1].

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviation, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, on August 2, 2017, while performing a preventative maintenance activity of the backdraft damper, the licensee failed to promptly identify and correct a condition adverse to quality associated with a degraded coiled ribbon spring used to ensure the closure of the reactor containment fan cooler 21B backdraft damper.

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

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On January 24, 2018, a senior reactor inspector presented the final inspection results to Mr. G. Powell, Interim President and Chief Executive Officer/Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented.

On March 30, 2018, the health physicist inspectors presented the radiation safety inspection results to Mr. G. Powell, Interim President and Chief Executive Officer/Chief Nuclear Officer, and other members of the licensee staff.

On May 7, 2018, the inspectors presented the final inspection results to Mr. G. Powell, Interim President and Chief Executive Officer/Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Condition Reports (CRs)18-725 17-727 17-729

Procedures

Number Title Revision

0POP01-ZO-0004 Extreme Cold Weather Guidelines 37

0PSP03-EA-0002 ESF Power Availability 38

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

0POP02-AF-0001 Auxiliary Feedwater 48

0POP02-SI-0002 Safety Injection System Initial Lineup 45

Section 1R05: Fire Protection

Procedures

Number Title Revision

0TGB90-FP-0702 Fire Preplan for Turbine Generator Building 4.16KV and 3

Electrical Equipment Rooms

0EAB01-FP-0032 Fire Preplan Electrical Auxiliary Building Relay Cabinet 4

Area of Control Room

0EAB04-FP-0054 Fire Preplan Electrical Auxiliary Building Motor Generator 3

Room

0FHB35-FP-0306 Fire Preplan Fuel Handling Building Train B SI/CSS 3

Cubicle

0FHB35-FP-0305 Fire Preplan Fuel Handling Building Train C SI/CS Cubicle 3

0FHB35-FP-0307 Fire Preplan Fuel Handing Building Train A SI/CS Cubicle 2

ZFG-0001 Fire Watch Program Guidelines 14

0PGP03-ZF-0001 Fire Protection Program 31

Condition Reports

16-7089 16-7344 16-7305 16-9077 18-0948

Section 1R06: Flood Protection Measures

Calculations

Number Title Revision

CC08044 Flood Load Analysis Fuel Handling Building 1

MC05365 Fuel Handling Building Flooding Calculation 11

NC09708 Facility Response Analysis Fuel Handling Building Flooding/Spray 3

Effects

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Condition Reports

18-1595 18-1005 18-1010

Section 1R12: Maintenance Effectiveness

Condition Reports (CRs)

18-1804 17-21794 18-806 18-866 16-2663

17-21792 17-21789 14-6080 16-9833 17-22021

17-21798 17-20762 17-22942 17-23630 17-1512

Procedures

Number Title Revision

SEG-0009 Maintenance Rule Basis Document Guideline 4

WAN 574409 TSC Diesel Generator Jacket Water Leak 0

WAN 537846 TSC Diesel Generator Lube Generator Outboard Bearing 9

WAN 574402 TSC DG Troubleshoot Failed to Secure After Cooldown 0

WAN 493636 IA Compressor 11 Inspect Motor Bearings 0

WAN 580365 Replace Compressor Airend Unit 0

Miscellaneous

Title Date

Performance Criteria, Goals, and Monitoring List March 21, 2018

Kaeser Compressors Service Order 72032474

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Condition Reports (CRs)

17-20311 18-2773

Procedures

Number Title Revision

0PSP06-DJ-0007B Train B - 125 Volt Class 1E Battery Modified Performance 1

Surveillance Test

0PGP02-ZA-003 Comprehensive Risk Management Program 14

0PSP03-SI-0024 Safety Injection System Valve Operability Test 25

0POP11-DJ-0002 Online Class 1E 125V DC Battery and Inverter Removal 13

from Service and Restoration

0PSP06-DJ-0007A Train A - 125 Volt Class 1E Battery Modified Performance 1

Surveillance Test

RasCal Calculation Sequence Number

3115 3086 3114 3074 3100

RICTCal Calculation Sequence Number

3105

Work Authorization Number (WAN)

2804 519663

Work Activity Risk (WAR) Plan of Action

2457

Work Order No.

96011552

Miscellaneous

Number Title Revision

CRM0590 Class 1E 120 VAC System 2

Section 1R15: Operability Determinations and Functionality Assessments

Condition Reports (CRs)

18-3094 18-2395

Procedures

Number Title Revision

0PSP03-SI-0024 Safety Injection System 1B(2B) Valve Operability Test 25

Procedures

Number Title Revision

0PSP03-SP-008B SSPS Train B Quarterly Slave Relay Test 28

Work Authorization Number (WAN)

96011552 583742 584964

Miscellaneous

Title Date

Operation and Installation Manual, Multipoint Level Sensors, August 1984

Model 8-66MA

Section 1R19: Post-Maintenance Testing

Condition Reports (CRs)

17-24786 17-21431 18-2295 18-1170 18-1005

18-0995 18-1905 18-1327 18-2036

Procedures

Number Title Revision

0PSP02-RC-0417 RCS Flow ACOT 11

0POP02-AF-0001 Auxiliary Feedwater 48

0PSP03-AF-0007 Auxiliary Feedwater Pump 14(24) Inservice Test 50

0POP02-DB-0003 Balance of Plant Diesel Generator 33

0POP07-DB-0003 BOP Diesel Generator Performance Test 20

0PSP03-HE-0001 Control Room Emergency Ventilation System 16

Work Authorization Number (WAN)

580365 559188 448682 583634 581430

579810 540499 581240 540033 536591

28272 583052 566033

Section 1R20: Refueling Outage

Procedures

Number Title Revision

0PGP03-ZR-0051 Radiological Access Controls/Standards 40

0POP03-ZG-0006 Plant Shutdown From 100% to Hot Standby 68

Procedures

Number Title Revision

0POP03-ZG-0007 Plant Cooldown 83

Miscellaneous

Title Date

2RE19 Shutdown Risk Assessment Report March 8, 2018

Section 1R22: Surveillance Testing

Condition Reports (CRs)

17-21040

Procedures

Number Title Revision

0PSP11-CS-0008 Containment Spray System Train 2C Containment System 23

Leakage Test

0PSP11-MS-0001 Main Steam Safety Valve Inservice Test 23

0PSP03-FC-0003 Spent Fuel Pool Cooling Pump 1B(2B) Inservice Test 19

2PSP03-ZG-0007B Train B Remote Shutdown System Operability Test 5

0PSP03-SI-003 Low Head Safety Injection Pump 1C(2C) Inservice Test 17

0PSP02-NI-0041 Power Range Neutron Flux Channel I ACPT (N-0041) 20

Inspection Procedure 71124.01: Radiological Hazard Assessment and Exposure Controls

Condition Reports (CRs)

17-13843 17-13942 17-14100 17-14172 17-14267

17-14945 17-15006 17-16057 17-17174 17-17816

17-17957 17-19506 17-21806 17-24212 17-24235

18-00483 18-01607

Procedures

Number Title Revision

0PGP03-ZR-0048 Personnel Dosimetry Program 20

0PGP03-ZR-0050 Radiation Protection Program 14

0PGP03-ZR-0051 Radiological Access Controls/Standards 40

0PGP03-ZR-0053 Radioactive Material Control Program 20

Procedures

Number Title Revision

0PRP01-ZA-0010 Radiation Protection Task Schedule 16

0PRP03-ZR-0004 Inventory and Leak Testing of Radioactive Sources 9

0PRP03-ZR-0012 Processing, Tracking, and Loading of Spent Radioactive 8

Filters

0PRP04-ZR-0004 Release of Materials From Radiologically Controlled Areas 28

0PRP04-ZR-0013 Radiological Survey Program 38

0PRP04-ZR-0015 Radiological Postings, Warning Devices and High 35

Radiation Area Access Controls

0PRP04-ZR-0016 Radiological Air Sampling and Analysis 30

0PRP05-RA-0007 Grab Sample Collection on the (PIG) Continuous 16

Atmospheric Monitors

0PRP05-ZR-0010 Health Physics Instrumentation Program 26

0PRP05-ZR-0030 Portable Air Monitoring Instruments (AMS-4) 22

0PRP07-ZR-0034 Radiological Risk Management 4

0PRP08-ZR-0001 Personnel Decontamination 20

0PRP08-ZR-0015 Tool and Equipment Decontamination 14

Audits and Self-Assessment

Number Title Date

0PGP03-ZX-0003 Snapshot Self-Assessment Report - 71124.01/.02 March 12, 2018

Pre-Inspection

Radiation Work

Permits Number Title Revision

2018-2-0100 2RE19 - Replace Reactor Coolant Pump 2B Seal 0

Package (HRA)

2018-2-0108 2RE19 - Repair/Replace Lights in the Spent Fuel Pool, 0

Reactor Cavity, and Transfer Canals

2018-2-0116 2RE19 - Maintenance and Support Work - Room 001 0

(LHRA)

2018-2-0118 2RE19 - Disconnect/Re-Connect Seal Table (LHRA) 0

2018-2-0119 2RE19 - Retract/Re-Insert Thimble Tubes (LHRA) 0

2018-2-0122 2RE19 - Install/Remove RCS Loop Drain Spool (HRA) 0

Radiation Work

Permits Number Title Revision

2018-2-0139 2RE19 - Maintenance on C2PSFV4451B 0

Radiation Surveys Title Date

Number

97172 +68 Detailed Walkway March 24, 2018

97191 +52 Detailed Walkway March 25, 2018

97192 +37 Detailed Walkway March 25, 2018

97196 +19 Detailed Walkway March 25, 2018

97193 -002 Detailed Walkway March 25, 2018

97197 -011 Detailed Walkway March 25, 2018

246 Inside Secondary Shield Wall March 26, 2018

246 Above Room 003 March 26, 2018

89698 +19 Detailed Walkway October 28, 2016

97356 Inside Secondary Shield Wall March 28,2018

259 RCP Platforms March 26, 2018

97400 Inside Secondary Shield Wall March 29, 2018

97384 +68 Detailed Walkway March 29, 2018

97368 Equipment Hatch March 28, 2018

97339 +68 RCB North of Cavity March 28, 2018

97185 S/G Platform March 25, 2018

97185 S/G Sludge Lance at Elev+38 March 25, 2018

21381 2-RCB-68 March 26, 2018

Miscellaneous Documents Title Date

Sealed Source Leak Test January 29, 2018

Sealed Source Leak Test July 13, 2017

Miscellaneous Documents Title Date

Spent Fuel Pool Inventory - Non-Fuel Items July 3, 2107

NSTS Annual Inventory Reconciliation Report January 6, 2011

Radioactive Source Surveillance July 19, 2017

Radioactive Source Surveillance March 8, 2018

Inspection Procedure 71124.02 Occupational ALARA Planning and Controls

Condition Reports (CRs)

17-22623 17-23768 17-24348 17-24405

18-1634 17-1136 17-14629

Procedures

Number Title Revision

OPGP03-ZR-0050 Radiation Protection Program 06

OPGP03-ZR-0052 ALARA Program 17

0PRP07-ZR-0004 Shielding 20

0PRP07-ZR-0007 Radiation Shield Verification and Trending Surveys 06

0PGP03-ZR-0048 Personnel Dosimetry Program 18

0PRP07-ZR-0033 Radiological Briefings 07

0PRP07-ZR-0034 Radiological Risk Management 04

0PRP07-ZR-0010 Radiation Work Permits Radiological Work ALARA 37

Reviews

0PRP03-ZR-0014 Onsite Staging Facility Operations 10

0PRP07-ZR-0013 Filter Replacement (Filters Stored in Room 218J) 07

0PRP07-ZR-0014 Filter Replacement (Alternate Locations) 09

0PRP07-ZR-0026 Transfer of Filters from Cubicles in MAB Room 333 03

To MAB 218J to Radwaste Truck Bay

Audits and Self-Assessment

Number Title Date

0PGP03-ZX-0003 Snapshot Self-Assessment Report - 71124.01 and March 12, 2018

71124.02

WANs. ALARA Planning, and TEDE ALARA Evaluations 2RE19

Number Title

18-276-7 Reactor Head Disassembly/Reassembly

18-276-5 Withdraw/insert BMI Thimbles Room 003

18-276-9 Replace NI Power Range Detectors

18-276-8 Steam Generator Inspections

Radiation Work Permits/ALARA Reviews

Number Title Revision

RWP 2017-2-0196 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2017-1-0159 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2018-0111 2RE19 Reactor Head Vessel Upper Internal Movement 0

RWP 2018-0118 2RE19 - Disconnect/Re-Connect Seal Table (LHRA) 0

RWP 2018-0119 2RE19 Retract/Re-Insert Thimble Tubes 0

RWP 2017-2-0196 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2017-1-0159 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

Miscellaneous Documents Title Date

2017 Long-Term Dose Report September 25, 2017

2018 U-2 Shielding March 2018

2018 Crud Burst Data March 2018

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number Title Revision

PI-0002 NRC & INPO Performance Indicator: Initiating Events 6

Cornerstone (by Unit) and Barrier Integrity Cornerstone

(by Unit) Guidelines

Section 4OA1: Performance Indicator Verification

Condition Reports (CRs)

13-3103 15-23019 17-539 17-15685

Procedures

Number Title Revision

0PGP05-ZN-0007 Preparation and Submittal of NRC Performance Indicators 8

SEG-0007 Mitigating System Performance Indicator Collection, 10

Processing and Maintenance of Data

Section 4OA2: Problem Identification and Resolution

Condition Reports (CRs)

17-20177 17-14594 17-18609 17-17537 17-17607

17-17610 17-17613 17-16109 17-16636 17-12616

17-17659 16-6491 17-17075 17-15589 17-17876

17-13662 17-14786 17-14510 17-14919 17-18220

17-17857 17-22934 17-21176 17-20463 17-20617

14-1102 17-21012 17-20764 17-20798 17-20955

17-20917 17-23022

Procedures

Number Title Revision

0POP04-CD-0001 Loss of Condensate Flow 23

Drawings

Number Title Revision

9-E-PDAA-01#1 Single Line Diagram 4.16KV Switchgear 10

5-V-14-9-V-0084 HVAC Reactor Containment Building 9

5V149V00016#2 HVAC Reactor Containment Building Fan Coolers 10

13304-1 Constant Spring Assembly B

13304 Modified DAA-P-7900 Backdraft Damper N

Work Authorization Number (WAN)

28270 528271 573745 573744 573741

573742 573743 573740 573746 573747

Initial Request for Information

Integrated Inspection Report 2018-001

South Texas Project

Inspection Report: 05000498/2018001; 05000499/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: Baseline Inspection Procedures

Lead Inspector: Alfred Sanchez, Senior Resident Inspector

• Information Due Date: January 11, 2018

• System of Interest: High Head, Low Head Safety Injection (SI), and Containment

Spray (CS)

The following information should be provided in electronic format (Certrec IMS preferred), to the

attention of Alfred Sanchez by January 11, 2018. The specific items selected from the lists shall

be available and ready for review on the day indicated in this request. *Please provide

requested documentation electronically in pdf files, Excel, or other searchable formats, if

possible. The information should contain descriptive names, and be indexed and hyperlinked to

facilitate ease of use. Information in lists should contain enough information to be easily

understood by someone who has knowledge of pressurized water reactor technology. If

requested documents are large and/or only hard copy formats are available, please inform me

and provide subject documentation.

1. A list of High Head/ Low Head Safety Injection (SI) and Containment Spray (CS)

system licensee contacts with phone numbers.

2. Any pre-existing evaluation or list of SI/CS system components and associated

calculations with low design margins.

3. A list of SI/CS system related operating experience evaluations for the last 3 years.

4. A list of all SI/CS system time-critical operator actions in procedures.

5. Copies of the initial operator licensed operators training materials.

6. List of drawings for the system (P&ID)-number and title

7. SI/CS maintenance work windows schedules (all trains) and summary of the work to

be performed in those windows.

8. List and schedule of surveillance tests scheduled for the quarter

9. Complete copies of normal operating, abnormal operating, emergency operating,

surveillance, and alarm response procedures associated with the SI/CS system

10. A list of permanent and temporary modifications related to the SI/CS system sorted

by component for the last 3 years

11. A list of current SI/CS system related operator work arounds/burdens.

2. A list of the SI/CS system design calculations, which provide the design margin

information for components.

13. Flooding calculations for the SI/CS area (Fuel Handling Building)

14. List of SI/CS system root cause evaluations associated with component failures

or design issues initiated/completed in the last 5 years.

15. A list of any SI/CS system common-cause failures of components in the last 3 years.

16. A list of condition reports (with descriptions) for the last 2 years

17. An electronic copy of the SI/CS system Design Bases Documents and any open,

pending, or recently completed changes. Please include any open, pending, or recently

completed changes to emergency operating, abnormal operating, normal operating,

alarm response, system alignment, surveillance, or other procedure.

18. An electronic copy of the System Health Report for the SI/CS system.

19. A copy of SI/CS system related audits completed in the last 3 years.

20. A list of SI/CS system motor operated valves (MOVs) in the program, design

margin, and risk ranking.

21. A list of SI/CS system air operated valves (AOVs) in the valve program, design

margin, and risk ranking.

2. SI/CS system structure, system, and components maintenance rule category,

scoping, functional failure evaluations, (a)(1) determinations, (a)(1) goals, and any

supporting basis documentation.

23. SI/CS system unavailability and unreliability raw data, and CDE sheets for the last 18

months

24. A list of high risk SI/CS system maintenance rule systems/components and functions,

based on engineering or expert panel judgement.

25. Copies of surveillance packages (last four performances) for all three trains of SI/CS

systems on both Units.

26. An Excel spreadsheet of SI/CS system related probabilistic risk assessment (PRA)

human action basic events or risk ranking of operator actions from your site specific

PSA sorted by risk achievement worth (RAW) and Fussell-Vesely (FV). Provide

copies of your human reliability worksheets for these items.

27. In so far as there are recent or pending changes, please provide an Excel

spreadsheet of SI/CS system related equipment basic events (with definitions),

including importance measures sorted by RAW and FV from your internal events

PRA. Include basic events with RAW value of 1.3 or greater.

The following items are requested for the

Occupational Radiation Safety Inspection

South Texas Project

March 26 - March 30, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before March 16, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

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

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis

C. Carson II at (817) 200-1221,

Louis.Carson@nrc.gov or Shawn Money at (817) 200-1466, Shawn.Money@nrc.gov.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: March 31, 2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since date of last inspection, related to this

inspection area

D. Procedure indexes for the radiation protection procedures

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and sub-tiered systems) since

date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

If not covered above, a summary of corrective action documents since date of last

inspection involving unmonitored releases, unplanned releases, or releases in which any

dose limit or administrative dose limit was exceeded (for Public Radiation Safety

Performance Indicator verification in accordance with IP 71151)

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

ML18131A014

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: NHT/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/B RI:DRP/B C:DRS/EB2 C:DRS/PSB2 C:DRS/OB C:DRS/EB1

NAME ASanchez NHernandez JDrake HGepford VGaddy TFarnholtz

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/8/18 5/9/18 5/8/18 5/4/18 5/7/18 5/4/18

OFFICE C:DRS/IPAT SPE:DRP/B TL:ACES BC:DRP/B

NAME GGeorge DProulx MVasquez NTaylor

SIGNATURE /RA/ /RA/ /RA-JKramer /RA/

for/

DATE 5/4/2018 5/8/18 5/4/18 5/14/18

May 14, 2018

EA-17-135

Mr. G. T. Powell

Interim President, Chief Executive Officer

and Chief Nuclear Officer

STP Nuclear Operating Company

P. O. Box 289

Wadsworth, TX 77483

SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC

INTEGRATED INSPECTION REPORT 05000498/2018001 AND

05000499/2018001

Dear Mr. Powell:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your South Texas Project Electric Generating Station, Units 1 and 2, facility. On May 7, 2018,

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.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Both of these findings involved violations of NRC requirements. Further, inspectors

documented licensee-identified violations which were determined to be of very low safety

significance in this report. The NRC is treating these violations as non-cited violations (NCVs)

consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, you should provide a response within

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 the South Texas Project Electric Generating Station.

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 the South Texas Project Electric Generating Station.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Nicholas

H. Taylor, Chief

Project Branch B

Division of Reactor Projects

Docket Nos. 50-498 and 50-499

License Nos. NPF-76 and NPF-80

Enclosure:

Inspection Report 05000498/2018001

and 05000499/2018001

w/Attachment

1: Supplemental Information

2: Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000498, 05000499

License Numbers NPF-76, NPF-80

Report Numbers: 05000498/2018001; 05000499/2018001

Licensee: STP Nuclear Operating Company

Facility: South Texas Project Electric Generating Station, Units 1 and 2

Location: Wadsworth, TX 77483

Inspection Dates: January 1, 2018 to March 31, 2018

Inspectors:

A. Sanchez, Senior Resident Inspector

N. Hernandez, Resident Inspector

D. Proulx, Senior Project Engineer

S. Graves, Senior Reactor Inspector

L. Carson II, Senior Health Physicist

P. Hernandez, Health Physicist

Approved By: Nicholas H. Taylor

Chief, Project Branch B

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting a quarterly integrated inspection at South Texas Projects 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. NRC and

self-revealed findings, violations, and additional items are summarized in the table below.

Licensee-identified non-cited violations are documented in report section 71111.05.

List of Findings and Violations

Failure to Perform a Maintenance Risk Assessment Prior to Conducting Maintenance

Cornerstone Significance Cross-cutting Report

Aspect Section

Initiating Events Green [H.1] -Human 71111.13

NCV 05000498/2018-01 Performance, Maintenance

Closed Resources Risk

Assessments

and

Emergent

Work Control

Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4) for the failure to

perform a maintenance risk assessment prior to performing maintenance that could have

resulted in a reactor shutdown. Specifically, maintenance performed to install bird netting on

the Unit 1 deaerator structure above the balance of plant 13.8 kV transformers was not

evaluated or identified as being a threat to stable power operations.

Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with

Reactor Containment Fan Coolers

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.1] -Human 71152

Systems NCV 050004992018-02 Performance, Problem

Closed Resources Identification

and

Resolution

Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI for the failure to promptly identify and correct a condition adverse to quality.

Specifically, the backdraft damper of the Unit 2, train B reactor containment fan cooler failed

to close, as designed, due to a failed closing spring. The backdraft damper had undergone a

preventative maintenance activity one month prior to the failure, but the closing spring

degradation was not identified.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power. On March 12, 2018, the unit entered

coast down operations for refueling outage 2RE19, which began on March 24, 2018. The unit

remained in a refueling outage for the remainder of the 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/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

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the

onset of seasonal warm weather and the increased likelihood of tornados on February 21,

2018.

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for

(1) Extreme cold weather and ice on January 16, 2018

71111.04 - Equipment Alignment

Partial Walkdown (6 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Unit 1, train B steam generator power operated relief valve while train C was out of

service for planned maintenance on January 18, 2018

(2) Unit 2, train C 125 Vdc battery while train B battery was out of service for planned

maintenance on January 19, 2018

(3) Unit 2, train B auxiliary feedwater while train C was out of service for planned

maintenance on January 22, 2018

(4) Unit 1, train B control room envelope Heating, Ventilation, and Air Conditioning while

train C was out of service for planned maintenance on February 13, 2018

(5) Unit 1, train A diesel generator while train C emergency diesel generator was out of

service for planned maintenance on February 28, 2018

(6) Unit 2, train C low head safety injection while train A was out of service for planned

maintenance on March 6, 2018

71111.05AQ - Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Turbine generator building 4.16kV and electrical equipment rooms, Unit 1, Fire Area: 90,

Fire Zone Z702 on January 2, 2018

(2) Electrical auxiliary building relay cabinet area of control room, Unit 1, Fire Area: 01, Fire

Zone Z032 on January 18, 2018

(3) Electrical auxiliary building motor generator room, Unit 2, Fire Area: 04, Fire Zone: Z054

on January 22, 2018

(4) Fuel handling building, emergency core cooling cubicle, train B, Unit 1, Fire Area: 35,

Fire Zone: Z306 on January 29, 2018

(5) Fuel handling building, emergency core cooling cubicle, train B, Unit 2, Fire Area: 35,

Fire Zone: Z306 on February 23, 2018

71111.06 - Flood Protection Measures

Internal Flooding (1 Sample)

The inspectors evaluated internal flooding mitigation protection:

(1) Emergency core cooling pump rooms Unit 1 and Unit 2 on January 30, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated simulator training exercises on February 22, 2018

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) Unit 1, Containment particulate radiation monitor, RT-8011, failed on February 7, 2018

(2) Unit 2, Reactor shutdown to Mode 3 for refueling outage on March 24, 2018

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Unit 1 technical support center diesel generator following failure of the output breaker to

close during a post maintenance test on March 29, 2018

(2) Unit 1 train A instrument air compressor following high vibrations and a failed post

maintenance test on March 30, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (6 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Unit 2, elevated risk due to train A 125 Vdc battery testing that required entry into the

configuration risk management program on January 10-11, 2018

(2) Unit 1, elevated risk due to train D auxiliary feedwater pump room HVAC supply fan that

failed during surveillance testing on January 23, 2018

(3) Unit 2, elevated risk due to train D 125 Vdc battery testing that required entry into the

configuration risk management program on January 31, 2018

(4) Unit 1, elevated risk due to train C emergency diesel generator and control room

envelope HVAC maintenance exceeding planned maintenance window, on February 14,

2018

(5) Unit 2, elevated risk due to qualified display processing system APC-B1 analog-to-digital

card replacement on February 14, 2018

(6) Unit 1, elevated risk due to low head safety injection sump isolation valve failing to open

from the control room on March 8, 2018

71111.15 - Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Unit 2 balance of plant (BOP) diesel generator and the G5 480Vac bus functionality

assessment following a blown fuse during the BOP diesel automatic alignment

(2) Unit 1, train B emergency core cooling system operability assessment following failure of

a control room hand switch for the containment sump to safety injection suction header

isolation valve

(3) Unit 1, secondary containment sump level transmitter historical operability assessment

following failure to indicate sump level

(4) Unit 1, train A auxiliary feedwater pump room floor drains due to debris

71111.19 - Post Maintenance Testing (7 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1, instrument air compressor 11 after replacement of the air end unit and pneumatic

valve on January 22, 2018

(2) Unit 2, loop 3 reactor coolant system flow channel power supply card replacement on

January 26, 2018

(3) Unit 1, train D turbine-driven auxiliary feedwater pump following planned preventative

maintenance on January 26, 2018

(4) Unit 2, BOP diesel generator following planned preventative maintenance on

January 30, 2018

(5) Unit 1, train C control room envelope makeup damper following corrective maintenance

on February 15, 2018

(6) Unit 1, train C 125 Vdc battery room heater following corrective maintenance on

February 15, 2018

(7) Unit 2, train C control room makeup fan following corrective maintenance February 23,

2018

71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated refueling outage 2RE19 activities from March 24-31, 2018. The

inspectors competed inspection procedure Sections 03.01.a, 03.01.b, and 03.01.c.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (4 Samples)

(1) 0PSP11-CS-0008, Unit 2, containment spray system, train C, contaminated system

leakage test, on January 23, 2018

(2) 0PSP05-MS-0505T, Unit 2, turbine impulse chamber pressure (P-13) transmitter

calibration on January 29, 2018

(3) 0PSP02-NI-0041, Unit 2, NI-41 power range channel surveillance test on February 7,

2018

(4) 2PSP03-ZG-007B, Unit 2, train B remote shutdown system operability test on

February 14, 2018

In-service (4 Samples)

(1) 0PSP03-FC-0003, Unit 2, train B spent fuel pool cooling pump, inservice test on

January 24, 2018

(2) 0PSP03-SI-0003, Unit 1, train C low head safety injection pump inservice test on

February 15, 2018

(3) 0PSP11-MS-0001, Unit 2, train D main steam safety valve inservice test on March 20,

2018

(4) 0PSP03-SI-0039, Unit 2, train B, emergency core cooling system comprehensive pump

tests

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated the licensees emergency response drill involving a loss of

residual heat removal, small break loss-of-coolant accident, and general emergency on

March 1, 2018.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Implementation of ALARA and Radiological Work Controls (1 Sample)

The inspectors reviewed ALARA practices and radiological work controls by reviewing the

following activities:

(1) RWP 2017-2-0196 Transfer of filters from room 333 to room 218J to on-site storage

container (OSSC)

(2) RWP 2017-1-0159 Transfer of filters from room 333 to room 218J to OSSC

(3) RWP 2018-0111 2RE19 reactor head vessel upper internal movement

(4) RWP-2018-0118 2RE19 - Disconnect/re-connect seal table (LHRA)

(5) RWP 2018-0119 2RE19 Retract/re-insert thimble tubes

Radiation Worker Performance (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below.

(8 Samples)

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (Units 1 and 2, January -

December 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample ( Units 1 and 2,

January-December 2017)

(3) IE04: Unplanned Scrams with Complications Sample (Units 1 and 2, January-

December 2017)

(4) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation

Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent

Occurrences Sample (May 1-December 31, 2017)

(5) OR01: Occupational Exposure Control Effectiveness Sample (May 1-December 31,

2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) Review of continued water intrusion into the diesel generator rooms, which periodically

resulted in moisture accumulating on the control panels, specifically for Unit 2, train B

emergency diesel generator

(2) Failed reactor containment fan cooler, 21B, backdraft damper due to a failed closing

spring

INSPECTION RESULTS

Licensee Identified Non-Cited Violation, EA-17-135 71111.05AQ -

Fire Protection

Annual/Quarterly

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.

Violation: Title 10 CFR 50.48, Fire Protection, requires, in part, that licensees have a fire

protection plan that outlines the plans for fire protection, fire detection, suppression capability,

and limitation of damage.

STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.

E.

Fire Protection states, in part, that the licensee shall implement and maintain in effect all

provisions of the approved fire protection program as described in the Final Safety Analysis

Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1

Administrative Controls states, in part, that the operability/functional capability of the fire

protection systems required to protect safe shutdown capability is assured through the

implementation of an administrative program. This program includes compensatory actions

for systems out-of-service.

Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 4.7.2.14, requires,

in part, hourly fire watch personnel must pass through the areas covered by the fire watch

and then sign and enter the time on the fire watch log, using the bar code reader, at least

once every clock hour.

Contrary to the above, on May 25 and 26, 2016, the licensees fire watch personnel failed to

pass through the areas covered by the fire watch and then sign and enter the time on the fire

watch log, using the bar code reader, at least once every clock hour. Specifically, two fire

watch individuals documented conducting Unit 2 Fire Watch 10118 for Room 105 starting on

May 25, 2016, at 1928 and finishing on May 26, 2016, at 0504 when in fact the individuals did

not enter Room 105.

Significance/Severity Level: Although this violation is willful, it was brought to the NRCs

attention by the licensee, it involved isolated acts of low-level individuals, and it was

addressed by appropriate remedial action. Therefore, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Corrective Action References: Condition Reports 16-7305, 16-7089, 16-7344, and 16-9077

Licensee Identified Non-Cited Violation, EA-17-135 71111.05AQ -

Fire Protection

Annual/Quarterly

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.

Violation: Title 10 CFR 50.9, Completeness and accuracy of information, requires, in part,

that information required by the Commissions regulations, orders, or license conditions to be

maintained by the licensee shall be complete and accurate in all material respects.

STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.

E.

Fire Protection states, in part, that the licensee shall implement and maintain in effect all

provisions of the approved fire protection program as described in the Final Safety Analysis

Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1

Administrative Controls states, in part that the operability/functional capability of the fire

protection systems required to protect safe shutdown capability is assured through the

implementation of an administrative program. This program includes compensatory actions

for systems out-of-service.

Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 7.3 requires, in

part, that completed fire watch logs Form 4 or their equivalent shall be retained for 3 years.

Contrary to the above, the licensee failed to maintained information required by the

Commissions regulations, orders, or license conditions that was complete and accurate in all

material respects as evidenced by the following two examples:

1. On May 25, 2016, the written fire watch log, documented on Form 4, for Unit 2 Fire

Watch 10118, for Room 105, for the hours of 1928 and 2015, indicated that the hourly

fire watches were conducted by passing through the areas covered by the fire watch.

However, the fire watch never entered Room 105 for these 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The hourly fire

watch patrol data is material to the NRC in that it provides sufficient evidence of

compliance with regulatory requirements.

2. On May 25-26, 2016, the electronic fire watch scanned logs for Unit 2 Fire

Watch 10118, for Room 105 between the hours of 2105 on May 25, 2016, to 0504 on

May 26, 2016, show that the 9 hourly fire watches were conducted by passing through

the areas covered by the fire watch. However, a temporary scan point was placed at

the base of the ladder in Room 002 to scan for Room 105. The hourly fire watch

individuals never entered Room 105. The hourly fire watch patrol data is material to the

NRC in that it provides sufficient evidence of compliance with regulatory requirements.

Significance/Severity Level: Although this violation is willful, it was brought to the NRCs

attention by the licensee, it involved isolated acts of low-level individuals, and it was

addressed by appropriate remedial action. Therefore, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy.

Corrective Action Reference: Condition Report 18-0948

Failure to Perform a Maintenance Risk Assessment Prior to Conducting Maintenance

Cornerstone Significance Cross-cutting Report

Aspect Section

Initiating Events Green [H.1] -Human 71111.13

NCV 05000498/2018-01 Performance, Maintenance

Closed Resources Risk

Assessments

and

Emergent

Work Control

Introduction:

The inspectors identified Green, non-cited violation of 10 CFR 50.65(a)(4) for the failure to

perform a maintenance risk assessment prior to performing maintenance that could have

resulted in a reactor shutdown. Specifically, maintenance performed to install bird netting on

the Unit 1 deaerator structure above the balance of plant 13.8 kV transformers was not

evaluated or identified as being a threat to stable power operations.

Description:

On November 3, 2017, the inspectors observed work being performed on the deaerator

structure on the roof of the Unit 1 turbine building. The workers were in the process of

installing bird netting over the entire structure to help alleviate the bird feces problem on and

under that structure. The inspectors observed the use of a man basket machine lift (JLG) to

accomplish this work. At the time, the JLG was in operation over two 13.8kV to 4160V

transformers 1D1 and 1D2, known as the balance of plant transformers. The transformers

provide electrical power to buses that provide power to various loads including open loop

cooling pumps. Unit 1 has three open loop cooling pumps. The open loop cooling pumps

provide main cooling reservoir water to cool secondary plant loads, most importantly, turbine

generator hydrogen coolers. The inspectors inquired as to the risk assessment for the activity

over the transformers. After realizing that the control room operators were not aware of the

work, the shift manager went out to the work site and stopped the activity and initiated

Condition Report 17-22934. The corrective action for issue was to notify the control room

prior to beginning work above the transformers until the project was complete.

On November 7, 2017, the inspectors again observed work activities to install bird netting

over the Unit 1 balance of plant transformers. The inspectors asked the Unit 1 shift manager

about a risk assessment for the maintenance activity. Again, the control room operators were

not aware of the work activity. Contrary to the corrective action for the November 3 issue, the

facilities work group mistakenly called the security department instead of the control room to

communicate their work activities. The work activity was shut down by the Unit 1 shift

manager, who then initiated Condition Report 17-23022. Operations subsequently put

together a very specific plan, with diagrams, expectations, and specific contact information for

the facilities department to follow work the bird netting installation until completion of the

project. Facilities reviewed and accepted the plan and no other incidents were noted.

The inspectors reviewed the prompt investigation and the human performance checklist. The

prompt investigation named several flawed or missing tools, such as situational awareness

and questioning attitude. The prompt human performance checklist concluded lack of

communication between departments and the failure to recognize risk resulted in work being

performed without a risk assessment or operations knowledge.

Corrective Action: The main corrective action included a question in the facilities work order

process (when an individual fills out a work order request on line) to prompt consideration of

plant impact and plant status control and to approval through the work start authority when

identified.

Corrective Action References: Condition Reports 18-4707, 17-23022, 17-22934

Performance Assessment:

Performance Deficiency: The failure to assess and manage the increase in risk for planned

maintenance that could have affected stable plant operations was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding,

because it can be viewed as a precursor to a more significant event. Specifically, not

performing a risk assessment for maintenance activities to install bird netting on the deaerator

structure, which involved the use of a man basket (JLG) over the balance of plant (BOP)

transformers could have caused a loss of one or both BOP transformers and would have

resulted in a plant shutdown without operations being aware of the vulnerability or being able

to take risk mitigating actions. In this case the licensee would not have allowed the work

without extra precautions on the work platform to protect from foreign material falling off the

platform and into the transformers. Furthermore, operations would not have allowed the work

activity on November 7, 2017, because open loop pump 11 was out of service for

maintenance, which was a loss in redundancy, and would result in a reactor trip if one pump

were to have failed.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter 0609 Appendix K, Maintenance Risk Assessment and Risk Management

Significance Determination Process, to determine the significance. This process involved

working with the Senior Reactor Analyst (SRA) and your probabilistic risk assessment (PRA)

group to perform a risk assessment to determine the incremental core damage probability

(ICDP), or in this case, the risk deficit because a risk assessment was not initially performed.

The analyst determined that the ICDP was roughly equivalent to a turbine trip (7 x 10-7), which

at full reactor power, would also result in a reactor trip. The analyst noted that this value was

bounding because a turbine trip did not actually occur; the duration of the condition was not

taken into account; and the zero-maintenance core damage frequency was not deducted from

the risk deficit. The dominant core damage sequences for a plant transient involved

anticipated transient without scram combined with either: 1) a failure to relieve reactor coolant

system; 2) successful pressure control with failure of the main feedwater system and reactor

coolant system boration; or a consequential failure of offsite power. Because the bounding

ICDP was less than 1 x 10-6, in accordance with Appendix K, Flowchart 1, Assessment of

Risk Deficit, the finding was determined to be of very low safety significance, Green.

Cross-cutting Aspect: The inspectors determined that the finding had a cross-cutting aspect

in the area of human performance associated with resources.

Licensee personnel

failed to

ensure that procedures were available and adequate to support nuclear safety. Specifically,

the maintenance work activity performed on November 3 and November 7, 2017 was not

recognized as affecting plant operations because the facilities work order process did not

prompt planners to consider plant impact [H.1].

Enforcement:

Violation: Title 10 CFR 50.65(a)(4) states, in part, that the licensee shall assess and manage

the increase in risk that may result from proposed maintenance activity.

Contrary to the above, on November 3 and 7, 2017, the licensee failed to assess and manage

the increase in risk that resulted from a maintenance activity. Specifically, the licensee failed

to assess and manage the risk of the maintenance activity to install bird netting on the

deaerator structure, which involved the use of a man basket (JLG) over the balance of plant

transformers. The loss of one or both BOP transformers would have resulted in a plant

shutdown without operations being aware of the vulnerability or being able to take risk

mitigating actions.

Disposition: This violation is being treated as non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with

Reactor Containment Fan Coolers

Cornerstone Significance Cross-cutting Report

Aspect Section

Mitigating Green [H.1] -Human 71152

Systems NCV 05000499/2018-02 Performance, Problem

Closed Resources Identification

and

Resolution

Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI for the failure to promptly identify and correct a condition adverse to quality.

Specifically, the backdraft damper of the Unit 2, train B reactor containment fan cooler failed

to close, as designed, due to a failed closing spring. The backdraft damper had undergone a

preventative maintenance activity one month prior to the failure, but the closing spring

degradation was not identified.

Description:

The reactor containment fan coolers (RCFC) are safety related containment cooling systems

that are designed to remove heat from the containment building in normal and design basis

accidents. Each containment building contains three trains of coolers and each train is

comprised of two cooling fans. Each fan has a backdraft damper on the exhaust side of the

fan. This damper is designed to automatically close to prevent cooled air from flowing

through the secured fan and reducing the cooling efficiency in containment. The backdraft

damper is designed with a coiled ribbon spring to provide the initial momentum to close under

the weight of the damper blades themselves.

On August 2, 2017, a preventative maintenance activity (work authorization number 526002)

to lube and inspect the backdraft damper for the RCFC Fan 21B was completed with no

discrepancies noted. On August 30, 2018, Unit 2 control room operators identified a

discrepancy in the inlet temperature for RCFC Fan 21C reading approximately 20 degrees

lower than all other similar temperature indicators. The shift manager declared the

temperature indicator inoperable and removed it from the calculation to determined average

containment temperature, a technical specification surveillance (Technical Specification 4.6.1.5). On September 5, 2018 Unit 2 operators wrote a condition report concerning RCFC

Fan 21B backdraft damper remaining open based on an engineering evaluation of the inlet

temperature for the RCFC Fan 21C. The Unit 2 shift manager declared RCFC Fan 21B

operable but degraded based on a 2014 condition report engineering evaluation (CREE).

On September 8, 2017, the inspectors accompanied the mechanics into containment as they

re-performed the lube and inspect preventative maintenance. A troubleshooting work order

was not developed. During the inspection of RCFC Fan 21B and backdraft damper, the

cause for the failure to close was determined to be a failed ribbon spring. After the

maintenance technicians completed their inspection, the inspectors felt the spring and

confirmed that the spring had lost all tension and was not capable of applying the required

closing force on the backdraft damper. The inspectors communicated the observations to the

control room and following notification by the mechanics who performed the maintenance,

operations declared the RCFC Fan 21B inoperable due to the failed spring. The inspectors

reviewed the preventative maintenance instructions and interviewed the mechanics that had

performed the maintenance on August 2, 2017 and asked if they had noticed the backdraft

damper in the open position or if the spring was identified as degraded. The mechanics did

not note any abnormalities. The inspectors focused on the instructions, and based on the

inspectors field observations, questioned the adequacy of the instructions provided for the

preventative maintenance. The preventative maintenance did not mention inspecting or

testing the spring to look for degradation, did not specifically prescribe observing the

shutdown of the fan to observe that the backdraft damper would close, and did not prescribe

a post maintenance test to ensure that the maintenance did not affect the function of the

backdraft damper to close.

Corrective Actions: The failed spring was discovered on September 8, 2017, and was

replaced on September 13, 2017. The licensee modified the preventative maintenance

instructions to include inspection of the closing spring, and performed a series of lesson

learned discussions with the maintenance, engineering and operations departments.

Corrective Action References: Condition Reports 18-4708, 17-20917, 17-20798, 17-20764,

17-21176

Performance Assessment:

Performance Deficiency: The failure to promptly identify a condition adverse to quality

associated with degraded backdraft closing springs was a performance deficiency.

Specifically, the preventative maintenance activity performed on the RCFC 21B fan backdraft

damper failed to identify a degraded closing spring on the damper that did not ensure that the

damper would perform its safety function to close when the fan was secured to ensure that

the air coolers were cooling containment in a design basis accident.

Screening: The performance deficiency was determined to be more than minor because it is

associated with the Mitigating System cornerstone attribute of equipment performance and

adversely affect the cornerstone objective to ensure availability, reliability, and capability of

systems that respond to initiating events, and therefore a finding.

Significance: The inspectors assessed the significance of the finding using Inspection

Manual Chapter 0609, Appendix A, Exhibit 3 Barrier Integrity, the finding was determined to

be very low safety significance, Green. Specifically, the finding was not a deficiency that

represented an open pathway from containment and did not affect the function of the

hydrogen recombiners.

Cross-cutting Aspect: The inspectors determined that the finding had a cross-cutting aspect

in the area of human performance associated with resources.

Licensee personnel

failed to

ensure that procedures were available and adequate to support nuclear safety. Specifically,

the instructions for the preventative maintenance work activity performed on August 2, 2017,

lacked sufficient guidance to ensure the identification of the failed ribbon spring that caused

the failure of the RCFC backdraft damper on September 8, 2017 [H.1].

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action states, in part,

that measures shall be established to assure that conditions adverse to quality, such as

failures, malfunctions, deficiencies, deviation, defective material and equipment, and

nonconformances are promptly identified and corrected.

Contrary to the above, on August 2, 2017, while performing a preventative maintenance

activity of the backdraft damper, the licensee failed to promptly identify and correct a

condition adverse to quality associated with a degraded coiled ribbon spring used to ensure

the closure of the reactor containment fan cooler 21B backdraft damper.

Disposition: This violation is being treated as non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public

disclosure.

On January 24, 2018, a senior reactor inspector presented the final inspection results to

Mr.

G. Powell, Interim President and Chief Executive Officer/Chief Nuclear Officer, and other

members of the licensee staff. The licensee acknowledged the issues presented.

On March 30, 2018, the health physicist inspectors presented the radiation safety inspection

results to Mr.

G. Powell, Interim President and Chief Executive Officer/Chief Nuclear Officer,

and other members of the licensee staff.

On May 7, 2018, the inspectors presented the final inspection results to Mr.

G. Powell, Interim

President and Chief Executive Officer/Chief Nuclear Officer, and other members of the licensee

staff.

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Condition Reports (CRs)18-725 17-727 17-729

Procedures

Number Title Revision

0POP01-ZO-0004 Extreme Cold Weather Guidelines 37

0PSP03-EA-0002 ESF Power Availability 38

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

0POP02-AF-0001 Auxiliary Feedwater 48

0POP02-SI-0002 Safety Injection System Initial Lineup 45

Section 1R05: Fire Protection

Procedures

Number Title Revision

0TGB90-FP-0702 Fire Preplan for Turbine Generator Building 4.16KV and 3

Electrical Equipment Rooms

0EAB01-FP-0032 Fire Preplan Electrical Auxiliary Building Relay Cabinet 4

Area of Control Room

0EAB04-FP-0054 Fire Preplan Electrical Auxiliary Building Motor Generator 3

Room

0FHB35-FP-0306 Fire Preplan Fuel Handling Building Train B SI/CSS 3

Cubicle

0FHB35-FP-0305 Fire Preplan Fuel Handling Building Train C SI/CS Cubicle 3

0FHB35-FP-0307 Fire Preplan Fuel Handing Building Train A SI/CS Cubicle 2

ZFG-0001 Fire Watch Program Guidelines 14

0PGP03-ZF-0001 Fire Protection Program 31

Condition Reports

16-7089 16-7344 16-7305 16-9077 18-0948

Section 1R06: Flood Protection Measures

Calculations

Number Title Revision

CC08044 Flood Load Analysis Fuel Handling Building 1

MC05365 Fuel Handling Building Flooding Calculation 11

NC09708 Facility Response Analysis Fuel Handling Building Flooding/Spray 3

Effects

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Condition Reports

18-1595 18-1005 18-1010

Section 1R12: Maintenance Effectiveness

Condition Reports (CRs)

18-1804 17-21794 18-806 18-866 16-2663

17-21792 17-21789 14-6080 16-9833 17-22021

17-21798 17-20762 17-22942 17-23630 17-1512

Procedures

Number Title Revision

SEG-0009 Maintenance Rule Basis Document Guideline 4

WAN 574409 TSC Diesel Generator Jacket Water Leak 0

WAN 537846 TSC Diesel Generator Lube Generator Outboard Bearing 9

WAN 574402 TSC DG Troubleshoot Failed to Secure After Cooldown 0

WAN 493636 IA Compressor 11 Inspect Motor Bearings 0

WAN 580365 Replace Compressor Airend Unit 0

Miscellaneous

Title Date

Performance Criteria, Goals, and Monitoring List March 21, 2018

Kaeser Compressors Service Order 72032474

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Condition Reports (CRs)

17-20311 18-2773

Procedures

Number Title Revision

0PSP06-DJ-0007B Train B - 125 Volt Class 1E Battery Modified Performance 1

Surveillance Test

0PGP02-ZA-003 Comprehensive Risk Management Program 14

0PSP03-SI-0024 Safety Injection System Valve Operability Test 25

0POP11-DJ-0002 Online Class 1E 125V DC Battery and Inverter Removal 13

from Service and Restoration

0PSP06-DJ-0007A Train A - 125 Volt Class 1E Battery Modified Performance 1

Surveillance Test

RasCal Calculation Sequence Number

3115 3086 3114 3074 3100

RICTCal Calculation Sequence Number

3105

Work Authorization Number (WAN)

2804 519663

Work Activity Risk (WAR) Plan of Action

2457

Work Order No.

96011552

Miscellaneous

Number Title Revision

CRM0590 Class 1E 120 VAC System 2

Section 1R15: Operability Determinations and Functionality Assessments

Condition Reports (CRs)

18-3094 18-2395

Procedures

Number Title Revision

0PSP03-SI-0024 Safety Injection System 1B(2B) Valve Operability Test 25

Procedures

Number Title Revision

0PSP03-SP-008B SSPS Train B Quarterly Slave Relay Test 28

Work Authorization Number (WAN)

96011552 583742 584964

Miscellaneous

Title Date

Operation and Installation Manual, Multipoint Level Sensors, August 1984

Model 8-66MA

Section 1R19: Post-Maintenance Testing

Condition Reports (CRs)

17-24786 17-21431 18-2295 18-1170 18-1005

18-0995 18-1905 18-1327 18-2036

Procedures

Number Title Revision

0PSP02-RC-0417 RCS Flow ACOT 11

0POP02-AF-0001 Auxiliary Feedwater 48

0PSP03-AF-0007 Auxiliary Feedwater Pump 14(24) Inservice Test 50

0POP02-DB-0003 Balance of Plant Diesel Generator 33

0POP07-DB-0003 BOP Diesel Generator Performance Test 20

0PSP03-HE-0001 Control Room Emergency Ventilation System 16

Work Authorization Number (WAN)

580365 559188 448682 583634 581430

579810 540499 581240 540033 536591

28272 583052 566033

Section 1R20: Refueling Outage

Procedures

Number Title Revision

0PGP03-ZR-0051 Radiological Access Controls/Standards 40

0POP03-ZG-0006 Plant Shutdown From 100% to Hot Standby 68

Procedures

Number Title Revision

0POP03-ZG-0007 Plant Cooldown 83

Miscellaneous

Title Date

2RE19 Shutdown Risk Assessment Report March 8, 2018

Section 1R22: Surveillance Testing

Condition Reports (CRs)

17-21040

Procedures

Number Title Revision

0PSP11-CS-0008 Containment Spray System Train 2C Containment System 23

Leakage Test

0PSP11-MS-0001 Main Steam Safety Valve Inservice Test 23

0PSP03-FC-0003 Spent Fuel Pool Cooling Pump 1B(2B) Inservice Test 19

2PSP03-ZG-0007B Train B Remote Shutdown System Operability Test 5

0PSP03-SI-003 Low Head Safety Injection Pump 1C(2C) Inservice Test 17

0PSP02-NI-0041 Power Range Neutron Flux Channel I ACPT (N-0041) 20

Inspection Procedure 71124.01: Radiological Hazard Assessment and Exposure Controls

Condition Reports (CRs)

17-13843 17-13942 17-14100 17-14172 17-14267

17-14945 17-15006 17-16057 17-17174 17-17816

17-17957 17-19506 17-21806 17-24212 17-24235

18-00483 18-01607

Procedures

Number Title Revision

0PGP03-ZR-0048 Personnel Dosimetry Program 20

0PGP03-ZR-0050 Radiation Protection Program 14

0PGP03-ZR-0051 Radiological Access Controls/Standards 40

0PGP03-ZR-0053 Radioactive Material Control Program 20

Procedures

Number Title Revision

0PRP01-ZA-0010 Radiation Protection Task Schedule 16

0PRP03-ZR-0004 Inventory and Leak Testing of Radioactive Sources 9

0PRP03-ZR-0012 Processing, Tracking, and Loading of Spent Radioactive 8

Filters

0PRP04-ZR-0004 Release of Materials From Radiologically Controlled Areas 28

0PRP04-ZR-0013 Radiological Survey Program 38

0PRP04-ZR-0015 Radiological Postings, Warning Devices and High 35

Radiation Area Access Controls

0PRP04-ZR-0016 Radiological Air Sampling and Analysis 30

0PRP05-RA-0007 Grab Sample Collection on the (PIG) Continuous 16

Atmospheric Monitors

0PRP05-ZR-0010 Health Physics Instrumentation Program 26

0PRP05-ZR-0030 Portable Air Monitoring Instruments (AMS-4) 22

0PRP07-ZR-0034 Radiological Risk Management 4

0PRP08-ZR-0001 Personnel Decontamination 20

0PRP08-ZR-0015 Tool and Equipment Decontamination 14

Audits and Self-Assessment

Number Title Date

0PGP03-ZX-0003 Snapshot Self-Assessment Report - 71124.01/.02 March 12, 2018

Pre-Inspection

Radiation Work

Permits Number Title Revision

2018-2-0100 2RE19 - Replace Reactor Coolant Pump 2B Seal 0

Package (HRA)

2018-2-0108 2RE19 - Repair/Replace Lights in the Spent Fuel Pool, 0

Reactor Cavity, and Transfer Canals

2018-2-0116 2RE19 - Maintenance and Support Work - Room 001 0

(LHRA)

2018-2-0118 2RE19 - Disconnect/Re-Connect Seal Table (LHRA) 0

2018-2-0119 2RE19 - Retract/Re-Insert Thimble Tubes (LHRA) 0

2018-2-0122 2RE19 - Install/Remove RCS Loop Drain Spool (HRA) 0

Radiation Work

Permits Number Title Revision

2018-2-0139 2RE19 - Maintenance on C2PSFV4451B 0

Radiation Surveys Title Date

Number

97172 +68 Detailed Walkway March 24, 2018

97191 +52 Detailed Walkway March 25, 2018

97192 +37 Detailed Walkway March 25, 2018

97196 +19 Detailed Walkway March 25, 2018

97193 -002 Detailed Walkway March 25, 2018

97197 -011 Detailed Walkway March 25, 2018

246 Inside Secondary Shield Wall March 26, 2018

246 Above Room 003 March 26, 2018

89698 +19 Detailed Walkway October 28, 2016

97356 Inside Secondary Shield Wall March 28,2018

259 RCP Platforms March 26, 2018

97400 Inside Secondary Shield Wall March 29, 2018

97384 +68 Detailed Walkway March 29, 2018

97368 Equipment Hatch March 28, 2018

97339 +68 RCB North of Cavity March 28, 2018

97185 S/G Platform March 25, 2018

97185 S/G Sludge Lance at Elev+38 March 25, 2018

21381 2-RCB-68 March 26, 2018

Miscellaneous Documents Title Date

Sealed Source Leak Test January 29, 2018

Sealed Source Leak Test July 13, 2017

Miscellaneous Documents Title Date

Spent Fuel Pool Inventory - Non-Fuel Items July 3, 2107

NSTS Annual Inventory Reconciliation Report January 6, 2011

Radioactive Source Surveillance July 19, 2017

Radioactive Source Surveillance March 8, 2018

Inspection Procedure 71124.02 Occupational ALARA Planning and Controls

Condition Reports (CRs)

17-22623 17-23768 17-24348 17-24405

18-1634 17-1136 17-14629

Procedures

Number Title Revision

OPGP03-ZR-0050 Radiation Protection Program 06

OPGP03-ZR-0052 ALARA Program 17

0PRP07-ZR-0004 Shielding 20

0PRP07-ZR-0007 Radiation Shield Verification and Trending Surveys 06

0PGP03-ZR-0048 Personnel Dosimetry Program 18

0PRP07-ZR-0033 Radiological Briefings 07

0PRP07-ZR-0034 Radiological Risk Management 04

0PRP07-ZR-0010 Radiation Work Permits Radiological Work ALARA 37

Reviews

0PRP03-ZR-0014 Onsite Staging Facility Operations 10

0PRP07-ZR-0013 Filter Replacement (Filters Stored in Room 218J) 07

0PRP07-ZR-0014 Filter Replacement (Alternate Locations) 09

0PRP07-ZR-0026 Transfer of Filters from Cubicles in MAB Room 333 03

To MAB 218J to Radwaste Truck Bay

Audits and Self-Assessment

Number Title Date

0PGP03-ZX-0003 Snapshot Self-Assessment Report - 71124.01 and March 12, 2018

71124.02

WANs. ALARA Planning, and TEDE ALARA Evaluations 2RE19

Number Title

18-276-7 Reactor Head Disassembly/Reassembly

18-276-5 Withdraw/insert BMI Thimbles Room 003

18-276-9 Replace NI Power Range Detectors

18-276-8 Steam Generator Inspections

Radiation Work Permits/ALARA Reviews

Number Title Revision

RWP 2017-2-0196 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2017-1-0159 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2018-0111 2RE19 Reactor Head Vessel Upper Internal Movement 0

RWP 2018-0118 2RE19 - Disconnect/Re-Connect Seal Table (LHRA) 0

RWP 2018-0119 2RE19 Retract/Re-Insert Thimble Tubes 0

RWP 2017-2-0196 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

RWP 2017-1-0159 Transfer of Filters from Rm 333 to Rm 218J to OSSC 0

Miscellaneous Documents Title Date

2017 Long-Term Dose Report September 25, 2017

2018 U-2 Shielding March 2018

2018 Crud Burst Data March 2018

Inspection Procedure 71151: Performance Indicator Verification

Procedures

Number Title Revision

PI-0002 NRC & INPO Performance Indicator: Initiating Events 6

Cornerstone (by Unit) and Barrier Integrity Cornerstone

(by Unit) Guidelines

Section 4OA1: Performance Indicator Verification

Condition Reports (CRs)

13-3103 15-23019 17-539 17-15685

Procedures

Number Title Revision

0PGP05-ZN-0007 Preparation and Submittal of NRC Performance Indicators 8

SEG-0007 Mitigating System Performance Indicator Collection, 10

Processing and Maintenance of Data

Section 4OA2: Problem Identification and Resolution

Condition Reports (CRs)

17-20177 17-14594 17-18609 17-17537 17-17607

17-17610 17-17613 17-16109 17-16636 17-12616

17-17659 16-6491 17-17075 17-15589 17-17876

17-13662 17-14786 17-14510 17-14919 17-18220

17-17857 17-22934 17-21176 17-20463 17-20617

14-1102 17-21012 17-20764 17-20798 17-20955

17-20917 17-23022

Procedures

Number Title Revision

0POP04-CD-0001 Loss of Condensate Flow 23

Drawings

Number Title Revision

9-E-PDAA-01#1 Single Line Diagram 4.16KV Switchgear 10

5-V-14-9-V-0084 HVAC Reactor Containment Building 9

5V149V00016#2 HVAC Reactor Containment Building Fan Coolers 10

13304-1 Constant Spring Assembly B

13304 Modified DAA-P-7900 Backdraft Damper N

Work Authorization Number (WAN)

28270 528271 573745 573744 573741

573742 573743 573740 573746 573747

Initial Request for Information

Integrated Inspection Report 2018-001

South Texas Project

Inspection Report: 05000498/2018001; 05000499/2018001

Inspection Dates: January 1 - March 31, 2018

Inspection Procedure: Baseline Inspection Procedures

Lead Inspector: Alfred Sanchez, Senior Resident Inspector

• Information Due Date: January 11, 2018

• System of Interest: High Head, Low Head Safety Injection (SI), and Containment

Spray (CS)

The following information should be provided in electronic format (Certrec IMS preferred), to the

attention of Alfred Sanchez by January 11, 2018. The specific items selected from the lists shall

be available and ready for review on the day indicated in this request. *Please provide

requested documentation electronically in pdf files, Excel, or other searchable formats, if

possible. The information should contain descriptive names, and be indexed and hyperlinked to

facilitate ease of use. Information in lists should contain enough information to be easily

understood by someone who has knowledge of pressurized water reactor technology. If

requested documents are large and/or only hard copy formats are available, please inform me

and provide subject documentation.

1. A list of High Head/ Low Head Safety Injection (SI) and Containment Spray (CS)

system licensee contacts with phone numbers.

2. Any pre-existing evaluation or list of SI/CS system components and associated

calculations with low design margins.

3. A list of SI/CS system related operating experience evaluations for the last 3 years.

4. A list of all SI/CS system time-critical operator actions in procedures.

5. Copies of the initial operator licensed operators training materials.

6. List of drawings for the system (P&ID)-number and title

7. SI/CS maintenance work windows schedules (all trains) and summary of the work to

be performed in those windows.

8. List and schedule of surveillance tests scheduled for the quarter

9. Complete copies of normal operating, abnormal operating, emergency operating,

surveillance, and alarm response procedures associated with the SI/CS system

10. A list of permanent and temporary modifications related to the SI/CS system sorted

by component for the last 3 years

11. A list of current SI/CS system related operator work arounds/burdens.

2. A list of the SI/CS system design calculations, which provide the design margin

information for components.

13. Flooding calculations for the SI/CS area (Fuel Handling Building)

14. List of SI/CS system root cause evaluations associated with component failures

or design issues initiated/completed in the last 5 years.

15. A list of any SI/CS system common-cause failures of components in the last 3 years.

16. A list of condition reports (with descriptions) for the last 2 years

17. An electronic copy of the SI/CS system Design Bases Documents and any open,

pending, or recently completed changes. Please include any open, pending, or recently

completed changes to emergency operating, abnormal operating, normal operating,

alarm response, system alignment, surveillance, or other procedure.

18. An electronic copy of the System Health Report for the SI/CS system.

19. A copy of SI/CS system related audits completed in the last 3 years.

20. A list of SI/CS system motor operated valves (MOVs) in the program, design

margin, and risk ranking.

21. A list of SI/CS system air operated valves (AOVs) in the valve program, design

margin, and risk ranking.

2. SI/CS system structure, system, and components maintenance rule category,

scoping, functional failure evaluations, (a)(1) determinations, (a)(1) goals, and any

supporting basis documentation.

23. SI/CS system unavailability and unreliability raw data, and CDE sheets for the last 18

months

24. A list of high risk SI/CS system maintenance rule systems/components and functions,

based on engineering or expert panel judgement.

25. Copies of surveillance packages (last four performances) for all three trains of SI/CS

systems on both Units.

26. An Excel spreadsheet of SI/CS system related probabilistic risk assessment (PRA)

human action basic events or risk ranking of operator actions from your site specific

PSA sorted by risk achievement worth (RAW) and Fussell-Vesely (FV). Provide

copies of your human reliability worksheets for these items.

27. In so far as there are recent or pending changes, please provide an Excel

spreadsheet of SI/CS system related equipment basic events (with definitions),

including importance measures sorted by RAW and FV from your internal events

PRA. Include basic events with RAW value of 1.3 or greater.

The following items are requested for the

Occupational Radiation Safety Inspection

South Texas Project

March 26 - March 30, 2018

Integrated Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before March 16, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

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

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis

C. Carson II at (817) 200-1221,

Louis.Carson@nrc.gov or Shawn Money at (817) 200-1466, Shawn.Money@nrc.gov.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: March 31, 2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since date of last inspection, related to this

inspection area

D. Procedure indexes for the radiation protection procedures

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program Description

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Declared Pregnant Worker Program

F. List of corrective action documents (including corporate and sub-tiered systems) since

date of last inspection

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

If not covered above, a summary of corrective action documents since date of last

inspection involving unmonitored releases, unplanned releases, or releases in which any

dose limit or administrative dose limit was exceeded (for Public Radiation Safety

Performance Indicator verification in accordance with IP 71151)

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

ML18131A014

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: NHT/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/B RI:DRP/B C:DRS/EB2 C:DRS/PSB2 C:DRS/OB C:DRS/EB1

NAME ASanchez NHernandez JDrake HGepford VGaddy TFarnholtz

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/8/18 5/9/18 5/8/18 5/4/18 5/7/18 5/4/18

OFFICE C:DRS/IPAT SPE:DRP/B TL:ACES BC:DRP/B

NAME GGeorge DProulx MVasquez NTaylor

SIGNATURE /RA/ /RA/ /RA-JKramer /RA/

for/

DATE 5/4/2018 5/8/18 5/4/18 5/14/18