IR 05000335/2014007

IR 05000335-14-007 & 05000389-14-007; 01/13/2014 - 02/06/2014; St. Lucie Nuclear Plant, Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program

ML14080A131
Person / Time
Site:	Saint Lucie
Issue date:	03/21/2014
From:	Steven Rose Reactor Projects Branch 7
To:	Nazar M Florida Power & Light Co
References
IR-14-007
Download: ML14080A131 (23)

Text

UNITED STATES rch 21, 2014

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000335/2014007 AND 05000389/2014007

Dear Mr. Nazar:

On February 6, 2014, the Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your St. Lucie Nuclear Plant Units 1 and 2.

The enclosed report documents the inspection results, which were discussed on February 6, 2014, with Mr. Jensen and other members of your staff.

Based on the inspection sample, the inspection team determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staffs performance was adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The team determined that your stations performance in each of these areas supported nuclear safety.

Finally, the team determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the teams observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. The enclosed inspection report discusses one NRC-identified finding and two self-revealing findings of very low safety significance (Green) identified during this inspection. All three of the findings were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy because of the very low safety significance of the violations and because they are entered into your corrective action program. If you contest 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 Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the St. Lucie facility. In addition, if you disagree with the cross-cutting aspect assigned to any finding 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 Regional Administrator, Region II, and the NRC Resident Inspector at St. Lucie.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven D. Rose, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2014007, 05000389/2014007 w/Attachment: Supplemental Information

REGION II==

Docket No.: 50-335, 50-389 License No.: DPR-67, NPF-16 Report No: 05000335/2014007, 05000389/2014007 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 6501 South Ocean Drive Jensen Beach, FL 34957 Dates: January 13 - 17, 2014 February 3 - 6, 2014 Inspectors: R. Taylor, Senior Project Inspector, Team Leader T. Goulding, Fuel Facility Inspector N. Staples, Senior Project Inspector T. Vukovinsky, Fuel Facility Inspector J. Reyes, Resident Inspector Approved by: Steven D. Rose, Branch Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000335/2014007, 05000389/2014007; 01/13/2014 - 02/06/2014; St. Lucie Nuclear Plant,

Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by two senior project inspectors, two fuel facility inspectors, and one resident inspector. Three Green non-cited violations (NCVs) were identified. The significance of most findings is identified by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP); cross-cutting aspects were determined using IMC 0310; Aspects Within Cross-Cutting Areas; and findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process (ROP).

Identification and Resolution of Problems The team concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The threshold for initiating Condition Reports (CRs) in the corrective action program (CAP) was appropriately low, as evidenced by the types of problems identified and the number of CRs entered annually into the CAP. However, the team did identify deficiencies in the areas of identification of problems, prioritization and evaluation of identified problems, and effectiveness of corrective actions. The team noted that the licensees performance improvement audit results, from 2014, were in line with the teams observations and findings.

The audit documented examples of items in the CAP not being corrected and closed in a complete, timely and accurate manner.

The inspectors determined that overall audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the team determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

Cornerstone: Initiating Events

Green: A self-revealing, Non-Cited Violation (NCV) of 10 CFR Part 50 Appendix B,

Criterion XVI, Corrective Action, was identified for the licensees failure to correct an identified condition adverse to quality associated with the water intrusion into the HCV-09-2A relay box. The licensees failure to implement corrective actions to address previous water intrusion events was a performance deficiency. Specifically, the licensee failed to implement corrective actions to address previous water intrusion events, which resulted in the failure of HCV-09-2A, and a plant trip. This issue was documented in the licensees corrective action program as CR 1920696. Immediate corrective actions included the restoration of HCV-09-2A to operable status and the inspection of other Main Feedwater Isolation Valve (MFIV) relay boxes.

This performance deficiency was more than minor because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and it adversely affected the associated cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. In accordance with the NRC inspection Manual Chapter 0609,

Attachment 4, Initial Characterization of Findings, the finding was determined to be of very low safety significance (Green) because the finding did not result in a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, in the component of Evaluation, because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P2). (Section 4OA2.a(3)(i))

Cornerstone: Mitigating Systems

Green: An NRC identified non-cited violation (NCV) of Technical Specification 6.8.1,

Procedures and Programs, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978. The licensees failure to comply with procedures to seismically restrain ladders was a performance deficiency.

Specifically, the licensees procedures for seismic restraint of ladders: MA-AA-100-1008, Station Housekeeping and Material Control; QI-13-PSL, Housekeeping and Cleanliness Controls Methods St. Lucie Plant; ADM-04.02, Industrial Safety Program; and ADM-27.11, Scaffold Control, were not implemented as written with regard to ladders that were installed near safety-related equipment. The inspectors identified three examples of ladders not seismically restrained in accordance with the licensees procedures. Immediate corrective actions included completing a site-wide walkdown of the safety-related systems to identify and bring into procedural compliance any ladders that were not seismically restrained. This issue is documented in the licensees corrective action program as Action Request (AR) 1935979 and 1933112.

The performance deficiency was determined to be more than minor because if left uncorrected the failure to comply with station procedures to ensure adequate restraining of seismically controlled ladders could lead to a more significant safety concern.

Specifically, seismically unrestrained ladders could impact safety-related equipment during a design basis seismic event. Using Manual Chapter 0609.04, Significance Determination Process Initial Characterization of Findings Table 2 dated June 19, 2012, the finding was determined to affect the Mitigating Systems Cornerstone. The inspectors evaluated the risk of this finding using Manual Chapter 0609 Appendix A,

Significance Determination Process for Findings At-Power, Exhibit 2- Mitigating Systems Screening questions. The inspectors determined that the finding was of very low safety significance because it did not represent an actual loss of safety function. The finding involved the cross-cutting area Problem Identification and Resolution, in the component of Resolution. Specifically licensee failed to take effective corrective actions to address issues in a timely manner commensurate with their safety significance (P3). (Section 4OA2.a(3)(ii))

Cornerstone: Barrier Integrity

Green: A self-revealing, Non-Cited Violation (NCV) of Technical Specification (TS)6.8.1, Procedures and Programs, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978, including safety related activities carried out during operation of the reactor plant. The licensees failure to comply with refueling procedure 0-NOP-67.05, Refueling Operations, was a performance deficiency. Specifically, the licensees procedure for refueling operation, 0-NOP-67.05, Refueling Operations, was not implemented as written for conducting refueling operations resulting in a fuel mishandling event. This issue was documented in the licensees corrective action program as condition report 1911660.

This performance deficiency was more than minor because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and it adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. Specifically, failure to prevent fuel assemblies from contacting one another during refuel operations could fail to provide reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the risk of this finding using Manual Chapter 0609, Appendix G, Significance Determination Process for Shutdown Operations. The inspectors determined that the finding was of very low safety significance Green using IMC 0609, Appendix G, Figure 1, because it did not require a quantitative assessment as determined in IMC 0609, Appendix G,

Attachment 1, Checklist 4. The finding involved a cross-cutting aspect of Human Performance, in the component of Teamwork. Specifically, individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. (H.4) (Section 4OA2.a(3)(iii))

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Corrective Action Program Effectiveness

(1) Inspection Scope The team reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports. To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the team reviewed a sample of CRs that had been issued between March 2012 and January 2014, including a detailed review of selected CRs associated with the following risk-significant systems and components:

Auxiliary Feedwater (AFW), 125 Volt DC, and Fuel Oil (FO). Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The team conducted plant walkdowns of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The team reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, a five-year review was performed for selected systems for age-dependent issues.

Control room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were being tracked to resolution. A sample of operator workarounds and operator burden screenings were reviewed and the team verified compensatory measures for deficient equipment were being implemented in the field.

The team conducted a detailed review of selected CRs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The team reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure PI-AA-100-1006, Apparent Cause Evaluation, and PI-AA-100-1005, Root Cause

Analysis.

The team assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The team reviewed selected industry operating experience items, including NRC generic communications and Part 21 reports, to verify that they had been appropriately evaluated for applicability or used in licensee activities and that issues identified through these reviews had been entered into the CAP.

The team reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The team attended various plant meetings to observe management oversight functions of the corrective action process. These included CR Initial Screening Team (IST)meetings and Management Review Committee (MRC) meetings.

Documents reviewed are listed in the Attachment.

(2) Assessment Problem Identification The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure PI-AA-204, Condition Identification and Screening Process, managements expectation that employees were encouraged to initiate CRs for any reason, and the relatively few number of deficiencies identified by the team during plant walkdowns not already entered into the CAP. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the team determined that system deficiencies were being identified and placed in the CAP.

The team identified the following deficiencies related to identification of issues:

• The station was not aware of a problem which occurred during fuel handling operations for approximately 5 days. Failure to report this event to station management in a timely manner could have resulted in a missed opportunity to promptly perform an inspection of potentially damaged fuel, eliminated station managements ability to conduct a thorough and timely investigation and put in place measures to prevent another potential fuel handling event. A finding associated with this deficiency is documented in Section 4OA2.a(3)(iii) of the report.

• During the course of the inspection period the inspectors identified three examples of the licensee failing to seismically restrain ladders in accordance with the station procedures. A finding associated with this failure is documented in Section 4OA2.a(3)(ii) of the report.

Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR severity level determination guidance in procedure PI-AA-204. Each CR was assigned a severity level at the IST meeting, and adequate consideration was given to system or component operability and associated plant risk.

The team determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and the assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with PI-AA-100-1006 and PI-AA-100-1005.

The team identified several performance deficiencies associated with the licensees prioritization and evaluation of issues. These issues were screened in accordance with Manual Chapter 0612, Issue Screening.

• NCV 05000335, 389/2013-003-01, Failure to Monitor SSCs Under 10 CFR 50.65(a)(1), did not receive an Apparent Cause Evaluation as required by Condition Identification and Screening Process. The inspectors determined that this failure to implement a procedural requirement was a performance deficiency. This failure had no impact on safety related equipment and caused no safety consequences and is, therefore of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Licensee initiated CR 1938478 to address the issue.

• RCE 1920696 narrowly focused on the MFIV water intrusion event. The root cause was contributed to water entering the box via conduits, however, the Corrective Action to Prevent Recurrence (CAPR) focused only on the MFIV box itself. The known source of water intrusion in electrical boxes in this area was the ServicAir type of conduit. The RCE did not address this ServicAir type of conduit as far as extent of condition was concerned. Additionally, there was no program guidance to apply the RTV sealant that was used on this type of conduit. A finding associated with this deficiency is documented in Section 4OA2.a(3)(i) of the report.

• Action Requests (ARs) 1766355 (Unit 2 Trip Due to Erratic Feed Water Regulatory Valve Behavior) and 01755493 (Unit 1 Steam Bypass Control System Causes Plant Transient), included RCEs that identified the plant trips were a result of inadequate risk based decision making in that the station failed to adequately assess and manage the risk associated with the repeated failures and thereby failed to take timely corrective actions that could have prevented the plant trip. The corrective action was to develop and establish an FPL integrated risk program/policy. This corrective action was cancelled by the MRC with a justification that the problem was performance related rather than process related. This cancellation did not evaluate the adequacy of other corrective actions or the need for additional actions to address the process related aspect of the problem. Also there was no evaluation regarding the adequacy of the original root cause evaluation to properly identify the causes of the event. The inspectors determined that the stations inadequate risk based decision making was a contributor to the MFIV water intrusion event documented in Section 4OA2.a(3)(i) of the report.

Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that generally, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring with the exception of those issues identified in this report. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred.

Effectiveness reviews for CAPRs were sufficient to ensure corrective actions were properly implemented and were effective. However, the team determined that evaluation deficiencies discussed in the previous section, Prioritization and Evaluation of Issues, of the report rendered the corrective actions ineffective for those issues.

The team identified a performance deficiency associated with the licensees effectiveness of corrective actions. Specifically, the team identified a lack of interim corrective actions for some CAPRs. This is contrary to PI-AA-204 which lists an MRC primary function to Consider the need for implementing interim corrective actions to mitigate further events. Failure to identify interim corrective actions was also identified as a contributing cause in AR 1755493 (Steam Bypass Control System Operational Failures). The inspectors determined that this was a failure to implement a procedural requirement that had no impact on safety related equipment and caused no safety consequences. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. Licensee initiated condition report (CR) 1938478 to address the issue.

(3) Findings i.

Introduction:

A Green, self-revealing, Non-Cited Violation (NCV) of 10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to correct an identified condition adverse to quality associated with the water intrusion into the HCV-09-2A relay box. Specifically, the licensee failed to implement corrective actions to address previous water intrusion events, which resulted in the failure of HCV-09-2A, and a plant trip. This issue was documented in the licensees corrective action program as CR 1920696.

Description:

On November 14, 2013, the 2B Steam Generator Train A Main Feedwater Isolation Valve (MFIV) spuriously stroked closed. Unit 2 was manually tripped from 100 percent power due to lowering level in the 2B Steam Generator. The investigation determined that the isolation valve stroked closed in the slow mode and this could have only resulted from a spurious electrical actuation. The locally mounted HCV-09-2A relay box contains the normal operation and test relay logic for the valve. Water intrusion was identified upon inspection of this relay box. Some of the relays were corroded due to the wetted environment, including the slow close relay 3Y/671. The licensee determined that the spurious slow close could only have occurred due to actuating either of two relays (3Y/671 or 20X/671).

The inspectors noted that there were two instances involving similar occurrences of water intrusion into the HCV-09-2A relay box. During the first occurrence on December 11, 2012, the licensees Quality Assurance department identified water intrusion into the HCV-09-2A relay box. The water intrusion was attributed to improperly routed drain hoses under the relay box. The corrective action established was to change the procedure providing instructions on how to route drain hoses. The second occurrence on April 10, 2013, identified internal corrosion in relay box HCV-09-2A. One of the relays identified during this inspection was 3Y/671, which was later determined to be one of the two potential causes for the slow close of this valve. A CR and Work Request (WR)were initiated. The corrective action established was to repair/replace the affected relays during the next refueling outage.

The licensee identified the electrical conduit as the source of water intrusion into the HCV-09-2A relay box. The relays are mounted in an enclosure designed for outdoor use, however, the conduits are not watertight. In particular, the ServicAir type flexible conduits are not designed to prevent water intrusion. A coating of RTV was applied over the ServicAir conduit but this was subsequently determined by the licensee to be inadequate. The ServicAir conduit was not previously addressed as a source of water intrusion during the two previous instances of water intrusion into the relay box. The extent of condition performed during the Root Cause Evaluation (RCE) is summarized below:

Valve Relay Box Conduit Actuator Conduit 11/15/13 Box Configuration Configuration Inspection Results HCV-09-1A Rigid - Side Entry Flexible - No water SEALTITE HCV-09-1B Rigid - Side Entry Flexible - ServicAir Wetted HCV-09-2A Rigid - Side Entry Flexible - ServicAir Wetted HCV-09-2B Rigid - Side Entry Flexible - No water SEALTITE In both instances where ServicAir type conduit was used, it was found that the relay box was wetted. ServicAir type flexible conduits used on Unit 2 have been identified as a known source of water intrusion. Although ServicAir was a known source of water intrusion for outdoor electrical boxes, the licensee failed to take corrective actions to address this source of water intrusion. The licensee initiated AR 1933710 to evaluate the existing RTV applied to ServicAir conduits. A CAPR has been completed to install internal PCI Silicone Foam seals in the conduits leading to the affected relay boxes as well as weep holes drilled in the conduit to allow any moisture to drain.

The licensees Preventive Maintenance program incorporates periodic inspection activities for outdoor electrical boxes. The primary reason for these inspections is to detect water intrusion and degraded components due to the outdoor environment to which the boxes are exposed. The program interfaces with the corrective action program when deficiencies are identified during the inspections. The source of water into the HCV-09-2A relay box was identifiable and correctable; however, the actions taken have been limited to replacing degraded components. This addressed the symptoms but not the source of the water intrusion. The licensee initiated a corrective action to incorporate additional inspection guidance in 0-PME-100.10, 18 Month Inspection of Electrical Boxes, for identifying and documenting the nature and source of water intrusion.

Analysis:

The licensees failure to implement corrective actions to address previous water intrusion events was a performance deficiency. This performance deficiency was more than minor because it was associated with the equipment reliability attribute of the Initiating Events Cornerstone and adversely affected the associated cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to determine and correct the cause of the water intrusion into the HCV-09-2A relay box impacts the likelihood of limiting events that upset plant stability and challenge critical safety functions. In accordance with the NRC inspection Manual Chapter 0609.04, Initial Characterization of Findings, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding did not result in a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, in the component of Evaluation, because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P2).

Enforcement:

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, the licensee failed to take adequate corrective actions to address an adverse trend of water intrusion in the HCV-09-2A relay box and as a result, on November 14, 2013, the Train A MFIV spuriously closed resulting in Unit 2 having to be manually tripped. Because this finding is of very low safety significance and has been entered into the CAP as CR 1920696, this violation is being treated as an NCV consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000389/2014-007-01 Inadequate Corrective Actions to Address Water Intrusion in the HCV-09-2A Relay Box)ii. Failure to Follow Seismic Restraining Procedures on Ladders Located Near Safety-Related Equipment

Introduction:

A Green, NRC identified, non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978. The inspectors identified three examples where licensees procedures for seismic restraint of ladders were not complied with as written. During the inspectors extent of condition review, 24 additional examples were identified.

Description:

On January 30, 2013, the NRC issued NCV 05000335, 389/2012005-01, Failure to Follow Seismic Restraining Procedures on Ladders Located Near Safety-Related Equipment, for the licensees failure to follow procedural requirements for seismically restraining ladders. Specifically, the licensee failed to follow procedures:

MA-AA-100-1008, Station Housekeeping and Material Control; QI-13-PSL, Housekeeping and Cleanliness Controls Methods St. Lucie Plant; ADM-04.02, Industrial Safety Programs; ADM-27.11, Scaffold Control; and ADM-27.21, Ladder Usage and Compliance. In addition, these procedures require an engineering evaluation if the seismic restraints requirements cannot be met. The licensee initiated a severity level 2 apparent cause evaluation (AR 1829233).

AR 1829233 evaluated the condition and assigned 21 corrective actions including 4 corrective actions for procedure changes. Based on non-specific comments from the Corrective Action Review Board (CARB) to condense actions to revise the program, 15 of the 21 corrective actions were cancelled. During a subsequent review of the AR, the licensee determined that several proposed corrective actions had been cancelled and that this action left the station vulnerable to another finding in the area of ladder use and storage in safety related areas. A new AR (1893845) was initiated to revise/refresh the plan to integrate effective ladder guidance. This AR had the following action:

Reconsider the canceled actions of SL2 AR 1829233. Reopen them and revise the prescribed actions, implement the removal of redundant guidance in the associated procedures: MA-AA-100-1008, QI-13-PSL-2, ADM-04-02, ADM-217.11 for improvement opportunities of the new ADM-27.21 Ladder Usage and Compliance procedure. Of the actions reopened, some were completed as written, some were partially completed and others were not completed but still show a status of complete.

During the course of the inspection, inspectors identified three additional examples of ladders not seismically restrained in accordance with the licensees procedures. No equipment operability issues were identified for any of these three examples. However, the inspectors identified a continuing adverse trend in the area of seismic restraints of ladders. Immediate licensee actions included assembling a team which consisted of personnel from Maintenance, Operations and Engineering to perform a site-wide walkdown to identify and correct any ladders not in compliance with procedure seismic restraint requirements. One of the inspector-identified examples of noncompliance occurred following the licensee walkdown.

Analysis:

The licensees failure to comply with procedures to seismically restrain ladders was a performance deficiency. The performance deficiency was determined be more than minor because if left uncorrected, the failure to comply with station procedures to ensure adequate restraint of seismically controlled ladders, could lead to a more significant safety concern. Specifically, seismically unrestrained ladders could impact safety-related equipment during a design basis seismic event. Using Manual Chapter 0609.04, Significance Determination Process Initial Characterization of Findings, Table 2, dated June 19, 2012, the finding was determined to affect the Mitigating Systems Cornerstone. The inspectors evaluated the risk of this finding using Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2-Mitigating Systems Screening questions, dated June 19, 2012. The inspectors determined that the finding was of very low safety significance because it did not represent an actual loss of safety function. The finding involved the cross-cutting area of Problem Identification and Resolution, in the Component of Resolution. Specifically, the licensee failed to take effective corrective actions to address issues in a timely manner commensurate with their safety significance to ensure ladders were properly restrained to prevent interaction with safety-related systems during a design basis seismic event.

(P3)

Enforcement:

Unit 1 and Unit 2 Technical Specification 6.8.1, Procedures and Programs, requires, in part, that written procedures be implemented covering activities referenced in Regulatory Guide 1.33, Revision 2, dated February 1978, that include safety-related activities carried out during operation of the reactor plants. Section 9.a, Procedures for Performing Maintenance, states in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures appropriate to the circumstances.

Requirements to seismically restrain ladders to ensure no interaction with safety-related equipment during a design basis seismic event are specified in: MA-AA-100-1008, Station Housekeeping and Material Control; QI-13-PSL, Housekeeping and Cleanliness Controls Methods St. Lucie Plant; ADM-04.02, Industrial Safety Programs; ADM-27.11, Scaffold Control; and ADM-27.21, Ladder Usage and Compliance. Contrary to the above, multiple examples were identified where the licensee failed to seismically restrain ladders located near safety-related equipment as specified in the licensees procedures.

Because the licensee entered the issue into their corrective action program as Action Request (AR) 1935979 and 1933112 and because the finding is of very low safety significance (Green), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000335, 389/2014007-02, Failure to Follow Seismic Restraining Procedures on Ladders Located Near Safety-Related Equipment)iii. Failure to Follow Refueling Operations Procedure Resulting in a Fuel Mishandling Event

Introduction:

A Green, self-revealing, Non-Cited Violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978, including safety related activities carried out during operation of the reactor plant. The licensees procedure for refueling operation, 0-NOP-67.05, Refueling Operations was not implemented as written for conducting refueling operations resulting in a fuel mishandling event. This issue was documented in the licensees corrective action program as condition report 1911660.

Description:

On October 6, 2013, the Unit 1 reactor was being defueled as part of the SL1-25 refueling outage. Fuel assemblies were being transferred from the reactor core to the spent fuel pool using the refueling machine and the fuel transfer machine. The refueling machine upender would normally lay the assembly down horizontally in preparation for transfer to the spent fuel pool and return to the vertical position when the transfer has completed. The refueling team had placed a fuel assembly in the transfer machine and initiated the automatic sequence to send it to the spent fuel pool.

However, when the sequence was initiated, the fuel assembly transfer to the spent fuel pool did not occur. The refueling machine then transferred back to the core to pick up another assembly. The refueling team failed to recognize that the fuel transfer did not occur and that the upender still contained the previous fuel assembly. Refueling procedure 0-NOP-67.05, Refueling Operations, Attachment 4, Section 5.0, Duties and Responsibilities of the Spotter, directs verifying a clear path exists for the machine and assembly. On two occasions, the spotter incorrectly reported that the basket was up and empty, meaning the upender was empty and clear. The refueling team then attempted to load the next fuel assembly into the basket of the already full upender. An alarm condition stopped the machine which prompted the refueling team to further investigate, and at that point, the first fuel assembly was discovered still in the basket of the upender.

Analysis:

The licensees failure to comply with refueling procedure 0-NOP-67.05, Refueling Operations, was a performance deficiency. Specifically, failure to prevent fuel assemblies from contacting one another during refueling operations could fail to provide reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. This performance deficiency was more than minor because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and it adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding)protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the risk of this finding using Manual Chapter 0609 Appendix G, Significance Determination Process for Shutdown Operations, dated May 25, 2005. The inspectors determined that the finding was of very low safety significance Green using IMC 0609, Appendix G, Figure 1, because it did not require a quantitative assessment as determined in IMC 0609, Appendix G Attachment 1, Checklist 1. The finding involved a cross-cutting aspect of Human Performance, in the component of Teamwork.

Specifically, individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. (H.4)

Enforcement:

Unit 1 Technical Specification 6.8.1, Procedures and Programs, requires, in part, that written procedures be implemented covering activities referenced in Regulatory Guide 1.33, Revision 2, dated February 1978 including safety related activities carried out during operation of the reactor plant. Refueling procedure 0-NOP-67.05, Refueling Operations, Attachment 4, Section 5.0, Duties and Responsibilities of the Spotter, directs verifying a clear path exists for the machine and assembly. Contrary to the above, the licensee failed to ensure that the fuel transfer machine upender was empty prior to attempting to place a fuel assembly in the upender. Because the licensee entered the issue into their corrective action program as CR 1911660 and because the finding is of very low safety significance (Green), this violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000389/

2014007-03, Failure to Follow Refueling Operations Procedure Resulting in a Fuel Mishandling Event)b. Use of Operating Experience

(1) Inspection Scope The team examined licensees use of industry operating experience (OE) to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since March 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the St. Lucie site, and whether issues identified through these reviews were entered into the CAP.

Documents reviewed are listed in the Attachment.

(2) Assessment Based on a review of documentation related to the review of operating experience issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was screened by the corporate OE coordinator and relevant information was then forwarded to the sites OE coordinator. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure PI-AA-100-1005.

(3) Findings No findings were identified.

c.

Self-Assessments and Audits

(1) Inspection Scope The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure PI-AA-101, Self-Assessment and Benchmarking Program.

Documents reviewed are listed in the Attachment.

(2) Assessment The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The team verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.

Generally, the licensee performed evaluations that were technically accurate.

(3) Findings No findings were identified.

d. Safety-Conscious Work Environment

(1) Inspection Scope During the course of the inspection, the team assessed the stations safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment Based on the interviews conducted and the CRs reviewed, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the team determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The team did not identify any reluctance on the part of the licensee staff to report safety concerns. However, the number and content of anonymous CRs indicates that some plant personnel are reluctant to identify themselves.

(3) Findings No findings were identified.

4OA3 Event Follow-up

.1 (Closed) Licensee Event Report (LER) 05000389/2013004-00 Manual Trip Following

Spurious Closure of Main Feedwater Isolation Valve (MFIV) and Lowering of Steam Generator Levels On November 14, 2013, Unit 2 was in Mode 1 at 100 percent power when the 2B Steam Generator Train A MFIV HCV-09-2A spuriously stroked closed. This resulted in a manual reactor trip of Unit 2 due to rapidly lowering steam generator water level. The inspectors reviewed the LER to verify the accuracy and completeness of the LER and the appropriateness of the licensees corrective actions. A finding associated with this LER is documented in Section 4OA2.a(3)(ii) of the report. This LER is closed.

.2 (Closed) Licensee Event Report 05000335/2013002-00 Unplanned Manual Reactor Trip

Due to Digital-Electrohydraulic (DEH) System Leak On November 12, 2013 St. Lucie Unit 1 was manually tripped due to a digital-electrohydraulic fluid leak from a tubing fitting in the turbine control system. Prior to the reactor trip, PSL Unit 1 was at 90 percent power ascending to 98 percent power following the SL1-25 refueling outage. The inspectors reviewed the LER to verify the accuracy and completeness of the LER and the appropriateness of the licensees corrective actions. This LER is closed.

4OA6 Meetings, Including Exit

On February 6, 2014, the inspectors presented the inspection results to Mr. J. Jensen and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

C. Bible, Engineering Manager

W. Blackwell, I&C Supervisor

B. Castaglia, Performance Improvement Manager

D. Cecchett, Licensing Engineer

B. Coffey, Plant General Manager

C. Cullen, Safety Manager

A. Dong, OPS Operator Burden Coordinator

J. Jensen, Site Vice President

E. Katzman, Licensing Manager

J. Kramer, Performance Programs Improvement Manager

R. Mixon, OPS CAP Coordinator

A. Pell, AFW System Engineer

J. Rexrode, OPS Shift Supervisor

W. Ryley, OPS Shift Supervisor

R. Sciscente, Performance Improvement Analyst

T. Spillman, Assistant Operations Manager

NRC personnel

T. Morrissey, Senior Resident Inspector

S. Rose, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened and Closed

05000389/2014-007-01 NCV Inadequate Corrective Actions to Address Water Intrusion in the HCV-09-2A Relay Box (Section 4OA2.a(3)(i))

05000335,389/2014007-02 NCV Failure to Follow Seismic Restraining Procedures on Ladders Located Near Safety-Related Equipment (Section 4OA2.a(3)(ii))

05000389/2014007-03 NCV Failure to Follow Refueling Operations Procedure Resulting in a Fuel Mishandling Event (Section 4OA2.a(3)(iii))

Closed

05000389/2013004-00 LER Manual Trip Following Spurious Closure of Main Feedwater Isolation Valve (MFIV) and Lowering of Steam Generator Levels( Section 4OA3.1)

05000335/2013002-00 LER Unplanned Manual Reactor Trip Due to Digital-

Electrohydraulic System Leak (Section 4OA3.2)