IR 05000335/2022004
| ML23040A370 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/10/2023 |
| From: | David Dumbacher Division Reactor Projects II |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2022004 | |
| Download: ML23040A370 (14) | |
Text
SUBJECT:
ST LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2022004 AND 05000389/2022004
Dear Bob Coffey:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St Lucie Units 1 & 2 and discussed the results of this inspection with Robert Craven, Nuclear Site Vice President, St Lucie Power Plant and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St Lucie Units 1 & 2.
If you disagree with a finding not associated with a regulatory requirement 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at St Lucie Units 1 & 2.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
February 10, 2023
Sincerely, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000335 and 05000389 License Nos. DPR-67 and NPF-16
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000335 and 05000389
License Numbers:
Report Numbers:
05000335/2022004 and 05000389/2022004
Enterprise Identifier:
I-2022-004-0025
Licensee:
Florida Power & Light Company
Facility:
St Lucie Units 1 & 2
Location:
Jensen Beach, FL 34957
Inspection Dates:
October 01, 2022, to December 31, 2022
Inspectors:
J. Bundy, Senior Operations Engineer
P. Cooper, Senior Reactor Inspector
S. Downey, Senior Reactor Inspector
D. Lanyi, Senior Operations Engineer
T. Morrissey, Senior Resident Inspector
D. Orr, Senior Resident Inspector
S. Roberts, Resident Inspector
Approved By:
David E. Dumbacher, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at St Lucie Units 1 & 2, in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Unit 1 Manual Trip Due to Insufficient Feed Flow to 1A Steam Generator
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
None (NPP)
A self-revealed Green finding was identified when the licensee failed to ensure condensate
flow controller (FIC-12-1) was classified in accordance with ER-AA-101, "Equipment
Reliability". Specifically, FIC-12-1 was classified non-critical, and its failure caused a
significant reduction in feedwater flow to steam generator 1A water level resulting in a manual
Failed Unit 1 Emergency Core Cooling System (ECCS) Ventilation System Charcoal Filter
Testing Results
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
None (NPP)
A self-revealed Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1.a.,
Procedures and Programs, was identified for the licensees failure to develop and establish an
appropriate preventive maintenance schedule to replace charcoal adsorber units in the
emergency core cooling system (ECCS) ventilation system prior to methyl iodide efficiency
degrading to less than TS surveillance requirements (TSSR).
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period shut down in refueling outage, SL1-31. The unit was
restarted on October 3, 2022, and was returned to rated thermal power (RTP) on October 6,
2022. On November 14, 2022, the unit was down powered to 75 percent for a 1B drain cooler
tube leak repair and was returned to RTP on November 18, 2022, and remained at or near RTP
for the remainder of the inspection period.
Unit 2 operated at or near RTP for the entire 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 activities described in IMC 2515,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Plant Status, observed risk significant activities, and completed on-site portions of
IPs. 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 03.02) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-
significant systems from impending severe weather, Hurricane Nicole, on November
7 - 10, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 2 component cooling water (CCW) system while the 2B CCW pump was out of
service (OOS) for planned maintenance on October 19 - 20, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Fire zone (FZ) 81, Unit 1 external control zones on October 6, 2022
(2)
FZ 7, Unit 2 external control zones on October 6, 2022
(3)
FZ 71, Unit 1 control room heating ventilation air conditioning area on October 26,
2022
(4)
FZs 42II and 42III, Unit 2 control room air conditioning room and control room
emergency air cleanup system room on October 26, 2022
(5)
FZ 2, Unit 2 pipe tunnel on October 26, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1)
The licensee completed the annual requalification operating examinations required to
be administered to all licensed operators in accordance with Title 10 of the Code of
Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's
"Operator's Licenses." During the week of January 2, 2023, the inspector performed
an in-office review of the overall pass/fail results of the individual operating
examinations and the crew simulator operating examinations in accordance with IP 71111.11, "Licensed Operator Requalification Program." These results were
compared to the thresholds established in Section 3.03, "Requalification Examination
Results," of IP 71111.11.
The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam completed on December 20, 2022.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1
Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the Control
Room during a Unit 1 reactor startup on October 3, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated a simulator licensed operator annual
operating examination on October 31, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Action request (AR) 2429763, 1B2 emergency diesel generator (EDG) radiator
coolant leak, review completed on November 1, 2022
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program by reviewing
the following:
(1)
AR 2407701, Quarterly Review of License Renewal Internal Operating
Experience - 4th Quarter 2021
AR 2424155, Quarterly Review of License Renewal Internal Operating
Experience - 1st Quarter 2022
AR 2442435, Quarterly Review of License Renewal Internal Operating
Experience - 2nd Quarter 2022
Reviews were completed on December 1, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
Unit 1 elevated risk while the 1C auxiliary feedwater (AFW) pump was OOS for
unplanned maintenance on October 13, 2022
(2)
Unit 1 and Unit 2 elevated risk while the 1B EDG was OOS for planned maintenance
from October 24 - 25, 2022
(3)
Unit 1 and Unit 2 elevated risk while the 1A EDG was unavailable for a 24-hour
endurance run from November 28 - 29, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
AR 2439052, V09151, steam leak at hinge pin on check valve for AFW pump 1C
supply to SG 1A feedwater inlet, review completed on October 12, 2022
(2)
AR 2440216, Unit 2 RM-26-26, radiation monitor for Unit 2 containment atmosphere,
is causing nuisance alarms on the radiation monitoring computer system, review
completed on November 3, 2022
(3)
AR 2437929, 1C charging pump discharge piping leak and AR 2438397, charging
system piping leak downstream of MV-02-2, review completed on November 14, 2022
(4)
AR 2440221, Boric acid evaluation for Unit 2 RC-121-2B1 cold leg piping and reactor
vessel, review completed on November 30, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
Engineering Change (EC) 294435, 1A3 and 1B3 safety-related 4 kV switchgear,
replace SF6 breakers with vacuum breakers, review completed on October 5, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1)
Work Order (WO) 40695460, 2B CCW pump overhaul, review completed on October
26, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated refueling outage SL1-31 activities from September 3, 2022,
to October 4, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (2 Samples)
(1)
1-OSP-69.14B, ESF-18 Month Surveillance for EDG Start on SIAS Without LOOP
and 24-Hour Load Run - Train B, reviewed on October 24 - 25, 2022
(2)
1-OSP-52.01A, Surveillance Test of Degraded Grid Voltage A Train, reviewed on
November 2, 2022
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
(1)
Unit 1 (October 1, 2021, through September 30, 2022)
(2)
Unit 2 (October 1, 2021, through September 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
(1)
Unit 1 (October 1, 2021, through September 30, 2022)
(2)
Unit 2 (October 1, 2021, through September 30, 2022)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
(1)
Unit 1 (October 1, 2021, through September 30, 2022)
(2)
Unit 2 (October 1, 2021, through September 30, 2022)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
(1)
Unit 1 (October 1, 2021, through September 30, 2022)
(2)
Unit 2 (October 1, 2021, through September 30, 2022)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
(1)
Unit 1 (October 1, 2021, through September 30, 2022)
(2)
Unit 2 (October 1, 2021, through September 30, 2022)
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
Several ARs related to previously identified structural deficiencies and areas of aging
related degradation associated with the Unit 1 and Unit 2 intake structure: AR
2408625, 2409095, 2409555, 2409612, 2410253, 2410259, and 2410333. These
ARs were selected for follow-up to verify the licensees corrective actions were
appropriate to maintain structural integrity of the intake structures and associated
appurtenances.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (2 Samples)
H
The inspectors evaluated the following licensee event reports (LERs):
(1)
LER 050000335/2022-003-00, Manual Reactor Trip Due to Loss of Feedwater Pump.
(ADAMS Accession Number ML22301A127). The inspection conclusions associated
with this LER are documented in this report under Inspection Results Section 71153.
(2)
LER 050000335/2022-002-00, Condition Prohibited by Technical Specifications
(ADAMS Accession No. ML22301A124). The inspection conclusions associated with
this LER are documented in this report under Inspection Results Section 71153.
INSPECTION RESULTS
Unit 1 Manual Trip Due to Insufficient Feed Flow to 1A Steam Generator
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
None (NPP)
A self-revealed Green finding was identified when the licensee failed to ensure condensate
flow controller (FIC-12-1) was classified in accordance with ER-AA-101, "Equipment
Reliability". Specifically, FIC-12-1 was classified non-critical, and its failure caused a
significant reduction in feedwater flow to steam generator 1A water level resulting in a manual
Description: On September 2, 2022, St Lucie Unit 1 was down powered to begin refueling
outage SL1-31. After reaching approximately 45% rated thermal power, an operator was
assigned to manually control condensate flow to the single operating condensate pump using
the condensate recirculation valve (FCV-12-1) in accordance with procedure 1-GOP-123,
Turbine Shutdown - Full Load To Zero Load. When the local switch at condensate controller
FIC-12-1, was placed in manual, FCV-12-1 fully opened. FCV-12-1 fully opened caused a
substantial reduction in condensate flow to the operating main feedwater pump (MFP). The
MFP tripped on low suction pressure, resulting in a loss of steam generator feedwater flow.
Based on lowering and unrecoverable 1A steam generator water level, the reactor was
manually tripped by control room operators.
FIC-12-1 was infrequently used and, prior to being placed in service, was balanced by
adjusting a loader until a metal ball indicator was stable inside a visible switching zone. Once
balanced and switched to manual operation, there should be no FCV-12-1 movement until
the loader was adjusted. On September 2, 2022, the controller indicated balanced, but the
actual output of the manual controller was high resulting in FCV-12-1 going full open when
FIC-12-1 was transferred to manual.
The inspectors reviewed the root cause evaluation associated with this issue documented in
AR 2488832. The licensee determined that condensate flow controller FIC-12-1 is not
classified, maintained or pre-operational checked consistent with its actual functional
importance consistent with ER-AA-101, Equipment Reliability.
ER-AA-101, section 3.3, step 1, requires the licensee to implement the equipment reliability
process. ER-AA-101 Attachment 1, INPO AP-913, Equipment Reliability Process and
Objectives, references ER-AA-204-2006, Management of Critical Components and Single
Point Vulnerabilities (SPVs), for scoping, preventative maintenance, and continuing
improvement. ER-AA-204-2006, section 4.1, step 1, requires scoping and identification of
single point vulnerabilities and critical components to be accomplished using ER-AA-2006-
100001, Functional Importance Determination and ER Scoping. ER-AA-2006-100001,
section 7.0, step 2, part B, references Attachment 2, Criticality Criteria, to develop an initial
Functional Importance Determination (FID). A potential scram or large down power greater
than 20% should be classified as FID-1. FID-1 classification required recurring preventative
maintenance. FIC-12-1 was inappropriately classified as FID-N, i.e., a loss of a function will
not cause a significant impact on nuclear safety, production capability, or level of
consequence on other indicators of importance.
Corrective Actions: The licensee entered this issue into its corrective action program as AR
2435832. The licensee rebuilt FIC-12-1 and updated the FID for both Unit 1 and Unit 2 control
loop F-12-1 components. The licensee additionally initiated a procedural change to both units
[1,2]-GOP-123, Turbine Shutdown - Full Load To Zero, to maintain two condensate pumps in
operation during the down power to minimize the risk of FCV-12-1 spurious opening.
Corrective Action References: AR 2435832
Performance Assessment:
Performance Deficiency: The licensees failure to ensure controller FIC-12-1 was classified,
maintained or pre-operational checked consistent with its actual functional importance as
expected in ER-AA-101, Equipment Reliability, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance attribute of the Initiating Events
cornerstone and adversely affected the cornerstone objective to limit the likelihood of events
that upset plant stability and challenge critical safety functions during shutdown as well as
power operations. Specifically, the licensee failed to ensure condensate recirculation valve
FIC-12-1 was classified in accordance with ER-AA-101, Equipment Reliability. FIC-12-1 was
classified non-critical, and its failure caused a reduction in steam generator 1A water level
resulting in a manual reactor trip.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power. The
finding screened to very low safety significance (Green) because it did not cause a reactor
trip and the loss of mitigation equipment relied upon to transition the plant from the onset of
the trip to a stable shutdown condition (e.g., loss of main condenser or the loss of feedwater).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated
with this finding.
Failed Unit 1 Emergency Core Cooling System (ECCS) Ventilation System Charcoal Filter
Testing Results
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
Open/Closed
None (NPP)
A self-revealed Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1.a.,
Procedures and Programs, was identified for the licensees failure to develop and establish
an appropriate preventive maintenance schedule to replace charcoal adsorber units in the
emergency core cooling system (ECCS) ventilation system prior to methyl iodide efficiency
degrading to less than TS surveillance requirements (TSSR).
Description: On September 3, 2022, the licensee received laboratory results for samples
taken from the ECCS ventilation system charcoal adsorber units, HVE-9A and HVE-9B. The
charcoal samples were obtained on August 31, 2022, and tested for methyl iodide penetration
in accordance with the Ventilation Filter Testing Program (VFTP) and TSSR 4.7.8.1.b. The
requirements of the VFTP are established in TS 6.8.4.k. and require the ECCS area
ventilation system charcoal adsorber units have a methyl iodide penetration less than or
equal to 2.5%. HVE-9A was at 6.05% and HVE-9B was at 3.26% methyl iodide
penetration. These results exceeded the TS maximum required limit of 2.5%. On September
3, 2022, the licensee declared both trains of ECCS ventilation system inoperable from August
31, 2022, which placed the unit in TS limiting condition for operation (LCO) 3.0.3. TS 3.0.3.
requires within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that action shall be initiated to place the unit in a mode in which the
specification does not apply, which for this instance, required cold shutdown within the
subsequent 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Cold shutdown was established on September 3, 2022, at 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />
as part of the planned refuel outage, SL1-31, sequence. The licensee submitted LER 05000335/2022-002-00 to document this condition. The licensee entered this issue into the
corrective action program as ARs 2435856 and 2435857.
The inspectors reviewed LER 05000335/2022-002-00 and the associated corrective action
documents in ARs 2435856 and 2435857. The licensee concluded in its equipment failure
investigation reviews that although the charcoal is tested for methyl iodide penetration every
eighteen months, the charcoal efficiency cannot be trended with reliable
predictions. Additionally, the licensee did not have an appropriate replacement frequency for
the charcoal adsorber units to ensure the charcoal was replaced prior to unacceptable methyl
iodide penetration results. The charcoal adsorber units were 22 and 10 years in service for
HVE-9A and HVE-9B respectively, when replaced in October 2022.
Corrective Actions: The licensee replaced the charcoal adsorber units in HVE-9A and HVE-
9B during refuel outage SL1-31. The licensee also intended to replace all Unit 1 charcoal
adsorber units every 9 years and all Unit 2 charcoal adsorber beds every 10.5 years which
they judged to be conservative based on several years of VFTP results and site operating
experience. This corrective action was entered into the corrective action program as AR
2435856-09 on December 21, 2022.
Corrective Action References: ARs 2435856 and 2435857.
Performance Assessment:
Performance Deficiency: The licensees failure to implement a preventive maintenance
schedule to replace the charcoal adsorber units in the ECCS ventilation system prior to
efficiency degrading to less than technical specification surveillance requirements was a
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the SSC and Barrier Performance attribute of the Barrier
Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases caused
by accidents or events. Specifically, the licensee failed to establish an appropriate preventive
maintenance schedule to replace charcoal adsorber units in the ECCS ventilation system
which caused methyl iodide efficiency to degrade below TS requirements.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power. Using
Exhibit 3, Barrier Integrity, for "Control Room, Auxiliary, Reactor, or Spent Fuel Pool
Building," the inspectors determined the finding to be of very low safety significance (Green)
because the finding only represented a degradation of the radiological barrier function
provided for the control room, auxiliary building, spent fuel pool, SBGT system (BWR), or
EGTS system (PWR ice condenser).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance. The licensee since initial operation did not establish an appropriate
replacement schedule for charcoal adsorber units and the charcoal adsorber methyl iodide
test results were satisfactory for over ten years.
Enforcement:
Violation: St Lucie Unit 1 Technical Specification 6.8.1.a, stated in part, that written
procedures shall be established, implemented, and maintained covering the activities
referenced in the applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, Appendix A, item 9,
Procedures for Performing Maintenance, subsection b, stated in part, preventive maintenance
schedules should be developed to specify replacement of such items as filters and
replacement of parts that have a specified lifetime. The Unit 1 ECCS ventilation system
charcoal adsorber units have a finite service life based on methyl iodide penetration
efficiency. Contrary to the above, from initial operation until December 21, 2022, the licensee
failed to establish a replacement schedule for the ECCS ventilation system charcoal adsorber
units.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 12, 2023, the inspectors presented the integrated inspection results to
Robert Craven, Nuclear Site Vice President, St Lucie Power Plant and other members of
the licensee staff.
THIRD PARTY REVIEWS
On November 16, 2022, the inspectors reviewed the Institute on Nuclear Power Operations
continuum report that was issued in October 2022.