IR 05000335/2024010
| ML24354A139 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/19/2024 |
| From: | Masters A NRC/RGN-II/DORS/EB1 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2024010 | |
| Download: ML24354A139 (14) | |
Text
SUBJECT:
ST. LUCIE PLANT UNITS 1 AND 2 - NRC QUADRENNIAL FOCUSED ENGINEERING INSPECTION (FEI) AGE RELATED DEGRADATION REPORT 05000335/2024010 AND 05000389/2024010
Dear Bob Coffey:
On December 18, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St. Lucie Plant Units 1 and 2 and discussed the results of this inspection with Mr.
Robert Craven 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 St. 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 St. Lucie Plant Units 1 and 2.
December 19, 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, Anthony D. Masters, Chief Engineering Branch 1 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:
05000335/2024010 and 05000389/2024010
Enterprise Identifier:
I-2024-010-0049
Licensee:
Florida Power and Light Company
Facility:
St. Lucie Plant Units 1 and 2
Location:
Jensen Beach, FL.
Inspection Dates:
November 18, 2024 to December 18, 2024
Inspectors:
T. Fanelli, Senior Reactor Inspector
C. Franklin, Reactor Inspector
G. Ottenberg, Senior Reactor Inspector
J. Rolland, Mechanical Engineer
Approved By:
Anthony D. Masters, Chief
Engineering Br 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC Quadrennial Focused Engineering Inspection (FEI) of Age Related Degradation at St. 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
Loss of Design Control for DC switchgear Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2024010-01 Open/Closed
[H.5] - Work Management 71111.21N.
The NRC identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to control the U1 and U2 direct current (DC) switchgear design in accordance with the design control program.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.04 - Age-Related Degradation Age-Related Degradation
- (1) Vital DC Switchboards
- (2) Class 1E Underground Cables-Conduits
- (3) Emergency Diesel Generator flexible hoses, ducts, and couplings
- (4) Reactor Coolant System and Main Steam System Snubbers
- (5) Auxiliary Feedwater System Piping
- (6) Intake Piping from Intake Cooling Water to Component Cooling Water and Turbine Cooling Water
- (7) Unit 1: Component Cooling Water Pumps
- (8) Unit 2: Containment Spray System
INSPECTION RESULTS
Loss of Design Control for DC switchgear Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2024010-01 Open/Closed
[H.5] - Work Management 71111.21N.0 The NRC identified a finding of very low safety significance (Green) and an associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to control the U1 and U2 direct current (DC) switchgear design in accordance with the design control program.
Description:
The original model molded case circuit breakers (MCCBs) are no longer available, the site used Item Equivalent Evaluations (IEE) to procure and install new model MCCBs into the station Class 1E DC switchgear. The IEEs evaluated the acceptability of replacing type HFB breakers with HFD type breakers in safety related DC panels. It concluded that an engineering change was required prior to installing the new breakers to ensure appropriate calculations were evaluated and revised as needed prior to installation.
Although the MCCBs were functionally equivalent, they were not identical, in that the tripping characteristics were not the same, thus affecting important electrical design calculations.
These calculations would need to be updated and verified for adequate system designs.
Calculations for Electrical Coordination Studies examines the site electrical power systems for selective coordination. Calculations for 125V DC System ETAP Models & Analyses performs load flow, voltage drop, battery sizing and short circuit analysis for the safety related DC systems. These calculations were not verified against the new MCCB designs, and in addition, the databases that tracks what MCCB is installed in each location was not updated with the correct information.
The inspection found that since approximately 2015 more than 70 MCCBs had been installed without completing the engineering design changes to the DC systems. The inspectors determined that the licensees failure to meet the site design control program affected the safe design of the Class 1E DC systems.
Corrective Actions: The licensee entered this issue into the corrective action program, and separate corrective action assignments would be generated to request updating the identified documents and equipment database NAMS panels and verify the design of the DC systems.
Corrective Action References: Action Requests (ARs) 02502554 and 02502564
Performance Assessment:
Performance Deficiency: The licensees failure to control the U1 and U2 direct current (DC)switchgear design in accordance with the design control program was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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 failure to ensure that MCCB trip characteristic could not impede or delay the safe operation of the DC power system affected the reliability and capability of the systems that rely on DC power to perform their safety function.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2
- Mitigating Systems Screening Questions, Item A. The finding was a deficiency affecting the design or qualification of a mitigating SSC, and it maintain its operability or PRA functionality which screened to Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities.
The organization did not implement a process of planning, controlling, and executing work activities affecting the Class 1E power systems such that nuclear safety was the overriding priority.
Enforcement:
Violation: Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that the design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Contrary to the above, the licensee failed to verify the design of the Class 1E DC power system by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, the licensee failed to verify the DC system performance after changing the design of the DC power system protection devices.
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 December 18, 2024, the inspectors presented the NRC Quadrennial Focused Engineering Inspection (FEI) Age Related Degradation results to Mr. Robert Craven and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
01902957, AR
2036040, AR
2076003, AR
2095478, AR
29763, AR
2483373, AR
2362262, AR
2403868, AR
2403929, AR
2404011, AR
2404013, AR
2488777, AR
2437896
U1 MCCB Config Mgmnt
U2 MCCB Config Mgmnt
Dwg Error
NRC Identified Issue: Evaluate MSLB Temperature per
MN-2.91
1B EDG Air Intake To EDG Flex Duct Excessive Offset
(U1 SH 21334 Degraded Flange Studs & Nuts)
(U1 Cw105 Flange - Cs Bolt Instead of Ss)
[NRC ARD Insp] Root Valves V09125 & V09126 Bonnet
Corrosion
[NRC ARD Insp] Vent Line Caps Not Installed Post Sl2-28
[NRC ARD Insp] Condensate Line C-52 In-Contact With
Grating
NRC PSL Eng 2B EDG Wlkdown
NRC ARD Insp-2A EDG 2A1 DC Turbo Lube Oil Pp
NRC ARD Insp-1A2 Air Start MTR Vent Hose
NRC ARD Insp-1B1 Air Start MTR Vent Hose
71111.21N.04
Corrective Action
Documents
Resulting from
Inspection
NRC ARD Insp-2A1 Air Start MTR Vent Hose
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NRC ARD Insp-1A1 Soak-back Pp MTR Fan Cover
NRC ARD Insp-2A1 Soak-back PP Disch Line
2A EDG Flex Hose Offset
Cosmetic Damage
Evaluate Accident Conditions Snubbers
037061-JL-LD-1
JL Breaker Modification
Rev 3
2998-A-451-1000
St. Lucie Plant Unit No 2 Equipment Qualification
Documentation Package
Rev 15
2998-G-080 Sht
2B
Flow Diagram Feedwater & Condensate Systems
Rev 40
2998-G-082
P&ID Circulating & Intake Cooling Water System
Rev. 67
2998-G-088
P&ID Containment Spray and Refueling Water Systems
Rev. 52
2998-G-170
Yard Piping Sheet No 1
Rev 24
8770-A-451-1000
St. Lucie Unit No 1 Equipment Qualification
Documentation Package
Rev 16
8770-G-080 Sht 4
Flow Diagram Feedwater & Condensate Systems
Rev 46
8770-G-082
P&ID Circulating & Intake Cooling Water System
Rev. 3
Drawings
8770-G-170 Sht 2
Yard Piping Sheet No 1B
Rev 17
25V DC Bus 1B Breaker Replacements for CKT 29, 30
and 32
Rev 0
25V DC BUS 2AB
Rev 0
Engineering
Changes
PSL-2FSE-08-001 Unit 2 Electrical
Coordination Study; Reg Guide 1.63, Reg Guide 1.75 And
Appendix R Validation
Rev 0
2481032-03
PLS Testing of Inaccessible Cables
2/02/2024
ERC-037061-JL-
JL Circuit Breaker Equivalency Evaluation
Rev 1
EVAL-PSL-12-
282
Unit 2 Condensate System
JPE-M-87-103
Snubber Acceptance Criteria
Rev 20
Engineering
Evaluations
Molded Case
Circuit Breaker
Time Current
Curves
HFB 15, HFB 30, HFB 50, HFB 70, HFB 100, ITE CE
15A, ITE CE 20A, ITE JL 350A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
QR-037061-2
Qualification Report for NLI JL Retrofit Breakers
Rev1
LISEGA Snubber Replacement Booklet
LISEGA Information Bulletin August 24, 2004
07/30/2007
L-2018-042, Snubber Program Plan Submittal
2/09/2018
L-2024-133, Snubber Program Plan Submittal
08/14/2024
DBD-AFW-1
Auxiliary Feedwater System
Rev 8
DBD-AFW-2
Auxiliary Feedwater System
Rev 12
ENG-CSI-XCI-
100
External Corrosion (XCI) Monitoring Program for Insulated
Piping for PSL and PTN License Renewal
Rev 6
ENG-LRAM-01-
23
CST Cross Connect Buried Pipe Inspection License
Renewal Basis Document
Rev 3
EVAL-PSL-12-
282
CNDSR 2A (AR 02488777) l PSL Condenser Extent of
Condition (EOC): CNDSR 2B/1A/1B
Letter
Service Life of LISEGA Hydraulic Snubbers
08/01/2001
Maintenance
Rule Event
20VA VITAL SYSTEM - EVT-49-2024-49935
04/13/2024
Maintenance
Rule Event
DC system event-EVT-50-2023-48964
11/20/2023
Maintenance
Rule Event
DC system event-EVT-50-2024-49752
03/28/2024
Guidelines for the Implementation of the Snubber
Inspection and Test Program
Rev 16
PMC-19-006604
Aux Feedwater and Condensate Pipe trench Inspections
(FREQ CHANGE SL1-33)
PMC-20-007345
Add Structures Inspection Tasks to Model WOs for
PMRQs 83579-01 & 83581-01 CST & AFW Pipe
Trenches
PMCR 2109388
Unit 2 CST & AFW Piping Inspection in the Trenches
2/11/2016
&
03/07/2016
Miscellaneous
00083579-01
Unit 2 CST & AFW Piping Inspection in the Trenches
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PSL-ENG-LRAM-
00-082
License Renewal Aging Management Review-Diesel
Generator Cooling Water System
Rev 3
PSL-ENG-LRAM-
00-084
St. Lucie Units 1 and 2 License Renewal Aging
Management Review-Diesel Generator Air System
Rev 4
PSL-ENG-LRAM-
00-093
Chemistry Control Program-License Renewal Basis
Document
Rev 10
PSL-ENG-LRAM-
00-096
Periodic Surveillance and Preventive Maintenance
Program-License Renewal Basis Document
Rev 16
PSL-ENG-LRAM-
00-114
Pipe Wall Thinning Inspection Program License Renewal
Basis Document
Rev 8
PSL-ENG-SECS-
05-053
Inspection Procedures and Repair Contingencies for the
Refueling Water Tank Bottom Liner
Rev. 1
Q3-2024
Snubber Program Health Report
QP-037061-2
Test plan JL Circuit Breaker Qualification
REV-0
SL1-31
Outage Report
11/04/2024
SL1-32
Outage Report
03/29/2024
SL2-27
Outage Report
04/14/2023
SL2-28
Outage Report
09/25/2024
SPEC-M-023
ICW & CW System Inspection and Repair for St. Lucie
Units 1 and 2
Rev. 14
Spec-M-081
CCW Heat Exchangers Tube Integrity Inspection, PTN
Units 3 and 4 and PSL Units 1 and 2
Rev. 1
Specification DS30-001
LISEGA Series 30 Snubbers and 33 Extensions
Rev 3
Specification DS30-002
LISEGA Series 30 Snubbers
Rev 0
Specification MN
2.91
Hydraulic Snubbers for Piping
Rev 2
Specification MN
3.29
Design Specification for Steam Generator Hydraulic
Snubbers for St. Lucie Plant Units 1 & 2
Rev 1
Spreadsheet
2/02/2024
Spreadsheet
2/02/2024
VTM 2998-7434
I/M Diesel Generator
Rev 48
VTM 8770-6703
Emergency Diesel Generator System-General
Rev 33
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Description, Operation and Maintenance
0-CMM-21.06
Intake Cooling Water (ICW) System Piping Inspection and
Repair
Rev. 11
0-COP-05.04
Chemistry Department Surveillances and Parameters
Rev 123
0-GME-53.01
Grounding or Testing of High Voltage (4.16 or 6.9 kV)
Loads
Rev 21
0-GME-53.02
Grounding or Testing of High Voltage (4.16 or 6.9 kV)
Switchgear Buses for Maintenance
Rev 9
0-PME-75.03
Preventive Maintenance Procedure for Corrpro Constant
Potential Cathodic Protection Rectifiers
Rev. 2
1-PME-75.01
Preventive Maintenance Procedure for Surveying
Cathodic Protection Systems
Rev, 9
2-ISP-100.01
ASME Section Xi Pressure Test Procedure for Class 2 &
Systems
Rev. 31
2-PME-75.01
Preventive Maintenance Procedure for Surveying
Cathodic Protection Systems
Rev. 8
ADM-17.32
Structures Monitoring Program
Rev. 14
ADM-17.33
License Renewal Systems / Programs Monitoring
Rev. 15
ADM-17.33
License Renewal Systems / Programs Monitoring
Rev 15
ADM-29.01A
Inservice Testing (IST) Program for Pumps And Valves
Rev. 35
CY-SL-108-0001
Condenser Tube Leak or Air Leak
Rev 5
Design Control Program
Rev 11
ENG-CSI-XCI-
100
External Corrosion (XCI) Monitoring Program For
Insulated Piping For PSL and PTN License Renewal
Rev. 6
Cable Condition Monitoring Program
Rev 8
Fleet Snubber Program
Rev 9
Snubber Program Procedure
Rev 10
IM-037061-2
Installation Manual for NLI JL Retrofit Breakers
Rev.1
PSL ENG-LRAM-
00-110
Galvanic Corrosion Susceptibility Inspection Program
License Renewal Basis Document
Rev. 8
PSL-ENG-LRAM-
00-067
License Renewal Aging Management Review -
Containment Spray System
Rev. 2
Procedures
PSL-ENG-LRAM-
00-093
Chemistry Control Program - License Renewal Basis
Document
Rev. 10
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PSL-ENG-LRAM-
00-095
Systems and Structures Monitoring Program - License
Renewal Basis Document
Rev. 14
PSL-ENG-LRAM-
00-096
Periodic Surveillance and Preventative Maintenance
Program - License Renewal Basis Document
Rev. 16
PSL-ENG-LRAM-
00-114
Pipe Wall Thinning Inspection Program License Renewal
Basis Document
Rev. 8
PSL-ENG-LRAM-
00-115
Intake Cooling Water System Inspection Program -
License Renewal Basis Document
Rev. 9
PSL-ENG-LRAM-
2-029
Containment Cable Inspection Program - License
Renewal Basis Document
Rev 6
PSL-ENG-SERS-
16-001
PSL Asset Management Plan for the Underground Piping
and Tank Integrity Program (UPTIP)
Rev, 2
Work Orders
Work Orders
40055265, 4005526101, 4015329901, 40420932,
40767873, 40775270-01, 40776490-01, 40845589-01,
40847368-01, 40712636-01, 40750329-04, 4014873-01,
40147878-01, 40084246-01, 40104763-01, 40657785-01,
40738772-01, 40745879-01, 40817296-01, 40627600-01,
40717680-01, 40717680-04, 40820201-01, 40920201-02,
40353539-01, 40876711-01, 40876711-02