IR 05000335/2024001

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Integrated Inspection Report 05000335/2024001 and 05000389/2024001
ML24131A103
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 05/10/2024
From: Renee Taylor
NRC/RGN-II/DRP/RPB3
To: Coffey B
Florida Power & Light Co
References
IR 2024001
Download: ML24131A103 (17)
v • d • e


Text

SUBJECT:

ST LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2024001 AND 05000389/2024001

Dear Bob Coffey :

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St Lucie Units 1 & 2. On April 18, 2024, the NRC inspectors discussed the results of this inspection with Mr. Rob Craven, Site Vice President, 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. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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 cross-cutting aspect assignment 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.May 10, 2024 B. Coffey 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.

Sincerely, Ryan C. Taylor, 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: 05000335/2024001 and 05000389/2024001

Enterprise Identifier: I-2024-001-0034

Licensee: Florida Power & Light Company

Facility: St Lucie Units 1 & 2

Location: Jensen Beach, FL 34957

Inspection Dates: January 01, 2024, to March 31, 2024

Inspectors: S. Battenfield, Operations Engineer P. Cooper, Senior Reactor Inspector J. Hickman, Senior Resident Inspector D. Johnson, Senior Emergency Preparedness Specialist K. Kirchbaum, Senior Operations Engineer R. Reyes, Project Engineer S. Roberts, Project Engineer C. Rosales-Cooper, Emergency Preparedness Inspector J. Walker, Senior Emergency Preparedness Inspector

Approved By: Ryan C. Taylor, 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 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

Failure to Provide Adequate Respiratory Protection Equipment for Emergency Response Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.3] - Change 71114.01 Preparedness NCV 05000335,05000389/2024001-01 Management Open/Closed The inspectors identified a Green, NRC identified, non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50.47(b)(10), 50.54(q), and 20.1703(e), for failure to provide adequate respiratory protection equipment for emergency response. Specifically, the licensee failed to provide adequate vision correction for new respirator masks that replaced a design where the provided vision correction was adequate.

Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71114.04 NCV 05000335,05000389/2024001-02 Open/Closed The inspectors identified a Severity Level IV (SL-IV) non-cited violation (NCV) (NRC identified) of Title 10 of the Code of Federal Regulations, Part 50.54(q)(3), for changes made to the St. Lucie Radiological Emergency Plan (E-Plan) that failed to demonstrate the changes would not reduce the effectiveness of the E-Plan. Specifically, the licensee did not provide an adequate analysis to demonstrate that the changes made to the definition of a radiological release used in their off-site notification process was not a reduction in effectiveness of the Saint Lucie E-Plan. Additionally, when a detailed evaluation was performed, the analysis showed a reduction of effectiveness of the E-Plan. This revision was approved on August 8, 2023.

Additional Tracking Items

None

PLANT STATUS

Unit 1 began the inspection period at or near rated thermal power (RTP). The unit was shut down for planned refueling outage, SL1-32, on March 9, 2024, and remained shut down for the remainder of the inspection period.

Unit 2 began the inspection period at or near RTP. The unit was shut down for safety injection tank leakage, on January 3, 2024. The unit was restarted on January 9, 2024, and was returned to RTP on January 11, 2024, and remained 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 activities described in IMC 2515, Appendix D, 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

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of cold temperatures, in accordance with 0-NOP-99-06 Cold Weather Preparations, for the following systems on January 21, 2024:

1. Moisture Separator and Feedwater Heater Drains 2. Emergency Diesel Generators (EDGs)3. Aux Feedwater (AFW)

Impending Severe Weather Sample (IP Section 03.02)

The inspectors evaluated the adequacy of the overall preparations to protect risk significant systems from impending severe weather, tornado warning on January 15, 2024.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2, 2A EDG while the 2B EDG was out of service (OOS) for critical maintenance management (CMM) from January 16-17, 2024
(2) Unit 2, 2B containment spray pump (CSP) while the 2A CSP was OOS for maintenance on February 06, 2024
(3) Unit 2, 2B and 2C auxiliary feedwater (AFW) pumps while the 2A EDG was OOS for testing February 15, 2024
(4) Unit 2, 2A low pressure safety injection (LPSI) pump while the 2B LPSI pump was OOS for testing on February 22, 2024

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the unit 2A and 2B AFW pumps February 2nd through February 16th, 2024.

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) Unit 2 Fire Zone (FZ) 52, cable spreading room and the safety-related 4160-Volt switchgear rooms on February 9, 2024
(2) Unit 2 FZ-37, A switchgear room on March 19, 2024
(3) Unit 2 FZ-6, auxiliary feedwater pump steam trestle on March 19, 2024
(4) Unit 1 FZ-1, auxiliary feedwater pump steam trestle on March 19, 2024
(5) Unit 1 FZ-57/57B, cable spreading room and static inverter room on March 19, 2024

===71111.08P - Inservice Inspection Activities (PWR)

The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities during the Unit 1 refueling outage from March 18 -

21, 2024.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===

Main article: IP 71111.08

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic Examination

Liquid Penetrant Examination

  • Chemical & Volume Control, Valve SA-351 to Pipe SA-312, ASME Class 2 (reviewed)

PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the license conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Bare Metal Visual of Reactor Vessel Closure Head, N-729-6 (video review)

PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1)

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:
  • Shut down to mode 5 of Unit 2 for the repair of safety injection tank (SIT) vent valve V3801, on January 3, 2024
  • Startup of Unit 2 following repairs of SIT vent valve V3801, on January 11, 2024.
  • Plant shutdown and commence of cooldown for outage SL1-32, on March 9, 2024
  • Reactor system drain down from 41 ft level to 35 ft level (Lowered Inventory)for reactor head de-tensioning.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator continuing training evaluation in the control room simulator on January 23, 2024

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) 02458513 and WO 40883261 and 40788090, "C" Wide Range Nuclear Instruments inoperable due to spiking troubleshoot and repair, completed review on March 29, 2024

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) WO 40969731, Unit 1A LPSI pump radial bearing replacement, bearing housing repairs, and motor replacement, review completed March 27, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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 2, elevated risk while the 2B EDG was OOS for CMM from January 16-17, 2024
(2) Unit 2, elevated risk while the: 2A CSP; MV-08-19A, atmospheric dump valve; and MV-08-15, atmospheric dump valve block valve were OOS for maintenance on February 6, 2024
(3) Unit 1 elevated risk while the 1A CSP was OOS on February 13, 2024
(4) Unit 1 and Unit 2 online risk while Unit 2 was on elevated risk due to the 2A EDG being OOS during a fast start and 24-hour loaded run on February 15, 2024
(5) Unit 1 outage risk evaluation per ADM-09.23. Elevated risk due to reactor coolant system lowered inventory, core cooling due to loops not filled, containment due to containment being open with dedicated plus closure crew, and fuel pool cooling due to A train fuel pool cooling pump being on OOS for outage work. All conditions associated with plant shutdown and cooldown for planned refueling outage SL1-32. March 11-13, 2024

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) AR 02475748, through-wall leak upstream of the Unit 2 2A2 safety injection tank (SIT) vent valve V3801, review completed January 5, 2024
(2) AR 02477877, packing leak on valve V59134, isolation valve for startup air tank for 2B EDG, review completed February 2, 2024
(3) AR 02478123, Unit 2 Thermal Margin Low Pressure (TMLP) module failure in channel "C" reactor protection system, review completed February 8, 2024
(4) AR 02480170, Unit 2 "A" intake cooling water pump, during the quarterly pump code run, increased vibrations into the alert range, review completed March 1, 2024
(5) AR 02480925, Unit 1 "A" EDG failed safeguards testing due to exceeding breaker closure time of 10 seconds (actual time was 52 seconds), review completed March 12, 2024

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering change 299278, Unit 2 SIT vent valve V3801 replacement (3/4 inch to one inch), review completed on January 19, 2024
(2) Engineering change 297116, 1C charging pump casing inspection plate oil access, review completed on February 06, 2024

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated the Unit 2, 2A2 SIT vent valve V3801 leak/replacement, forced outage activities from January 3, 2024, to January 11, 2024.
(2) The inspectors evaluated refueling outage SL1-32 activities from March 9, 2024, through March 31, 2024.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)

(1) WO 40790965, engineering change 299278, Unit 2 SIT vent valve V3801 replacement (3/4 inch to one inch), review completed on January 11, 2024
(2) 1-OSP-02.01C, 1C charging pump code run after completing: EC 297116, 1C charging pump casing inspection plate oil access; coupling inspection and lubrication; and replacement of suction and discharge valves per WO 40875624, review completed on February 05, 2024
(3) 2-OSP-02.01A, 2A charging pump code run, after repairing the pump's motor operating discharge valve and completing preventive maintenance on the pump per WO 4085509503, review completed on February 21, 2024
(4) 2-OSP-99.08A, A train quarterly non-check valve cycle test, after performing stem lube & full actuator inspection of atmospheric dump block valve (2-MV-08-15) per WO

===40848808, review completed on March 6, 2024

(5) 1-SMI-63.02C, RPS - monthly functional test - channel C, to perform troubleshooting and repair PR-1102C, pressurizer pressure alarm / TMLP setpoint - multiple alarms per WO 40968935, review completed on March 7, 2024
(6) 1-OSP-59.01A, 1A EDG Monthly Surveillance following K-3 replacement WO 40969273, review completed on March 14, 2024

Surveillance Testing (IP Section 03.01)===

Main article: IP 40848
(1) 1-OSP-59.01A, 1A EDG Monthly Surveillance, review completed on January 4, 2024
(2) 2-OSP-69.14B, ESF-Surveillance for EDG Start on SIAS Without Loop and 24-Hour Load Run - Train B, review completed on January 23, 2024
(3) 1-SMM-08.08, Main Steam Safety Valve Setpoint Surveillance Using Furmanite Trevitest Mark VIII Equipment, review completed on March 11, 2024
(4) 1-OSP--69.13A, ESF-Staggered 36 Month Surveillance for SIAS/CIS/CSAS - Train A, review completed on March 12, 2024
(5) 1-OSP0.03.17, Stroke Testing of the SIT Discharge and SI Loop Check Valves, review completed on March 13, 2024

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) 1-GOP-305, Attachment 1, Boratian Flow Path Surveillance, review completed on March 11, 2024.
(2) 1-OSP-03.01A, 1A HPSI Pump Safeguards Full Flow Test, review completed on March 13, 2024

Containment Isolation Valve (CIV) Testing (IP Section 03.01)

1-OSP-68.02, Local Leak Rate Test, Section 4.5, Penetration 7 - Primary Water, review completed on March 19, 2024.

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Sample)

(1) The inspectors evaluated the biennial emergency plan exercise during the week of February 12, 2024. The simulated scenario began with an increase in Unit 2s reactor coolant activity above the Unusual Event dose equivalent Iodine-131 threshold. Later, conditions for declaring an Alert were met when a minor tube leak developed in one of Unit 2s steam generators. Subsequently, after the tube leak degraded, the operators manually tripped the reactor. Multiple control element assemblies failed to fully insert, resulting in rising indications on containment radiation monitors. With increased flow from the tube rupture, multiple control rods stuck out of the reactor core and increased radiation monitor readings (indicative of fuel clad barrier loss), the conditions for declaring a Site Area Emergency were met. When a main steam safety valve failed open, conditions for a General Emergency were met, and the Offsite Response Organizations were able to demonstrate their ability to implement emergency actions.

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of February 12, 2024.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of February 12, 2024. This evaluation does not constitute NRC approval.

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed and evaluated in-office, the proposed scenario for the biennial emergency plan exercise at least 30 days prior to the day of the exercise.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

Main article: IP 71151
(1) Unit 1 (January 1, 2023 - December 31, 2023)
(2) Unit 2 (January 1, 2023 - December 31, 2023)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 1 (January 1, 2023 - December 31, 2023)
(2) Unit 2 (January 1, 2023 - December 31, 2023)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 (January 1, 2023 - December 31, 2023)
(2) Unit 2 (January 1, 2023 - December 31, 2023)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) October 1, 2022, through December 31, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
(1) October 1, 2022, through December 31, 2023

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) October 1, 2022, through December 31, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) AR 2466026 and referenced ARs related to previously identified missed technical specification surveillance in multiple areas. AR 2456059, 2462402, 246045, 2465826, 2465933, 2461177, 2461229, and 2480036. AR 2480036 occurred following the completion of the corrective action for AR 2466026. It was selected for follow-up to verify the licensees extent of condition and corrective actions were adequate to prevent missed technical specification surveillances.

INSPECTION RESULTS

Failure to Provide Adequate Respiratory Protection Equipment for Emergency Response Cornerstone Significance Cross-Cutting Report Aspect Section Emergency Green [H.3] - Change 71114.01 Preparedness NCV 05000335,05000389/2024001-01 Management Open/Closed The inspectors identified a Green, NRC identified, non-cited violation (NCV) of Title 10 of the Code of Federal Regulations, Part 50.47(b)(10), 50.54(q), and 20.1703(e), for failure to provide adequate respiratory protection equipment for emergency response. Specifically, the licensee failed to provide adequate vision correction for new respirator masks that replaced a design where the provided vision correction was adequate.

Description:

While observing the licensees emergency response organizations (ERO)performance during the biennial exercise, inspectors observed the initial emergency responders to staff the offsite field teams did not have adequate vision correction. These field teams were then replaced by an additional mechanic who responded for a different position, and who did not require vision correction.

After the exercise, the inspectors interviewed the staff and discovered that the previous masks were replaced prior to the exercise without ensuring that the appropriate vision correction was also replaced. This effected the performance of the emergency workers during the exercise, but also had the potential to compromise the protective actions developed for the plume exposure pathway for emergency workers during a radiological emergency.

Corrective Action References: AR 02484131, NRC Identified Green Non-cited violation for the licensee's failure to provide adequate vision correction for the new respirator masks.

Performance Assessment:

Performance Deficiency: The licensees failure to provide adequate vision correction for the new respirator masks that replaced the previous design where the provided vision correction was adequate effecting emergency response of the ERO.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors determined the performance deficiency was more than minor because it was associated with the Emergency Preparedness Cornerstone, and if left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern. In that, emergency responders having inadequate vision while wearing the newer masks could challenge the licensees state of operational readiness and emergency response capabilities during a radiological emergency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. The inspectors assessed the significance of the finding using IMC 0609, Attachment B, "Emergency Preparedness Significance Determination Process" and determined to be of very low safety significance because this failure to comply represented a planning standard issue, however, it did not result in a risk-significant planning standard nor was it indicative of a planning standard functional failure as the pool of qualified personnel contained staff that did not need vision correction.

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

The licensee did not ensure that personnel, equipment, procedures, and other resources are available for adequate support of nuclear safety. In addition, the licensee did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

Enforcement:

Violation: Violation: Title 10 of the Code of Federal Regulations, Part 50.47(b)(10) requires, in part, that guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place.

10 CFR 50.54(q)(2) requires, in part, that licensees shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E.

10 CFR 50.54(q)(3) requires, in part, that licensees may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements in appendix E.

10 CFR 20.1703(e) requires, in part, that licensees when selecting respiratory devices the licensee shall provide for vision correction, adequate communication, low temperature work environments, and the concurrent use of other safety or radiological protection equipment.

Contrary to the above, on January 15, 2024, the licensee failed to provide adequate respiratory protection equipment for emergency response. Specifically, the licensee failed to provide adequate vision correction for new respirator masks that replaced a design where the provided vision correction was adequate.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Adequately Document the Basis for a Change to an Emergency Plan Implementing Procedure Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71114.04 Applicable NCV 05000335,05000389/2024001-02 Applicable Open/Closed The inspectors identified a Severity Level IV (SL-IV) non-cited violation (NCV) (NRC identified) of Title 10 of the Code of Federal Regulations, Part 50.54(q)(3), for changes made to the St. Lucie Radiological Emergency Plan (E-Plan) that failed to demonstrate the changes would not reduce the effectiveness of the E-Plan. Specifically, the licensee did not provide an adequate analysis to demonstrate that the changes made to the definition of a radiological release used in their off-site notification process was not a reduction in effectiveness of the Saint Lucie E-Plan. Additionally, when a detailed evaluation was performed, the analysis showed a reduction of effectiveness of the E-Plan. This revision was approved on August 8, 2023.

Description:

While performing a detailed review of a change to the St. Lucie E-Plan, the inspectors identified that the 50.54(q) change documentation for EPIP-08, Off-Site Notifications and Protective Action Recommendations, Rev. 58, did not adequately assess whether the changes were a reduction in effectiveness to the E-Plan. The licensee provided a white paper on the change to the definition of a radiological release, to provide additional information not in the 50.54 q evaluation. The inspectors review of the white paper determined that the changes made would reduce the effectiveness of the E-Plan, since the settings of the effluent monitors, which defines a radiological release, were changed to higher values and thus would delay the notification to the state and counties that a radiological release had occurred.

Corrective Actions: The licensee entered this violation into the corrective action program.

Corrective Action References: AR 02483734, NRC SLIV Violation for Inadequate 50.54(q)

Performance Assessment:

The licensees failure to provide an adequate analysis demonstrating that changes to EPIP-08, Off-Site Notifications and Protective Action Recommendations was a performance deficiency. The performance deficiency did not result in a reduction in effectiveness but was determined to impede the NRCs ability to perform its regulatory function and was dispositioned using the Traditional Enforcement process. The inspectors determined the performance deficiency was more than minor because it impacted the NRCs ability to perform its regulatory function; therefore, traditional enforcement is applicable in accordance with Inspection Manual Chapter (IMC) 0611. The inspectors assessed the significance of the finding using Appendix B, Emergency Preparedness SDP.

Enforcement:

Severity: This finding is a violation of NRC requirements because it had the potential for impacting the NRCs ability to perform its regulatory function. Therefore, traditional enforcement is applicable, in accordance with Inspection Manual Chapter 0611 and 0612, Appendix B, Figure 2. This finding is determined to be a SL-IV violation in accordance with Section 6.6.d of the Enforcement Policy because it involves the licensees ability to meet or implement a regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan is reduced. The finding was determined to be not greater than SL-IV since the reduction of effectiveness was minor, due to the defined radiological release setpoints were still well below protected action guidelines.

Violation: Title 10 of the Code of Federal Regulations, Part 50.54(q)(3) states, in part, that a licensee may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan and the plan, as changed, continues to meet the requirements in Appendix E to this part. Contrary to the above, as of August 8, 2023, the licensee failed to perform an adequate analysis demonstrating that changes to their E-Plan did not reduce the effectiveness of the plan. Specifically, the licensee did not provide an adequate analysis to demonstrate that the changes made to the setpoints that define a radioactive release used in their off-site notification process was not a reduction in effectiveness of the St. Lucie E-Plan.

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 April 18, 2024, the inspectors presented the integrated inspection results to Mr. Rob Craven, Site Vice President, and other members of the licensee staff.
  • On March 21, 2024, the inspectors presented the In-Service Inspection results to Mr.

Rob Craven, Site Vice President, and other members of the licensee staff.

  • On February 15, 2024, the inspectors presented the Emergency Preparedness Exercise Inspection Exit Meeting inspection results to Mr. Rob Craven, Site Vice president, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71114.01 Procedures Emergency Action Level Matrix (HOT) Rev. 9

Emergency Action Level Matrix (COLD) Rev. 7

EPIP-01 Classification of Emergencies Rev. 30

EPIP-03 Emergency Response Organization Notification/Staff Rev. 30

Augmentation

71114.04 Miscellaneous 10 CFR 50.54(q) Screening and Evaluation Forms for EPIP- 04/07/2022

14, "Dose Assessment Using the Unified Rascal Interface,"

Rev. 12

PCR/AR/NAMS 50.54(q) Screen & Evaluation for EPIP-08 Rev. 56 10/25/2022

No. 2412158,

22697,

22574

PCR/AR/NAMS 50.54(q) Screen & Evaluation for EPIP-08 Rev. 57 03/30/2023

No. 2451308

PCR/AR/NAMS 50.54(q) Screen & Evaluation for EPIP-08 Rev. 58 08/25/2023

No. 2464619

Procedures St. Lucie Plant Radiological Emergency Plan Rev. 76

Emergency Action Level Technical Bases Document 03/05/2021

EP-AA-100-1007 Evaluation of Changes to the Emergency Plan Supporting Rev. 10

Documents and Equipment (10CFR50.54(Q))

EPIP-08 Off-Site Notifications and Protective Action Rev. 58

Recommendations

EPIP-08 Offsite Notifications and Protective Action RecommendationsRev. 57

EPIP-08 Offsite Notifications and Protective Action RecommendationsRev. 56

EPIP-08 Offsite Notifications and Protective Action RecommendationsRev. 55

EPIP-08 Offsite Notifications and Protective Action RecommendationsRev. 54

EPIP-14 Dose Assessment Using the Unified RASCAL Interface Rev. 13

14

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