IR 05000335/2021003
| ML21307A037 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/03/2021 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2021003 | |
| Download: ML21307A037 (27) | |
Text
November 3, 2021
SUBJECT:
ST LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2021003 AND 05000389/2021003
Dear Mr. Coffey:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St Lucie Units 1 & 2. On October 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. Dan DeBoer, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St Lucie Units 1 & 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket Nos. 05000335 and 05000389 License Nos. DPR-67 and NPF-16
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000335 and 05000389
License Numbers:
Report Numbers:
05000335/2021003 and 05000389/2021003
Enterprise Identifier: I-2021-003-0006
Licensee:
Florida Power & Light Company
Facility:
St Lucie Units 1 & 2
Location:
Jenson Beach, FL 34957
Inspection Dates:
July 01, 2021 to September 30, 2021
Inspectors:
A. Butcavage, Reactor Inspector
J. Diaz-Velez, Senior Health Physicist
J. Griffis, Senior Health Physicist
D. Orr, Senior Resident Inspector
W. Pursley, Health Physicist
J. Rivera, Health Physicist
S. Roberts, Resident Inspector
Approved By:
David E. Dumbacher, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at St Lucie Units 1 & 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
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000389/2021003-01 Open None (NPP)71111.19 An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.
Unit 2 operated at or near RTP until the unit was shutdown for planned refueling outage, SL2-26, on August 28, 2021. Unit 2 was restarted on September 29, 2021, and was in the process of power ascension, achieving 93 percent RTP, when the inspection period ended on September 30,
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), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted.
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP
===71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 auxiliary feedwater system (AFW) and 1A emergency diesel generator (EDG)while the 1B EDG was out of service (OOS) for planned maintenance on July 15, 2021
- (2) Unit 1 containment spray (CS) B train while A train was OOS for planned maintenance on August 4, 2021
- (3) Unit 2 CS A train while the 2B CS pump was OOS for surveillance testing and the 2B CS pump after surveillance testing completed on August 25, 2021
- (4) Unit 2 spent fuel pool cooling system during refueling outage SL2-26 full core offload window on September 8, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2 control element assembly motor-generator area, reactor auxiliary building (RAB) on July 7, 2021
- (2) Unit 2 fuel handling building on July 21, 2021 (3)1B EDG building on August 3, 2021
- (4) Unit 2 RAB 43 foot elevation on August 10, 2021
- (5) Unit 2 reactor containment building on September 8, 2021
- (6) Unit 2 cable spread room on September 11, 2021
- (7) Unit 1 and Unit 2 external control zones on September 15, 2021
- (8) Unit 2 electrical penetration rooms on September 20, 2021
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
The inspectors verified that the reactor coolant system boundary, steam generator tubes, risk-significant piping system boundaries, and containment moisture barrier are appropriately monitored for degradation and that sample repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from August 30, 2021 to October 4, 2021.
- (1) 03.01.a - Nondestructive Examination (NDE) and Welding Activities.
- Ultrasonic Examination (UT), RC-147-1-SW-2 (MRP-146), ASME Class1, Elbow to Pipe Weld and Elbow Base Material
- WO 40787195, Safety Injection Piping, Valve 3259, ASME Class 1, Weld Package
- WO 40718077-05, Low Pressure Safety Injection (LPSI) Pump 2A, Valve 3104 to Pipe, ASME Class 2, Weld Package
- Containment Integrated Leak Rate Test Results Samples
- Containment Moisture Barrier, Annulus Side, NDE Reports: PSL2-21-VT-1000, PSL2-21-VT-1001, PSL2-21-VT-1002, PSL2-21-VT-1003, PSL2-21-VT-1004, PSL2-21-VT-1005
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
- SL2-26 Reactor Vessel Closure Head In-Service Inspection Bare Metal Visual Examination, in accordance with Code Case N-729, ASME Class 1, Report 180-9336089 and Photo Review
- Reactor head penetration #85 presented potential boric acid recordable indication. Accepted for continued service by additional evaluation (AR
===02403288) and verbal authorization of NRC Relief Request No.19
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
The inspectors evaluated the licensees boric acid corrosion control program performance, through photographs provided for the Reactor Vessel Head and other areas described in action requests, and sample action requests combined with review of the boric acid program corrective actions and evaluations of reported leakage as listed in the documents reviewed section.
- Review of the licensee containment boric acid walkdown inspection results and Action Request (AR) initiations.
- Review of engineering boric acid AR evaluations and dispositions associated with:
AR 02365843-01, Active borated water leak of 20 drops/minute, Unit 2 Line No.
CS-76 AR 02392964-01, Wet boric acid found on the 2A Low Pressure Safety Injection (LPSI) pump AR 02402992, - White Residue - 2B2 Cold Leg Nozzle to Main Spray (PCV-1100E)
AR 02403787-01, Noted Inactive Boric Acid Residue on the Reactor Vessel Bottom Head area Insulation
03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
- Major Scope: Bobbin Coil,100% Full Length, Active Tubes Each steam generator (SG) for wear, Array Probe, HL and CL expansion transitions in periphery (high flow) TTS region, for Loose Part Detection and Foreign Object Wear, +Point (TM) Probe, for all new dents and dings, PWSCC and ODSCC (not potential), Visual for all tube plugs. (Details contained in Document Reference AIM 210510993-2Q-1, Rev. 2)
- Observed remotely a sample of resolution analyst dispositions during the Resolution Process
- Review of secondary side AR 02403170, Feed Ring Support Inspection &
Repair
- Review of AIM 210711013-2Q-1, Screening Chart Basis for Condition Monitoring of St. Lucie Unit 2 Steam Generators for the September 2021 Inspection
- OE Review: AR No. 01730372, San Onofre Steam Generator Tube Leak
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during:
- Interim pressurization of the Unit 2 safety injection tanks (SIT) due to a slow pressure loss in the 2A2 SIT on July 27, 2021
- A planned power reduction and shutdown of Unit 2 to support refueling outage SL2-26 on August 27-28, 2021
- Unit 2 startup and power ascension activities following refueling outage SL2-26 on September 29, 2021
Licensed Operator Requalification Training/Examinations (IP Section 03.02)===
- (1) The inspectors observed and evaluated an operating crews response to a requalification training simulator scenario in the control room simulator on July 26, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
- (1) AR 2401971, 2021 maintenance rule (a)(3) evaluation on September 20, 2021
- (2) AR 2402451, 2A intake cooling water (ICW) pump did not start in required time on September 27, 2021
- (3) AR 2400485, entry into 2-AOP-18.01, Instrument Air Malfunction on September 30, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1 elevated risk with the 1B EDG OOS for planned maintenance on July 15, 2021, and Unit 2 elevated risk with the 2AA 125 VDC battery charger OOS for emergent repairs on July 15, 2021
- (2) Unit 2 elevated risk with the 2B CS, 2B high pressure safety injection (HPSI), and 2B low pressure safety injection (LPSI) pumps OOS to troubleshoot flow transmitter, FT-07-03, associated with the reactor cavity sump inlet flow monitoring system on July 27, 2021
- (4) Unit 1 and Unit 2 elevated risk for the 1B and 2B startup transformers OOS for planned maintenance and Unit 1 additional elevated risk for battery charger 1AB OOS for a load test on August 18, 2021
- (5) Unit 2 yellow shutdown safety assessment (SSA) with the reactor coolant system (RCS) depressurized and level lowered to support reactor head removal on September 1, 2021
- (6) Unit 2 yellow SSA with 2A EDG and A train electrical busses OOS for 4160 volt breaker replacement from September 6-10, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2398812, little to no seal packing gland leak-off flow for 1B ICW pump on August 22, 2021
- (2) AR 2401630, tritium identified internal to the Unit 1 CCW system on August 27, 2021
- (3) AR 2398173, through-wall leak on 1B ICW header on September 20, 2021
- (4) AR 2400714, pressurizer safety valve, PSV-V1202, failed as-found lift test on September 21, 2021
- (5) AR 2403182 and 2403284, debris identified on fuel assembly lower tie plates during Unit 2 end of fuel cycle 25 bottom nozzle inspections on September 21, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC 296363, installation of jumper across synchroscope check relay in 4160 volt switchgear
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) WO 40738733, 1B EDG critical maintenance management (CMM), 36 month preventive maintenance inspection on July 21, 2021
- (2) WO 40715198, 480V breaker replacement for 1A CS pump isolation valve, MV-07-3A, on August 5, 2021
- (3) WO 40785251, 2AA battery charger phase alarm, troubleshoot and repair on September 13, 2021
- (4) WO 40792135, 2A3 4160 volt switchgear undervoltage relay 27-1 repair on September 14, 2021
- (5) WOs 40687479, 40687481, 40682187, 40687483, 40682186, and 40687482, Unit 2 reactor trip switchgear TCB-1, 2, 3, 5, 6, and 7 respectively, perform breaker swap, and WO 40792125, Unit 2 reactor trip switchgear TCB-1 through 8 - inadequate surveillance on September 27, 2021
- (6) WO 40602138, replace 2A EDG digital reference unit and electronic governor control unit replacements on September 27, 2021
- (7) WO 40755282, 1A fire water pump repair on September 27, 2021
- (8) WO 40628431, Unit 2 safety linear power range detector number 5 for uncompensated ion chamber replacement and associated WO 40717791, install de-calibration factors for reactor protection system channel A on September 28, 2021
- (9) WO 40710305, Unit 2 startup range nuclear instrument channel number 2 has low counts on September 28, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 refueling outage SL2-26 activities from August 28, 2021 to September 30, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
(1)2-OSP-59.01A, 2A Emergency Diesel Generator Monthly Surveillance, fast start from the control room on July 6, 2021 (2)1-SMI-09.05C, 1C Auxiliary Feedwater Pump Flow Channel Check on July 20, 2021 (3)1-OSP-52.01B, Surveillance Test of Degraded Grid Voltage B Train on August 19, 2021 (4)0-SME-50.06, Safety Related 125 VDC System Monthly Maintenance, for the 1B battery on August 23, 2021 (5)2-SMM-08.08, Main Steam Safety Valve Setpoint Surveillance Using Furmanite Trevitest Mark VIII Equipment on September 21, 2021 (6)2-OSP-24.01, RAB Fluid Systems Periodic Leak Test, Attachment 8, 2A High Pressure Safety Injection System Leak Test on September 21, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) 2-OSP-68.01, Integrated Leak Test, on September 22, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) On October 14, 2021 the inspectors evaluated an emergency response drill that included a loss of coolant accident (LOCA), reactor trip, and safety injection. The scenario included situations that resulted in declarations of Unusual Event, Alert, Site Area Emergency, and General Emergency.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- RWP 21-3441, Eddy Current Testing
- RWP 21-3438, S/G Primary Side Support Work
- RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal
Electronic Alarming Dosimeter Alarms
Labeling of Containers
- Sealand Containers in Outdoor RCA
- Vacuum Cleaners and HEPA Units in the S/G Blowdown Building
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed licensee surveys of potentially contaminated material leaving the RCA during the Unit 2 refueling outage
- (2) Observed licensee activities at the Unit 2 Reactor Building equipment hatch during the unit 2 refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) RWP-21-3102 Surveys for unit 2 reactor head disassembly
- (2) RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal
- (3) RWP 21-3008, Unit 2 reactor head lift
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) LHRA Control Unit 1 Waste Ion Exchanger Room
- (2) LHRA Control Unit 1 Spent Fuel Pool Ion Exchanger Room
- (3) LHRA Control Unit 1 Volume Control Tank Room
- (4) VHRA Unit Reactor Containment Building
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements during the Unit 2 refueling outage.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensees radiological work planning for:
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)
The inspectors evaluated dose estimates and exposure tracking for:
- (1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1004) and the respective radiological outcome evaluation.
- (2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-1030) and the respective radiological outcome evaluation.
- (3) SL1-30 Incore Detectors Remove/Install, Cut Up and Dispose ALARA Package (RWP 21-1118) and the respective radiological outcome evaluation.
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (2 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and switch adjustment activities.
All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and performed the reactor head lift.
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during:
- (1) RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Control Room Emergency Ventilation System (HV-13) for Units 1 and 2
- (2) Reactor Auxiliary Building Ventilation System (HV-10) for Units 1 and 2
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) HEPA Unit 004 staged in Unit 1 Cavity to support Reactor Disassembly
- (2) HEPA Unit 058 supporting filter changeout in the Steam Generator Blowdown Building
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization. The evaluation included a review of the licensee's Site Alpha Characterization Update, dated August 24, 2020.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign external dose.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the internal dosimetry program implementation.
- (1) The inspectors reviewed the following:
Whole Body Counts
- Whole Body Count (WBC) data and exposure investigation information for Personal Contamination Event (PCE)21-005
- WBC data and exposure investigation information for facial contamination associated with CR 02347965
No internal dose assessments were available for review during the inspection that used in-vitro monitoring or air sampling and Derived Air Concentration (DAC)-hour monitoring.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
(1)
- Dose assessment and implementation of fetal monitoring for one declared pregnant worker.
- Multi-badging and calculation of Effective Dose Equivalent (EDEX) for workers who were monitored under RWP 2-2144 (Upender Bracket Replacement),
RWP 20-3008 (Reactor Head Set), and RWP 21-1008-2 (Reactor Head Set).
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (7 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Electronic dosimeters at HP control point.
- (2) Portable instrumentation in the instrumentation lab.
- (5) Portal Monitors (PMs) at the Protected Area (PA) exit point.
- (6) Area Radiation Monitors (ARMs) in the Unit 2 auxiliary building.
- (7) ARMs in the Unit 1 spent fuel pool.
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Unit 2 Containment High Range Monitor, RIM-26-41.
- (2) DMC 3000 electronic dosimeter no. 987428.
- (3) Ludlum 9-3 ion chamber, SN 336971.
- (4) Ludlum 12 count rate meter, SN 305073.
- (5) Ludlum 177 alarm rate meter, SN 19552.
- (6) Argos 5AB PCM, SN 1411-311.
- (7) SAM-12, SN 12052.
- (8) Eberline AMS-4 continuous air monitor, SN 12617.
- (9) Eberline AMS-4 continuous air monitor, SN 1615.
- (10) MGP AMP-100 area monitor, SN 5008-090.
- (11) MGP Telepole, SN 6605-039.
- (12) Ludlum 2241-4 neutron meter, SN 286222.
- (13) GEM-5 PM, SN 1307-176.
- (14) Whole Body Counter, Fastscan2.
- (15) Whole Body Counter, Fastscan3.
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 2 Plant Vent Stack Gaseous Effluent Monitor, RM-26-14.
- (2) Unit 1 Liquid Effluents Monitor, RE-6627.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1, Safety System Functional Failures from July 1, 2020 through June 30, 2021
- (2) Unit 2, Safety System Functional Failures from July 1, 2020 through June 30, 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) November 1, 2019 - October 31, 2021
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) November 1, 2019 - August 18, 2021
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 2400507, 1A EDG uncontrolled load swings during functional test
- (2) Several issues documented in the licensee's corrective action program related to equipment issues identified during refueling outage SL2-26 activities. The ARs are listed in the reference section of this inspection report.
INSPECTION RESULTS
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000389/2021003-01 Open
None (NPP)71111.19 An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional.
Description:
On July 29, 2021, the licensee completed post-maintenance testing for reactor trip switchgear TCBs 1, 2, 3, 5, 6, and 7. The post-maintenance testing included a functional test from the reactor turbine generator board (RTGB) in the Unit 2 control room that tripped the TCBs one channel at a time from the RTGB. The post-maintenance test was completed because the TCBs were replaced with spare breakers that had preventive maintenance performed in accordance with 0-SME-66.04, Inspection of the Reactor Trip Switchgear (RTSG) Breakers." The inspectors noted that 0-SME-66.04 verified independent operability of the undervoltage and shunt trips of the TCB in a test cubicle. The inspectors questioned if the RTSG cubicles included contacts, relays, or other circuit portions that would go untested if only using a test cubicle to verify the surveillance requirement to verify the independent operability of the undervoltage and shunt trips. The surveillance requirement to verify the independent operability of the undervoltage and shunt trip functionality is specified in Technical Specification Table 4.3-1, Reactor Protective Instrumentation Surveillance Requirements, Functional Unit 12, Reactor Trip Breakers, Note 6, and states: in accordance with the surveillance frequency control program and following maintenance or adjustment of the reactor trip breakers, the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips.
The licensee reviewed the inspectors' questions and determined that its surveillance procedures, 0-SME-66.04, and 2-OSP-63.01, RPS Logic Matrix Test, Attachment 2, RPS Trip Relay Contact Test, and Attachment 3, RTGB Manual Reactor Trip Pushbutton Contact Test, did not ensure the independent operability of the undervoltage and shunt trips. Specifically, there are portions of these circuits connected through circuit breaker and cradle disconnects to terminal points in the switchgear that are not tested independently.
The licensee entered this issue into the corrective action program as AR 2403473 on September 8, 2021. At the time of discovery, Unit 2 was shutdown for refueling outage PSL2-26 and the reactor was defueled. The licensee verified that this issue did apply to Unit 1 because 0-SME-66.04 is a common unit procedure. However, Unit 1 Technical Specifications do not include a similar surveillance requirement to verify the independent operability of the undervoltage and shunt trip functions. Nonetheless, unlike the Unit 2 RPS Trip Status Panel, the Unit 1 RPS Trip Status Panel includes lights that indicate the individual status of the undervoltage and shunt trip coils and the individual lights' status are verified during 1-OSP-63.01, RPS Logic Matrix Test. Going forward, the Unit 1 TCBs will be similarly tested by the licensee to verify the independent operability of the undervoltage and shunt trips because 0-SME-66.04 was revised and is a procedure implemented on both units.
The licensee completed an organization effectiveness investigation and determined that the inadequate surveillance testing of Unit 2 TCBs was caused by inappropriately removing TCB tests performed in a legacy RPS Logic Matrix surveillance procedure 2-1400059. The licensee credited those tests performed during maintenance activities without conforming the maintenance testing to technical specification surveillance requirements. This was a legacy issue associated with a procedure upgrade project that created 0-SME-66.04 in 2008. 0-SME-66.04, Revision 0, was issued on October 13, 2008.
Corrective Actions: The licensee revised 0-SME-66.04 and 2-OSP-63.01 and included procedure steps and verification that the Unit 2 TCBs' undervoltage and shunt trips operated independently. All Unit 2 RTSG TCBs were tested per the applicable new section in 0-SME-66.04 and 2-OSP-63.01 in WO 40792125 during PSL 2-26 prior to making the control element assembly drive system capable of withdrawal on September 26, 2021.
Corrective Action References: AR 2403473
Performance Assessment:
Performance Deficiency: The licensee's failure to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to ensure that procedures 0-SME-66.04 and 2-OSP-63.01 included steps to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Using the screening questions in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, section C, Reactor Protection System (RPS), the performance deficiency screened to very low safety significance (Green) because the finding only affected a single RPS trip signal to initiate a reactor trip AND the function of other redundant trips or diverse methods of reactor shutdown (e.g., other automatic RPS trips, alternate rod insertion, or manual reactor trip capacity) was not affected. The independent operability of the undervoltage and shunt trip functions were subsequently verified during subsequent surveillance testing on September 26, 2021.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, this was a legacy issue associated with a procedure upgrade project in 2008.
Enforcement:
Violation: Unit 2, TSSR 4.3.1, stated in part, that each reactor protective instrumentation channel shall be demonstrated operable by the performance of the channel functional test operations for the modes and at the frequencies shown in Table 4.3-1. Table 4.3-1, Functional Unit 12, Reactor Trip Breakers, Note 6, required the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips.
Contrary to the above, from about 2008 until August 28, 2021, when Unit 2 entered Mode 3 and the TCBs were opened to begin SL2-26, the licensee failed to include verification of the independent operability of the undervoltage and shunt trips.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 2, 2021, the inspectors presented the Occupational Radiation Safety inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
- On September 17, 2021, the inspectors presented the Inservice Inspection Activities inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
- On October 13, 2021, the inspectors presented the integrated inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.08P Corrective Action
Documents
Evaluation of Operating Experience on San Onofre Steam
Generator Tube Leak
/2 /12
Level 1 Core Business Assessment Report, Adverse trend in
through wall boric acid leaks
2/5/20
A Through Wall Leak was Identified on a U2 RWT LINE 3/4"
CS-76
8/18/20
Change Welds to Reduce Future Crack Initiation
08/26/20
2A SG MAXIMUM AFW FLOW WAS >150GPM WITH NR
LEVEL <28.2%
1/21/21
LPSI PP 2A Active Boric Acid Leakage at the Suction Flange
and Boric Acid Evaluation
6/12/21
V2857 Active Seat Leakage less than 1 DPM
6/22/21
AR 02402502-01
Evaluation of Excessive Boric Acid Residue Observed on the
Unit 2 V3862 Vent Valve, adjacent Pipe Support and
Downstream Quick Disconnect
Rev. 1
AR 02402605-01
Evaluation of Brown/discolored Boric Acid Residue
Observed on the Unit 2 V1219
Rev. 1
WHITE RESIDUE-2B2 COLD LEG NOZZLE TO MAIN
SPRAY (PCV-1100E
SL2-26 SG-2A Feedring Support Inspection Results
9/4/21
Observation from Visual Exam -RPV Upper Head
Penetration 85
9/6/21
SL2-26 Containment Liner Moisture Barrier Minor Damage
Repair
9/7/21
Possible Through Wall Leak in U2, 2B LPSI Header, I-10-SI-
9/7/21
Boric Acid Residue on the Reactor Vessel Bottom Head
Insulation
9/10/21
Review of MRP 2019-008, Management of Thermal Fatigue
in Non-Isolable Reactor Coolant System Branch Lines
6/24/20
AR-02402418-01
Evaluation of Accumulation of Boric Acid Residue in the
vicinity of the 2A2 Reactor Coolant Pump (RCP) and below
Rev. 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
in the Spider Trench
Inactive Boric Acid Residue on Reactor Vessel
9/10/21
CR-2021-2099
S/G A H/L Plug Protruding (Row 94 Column 105)
9/12/21
Corrective Action
Documents
Resulting from
Inspection
St. Lucie Unit 2 - EOC25 - S/G 2A and S/G 2B Plug List
Rev, 0
Engineering
Evaluations
51-9332977-000
St Lucie Unit 2 SL2-26 (EOC25) SG Eddy Current Inspection
Plan
Rev. 000
AIM 210510993-
Degradation Assessment for St. Lucie Unit 2 Steam
Generators for End-of-Cycle 25, September, 2021
Rev. 2
D02-PEEG-F-13-
200
St Lucie Unit 2 RSGs Risk Assessments
Rev 1
Miscellaneous
THERMAL FATIGUE PROGRAM (MRP-146 & MRP-192)
7/14/21
ID#: 1193
Curtiss Wright, Personnel Qualifications Certifications for
Ultrasonic Testing
7/28/21
Welder ID's
RXT01F6,
DXW0MCB
Welder Qualifications
3/31/21,
8/31/21
AIM 210711013-
Intertek AIM Letter Report, Screening Charts for Condition
Monitoring of St. Lucie Unit 2 Steam Generators for the
September 2021 Inspection
8/27/21
Curtiss Wright
Certification for ID
No. 458
Personnel Qualification for Penetrant Inspections
4/12/21
FPE-NDE-21-017
Eddy Current Personnel Certification and Qualification
Documentation Review, St.
Lucie Unit 2 (SL2-26) Steam Generator Examinations
9/1/21
Fram. Cert
No.63085,
Certificate of Calibration, Torque Transducer, 200 In-Lb
7/23/21
Fram. Cert No:
2950
Certificate of Calibration, Eddy Current Tester,MIZ-80
7/14/21
Fram. Cert No:
233
Certificate of Calibration, LAN SAP CONTROL BOX
7/29/21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Framatome ID
Code: M-6527
and W7014
Certificates of Visual Examination
6/24/21 and
1/2/21
Framatome ID
No. 6527 and
W7014
Certificate of Personnel Qualification
6/29/21 and
7/30/21
ID No M6527
Certificate of Personnel Qualification, VT-1,2 & 3, Level III,
with Bare Head Visual Endorsement
11/21/20
Relief Request
Number 19
Request for Alternative to ASME Code Case N-729-6 for
Replacement Reactor Vessel Closure Head Penetration
Nozzle 85
9/13/21
Report No.
1600579.401
MRP-146 and MRP-192 Thermal Fatigue Program Review
for St. Lucie Nuclear Plant (Review of MRP Interim
Guidance)
Rev. 0
SL-2 Tech Spec,
Administration
Section "L"
Steam Generator (SG) Program
Amendment
160
Training
Certification
BACC Program
Owner (DG)
Boric Acid Corrosion Control (BACC) Program Evaluator
2/27/17
NDE Reports
Doc. ID.180-
9336089-000
NDE Services Final Report, St Lucie 2 - SL2R26 Reactor
Vessel Closure Head In-Service Inspection Bare Metal
Visual Examination
9/23/21
01.
Liquid Penetrant Examination Report for Weld No. 02000,
Comp ID V3259, SI Piping
9/10/21
Rpt. No. PSL2-
PT-21-003,
Summary No.
SL2-209900
Component ID: 1-2742-3, Pad to Vessel Weld, Shut Down
Cooling Hx."2A"
0/13/21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Rpt. No. PSL2-
UT-21-010,
Summary No.
SL2-075220
Ultrasonic Examination of Elbow to Pipe and Elbow Base
Material, Component ID, RC-147-1-SW-2 (MRP-146)
9/13/21
SL2-20035
WO 407180177-05, NIS-2A, Repair Replacement
Certification Form
9/27/21
05, Weld No.
00005
Weld Penetrant Test Results
9/14/21
ASME Pressure Test Results (VT-2 Leakage Exam), Valve
3104 Welds
9/27/21
V3259, ASME Section XI Repair/Replacement Checklist
9/14/21
Procedures
03-9219485
St. Lucie (PSL) Unit 2 Eddy Current Data Analysis
Guidelines
Rev. 4
2-OSP-68.01
10/4/21
51-9332993-000
Site Validation of Eddy Current Examination Techniques for
St. Lucie Unit 2, SL2-26
9/1/21
54-ISI-400-024
Multi-Frequency Eddy Current Examination of Tubing
2/7/20
STEAM GENERATOR SECONDARY SIDE INTEGRITY
PLAN
Rev. 16
Thermal Fatigue Program (MRP-146 & MRP-192)
14 21
Nuclear Fleet Administrative Procedure, Boric Acid
Corrosion Control Program
Rev, 5
ER-AP-116-1000-
10000
Boric Acid Corrosion Control Program Implementation
Rev. 000
NDE 3.3
Liquid Penetrant Examination, Solvent Removable, Visible
Dye Technique
Rev. 15
NDE 4.15
Visual Examination (VE), ASME Section XI Code Case N-
2-1, N-729-6, N-770-5 and Bare Metal Visual
4/14/21
NSE 5.32
Ultrasonic Examination Technique Austenitic Piping Welds
for Thermal Fatigue Cracking/Crazing (MRP-146 & MRP-
2)
4/17/2021
Work Orders
U2 CS-79 Rework Welds Upstream of V07196
xx/yy/zz
RCB Annulus:SL226 INSP/RPR 40717685 04 Moisture Seal
9/21/21
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
U2 RCB Safety Related Protective Coatings
9/21/ 21
U2 LPSI PP 2A, Replace Pump Inlet Gasket and Inspect
Hardware
9/1/21
U2 CS-76, Repair Leak Flange Upstream of V07199 (NDE)
8/19/20
U2: LPSI PP 2A - Remove/ Clean DBA/ Oil Residue
3/30/20
U2, V3104 Check valve Replacement
9/27/21
WO-40718309 01
U2 LPSI PP 2A, Inspect Pump
5/26/21
WO-40718309-01 U2 LPSI PP 2A: Inspect Pump (Includes Pressure Boundary
Bolting)
5/11/21
(Supplement)
2A LPSI PP, Safety Injection, Pump Casing Bolting, VT-1,
NDE Results
6/9/21
Replace ASME Class 1, Safety Injection Valve V3259
9/14/21
Corrective Action
Documents
Resulting from
Inspection
Procedures
RP-SL-103-2006
Radiation Protection Outage Activities
Revision 15
Radiation
Surveys
PSL-M-
210831-30
HPS-263 Down Post of Unit 2 RCB Keyway from LHRA to
08/31/2021
PSL-M-
2110831-29
U2 RCB Sump Downpost from LHRA to HRA
08/31/2021
ALARA Plans
RWP 21-1004
Reactor Disassembly Activities (Completed ALARA
package)
06/17/2021
RWP 21-1030
Scaffold Install / Remove (Completed ALARA package)
06/17/2021
RWP 21-1118
Incore Detectors: Remove / Install, Cut Up and Dispose
(Completed ALARA package)
06/17/2021
RWP 21-1302
RP Activities in RCB during Refueling / Maintenance Outage
(Completed ALARA package)
06/17/2021
RWP 21-1321
S/G Secondary Side Activities (Completed ALARA package)
08/20/2021
Corrective Action
Documents
CRs: 02343210,
2347080,
2347252,
2350726, and
2363195
CRs: 02343210, 02347080, 02347252, 02350726, and
2363195
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Source Term
Reduction Update
Source Term Reduction Update (Letter to ALARA File)
08/17/2021
Procedures
HPP-1
PREPARING RADIATION WORK PERMITS (RWP)
Rev. 41
ALARA PROGRAM
Rev. 8
ALARA IMPLEMENTING PROCEDURE
Rev. 18
Miscellaneous
1-OSP-25.04
Filter testing results for ventilation systems 1-HVE-13A, 1-
HVE-13B, 2-HVE-13-A, 2-HVE-13B, 1-HVE-10A, and 2-
HVE-10A
Various
dates 2020-
21
Order Numbers
2676 & 123941
Compressed Air/Gas Quality Testing Lab Results for
breathing air compressors and service air system
April - July
21
Procedures
Alpha Monitoring
Rev. 6
RP-SL-106-1002
Respiratory Protection Manual
Rev. 5
RP-SL-106-1003
Use of Respiratory Protective Equipment
Rev. 6
RP-SL-106-1004
Inspection and Maintenance of Respiratory Protection
Equipment
Rev. 4
Work Orders
4071756201
U2 Breather Boxes - CO2 Monitors, Pre-Outage Calibration
Corrective Action
Documents
Resulting from
Inspection
2402939
Incorrect HPP-30 Internal Dose Document Statement
09/07/2021
2402942
Correct RP-AA-101-2004 EDE Procedure Discrepancies
09/07/2021
Miscellaneous
HP-100-200824
2019-2020 Site Alpha Characterization Update
08/24/2020
HPP-30.17
Exposure Investigation Report for RWP 2021-515, Task 1
04/17/21
NVLAP Lab Code
100555-0
Certificate of NVLAP Accreditation
07/01/2021
RP-AA-101-2004-
F01
EDEX Monitoring Plans for RWP 20-2144, RWP 20-3008,
and RWP 21-1008-2
Various
Procedures
HPP-30
Personnel Monitoring
Rev. 65
Method for Monitoring and Assigning Effective Dose
Equivalent (EDE) for High Dose Gradient Work
Rev. 7
RP-SL-101-1008
Multibadging
Rev. 6
RP-SL-101-1011
Skin Dose Assessment
Rev. 3
Corrective Action
Documents
ARs, 02401362,
2371871,
2360323, and
Various related to inoperable area radiation monitors.
Various
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2364447.
71151
Corrective Action
Documents
2390317
Worker received accumulated dose alarm
08/25/2021
Corrective Action
Documents
2A ICW Pump Did Not Start in Required Time
Unit 2 FT-09-202 2C AFW Pump Discharge Flow Transmitter
Requires Recalibration
White Residue 2B2 Cold Leg Nozzle to Main Spray PCV-
1100E
V-25-20 Containment Vacuum Relief Check Valve Failed
Open Test Stroke
Found Cracked Relay in 4kV Switchgear 2A3-12 B Phase
Over-current
Seventh Sensor of LT-07-13B, Containment Sump Wide
Range B, is Failed
Unit 2 Reactor Containment Building Penetration P58 Seal
Has Holes
SL2-26 Containment Liner Moisture Barrier Minor Damage
Possible Through-wall Leak in 2B LPSI Header at I-10-SI-
556
SL2-26 Containment Shell Plate to Floor Interface on
Annulus Side Indications
RI-26-80A4, Startup Range Nuclear Instrument for Excore
Monitoring Needs Repair
V3104, Check Valve for 2A LPSI Pump Recirculation to
Refueling Water Tank, Internal Valve Inspection
Unsatisfactory
SL 2-26 Support SI-4200-673 Misaligned
2B1 RCS Cold Leg Inactive Boric Acid
Wide Range Nuclear Instrument Troubleshooting - J9
Connector Failed Requires Repair
Corrosion on Pipe BF-40 at Tee in Unit 2 AFW Trench
2/1218 Load Sequence Relay Adjusted
V09119, Check Valve for 2A AFW Pump Supply to 2A
Steam Generator FW Inlet Requires Seat Replacement
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SL2-26 IWE Inspection Areas of Degradation
SL2-26 Main Steam Piping Support Setting at Zero
Foreign Material on the Reactor Head that Cannot Be
Removed
Unit 2 Startup Range Nuclear Instrument Channel 1
Unreliable
Unit 2 FU-3 Fuses Ampere Rating for 29-1/1636 Isolating
Relay for Auxiliary Feedwater Actuation System Battery
Failure
Conditional Release for Unit 2 FCV-25-36, Isolation Valve for
Containment Hydrogen Purge Make-up Air
Unit 2, MV-09-10, MOV from 2B AFW Pump Discharge to
Steam Generator, Stem Coupling Found Loose During
Testing
SL2-26 IWE Containment Penetration Indications
Unit 2 Water Coming Out of Nuclear Instrument Conduit and
Terminal Boxes
Snubber 2-234 and Pipe Clamp Were Found Out of
Alignment
SL2-26 IWE Containment Penetration Indications
Unit 2, V5201, Isolation Valve for Pressurizer Surge Sample,
has a Leaking Swagelok
SL2-26 Containment Shell Plate Coating Degradation
2A AFW Pump Discharge Valve to 2A Steam Generator
Open Limit Switch Adjustment
Unit 2, MV-08-1B, MOV Equalizer for B Steam Generator
Unit 2, Wide Range Containment Level Incorrect Calibration