IR 05000335/2022012

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Biennial Problem Identification and Resolution Inspection Report 05000335 2022012 and 05000389 2022012
ML22180A029
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 06/29/2022
From: David Dumbacher
Division Reactor Projects II
To: Coffey B
Florida Power & Light Co
References
IR 2022012
Download: ML22180A029 (14)


Text

SUBJECT:

ST LUCIE UNITS 1 & 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000335/2022012 AND 05000389/2022012

Dear Mr. Coffey:

On May 20, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your St Lucie Units 1 & 2 and discussed the results of this inspection with Mr. Daniel DeBoer, Site Vice President and other members of your staff.

The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations problem identification and resolution 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 problem identification and resolution 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 June 29, 2022 Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

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: DPR-67 and NPF-16

Report Numbers: 05000335/2022012 and 05000389/2022012

Enterprise Identifier: I-2022-012-0015

Licensee: Florida Power & Light Company

Facility: St Lucie Units 1 & 2

Location: Jensen Beach, FL

Inspection Dates: May 02, 2022 to May 20, 2022

Inspectors: J. Hamman, Senior Project Engineer C. Kontz, Senior Project Engineer L. Pressley, Reliability and Risk Analyst S. Roberts, Resident Inspector

Approved By: David E. Dumbacher, 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 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 03.04)

(1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the auxiliary feedwater and 125-volt direct current systems. In addition, the inspectors performed a high-level review of the licensees corrective action program related to any aging issues, general corrosion and erosion and environmental qualifications with specific attention given to circuit boards, relays and power supplies.

Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.

Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 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. station batteries and auxiliary feedwater 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 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 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 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 71152B The inspectors reviewed the licensees safety conscious work environment (SCWE). This included a review of Nuclear Safety Culture Site Leadership Team meeting minutes, procedure, AD-AA-103, Nuclear Safety Culture Program and other relevant procedures and licensee documents.

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.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On May 20, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Daniel DeBoer, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective 02423529 02372036 02422566

Action 02423857 02377147 02370748

Documents 02424262 02395828 02380151

2358851 02398481 02381590

2381509 02404036 02399463

2413519 02404285 02402496

2415359 02404416 02407060

2416187 02411677 02419630

2369201 02417041 02420540

2355625 02426764 02366489

2358403 02426856 02415359

2368316 02426951 02381509

2368421 02426987 02384319

2388996 02426989 02383050

2377657 02426992 02383373

2417569 02426995 02404894

2381504 02426997 02420302

2359116 02407967

2407252 02147383

2380625 02282775

2425203 02423837

2417840 03423929

2417149 02425923

2357024 02322281

2358155 02356660

2358720 02358833

2362210 02404422

2367409 02413519

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective 02426764 Control Room Deficiency Log Various

Action Administrative Deficiencies

Documents 02426856 Degraded Pipe Insulation Unit 2 on piping

Resulting from adjacent to V08112, Secondary Root Valve

Inspection For PT-08-3B

2426951 1B Battery Charger AC Power Light

Operations promptly replaced the light bulb.

2426987 2B 125V DC Bus Power Panel Yellow

electrical tape labeling not part of normal

plant labeling applied to circuits located in

the 2B 125V DC Bus Power Panel, 125V DC

BUS POWER DISTRIBUTION PANEL ESS-

SB

2426989 V09726 Fitting Corrosion on a fitting

adjacent to V09726, CHEM INJ TO 2C AFW

PUMP DICH HDR TO 2B S/G/CHECK

No evidence of active leakage

2426992 V09154 Vent Cap Leaking (less than 1

drop/minute) Unit 2 secondary root valve for

PX-09-3B2 V09154 previously identified with

seat leak

2426995 V09124 External Corrosion Isolation Valve

for AFW Pump 2B Discharge

2426997 Degraded pipe insulation on tubing tapping

off downstream of the 1B MFIV, HCV-09-8

2427934 Procedure Change Revision (PCR) for EN-

AA-203-1001, Operability

Determinations/Functionality, to revise

authorized screeners (section 4.2.1) to

reflect PSL SM/SRO screening JB CRs. The

process change has been effective since

2018 (CMP 2291377). PCR is needed to

align with the current process.

Inspection Type Designation Description or Title Revision or

Procedure Date

2428049 NRC Observation: Anonymous Concern

Reporting Plant personnel interviewed were

unfamiliar with current processes for

documenting anonymous concerns.

Additionally, the NRC team identified related

administrative process inconsistencies.

Engineering 295797 CEDMCS Cabinet C2 - Revise 120 VAC 4/8/2021

Changes Logic Power Source UV relays

295961 Channel Assignments for Turbine Trip on 7/26/2021

Reactor Trip Relays

296428 Update PSL-2 USFAR Section 7.6.3.11.2 4/8/2021

per AR 2383050

Miscellaneous 2020 & 2021 - Quarter 1 through Quarter 4

NUCLEAR SAFETY CULTURE SITE

LEADERSHIP TEAM MEETING MINUTES

Control Room Deficiencies WO Schedule

Dates

System Health Report, Unit 1, AFW April 28,

22

System Health Report, Unit 2, AFW April 28,

22

Lists of AFW MOV PMs

List of 125V DC System ARs

System Health Report, Unit 1, System 50,

25 VDC

AR 02278047, MRFF: MV-09-10 SWITCH

ON RTGB BROKEN WITH AFW FLOW @

117 GPM

Lists of AFW System ARs

System Health Report, Unit 2, System 50,

25 VDC

List of Control Room Deficiencies (historical

and current)

Inspection Type Designation Description or Title Revision or

Procedure Date

Root Cause Evaluation for Unit 2 automatic 1/21/2021

reactor trip due to an unexpected de-

energization of the 480V motor control

center 2B2

278047 MRFF: MV-09-10 SWITCH ON RTGB

BROKEN WITH AFW FLOW @ 117 GPM

278047 Equipment Failure Investigation

282775 Perform an MRFF IAW ER-AA-100-2002-

F01 for 2C AFW PP

282775 Equipment Failure Investigation

EVAL-PSL-03b-02442 (a)(1) LPSI System

EVAL-PSL-11-02643 (a)(1) Review Heater Drains and Vents

System

EVAL-PSL-18b-02382 (a)(1) Instrument Air

EVAL-PSL-25a-02642 (a)(1) Risk Significant HVAC

EVAL-PSL-66-02684 (a)(1) Control Element Drive Mechanism

WO 40627600 U1 AFW A-Train WO 40627600,

Components Requiring Inspection for

License Renewal Walkdown Report

Operability 02417041

Evaluations 02417149

2417840

Procedures 0-CME-50.20 REPAIR OF LCR / LCY TYPE BATTERY 1

COVERS

0-SME-50.06 SAFETY RELATED 125 VDC SYSTEM 17, 20

MONTHLY MAINTENANCE

0-SME-50.11 SAFETY RELATED 125 VDC SYSTEM 5

QUARTERLY MAINTENANCE

0-SME-66.04 Inspection of the Reactor Trip Switchgear 10

(RTTSG) Breakers

EN-AA-106 RENEWED LICENSE PROGRAM 8

EN-AA-203-1001 OPERABILITY DETERMINATIONS / 38

FUNCTIONALITY ASSESSMENTS

EN-AA-206 Renewed License Process 13

Inspection Type Designation Description or Title Revision or

Procedure Date

ENG-CSI-XCI-100 EXTERNAL CORROSION (XCI) 2

MONITORING PROGRAM FOR

INSULATED PIPING FOR PSL AND PTN

LICENSE RENEWAL

ER-AA-100-2002 MAINTENANCE RULE PROGRAM 12

ADMINISTRATION

ER-AA-201-2002 SYSTEM PERFORMANCE MONITORING 7

MA-AA-101-1000-F01 FME Risk Determination Checklist 16

MA-AA-200 FIN Team Process 11

MA-AA-203-1001 Work Order Planning 27

OP-AA-108-1000 OPERATOR CHALLENGES PROGRAM 8

MANAGEMENT

OPS-529 OPERATIONS DEFICIENCY AND 17

TAGGING POLICY

PI-AA-100-1005 Root Cause Analysis 26

PI-AA-100-1005-F03 Nuclear Safety Culture Evaluation Form

PI-AA-1003 Sharing Operating Experience with Nuclear 15

Industry

PI-AA-102 Operating Experience Program 20

PI-AA-102-1000 Significant Operating Experience Report 21

(SOER) and INPO Event Report (IER)

Process Implementation

PI-AA-102-1001 Operating Experience Program Screening 28

and Responding to Incoming Operating

Experience

Pl-AA-100-1007 Issue Investigation 28

PSL-BFJR-13-001 Risk Significance Determination of SSCs for 3

St. Lucie Units 1 & 2

Self-PSL 19-009 St. Lucie Nuclear Assurance Report - 2/6/2020

Assessments Performance Improvement

PSL 20-005 St. Lucie Nuclear Assurance Report - 8/6/2020

Operations

PSL 20-006 St. Lucie Nuclear Assurance Report - 7/9/2020

Maintenance and Work Management

Inspection Type Designation Description or Title Revision or

Procedure Date

PSL 21-003 St. Lucie Nuclear Assurance Report - 04/28/2021

Access Authorization/Fitness for Duty

PSL 21-004 St. Lucie Nuclear Assurance Report - QA 5/20/2021

Programs and Records Management

PSL 21-005 St. Lucie Nuclear Assurance Report - 06/30/2021

Engineering

PSL 21-009 St. Lucie Nuclear Assurance Report - 12/15/2021

Training

PSL 21-010 St. Lucie Nuclear Assurance Report - 2/4/2022

Performance Improvement

PSL 22-003 St. Lucie Nuclear Assurance Report - 4/8/2022

Radiation Protection

Work Orders 40822051 40822561 40692228

40823167 40824133 40723987

40627600 40353539 40704676

40601214 40641402 40704677

40731950 40785620 40712479

40713819 94218741 40792125

11