IR 05000335/2023010: Difference between revisions

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{{Adams
{{Adams
| number = ML23184A035
| number = ML24025A058
| issue date = 06/30/2023
| issue date = 01/26/2024
| title = Notification of St. Lucie Units 1 & 2 – Focused Engineering Inspection (FEI) 05000335/2023010 and 05000389/2023010 and Initial Information Request
| title = NRC Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication Report 05000335/2023010 and 05000389/2023010
| author name =  
| author name = Baptist J
| author affiliation = NRC/RGN-II/DRS
| author affiliation = NRC/RGN-II/DRS/EB1
| addressee name = Coffey R
| addressee name = Coffey B
| addressee affiliation = Florida Power & Light Co
| addressee affiliation = Florida Power & Light Co
| docket = 05000335, 05000389
| docket = 05000335, 05000389
| license number =  
| license number = NPF-067, NPF-016
| contact person =  
| contact person =  
| document report number = IR 2023010
| document report number = IR 2023010
| document type = Letter
| document type = Letter, Inspection Report
| page count = 7
| page count = 12
}}
}}


Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:June 30, 2023
{{#Wiki_filter:==SUBJECT:==
ST. LUCIE PLANT UNITS 1 AND 2 - NRC QUADRENNIAL FOCUSED ENGINEERING INSPECTION (FEI) COMMERCIAL GRADE DEDICATION REPORT 05000335/2023010 AND 05000389/2023010


Mr. Robert Coffey Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.
==Dear Bob Coffey:==
On December 15, 2023, 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.


Juno Beach, FL 33408
Robert Craven and other members of your staff. The results of this inspection are documented in the enclosed report.


SUBJECT: NOTIFICATION OF ST. LUCIE UNITS 1 & 2 - FOCUSED ENGINE ERING INSPECTION (FEI) 05000335/2023010 AND 05000389/2023010 AND INIT IAL INFORMATION REQUEST
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.


Inspection Procedure: 71111.21N,03, Focused Engineering Inspection (FEI),
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Attachment 21N.03, Commercial Grade Dedication, dated June 28, 2022 (ADAMS ML22075A251)
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.


Inspection Report: 05000335/2023010 AND 05000389/2023010 (Standalone Inspection Report)
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.


Inspectors: T. Fanelli (Lead)
January 26, 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.
J. Hamman (Elec/CGD)
Inspect 3 (TBD)


The purpose of this letter is to notify St. Lucie that three in spectors from Region II will conduct an inspection at your site in accordance with Inspection Proced ure 71111.21N.03, Focused Engineering Inspection (FEI), Attachment 21N.03, Commercial G rade Dedication, Commercial Grade Dedicatio This is not considered a team in spectio The inspection will evaluate Watts Bars process for dedicating commercial-grade it ems, as required in applicable portions of Appendix B to Title 10 of the Code of Federal Regul ations (10 CFR) Part 50 (Appendix B), to ensure reasonable assurance is provided that t hese items will perform their intended safety functio Additionally, this inspection will e valuate implementation of Watts Bars procurement process for safety-related components, as req uired in Appendix The inspectors will select samples of components that are risk sign ificant and within the scope of the progra During a 6/30/2023, phone call Mr. Tim Falkiewicz, PSL Regulato ry Affairs, we confirmed arrangements for an information-gathering site visit and the tw o-week onsite inspectio The schedule is as follows:
Sincerely, James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000335 and 05000389 License Nos. DPR-67 and NPF-16
Information Gathering Visit: November 6, 2023; Preparation Wee k: November 20, 2023.


Onsite Weeks of November 27 and December 11, 202 On November 6, 2023, Mr. Theo Fanelli, a Senior Reactor Inspect or from the NRCs Region II office, will begin the inspection with an information gathering visit to the sit The purpose of the
===Enclosure:===
As stated


R. Coffey 2
==Inspection Report==
Docket Numbers:
05000335 and 05000389 License Numbers:
DPR-67 and NPF-16 Report Numbers:
05000335/2023010 and 05000389/2023010 Enterprise Identifier:
I-2023-010-0052 Licensee:
Florida Power and Light Company Facility:
St. Lucie Plant Units 1 and 2 Location:
Jensen Beach, FL.


visit is to become familiar with the process for dedicating com mercial-grade items and the process for procuring safety-related components at ST. Luci This visit may include a tour of onsite commercial-grade item dedication facilities, receipt ins pection facilities, storage facilities, and installed plant components associated with potential inspec tion sample During the visit, the team lead will also review the information provided in the initial information request to select a list of potential inspection sample The team lead may also identify other information needed to support the inspection during this visi To minimize the impact on your staff and to ensure a productive inspection, we have enclosed two separate requests for information needed prior to the onsit e information gathering visit and offsite inspection preparation wee The first request (Enclos ure 1) is generally for information that will be used to choose the inspection samples or informati on that will be applicable to all inspection samples throughout the inspectio This information should be made available to the team lead prior to the information gathering visi The second request (Enclosure 2) is for information specific to individual samples and should be made a vailable prior to the offsite preparation wee Please provide the information requested in Enclosure 1 to the Region II Office or a file sharing site by October 30, 202 Additional documents may be requeste d during the information gathering visi The inspectors w ill try to minimize your administrative burden by specifically identifying only those documents required for inspection prepar atio The additional information should be provided to the Inspectors in the Region II office or a file sharing site by November 20, 202 During the information gathering visit, Mr. Fanelli will also d iscuss the following inspection support administrative details : (1) availability of knowledgeab le plant engineering and licensing personnel to serve as points of contact during the inspection, (2) method of tracking inspector requests during the inspection, (3) computer access, (4) workin g space, (5) arrangements for site access, and (6) other applicable informatio R. Coffey 3
Inspection Dates:
November 27, 2023 to December 15, 2023 Inspectors:
T. Fanelli, Senior Reactor Inspector J. Lizardi-Barreto, Reactor Inspector T. Su, Reactor Inspector Approved By:
James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety


INFORMATION REQUEST FOR ST. LUCIE UNITS 1 & 2 - FOCUSED ENGINEE RING INSPECTION (FEI) COMMERCIAL GRADE DEDICATION
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection 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.


Prior to the information gathering visit, please provide the in formation electronically in.pdf files, Excel, or other searchable format on CDROM (or FTP site, SharePoint, etc.). The CDROM (or website) should be indexed and hyperlinked to facilit ate ease of us Contact Information: T. Fanelli (404) 997-4433 tnf1@nrc.gov
===List of Findings and Violations===
Failure to Justify the Quality and Reliability of Agastat Relays Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-01 Open/Closed
[H.3] - Change Management 71111.21N.


Information Gathering Visit: An information gathering visit is currently scheduled the week of November 6, 202 During this visit, we would like to identify the component samples for this inspectio Wed like to meet with procurement and dedication specialists to discuss the upcoming inspection and our sample selection proces Purposes of the site visit are to: (a)
The NRC identified a Green finding and associated NCV of TS 6.8.1.a, "Procedures," and Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation), dated November 1978, for failure to implement an effective maintenance strategy to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period was consistent with the manufactures ratings.
discuss the scope of the planned inspection; (b) obtain advance information to review in preparation for the inspection; (c) ensure that the information to be reviewed is available at the beginning of the inspection; and (d) verify that logistical iss ues (such as obtaining both site and computer system access and arranging the location of the inspec tion team working area) will be resolved prior to inspector arriva Please reserve a room dur ing the scheduled inspection dates. We request the room have a telephone, wireless internet access, and a licensee computer with access to procedures, corrective action program d ocuments, and a printe Logistics:


Information gathering visit: week of November 6, 2023 Onsite inspection weeks: weeks of November 27 and December 11, 2023
Failure to Address Critical Characteristics for Design Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-02 Open/Closed
[H.3] - Change Management 71111.21N.


Please schedule an entrance meeting for around 2:00 p.m. on Mon day, November 27, 2023 (approximately 15 minutes). The date and time of the exit meet ing will be discussed late In addition, Id like to have a daily debrief with your inspection support staff at a convenient time in the afternoons for both onsite inspection weeks (Time TBD, appr oximately 30 minutes).
The NRC identified a Green finding and associated NCV of Title 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements.


We will need a conference room as workspace for the inspector We will also need an area available for conducting interview Please provide access to your document system (preferably at le ast one computer in our conference room), nearby printers, and Wi-Fi acces During the information gathering visit, please provide info on (1) conference room location &
===Additional Tracking Items===
phone number, (2) cafeteria location/hours, and (3) procurement and engineering staff normal working hour Also, please let me know if there are any poten tial resource conflicts during our scheduled inspection weeks (Fridays off, EP drills, management retreats) and well do our best to accommodat R. Coffey 4
None.


Team Members: Theo Fanelli (Inspection Lead)
=INSPECTION SCOPES=
J. Hamman (Elec/CGD)
Inspect 3 (TBD)


Please verify the status of access authorization and requiremen ts for unescorted access for each inspecto Please provide me with a list of exceptions, a nd I will address the PAPERWORK REDUCTION ACT STATEMENT
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.


This letter contains voluntary information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
==REACTOR SAFETY==
approved these information collections (approval number 3150-00 11). The burden to the public for these information collections is estimated to average 60 ho urs per respons Send comments regarding this information collection to the Informati on Services Branch, Office of the Chief Information Officer, Mail Stop: T6A10M, U.S. Nuclear Reg ulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resourc e@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-102 02, (3150-0011) Office of Management and Budget, Washington, DC 2050 PUBLIC PROTECTION NOTIFICATION
===71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (section 03.01)===
{{IP sample|IP=IP 71111.21|count=11}}
The inspectors reviewed the implementation of the licensees processes for dedicating commercial-grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:
(1)
* Commercial Dedication Package (CGD) CID 321605-2 for Swagelok 1/2 inch Ball Valve (Replacement for safety-related valve tag number SH15440)
(2)
* Commercial Dedication Package CID 366270-1 for Mobil SHC-824OIL Hydraulic, 1-GALLON (i.e. hydraulic fluid consumable for safety related-functions)
(3)
* Commercial Dedication Package CID 366498-2 Regal Oil (i.e. oil consumable for safety relate-functions)
(4)
* Commercial Dedication Packages CID 366598-2 for Grout, and CID #
301609-1 for steel reinforcing bars (i.e. for reinforced concrete repairs on the Ultimate Heat Sink Barrier Wall)
(5)
* Commercial Dedication Package CID 366598-1 for Grout, and CID 381606-2 for steel reinforcing bars (i.e. for reinforced concrete repairs on Unit 2 ICW Pump Pedestal)
(6)
* Commercial Dedication Package CID 1720223 Module: RPS, Aux Trip Unit (7)
* Commercial Dedication Packages CID 197197 Board, Tri Bistable Trip PCA (8)
* Commercial Dedication Packages CID 309 923 Board, Control "B" (9)
* Commercial Dedication Packages CID 408443 Board, Printed Circuit:
Synchronizing, Static Inverter (10)
* Commercial Dedication Package CID 84949-2 Communication Isolation (11)
* Commercial Dedication Package CID 345075-1 Agastat Relay, Timing, 110-120 VAC, 5060 HZ, 20 to 200 Second


The NRC may not conduct nor sponsor, and a person is not requir ed to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control numbe 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 Regulat ions 2.390, Public Inspections, Exemptions, Requests for Withholdin Documents Requested Prior to Information Gathering Visit
==INSPECTION RESULTS==
Failure to Justify the Quality and Reliability of Agastat Relays Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-01 Open/Closed
[H.3] - Change Management 71111.21N.0 The NRC identified a Green finding and associated NCV of TS 6.8.1.a, "Procedures," and Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation), dated November 1978, for failure to implement an effective maintenance strategy to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period was consistent with the manufactures ratings.


The documents and information requested below should generally be made available to the inspection team for the team's use both on-site and off-site du ring the information gathering visi Electronic format is the preferred medi If electroni c media is made available via an internet-based remote document management system, then the remo te document access must allow inspectors to download, save, and print the documents in the NRC's regional office.
=====Description:=====
The team reviewed the sites licensing basis for Class 1E components, which specified that their quality and reliability shall be assured (IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations Sections 4.3 and 4.4). The inspectors reviewed normally energized Agastat relays model E7022AET004. The manufacturer qualified the relay for 25000 cycles or 10 years from the date of manufacture.


Electronic media on compact disc or paper records (hard copy) a re acceptabl At the end of the inspection, the documents in the team's possession will not be retaine This document request is based on typical documents that a gene ric plant might hav As such, it is not meant to imply that any specific plant is required to have all the listed document In addition, your plant specific docu ment titles may vary from the document titles listed belo We also request that the information provided be sorted by the lis t belo Documents requested by October 30, 2023: Licensing basis documents such as the updated final safety a nalysis report and technical specification. Procedures for dedicating commercial-grade items and for pro curement of safety-related component Procedure controlling counterfeit, fraudulent, and suspect item. List of commercial-grade items, with a brief description of application, that have been dedicated for safety-related application These items may be dedicated by Site or dedicated by a vendor (or another licensee) and procured by the Sit Please note whether the item has been installed in the plan The list sho uld encompass the past six years of dedication activitie. List of any commercial grade-items that failed after complet ing the dedication proces The list should encompass the past six years of dedication acti vitie. List of components procured as safety-related, with descript ions, if not included abov Please note whether the item has been installed in the plan The list should encompass the past six years of procurement activitie. List of corrective action program documents, with descriptio ns, related to commercial-grade items, procurement, or storage, including any items that failed after completing the dedication proces The list should encompass the past six yea rs of these activitie. List of systems, system numbers/designators, and correspondi ng name Enclosure Documents Requested Prior to Inspection Preparation Week
The licensee extended the shelf life to an unlimited life and the replacement life while in service to 15 years. The licensee used a UL thermal index value to justify this in JPN-PSL-89-1579, Related to Qualified Life of Agastat Relays at Nuclear Power Plants, dated 6/7/1989. Based on this analysis, the relays were determined to have an unlimited life while energized in service. However, operating experience has shown this to be incorrect with many failures in the industry. The site had recorded failures of these types of relays, within the last six years, in the corrective action program (e.g. AR 02391272 and AR02330068). The thermal index values do not account for the dynamic properties of the relay.


For the samples identified by the team lead, the documents and information requested below should generally be made available to the inspection team for t he team's use both on-site and off-site during the inspectio Electronic format is the prefe rred medi If electronic media is made available via an internet-based remote document management system, then the remote document access must allow inspectors to download, save, and pr int the documents in the NRC's regional offic Electronic media on compact disc or pap er records (hard copy) are acceptabl At the end of the inspection, the documents in the team's possession will not be retaine This document request is based on typical documents that a gene ric plant might have. As such, it is not meant to imply that any specific plant is required to have all the listed document In addition, your plant specific docu ment titles may vary from the document titles listed belo We also request that the information provided be sorted by the lis t below for each sampl Documents requested by November 20, 2023: Purchase requisition and purchase order. Other pertinent vendor/licensee correspondenc. Original and updated design specification. Catalog specification. Procurement basis evaluation such as like-for-like, equivale ncy, plant design change packages, drawing and specification update. 10 CFR 50.59 documentation, if require. Material receiving reports, packing lists/invoices, and othe r shipping document. Receipt inspection reports and any related test reports and evaluations (similarity etc.). Other documents to trace the item from the time it was dedic ated to the time it was installed, tested, and accepte. Certificates of conformance/compliance/qualit. Vendor test and inspection report. Third-party or sub-vendor test and inspection report. Shelf-life informatio. Vendor dedication/partial dedication informatio. Design/material/process change history informatio. Completed commercial-grade dedication document, including s afety classification; identification of safety function/application requirements; ide ntification of critical characteristics; identification of verification methods and acc eptance criteria for the critical characteristics, evaluation of credible failure modes (if applicable); and identification of the suppliers quality assurance program that meets 10 CFR Part 50, Appendix. Any deviation from design, material, and performance charac teristics relevant to the safety function (nonconformance dispositions).
In addition, the licensee justified the change with EPRI 3002000541, Relay Series-Specific Guidance: Generic Service Life Analyses (GSLA) and Preventive Maintenance (PM).


18. Documents showing objective evidence such as: special test and inspection procedures and results; commercial-grade survey reports, showing item, des ign, material, and specific performance characteristics (relevant to safety functi on); and source inspection report. Completed post-installation test procedure and result. Completed stock or material issue forms and installation wo rk orders or report. Historical performance informatio
However, Appendix A for Agastat 7000 relays states in part, for E7000 relays, all recommended preventive maintenance, inspections, and surveillances are performed as intended, and the applicable relays demonstrate acceptable performance during normal operation as well as during testing, and that the replacement interval needs to be established consistent with the manufacturers ratings. The inspectors determined that the licensees preventive maintenance, inspections, and surveillances were not performed as intended and replacement interval needs were not established consistent with the manufacturers ratings.
 
Records indicated that the Unit 1 relays were last replaced in 11/9/1991; approximately 32 years ago. The inspectors determined that the relays were not replaced within the interval required by the preventative maintenance program and was inconsistent with the manufacturers ratings.
 
Corrective Actions: The licensee entered the issue into the corrective action program to determine a resolution.
 
Corrective Action References: AR 02474574
 
=====Performance Assessment:=====
Performance Deficiency: The licensees failure to implement an effective maintenance strategy, to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period consistent with the manufactures ratings, 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 the quality and reliability resulted in a condition where the team had reasonable doubt that the Agastat relays could continue to perform their safety functions.
 
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 maintained its operability or PRA functionality - Screen to Green.
 
Cross-Cutting Aspect: H.3 - Change Management: Leaders did not use a systematic process for evaluating and implementing a change to relay shelf and in service life for Agastat relays that have a specified lifetime so that nuclear safety remains the overriding priority.
 
=====Enforcement:=====
Violation: TS 6.8.1.a requires in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Appendix A, February 1978. Section 9.b, requires in part, that preventive maintenance schedules should be developed to specify inspection of replacement parts that have a specified lifetime. The vendor specified lifetime is 25,000 operations or 10 years from the date of manufacture, whichever occurs first, which was exceeded for some relays.
 
Contrary to the above, since 11/9/1991, the licensee failed to develop and implement a preventive maintenance schedule, or an effective maintenance strategy to ensure the quality and reliability of Agastat control relays in the safety related applications.
 
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
 
Failure to Address Critical Characteristics for Design Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-02 Open/Closed
[H.7] -
Documentation 71111.21N.0 The NRC identified a Green finding and associated NCV of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements.
 
=====Description:=====
The inspectors reviewed the reverse engineering program and sampled six electronic board assemblies used in safety related analog and digital systems. The licensees used the equivalency evaluation process to address the rebuild and manufacturing of the new boards. The inspectors reviewed the Quality Assurance Topical Report (QATR) and identified that Electric Power Research Institute (EPRI) 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, was a regulatory commitment. Based on the review, deficiencies were identified in the program.
 
The inspectors sampled a small number of critical characteristics of design to determine how the reverse engineered components were verified and validated (temperature and humidity).
 
The licensee did not verify or validate these two characteristics even though many board components were not identical to the originals. The licensee determined that the equivalency evaluation process negated the requirement to verify the formal performance specifications for the components being reverse engineered. Thus, the licensee could not demonstrate the development of a technical evaluation and acceptance plan or a failure modes and effects analyses (FMEAs) to address the critical characteristics for design (e.g. systems and environments, temperature, interfaces, humidity etc.).
The inspectors determined that EPRI 3002002982, Section 6.1.3 Critical Characteristics for Design and Critical Characteristics for Acceptance, does specify that equivalency evaluations require critical characteristics for design. Critical characteristics for design ensure that the reverse engineered boards will meet the plants design requirements. For example, the characteristics address the items interaction with other parts, components, systems, and structures; the items interchangeability; and the items safety function, and dependability.
 
These characteristics are essential to the quality and reliability of these reverse engineered products.
 
Corrective Actions: The licensee entered the issue into the corrective action program.
 
Corrective Action References: AR 02474576
 
=====Performance Assessment:=====
Performance Deficiency: The failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements 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 the critical characteristics for design increased the likelihood of embedded latent flaws, which is averse to the availability, reliability, and capability of the components developed by the program and created a reasonable doubt about their operability.
 
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 - Screen to Green.
 
Cross-Cutting Aspect: H.7 Documentation: The organization did not create and maintain complete, accurate and up-to-date reverse engineering procedures and technical evaluation instructions for equivalency evaluations. (WP.3).
 
=====Enforcement:=====
Violation: 10 CFR 50, Appendix B, Criterion III, Design Control, states in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
 
Contrary to the above, since 2017 the licensee failed to ensure that applicable design basis for safety related electronic circuit boards were correctly translated into specifications, drawings, procedures, and instructions for reverse engineering activities.
 
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 15, 2023, the inspectors presented the NRC inspection results to Mr.
 
Robert Craven and other members of the licensee staff.
* On December 14, 2023, the inspectors presented the Inspection Debrief inspection results to Tim Falkiewicz St. Lucie Plant, N Regulatory Affairs Manager and other members of the licensee staff.
 
=DOCUMENTS REVIEWED=
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
AR 02471898
EXPIRED GREASE FOUND IN CABINET DURING NRC
WALKDOWN
11/8/2023
AR 02473098
PROCESS IMPROVEMENTS IN DOCUMENTING
DEDICATION TESTING
11/27/2023
AR 02473617
23 NRC CGD INSPECTION - ISC TS ASE - TECH
EVAL - 84949-2
2/4/2023
AR 02474574
23 CGD INSP - GREEN NCV - QUAL AND REL OF
AGASTAT RELAYS
2/14/2023
AR 02474576
23 CGD INSP - GREEN NCV - RE DESIGN CRITICAL
CHARAC.
2/14/2023
AR 02474577
23 CGD INSP - MINOR VIOLATION - DOC ERROR IN
RE BOARD
2/14/2023
Corrective Action
Documents
Resulting from
Inspection
AR 02474578
23 CGD INSP - MINOR VIOLATION - APPEND B
MAT'L STORAGE
2/14/2023
Drawings
2998-A-451-1000
Equipment Qualification Documentation Package
rev. 15
00427168
Procurement Engineering Evaluation Record Agastat
04/11/2011
2357321
Technical Evaluation Document CID 366598-1 for Grout
9/28/2016
2379992
Technical Evaluation Document CID 366270-1 for Mobil
SHC-824 Hydraulic Fluid/Oil
7/13/2020
273211981
Technical Evaluation Document CID 366498-2 Regal Oil
6/11/2022
CPED-RE-
20223
Technical Evaluation Document CID 1720223-2 Auxiliary
Trip Unit
10/18/21
CPED-RE-
197197-2022
Technical Evaluation Document CID 197197 Tri-Bistable
Trip PCB
11/02/22
CPED-RE-
309923-2017
Technical Evaluation Document CID 309923 C&D Control
B PCB
2/19/17
CPED-RE-
347646-2019
Technical Evaluation Document CID 347646 Synchnizing
Board
2/11/2019
PEER 00465158
Technical Evaluation Document CID 301609-1 for
Concrete Steel Reinforcing Bars
07/17/2015
71111.21N.03
Engineering
Evaluations
PEER 00477369
Technical Evaluation Document CID 381606-2 for
Concrete Steel Reinforcing Bars
08/10/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PEER 00488497
Technical Evaluation Document CID CID 366598-2 for
Grout
10/14/2020
SS-63TF8
Technical Evaluation Document CID 321605-2 Swagelok
1/2 inch Ball Valve
10/01/2020
Technical
Evaluation
CPED-RE-
84949-2022
Communication Isolation Device
rev 4
}}
}}

Latest revision as of 20:41, 24 November 2024

NRC Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication Report 05000335/2023010 and 05000389/2023010
ML24025A058
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 01/26/2024
From: James Baptist
NRC/RGN-II/DRS/EB1
To: Coffey B
Florida Power & Light Co
References
IR 2023010
Download: ML24025A058 (12)
v • d • e


Text

SUBJECT:

ST. LUCIE PLANT UNITS 1 AND 2 - NRC QUADRENNIAL FOCUSED ENGINEERING INSPECTION (FEI) COMMERCIAL GRADE DEDICATION REPORT 05000335/2023010 AND 05000389/2023010

Dear Bob Coffey:

On December 15, 2023, 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.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St. Lucie 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.

January 26, 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, James B. Baptist, Chief Engineering Branch 1 Division of 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:

05000335/2023010 and 05000389/2023010 Enterprise Identifier:

I-2023-010-0052 Licensee:

Florida Power and Light Company Facility:

St. Lucie Plant Units 1 and 2 Location:

Jensen Beach, FL.

Inspection Dates:

November 27, 2023 to December 15, 2023 Inspectors:

T. Fanelli, Senior Reactor Inspector J. Lizardi-Barreto, Reactor Inspector T. Su, Reactor Inspector Approved By:

James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection 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

Failure to Justify the Quality and Reliability of Agastat Relays Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-01 Open/Closed

[H.3] - Change Management 71111.21N.

The NRC identified a Green finding and associated NCV of TS 6.8.1.a, "Procedures," and Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation), dated November 1978, for failure to implement an effective maintenance strategy to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period was consistent with the manufactures ratings.

Failure to Address Critical Characteristics for Design Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-02 Open/Closed

[H.3] - Change Management 71111.21N.

The NRC identified a Green finding and associated NCV of Title 10 CFR Part 50, Appendix B,

Criterion III, Design Control, for the failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements.

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.03 - Commercial Grade Dedication Commercial Grade Dedication (section 03.01)

Main article: IP 71111.21

The inspectors reviewed the implementation of the licensees processes for dedicating commercial-grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:

(1)

  • Commercial Dedication Package (CGD) CID 321605-2 for Swagelok 1/2 inch Ball Valve (Replacement for safety-related valve tag number SH15440)

(2)

  • Commercial Dedication Package CID 366270-1 for Mobil SHC-824OIL Hydraulic, 1-GALLON (i.e. hydraulic fluid consumable for safety related-functions)

(3)

  • Commercial Dedication Package CID 366498-2 Regal Oil (i.e. oil consumable for safety relate-functions)

(4)

301609-1 for steel reinforcing bars (i.e. for reinforced concrete repairs on the Ultimate Heat Sink Barrier Wall)

(5)

  • Commercial Dedication Package CID 366598-1 for Grout, and CID 381606-2 for steel reinforcing bars (i.e. for reinforced concrete repairs on Unit 2 ICW Pump Pedestal)

(6)

Synchronizing, Static Inverter (10)

  • Commercial Dedication Package CID 345075-1 Agastat Relay, Timing, 110-120 VAC, 5060 HZ, 20 to 200 Second

INSPECTION RESULTS

Failure to Justify the Quality and Reliability of Agastat Relays Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-01 Open/Closed

[H.3] - Change Management 71111.21N.0 The NRC identified a Green finding and associated NCV of TS 6.8.1.a, "Procedures," and Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation), dated November 1978, for failure to implement an effective maintenance strategy to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period was consistent with the manufactures ratings.

Description:

The team reviewed the sites licensing basis for Class 1E components, which specified that their quality and reliability shall be assured (IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations Sections 4.3 and 4.4). The inspectors reviewed normally energized Agastat relays model E7022AET004. The manufacturer qualified the relay for 25000 cycles or 10 years from the date of manufacture.

The licensee extended the shelf life to an unlimited life and the replacement life while in service to 15 years. The licensee used a UL thermal index value to justify this in JPN-PSL-89-1579, Related to Qualified Life of Agastat Relays at Nuclear Power Plants, dated 6/7/1989. Based on this analysis, the relays were determined to have an unlimited life while energized in service. However, operating experience has shown this to be incorrect with many failures in the industry. The site had recorded failures of these types of relays, within the last six years, in the corrective action program (e.g. AR 02391272 and AR02330068). The thermal index values do not account for the dynamic properties of the relay.

In addition, the licensee justified the change with EPRI 3002000541, Relay Series-Specific Guidance: Generic Service Life Analyses (GSLA) and Preventive Maintenance (PM).

However, Appendix A for Agastat 7000 relays states in part, for E7000 relays, all recommended preventive maintenance, inspections, and surveillances are performed as intended, and the applicable relays demonstrate acceptable performance during normal operation as well as during testing, and that the replacement interval needs to be established consistent with the manufacturers ratings. The inspectors determined that the licensees preventive maintenance, inspections, and surveillances were not performed as intended and replacement interval needs were not established consistent with the manufacturers ratings.

Records indicated that the Unit 1 relays were last replaced in 11/9/1991; approximately 32 years ago. The inspectors determined that the relays were not replaced within the interval required by the preventative maintenance program and was inconsistent with the manufacturers ratings.

Corrective Actions: The licensee entered the issue into the corrective action program to determine a resolution.

Corrective Action References: AR 02474574

Performance Assessment:

Performance Deficiency: The licensees failure to implement an effective maintenance strategy, to ensure the continued quality and reliability of energized Agastat E7000 relays for an extended period consistent with the manufactures ratings, 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 the quality and reliability resulted in a condition where the team had reasonable doubt that the Agastat relays could continue to perform their safety functions.

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 maintained its operability or PRA functionality - Screen to Green.

Cross-Cutting Aspect: H.3 - Change Management: Leaders did not use a systematic process for evaluating and implementing a change to relay shelf and in service life for Agastat relays that have a specified lifetime so that nuclear safety remains the overriding priority.

Enforcement:

Violation: TS 6.8.1.a requires in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33, Appendix A, February 1978. Section 9.b, requires in part, that preventive maintenance schedules should be developed to specify inspection of replacement parts that have a specified lifetime. The vendor specified lifetime is 25,000 operations or 10 years from the date of manufacture, whichever occurs first, which was exceeded for some relays.

Contrary to the above, since 11/9/1991, the licensee failed to develop and implement a preventive maintenance schedule, or an effective maintenance strategy to ensure the quality and reliability of Agastat control relays in the safety related applications.

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

Failure to Address Critical Characteristics for Design Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000335,05000389/2023010-02 Open/Closed

[H.7] -

Documentation 71111.21N.0 The NRC identified a Green finding and associated NCV of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements.

Description:

The inspectors reviewed the reverse engineering program and sampled six electronic board assemblies used in safety related analog and digital systems. The licensees used the equivalency evaluation process to address the rebuild and manufacturing of the new boards. The inspectors reviewed the Quality Assurance Topical Report (QATR) and identified that Electric Power Research Institute (EPRI) 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, was a regulatory commitment. Based on the review, deficiencies were identified in the program.

The inspectors sampled a small number of critical characteristics of design to determine how the reverse engineered components were verified and validated (temperature and humidity).

The licensee did not verify or validate these two characteristics even though many board components were not identical to the originals. The licensee determined that the equivalency evaluation process negated the requirement to verify the formal performance specifications for the components being reverse engineered. Thus, the licensee could not demonstrate the development of a technical evaluation and acceptance plan or a failure modes and effects analyses (FMEAs) to address the critical characteristics for design (e.g. systems and environments, temperature, interfaces, humidity etc.).

The inspectors determined that EPRI 3002002982, Section 6.1.3 Critical Characteristics for Design and Critical Characteristics for Acceptance, does specify that equivalency evaluations require critical characteristics for design. Critical characteristics for design ensure that the reverse engineered boards will meet the plants design requirements. For example, the characteristics address the items interaction with other parts, components, systems, and structures; the items interchangeability; and the items safety function, and dependability.

These characteristics are essential to the quality and reliability of these reverse engineered products.

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

Corrective Action References: AR 02474576

Performance Assessment:

Performance Deficiency: The failure to ensure that reversed engineered electrical components met the critical characteristics for design and thus the plants design requirements 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 the critical characteristics for design increased the likelihood of embedded latent flaws, which is averse to the availability, reliability, and capability of the components developed by the program and created a reasonable doubt about their operability.

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 - Screen to Green.

Cross-Cutting Aspect: H.7 Documentation: The organization did not create and maintain complete, accurate and up-to-date reverse engineering procedures and technical evaluation instructions for equivalency evaluations. (WP.3).

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion III, Design Control, states in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, since 2017 the licensee failed to ensure that applicable design basis for safety related electronic circuit boards were correctly translated into specifications, drawings, procedures, and instructions for reverse engineering activities.

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 15, 2023, the inspectors presented the NRC inspection results to Mr.

Robert Craven and other members of the licensee staff.

  • On December 14, 2023, the inspectors presented the Inspection Debrief inspection results to Tim Falkiewicz St. Lucie Plant, N Regulatory Affairs Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AR 02471898

EXPIRED GREASE FOUND IN CABINET DURING NRC

WALKDOWN

11/8/2023

AR 02473098

PROCESS IMPROVEMENTS IN DOCUMENTING

DEDICATION TESTING

11/27/2023

AR 02473617

23 NRC CGD INSPECTION - ISC TS ASE - TECH

EVAL - 84949-2

2/4/2023

AR 02474574

23 CGD INSP - GREEN NCV - QUAL AND REL OF

AGASTAT RELAYS

2/14/2023

AR 02474576

23 CGD INSP - GREEN NCV - RE DESIGN CRITICAL

CHARAC.

2/14/2023

AR 02474577

23 CGD INSP - MINOR VIOLATION - DOC ERROR IN

RE BOARD

2/14/2023

Corrective Action

Documents

Resulting from

Inspection

AR 02474578

23 CGD INSP - MINOR VIOLATION - APPEND B

MAT'L STORAGE

2/14/2023

Drawings

2998-A-451-1000

Equipment Qualification Documentation Package

rev. 15

00427168

Procurement Engineering Evaluation Record Agastat

04/11/2011

2357321

Technical Evaluation Document CID 366598-1 for Grout

9/28/2016

2379992

Technical Evaluation Document CID 366270-1 for Mobil

SHC-824 Hydraulic Fluid/Oil

7/13/2020

273211981

Technical Evaluation Document CID 366498-2 Regal Oil

6/11/2022

CPED-RE-

20223

Technical Evaluation Document CID 1720223-2 Auxiliary

Trip Unit

10/18/21

CPED-RE-

197197-2022

Technical Evaluation Document CID 197197 Tri-Bistable

Trip PCB

11/02/22

CPED-RE-

309923-2017

Technical Evaluation Document CID 309923 C&D Control

B PCB

2/19/17

CPED-RE-

347646-2019

Technical Evaluation Document CID 347646 Synchnizing

Board

2/11/2019

PEER 00465158

Technical Evaluation Document CID 301609-1 for

Concrete Steel Reinforcing Bars

07/17/2015

71111.21N.03

Engineering

Evaluations

PEER 00477369

Technical Evaluation Document CID 381606-2 for

Concrete Steel Reinforcing Bars

08/10/2017

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

PEER 00488497

Technical Evaluation Document CID CID 366598-2 for

Grout

10/14/2020

SS-63TF8

Technical Evaluation Document CID 321605-2 Swagelok

1/2 inch Ball Valve

10/01/2020

Technical

Evaluation

CPED-RE-

84949-2022

Communication Isolation Device

rev 4

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