IR 05000335/2019003
| ML19318F156 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/14/2019 |
| From: | Randy Musser Division Reactor Projects II |
| To: | Moul D Florida Power & Light Co |
| Reeder D | |
| References | |
| IR 2019003 | |
| Download: ML19318F156 (18) | |
Text
November 14, 2019
SUBJECT:
SAINT LUCIE PLANT UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2019003 AND 05000389/2019003
Dear Mr. Moul:
On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Saint Lucie Units 1 & 2. On October 10, 2019, the NRC inspectors discussed the results of this inspection with Mr. D. DeBoer 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.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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 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 Saint 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Randall A. Musser, 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:
05000335/2019003 and 05000389/2019003
Enterprise Identifier:
I-2019-003-0018
Licensee:
Florida Power & Light Company
Facility:
Saint Lucie Plant Units 1 & 2
Location:
Jensen Beach, FL 34957
Inspection Dates:
July 1, 2019 to September 30, 2019
Inspectors:
P. Cooper, Reactor Inspector
M. Kennard, Operations Engineer
D. Lanyi, Senior Operations Engineer
T. Morrissey, Senior Resident Inspector
J. Reyes, Resident Inspector
S. Roberts, Resident Inspector
Approved By:
Randall A. Musser, 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 Saint 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. A licensee-identified non-cited violation is documented in report section: 7115
List of Findings and Violations
Failure to accurately translate the static head loss to calculate the maximum allowable biological fouling of the ultimate heat sink culverts Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2019003-01 Open/Closed None 71111.07T An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion III was identified for the licensee's failure to accurately translate the static head loss, associated with the design basis water level of Big Mud Creek, to the calculations that established the basis for the maximum allowable biological fouling of the ultimate heat sink culverts.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power (RTP). On September 7, 2019, the unit automatically tripped from RTP when the 1A1 reactor coolant pump (RCP) breaker opened causing a low reactor coolant system (RCS) flow reactor trip signal. The RCP breaker tripped open due to a motor ground caused by wetting of the RCP motor from a leaking component cooling water (CCW) pipe connection to the upper motor oil cooler. On September 9 - 10, 2019, the unit was cooled down to Mode 5 (<200F) to replace the 1A1 RCP motor. The 1A1 RCP motor was replaced and the unit was restarted on September 21, 2019. The unit reached RTP on September 22, 2019. Unit 1 operated at or near RTP for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power (RTP). On September 26, 2019, power was lowered to approximately 85 percent RTP for several hours to support planned turbine valve testing. Unit 2 operated at or near RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated licensee readiness for impending adverse weather conditions due to Hurricane Dorian approaching the site on August 28 - September 4, 2019. The site was under a hurricane warning, however, hurricane and tropical storm force winds were not experienced on site.
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
- (1) Unit 2, 2B low pressure safety injection (LPSI) train while 2A LPSI train was out of service (OOS) for emergent work, on July 11, 2019
- (2) Unit 1, 1A emergency diesel generator (EDG) while 1B EDG was OOS for emergent work, from July 16 - 27, 2019
- (3) Unit 1, 1B and 1C CCW pumps while 1A CCW pump was OOS for emergent maintenance, on July 25, 2019
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
- (1) Unit 2, control room, on July 5, 2019
- (2) Unit 1, auxiliary feedwater (AFW) and steam trestle area, on July 17, 2019
- (3) Unit 2, AFW and steam trestle area, on July 17, 2019
- (4) Unit 2, 2A EDG and 2A diesel oil storage tank rooms, on August 12, 2019
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 02.02a.) (1 Sample)
- (1) Unit 1, 1B train high pressure safety injection (HPSI), 1B train LPSI, and 1B train containment spray flood area, on September 24, 2019
===71111.07T - Heat Sink Performance
Triennial Review (IP Section 02.02)===
(1)1B-CCW Heat Exchanger, Cooled by Service Water (2)1A Shutdown Cooling Heat Exchanger, Closed Loop
- (3) U2 Control Room Air Conditioning, Closed Loop
- (4) Sections 02.02d.1, 02.02d.2, 02.02d.5 and 02.02d.7 were completed to support the review of the Ultimate Heat Sink Dam and Intake Structure.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
The inspectors completed an inspection to verify the licensees ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 23 - 27, 2019.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) On September, 21 - 22, 2019, the inspectors observed licensed operator performance in the Unit 1 control room during reactor startup and power ascension activities in accordance with general operating procedures 1-GOP-302, "Reactor Plant Startup - Mode 3 to Mode 2," and 1-GOP-201, "Reactor Plant Startup - Mode 2 to Mode 1."
- (2) On September 26, 2019, the inspectors observed licensed operator performance in the Unit 2 control room during changing power from RTP to 85 percent RTP and back to RTP in accordance with procedure 2-GOP-123, "Turbine Shutdown - Full Load to Zero Load," to support planned turbine valve testing.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) On July 15, 2019, the inspectors observed a licensed operator requalification training emergency plan evaluation on the control room simulator. The simulated scenario included loss of a circulating water pump, a steam generator tube leak, a rapid downpower, a non-isolable RCS leak, a manual reactor trip, a failure of the 2B start up transformer, a failure of 2B EDG output breaker, and execution of emergency operating procedure 2-EOP-15, "Functional Recovery." The degradation of the reactor coolant system boundary resulted in an Alert emergency classification which required a simulated notification to the State of Florida and the NRC.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (2 Samples)
- (1) Unit 1, action request (AR) 2317358, motor operated valve V3480, loop 1A shutdown cooling system return valve, failed to open, on July 10, 2019
- (2) Unit 2, AR 2319219, LPSI pump 2A to LPSI header pipe elbow through-wall leak, on September 12, 2019
Quality Control (IP Section 02.02) (1 Sample)
- (1) Unit 1, AR 2321166, 1B EDG 12-cylinder engine crankshaft end connection to radiator fan shaft failed, on July 15, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
- (1) Unit 2, elevated risk while 2A LPSI train was OOS for emergent maintenance, from July 10 - 12, 2019
- (3) Unit 1, elevated risk while 1A CCW pump and 1B EDG were OOS for emergent maintenance, on July 25, 2019
- (4) Unit 2, elevated risk with 2A train emergency core cooling system (ECCS) OOS due to planned maintenance on motor operated valves MV-07-1A and MV-07-2A (refueling water tank (RWT) and containment sump suction valves) and separately 2A train ECCS OOS due to emergent maintenance on boric acid makeup pumps (BAMP)2A and 2B, from August 6 - 10, 2019.
- (5) Unit 1, Yellow shutdown safety assessment with the unit in Mode 5, depressurized and drained below the reactor vessel flange (lowered inventory) to support 1A1 RCP seal replacement, on September 14, 2019.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (4 Samples)
- (1) AR 2321166, 1B EDG 12-cylinder engine crankshaft end connection to radiator fan shaft failed, common cause determination for 1A EDG, on July 19, 2019
- (2) AR 2321577, Unit 1, reactor protection system channel D, 1A steam generator low level bistable has high impedance, on August 6, 2019
- (3) AR 2322545, Unit 2, missing pipe hanger on EDG water drain line, on August 13, 2019
- (4) AR 2322572, 1B EDG adverse trend for fast start time to rated voltage, on September 5, 2019
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
- (1) Unit 2, work order (WO) 40671844, 2A LPSI, replace pipe elbow upstream of flow element FE-3306, on July 14, 2019
- (2) Unit 1, WO 40674502, 1B EDG, replace the 12-cylinder engine crankshaft, from July 16 - 27, 2019
- (3) Unit 1, WO 40675074, 1A CCW pump impeller replacement, on July 31, 2019
- (4) Unit 1, WO 40673684, 1A intake cooling water (ICW) pump packing replacement, on August 16, 2019
- (5) Unit 1, WO 40679198, 1A CCW motor replacement, on August 23, 2019
- (6) Unit 1, WO 40566326, 1B ICW pump replacement, on September 4, 2019
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) Unit 1 Forced Outage ( September 7 - September 21, 2019)
On September 7, 2019, the unit automatically tripped from RTP when the 1A1 reactor coolant pump (RCP) breaker opened causing a RCS low flow reactor trip signal.
The RCP breaker tripped open due to a motor ground caused by wetting of the RCP motor from a leaking CCW pipe connection to the upper motor oil cooler.
On September 9 - 10, 2019, the unit was cooled down to Mode 5 (<200F) to replace the 1A1 RCP motor. RCS level was drained to a lowered inventory condition to allow replacement of the RCP's seal. The 1A1 RCP motor was replaced and the unit was restarted on September 21, 2019. The unit reached RTP on September 22, 2019.
The inspectors evaluated Unit 1 forced outage activities from September 7, 2019 until the unit was returned to service on September 21, 2019. The inspectors completed applicable portions of sections 03.01b, 03.01c, 03.01d, and 03.01e of IP 71111.20.
71111.22 - Surveillance Testing
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
- (1) Unit 2, 2-SMI-69-02, "Engineered Safeguards Actuation System - Channel Functional Test," on August 9, 2019
- (2) Unit 2, 0-SME-66.04, "Inspection of the Reactor Trip Switchgear (RTSG) Breakers,"
on September 25, 2019
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2, 2-OSP-09.01B, "2B Auxiliary Feedwater Pump Code Run," on August 27, 2019
FLEX Testing (IP Section 03.02) (1 Sample)
(1)0-OSP-83.04A(B)(C), "Periodic Testing of the Flex 480V DG A(B)(C)," 0-OSP-83.01A(B)(C), "Periodic Testing of the Flex SG Pump A(B)(C), 0-OSP-83.02A(B),
"Periodic Testing of the Flex CST Pump A(B)," and 0-OSP-83.03A(B), "Periodic Testing of the Flex SFP Pump A(B)," on August 21, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated an emergency response drill in the training simulator, technical support center, and the emergency operations facility. The drill included an EDG fire, main steam safety valve leakage, a RCP shaft shear, an automatic reactor trip and a steam generator tube rupture, on August 20,
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)
- (1) Unit 1 Safety System Functional Failures from July 1, 2018, through June 30, 2019
- (2) Unit 2 Safety System Functional Failures from July 1, 2018, through June 30, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
- (1) AR 2319219, Possible boric acid residue on 2A LPSI pipe insulation, AR 2323559, 2A BAMP active casing leak, and AR 2323562, 2B BAMP active casing leak
- (2) AR 2321678, "1A CCW flow went from 5200 gallons per minute (gpm) to 4750 gpm"
71153 - Followup of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) On September 7, 2019, the unit automatically tripped from RTP when the 1A1 RCP breaker opened causing a RCS low flow reactor trip signal. The inspectors reviewed operator performance in response to the trip, operator logs, computer and recorder data, and the post trip report to verify plant equipment, and operations personnel, responded appropriately. The inspectors provided details regarding operator and equipment performance to NRC management. The inspectors verified the cause of the trip was appropriately resolved prior to unit restart. The unit was restarted on September 21, 2019 and was returned to RTP on September 22, 2019.
Reporting (IP Section 03.05) (1 Sample)
- (1) On September 1, 2019, with both units operating at RTP, St. Lucie County as well as the site were placed under a hurricane watch due to Hurricane Dorian approaching the area. The site met Emergency Action Level (EAL) HU1, which in part, requires a Notification of Unusual Event (NOUE) emergency declaration for a natural occurrence affecting the protected area that includes a confirmed hurricane warning in effect.
The NOUE was declared at 1717 hours0.0199 days <br />0.477 hours <br />0.00284 weeks <br />6.533185e-4 months <br /> on September 1, 2019 and was terminated at 1818 hours0.021 days <br />0.505 hours <br />0.00301 weeks <br />6.91749e-4 months <br /> on September 3, 2019 when the hurricane watch was lifted for the area.
The inspectors verified the event was properly classified and notifications to the State of Florida and the NRC were properly made in accordance with the emergency plan implementing procedure EPIP-01, "Classification of Emergencies," and EPIP-02, "Duties and Responsibilities of the Emergency Coordinator," on September 2,
INSPECTION RESULTS
Failure to accurately translate the static head loss to calculate the maximum allowable biological fouling of the ultimate heat sink culverts Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000335,05000389/2019003-01 Open/Closed None 71111.07T An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion III was identified for the licensee's failure to accurately translate the static head loss, associated with the design basis water level of Big Mud Creek, to the calculations that established the basis for the maximum allowable biological fouling of the ultimate heat sink culverts.
Description:
Two independent sources of water comprise the ultimate heat sink for the Saint Lucie Nuclear Plant. The primary source of water is the Atlantic Ocean and the secondary source is Big Mud Creek. The primary source is used for normal plant operation and is available for all natural phenomena apart from an event which results in liquefaction. For this event, it is conceivable for the ocean intake system to become impassable due to soil liquefaction, requiring that the secondary source, Big Mud Creek, provide the necessary cooling water.
The water from Big Mud Creek passes through a series of culverts, sized to maintain the volume within the intake bay, to support the intake cooling water pump functionality. The culverts, however, are susceptible and experience biological growth from aquatic life, such as clams and mussels, which results in a reduction of the effective culvert diameter and consequently the culvert capacity. The inspector reviewed calculation PSL-BFSM-03-003, "Ultimate Heat Sink Flow Through Wall Barrier Calculation," which calculates the maximum allowable marine growth buildup on internal pipe surfaces and identified that one of the design inputs, the static head loss, was incorrectly referenced to the 1-ARP-01-E00, Control Room Panel E RTGB-102 procedure. This procedure provides instructions for operator action should the annunciator in the control room indicate an Intake Water Level Low alarm.
Within these actions are water levels associated with the intake bay to alert the control room on the loss of the primary source of cooling water, the Atlantic Ocean. The ultimate heat sink culverts that connect Big Mud Creek to the intake bay, however, are not submerged at the time these actions are initiated and thus, this procedure doesn't provide relevant design inputs for the culvert capacity.
Interviews with licensee staff revealed that the static head loss from the calculation was derived from the difference of the water surface elevation of Big Mud Creek to the invert of the heat sink culverts. This difference in elevation, however, does not represent the static head loss, but rather the total available static head. Utilizing the static head loss, while maintaining the methodology, pipe size, safety margins, and assumptions, resulted in an approximate reduction in capacity of 7k gallons per minute (gpm) from the required 29k gpm design basis flow.
Corrective Actions: As an immediate corrective action, the licensee developed calculations, by modifying the pipe size, clarifying assumptions, and reducing safety margins, that preliminarily demonstrates the functionality of the culverts.
Corrective Action References: AR 02322281
Performance Assessment:
Performance Deficiency: The inspector determined that the failure to accurately translate the static head loss associated with design basis water level of Big Mud Creek to PSL-BFM-03-003, "Ultimate Heat Sink Flow Through Barrier Wall Calculation," which establishes the basis for the maximum allowable biological fouling of the ultimate heat sink culverts, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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. It adversely affected the cornerstone objective in that there was a reasonable doubt on the operability of the ultimate heat sink culverts.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the finding to be of very low safety significance (Green) because the culverts maintained their functionality at the currently prescribed acceptance criteria.
Cross-Cutting Aspect: None
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, "Design Control," stated, in part, that "measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into drawings, procedures and instructions." Contrary to the above, since April 2003, the licensees design control measures failed to correctly translate the static head loss, associated with the design basis water level of Big Mud Creek, into calculation PSL-BFSM-03-003, "Ultimate Heat Sink Flow Through Wall Barrier Calculation," which was used to establish the allowable biological fouling of the heat sink culverts. As an immediate corrective action, the licensee evaluated the functionality of the culverts and initiated corrective action to make changes to the calculations.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71152 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality, such as deficiencies are promptly identified and corrected. The licensee's nuclear fleet procedure ER-AP-116-1000, "Boric Acid Corrosion Control Program," revision 4, Section 4.1.1, "Boric Acid Leak Identification," step 3, requires that an individual discovering evidence of leakage shall initiate a Work Request/Action Request in accordance with fleet procedures.
Contrary to the above, on June 25, 2019, during a scheduled boric acid corrosion control (BACC) program walk down of the unit 2 reactor auxiliary building, the licensee identified boric acid deposits on both 2A and 2B BAMP casings and failed to initiate an action request to place the issue in the corrective action program. The licensee cleaned off the boric acid deposits and marked the areas of concern. On August 06, 2019, during a unscheduled walk down of the BAMP casings, the licensee identified a return of the boric acid deposits in the marked areas of concern. The issue was placed in the corrective action program as ARs 2323559 and 2323562. Additional information regarding this licensee-identified violation is contained in section 71152 of this report.
Significance/Severity: Green. The failure to place this issue in the corrective action program on June 25, 2019, is a performance deficiency. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined this finding was of very low safety significance (Green) because the finding did not represent an actual loss of function for either BAMP.
Corrective Action References: AR 2324657
Observation: Boric Acid Program Review 71152 One licensee-identified violation was identified.
On June 26, 2019, the licensee identified suspected boric acid residue on 2A LPSI piping insulation. The AR documented that a thorough search revealed no surrounding possible sources of leakage. A work order, assigned with a low priority, was initiated to remove the pipe insulation to allow for inspection of the pipe. On July 9, 2019, the pipe insulation was removed and the 2A LSPI piping was found to have through-wall leakage. The 2A LPSI train was declared inoperable and the pipe was replaced within the Technical Specification allowed outage time of 7 days. The licensee completed a past operability review that determined the 2A LSPI train would have performed its safety function and would have been considered operable but degraded with the through-wall leaks.
On June 25, 2019, during a scheduled BACC program walk down of the unit 2 reactor auxiliary building, the licensee identified a small boric acid deposit on both 2A and 2B BAMP casings. The licensee cleaned off the boric acid deposits and marked the areas of concern on the casings. The issue was not placed in the corrective action program. On August 6, 2019, during an informal BACC walk down of the BAMPs, the licensee identified a return of the boric acid deposits in the marked areas of concern. The issue was placed in the CAP as ARs 2323559 and 2323562. Each BAMP was declared inoperable due to pump casing through-wall leakage. The licensee declared the "A" train of the emergency core cooling system inoperable since there was no flow path from an operable BAMP to a charging pump as required by Technical Specification 3.5.2.d. Technical Specification 3.5.2 action statement required the train to be restored to an operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or place the unit in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. On August 8, 2019, the NRC granted relief from American Society of Mechanical Engineers Boiler & Pressure Vessel Code (ASME Code)Section XI for the 2B BAMP (ML19221B674).
The code relief allowed the licensee to declare the 2B BAMP operable but degraded and allowed exiting of Technical Specification action statement. The 2A BAMP casing was weld repaired. The 2B BAMP was sent off site for repair, however, inspection and testing could not find a through-wall leak or defect in the 2B BAMP casing. The 2B BAMP was returned to service.
The inspectors as well as the licensee noted deficiencies in the BACC program. The work order for the suspected 2A LPSI piping leakage was not assigned a priority level commensurate with the consequences of a potential through-wall leak. The LPSI piping through-wall leakage was identified 13 days after the initial identification of the suspected boric acid on the pipe insulation. For the identified boron on the BAMP casings found on June 25, 2019, the licensee determined that an ER-AP-116-1000-F01, Boric Acid Leak Screening, work sheet had not been completed for the suspected BAMP casing leaks.
If a screening had been completed, the issue would have been placed into the corrective action program with immediate corrective actions implemented. A licensee-identified violation has been documented in this report for the licensees failure to place the issue in the corrective action program. The licensee completed a fleet BACC program assessment (AR 2324657). The inspectors found that the assessment was comprehensive, addressed program deficiencies, and included corrective actions necessary to improve BACC program implementation.
Observation: 1A CCW Pump Degraded Impeller Review 71152 AR 2321678, documenting degraded 1A CCW pump discharge flow, was placed in the corrective action program on July 15, 2019. AR 2321678 was not updated to reflect the damaged impeller found during subsequent inspections and repair, nor did it identify or cross reference any extent of condition analysis performed by the licensee. The AR was closed to the work management process (WMP) on July 21, 2019. On August 13, 2019, AR 2324343 was written to track an extent of condition review for the 1B and 1C CCW pumps, however, the AR was designated as a routine work task (RWT), which falls outside the licensee's CAP program. After this was identified by NRC inspectors, the licensee initiated AR 2329106 to formally address the extent of condition review for the 1A CCW pump degraded impeller.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 10, 2019, the inspectors presented the integrated inspection results to Mr.
D. DeBoer and other members of the licensee staff.
- On September 26, 2019, the Operator Licensing inspectors presented the Exit Meeting inspection results to D. DeBoer and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0005753
Severe Weather Preparations
71111.07T Calculations
PSL-BFSM-03-
003
UHS Flow Through Barrier Calculation
2/11/03
PSL-ENG-SEMS-
98-069
Assurance of Equipment Operability and Containment
Integrity During Design-Basis Accident Conditions
Rev. 0
PSL-ENG-SENS-
99-006
Starting the SDC System
Rev. 0
Corrective Action
Documents
1B CCW Hx Retube
Drawings
8770-G-712
Barrier Wall - Plan & Sect
Rev. 10
Miscellaneous
ICW Inservice Testing Basis, Ultimate Heat Sink Valve
SDC Hx Thermal Transient Re-analysis
09/26/02
UHS Valve Test
April 2019
UHS Valve Test
July 2019
8770-3599
NY-422226 I/M Technical Manual - 1B CCW Hx
10/25/15
Bathymetric
Survey
Intake Canal and Big Mudd Creek
2017
Bathymetric
Survey
Dredging Near Intake Headwall
2019
PSL-ENG-SEMS-
99-038
Review of Unit 1 SDC System Operation
Rev. 2
SL1-27
CCW 1B Eddy Current Report
10/3/2016
SL1-28
CCW 1B Eddy Current Report
4/26/2018
SL2-23
License Renewal Walkdown Control Room Air Conditioning
25G
03/15/2017
SPEC-M-081
CCW Hx Tube Integrity Inspection
06/27/13
Procedures
0-PMM-14.01
Component Cooling Water Heat Exchanger Clean/Repair
Rev. 15
1-AOP-37.01
Emergency Cooling Water Canal
Rev. 9
1-NOP-03.05
Rev. 66
1-NOP-14.02
Component Cooling Water System Operation
Rev. 78
1-NOP-21.03B
1B Intake Cooling Water System Operation
Rev 16
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ADM-27.17
Land Utilization Routine and Inspection Program
Rev. 13
Work Orders
35027285
SDC Hx 1A Inspection
11/17/05
4032519401
UHS Dive Inspection
07/06/15
4032519402
UHS Dive Inspection
07/09/15
4039194601
1B CCW Clean and Inspect
09/28/16
4041681401
1B CCW Clean and Inspect
03/16/16
4044167701
UHS Dive Inspection
01/24/17
4044167702
UHS Dive Inspection
01/24/17
4055260101
UHS Dive Inspection
10/09/18
4055260102
UHS Dive Inspection
10/09/18
4063647101
1B CCW Clean and Inspect
05/11/19
71111.11B Miscellaneous
2019 BRE Week
Biennial
Examination, RO
and SRO
2019 BRE Week 3 Biennial Examination, RO and SRO
Rev 0
21004
Perform Control Room Actions for Control Room
Inaccessibility - Unit 2
Rev 16
21014A
Verify CSAS - Unit 2
Rev 14
21034
Align 1A Condensate Pump Power Supply to 1C
Condensate Pump
Rev 19
21035
Respond to Linear Power Range Malfunction - Unit 1
Rev 22
21051A
M STANDARD POST TRIP ACTIONS - UNIT 1
Rev 18
21055
Check 2C AFW Pump for Steam Binding
Rev 22
21062
Align Unit 2 CST to Supply 1A AFW Pump
Rev 21
21112T
Respond to CEA Continuous Gripper Hi Voltage Alarm -
Unit 2
Rev 14
21305A
VERIFY MSIS - UNIT 2
Rev 2
21307A
Respond to Abnormal Pressure Control - PCV-1100E Fails
Open - Unit 2
Crew 3 Licensed
Operator 2018-
2019 Training
Attendance
Records
Crew 3 Licensed Operator 2018-2019 Training Attendance
Records
9/24/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Crew 3 Licensed
Personnel
Quarterly
Proficiency Time
Records 2018-
2019
Crew 3 Licensed Personnel Quarterly Proficiency Time
Records 2018-2019
9/25/2019
Eight (8) Licensed
Operator Medical
Records
Eight (8) Licensed Operator Medical Records
9/25/2019
Resumption of
Active NRC
License
Qualification for
two (2) licensed
operators
Resumption of Active NRC License Qualification for two (2)
licensed operators
9/24/2019
Scenario
0815006
Week 2 Scenario 0815006
Rev 24
Scenario 15018
Week 2 & 4 Scenario 15018
Rev 21
Scenario 15048
Week 4 Scenario 15048
Rev 6
Scenario 15053
Scenario 15053 Week 5
Rev 2
Procedures
NRC Licensed Operator Exam Security
Rev 4
Conduct of Simulator Training and Evaluation
Rev 12
Simulator Scenario Based Testing and Validation
3