IR 05000335/2024003
| ML24311A118 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/07/2024 |
| From: | Tom Stephen NRC/RGN-II/DORS/PB6 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2024003 | |
| Download: ML24311A118 (18) | |
Text
SUBJECT:
SAINT LUCIE PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000335/2024003 AND 05000389/2024003
Dear Bob Coffey:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Saint Lucie Plant, Units 1 and 2. On October 21, 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. 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 Saint Lucie Plant, Units 1 and 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 Saint Lucie Plant, Units 1 and 2.
November 7, 2024 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, Thomas A. Stephen, Chief Projects Branch 6 Division of Operating Reactor Safety 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:
05000335/2024003 and 05000389/2024003 Enterprise Identifier:
I-2024-003-0027 Licensee:
Florida Power & Light Company Facility:
Saint Lucie Plant, Units 1 and 2 Location:
Jensen Beach, FL 34957 Inspection Dates:
July 01, 2024 to September 30, 2024 Inspectors:
S. Bruneau, Resident Inspector P. Cooper, Senior Reactor Inspector J. Diaz-Velez, Senior Health Physicist J. Hickman, Senior Resident Inspector J. Rivera, Health Physicist S. Roberts, Project Engineer S. Sandal, Senior Reactor Analyst T. Steadham, Senior Resident Inspector Approved By:
Thomas A. Stephen, Chief Projects Branch 6 Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Saint Lucie Plant, Units 1 and 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 Correct a Degraded Condition on the Unit 1B Intake Cooling Water (ICW) Header Inlet Strainer Bypass Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335/2024003-01 Open/Closed
[P.3] -
Resolution 71152A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly correct long-term degradation of intake cooling water (ICW) piping due to corrosion.
This condition led to significant through-wall leakage of safety-related piping and Unit 1 entry into risk-informed completion time (RICT) for various technical specification (TS) action statements.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000389/2024-003-00 LER 2024-03-00 for St.
Lucie, Unit 2, Unplanned Reactor Scram 71153 Closed LER 05000389/2024-002-01 LER 2024-002-01, Unit 2,
Safety Injection Tank Vent Through Wall Leakage 71153 Closed
PLANT STATUS
Unit 1 began the inspection period at or near rated thermal power (RTP). The unit was shut down due to a reactor trip from the main steam isolation valve, HCV-08-1A, spurious trip. The unit was restarted on August 4, 2024, and was returned to RTP on August 5, 2024, and remained at or near RTP for the remainder of the inspection period.
Unit 2 began the inspection period at or near RTP. The unit was down powered to 92 percent on August 28, 2024, and then to 80 percent on August 29, 2024, to support early work on main condenser water boxes in the preparation for the SL2-28 outage. The unit was shut down for planned refueling outage, SL2-28, on August 31, 2024, and remained shut down 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
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 Helene, on September 25 - 27, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 auxiliary feedwater (AFW) system and 1A emergency diesel generator (EDG)during and following the 1A EDG 24-hour load run on August 8, 2024
- (2) Unit 2 shutdown cooling system while in operation for decay heat removal on September 4, 2024
- (3) Unit 2 component cooling water (CCW) system while in Mode 5 for valve lineup of fuel pool cooling, 2B high pressure safety injection (HPSI) bearing cooling, and CCW surge tank, on September 30, 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) 51E and 51W, auxiliary building elevation 19.5' on July 18, 2024
- (2) Unit 2, FZ 22 and 23, electrical penetration rooms 2A and 2B elevation 19.5' on July 18, 2024
- (3) Unit 1 FZ 5, CCW area on September 6, 2024
- (4) Unit 2 FZ 3, CCW area on September 6, 2024
- (5) Unit 2 FZ 19, reactor auxiliary building (RAB) -0.5ft east hallway and miscellaneous equipment rooms, and Unit 2 FZ 20, RAB -0.5ft east-west common hallway areas on September 6, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade performance during an actual event for a small fire in Saint Lucie Unit 1, B iso-phase bus duct (IPBD) cooling fan motor on September 11, 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 in Unit 2 during the refueling outage from September 9 - 12, 2024.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination were performed appropriately:
- (1) Ultrasonic Examination
- Shutdown Cooling Elbow to Pipe and Elbow Base Material, RC-162-1-SW-4 (MRP-146) ASME Class 1, observed Visual Examination
- Metallic Containment Shell Plate (Containment Side) Zone 4 - PSL2-21-VT-1054 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) AR 0249071, Reg Heat Exchanger Inlet Valve
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:
- Unit 1 startup and power ascension activities following inadvertent main steam isolation valve closure and repairs on August 3, 2024
- A planned power reduction and shutdown of Unit 2 to support refueling outage SL2-28 on August 30-31, 2024
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 July 22, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) AR 02488945, 1B emergency diesel generator 1B2 AC soak-back pump failed, review completed on September 19, 2024
- (2) AR 02494517, Maintenance rule a(1) action plan for Unit 2 instrument air compressors, review completed on September 24, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Protected system lineup while Unit 1 AFW train 1B was out of service for planned maintenance on July 22, 2024
- (2) Guarded equipment lineup while 2A EDG was out of service for planned maintenance (WO 4087716702) on the air start system on August 12, 2024
- (3) Unit 2 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 out of service for outage work. All conditions associated with plant shutdown and cooldown for planned refueling outage SL2-28 on August 31 - September 4, 2024.
- (4) Unit 2 yellow shutdown safety assessment (SSA) with the 2A EDG inoperable and spent fuel cooling with two trains not independent power supplies on September 12 - 17, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2491253, Unit 1 reactor protective system (RPS) cabinet B Axial Shape Index (ASI) indication dropped to zero, review completed on July 26, 2024
- (2) AR 2493085, Unit 1 charging system suction pipe non-destructive ultrasonic examination identified pin hole leaks, review completed on August 26, 2024
- (3) AR 2493873, Unit 2 HVE-13A control room emergency ventilation system charcoal lab test failure, review completed on August 30, 2024
- (4) AR 02495994, Unit 1 power operated relief valve internal magnetic rod is weak and requires replacement, review completed on September 25, 2024
- (5) AR 02496219, Unit 2 D wide range nuclear instrument channel is not channel checking, review completed on September 27, 2024
- (6) AR 02496412, Unit 2 main steam isolation system relay exhibited chatter, review completed on September 30, 2024
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 299537, St. Lucie 2 In-core Instrument Assemblies with Rhodium emitter detectors replacement with Vanadium Emitter models, review completed on September 21, 2024
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage SL2-28 activities from August 31, 2024, through September 30, 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) (8 Samples)
(1)1-OSP-99.08A, A Train Quarterly Non-Check Valve Cycle Test, after Stem Lube and Full Actuator Inspection on MV-09-9 1A Auxiliary Feedwater (AFW) Pump Discharge to 1A Steam Generator, WO 40887166, review completed on June 11, 2024
- (2) Reactor protection system cabinet B axial shape index, troubleshoot indication reading low, WO 40985596, review completed on July 24, 2024
- (3) Stem lube and actuator electrical inspection on MV-09-10, 1B AFW Pump Discharge to 1B Steam Generator, WO 40887167, review completed on July 30, 2024
- (4) WO 40986291-15, Test/replace Unit 1 K627A relay, review completed on August 3, 2024
- (5) WO 40877167, Replace Unit 2A EDG relief valves for start-up air tanks, review completed August 13, 2024
- (6) WO 40982206, Unit 2B intake cooling water pump motor replacement, review completed on August 22, 2024 (7)2-OSP-69.14A, EDG Start on Safety Injection Actuation System (SIAS) Without LOOP and 24-Hour Load Run-Train A, following maintenance on 2A EDG, review completed on September 17, 2024
- (8) WO 40642569-01, U2 RE-001-B2 DET #11; Replace Wide Range Due to End of Life; and WO 40876266-01. TS/FYP8047B/NIS CALS CHANNEL B, review completed on September 27, 2024
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)2-OSP-59-01A, 2A Emergency Diesel Generator monthly surveillance, review completed on June 9, 2024 (2)1-OSP-59.01B, 1B Emergency Diesel Generator monthly surveillance, review completed on July 16, 2024 (3)1-OSP-69.14A, ESF - 18 Month Surveillance for EDG Start on SIAS Without LOOP and 24-Hour Load Run - Train A, review completed on August 9, 2024 (4)2-OSP-69.13A, ESF-Staggered 36 Month Surveillance for SIAS/CIS/CSAS - Train A, review completed on September 6, 2024
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1)2-OSP-68.04, Purge Valve Leak Rate Test, Penetration 56 - Hydrogen Purge Exhaust, review completed on September 29, 2024
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
(1)0-OSP-83.04, Periodic Testing of the Flex 480V DG A, review completed on July 9, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) On July 18, 2024, the inspectors evaluated an emergency response drill that included an unisolable steam line break, a failure to manually trip the reactor, loss of offsite power, an emergency diesel generator failure, and a steam generator tube rupture. The scenario included situations that resulted in declarations of Unusual Event, Alert, and Site Area Emergency.
Additional Drill and/or Training Evolution (1 Sample)
- (1) On July 3, 2024, the inspectors evaluated a licensed operator continuing training simulator evaluation that included a small break loss of coolant accident resulting in an Alert declaration and notification to the Florida State Watch Officer and St Lucie and Martin County Emergency Operations Centers.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Workers exiting the radiologically controlled area (RCA) during Unit 2 refueling outage
- (2) Workers and potentially contaminated items exiting Unit 2 containment during Unit 2 refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Unit 2 reactor containment building (RCB) under reactor vessel head inspection, radiation work permit (RWP) no. 24-3350, Rev. 0
- (2) Unit 2 RCB valve V3667 testing, RWP no. 24-2515, Rev. 0
- (3) Unit 2 RCB reactor coolant pump (RCP) 2B2 seal removal, RWP no. 24-3450, Rev. 1
- (4) Unit 2 RCB top of pressurizer insulation removal, RWP no. 24-3419, Rev. 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
- (1) Unit 1 and Unit 2 drumming rooms
- (2) Unit 1 and Unit 2 letdown pipe galleries Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) U2 RAB 19.5' Calibration Laboratory
- (2) U1 RAB 19.5' Electrical Penetration Room
- (3) Blowdown Building 1st Floor I&C Shop
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Unit 1, Reactor Auxiliary Building Drumming Station (DTS System and associated equipment)
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
(1)10 CFR Part 61 analysis for 2023 Dry Active Waste (Sample ID 609064004),01/25/2023 (2)10 CFR Part 61 analysis for 2022 Dry Active Waste (Sample ID 552882002),08/04/2021 (3)10 CFR Part 61 analysis for 2020 U2 SRT Resin (Sample ID 510251001), 04/15/2020
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed the receipt of HPS-264 shipment (pressurizer code safety valves).
Shipping Records (IP Section 03.05) (5 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Shipment PSL 22-076, UN3321, Radioactive Material, Low Specific Activity (LSA-II),
- (2) Shipment PSL 23-027, UN3321, Radioactive Material, Low Specific Activity (LSA-II),
- (3) Shipment PSL 23-085, UN2915, Radioactive Material, Type A package, 7
- (4) Shipment PSL 24-037, UN3321, Radioactive Material, Low Specific Activity (LSA-II),
- (5) Shipment PSL 24-048, UN3321, Radioactive Material, Low Specific Activity (LSA-II),
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1, July 1, 2023 through June 30, 2024
- (2) Unit 2, July 1, 2023 through June 30, 2024
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) February 1, 2023 through September 13, 2024 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) February 1, 2023 through July 1, 2024
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unit 1 intake cooling water (ICW) rupture investigation (AR 02486981) was selected for follow-up to verify the licensees extent of condition, causal analysis, and corrective actions were adequate to resolve the deficiencies and mitigate recurrence of through wall leaks, review completed on September 17, 2024
- (2) Unit 2 B2 circulating water pump (CWP) tripped upon opening 2A2 CWP discharge outlet valve resulting in lowering condenser vacuum and a subsequent reactor trip (AR.02487833) was selected for follow-up to verify the licensees extent of condition, causal analysis, and corrective actions were adequate to resolve the deficiencies and mitigate recurrence of CWP trips, review completed on September 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in Fire Protection Equipment, 12 month and 18 month testing, that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) LER 05000389/2024-003-00, Unplanned Reactor Scram (ADAMS Accession:
ML24218A080). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred. This LER is Closed.
- (2) LER 05000389/2024-002-01, Safety Injection Tank Vent Line Through Wall Leakage (ADAMS Accession No. ML24194A149). The inspectors determined that the revision of the LER identified no additional performance deficiencies. The inspectors also concluded that no additional violations of NRC requirements occurred other than the non-cited violation 05000389/2024002-01 previously documented in Saint Lucie Units 1 & 2 - Integrated Inspection Report 05000335/2024002 and 05000389/2024002. This LER is Closed.
INSPECTION RESULTS
Failure to Correct a Degraded Condition on the Unit 1B Intake Cooling Water (ICW) Header Inlet Strainer Bypass Piping Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335/2024003-01 Open/Closed
[P.3] -
Resolution 71152A A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly correct long-term degradation of intake cooling water (ICW) piping due to corrosion.
This condition led to significant through-wall leakage of safety-related piping and Unit 1 entry into risk-informed completion time (RICT) for various technical specification (TS) action statements.
Description:
On May 23, 2024, during restoration of the 1B component cooling water (CCW)heat exchanger following maintenance, the ICW header inlet strainer bypass piping (20-CW-97) ruptured. The failure of this safety-related piping resulted in Unit 1 entry into RICT for various TS action statements (3.5.2.A, 3.5.2.B, 3.6.6.A, 3.6.6.B, 3.6.6.D, 3.7.7.A and 3.7.8.A).
Investigation revealed that corrosion of the 20-CW-97 piping had been identified on multiple occasions since 2013.
On August 22, 2013, external corrosion on the 20-CW-97 piping was initially identified and documented in action request (AR) 1898890 and closed to work order (WO) 40269865 to restore protective coatings on the subject piping. This work order was not planned or set to active status until November 2016.
In March of 2018, during the SL1-28 outage, the Unit 1 ICW system license renewal (LR)walkdown was performed per WO 40502846. This WO tracked previous AR 1898890 / WO 40269865-01 and identified further degradation of the 20-CW-97 piping. Following the LR walkdown, AR 02256310 / WO 40593738 was generated to ensure the repair scope addressed the further degraded condition.
In April 2019, the affected 20-CW-97 (carbon steel) piping was scraped/cleaned, and Denso Tape applied under WO 40593738 (i.e., a temporary repair to arrest corrosion until a permanent repair could be performed). Denso Tape is an approved temporary coating in accordance with safety-related specification SPEC-C-004, "Protective Coatings for Areas Outside the Reactor Containment." WO 40269865 (original 2013 repair WO) was closed to the completion of WO 40593738 (Denso Tape temporary repair).
Contrary to SPEC-C-004, WO 40593738 instructions did not include a step to initiate a new work order for application of a permanent coating product, or a step for the Nuclear Coatings Specialist to review and sign off on the application of the Denso products.
The licensee completed an issue investigation and also determined that, although the affected area is within a walled region with limited accessibility, a gap existed in the process of system monitoring. The ownership of routine walkdowns and monitoring was recently transferred from Engineering to Operations in 2022/2023.
Corrective Actions: The licensee entered these issues in their corrective action program and performed a walkdown of all Unit 1 and Unit 2 safety-related piping and identified all temporary Denso Tape repairs. The licensee reviewed associated WOs to ensure permanent repair (e.g., blast & coat) WOs exist and coordinated with Fleet Strategic Reliability Engineering to ensure WOs are properly coded for priority and risk. On May 29, 2024, the licensee restored the 1B CCW heat exchanger and exited from the RICT for the various technical specification action statements through installation of a temporary modification (reference engineering change (EC) 299726), which isolated the rupture/leak by removing a portion of the 20-CW-97 bypass piping and installing a blind flange downstream where it reconnects with the 1B ICW header piping.
Corrective Action References: AR 02486981
Performance Assessment:
Performance Deficiency: The failure to correct long-term, degradation of ICW piping due to corrosion was a performance deficiency. This condition led to significant through-wall leakage of safety-related piping and Unit 1 entry into RICT for various technical specification action statements.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the ICW leakage was such that the licensee had to initiate actions to secure the 1B CCW train, as required by the restoration procedure.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, the finding was determined to be of very low safety significance (i.e., Green) because the performance deficiency did not result in an actual loss of safety system function, and it did not represent a loss of function of one or more than one train for more than its technical specification allowed RICT.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the site failed to monitor and correct the latent issues caused by corrosion of the ICW piping.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to ensure conditions adverse to quality, such as failures, deficiencies, deviations, and nonconformances are corrected.
Contrary to the above, from August 22, 2013, until May 29, 2024, the licensee failed to promptly correct long-term, degradation of safety-related ICW piping due to corrosion (a condition adverse to quality), which led to significant through-wall leakage of the subject piping.
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 October 21, 2024, the inspectors presented the integrated inspection results to Rob Craven, Site Vice President and other members of the licensee staff.
- On September 12, 2024, the inspectors presented the inservice inspection results to Rob Craven, Site Vice President and other members of the licensee staff.
- On September 12, 2024, the inspectors presented the radiation protection inspection results to Rob Craven, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fire Plans
PFP-2-RAB-19.5
UNIT 2 REACTOR AUXILIARY BUILDING
Corrective Action
Documents
Miscellaneous
Procurement
evaluation
475177
Receipt inspection and acceptance of UTC 1266888, main
steam isolation system relays, dated 5/23/2017
Work Orders
40985596,
40887167,
40986291
Miscellaneous
St. Lucie Nuclear Plant Emergency Response Organization
Drill Packet
Corrective Action
Documents
Resulting from
Inspection
09/13/2024
Radiation
Surveys
PSL-M-
230304-23
U1 RAB Drumming Station 19.5'
03/04/2023
Radiation Work
Permits (RWPs)
23-0135
Unit 1 DTS Temp Ion Exchanger Skid: Operate, Maintain
Rev. 0
Corrective Action
Documents
2438977,
2450087,
2457551, and
2482409
Various
Drawings
SLNP-2191-S-
2001
Waste Processing System (DTS System)
03/08/2015
Miscellaneous
24 Annual
Inventory
Reconciliation
Confirmation
24 Confirmation of Annual Inventory Reconciliation for
01/22/2024
Miscellaneous
N2.500025
Instrument Calibrator Preventative Maintenance Record
(performed by the manufacturer)
10/06/2023
Miscellaneous
PSL RP Training
Part 37 Training
08/28/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Records for NUC
RPT 1030
Miscellaneous
Source Leak Test
and Inventory
Form
Control, Inventory and Leak Testing of Radioactive Sources
08/07/2024