IR 05000335/2012008

IR 05000335-12-008 and 05000389-12-008, on 10/28/2012 - 11/30/2012, St. Lucie Nuclear Plant, Units 1 & 2, Component Design Bases Inspection

ML13036A144
Person / Time
Site:	Saint Lucie
Issue date:	02/01/2013
From:	Nease R NRC/RGN-II/DRS/EB1
To:	Nazar M Florida Power & Light Co
References
IR-12-008
Download: ML13036A144 (28)

Text

UNITED STATES February 1, 2013

SUBJECT:

ST. LUCIE NUCLEAR PLANT - NRC COMPONENT DESIGN BASES INSPECTION - REPORT 05000335/2012008 AND 05000389/2012008

Dear Mr. Nazar:

On, December 18, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on December 18, 2012, with Mr. Bible and other members of your staff.

The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The team reviewed selected procedures and records, observed activities, and interviewed personnel.

One NRC-identified finding of very low safety significance (Green), was identified during this inspection, and was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation consistent with section 2.3.2 of the NRC Enforcement Policy. If you contest this violation or the significance of the violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Saint Lucie.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its Enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agency-wide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Rebecca L. Nease, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-335 and 50-389 License No. DPR-67 and NPF-16

Enclosure:

Inspection Report 05000335/2012008 and 05000389/2012008 w/Attachment:

Supplemental Information

REGION II==

Docket Nos.: 50-335, 50-389 License Nos.: DPR-67 and NPF-16 Report Nos.: 05000335/2012008, 05000389/2012008 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 6501 South Ocean Drive Jensen Beach, Florida 34957-2010 Dates: October 28 - November 30, 2012 Inspectors: Robert Patterson, Reactor Inspector (Lead)

Steve Rose, Senior Construction Project Engineer Jamie Heisserer, Senior Construction Inspector Theodore Fanelli, Construction Inspector Alexander Butcavage, Reactor Inspector (Training)

William Sherbin, Accompanying Personnel Stanley Kobylarz, Accompanying Personnel Approved by: Rebecca L. Nease, Chief Engineering Branch 1 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000335/2012008 and 05000389/2012008; 10/28/2012 - 11/30/2012; St. Lucie Nuclear

Plant, Units 1 & 2; Component Design Bases Inspection.

This inspection was conducted by a team of five Nuclear Regulatory Commission (NRC)inspectors from Region II, and two NRC contract personnel. One Green non-cited violation (NCV) was identified. The significance of inspection findings are indicated by their color (i.e.,

greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manuel Chapter 0609, Significance Determination Process dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manuel Chapter 0310, Components Within the Cross Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated [issue date]. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process revision 4.

NRC identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The team identified a non-cited violation of Technical Specification 6.8,

Procedures and Programs, for an inadequate technical specification required procedure to combat a loss of feedwater or feedwater system failure. Abnormal operating procedure 1-AOP-09.02, Auxiliary Feedwater, Attachment 5,

Supplying Unit 1 AFW Pumps from the Unit 2 CST, could not be performed as written with respect to ensuring the availability of the Auxiliary Feedwater (AFW)pumps. The licensee promptly issued a standing night order to ensure that the AFW pumps would remain available and initiated action requests 1816711 and 1826000. The licensee has subsequently modified the procedure to rectify the issue.

The licensees failure to provide an adequate procedure to mitigate a design basis event was a performance deficiency. The performance deficiency affected the Mitigating Systems Cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, procedure 1-AOP-09.02, secured all suction sources to the AFW pumps without ensuring that the motor driven auxiliary feedwater (MDAFW) pumps would not auto start if an auxiliary feedwater actuation signal was received. The performance deficiency was determined to have more than minor safety significance because if left uncorrected, the failure of the MDAFW pumps could lead to a more significant safety concern as a result of the plant not being able to sustain short-term decay heat removal under specific conditions. The procedure steps created a condition that could have resulted in the inoperability of both MDAFW pumps. In accordance with NRC Inspection Manuel Chapter 0609.04, Initial Screening and Characterization of Findings, the team determined that a detailed risk evaluation was required because the finding screened as potentially risk-significant due to a severe weather initiating event. A bounding Significance Determination Process Phase analysis was performed by a regional senior risk analyst which determined the performance deficiency was a Green finding of very low safety significance. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. [Section 1R21.3]

Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R21 Component Design Bases Inspection

.1 Inspection Sample Selection Process

The team selected risk significant components and related operator actions for review using information contained in the licensees probabilistic risk assessment. In general, this included components and operator actions that had a risk achievement worth factor greater than 1.3 or Birnbaum value greater than 1 X10-6. The sample included 17 components, including two associated with containment large early release frequency, and six operating experience items.

The team performed a margin assessment and a detailed review of the selected risk-significant components and operator actions to verify that the design bases had been correctly implemented and maintained. Where possible, this margin was determined by the review of the design basis and Updated Final Safety Analysis Report (UFSAR)response times associated with operator actions. This margin assessment also considered original design issues, margin reductions due to modifications, or margin reductions identified as a result of material condition issues. Equipment reliability issues were also considered in the selection of components for a detailed review. These reliability issues included items related to failed performance test results, significant corrective action, repeated maintenance, maintenance rule status, Regulatory Issue Summary 05-020 (formerly Generic Letter 91-18) conditions, NRC resident inspector input regarding problem equipment, system health reports, industry operating experience, and licensee problem equipment lists. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense-in-depth margins. An overall summary of the reviews performed and the specific inspection findings identified is included in the following sections of the report.

Documents reviewed are listed in the Attachment.

.2.1 Unit 2 C Turbine Driven Auxiliary Feedwater (TDAFW) Pump

a. Inspection Scope

The team reviewed the plants Technical Specifications (TS), UFSAR, System Design Bases Documents (SDBDs), and Piping and Instrumentation Drawings (P&IDs) to establish an overall understanding of the design bases of the 2C turbine-driven auxiliary feedwater pump (TDAFW) pump. The team reviewed analyses, procedures, and test results associated with operation of the auxiliary feedwater (AFW) pumps under transient, accident, station blackout, and Appendix R scenarios. The analyses included hydraulic performance, net positive suction head (NPSH), and potential for vortexing at the suction source. In-service Testing (IST) results were reviewed to verify pump test acceptance criteria was met and performance degradation would be identified, taking into account set-point tolerances and instrument inaccuracies. In addition, the licensee responses and actions to Bulletin 88-04, Potential Safety-Related Pump Loss, were reviewed to assess implementation of operating experience related to the pumps minimum flow, and pump to pump interaction. The team conducted a detailed walk-down of the pumps to assess the material conditions, and to verify that the installed configuration was consistent with system drawings, and the design and licensing bases.

Corrective action history was reviewed to ensure problems were identified and corrected in a timely manner.

b. Findings

No findings were identified.

.2.2 Unit 1A & 1B AFW Motor Driven Pumps and Motors

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the 1A and 1B AFW motor driven pumps. The team reviewed analyses, procedures, and test results associated with operation of the AFW pumps under transient, accident, and Appendix R scenarios.

The analyses included hydraulic performance, NPSH, and potential for vortexing at the suction source. IST results were reviewed to verify pump test acceptance criteria were met and performance degradation would be identified, taking into account set-point tolerances and instrument inaccuracies. In addition, the licensee responses and actions to Bulletin 88-04, Potential Safety-Related Pump Loss were reviewed to assess implementation of operating experience related to the pumps minimum flow, and pump to pump interaction. The team conducted a detailed walk-down of the pumps to assess the material conditions, and to verify that the installed configuration was consistent with system drawings, and the design and licensing bases. Corrective action history was reviewed to ensure problems were identified and corrected in a timely manner.

b. Findings

No findings were identified.

.2.3 1B AFW Discharge and Supply to Steam Generator Check Valves

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs and P&IDs to establish an overall understanding of the design bases of the AFW pump 1B discharge (V09123) and 1B AFW supply to steam generator 1B (V09135) check valves. Component walk-downs were conducted to verify that the installed configurations would support their design bases functions under accident conditions and had been maintained to be consistent with design assumptions. The team also reviewed vendor documentation, system health reports, and corrective action system documents were reviewed in order to verify that potential degradation was monitored or prevented.

b. Findings

No findings were identified.

.2.4 Unit 1 Condensate Storage Tank (CST)

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, logic drawings, and P&IDs to establish an overall understanding of the design bases of the Unit 1 CST. Design calculations were reviewed to ensure that the CST contained sufficient volume to meet its TS requirements. The team reviewed level and pressure alarm set-point bases calculations to verify AFW pumps would be stopped prior to exceeding the calculated useable volume the CST. The adequacy of tornado missile protection was also reviewed during detailed walk-downs. In addition, the team reviewed design basis calculations and operating procedures that would be entered in the event of a loss of Unit 1 CST due to tornado missile to ensure a suction source of water for the Unit 1 AFW pumps would be available from a cross-tie to the Unit 2 CST.

b. Findings

No findings were identified.

.2.5 Trip/Throttle Valve for 1C TDAFW Pump (MV-08-3)

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, logic drawings, and P&IDs to establish an overall understanding of the design bases of the TDAFW pump Trip/Throttle Valve. Specifically, the team reviewed motor operated valve (MOV) testing, thrust, weak link, and differential pressure calculations. The team also reviewed preventive maintenance records regarding lubrication of valve linkage to ensure valve trip mechanism was properly greased. In addition, the team reviewed the vendor manual to ensure vendor documentation was up to date, and a sample of condition reports were reviewed to ensure problems were identified and corrected.

b. Findings

No findings were identified.

.2.6 High Pressure Safety Injection (HPSI)

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the HPSI pumps. System health reports, preventative and corrective maintenance documents, were also reviewed to verify that potential degradation was being monitored and addressed. The team also reviewed updated HPSI pump output requirements need to support Extended Power Uprate (EPU) conditions. HPSI pump discharge requirements were compared to actual pump field test results in order to provide reasonable assurance that the HPSI pump could perform their intended safety function.

The teams review also included various aspects of the Refueling Water Tank (RWT)requirements for the injection phase of HPSI operation and the containment sump source for the recirculation phase of the HPSI pump. In addition, a selection of EPU Vendor calculations were reviewed in order to provide reasonable assurance that correct inputs were used for the modifications to HPSI. Finally, a previously completed HPSI pump seal cooler modification was reviewed to verify that the modification was integrated into the several year effort of the EPU project.

b. Findings

No findings were identified.

.2.7 Main Steam Isolation Valves (MSIVs)

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs and P&IDs to establish an overall understanding of the design bases of the MSIVs (Unit 1 and 2). System health reports, preventative and corrective maintenance documents, were also reviewed to verify that potential degradation was being monitored and addressed.

The team compared MSIV requirements established as part of the sites EPU project to recent field test reports in order to provide reasonable assurance that the valves could perform their intended functions. Specifically, a sample of recent field test procedures were reviewed in order to determine if the most recent outputs from the EPU calculations were incorporated into testing, operation and emergency procedures used by the plant staff. Additionally, the team interviewed responsible licensee personnel to answer questions that arose during document reviews and walk-downs to determine the adequacy of maintenance and configuration control.

b. Findings

No findings were identified.

.2.8 Auxiliary Under-Voltage Relays 27X-1 and 27Y_967 to Close Emergency Diesel

Generator 4160V AC Circuit Breaker to Bus 1B3

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, and electrical drawings to establish an overall understanding of the design bases of the Class 1E 4160V AC distribution system. The team reviewed preventive maintenance and testing procedures to confirm that the relays operation characteristics were maintained in accordance with manufacturers recommendations. The team assessed the adequacy of the maintenance observations reviewed in recent system corrective action reports. A field walk-down of the control panels was performed to assess the installation of the relays and their observable material condition. Additionally, the team interviewed responsible licensee personnel to answer questions that arose during document reviews and walk-downs to determine the adequacy of maintenance and configuration control.

b. Findings

No findings were identified.

.2.9 Auxiliary Under-Voltage Relay 27X-11 to Open 4160V AC Tie Breaker between Buses

1B2 and 1B3

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, and electrical drawings to establish an overall understanding of the design bases of the Class 1E 4160V AC distribution system and Emergency Diesel Generator (EDG) System. The team reviewed preventive maintenance and testing procedures to confirm that the relays operation characteristics were maintained in accordance with manufacturers recommendations. The team assessed the adequacy of the maintenance observations reviewed in recent system corrective action reports. A field walk-down of the control panels was performed to assess the installation of the relays and their observable material condition. Additionally, the team interviewed responsible licensee personnel to answer questions that arose during document reviews and walk-downs to determine the adequacy of maintenance and configuration control.

b. Findings

No findings were identified.

.2.10 Control Room Instrumentation for Auxiliary Feed Water Flow Indication

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the AFW system. The team reviewed actions taken associated with licensee event report (LER) 2012-006-00, as well as preventive maintenance and testing procedures to confirm that the flow instrumentation was maintained in accordance with manufacturers recommendations.

Additionally, the team interviewed responsible licensee personnel to answer questions that arose during to the document reviews and to determine if procedures and practices described in the LER had been corrected for future maintenance activities.

b. Findings

No findings were identified.

.2.11 Unit 2 Class 1E 125V DC Battery Banks 2A and 2B

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the Class 1E DC electrical distribution system. The team reviewed preventive maintenance and testing procedures to confirm that the batteries were maintained in accordance with manufacturers recommendations. The team also addressed voltage drop capabilities to verify that adequate voltage was conveyed to the most limiting circuit. The team reviewed system modifications and selected corrective action reports to verify that any deviations were addressed and corrected. A field walk-down of the battery banks and DC circuits was performed to assess their installation and observable material condition of devices that affect voltage drop across the DC circuits. Additionally, the team interviewed responsible licensee personnel to answer questions that arose during document reviews and walk-downs and to determine if the licensee accounted for the relevant devices that introduce voltage drop on the DC circuitry.

b. Findings

No findings were identified.

.2.12 Unit 1 and 2 480V AC circuit breaker modification, Square D Masterpact circuit breakers

with digital trip units

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the Class 1E 480V AC distribution system. The team reviewed 10 CFR 50.59 screening documents, qualification reports, operating experience, verification and validation reports, and failure modes and effects analyses to determine if any operating or failure modes existed for the Square D Masterpact circuit breakers. A field walk-down of the circuit breakers was performed to assess their installation and observable material conditions. Additionally, the team interviewed responsible licensee personnel to answer questions that arose during document reviews and walk-downs and to determine if the modification adversely affected the SSCs functions described if the in the UFSAR.

b. Findings

No findings were identified.

.2.13 High Pressure Safety Injection (HPSI) Pump (1A) and Auxiliary Feedwater (AFW) Pump

(1A) Motor Feeder Breakers

a. Inspection Scope

The team reviewed the plants UFSAR and P&IDs to establish an overall understanding of the design bases of the pumps. The team verified by review of schematic drawings, that operation of the pump motors was consistent with the design basis and operational requirements. The team verified that the brake horsepower required by the pump was the maximum horsepower that was required during a LOCA condition and was within the motor rating. The team reviewed the protection coordination calculation for the motor and verified that the circuit breaker ratings and protective devices trip settings and alarm functions were consistent with the licensing basis and operational requirements. The team reviewed recent calibration tests of the breaker overcurrent relays to confirm that the calibration results satisfied design requirements and that corrective actions were implemented, if required. The team reviewed electrical maintenance and corrective action histories to determine whether there had been any adverse operating trends. The team verified that the ambient conditions were consistent with vendor recommendation for the motors. The team performed a walk-down of the pump motors to assess the observable material condition, to verify motor nameplate data, to determine whether the installed configuration was consistent with design documents including drawings, and calculations, and to assess the presence of hazards.

b. Findings

No findings were identified.

.2.14 4160V to 480V Substation Transformers 2H and 2J

a. Inspection Scope

The team reviewed the plants TS, UFSAR, SDBDs, electrical drawings, and electrical standards to establish an overall understanding of the design bases of the 2H and 2J 4160V to 480V transformers. Component walk-downs were conducted to verify that the installed configurations would support their design bases functions under accident conditions and had been maintained to be consistent with design assumptions.

Protective relaying schemes and calculations were reviewed to determine whether the transformer was adequately protected and whether it was susceptible to spurious tripping. Test procedures and recent test results were reviewed against design bases documents to verify that acceptance criteria for tested parameters were supported by calculations or other engineering documents and that individual tests and analyses served to validate component operation under accident conditions. Vendor documentation, system health reports, and corrective action system documents were reviewed in order to verify that potential degradation was monitored or prevented.

b. Findings

No findings were identified.

.2.15 Power Operated Relief (PORV) Block Valve Motor Operated Valve - Electrical (V-1403

and V-1405)

a. Inspection Scope

The team reviewed the plants UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the PORV Block Valves. The team verified by review of schematic drawings, that operation of the valve motors was consistent with the design basis and operational requirements. The team reviewed the valve motor vendor data and the specifications for the motor to verify conformance with the calculation for motor terminal voltage. The team reviewed the calculation for determining the minimum motor terminal voltage under design/licensing basis conditions to assess the capability of the motor to provide the required thrust to operate the valve.

The team also reviewed the calculation for determining the minimum motor starter contactor terminal voltage under design/licensing basis conditions to verify adequate voltage at the contactor coil for valve motor starting and running conditions.

b. Findings

No findings were identified.

.2.16 4.16 kV Switchgear 1B-3

a. Inspection Scope

The team reviewed the plants UFSAR, SDBDs, electrical drawings, and electrical standards to establish an overall understanding of the design bases of the switchgear.

The team verified by review of one-line diagrams and the electrical system calculations that operation of the switchgear was consistent with the design basis and operational requirements. The team reviewed the protection coordination calculation for the switchgear and verified that the circuit breaker ratings and protective devices trip settings and alarm functions were consistent with the licensing basis and operational requirements. The team reviewed maintenance schedules, procedures, and completed work orders to determine whether the selected breakers were being properly maintained.

The team reviewed protective relaying schemes and calculations to determine whether the breakers were adequately protected and coordinated with switchgear. The team reviewed maintenance and corrective action histories to determine whether there have been any adverse operating trends. The team reviewed recent calibration tests of the breaker overcurrent relays to confirm that the calibration results satisfied design requirements and that corrective actions were implemented if required. The team performed a walk-down of the installed equipment to assess the observable material conditions, to determine whether the installed configuration was consistent with design documents including drawings, and calculations, and to assess the presence of hazards.

b. Findings

No findings were identified.

.2.17 4160 to 480V Station Service Transformer 1A-2

a. Inspection Scope

The team reviewed the plants UFSAR, SDBDs, electrical drawings, and P&IDs to establish an overall understanding of the design bases of the station service transformer and load center 1A-2. The team reviewed load flow and short circuit current calculations to determine the design basis for maximum load, interrupting duty and bus bracing requirements and the load center equipment vendor ratings for conformance with design bases. The team also reviewed the coordination/protection calculation for the transformer and load center feeder breakers for design basis load conditions and transformer protection. The team reviewed surveillance tests on the transformer feeder breaker for adequacy of results in accordance with design basis setting requirements.

The team reviewed transformer cooling fan operation and preventive maintenance procedures to verify the capability to satisfy the design basis load requirement. The team reviewed corrective action documents and corrective maintenance history for recurring issues affecting reliability. The team reviewed alarm response procedures for the transformer to assess the adequacy of operator actions. The team performed a walk-down of the installed equipment to assess the observable material conditions, to verify transformer nameplate data, to determine whether the installed configuration is consistent with design documents including drawings and calculations, and to assess the presence of hazards.

b. Findings

No findings were identified.

.3 Review of Low Margin Operator Actions

a. Inspection Scope

The team performed a margin assessment and detailed review of four risk-significant operator actions associated with the selected components. Where possible, margins were determined by the review of the assumed design basis and UFSAR response times. For the selected operator actions, the team performed a walkthrough of associated emergency operating procedures, abnormal operating procedures, annunciator response procedures, and other operations procedures with plant operators and engineers to assess operator knowledge level; adequacy of procedures; availability of special equipment when required; and the conditions under which the procedures would be performed. Detailed reviews were also conducted with operations and training department personnel. Observation and utilization of a simulator training period was used to further understand and assess the procedural rationale and approach toward meeting the design basis and UFSAR response and performance requirements. The inspectors performed a walk-down of the simulator control boards to assess the instrumentation that the operators would utilize as indication that action would be needed to accomplish the tasks being observed. Operator actions were observed on the plant simulator and during plant walk-downs. The team reviewed operating procedures and operator training material to verify that risk significant operator actions could be accomplished as relied upon in design basis calculations. Selected operator actions associated with the following events/evolutions were reviewed:

• Operator actions for closing the MSIV within the required time following a steam generator tube rupture

• Operator actions for initiation of once through cooling upon loss of the condensate storage tank (CST)

• Operator actions for manual initiation of AFW flow following a small break loss of coolant accident, with the failure of the AFW automatic initiation function

• Operator actions for connecting the AFW suction to the Unit 2 CST following a loss of Unit 1 CST The team conducted focused walk-downs of the AFW system to assess if the operator actions required to cross connect the Unit 1 AFW pump suction to the Unit 2 CST could be successfully accomplished.

b. Findings

Introduction:

A Green, NRC-identified, non-cited violation (NCV) of TS 6.8, Procedures and Programs, was identified for an inadequate technical specification required procedure to combat a loss of feedwater or feedwater system failure. Abnormal operating procedure 1-AOP-09.02, Auxiliary Feedwater, Attachment 5, Supplying Unit 1 AFW Pumps From the Unit 2 CST, could not be performed as written with respect to ensuring the availability of the AFW pumps.

Description:

Saint Lucie Unit 1 TS 6.8.1, states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2. Item 6.j. of Appendix A to Regulatory Guide 1.33 requires a procedure to combat a loss of feedwater or feedwater system failure. At Saint Lucie, Unit 1 CST is the primary water source for the AFW system. Unit 1 CST has been specified in the UFSAR as being susceptible to being incapacitated due to a wind generated missile. Abnormal operating procedure 1-AOP-09.02, Attachment 5, was written to ensure a water source was maintained for Unit 1, during a tornado.

The Unit 1 CST is not fully protected (sides are protected but top is not) from tornado generated missiles. The UFSAR postulates an initiating event in which a tornado generated missile penetrates the top of Unit 1 CST and exits through the side of the CST causing a loss of the CST. To mitigate this event, 1-AOP-09.02, Attachment 5, realigns the Unit 1 AFW pumps suction to the Unit 2 CST. Procedure 1-AOP-09.02, Rev. 1, Step 1.B ensured all Unit 1 AFW pumps were off but did not specify how this was to be accomplished. The Operations department stated that if the pumps were operating at the time of this procedure step, their control switches would be taken to the OFF position to secure the pumps. It was identified that the Unit 1 motor driven AFW (MDAFW) pump control switches do not have an OFF maintaining position. Therefore, the pumps would auto start if an auxiliary feedwater actuation signal was received during the performance of this procedure. Step 1.E(1) secured the suction from the Unit 1 CST, by shutting the manual isolation valve, placing the pumps in a condition where no suction source is aligned. Step 1.E(2) aligned the suction of the AFW to Unit 2 CST. There is a period of time of approximately 2 to 4 minutes where the AFW pumps would have inadequate suction to support operation. If the AFW pumps were to receive an automatic start signal during this time, pump damage would occur. The TDAFW pump has an OFF maintaining switch which would prevent it from auto-starting allowing it to be recoverable.

Analysis:

The licensees failure to provide an adequate procedure to mitigate a design basis event was a performance deficiency. The performance deficiency affected the Mitigating Systems Cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, 1-AOP-09.02, secured all suction sources to the AFW pumps without ensuring that the MDAFW pumps would not auto start if an auxiliary feedwater actuation signal was received. The performance deficiency was determined to be of more than minor significance because if left uncorrected, the failure of the MDAFW pumps could lead to a more significant safety concern as a result of the plant not being able to sustain short-term decay heat removal under specific conditions. The procedure steps created a condition that could have resulted in the inoperability of both MDAFW pumps. The inspectors evaluated the risk of this finding using a Phase 1 evaluation per Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings. The inspectors determined that the finding was potentially risk significant due to a severe weather initiating event (e.g., tornadoes). Since this finding was determined to involve the loss of equipment specifically designed to mitigate a severe weather initiating event, a Phase 3 analysis per IMC 0609 was required to determine the safety significance. The regional Senior Reactor Analyst performed a detailed risk evaluation for the finding to determine the impact on the plant's response to the tornado. The finding was modeled as a severe weather related loss of off-site power without AFW. The result was multiplied by the frequency of a F2 or greater tornado striking the site. Primarily because of the low frequency of tornados strong enough to generate an airborne object with sufficient energy that could damage the CST, the finding screened as Green. The inspectors determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance.

Enforcement:

Unit 1 Technical Specification 6.8.1, Procedures and Programs, states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Item 6.j. of Appendix A to Regulatory Guide 1.33 requires procedures to combat a loss of feedwater or feedwater system failure.

Contrary to the above, the licensee failed to implement a procedure to adequately combat a loss of feedwater or feedwater system failure. Specifically, the procedure failed to ensure the AFW pumps would not automatically start if an AFAS was received during the time that no suction source was aligned to the pumps which would result in damage to the pumps. At Saint Lucie, Unit 1 CST is the primary water source for the AFW system. Unit 1 CST has been specified in the UFSAR as being susceptible to being incapacitated due to a wind generated missiles. Procedure 1-AOP-09.02, 5, was written to provide for this event to ensure a water source was maintained for Unit 1. The licensee promptly issued a standing night order to ensure that the AFW pumps would remain available and initiated action requests 1816711 and 1826000. The licensee has subsequently modified the procedure to rectify the issue.

Because the licensee entered the issue into their corrective action program as action requests 1816711 and 1826000, and the finding is of very low safety significance (Green), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000335/2012008-01, Inadequate Procedure for Severe Weather Mitigation.

.4 Operating Experience (Six Samples)

a. Inspection Scope

The team reviewed six operating experience issues for applicability at Saint Lucie Nuclear Plant. The team performed an independent review for these issues and where applicable, assessed the licensees evaluation and disposition of each item. The issues that received a detailed review by the team included:

• NRC Information Notice 2008-02, Findings Identified During Component Design Bases Inspections

• NRC Information Notice 2010-20, TDAFW Pump Repetitive Failures

• NRC Information Notice 2006-31, Inadequate Fault Interrupting Rating of Breakers

• NRC Information Notice 2010-03, Failures of MOVs Due to Degraded Stem Lubricant

• NRC Information Notice 2011-22, Instrumentation and Control Module Hardware, Configuration, and Procedure Issues

• NRC Information Notice 2012-06, Use of Vendor Recommendations

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On November 30, 2012 and on December 18, 2012, the team presented the inspection results to Mr. Jensen and other members of the licensees staff. Proprietary information that was reviewed during the inspection was returned to the licensee or destroyed in accordance with prescribed controls.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

P. Barnes, Mechanical Engineering Design Supervisor

D. Cecchett, Licensing

G. Johnston, Site Vice President

E. Katzman, Licensing Manager

D. Lany, Operations Senior Reactor Operator

J. Porter, Manager Design Engineering

S. Short, Electrical Engineering Design Supervisor

NRC personnel

R. Nease, Chief, Engineering Branch Chief 1, Division of Reactor Safety, Region II

D. Rich, Chief, Project Branch 3, Division of Reactor Project, Region II

T. Hoeg, Senior Resident Inspector, Division of Reactor Projects, Saint Lucie Resident Office

R. Reyes, Resident Inspector, Division of Reactor Projects, Saint Lucie Resident Office

LIST OF ITEMS

Opened and Closed

05000335, 389/2012008-01 NCV Inadequate Procedure for Severe Weather Mitigation (Section 1R21.3)