IR 05000498/2020010
| ML20349A331 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/14/2020 |
| From: | Ami Agrawal Division of Nuclear Materials Safety IV |
| To: | Gerry Powell South Texas |
| References | |
| IR 2020010 | |
| Download: ML20349A331 (12) | |
Text
December 14, 2020
SUBJECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000498/2020010 AND 05000499/2020010
Dear Mr. Powell:
On November 5, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your South Texas Project, Units 1 and 2 and discussed the results of this inspection with yourself and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety
Docket Nos. 05000498 and 05000499 License Nos. NPF-76 and NPF-80
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000498 and 05000499
License Numbers:
Report Numbers:
05000498/2020010 and 05000499/2020010
Enterprise Identifier: I-2020-010-0001
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project, Units 1 and 2
Location:
Wadsworth, TX
Inspection Dates:
October 21, 2020 to November 5, 2020
Inspectors:
R. Azua, Senior Reactor Inspector
A. Sanchez, Senior Project Engineer
J. Braisted, Reactor Inspector
L. Flores, Reactor Inspector
R. Grover, Observer
Approved By:
Ami N. Agrawal, Team Leader
Inspection Programs & Assessment Team
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at South Texas Project, 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
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 reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled approximately 170 condition reports as well as their associated Root Cause and Apparent Cause Evaluations. The team also conducted a 5-year review of the plant's essential cooling water systems and associated chillers.
- Operating Experience, Self-Assessments, and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety.
Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the South Texas Project developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance.
- As part of this inspection, the team selected the plant's essential cooling water systems and associated chillers for a focused review within the corrective action program. For these systems, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system. As a result of the off-site nature of this inspection, due to COVID-19 restrictions at the time of the inspection, the team was not able to walk down portions of these systems. However, the team did not identify any concerns with this system.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of operating experience including Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including Institute of Nuclear Power Operations (INPO) and Electric Power Research Institute (EPRI). The team determined that the South Texas Project, is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process. In the area of trend analysis, the team did identify that the licensee had not taken full advantage of established processes to perform trend analyses in each department twice a year. The licensee indicated that they presently perform a computer-generated analysis using an algorithm to identify trends plant-wide, and that they are looking into performing future departmental trends using the same process.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed ten individuals. The purpose of these interviews was:
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method;
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems; and
- (3) to evaluate the licensee's safety-conscious work environment (SCWE). The focus group participants were from the Security organization. Due to the challenges brought on by the COVID-19 pandemic, and the South Texas Project's performance in this area prior to this inspection, the NRC chose to limit the number of personnel interviewed. Overall, the South Texas Project has an adequate Safety Conscious Work Environment.
Willingness to Raise Nuclear Safety Issues: In the assessed focus group, the team found no evidence of challenges to SCWE. Individuals in this group expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
Overall, the team concluded that the South Texas Project maintained a healthy SCWE.
Employee Concerns Program: The team looked at the South Texas Project's Employee Concerns Program (ECP). The team interviewed the ECP manager and discussed her cases. The team reviewed the ECPs investigative packages. Overall, the team did not identify any concerns with the program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 5, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr G. Powell, President and CEO, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Condition Reports
(CRs)
04-9487, 06-8526, 07-8567, 10-1209, 10-21452, 12-23776,
15-25511, 16-3594, 16-3641, 16-5305, 16-11257, 16-11346,17-691, 17-17659, 17-22801, 18-1488, 18-2396, 18-3296,
18-3967, 18-4094, 18-4480, 18-5434, 18-6597, 18-6871, 18-
7183, 18-7184, 18-7185, 18-7186, 18-7193, 18-7195, 18-
209, 18-7842, 18-8061, 18-8454, 18-8858, 18-9456, 18-
9599, 18-9846, 18-10113, 18-10118, 18-10183, 18-10326,
18-11154, 18-11155, 18-12152, 18-13551, 18-13635, 18-
13638, 18-13993, 18-14266, 18-14369, 18-14473, 18-14474,
18-14475, 18-14476, 18-14937, 18-15029,19-241, 19-799,19-876, 19-957, 19-1009, 19-1101, 19-1225, 19-1916, 19-
1954, 19-1966, 19-2023, 19-2357, 19-2526, 19-2725, 19-
2836, 19-3431, 19-3611, 19-4076, 19-4187, 19-4323, 19-
4367, 19-4368, 19-4472, 19-4561, 19-4623, 19-4745, 19-
5470, 19-5569, 19-5666, 19-5669, 19-5670, 19-5671, 19-
5674, 19-5680, 19-5689, 19-5693, 19-5694, 19-5842, 19-
6437, 19-6440, 19-7019, 19-7043, 19-7164, 19-7441, 19-
7486, 19-7535, 19-8088, 19-8257, 19-8507, 19-8510, 19-
9050, 19-9764, 19-9800, 19-10133, 19-10210, 19-10223, 19-
289, 19-10487, 19-10643, 19-11414, 19-11467, 19-12074,
19-12135, 19-12372, 19-12401,20-705, 20-849,20-917, 20-
935, 20-1017, 20-1205, 20-1361, 20-1381, 20-1474, 20-
1490, 20-1507, 20-1589, 20-1643, 20-1828, 20-1939, 20-
2174, 20-2861, 20-3665, 20-3814, 20-3815, 20-3933, 20-
4910, 20-5103, 20-5149, 20-5798, 20-6283, 20-6310, 20-
6765, 20-6797, 20-7052, 20-7429, 20-7524, 20-7563, 20-
7564, 20-7714, 20-8188, 20-8590, 20-9405, 20-9748, 20-
9762, 20-10932, 20-11113, 20-11265
Miscellaneous
Quality Periodic Report
2/04/2019
Quality Periodic Report
07/24/2019
Quality Periodic Report
01/29/2020
Quality Periodic Report
08/17/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Unit 1 Operator Burden Working Report
11/04/2020
Unit 2 Operator Burden Working Report
11/4/2020
2019 Maintenance Observations
20 Maintenance Observations
Executive Oversight Board Report of Site Visit
2/13/2020
STP Executive Oversight Board Report
11/2018
STP Executive Oversight Board Report
03/2019
STP Executive Oversight Board Report
2/2020
Executive Oversight Board Report of Site Visit
09/19/2019
18-0-107397
Audit of CAP for Plant Operations
19-0-107556
Audit of CAP for Plant Operations
20-0-108142
Audit of CAP for Plant Operations
2019-06
CAP Health Program
06/2019
2019-12
CAP Health Program
2/2019
20-04
CAP Health Program
04/2020
20-08
CAP Health Program
08/2020
PRA-19-009
Risk Assessment to Provide Risk Information to Support
LER 2-19-001 as Required by Procedure 0PGP03-ZX-0002B
Procedures
0001
Human Performance (HU) Program
Integrated Performance Improvement Program
0PGP03-ZA-0090 Work Process Program
0002
Preventive Maintenance Program
0055
Protected Components
ECO1A
Equipment Clearance Order Instructions
0PGP03-ZX-0002 Condition Report Process
0002A
CAQ Resolution Process
0002B
Station Cause Analysis Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0PGP03-ZX-0003 Station Self-Assessment Program
0PGP03-ZX-0003 Station Self-Assessment Program
0PGP03-ZX-0008 Condition Not Adverse to Quality (CNAQ) Resolution
Process
0PGP03-ZX-0016 Trending Process Procedure
0PGP04-ZA-0002 Condition Report Engineering Evaluation
0POP01-ZA-0049 Condition Report Operations Evaluation Program
0011
Operability, Functionality, and Reportability Guidance
0014
Operability, Functionality & Reportability Guidance
0PQP02-ZA-0003 Quality Surveillance and Performance Monitoring
0PSP10-RC-0002 Core Exit Thermocouple or Resistance Temperature
Detector Cross Calibration
10, 25, 26
0PSP11-XC-0004 LLRT Penetration: M-91 Auxiliary Airlock Door Seals
CAP-002
Causal Analysis Guideine
CAP-003
Condition Report Screening
COM-0001
Conduct of Maintenance
Conduct of
Operations
Chapter 1
Operations Organization and Responsibilities
Conduct of
Operations
Chapter 11
Operations Departmental Business Practices
Conduct of
Operations
Chapter 2
Shift Operating Practices
Conduct of
Operations
Chapter 3
Communications
Conduct of
Operations
Chapter 7
Performance Monitoring and Self Assessment
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SLG-CPI1
Management Performance Improvement Committee
Activities
WCG-0002
Work Management Scheduling
WCG-0002
Work Management Scheduling
WCG-0003
Planner's Guide
Self-Assessments 19-05
Maintenance/Work Control Quality Audit
06/10/2019
19-10
Accredited Training Audit
CR 18-3296
Maintenance and Technical Training Programs
CR 19-7019
Mid-Cycle Self-Assessment Report
07/2019
CR 19-7164
Maintenance and Technical Training Training Programs
08/26/2019
CR 19-8088
Maintenance Fundamentals and Technical Skills
08/19/2019