IR 05000335/2020010
| ML20198L803 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/16/2020 |
| From: | Randy Musser NRC/RGN-II |
| To: | Moul D Florida Power & Light Co |
| References | |
| IR 2020010 | |
| Preceding documents: |
|
| Download: ML20198L803 (15) | |
Text
July 16, 2020
SUBJECT:
ST. LUCIE PLANT UNITS 1 & 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000335/2020010 AND 05000389/2020010
Dear Mr. Moul:
On June 18, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your St. Lucie Plant Units 1 & 2 and discussed the results of this inspection with Mr. Carlos Santos, Site Operations Director, and acting Site Director, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/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: DPR-67 and NPF-16 Report Numbers: 05000335/2020010 and 05000389/2020010 Enterprise Identifier: I-2020-010-0019 Licensee: Florida Power & Light Company Facility: St. Lucie Plant Units 1 & 2 Location: Jensen Beach, FL 34957 Inspection Dates: June 01, 2020 to June 18, 2020 Inspectors: D. Jackson, Project Engineer L. Pressley, Senior Project Engineer (Team Lead)
S. Roberts, Resident Inspector S. Sanchez, Senior Emergency Preparedness Inspector Approved By: Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at St. Lucie Plant, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the following:
- Corrective Action Program (CAP) Effectiveness: The inspectors assessed the licensee's CAP effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted an in-depth CAP review of the emergency diesel generators, intake cooling water, high pressure safety injection, low pressure safety injection and chemical and volume control systems. The inspectors also reviewed the status of corrective actions related to a Supplemental Inspection (Agency Documents Access and Management System (ADAMS)) Accession No. ML17263A055), dated September 20, 2017.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for the use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensee's self-assessments and audits.
- Safety Conscious Work Environment (SCWE): The inspectors assessed the effectiveness of the licensees programs to establish and maintain a safety conscious work environment. In addition, the inspectors reviewed the status of actions taken to address the assigned cross-cutting theme in this area, (ADAMS Accession No. ML20063N712), dated May 3,
INSPECTION RESULTS
Assessment of Corrective Action Program Effectiveness 71152B The inspectors reviewed the effectiveness of the licensees Corrective Action Program (CAP).
Specifically, as it related to the ability of the CAP to adequately perform the functions of problem identification, prioritization and evaluation of any issues identified and the subsequent related corrective actions.
This included a review of procedure, PI-AA-104-1000, Condition Reporting and other relevant procedures, and associated CAP documents, (i.e. cause evaluation, and operability determination process).
Inspectors performed in-depth reviews of past and current CAP actions for specific systems (i.e. emergency diesel generators, intake cooling water, high pressure safety injection, low pressure safety injection and chemical and volume control systems) and compared those to the current general condition and overall system health.
Inspectors performed a risk-informed sampling review of root cause and other lower level cause evaluations. Inspectors also reviewed corrective actions associated with prior NRC violations, findings and observations.
During the inspection period, inspectors observed multiple CAP meetings and licensee staff interactions related to the application of the CAP process. Additionally, inspectors conducted multiple interviews with licensee staff specifically related to corrective actions for the systems selected for in-depth reviews.
The inspectors also reviewed the status of corrective actions related to the Supplemental Inspection (ADAMS Accession No. ML17263A055), dated September 20, 2017, conducted under IP 95001, "Supplemental Inspection Response to Action Matrix Column 2 Inputs,"
which was associated with a White finding in the Initiating Events Cornerstone. The inspectors verified all corrective actions had been completed.
Inspectors reviewed site-specific corrective actions associated with a Notice of Violation (ADAMS Accession No. ML19234A332), dated September 12, 2019, and the status of actions taken to address the associated cross-cutting theme in the Safety Conscious Work Environment (SCWE) area, which was assigned in the Annual Assessment Letter (ADAMS Accession No. ML20063N712), dated May 3, 2020.
The inspectors concluded, that in general: the licensees CAP was effective in identifying problems and entering them in the CAP, and in prioritizing and evaluating those problems commensurate with the safety significance; that site management and staff were actively involved in managing and maintaining the CAP and in fully resolving any identified problems, and; that the licensees CAP complied with the regulatory requirements and self-imposed standards and therefore adequately supported nuclear safety.
Assessment of the Use of Operating Experience 71152B The inspectors reviewed the licensee's program for obtaining and using operating experience.
This included a review of procedure, PI-AA-102, Operating Experience Program and other relevant procedures, and associated CAP documents. This review included select in-depth reviews from the licensees list of all NRC generic communications (e.g., Information Notices, Generic Letters, etc.) and industry operating experience (OE) documents (e.g., Part 21 reports, vendor information letters, information from other sites, etc.).
The inspectors concluded that the licensees processes for the use of NRC and industry operating experience information were generally effective and complied with all regulatory requirements and licensee standards.
Assessment of Self-Assessments and Audits 71152B Inspectors reviewed the licensees self-assessments and audits programs.
This included a review of procedure, PI-AA-101, Assessment and Improvement Programs and other relevant procedures and licensee documents.
The inspectors concluded that the licensee was generally effective at performing a significant number of relatively critical self-assessments and audits. In addition, the licensee generally evaluated those issues at the appropriate level and prioritized and resolved them commensurate with their safety significance.
Assessment of the Safety Conscious Work Environment 71152B The inspectors reviewed the licensees safety conscious work environment (SCWE).
This included a review of procedure, AD-AA-103, Nuclear Safety Culture Program and other relevant procedures and licensee documents.
Inspectors also reviewed the status of actions taken to address the associated cross-cutting theme in the SCWE area, which was assigned in the Annual Assessment Letter (ADAMS Accession No. ML20063N712), dated May 3, 2020.
The inspectors performed interviews with a reasonable sample size and cross-section of St. Lucie employees and contractors.
In general, the employees interviewed by the inspectors stated that they were willing to raise nuclear safety concerns to their management chain and were both willing and familiar with the multiple means available to enter problems into the CAP.
Inspectors also reviewed the licensees internal programs to monitor the safety culture, which included; CAP trending, the employee concerns program (ECP), and relevant survey results.
Inspectors concluded that, in general, the licensee appears to have established an adequate safety conscious work environment.
Observation: Status of the SCWE Cross-Cutting Theme 71152B The inspectors identified an observation as part of reviews related to the overall assessment of the safety conscious work environment (SCWE) and the corrective actions for the associated SCWE cross-cutting theme.
A SCWE cross-cutting theme was assigned in the Annual Assessment Letter (ADAMS Accession No. ML20063N712), dated May 3, 2020. This cross-cutting theme was the result of a Notice of Violation (NOV) (ADAMS Accession No. ML19234A332), dated September 12, 2019. Inspectors performed a limited site-specific review of the corrective actions to address the NOV. Follow-up inspections specific to the NOV and associated root cause evaluation (RCE) had previously been performed by NRC inspectors at the NextEra/FPL corporate offices. The results of that inspection will be documented in the St. Lucie Integrated Inspection Report 2020002.
Given that the problem identification and resolution inspection performed an assessment in this area, the inspectors used this early opportunity to gauge the licensees, and specifically St. Lucies site-specific, in-progress corrective actions to address the SCWE cross-cutting theme. To support this review, inspectors also reviewed licensee procedures LI-AA-200, Regulatory Margin Corrective Action Strategy, and LI-AA-103-1000, Regulatory Issue Management.
Inspectors concluded that although corrective actions had been taken at the corporate level to address the NOV and the related SCWE aspects in the licensees original RCE, there were no official CAP corrective actions initiated to address the site-specific SCWE cross-cutting theme which was identified in the Assessment Letter. Also, there were no official CAP connections to associate the SCWE theme with the original RCE for the NOV and those related corrective actions. Inspectors concluded that the licensee should have initiated an action in the CAP in accordance with licensee procedures (LI-AA-200 and LI-AA-103-1000) or at a minimum added additional corrective actions to the original condition report to track and ensure that appropriate corrective actions were taken to ensure the cross-cutting theme was properly evaluated for potential additional correction actions.
The licensee initiated action request (AR) 02358851 to document this observation.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 18, 2020, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Carlos Santos, Site Operations Director, and acting Site Director, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 02081717
DocumentsCorrective 02086249
Action 02176118
DocumentsCorrective 02199767
Action Documents 02232869
262333
265371
266741
267118
267332
271925
272541
274595
276059
278452
279416
279817
280067
283879
284080
285892
288575
293647
294142
295052
297560
297760
2303872
2304431
2304535
2304530
2304605
Inspection Type Designation Description or Title Revision or
Procedure Date
2305795
2306313
2306384
2311906
2313071
2317801
2318833
2319219
2321007
2321166
2321678
2322281
2322418
2322585
2322753
2332786
2323105
2323570
2323757
2324633
2324657
2326687
2326689
2326690
2326834
2327033
2329202
2330722
2331546
2333089
2334051
2336830
2341303
2344398
Inspection Type Designation Description or Title Revision or
Procedure Date
2347597
2351863
2353576
Corrective Action 02358708
Documents Resulting 02358754
from Inspection 02358757
2358833
2358851
2360157
Miscellaneous 2020 Employee Engagement Survey Results
Maintenance Rule (a)1 Evaluation and Action Plan,
System 11 - Heater Drains and Vents System (AR
288575)
Maintenance Rule (a)1 Evaluation and Action Plan,
System 14 - 2B CCW Heat Exchanger (AR 2225449)
Maintenance Rule (a)1 Evaluation and Action Plan,
System 26 - Radiation Monitor RM-26-26
Maintenance Rule (a)1 Evaluation and Action Plan,
System 59 - 1B EDG (AR 2321166)
System Health Report, Unit 1 Safety Injection, Q2-20
System Health Report, Unit 2 Safety Injection, Q2-20
System Health Report, Unit 1 CVCS, Q2-20
System Health Report, Unit 2 CVCS, Q2-20
Maintenance Rule Functional Failure determination for 05/23/2019
solenoid valve for diesel oil supply shutoff to 1B-EDG day
tanks
19-0149-TR-001 1B Diesel Shaft Forensic Investigation
464712 IRIS Experience Report #464712 Emergency Diesel
Generator Trip, Radiator Fan Shaft is Not Spinning
EVAL-PSL-59- (a)(1) review for 1B-EDG 10/24/2019
01802
Miscellaneous FPL-1 Quality Assurance Topical Report
Inspection Type Designation Description or Title Revision or
Procedure Date
FPL-2 FP&L Quality Assurance Program Description
PSL-TS-33446 Test Report to evaluate fractured switch blade from an
Agastat 7000 series timing relay for 1B-EDG fuel oil
transfer at Saint Lucie Plant
RCE 02285892
RCE 02288575
RCE 02327033
RCE 02329202
Operability Past Operability Review for 1B2 EDG radiator fan shaft 10/24/2019
Evaluations not spinning
Procedures AD-AA-103 Nuclear Safety Culture Program
ER-AA-100-2002 Maintenance Rule Program Administration
IM-AA-102 Cyber Security Program
IM-AA-102-1002 Cyber Security Assessment
LI-AA-103-1000 Regulatory Issue Management
LI-AA-200 Regulatory Margin Corrective Action Strategy
NA-AA-02 Quality Assurance
NA-AA-06 Safety Conscious Work Environment
NA-AA-07 Employee Concerns Program
PI-AA-100 Condition Assessment & Response
PI-AA-100-1005 Root Cause Analysis
PI-AA-100-1006 Common Cause Evaluation
PI-AA-100-1007 Issue Investigation
PI-AA-101 Assessment and Improvement Programs
PI-AA-101-1000 Level 2 Independent Assessment Planning, Conduct and
Reporting
PI-AA-101-1001 Level 1 Core Business Assessments
PI-AA-102 Operating Experience Program
PI-AA-102-1001 Operational Experience Program Screening &
Responding to Incoming OE
PI-AA-102-1002 Internal Operating Experience
PI-AA-104-1000 Condition Reporting
Self- AR 2151217
Inspection Type Designation Description or Title Revision or
Procedure Date
AssessmentsSelf- Effectiveness
Assessments Review
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Work Orders 40196137-14,
40311234,
40490316,
40600716-01,
40605158-01,
40619929-02,
40625275-01,
40628607-01,
40634759-01,
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