IR 05000335/2021003: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot change) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
| Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:November 3, 2021 | ||
==SUBJECT:== | |||
ST LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2021003 AND 05000389/2021003 | |||
==Dear Mr. Coffey:== | |||
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St Lucie Units 1 & 2. On October 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. Dan DeBoer, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report. | |||
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. | |||
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: | |||
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St Lucie Units 1 & 2. 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, | |||
/RA/ | |||
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects 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: 05000335/2021003 and 05000389/2021003 Enterprise Identifier: I-2021-003-0006 Licensee: Florida Power & Light Company Facility: St Lucie Units 1 & 2 Location: Jenson Beach, FL 34957 Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: A. Butcavage, Reactor Inspector J. Diaz-Velez, Senior Health Physicist J. Griffis, Senior Health Physicist D. Orr, Senior Resident Inspector W. Pursley, Health Physicist J. Rivera, Health Physicist S. Roberts, Resident Inspector Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure | |||
=SUMMARY= | |||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at St Lucie Units 1 & 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=== | |||
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.19 Systems NCV 05000389/2021003-01 Open An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional. | |||
===Additional Tracking Items=== | |||
None. | |||
=PLANT STATUS= | |||
Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period. | |||
Unit 2 operated at or near RTP until the unit was shutdown for planned refueling outage, SL2-26, on August 28, 2021. Unit 2 was restarted on September 29, 2021, and was in the process of power ascension, achieving 93 percent RTP, when the inspection period ended on September 30, | |||
==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. | |||
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted. | |||
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP | |||
===71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP. | |||
==REACTOR SAFETY== | |||
==71111.04 - Equipment Alignment== | |||
Partial Walkdown Sample (IP Section 03.01) === | |||
{{IP sample|IP=IP 71152|count=4}} | |||
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | |||
: (1) Unit 1 auxiliary feedwater system (AFW) and 1A emergency diesel generator (EDG)while the 1B EDG was out of service (OOS) for planned maintenance on July 15, 2021 | |||
: (2) Unit 1 containment spray (CS) B train while A train was OOS for planned maintenance on August 4, 2021 | |||
: (3) Unit 2 CS A train while the 2B CS pump was OOS for surveillance testing and the 2B CS pump after surveillance testing completed on August 25, 2021 | |||
: (4) Unit 2 spent fuel pool cooling system during refueling outage SL2-26 full core offload window on September 8, 2021 | |||
==71111.05 - Fire Protection== | |||
===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)=== | |||
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas: | |||
: (1) Unit 2 control element assembly motor-generator area, reactor auxiliary building (RAB) on July 7, 2021 | |||
: (2) Unit 2 fuel handling building on July 21, 2021 | |||
: (3) 1B EDG building on August 3, 2021 | |||
: (4) Unit 2 RAB 43 foot elevation on August 10, 2021 | |||
: (5) Unit 2 reactor containment building on September 8, 2021 | |||
: (6) Unit 2 cable spread room on September 11, 2021 | |||
: (7) Unit 1 and Unit 2 external control zones on September 15, 2021 | |||
: (8) Unit 2 electrical penetration rooms on September 20, 2021 | |||
===71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01) === | |||
{{IP sample|IP=IP 71111.08|count=1}} | |||
The inspectors verified that the reactor coolant system boundary, steam generator tubes, risk-significant piping system boundaries, and containment moisture barrier are appropriately monitored for degradation and that sample repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from August 30, 2021 to October 4, 2021. | |||
(1)03.01.a - Nondestructive Examination (NDE) and Welding Activities. | |||
* Ultrasonic Examination (UT), RC-147-1-SW-2 (MRP-146), ASME Class1, Elbow to Pipe Weld and Elbow Base Material | |||
* WO 40787195, Safety Injection Piping, Valve 3259, ASME Class 1, Weld Package | |||
* WO 40718077-05, Low Pressure Safety Injection (LPSI) Pump 2A, Valve 3104 to Pipe, ASME Class 2, Weld Package | |||
* Containment Integrated Leak Rate Test Results Samples | |||
* Containment Moisture Barrier, Annulus Side, NDE Reports: PSL2-21-VT-1000, PSL2-21-VT-1001, PSL2-21-VT-1002, PSL2-21-VT-1003, PSL2-21-VT-1004, PSL2-21-VT-1005 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities. | |||
* SL2-26 Reactor Vessel Closure Head In-Service Inspection Bare Metal Visual Examination, in accordance with Code Case N-729, ASME Class 1, Report 180-9336089 and Photo Review | |||
* Reactor head penetration #85 presented potential boric acid recordable indication. Accepted for continued service by additional evaluation (AR | |||
===02403288) and verbal authorization of NRC Relief Request No.19 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities. | |||
The inspectors evaluated the licensees boric acid corrosion control program performance, through photographs provided for the Reactor Vessel Head and other areas described in action requests, and sample action requests combined with review of the boric acid program corrective actions and evaluations of reported leakage as listed in the documents reviewed section. | |||
* Review of the licensee containment boric acid walkdown inspection results and Action Request (AR) initiations. | |||
* Review of engineering boric acid AR evaluations and dispositions associated with: | |||
AR 02365843-01, Active borated water leak of 20 drops/minute, Unit 2 Line No. | |||
CS-76 AR 02392964-01, Wet boric acid found on the 2A Low Pressure Safety Injection (LPSI) pump AR 02402992, - White Residue - 2B2 Cold Leg Nozzle to Main Spray (PCV-1100E) | |||
AR 02403787-01, Noted Inactive Boric Acid Residue on the Reactor Vessel Bottom Head area Insulation 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities. | |||
* Major Scope: Bobbin Coil,100% Full Length, Active Tubes Each steam generator (SG) for wear, Array Probe, HL and CL expansion transitions in periphery (high flow) TTS region, for Loose Part Detection and Foreign Object Wear, +Point (TM) Probe, for all new dents and dings, PWSCC and ODSCC (not potential), Visual for all tube plugs. (Details contained in Document Reference AIM 210510993-2Q-1, Rev. 2) | |||
* Observed remotely a sample of resolution analyst dispositions during the Resolution Process | |||
* Review of secondary side AR 02403170, Feed Ring Support Inspection & | |||
Repair | |||
* Review of AIM 210711013-2Q-1, Screening Chart Basis for Condition Monitoring of St. Lucie Unit 2 Steam Generators for the September 2021 Inspection | |||
* OE Review: AR No. 01730372, San Onofre Steam Generator Tube Leak | |||
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance== | |||
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample) | |||
: (1) The inspectors observed and evaluated licensed operator performance in the control room during: | |||
* Interim pressurization of the Unit 2 safety injection tanks (SIT) due to a slow pressure loss in the 2A2 SIT on July 27, 2021 | |||
* A planned power reduction and shutdown of Unit 2 to support refueling outage SL2-26 on August 27-28, 2021 | |||
* Unit 2 startup and power ascension activities following refueling outage SL2-26 on September 29, 2021 Licensed Operator Requalification Training/Examinations (IP Section 03.02) === | |||
{{IP sample|IP=IP 02403|count=1}} | |||
: (1) The inspectors observed and evaluated an operating crews response to a requalification training simulator scenario in the control room simulator on July 26, 2021. | |||
==71111.12 - Maintenance Effectiveness== | |||
===Maintenance Effectiveness (IP Section 03.01) (3 Samples)=== | |||
: (1) AR 2401971, 2021 maintenance rule (a)(3) evaluation on September 20, 2021 | |||
: (2) AR 2402451, 2A intake cooling water (ICW) pump did not start in required time on September 27, 2021 | |||
: (3) AR 2400485, entry into 2-AOP-18.01, Instrument Air Malfunction on September 30, 2021 | |||
==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | |||
===Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)=== | |||
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed: | |||
: (1) Unit 1 elevated risk with the 1B EDG OOS for planned maintenance on July 15, 2021, and Unit 2 elevated risk with the 2AA 125 VDC battery charger OOS for emergent repairs on July 15, 2021 | |||
: (2) Unit 2 elevated risk with the 2B CS, 2B high pressure safety injection (HPSI), and 2B low pressure safety injection (LPSI) pumps OOS to troubleshoot flow transmitter, FT-07-03, associated with the reactor cavity sump inlet flow monitoring system on July 27, 2021 | |||
: (3) Unit 1 elevated risk with the 1A EDG OOS for planned maintenance from August 2-6, 2021 | |||
: (4) Unit 1 and Unit 2 elevated risk for the 1B and 2B startup transformers OOS for planned maintenance and Unit 1 additional elevated risk for battery charger 1AB OOS for a load test on August 18, 2021 | |||
: (5) Unit 2 yellow shutdown safety assessment (SSA) with the reactor coolant system (RCS) depressurized and level lowered to support reactor head removal on September 1, 2021 | |||
: (6) Unit 2 yellow SSA with 2A EDG and A train electrical busses OOS for 4160 volt breaker replacement from September 6-10, 2021 | |||
==71111.15 - Operability Determinations and Functionality Assessments== | |||
===Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)=== | |||
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments: | |||
: (1) AR 2398812, little to no seal packing gland leak-off flow for 1B ICW pump on August 22, 2021 | |||
: (2) AR 2401630, tritium identified internal to the Unit 1 CCW system on August 27, 2021 | |||
: (3) AR 2398173, through-wall leak on 1B ICW header on September 20, 2021 | |||
: (4) AR 2400714, pressurizer safety valve, PSV-V1202, failed as-found lift test on September 21, 2021 | |||
: (5) AR 2403182 and 2403284, debris identified on fuel assembly lower tie plates during Unit 2 end of fuel cycle 25 bottom nozzle inspections on September 21, 2021 | |||
==71111.18 - Plant Modifications== | |||
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample) | |||
The inspectors evaluated the following temporary or permanent modifications: | |||
: (1) EC 296363, installation of jumper across synchroscope check relay in 4160 volt switchgear | |||
==71111.19 - Post-Maintenance Testing== | |||
===Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)=== | |||
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality: | |||
: (1) WO 40738733, 1B EDG critical maintenance management (CMM), 36 month preventive maintenance inspection on July 21, 2021 | |||
: (2) WO 40715198, 480V breaker replacement for 1A CS pump isolation valve, MV-07-3A, on August 5, 2021 | |||
: (3) WO 40785251, 2AA battery charger phase alarm, troubleshoot and repair on September 13, 2021 | |||
: (4) WO 40792135, 2A3 4160 volt switchgear undervoltage relay 27-1 repair on September 14, 2021 | |||
: (5) WOs 40687479, 40687481, 40682187, 40687483, 40682186, and 40687482, Unit 2 reactor trip switchgear TCB-1, 2, 3, 5, 6, and 7 respectively, perform breaker swap, and WO 40792125, Unit 2 reactor trip switchgear TCB-1 through 8 - inadequate surveillance on September 27, 2021 | |||
: (6) WO 40602138, replace 2A EDG digital reference unit and electronic governor control unit replacements on September 27, 2021 | |||
: (7) WO 40755282, 1A fire water pump repair on September 27, 2021 | |||
: (8) WO 40628431, Unit 2 safety linear power range detector number 5 for uncompensated ion chamber replacement and associated WO 40717791, install de-calibration factors for reactor protection system channel A on September 28, 2021 | |||
: (9) WO 40710305, Unit 2 startup range nuclear instrument channel number 2 has low counts on September 28, 2021 | |||
==71111.20 - Refueling and Other Outage Activities== | |||
===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)=== | |||
: (1) The inspectors evaluated Unit 2 refueling outage SL2-26 activities from August 28, 2021 to September 30, 2021. | |||
==71111.22 - Surveillance Testing== | |||
The inspectors evaluated the following surveillance tests: | |||
===Surveillance Tests (other) (IP Section 03.01)=== | |||
{{IP sample|IP=IP 71111.22|count=6}} | |||
: (1) 2-OSP-59.01A, 2A Emergency Diesel Generator Monthly Surveillance, fast start from the control room on July 6, 2021 | |||
: (2) 1-SMI-09.05C, 1C Auxiliary Feedwater Pump Flow Channel Check on July 20, 2021 | |||
: (3) 1-OSP-52.01B, Surveillance Test of Degraded Grid Voltage B Train on August 19, 2021 | |||
: (4) 0-SME-50.06, Safety Related 125 VDC System Monthly Maintenance, for the 1B battery on August 23, 2021 | |||
: (5) 2-SMM-08.08, Main Steam Safety Valve Setpoint Surveillance Using Furmanite Trevitest Mark VIII Equipment on September 21, 2021 | |||
: (6) 2-OSP-24.01, RAB Fluid Systems Periodic Leak Test, Attachment 8, 2A High Pressure Safety Injection System Leak Test on September 21, 2021 | |||
===Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)=== | |||
: (1) 2-OSP-68.01, Integrated Leak Test, on September 22, 2021 | |||
==71114.06 - Drill Evaluation== | |||
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample) | |||
: (1) On October 14, 2021 the inspectors evaluated an emergency response drill that included a loss of coolant accident (LOCA), reactor trip, and safety injection. The scenario included situations that resulted in declarations of Unusual Event, Alert, Site Area Emergency, and General Emergency. | |||
==RADIATION SAFETY== | |||
==71124.01 - Radiological Hazard Assessment and Exposure Controls== | |||
===Radiological Hazard Assessment (IP Section 03.01) (1 Sample)=== | |||
: (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards. | |||
===Instructions to Workers (IP Section 03.02) (1 Sample)=== | |||
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas. | |||
: (1) The inspectors reviewed the following: | |||
Radiation Work Packages | |||
* RWP 21-3441, Eddy Current Testing | |||
* RWP 21-3438, S/G Primary Side Support Work | |||
* RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal Electronic Alarming Dosimeter Alarms | |||
* AR 02391119 | |||
* AR 02390317 | |||
* AR 02390457 Labeling of Containers | |||
* Sealand Containers in Outdoor RCA | |||
* Ground Shields in Outdoor RCA Containing HICs of Miscellaneous Waste | |||
* Vacuum Cleaners and HEPA Units in the S/G Blowdown Building | |||
===Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)=== | |||
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. | |||
: (1) Observed licensee surveys of potentially contaminated material leaving the RCA during the Unit 2 refueling outage | |||
: (2) Observed licensee activities at the Unit 2 Reactor Building equipment hatch during the unit 2 refueling outage | |||
: (3) Observed workers exiting the RCA at the RP control point during the Unit 2 refueling outage. | |||
===Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)=== | |||
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities. | |||
: (1) RWP-21-3102 Surveys for unit 2 reactor head disassembly | |||
: (2) RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal | |||
: (3) RWP 21-3008, Unit 2 reactor head lift High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples) | |||
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas: | |||
: (1) LHRA Control Unit 1 Waste Ion Exchanger Room | |||
: (2) LHRA Control Unit 1 Spent Fuel Pool Ion Exchanger Room | |||
: (3) LHRA Control Unit 1 Volume Control Tank Room | |||
: (4) VHRA Unit Reactor Containment Building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample) | |||
: (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements during the Unit 2 refueling outage. | |||
==71124.02 - Occupational ALARA Planning and Controls== | |||
===Radiological Work Planning (IP Section 03.01) (5 Samples)=== | |||
The inspectors evaluated the licensees radiological work planning for: | |||
: (1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1004) | |||
: (2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-1030) | |||
: (3) SL1-30 Incore Detectors Remove/Install, Cut Up and Dispose ALARA Package (RWP 21-1118) | |||
: (4) SL2-26 Reactor Disassembly/Assembly ALARA Package (RWP 21-3001, Rev. 0) | |||
: (5) SL2-26 RCB Scaffold Install/Remove ALARA Package (RWP 21-3018, Rev. 0) | |||
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples) | |||
The inspectors evaluated dose estimates and exposure tracking for: | |||
: (1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1004) and the respective radiological outcome evaluation. | |||
: (2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-1030) and the respective radiological outcome evaluation. | |||
: (3) SL1-30 Incore Detectors Remove/Install, Cut Up and Dispose ALARA Package (RWP 21-1118) and the respective radiological outcome evaluation. | |||
===Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (2 Samples)=== | |||
The inspectors reviewed as low as reasonably achievable practices and radiological work controls. | |||
: (1) The inspectors reviewed RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and switch adjustment activities. | |||
: (2) The inspectors reviewed RWP 21-3008 (LHRA) Reactor Head (Remove / Replace). | |||
All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and performed the reactor head lift. | |||
===Radiation Worker Performance (IP Section 03.04) (1 Sample)=== | |||
The inspectors evaluated radiation worker and radiation protection technician performance during: | |||
: (1) RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities | |||
==71124.03 - In-Plant Airborne Radioactivity Control and Mitigation== | |||
===Permanent Ventilation Systems (IP Section 03.01) (2 Samples)=== | |||
The inspectors evaluated the configuration of the following permanently installed ventilation systems: | |||
: (1) Control Room Emergency Ventilation System (HV-13) for Units 1 and 2 | |||
: (2) Reactor Auxiliary Building Ventilation System (HV-10) for Units 1 and 2 | |||
===Temporary Ventilation Systems (IP Section 03.02) (2 Samples)=== | |||
The inspectors evaluated the configuration of the following temporary ventilation systems: | |||
: (1) HEPA Unit 004 staged in Unit 1 Cavity to support Reactor Disassembly | |||
: (2) HEPA Unit 058 supporting filter changeout in the Steam Generator Blowdown | |||
===Building Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)=== | |||
: (1) The inspectors evaluated the licensees use of respiratory protection devices. | |||
===Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)=== | |||
: (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses. | |||
==71124.04 - Occupational Dose Assessment== | |||
===Source Term Characterization (IP Section 03.01) (1 Sample)=== | |||
: (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization. The evaluation included a review of the licensee's Site Alpha Characterization Update, dated August 24, 2020. | |||
===External Dosimetry (IP Section 03.02) (1 Sample)=== | |||
: (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign external dose. | |||
===Internal Dosimetry (IP Section 03.03) (1 Sample)=== | |||
The inspectors evaluated the internal dosimetry program implementation. | |||
: (1) The inspectors reviewed the following: | |||
Whole Body Counts | |||
* Whole Body Count (WBC) data and exposure investigation information for Personal Contamination Event (PCE) 21-005 | |||
* WBC data and exposure investigation information for PCE 21-007 | |||
* WBC data and exposure investigation information for facial contamination associated with CR 02347965 No internal dose assessments were available for review during the inspection that used in-vitro monitoring or air sampling and Derived Air Concentration (DAC)-hour monitoring. | |||
===Special Dosimetric Situations (IP Section 03.04) (1 Sample)=== | |||
The inspectors evaluated the following special dosimetric situations: | |||
(1) | |||
* Dose assessment and implementation of fetal monitoring for one declared pregnant worker. | |||
* Multi-badging and calculation of Effective Dose Equivalent (EDEX) for workers who were monitored under RWP 2-2144 (Upender Bracket Replacement), | |||
RWP 20-3008 (Reactor Head Set), and RWP 21-1008-2 (Reactor Head Set). | |||
==71124.05 - Radiation Monitoring Instrumentation== | |||
===Walkdowns and Observations (IP Section 03.01) (7 Samples)=== | |||
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns: | |||
: (1) Electronic dosimeters at HP control point. | |||
: (2) Portable instrumentation in the instrumentation lab. | |||
: (3) Small Article Monitors (SAMs) at the Radiologically Controlled Area (RCA) exit point. | |||
: (4) Personnel Contamination Monitors (PCMs) at the RCA exit point. | |||
: (5) Portal Monitors (PMs) at the Protected Area (PA) exit point. | |||
: (6) Area Radiation Monitors (ARMs) in the Unit 2 auxiliary building. | |||
: (7) ARMs in the Unit 1 spent fuel pool. | |||
===Calibration and Testing Program (IP Section 03.02) (15 Samples)=== | |||
The inspectors evaluated the calibration and testing of the following radiation detection instruments: | |||
: (1) Unit 2 Containment High Range Monitor, RIM-26-41. | |||
: (2) DMC 3000 electronic dosimeter no. 987428. | |||
: (3) Ludlum 9-3 ion chamber, SN 336971. | |||
: (4) Ludlum 12 count rate meter, SN 305073. | |||
: (5) Ludlum 177 alarm rate meter, SN 19552. | |||
: (6) Argos 5AB PCM, SN 1411-311. | |||
: (7) SAM-12, SN 12052. | |||
: (8) Eberline AMS-4 continuous air monitor, SN 12617. | |||
: (9) Eberline AMS-4 continuous air monitor, SN 1615. | |||
: (10) MGP AMP-100 area monitor, SN 5008-090. | |||
: (11) MGP Telepole, SN 6605-039. | |||
: (12) Ludlum 2241-4 neutron meter, SN 286222. | |||
: (13) GEM-5 PM, SN 1307-176. | |||
: (14) Whole Body Counter, Fastscan2. | |||
: (15) Whole Body Counter, Fastscan3. | |||
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples) | |||
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation: | |||
: (1) Unit 2 Plant Vent Stack Gaseous Effluent Monitor, RM-26-14. | |||
: (2) Unit 1 Liquid Effluents Monitor, RE-6627. | |||
==OTHER ACTIVITIES - BASELINE== | |||
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: | |||
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) === | |||
{{IP sample|IP=IP 71151|count=2}} | |||
: (1) Unit 1, Safety System Functional Failures from July 1, 2020 through June 30, 2021 | |||
: (2) Unit 2, Safety System Functional Failures from July 1, 2020 through June 30, 2021 | |||
===OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)=== | |||
: (1) November 1, 2019 - October 31, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample) | |||
: (1) November 1, 2019 - August 18, 2021 | |||
==71152 - Problem Identification and Resolution== | |||
===Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)=== | |||
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues: | |||
: (1) AR 2400507, 1A EDG uncontrolled load swings during functional test | |||
: (2) Several issues documented in the licensee's corrective action program related to equipment issues identified during refueling outage SL2-26 activities. The ARs are listed in the reference section of this inspection report. | |||
==INSPECTION RESULTS== | |||
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.19 Systems NCV 05000389/2021003-01 Open An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional. | |||
=====Description:===== | |||
On July 29, 2021, the licensee completed post-maintenance testing for reactor trip switchgear TCBs 1, 2, 3, 5, 6, and 7. The post-maintenance testing included a functional test from the reactor turbine generator board (RTGB) in the Unit 2 control room that tripped the TCBs one channel at a time from the RTGB. The post-maintenance test was completed because the TCBs were replaced with spare breakers that had preventive maintenance performed in accordance with 0-SME-66.04, Inspection of the Reactor Trip Switchgear (RTSG) Breakers." The inspectors noted that 0-SME-66.04 verified independent operability of the undervoltage and shunt trips of the TCB in a test cubicle. The inspectors questioned if the RTSG cubicles included contacts, relays, or other circuit portions that would go untested if only using a test cubicle to verify the surveillance requirement to verify the independent operability of the undervoltage and shunt trips. The surveillance requirement to verify the independent operability of the undervoltage and shunt trip functionality is specified in Technical Specification Table 4.3-1, Reactor Protective Instrumentation Surveillance Requirements, Functional Unit 12, Reactor Trip Breakers, Note 6, and states: in accordance with the surveillance frequency control program and following maintenance or adjustment of the reactor trip breakers, the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips. | |||
The licensee reviewed the inspectors' questions and determined that its surveillance procedures, 0-SME-66.04, and 2-OSP-63.01, RPS Logic Matrix Test, Attachment 2, RPS Trip Relay Contact Test, and Attachment 3, RTGB Manual Reactor Trip Pushbutton Contact Test, did not ensure the independent operability of the undervoltage and shunt trips. Specifically, there are portions of these circuits connected through circuit breaker and cradle disconnects to terminal points in the switchgear that are not tested independently. | |||
The licensee entered this issue into the corrective action program as AR 2403473 on September 8, 2021. At the time of discovery, Unit 2 was shutdown for refueling outage PSL2-26 and the reactor was defueled. The licensee verified that this issue did apply to Unit 1 because 0-SME-66.04 is a common unit procedure. However, Unit 1 Technical Specifications do not include a similar surveillance requirement to verify the independent operability of the undervoltage and shunt trip functions. Nonetheless, unlike the Unit 2 RPS Trip Status Panel, the Unit 1 RPS Trip Status Panel includes lights that indicate the individual status of the undervoltage and shunt trip coils and the individual lights' status are verified during 1-OSP-63.01, RPS Logic Matrix Test. Going forward, the Unit 1 TCBs will be similarly tested by the licensee to verify the independent operability of the undervoltage and shunt trips because 0-SME-66.04 was revised and is a procedure implemented on both units. | |||
The licensee completed an organization effectiveness investigation and determined that the inadequate surveillance testing of Unit 2 TCBs was caused by inappropriately removing TCB tests performed in a legacy RPS Logic Matrix surveillance procedure 2-1400059. The licensee credited those tests performed during maintenance activities without conforming the maintenance testing to technical specification surveillance requirements. This was a legacy issue associated with a procedure upgrade project that created 0-SME-66.04 in 2008. 0-SME-66.04, Revision 0, was issued on October 13, 2008. | |||
Corrective Actions: The licensee revised 0-SME-66.04 and 2-OSP-63.01 and included procedure steps and verification that the Unit 2 TCBs' undervoltage and shunt trips operated independently. All Unit 2 RTSG TCBs were tested per the applicable new section in 0-SME-66.04 and 2-OSP-63.01 in WO 40792125 during PSL 2-26 prior to making the control element assembly drive system capable of withdrawal on September 26, 2021. | |||
Corrective Action References: AR 2403473 | |||
=====Performance Assessment:===== | |||
Performance Deficiency: The licensee's failure to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions was a performance deficiency. | |||
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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 licensee failed to ensure that procedures 0-SME-66.04 and 2-OSP-63.01 included steps to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions. | |||
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Using the screening questions in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, section C, Reactor Protection System (RPS), the performance deficiency screened to very low safety significance (Green) because the finding only affected a single RPS trip signal to initiate a reactor trip AND the function of other redundant trips or diverse methods of reactor shutdown (e.g., other automatic RPS trips, alternate rod insertion, or manual reactor trip capacity) was not affected. The independent operability of the undervoltage and shunt trip functions were subsequently verified during subsequent surveillance testing on September 26, 2021. | |||
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, this was a legacy issue associated with a procedure upgrade project in 2008. | |||
=====Enforcement:===== | |||
Violation: Unit 2, TSSR 4.3.1, stated in part, that each reactor protective instrumentation channel shall be demonstrated operable by the performance of the channel functional test operations for the modes and at the frequencies shown in Table 4.3-1. Table 4.3-1, Functional Unit 12, Reactor Trip Breakers, Note 6, required the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips. | |||
Contrary to the above, from about 2008 until August 28, 2021, when Unit 2 entered Mode 3 and the TCBs were opened to begin SL2-26, the licensee failed to include verification of the independent operability of the undervoltage and shunt trips. | |||
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 September 2, 2021, the inspectors presented the Occupational Radiation Safety inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff. | |||
* On September 17, 2021, the inspectors presented the Inservice Inspection Activities inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff. | |||
* On October 13, 2021, the inspectors presented the integrated inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff. | |||
=DOCUMENTS REVIEWED= | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
71111.08P Corrective Action AR 01730372 Evaluation of Operating Experience on San Onofre Steam 2 /2 /12 | |||
Documents Generator Tube Leak | |||
AR 02323757 Level 1 Core Business Assessment Report, Adverse trend in 2/5/20 | |||
through wall boric acid leaks | |||
AR 02365843 A Through Wall Leak was Identified on a U2 RWT LINE 3/4" 8/18/20 | |||
CS-76 | |||
AR 02366640 Change Welds to Reduce Future Crack Initiation 08/26/20 | |||
AR 02381520 2A SG MAXIMUM AFW FLOW WAS >150GPM WITH NR 1/21/21 | |||
LEVEL <28.2% | |||
AR 02392964 LPSI PP 2A Active Boric Acid Leakage at the Suction Flange 6/12/21 | |||
and Boric Acid Evaluation | |||
AR 02396570 V2857 Active Seat Leakage less than 1 DPM 6/22/21 | |||
AR 02402502-01 Evaluation of Excessive Boric Acid Residue Observed on the Rev. 1 | |||
Unit 2 V3862 Vent Valve, adjacent Pipe Support and | |||
Downstream Quick Disconnect | |||
AR 02402605-01 Evaluation of Brown/discolored Boric Acid Residue Rev. 1 | |||
Observed on the Unit 2 V1219 | |||
AR 02402992 WHITE RESIDUE- 2B2 COLD LEG NOZZLE TO MAIN | |||
SPRAY (PCV-1100E | |||
AR 02403170 SL2-26 SG-2A Feedring Support Inspection Results 9/4/21 | |||
AR 02403288 Observation from Visual Exam -RPV Upper Head 9/6/21 | |||
Penetration 85 | |||
AR 02403357 SL2-26 Containment Liner Moisture Barrier Minor Damage 9/7/21 | |||
Repair | |||
AR 02403363 Possible Through Wall Leak in U2, 2B LPSI Header, I-10-SI- 9/7/21 | |||
AR 02403787 Boric Acid Residue on the Reactor Vessel Bottom Head 9/10/21 | |||
Insulation | |||
AR 2331605 Review of MRP 2019-008, Management of Thermal Fatigue 6/24/20 | |||
in Non-Isolable Reactor Coolant System Branch Lines | |||
AR-02402418-01 Evaluation of Accumulation of Boric Acid Residue in the Rev. 1 | |||
vicinity of the 2A2 Reactor Coolant Pump (RCP) and below | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
in the Spider Trench | |||
AR-02403787 Inactive Boric Acid Residue on Reactor Vessel 9/10/21 | |||
CR-2021-2099 S/G A H/L Plug Protruding (Row 94 Column 105) 9/12/21 | |||
Corrective Action AR-02406379 St. Lucie Unit 2 - EOC25 - S/G 2A and S/G 2B Plug List Rev, 0 | |||
Documents | |||
Resulting from | |||
Inspection | |||
Engineering 51-9332977-000 St Lucie Unit 2 SL2-26 (EOC25) SG Eddy Current Inspection Rev. 000 | |||
Evaluations Plan | |||
AIM 210510993- Degradation Assessment for St. Lucie Unit 2 Steam Rev. 2 | |||
2Q-1 Generators for End-of-Cycle 25, September, 2021 | |||
D02-PEEG-F-13- St Lucie Unit 2 RSGs Risk Assessments Rev 1 | |||
200 | |||
Miscellaneous THERMAL FATIGUE PROGRAM (MRP-146 & MRP-192) 7/14/21 | |||
ID#: 1193 Curtiss Wright, Personnel Qualifications Certifications for 7/28/21 | |||
Ultrasonic Testing | |||
Welder ID's Welder Qualifications 3/31/21, | |||
RXT01F6, 8/31/21 | |||
DXW0MCB | |||
AIM 210711013- Intertek AIM Letter Report, Screening Charts for Condition 8/27/21 | |||
2Q-1 Monitoring of St. Lucie Unit 2 Steam Generators for the | |||
September 2021 Inspection | |||
Curtiss Wright Personnel Qualification for Penetrant Inspections 4/12/21 | |||
Certification for ID | |||
No. 458 | |||
FPE-NDE-21-017 Eddy Current Personnel Certification and Qualification 9/1/21 | |||
Documentation Review, St. | |||
Lucie Unit 2 (SL2-26) Steam Generator Examinations | |||
Fram. Cert Certificate of Calibration, Torque Transducer, 200 In-Lb 7/23/21 | |||
No.63085, | |||
Fram. Cert No: Certificate of Calibration, Eddy Current Tester,MIZ-80 7/14/21 | |||
2950 | |||
Fram. Cert No: Certificate of Calibration, LAN SAP CONTROL BOX 7/29/21 | |||
233 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
Framatome ID Certificates of Visual Examination 6/24/21 and | |||
Code: M-6527 1/2/21 | |||
and W7014 | |||
Framatome ID Certificate of Personnel Qualification 6/29/21 and | |||
No. 6527 and 7/30/21 | |||
W7014 | |||
ID No M6527 Certificate of Personnel Qualification, VT- 1,2 & 3, Level III, 11/21/20 | |||
with Bare Head Visual Endorsement | |||
Relief Request Request for Alternative to ASME Code Case N-729-6 for 9/13/21 | |||
Number 19 Replacement Reactor Vessel Closure Head Penetration | |||
Nozzle 85 | |||
Report No. MRP-146 and MRP-192 Thermal Fatigue Program Review Rev. 0 | |||
1600579.401 for St. Lucie Nuclear Plant (Review of MRP Interim | |||
Guidance) | |||
SL-2 Tech Spec, Steam Generator (SG) Program Amendment | |||
Administration 160 | |||
Section "L" | |||
Training Boric Acid Corrosion Control (BACC) Program Evaluator 2/27/17 | |||
Certification | |||
BACC Program | |||
Owner (DG) | |||
NDE Reports Doc. ID.180- NDE Services Final Report, St Lucie 2 - SL2R26 Reactor 9/23/21 | |||
9336089-000 Vessel Closure Head In-Service Inspection Bare Metal | |||
Visual Examination | |||
WO-40787195- Liquid Penetrant Examination Report for Weld No. 02000, 9/10/21 | |||
01. Comp ID V3259, SI Piping | |||
Rpt. No. PSL2- Component ID: 1-2742-3, Pad to Vessel Weld, Shut Down 0/13/21 | |||
PT-21-003, Cooling Hx."2A" | |||
Summary No. | |||
SL2-209900 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
Rpt. No. PSL2- Ultrasonic Examination of Elbow to Pipe and Elbow Base 9/13/21 | |||
UT-21-010, Material, Component ID, RC-147-1-SW-2 (MRP-146) | |||
Summary No. | |||
SL2-075220 | |||
SL2- 20035 WO 407180177-05, NIS-2A, Repair Replacement 9/27/21 | |||
Certification Form | |||
WO - 40718077- Weld Penetrant Test Results 9/14/21 | |||
05, Weld No. | |||
00005 | |||
WO 40718077 ASME Pressure Test Results (VT-2 Leakage Exam) , Valve 9/27/21 | |||
3104 Welds | |||
WO-40787195 V3259, ASME Section XI Repair/Replacement Checklist 9/14/21 | |||
Procedures 03-9219485 St. Lucie (PSL) Unit 2 Eddy Current Data Analysis Rev. 4 | |||
Guidelines | |||
2-OSP-68.01 Integrated Leak Rate Test 10/4/21 | |||
51-9332993-000 Site Validation of Eddy Current Examination Techniques for 9/1/21 | |||
St. Lucie Unit 2, SL2-26 | |||
54-ISI-400-024 Multi-Frequency Eddy Current Examination of Tubing 12/7/20 | |||
EC- 000291144 STEAM GENERATOR SECONDARY SIDE INTEGRITY Rev. 16 | |||
PLAN | |||
EN-AA-113 Thermal Fatigue Program (MRP-146 & MRP-192) 7 14 21 | |||
ER-AP-116-1000 Nuclear Fleet Administrative Procedure, Boric Acid Rev, 5 | |||
Corrosion Control Program | |||
ER-AP-116-1000- Boric Acid Corrosion Control Program Implementation Rev. 000 | |||
10000 | |||
NDE 3.3 Liquid Penetrant Examination, Solvent Removable, Visible Rev. 15 | |||
Dye Technique | |||
NDE 4.15 Visual Examination (VE), ASME Section XI Code Case N- 4/14/21 | |||
2-1, N-729-6, N-770-5 and Bare Metal Visual | |||
NSE 5.32 Ultrasonic Examination Technique Austenitic Piping Welds 4/17/2021 | |||
for Thermal Fatigue Cracking/Crazing (MRP-146 & MRP- | |||
2) | |||
Work Orders WO 0470738534 U2 CS-79 Rework Welds Upstream of V07196 xx/yy/zz | |||
WO 40717685-04 RCB Annulus:SL226 INSP/RPR 40717685 04 Moisture Seal 9/21/21 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
WO 40717685-05 U2 RCB Safety Related Protective Coatings 9/21/ 21 | |||
WO 40718309 - U2 LPSI PP 2A, Replace Pump Inlet Gasket and Inspect 9/1/21 | |||
Hardware | |||
WO-40415569 U2 CS-76, Repair Leak Flange Upstream of V07199 (NDE) 8/19/20 | |||
WO-40695770-02 U2: LPSI PP 2A - Remove/ Clean DBA/ Oil Residue 3/30/20 | |||
WO-40718077 U2, V3104 Check valve Replacement 9/27/21 | |||
WO-40718309 01 U2 LPSI PP 2A, Inspect Pump 5/26/21 | |||
WO-40718309-01 U2 LPSI PP 2A: Inspect Pump (Includes Pressure Boundary 5/11/21 | |||
Bolting) | |||
WO-40718309-11 2A LPSI PP, Safety Injection, Pump Casing Bolting, VT-1, 6/9/21 | |||
(Supplement) NDE Results | |||
WO-40787195 Replace ASME Class 1, Safety Injection Valve V3259 9/14/21 | |||
71124.01 Corrective Action AR 2402800 | |||
Documents | |||
Resulting from | |||
Inspection | |||
Procedures RP-SL-103-2006 Radiation Protection Outage Activities Revision 15 | |||
Radiation PSL-M- HPS-263 Down Post of Unit 2 RCB Keyway from LHRA to 08/31/2021 | |||
Surveys 20210831-30 HRA | |||
PSL-M- U2 RCB Sump Downpost from LHRA to HRA 08/31/2021 | |||
2110831-29 | |||
71124.02 ALARA Plans RWP 21-1004 Reactor Disassembly Activities (Completed ALARA 06/17/2021 | |||
package) | |||
RWP 21-1030 Scaffold Install / Remove (Completed ALARA package) 06/17/2021 | |||
RWP 21-1118 Incore Detectors: Remove / Install, Cut Up and Dispose 06/17/2021 | |||
(Completed ALARA package) | |||
RWP 21-1302 RP Activities in RCB during Refueling / Maintenance Outage 06/17/2021 | |||
(Completed ALARA package) | |||
RWP 21-1321 S/G Secondary Side Activities (Completed ALARA package) 08/20/2021 | |||
Corrective Action CRs: 02343210, CRs: 02343210, 02347080, 02347252, 02350726, and Various | |||
Documents 02347080, 02363195 | |||
2347252, | |||
2350726, and | |||
2363195 | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
Miscellaneous Source Term Source Term Reduction Update (Letter to ALARA File) 08/17/2021 | |||
Reduction Update | |||
Procedures HPP-1 PREPARING RADIATION WORK PERMITS (RWP) Rev. 41 | |||
RP-AA-104 ALARA PROGRAM Rev. 8 | |||
RP-AA-104-1000 ALARA IMPLEMENTING PROCEDURE Rev. 18 | |||
71124.03 Miscellaneous 1-OSP-25.04 Filter testing results for ventilation systems 1-HVE-13A, 1- Various | |||
HVE-13B, 2-HVE-13-A, 2-HVE-13B, 1-HVE-10A, and 2- dates 2020- | |||
HVE-10A 2021 | |||
Order Numbers Compressed Air/Gas Quality Testing Lab Results for April - July | |||
2676 & 123941 breathing air compressors and service air system 2021 | |||
Procedures RP-AA-102-1000 Alpha Monitoring Rev. 6 | |||
RP-SL-106-1002 Respiratory Protection Manual Rev. 5 | |||
RP-SL-106-1003 Use of Respiratory Protective Equipment Rev. 6 | |||
RP-SL-106-1004 Inspection and Maintenance of Respiratory Protection Rev. 4 | |||
Equipment | |||
Work Orders 4071756201 U2 Breather Boxes - CO2 Monitors, Pre-Outage Calibration | |||
71124.04 Corrective Action 02402939 Incorrect HPP-30 Internal Dose Document Statement 09/07/2021 | |||
Documents 02402942 Correct RP-AA-101-2004 EDE Procedure Discrepancies 09/07/2021 | |||
Resulting from | |||
Inspection | |||
Miscellaneous HP-100-200824 2019-2020 Site Alpha Characterization Update 08/24/2020 | |||
HPP-30.17 Exposure Investigation Report for RWP 2021-515, Task 1 04/17/21 | |||
NVLAP Lab Code Certificate of NVLAP Accreditation 07/01/2021 | |||
100555-0 | |||
RP-AA-101-2004- EDEX Monitoring Plans for RWP 20-2144, RWP 20-3008, Various | |||
F01 and RWP 21-1008-2 | |||
Procedures HPP-30 Personnel Monitoring Rev. 65 | |||
RP-AA-101-2004 Method for Monitoring and Assigning Effective Dose Rev. 7 | |||
Equivalent (EDE) for High Dose Gradient Work | |||
RP-SL-101-1008 Multibadging Rev. 6 | |||
RP-SL-101-1011 Skin Dose Assessment Rev. 3 | |||
71124.05 Corrective Action ARs, 02401362, Various related to inoperable area radiation monitors. Various | |||
Documents 02371871, | |||
2360323, and | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
2364447. | |||
71151 Corrective Action 02390317 Worker received accumulated dose alarm 08/25/2021 | |||
Documents | |||
71152 Corrective Action AR 2402451 2A ICW Pump Did Not Start in Required Time | |||
Documents AR 2402986 Unit 2 FT-09-202 2C AFW Pump Discharge Flow Transmitter | |||
Requires Recalibration | |||
AR 2402992 White Residue 2B2 Cold Leg Nozzle to Main Spray PCV- | |||
1100E | |||
AR 2403025 V-25-20 Containment Vacuum Relief Check Valve Failed | |||
Open Test Stroke | |||
AR 2403079 Found Cracked Relay in 4kV Switchgear 2A3-12 B Phase | |||
Over-current | |||
AR 2403250 Seventh Sensor of LT-07-13B, Containment Sump Wide | |||
Range B, is Failed | |||
AR 2403280 Unit 2 Reactor Containment Building Penetration P58 Seal | |||
Has Holes | |||
AR 2403357 SL2-26 Containment Liner Moisture Barrier Minor Damage | |||
AR 2403363 Possible Through-wall Leak in 2B LPSI Header at I-10-SI- | |||
556 | |||
AR 2403408 SL2-26 Containment Shell Plate to Floor Interface on | |||
Annulus Side Indications | |||
AR 2403491 RI-26-80A4, Startup Range Nuclear Instrument for Excore | |||
Monitoring Needs Repair | |||
AR 2403801 V3104, Check Valve for 2A LPSI Pump Recirculation to | |||
Refueling Water Tank, Internal Valve Inspection | |||
Unsatisfactory | |||
AR 2403822 SL 2-26 Support SI-4200-673 Misaligned | |||
AR 2403847 2B1 RCS Cold Leg Inactive Boric Acid | |||
AR 2403854 Wide Range Nuclear Instrument Troubleshooting - J9 | |||
Connector Failed Requires Repair | |||
AR 2403867 Corrosion on Pipe BF-40 at Tee in Unit 2 AFW Trench | |||
AR 2403914 2/1218 Load Sequence Relay Adjusted | |||
AR 2403924 V09119, Check Valve for 2A AFW Pump Supply to 2A | |||
Steam Generator FW Inlet Requires Seat Replacement | |||
Inspection Type Designation Description or Title Revision or | |||
Procedure Date | |||
AR 2403985 SL2-26 IWE Inspection Areas of Degradation | |||
AR 2404005 SL2-26 Main Steam Piping Support Setting at Zero | |||
AR 2404023 Foreign Material on the Reactor Head that Cannot Be | |||
Removed | |||
AR 2404124 Unit 2 Startup Range Nuclear Instrument Channel 1 | |||
Unreliable | |||
AR 2404134 Unit 2 FU-3 Fuses Ampere Rating for 29-1/1636 Isolating | |||
Relay for Auxiliary Feedwater Actuation System Battery | |||
Failure | |||
AR 2404149 Conditional Release for Unit 2 FCV-25-36, Isolation Valve for | |||
Containment Hydrogen Purge Make-up Air | |||
AR 2404158 Unit 2, MV-09-10, MOV from 2B AFW Pump Discharge to | |||
Steam Generator, Stem Coupling Found Loose During | |||
Testing | |||
AR 2404400 SL2-26 IWE Containment Penetration Indications | |||
AR 2404408 Unit 2 Water Coming Out of Nuclear Instrument Conduit and | |||
Terminal Boxes | |||
AR 2404412 Snubber 2-234 and Pipe Clamp Were Found Out of | |||
Alignment | |||
AR 2404445 SL2-26 IWE Containment Penetration Indications | |||
AR 2404501 Unit 2, V5201, Isolation Valve for Pressurizer Surge Sample, | |||
has a Leaking Swagelok | |||
AR 2404509 SL2-26 Containment Shell Plate Coating Degradation | |||
AR 2404587 2A AFW Pump Discharge Valve to 2A Steam Generator | |||
Open Limit Switch Adjustment | |||
AR 2404904 Unit 2, MV-08-1B, MOV Equalizer for B Steam Generator | |||
MSIV, Broken Welds on Yoke | |||
AR 2405082 Unit 2, Wide Range Containment Level Incorrect Calibration | |||
24 | |||
}} | }} | ||
Revision as of 11:57, 18 January 2022
| ML21307A037 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie |
| Issue date: | 11/03/2021 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2021003 | |
| Download: ML21307A037 (27) | |
Text
November 3, 2021
SUBJECT:
ST LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2021003 AND 05000389/2021003
Dear Mr. Coffey:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St Lucie Units 1 & 2. On October 13, 2021, the NRC inspectors discussed the results of this inspection with Mr. Dan DeBoer, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at St Lucie Units 1 & 2. 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,
/RA/
David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects 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: 05000335/2021003 and 05000389/2021003 Enterprise Identifier: I-2021-003-0006 Licensee: Florida Power & Light Company Facility: St Lucie Units 1 & 2 Location: Jenson Beach, FL 34957 Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: A. Butcavage, Reactor Inspector J. Diaz-Velez, Senior Health Physicist J. Griffis, Senior Health Physicist D. Orr, Senior Resident Inspector W. Pursley, Health Physicist J. Rivera, Health Physicist S. Roberts, Resident Inspector Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at St Lucie Units 1 & 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
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.19 Systems NCV 05000389/2021003-01 Open An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.
Unit 2 operated at or near RTP until the unit was shutdown for planned refueling outage, SL2-26, on August 28, 2021. Unit 2 was restarted on September 29, 2021, and was in the process of power ascension, achieving 93 percent RTP, when the inspection period ended on September 30,
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted.
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP
===71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) ===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 auxiliary feedwater system (AFW) and 1A emergency diesel generator (EDG)while the 1B EDG was out of service (OOS) for planned maintenance on July 15, 2021
- (2) Unit 1 containment spray (CS) B train while A train was OOS for planned maintenance on August 4, 2021
- (3) Unit 2 CS A train while the 2B CS pump was OOS for surveillance testing and the 2B CS pump after surveillance testing completed on August 25, 2021
- (4) Unit 2 spent fuel pool cooling system during refueling outage SL2-26 full core offload window on September 8, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2 control element assembly motor-generator area, reactor auxiliary building (RAB) on July 7, 2021
- (2) Unit 2 fuel handling building on July 21, 2021
- (3) 1B EDG building on August 3, 2021
- (4) Unit 2 RAB 43 foot elevation on August 10, 2021
- (5) Unit 2 reactor containment building on September 8, 2021
- (6) Unit 2 cable spread room on September 11, 2021
- (7) Unit 1 and Unit 2 external control zones on September 15, 2021
- (8) Unit 2 electrical penetration rooms on September 20, 2021
71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)
The inspectors verified that the reactor coolant system boundary, steam generator tubes, risk-significant piping system boundaries, and containment moisture barrier are appropriately monitored for degradation and that sample repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from August 30, 2021 to October 4, 2021.
(1)03.01.a - Nondestructive Examination (NDE) and Welding Activities.
- Ultrasonic Examination (UT), RC-147-1-SW-2 (MRP-146), ASME Class1, Elbow to Pipe Weld and Elbow Base Material
- WO 40787195, Safety Injection Piping, Valve 3259, ASME Class 1, Weld Package
- WO 40718077-05, Low Pressure Safety Injection (LPSI) Pump 2A, Valve 3104 to Pipe, ASME Class 2, Weld Package
- Containment Integrated Leak Rate Test Results Samples
- Containment Moisture Barrier, Annulus Side, NDE Reports: PSL2-21-VT-1000, PSL2-21-VT-1001, PSL2-21-VT-1002, PSL2-21-VT-1003, PSL2-21-VT-1004, PSL2-21-VT-1005 03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination Activities.
- SL2-26 Reactor Vessel Closure Head In-Service Inspection Bare Metal Visual Examination, in accordance with Code Case N-729, ASME Class 1, Report 180-9336089 and Photo Review
- Reactor head penetration #85 presented potential boric acid recordable indication. Accepted for continued service by additional evaluation (AR
===02403288) and verbal authorization of NRC Relief Request No.19 03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
The inspectors evaluated the licensees boric acid corrosion control program performance, through photographs provided for the Reactor Vessel Head and other areas described in action requests, and sample action requests combined with review of the boric acid program corrective actions and evaluations of reported leakage as listed in the documents reviewed section.
- Review of the licensee containment boric acid walkdown inspection results and Action Request (AR) initiations.
- Review of engineering boric acid AR evaluations and dispositions associated with:
AR 02365843-01, Active borated water leak of 20 drops/minute, Unit 2 Line No.
CS-76 AR 02392964-01, Wet boric acid found on the 2A Low Pressure Safety Injection (LPSI) pump AR 02402992, - White Residue - 2B2 Cold Leg Nozzle to Main Spray (PCV-1100E)
AR 02403787-01, Noted Inactive Boric Acid Residue on the Reactor Vessel Bottom Head area Insulation 03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
- Major Scope: Bobbin Coil,100% Full Length, Active Tubes Each steam generator (SG) for wear, Array Probe, HL and CL expansion transitions in periphery (high flow) TTS region, for Loose Part Detection and Foreign Object Wear, +Point (TM) Probe, for all new dents and dings, PWSCC and ODSCC (not potential), Visual for all tube plugs. (Details contained in Document Reference AIM 210510993-2Q-1, Rev. 2)
- Observed remotely a sample of resolution analyst dispositions during the Resolution Process
- Review of secondary side AR 02403170, Feed Ring Support Inspection &
Repair
- Review of AIM 210711013-2Q-1, Screening Chart Basis for Condition Monitoring of St. Lucie Unit 2 Steam Generators for the September 2021 Inspection
- OE Review: AR No. 01730372, San Onofre Steam Generator Tube Leak
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during:
- Interim pressurization of the Unit 2 safety injection tanks (SIT) due to a slow pressure loss in the 2A2 SIT on July 27, 2021
- A planned power reduction and shutdown of Unit 2 to support refueling outage SL2-26 on August 27-28, 2021
- Unit 2 startup and power ascension activities following refueling outage SL2-26 on September 29, 2021 Licensed Operator Requalification Training/Examinations (IP Section 03.02) ===
- (1) The inspectors observed and evaluated an operating crews response to a requalification training simulator scenario in the control room simulator on July 26, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
- (1) AR 2401971, 2021 maintenance rule (a)(3) evaluation on September 20, 2021
- (2) AR 2402451, 2A intake cooling water (ICW) pump did not start in required time on September 27, 2021
- (3) AR 2400485, entry into 2-AOP-18.01, Instrument Air Malfunction on September 30, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1 elevated risk with the 1B EDG OOS for planned maintenance on July 15, 2021, and Unit 2 elevated risk with the 2AA 125 VDC battery charger OOS for emergent repairs on July 15, 2021
- (2) Unit 2 elevated risk with the 2B CS, 2B high pressure safety injection (HPSI), and 2B low pressure safety injection (LPSI) pumps OOS to troubleshoot flow transmitter, FT-07-03, associated with the reactor cavity sump inlet flow monitoring system on July 27, 2021
- (4) Unit 1 and Unit 2 elevated risk for the 1B and 2B startup transformers OOS for planned maintenance and Unit 1 additional elevated risk for battery charger 1AB OOS for a load test on August 18, 2021
- (5) Unit 2 yellow shutdown safety assessment (SSA) with the reactor coolant system (RCS) depressurized and level lowered to support reactor head removal on September 1, 2021
- (6) Unit 2 yellow SSA with 2A EDG and A train electrical busses OOS for 4160 volt breaker replacement from September 6-10, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2398812, little to no seal packing gland leak-off flow for 1B ICW pump on August 22, 2021
- (2) AR 2401630, tritium identified internal to the Unit 1 CCW system on August 27, 2021
- (3) AR 2398173, through-wall leak on 1B ICW header on September 20, 2021
- (4) AR 2400714, pressurizer safety valve, PSV-V1202, failed as-found lift test on September 21, 2021
- (5) AR 2403182 and 2403284, debris identified on fuel assembly lower tie plates during Unit 2 end of fuel cycle 25 bottom nozzle inspections on September 21, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC 296363, installation of jumper across synchroscope check relay in 4160 volt switchgear
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) WO 40738733, 1B EDG critical maintenance management (CMM), 36 month preventive maintenance inspection on July 21, 2021
- (2) WO 40715198, 480V breaker replacement for 1A CS pump isolation valve, MV-07-3A, on August 5, 2021
- (3) WO 40785251, 2AA battery charger phase alarm, troubleshoot and repair on September 13, 2021
- (4) WO 40792135, 2A3 4160 volt switchgear undervoltage relay 27-1 repair on September 14, 2021
- (5) WOs 40687479, 40687481, 40682187, 40687483, 40682186, and 40687482, Unit 2 reactor trip switchgear TCB-1, 2, 3, 5, 6, and 7 respectively, perform breaker swap, and WO 40792125, Unit 2 reactor trip switchgear TCB-1 through 8 - inadequate surveillance on September 27, 2021
- (6) WO 40602138, replace 2A EDG digital reference unit and electronic governor control unit replacements on September 27, 2021
- (7) WO 40755282, 1A fire water pump repair on September 27, 2021
- (8) WO 40628431, Unit 2 safety linear power range detector number 5 for uncompensated ion chamber replacement and associated WO 40717791, install de-calibration factors for reactor protection system channel A on September 28, 2021
- (9) WO 40710305, Unit 2 startup range nuclear instrument channel number 2 has low counts on September 28, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 refueling outage SL2-26 activities from August 28, 2021 to September 30, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) 2-OSP-59.01A, 2A Emergency Diesel Generator Monthly Surveillance, fast start from the control room on July 6, 2021
- (2) 1-SMI-09.05C, 1C Auxiliary Feedwater Pump Flow Channel Check on July 20, 2021
- (3) 1-OSP-52.01B, Surveillance Test of Degraded Grid Voltage B Train on August 19, 2021
- (4) 0-SME-50.06, Safety Related 125 VDC System Monthly Maintenance, for the 1B battery on August 23, 2021
- (5) 2-SMM-08.08, Main Steam Safety Valve Setpoint Surveillance Using Furmanite Trevitest Mark VIII Equipment on September 21, 2021
- (6) 2-OSP-24.01, RAB Fluid Systems Periodic Leak Test, Attachment 8, 2A High Pressure Safety Injection System Leak Test on September 21, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) 2-OSP-68.01, Integrated Leak Test, on September 22, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
- (1) On October 14, 2021 the inspectors evaluated an emergency response drill that included a loss of coolant accident (LOCA), reactor trip, and safety injection. The scenario included situations that resulted in declarations of Unusual Event, Alert, Site Area Emergency, and General Emergency.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- RWP 21-3441, Eddy Current Testing
- RWP 21-3438, S/G Primary Side Support Work
- RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal Electronic Alarming Dosimeter Alarms
- AR 02390457 Labeling of Containers
- Sealand Containers in Outdoor RCA
- Vacuum Cleaners and HEPA Units in the S/G Blowdown Building
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed licensee surveys of potentially contaminated material leaving the RCA during the Unit 2 refueling outage
- (2) Observed licensee activities at the Unit 2 Reactor Building equipment hatch during the unit 2 refueling outage
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) RWP-21-3102 Surveys for unit 2 reactor head disassembly
- (2) RWP 21-2104, Proximity Switch for Transfer Cart in Transfer Canal
- (3) RWP 21-3008, Unit 2 reactor head lift High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) LHRA Control Unit 1 Waste Ion Exchanger Room
- (2) LHRA Control Unit 1 Spent Fuel Pool Ion Exchanger Room
- (3) LHRA Control Unit 1 Volume Control Tank Room
- (4) VHRA Unit Reactor Containment Building Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements during the Unit 2 refueling outage.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensees radiological work planning for:
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (3 Samples)
The inspectors evaluated dose estimates and exposure tracking for:
- (1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1004) and the respective radiological outcome evaluation.
- (2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-1030) and the respective radiological outcome evaluation.
- (3) SL1-30 Incore Detectors Remove/Install, Cut Up and Dispose ALARA Package (RWP 21-1118) and the respective radiological outcome evaluation.
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (2 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) The inspectors reviewed RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and switch adjustment activities.
All Associated Activities and observed Radiological Work Controls while staff was performing area radiation surveys and performed the reactor head lift.
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during:
- (1) RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Transfer Canal - All Associated Activities
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Control Room Emergency Ventilation System (HV-13) for Units 1 and 2
- (2) Reactor Auxiliary Building Ventilation System (HV-10) for Units 1 and 2
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) HEPA Unit 004 staged in Unit 1 Cavity to support Reactor Disassembly
- (2) HEPA Unit 058 supporting filter changeout in the Steam Generator Blowdown
Building Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization. The evaluation included a review of the licensee's Site Alpha Characterization Update, dated August 24, 2020.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign external dose.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the internal dosimetry program implementation.
- (1) The inspectors reviewed the following:
Whole Body Counts
- Whole Body Count (WBC) data and exposure investigation information for Personal Contamination Event (PCE)21-005
- WBC data and exposure investigation information for facial contamination associated with CR 02347965 No internal dose assessments were available for review during the inspection that used in-vitro monitoring or air sampling and Derived Air Concentration (DAC)-hour monitoring.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
(1)
- Dose assessment and implementation of fetal monitoring for one declared pregnant worker.
- Multi-badging and calculation of Effective Dose Equivalent (EDEX) for workers who were monitored under RWP 2-2144 (Upender Bracket Replacement),
RWP 20-3008 (Reactor Head Set), and RWP 21-1008-2 (Reactor Head Set).
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (7 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Electronic dosimeters at HP control point.
- (2) Portable instrumentation in the instrumentation lab.
- (5) Portal Monitors (PMs) at the Protected Area (PA) exit point.
- (6) Area Radiation Monitors (ARMs) in the Unit 2 auxiliary building.
- (7) ARMs in the Unit 1 spent fuel pool.
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Unit 2 Containment High Range Monitor, RIM-26-41.
- (2) DMC 3000 electronic dosimeter no. 987428.
- (3) Ludlum 9-3 ion chamber, SN 336971.
- (4) Ludlum 12 count rate meter, SN 305073.
- (5) Ludlum 177 alarm rate meter, SN 19552.
- (6) Argos 5AB PCM, SN 1411-311.
- (7) SAM-12, SN 12052.
- (8) Eberline AMS-4 continuous air monitor, SN 12617.
- (9) Eberline AMS-4 continuous air monitor, SN 1615.
- (10) MGP AMP-100 area monitor, SN 5008-090.
- (11) MGP Telepole, SN 6605-039.
- (12) Ludlum 2241-4 neutron meter, SN 286222.
- (13) GEM-5 PM, SN 1307-176.
- (14) Whole Body Counter, Fastscan2.
- (15) Whole Body Counter, Fastscan3.
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 2 Plant Vent Stack Gaseous Effluent Monitor, RM-26-14.
- (2) Unit 1 Liquid Effluents Monitor, RE-6627.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===
- (1) Unit 1, Safety System Functional Failures from July 1, 2020 through June 30, 2021
- (2) Unit 2, Safety System Functional Failures from July 1, 2020 through June 30, 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) November 1, 2019 - October 31, 2021 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) November 1, 2019 - August 18, 2021
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 2400507, 1A EDG uncontrolled load swings during functional test
- (2) Several issues documented in the licensee's corrective action program related to equipment issues identified during refueling outage SL2-26 activities. The ARs are listed in the reference section of this inspection report.
INSPECTION RESULTS
Inadequate Surveillance for Unit 2 Trip Circuit Breakers Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.19 Systems NCV 05000389/2021003-01 Open An NRC-identified Green NCV of Technical Specification Surveillance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 trip circuit breaker (TCB)surveillance testing that independently verified that both undervoltage and shunt trip actuation circuits were functional.
Description:
On July 29, 2021, the licensee completed post-maintenance testing for reactor trip switchgear TCBs 1, 2, 3, 5, 6, and 7. The post-maintenance testing included a functional test from the reactor turbine generator board (RTGB) in the Unit 2 control room that tripped the TCBs one channel at a time from the RTGB. The post-maintenance test was completed because the TCBs were replaced with spare breakers that had preventive maintenance performed in accordance with 0-SME-66.04, Inspection of the Reactor Trip Switchgear (RTSG) Breakers." The inspectors noted that 0-SME-66.04 verified independent operability of the undervoltage and shunt trips of the TCB in a test cubicle. The inspectors questioned if the RTSG cubicles included contacts, relays, or other circuit portions that would go untested if only using a test cubicle to verify the surveillance requirement to verify the independent operability of the undervoltage and shunt trips. The surveillance requirement to verify the independent operability of the undervoltage and shunt trip functionality is specified in Technical Specification Table 4.3-1, Reactor Protective Instrumentation Surveillance Requirements, Functional Unit 12, Reactor Trip Breakers, Note 6, and states: in accordance with the surveillance frequency control program and following maintenance or adjustment of the reactor trip breakers, the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips.
The licensee reviewed the inspectors' questions and determined that its surveillance procedures, 0-SME-66.04, and 2-OSP-63.01, RPS Logic Matrix Test, Attachment 2, RPS Trip Relay Contact Test, and Attachment 3, RTGB Manual Reactor Trip Pushbutton Contact Test, did not ensure the independent operability of the undervoltage and shunt trips. Specifically, there are portions of these circuits connected through circuit breaker and cradle disconnects to terminal points in the switchgear that are not tested independently.
The licensee entered this issue into the corrective action program as AR 2403473 on September 8, 2021. At the time of discovery, Unit 2 was shutdown for refueling outage PSL2-26 and the reactor was defueled. The licensee verified that this issue did apply to Unit 1 because 0-SME-66.04 is a common unit procedure. However, Unit 1 Technical Specifications do not include a similar surveillance requirement to verify the independent operability of the undervoltage and shunt trip functions. Nonetheless, unlike the Unit 2 RPS Trip Status Panel, the Unit 1 RPS Trip Status Panel includes lights that indicate the individual status of the undervoltage and shunt trip coils and the individual lights' status are verified during 1-OSP-63.01, RPS Logic Matrix Test. Going forward, the Unit 1 TCBs will be similarly tested by the licensee to verify the independent operability of the undervoltage and shunt trips because 0-SME-66.04 was revised and is a procedure implemented on both units.
The licensee completed an organization effectiveness investigation and determined that the inadequate surveillance testing of Unit 2 TCBs was caused by inappropriately removing TCB tests performed in a legacy RPS Logic Matrix surveillance procedure 2-1400059. The licensee credited those tests performed during maintenance activities without conforming the maintenance testing to technical specification surveillance requirements. This was a legacy issue associated with a procedure upgrade project that created 0-SME-66.04 in 2008. 0-SME-66.04, Revision 0, was issued on October 13, 2008.
Corrective Actions: The licensee revised 0-SME-66.04 and 2-OSP-63.01 and included procedure steps and verification that the Unit 2 TCBs' undervoltage and shunt trips operated independently. All Unit 2 RTSG TCBs were tested per the applicable new section in 0-SME-66.04 and 2-OSP-63.01 in WO 40792125 during PSL 2-26 prior to making the control element assembly drive system capable of withdrawal on September 26, 2021.
Corrective Action References: AR 2403473
Performance Assessment:
Performance Deficiency: The licensee's failure to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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 licensee failed to ensure that procedures 0-SME-66.04 and 2-OSP-63.01 included steps to verify the independent operability of the Unit 2 TCB undervoltage and shunt trip functions.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Using the screening questions in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, section C, Reactor Protection System (RPS), the performance deficiency screened to very low safety significance (Green) because the finding only affected a single RPS trip signal to initiate a reactor trip AND the function of other redundant trips or diverse methods of reactor shutdown (e.g., other automatic RPS trips, alternate rod insertion, or manual reactor trip capacity) was not affected. The independent operability of the undervoltage and shunt trip functions were subsequently verified during subsequent surveillance testing on September 26, 2021.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, this was a legacy issue associated with a procedure upgrade project in 2008.
Enforcement:
Violation: Unit 2, TSSR 4.3.1, stated in part, that each reactor protective instrumentation channel shall be demonstrated operable by the performance of the channel functional test operations for the modes and at the frequencies shown in Table 4.3-1. Table 4.3-1, Functional Unit 12, Reactor Trip Breakers, Note 6, required the channel functional test shall include verification of the independent operability of the undervoltage and shunt trips.
Contrary to the above, from about 2008 until August 28, 2021, when Unit 2 entered Mode 3 and the TCBs were opened to begin SL2-26, the licensee failed to include verification of the independent operability of the undervoltage and shunt trips.
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 September 2, 2021, the inspectors presented the Occupational Radiation Safety inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
- On September 17, 2021, the inspectors presented the Inservice Inspection Activities inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
- On October 13, 2021, the inspectors presented the integrated inspection results to Dan DeBoer, Nuclear Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.08P Corrective Action AR 01730372 Evaluation of Operating Experience on San Onofre Steam 2 /2 /12
Documents Generator Tube Leak
AR 02323757 Level 1 Core Business Assessment Report, Adverse trend in 2/5/20
through wall boric acid leaks
AR 02365843 A Through Wall Leak was Identified on a U2 RWT LINE 3/4" 8/18/20
CS-76
AR 02366640 Change Welds to Reduce Future Crack Initiation 08/26/20
AR 02381520 2A SG MAXIMUM AFW FLOW WAS >150GPM WITH NR 1/21/21
LEVEL <28.2%
AR 02392964 LPSI PP 2A Active Boric Acid Leakage at the Suction Flange 6/12/21
and Boric Acid Evaluation
AR 02396570 V2857 Active Seat Leakage less than 1 DPM 6/22/21
AR 02402502-01 Evaluation of Excessive Boric Acid Residue Observed on the Rev. 1
Unit 2 V3862 Vent Valve, adjacent Pipe Support and
Downstream Quick Disconnect
AR 02402605-01 Evaluation of Brown/discolored Boric Acid Residue Rev. 1
Observed on the Unit 2 V1219
AR 02402992 WHITE RESIDUE- 2B2 COLD LEG NOZZLE TO MAIN
SPRAY (PCV-1100E
AR 02403170 SL2-26 SG-2A Feedring Support Inspection Results 9/4/21
AR 02403288 Observation from Visual Exam -RPV Upper Head 9/6/21
Penetration 85
AR 02403357 SL2-26 Containment Liner Moisture Barrier Minor Damage 9/7/21
Repair
AR 02403363 Possible Through Wall Leak in U2, 2B LPSI Header, I-10-SI- 9/7/21
AR 02403787 Boric Acid Residue on the Reactor Vessel Bottom Head 9/10/21
Insulation
AR 2331605 Review of MRP 2019-008, Management of Thermal Fatigue 6/24/20
in Non-Isolable Reactor Coolant System Branch Lines
AR-02402418-01 Evaluation of Accumulation of Boric Acid Residue in the Rev. 1
vicinity of the 2A2 Reactor Coolant Pump (RCP) and below
Inspection Type Designation Description or Title Revision or
Procedure Date
in the Spider Trench
AR-02403787 Inactive Boric Acid Residue on Reactor Vessel 9/10/21
CR-2021-2099 S/G A H/L Plug Protruding (Row 94 Column 105) 9/12/21
Corrective Action AR-02406379 St. Lucie Unit 2 - EOC25 - S/G 2A and S/G 2B Plug List Rev, 0
Documents
Resulting from
Inspection
Engineering 51-9332977-000 St Lucie Unit 2 SL2-26 (EOC25) SG Eddy Current Inspection Rev. 000
Evaluations Plan
AIM 210510993- Degradation Assessment for St. Lucie Unit 2 Steam Rev. 2
2Q-1 Generators for End-of-Cycle 25, September, 2021
D02-PEEG-F-13- St Lucie Unit 2 RSGs Risk Assessments Rev 1
200
Miscellaneous THERMAL FATIGUE PROGRAM (MRP-146 & MRP-192) 7/14/21
ID#: 1193 Curtiss Wright, Personnel Qualifications Certifications for 7/28/21
Ultrasonic Testing
Welder ID's Welder Qualifications 3/31/21,
RXT01F6, 8/31/21
DXW0MCB
AIM 210711013- Intertek AIM Letter Report, Screening Charts for Condition 8/27/21
2Q-1 Monitoring of St. Lucie Unit 2 Steam Generators for the
September 2021 Inspection
Curtiss Wright Personnel Qualification for Penetrant Inspections 4/12/21
Certification for ID
No. 458
FPE-NDE-21-017 Eddy Current Personnel Certification and Qualification 9/1/21
Documentation Review, St.
Lucie Unit 2 (SL2-26) Steam Generator Examinations
Fram. Cert Certificate of Calibration, Torque Transducer, 200 In-Lb 7/23/21
No.63085,
Fram. Cert No: Certificate of Calibration, Eddy Current Tester,MIZ-80 7/14/21
2950
Fram. Cert No: Certificate of Calibration, LAN SAP CONTROL BOX 7/29/21
233
Inspection Type Designation Description or Title Revision or
Procedure Date
Framatome ID Certificates of Visual Examination 6/24/21 and
Code: M-6527 1/2/21
and W7014
Framatome ID Certificate of Personnel Qualification 6/29/21 and
No. 6527 and 7/30/21
W7014
ID No M6527 Certificate of Personnel Qualification, VT- 1,2 & 3, Level III, 11/21/20
with Bare Head Visual Endorsement
Relief Request Request for Alternative to ASME Code Case N-729-6 for 9/13/21
Number 19 Replacement Reactor Vessel Closure Head Penetration
Nozzle 85
Report No. MRP-146 and MRP-192 Thermal Fatigue Program Review Rev. 0
1600579.401 for St. Lucie Nuclear Plant (Review of MRP Interim
Guidance)
SL-2 Tech Spec, Steam Generator (SG) Program Amendment
Administration 160
Section "L"
Training Boric Acid Corrosion Control (BACC) Program Evaluator 2/27/17
Certification
BACC Program
Owner (DG)
NDE Reports Doc. ID.180- NDE Services Final Report, St Lucie 2 - SL2R26 Reactor 9/23/21
9336089-000 Vessel Closure Head In-Service Inspection Bare Metal
Visual Examination
WO-40787195- Liquid Penetrant Examination Report for Weld No. 02000, 9/10/21
01. Comp ID V3259, SI Piping
Rpt. No. PSL2- Component ID: 1-2742-3, Pad to Vessel Weld, Shut Down 0/13/21
PT-21-003, Cooling Hx."2A"
Summary No.
SL2-209900
Inspection Type Designation Description or Title Revision or
Procedure Date
Rpt. No. PSL2- Ultrasonic Examination of Elbow to Pipe and Elbow Base 9/13/21
UT-21-010, Material, Component ID, RC-147-1-SW-2 (MRP-146)
Summary No.
SL2-075220
SL2- 20035 WO 407180177-05, NIS-2A, Repair Replacement 9/27/21
Certification Form
WO - 40718077- Weld Penetrant Test Results 9/14/21
05, Weld No.
00005
WO 40718077 ASME Pressure Test Results (VT-2 Leakage Exam) , Valve 9/27/21
3104 Welds
WO-40787195 V3259, ASME Section XI Repair/Replacement Checklist 9/14/21
Procedures 03-9219485 St. Lucie (PSL) Unit 2 Eddy Current Data Analysis Rev. 4
Guidelines
2-OSP-68.01 Integrated Leak Rate Test 10/4/21
51-9332993-000 Site Validation of Eddy Current Examination Techniques for 9/1/21
St. Lucie Unit 2, SL2-26
54-ISI-400-024 Multi-Frequency Eddy Current Examination of Tubing 12/7/20
EC- 000291144 STEAM GENERATOR SECONDARY SIDE INTEGRITY Rev. 16
PLAN
EN-AA-113 Thermal Fatigue Program (MRP-146 & MRP-192) 7 14 21
ER-AP-116-1000 Nuclear Fleet Administrative Procedure, Boric Acid Rev, 5
Corrosion Control Program
ER-AP-116-1000- Boric Acid Corrosion Control Program Implementation Rev. 000
10000
NDE 3.3 Liquid Penetrant Examination, Solvent Removable, Visible Rev. 15
Dye Technique
NDE 4.15 Visual Examination (VE), ASME Section XI Code Case N- 4/14/21
2-1, N-729-6, N-770-5 and Bare Metal Visual
NSE 5.32 Ultrasonic Examination Technique Austenitic Piping Welds 4/17/2021
for Thermal Fatigue Cracking/Crazing (MRP-146 & MRP-
2)
Work Orders WO 0470738534 U2 CS-79 Rework Welds Upstream of V07196 xx/yy/zz
WO 40717685-04 RCB Annulus:SL226 INSP/RPR 40717685 04 Moisture Seal 9/21/21
Inspection Type Designation Description or Title Revision or
Procedure Date
WO 40717685-05 U2 RCB Safety Related Protective Coatings 9/21/ 21
WO 40718309 - U2 LPSI PP 2A, Replace Pump Inlet Gasket and Inspect 9/1/21
Hardware
WO-40415569 U2 CS-76, Repair Leak Flange Upstream of V07199 (NDE) 8/19/20
WO-40695770-02 U2: LPSI PP 2A - Remove/ Clean DBA/ Oil Residue 3/30/20
WO-40718077 U2, V3104 Check valve Replacement 9/27/21
WO-40718309 01 U2 LPSI PP 2A, Inspect Pump 5/26/21
WO-40718309-01 U2 LPSI PP 2A: Inspect Pump (Includes Pressure Boundary 5/11/21
Bolting)
WO-40718309-11 2A LPSI PP, Safety Injection, Pump Casing Bolting, VT-1, 6/9/21
(Supplement) NDE Results
WO-40787195 Replace ASME Class 1, Safety Injection Valve V3259 9/14/21
71124.01 Corrective Action AR 2402800
Documents
Resulting from
Inspection
Procedures RP-SL-103-2006 Radiation Protection Outage Activities Revision 15
Radiation PSL-M- HPS-263 Down Post of Unit 2 RCB Keyway from LHRA to 08/31/2021
Surveys 20210831-30 HRA
PSL-M- U2 RCB Sump Downpost from LHRA to HRA 08/31/2021
2110831-29
71124.02 ALARA Plans RWP 21-1004 Reactor Disassembly Activities (Completed ALARA 06/17/2021
package)
RWP 21-1030 Scaffold Install / Remove (Completed ALARA package) 06/17/2021
RWP 21-1118 Incore Detectors: Remove / Install, Cut Up and Dispose 06/17/2021
(Completed ALARA package)
RWP 21-1302 RP Activities in RCB during Refueling / Maintenance Outage 06/17/2021
(Completed ALARA package)
RWP 21-1321 S/G Secondary Side Activities (Completed ALARA package) 08/20/2021
Corrective Action CRs: 02343210, CRs: 02343210, 02347080, 02347252, 02350726, and Various
Documents 02347080, 02363195
2347252,
2350726, and
2363195
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous Source Term Source Term Reduction Update (Letter to ALARA File) 08/17/2021
Reduction Update
Procedures HPP-1 PREPARING RADIATION WORK PERMITS (RWP) Rev. 41
RP-AA-104 ALARA PROGRAM Rev. 8
RP-AA-104-1000 ALARA IMPLEMENTING PROCEDURE Rev. 18
71124.03 Miscellaneous 1-OSP-25.04 Filter testing results for ventilation systems 1-HVE-13A, 1- Various
HVE-13B, 2-HVE-13-A, 2-HVE-13B, 1-HVE-10A, and 2- dates 2020-
HVE-10A 2021
Order Numbers Compressed Air/Gas Quality Testing Lab Results for April - July
2676 & 123941 breathing air compressors and service air system 2021
Procedures RP-AA-102-1000 Alpha Monitoring Rev. 6
RP-SL-106-1002 Respiratory Protection Manual Rev. 5
RP-SL-106-1003 Use of Respiratory Protective Equipment Rev. 6
RP-SL-106-1004 Inspection and Maintenance of Respiratory Protection Rev. 4
Equipment
Work Orders 4071756201 U2 Breather Boxes - CO2 Monitors, Pre-Outage Calibration
71124.04 Corrective Action 02402939 Incorrect HPP-30 Internal Dose Document Statement 09/07/2021
Documents 02402942 Correct RP-AA-101-2004 EDE Procedure Discrepancies 09/07/2021
Resulting from
Inspection
Miscellaneous HP-100-200824 2019-2020 Site Alpha Characterization Update 08/24/2020
HPP-30.17 Exposure Investigation Report for RWP 2021-515, Task 1 04/17/21
NVLAP Lab Code Certificate of NVLAP Accreditation 07/01/2021
100555-0
RP-AA-101-2004- EDEX Monitoring Plans for RWP 20-2144, RWP 20-3008, Various
F01 and RWP 21-1008-2
Procedures HPP-30 Personnel Monitoring Rev. 65
RP-AA-101-2004 Method for Monitoring and Assigning Effective Dose Rev. 7
Equivalent (EDE) for High Dose Gradient Work
RP-SL-101-1008 Multibadging Rev. 6
RP-SL-101-1011 Skin Dose Assessment Rev. 3
71124.05 Corrective Action ARs, 02401362, Various related to inoperable area radiation monitors. Various
Documents 02371871,
2360323, and
Inspection Type Designation Description or Title Revision or
Procedure Date
2364447.
71151 Corrective Action 02390317 Worker received accumulated dose alarm 08/25/2021
Documents
71152 Corrective Action AR 2402451 2A ICW Pump Did Not Start in Required Time
Documents AR 2402986 Unit 2 FT-09-202 2C AFW Pump Discharge Flow Transmitter
Requires Recalibration
AR 2402992 White Residue 2B2 Cold Leg Nozzle to Main Spray PCV-
1100E
AR 2403025 V-25-20 Containment Vacuum Relief Check Valve Failed
Open Test Stroke
AR 2403079 Found Cracked Relay in 4kV Switchgear 2A3-12 B Phase
Over-current
AR 2403250 Seventh Sensor of LT-07-13B, Containment Sump Wide
Range B, is Failed
AR 2403280 Unit 2 Reactor Containment Building Penetration P58 Seal
Has Holes
AR 2403357 SL2-26 Containment Liner Moisture Barrier Minor Damage
AR 2403363 Possible Through-wall Leak in 2B LPSI Header at I-10-SI-
556
AR 2403408 SL2-26 Containment Shell Plate to Floor Interface on
Annulus Side Indications
AR 2403491 RI-26-80A4, Startup Range Nuclear Instrument for Excore
Monitoring Needs Repair
AR 2403801 V3104, Check Valve for 2A LPSI Pump Recirculation to
Refueling Water Tank, Internal Valve Inspection
Unsatisfactory
AR 2403822 SL 2-26 Support SI-4200-673 Misaligned
AR 2403847 2B1 RCS Cold Leg Inactive Boric Acid
AR 2403854 Wide Range Nuclear Instrument Troubleshooting - J9
Connector Failed Requires Repair
AR 2403867 Corrosion on Pipe BF-40 at Tee in Unit 2 AFW Trench
AR 2403914 2/1218 Load Sequence Relay Adjusted
AR 2403924 V09119, Check Valve for 2A AFW Pump Supply to 2A
Steam Generator FW Inlet Requires Seat Replacement
Inspection Type Designation Description or Title Revision or
Procedure Date
AR 2403985 SL2-26 IWE Inspection Areas of Degradation
AR 2404005 SL2-26 Main Steam Piping Support Setting at Zero
AR 2404023 Foreign Material on the Reactor Head that Cannot Be
Removed
AR 2404124 Unit 2 Startup Range Nuclear Instrument Channel 1
Unreliable
AR 2404134 Unit 2 FU-3 Fuses Ampere Rating for 29-1/1636 Isolating
Relay for Auxiliary Feedwater Actuation System Battery
Failure
AR 2404149 Conditional Release for Unit 2 FCV-25-36, Isolation Valve for
Containment Hydrogen Purge Make-up Air
AR 2404158 Unit 2, MV-09-10, MOV from 2B AFW Pump Discharge to
Steam Generator, Stem Coupling Found Loose During
Testing
AR 2404400 SL2-26 IWE Containment Penetration Indications
AR 2404408 Unit 2 Water Coming Out of Nuclear Instrument Conduit and
Terminal Boxes
AR 2404412 Snubber 2-234 and Pipe Clamp Were Found Out of
Alignment
AR 2404445 SL2-26 IWE Containment Penetration Indications
AR 2404501 Unit 2, V5201, Isolation Valve for Pressurizer Surge Sample,
has a Leaking Swagelok
AR 2404509 SL2-26 Containment Shell Plate Coating Degradation
AR 2404587 2A AFW Pump Discharge Valve to 2A Steam Generator
Open Limit Switch Adjustment
AR 2404904 Unit 2, MV-08-1B, MOV Equalizer for B Steam Generator
AR 2405082 Unit 2, Wide Range Containment Level Incorrect Calibration
24