IR 05000335/2024004
| ML25029A238 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/31/2025 |
| From: | Shawn Smith Division of Operating Reactors |
| To: | Coffey R Florida Power & Light Co |
| References | |
| IR 2024004 | |
| Download: ML25029A238 (14) | |
Text
SUBJECT:
SAINT LUCIE PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000335/2024004 AND 05000389/2024004
Dear Robert Coffey:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Saint Lucie Plant, Units 1 and 2. On January 24, 2025, the NRC inspectors discussed the results of this inspection with Mr. Carlos Santos, 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.
January 31, 2025 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, Steven P. Smith, 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:
Report Numbers:
05000335/2024004 and 05000389/2024004
Enterprise Identifier:
I-2024-004-0023
Licensee:
Florida Power & Light Company
Facility:
Saint Lucie Plant, Units 1 and 2
Location:
Jensen Beach, FL 34957
Inspection Dates:
October 01, 2024 to December 31, 2024
Inspectors:
B. Bishop, Senior Project Engineer
S. Bruneau, Resident Inspector
J. Bundy, Senior Operations Engineer
J. Hickman, Senior Resident Inspector
D. Orr, Senior Project Engineer
R. Reyes, Project Engineer
M. Riley, Senior Project Engineer
Approved By:
Steven P. Smith, 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 Prescribe Preventative Maintenance Instructions for ESFAS Relays
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
NCV 05000335,05000389/2024004-01
Open/Closed
[P.2] -
Evaluation
The NRC identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, procedures, and drawings," when the licensee
failed to prescribe and accomplish procedures to meet the requirements of ASME NQA-1,
Subpart 2.18, and RG 1.33, App. A, Section 9, for the preventative maintenance of
engineered safety feature actuation system (ESFAS) relays.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
LER 2024-001-00 for St.
Lucie, Unit 1, Unplanned
Reactor Scram
Closed
05000335,05000389/20
24011-03
Operating Experience
Review of Action Request
(AR) 02439818
Closed
PLANT STATUS
Unit 1 began the inspection period at or near rated thermal power (RTP). On November 15, the
unit was shut down due to a manual reactor trip as a result of three dropped control rods during
rod control maintenance. The unit was restarted on November 17, 2024, and was returned to
RTP on November 18, 2024, and remained at or near RTP for the remainder of the inspection
period.
Unit 2 began the inspection period shut down for a planned refueling outage. On October 15,
2024, the unit was restarted, and power ascension was interrupted by let-down valve V2515
failure and down powered from 32 percent to 16 percent RTP on October 16, 2024. On October
16, 2024, the unit power was raised to 38 percent RTP and remained there due to incorrectly
located in-core vanadium detectors. On October 30, 2024, power ascension resumed following
the in-core instrument calibration, power ascension was interrupted by lowering condenser
vacuum and down powered from 93.5 percent to 74.1 percent. On October 31, 2024, power
ascension resumed, and power was raised to 94 percent and remained there for 2B2 water box
repairs. On November 5, 2024, the unit was returned to RTP, following condenser tube repairs,
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 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 Milton, on October 8
and 9, 2024.
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 1 low pressure safety injection (LPSI) 1A system lineup walkdown. 1A LPSI was
the protected train while 1B was receiving maintenance.
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 1 charging pump room and -0.5ft level main hallway, fire zones (FZ) 36A and 36,
respectively, on October 2, 2024
(2)
Unit 2 outside area between reactor auxiliary building (RAB), reactor containment
building, and turbine building, FZ 7, on October 2, 2024
(3)
Unit 1 RAB 19.5ft level, FZ 55, on October 17, 2024
(4)
Unit 2 control room air conditioner room, FZ 42, on November 14, 2024
(5)
Unit 1 switchgear room, FZ 47, on November 21, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated internal flooding mitigation protections in the Unit 1 and Unit
2 reactor auxiliary buildings at the -0.5ft levels and the engineered safeguards rooms.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
The licensee completed the annual requalification operating examinations and biennial
written 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." The inspectors performed an in-office
review of the overall pass/fail results of the individual operating examinations, the crew
simulator operating examinations, and the biennial written examinations in accordance with
Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program and
Licensed Operator Performance." These results were compared to the thresholds
established in Section 3.03, "Requalification Examination Results," of IP 71111.11.
(1)
The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam administered on November 27,
2024, and the biennial written examinations completed on December 11, 2024.
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:
1.
Unit 2 startup from refueling outage SL2-28 on October 14, 2024
2.
Unit 2 letdown isolation valve, V2515, failed closed, and the subsequent
xenon increase requiring operator actions to manipulate the plant to control
the down-power on October 15, 2024
3.
Unit 1 trip due to dropped control rods on November 15, 2024
4.
Unit 1 startup from dropped control rods trip on November 17, 2024
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated a simulator licensed operator annual
operating requalification examination on November 11, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 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)
Action request (AR) 2452183 and 2488709, Leading Edge Flow Meters (LEFM) 2A
and 2B, evaluation after low impedance failures starting March 2023 - October 2024
(2)
AR 2501702, Unit 1 Reactor Trip due to drop of 3 Control Element Assemblies,
evaluation of rod control work orders (WO) for Unit 1 and Unit 2 from 2022-2024
(3)
AR 2503251, Unit 2 "A" component cooling water (CCW) heat exchanger (HX)
cleaning, eddy current testing and inspection, review completed on December 17,
2024
(4)
AR 2501109, Unit 2 wide range nuclear instrument channel "A" failed low, review
completed on December 18, 2024
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 2 elevated risk due to pressure control valve, PCV-8802, for steam dump from
main steam header to condenser out-of-service (OOS), guarded equipment: 2A and
2B fuel pool cooling pump, fuel pool purification pump, 2A1 6.9kV bus start-up
transformer feeder breaker 2-30102, on November 22, 2024
(2)
Unit 1 elevated risk due to spent fuel pool time-to-boil < 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 1A instrument
air dryer OOS, guarded equipment: 1A and 1B fuel pool cooling pump, fuel pool
purification pump, 1A instrument air dryer, 1A, 1B and 1C instrument air compressors,
on November 25, 2024
(3)
Unit 2 elevated risk due to CCW HX 2A OOS for planned maintenance; guarded
equipment: 2B component cooling water pump, 2B intake cooling water pump, 2B
high pressure safety injection pump, 2B containment spray pump, from December 08,
2024, to December 12, 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 02498079, Unit 2 Linear Heat Rate alarms received during power ascension,
review completed on October 16, 2024
(2)
AR 02497354, Unit 2 "C" auxiliary feed water (AFW) discharge valve, SE-09-4, fails to
stop flow, review completed on October 18, 2024
(3)
AR 03498626, Unit 2 in-core instrument (ICI) detector axial misalignment, review
completed on October 22, 2024
(4)
AR 02499788, Unit 1 "C" intake cooling water (ICW) pump discharge check valve
leak has severely degraded, review completed on November 6, 2024
(5)
AR 02502039, Unit 1 "B" (ICW) header to component cooling water heat exchange
CW105 flange has a carbon steel bolt vice stainless steel, review completed on
November 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 October 1, 2024,
through October 15, 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)
2-OSP-99.08B "B Train Quarterly Non-Check Valve Cycle Test" and 2-OSP-100-16
"Remote Shutdown Components 18 Month Functional Test", following repairs to the
for 2C auxiliary feedwater pump solenoid valve SE-09-4, WO 40994102 and
40797545, review completed on October 25, 2024
(2)
CSTL2-NOPS-MN-NA-000001, St. Lucie Unit 2 Vanadium ICI Technical Manual
calibration following change in Beacon model on October 20, 2024
(3)
2-SMI-64.05A, "Nuclear Instrumentation Channel Calibration Channel A", following
repairs to Unit 2 wide range nuclear instruments failing low, WO 40998272, review
completed on November 5, 2024
(4)
1-OSP-02.01A "1A Charging Pump Code Run", St. Lucie Unit 1, following
preventative maintenance (PM) WO 40956274 for 40965284, and 40967297 for
motor PM, coupling PM, lubrication PM, and accumulator PM, review completed on
December 12, 2024
(5)
2-NOP-14.02, "Component Cooling Water System Operation", following 2A
component cooling water (CCW) heat exchanger cleaning and eddy current testing
WO 40964160, review completed on December 16, 2024.
(6)
2-OSP-14.01A "2A Component Cooling Water Pump Code Run", and 2-OSP-14.02A
"2A Component Cooling Water Pump Comprehensive Pump Test", following St. Lucie
Unit 2, 2A CCW Pump mechanical seal repairs, WO 40768378, review completed on
December 19, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
(1)
On December 18, 2024, the inspectors evaluated a licensed operator continuing
training table-top evaluation that included an extended loss of offsite and onsite
power resulting in a General Emergency declaration and notification to the Florida
State Watch Officer and St Lucie and Martin County Emergency Operations Centers.
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, 2023, through September 30, 2024)
(2)
Unit 2 (October 1, 2023, through September 30, 2024)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
(1)
Unit 1 (October 1, 2023, through September 30, 2024)
(2)
Unit 2 (October 1, 2023, through September 30, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
(1)
Unit 1 (October 1, 2023, through September 30, 2024)
(2)
Unit 2 (October 1, 2023, through September 30, 2024)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
(1)
Unit 1 (October 1, 2023, through September 30, 2024)
(2)
Unit 2 (October 1, 2023, through September 30, 2024)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
(1)
Unit 1 (October 1, 2023, through September 30, 2024)
(2)
Unit 2 (October 1, 2023, through September 30, 2024)
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
The inspectors reviewed the corrective actions (AR 2490514, 2486822, 2488583) for
issues that pose challenges to the free flow of information, and the licensee's risk
evaluations. The inspectors verified the licensees extent of condition, causal
analysis, and corrective actions were adequate to resolve the deficiencies
(2)
Unit 2 Safety Injection Tank (SIT) vent line through-wall leak (AR 02475748) 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 December 17, 2024
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees corrective action program to identify potential
trends with Unit 2 V2515 letdown isolation valve (for reactor coolant loop 2B1) that
might be indicative of a more significant safety issue. No adverse trend was identified.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensees event reporting determinations to ensure it
complied with reporting requirements.
(1)
LER 05000335/2024-001-00, Unplanned Reactor Scram (ADAMS Accession No.
ML24269A205). The inspectors concluded that a Green finding and associated Non-
cited Violation documented below occurred. This LER is Closed.
INSPECTION RESULTS
Failure to Prescribe Preventative Maintenance Instructions for ESFAS Relays
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Green
NCV 05000335,05000389/2024004-01
Open/Closed
[P.2] -
Evaluation
The NRC identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, procedures, and drawings," when the licensee
failed to prescribe and accomplish procedures to meet the requirements of ASME NQA-1,
Subpart 2.18, and RG 1.33, App. A, Section 9, for the preventative maintenance of
engineered safety feature actuation system (ESFAS) relays.
Description: AR 2439818 documented an event at Waterford Unit 3 where the site
experienced closure of the main steam isolation valves (MSIVs) and one of the main
feedwater isolation valves (MFIVs) unexpectedly, resulting in an automatic reactor trip from
100% power. The event was caused by a defective actuation relay within the engineered
safety feature actuation system (ESFAS) cabinet. The normally energized actuation relay coil
opened which resulted in the valve closures. Further investigation determined that the relay
was a single point vulnerability (SPV). Saint Lucies screening of this operating experience
(OE) item (dated 4/14/23) determined the issue was potentially applicable to their site and
concluded that no corrective actions were due. However, no evaluation was completed to
document how the conclusion was reached. On June 19, 2024, after inspector questioning,
the licensee performed the evaluation and determined that there were several relays in the
U1 and U2 ESFAS system that would result in a plant trip at 100% power, similar to the event
at Waterford.
On July 28, 2024, with Unit 1 in Mode 1 at 100% power, Saint Lucie Unit 1 automatically
tripped due to an inadvertent MSIV closure followed by unexpected closure of both MFIVs.
Troubleshooting revealed that the B main steam isolation system (MSIS) K627A relay coil
failed which caused a partial MSIS actuation and resulted in the 'A' MSIV closure, similar to
the event discussed in the Waterford operating experience. The licensee performed root
cause evaluation for CR 02491585, "U1 Trip Due to 'A' MSIV Closure," Rev. 0, which
concluded that age-related degradation was the most likely direct cause of the relay failure.
The licensee's failure investigation analysis also stated the ESFAS relays were assumed to
have been installed since the life of the plant since no maintenance history replacing the
relays could be found.
Section B.16 of the Saint Lucie Quality Assurance Topical Report (QATR) stated the site was
committed to ASME NQA-1, Subpart 2.18. NQA-1, Subpart 2.18, which required the
preventative maintenance requirements for the ESFAS relays be evaluated; taking into
consideration vendor recommendations, applicable industry standards, operation experience,
maintenance experience, and equipment history. It also required the ESFAS relays be
monitored and evaluated for degradation of performance because of age, as appropriate. The
inspectors noted that the licensee's strategy involving these relays was to perform an 18-
month surveillance test. The inspectors determined that, while the surveillance test verified
the current operability of the main steam isolation valves, the surveillance test did not contain
any steps to inspect or detect the relays for thermal degradation and stresses caused by
aging of normally energized relays. Additionally, section A.7 of the QATR documented the
sites commitment to RG 1.33, Quality Assurance Program Requirements (Operation), Rev.
2, App. A. Section 9.b of App. A states preventative maintenance schedules should be
developed to specify inspection or replacement of parts have a specific lifetime. Normally
energized relays have a shortened lifetime due to the thermal stresses caused on the
coils. NRC Information Notice 84-20, states that "In general, the service life of all relays in the
normally energized state is significantly shorter than when used in a cycled or normally de-
energized application. It is believed that the shorter service life of the normally energized
relays can be attributed to accelerated thermal aging of relay components....Preventative
maintenance programs should recognize the application-dependent (energized/de-energized)
service life of these relays and the service life of relays supplied by other manufacturers." The
inspectors noted that the licensee did not establish preventative maintenance schedules to
inspect or replace the normally energized ESFAS relays due to aging.
Corrective Actions: The licensee replaced six main steam isolation signal relays and one
actuation module on Unit 1 in response to the trip. The licensee also performed an extent of
condition review on Unit 1 and Unit 2 to evaluate replacement of all ESFAS relays and
actuation modules identified as single point vulnerabilities.
Corrective Action References: AR 02501617
Performance Assessment:
Performance Deficiency: The failure to prescribe and accomplish instructions or procedures
to meet the requirements of ASME NQA-1, Subpart 2.18, and RG 1.33, App. A, Section 9 for
the ESFAS relays was a performance deficiency (PD).
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 PD led to in-service component deterioration and failure of
safety-related ESFAS relay K627A, thereby causing a plant trip at 100% power, upsetting
plant stability, and challenging critical safety functions during at-power operations.
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
inspectors screened the significance of the finding using Exhibit 1 of IMC 0609 Appendix A
for the initiating events cornerstone and determined that a detailed risk evaluation was
required because the finding caused 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 (i.e., the
closure of main steam and main feedwater isolation valves as a result of the main steam
isolation signal (MSIS) plant transient). A detailed risk evaluation was performed by a regional
Senior Reactor Analyst using Systems Analysis Program for Hands-On Integrated Reliability
Evaluations (SAPHIRE) Version 8.2.11 and St. Lucie Unit 1 Standardized Plant Analysis Risk
(SPAR) model Version 8.82. An initiating event analysis was performed for Unit 1 using the
Loss of Main Feedwater (LOMFW) event sequence as a surrogate for the spurious MSIS
transient. No additional credit was provided in the analysis for post-failure repair of equipment
impacted by the performance deficiency. The dominant SPAR model sequences involved the
LOMFW initiating event followed by random unavailability of the auxiliary feedwater function
due to common mode pump failure and pressurizer power-operated relief valve failures
leading to core damage. The overall risk of the finding was mitigated by the remaining
mitigation capability of the auxiliary feedwater and once through cooling functions for the
event sequence. The initiating event analysis determined that the estimated increase in Core
Damage Frequency (CDF) and Large Early Release Frequency (LERF) were less than 1E-
06/year for delta-CDF and less than 1E-07/year for delta-LERF, representing a finding of very
low safety significance (GREEN) for Unit 1.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to
ensure that resolutions address causes and extent of conditions commensurate with their
safety significance. Specifically, the licensee failed to properly evaluate the operating
experience from Waterford in AR 2439818 to ensure resolutions address the causes.
Enforcement:
Violation: 10 CFR Part 50, App. B, Criterion V, Instructions, procedures, and drawings,
requires in part that Activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or drawings. Section B.16
of the St Lucie Quality Assurance Topical Report (QATR) states the site is committed to
NQA-1, Subpart 2.18. Subpart 2.18 requires in part that equipment shall be monitored and
evaluated for degradation of performance because of age, as appropriate. Additionally,
section A.7 of the QATR documents the sites commitment to RG 1.33, Quality Assurance
Program Requirements (Operation), Rev. 2, App. A. Section 9.b of App. A states preventative
maintenance schedules should be developed to specify inspection or replacement of parts
that have a specific lifetime. Contrary to the above, since at least April 2023, the licensee
failed to monitor and evaluate safety-related ESFAS relays for age-related degradation in
accordance with ASME NQA-1 and to establish preventative maintenance schedules to
inspect or replace normally energized safety-related ESFAS relays in accordance with RG 1.33, App. A. This closes URI 05000335, 389/2024011-03.
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 24, 2025, the inspectors presented the integrated inspection results to Mr.
Carlos Santos, Site Vice President and other members of the licensee staff.