IR 05000335/2021003
| 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 N RC inspectors discussed the results of this inspection with Mr. Dan DeBoer, Site Vice Presi dent, and other members of your staff. The results of this inspection are documented in the en closed report.
One finding of very low safety significance (Green) is document ed 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 Reg ulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies t o 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 monitori ng 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 i s the NRCs program for overseeing the safe operation of commercial nuclear power react ors. 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 Surveill ance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 tr ip circuit breaker (TCB)
surveillance testing that independently verified that both unde rvoltage 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 en tire 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 inspecti on period ended on September 30, 2021.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Wa ter Reactor Inspection Program - Operations Phase. The inspectors reviewed selected p rocedures and records, observed activities, and interviewed personnel to assess licens ee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergen cy declared by the President of the United States on the public health risks of the coronavi rus (COVID-19), resident and regional inspectors were directed to begin telework and to remo tely access licensee information using available technology. During this time, the resident ins pectors performed periodic site visits each week, increasing the amount of time on-site as loca l COVID-19 conditions permitted.
As part of their on-site activities, resident inspectors conduc ted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducte d routine reviews using IP 71152, Problem Identification and Resolution, observed risk s ignificant activities; and completed on-site portions of IPs. In addition, resident and r egional baseline inspections were evaluated to determine if all or a portion of the objectives an d requirements stated in the IP could be performed remotely. If the inspections could be perfo rmed 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 a nd requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial w alkdowns of the following systems/trains:
(1) Unit 1 auxiliary feedwater system (AFW) and 1A emergency di esel generator (EDG)
while the 1B EDG was out of service (OOS) for planned maintenan ce 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 surveill ance testing and the 2B CS pump after surveillance testing completed on August 25, 2021
(4) Unit 2 spent fuel pool cooling system during refueling outa ge 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 protect ion 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, react or 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, 2 021 (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) ( 1 Sample)
The inspectors verified that the reactor coolant system boundar y, steam generator tubes, risk-significant piping system boundaries, and containment mois ture barrier are appropriately monitored for degradation and that sample repairs and replacements were appropriately fabricated, examined and accepted by reviewing th e following activities from August 30, 2021 to October 4, 2021.
(1)
03.01.a - Nondestructive Examination (NDE) and Welding Activiti es.
- 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, PSL2-2 1-VT-1004, PSL2-21-VT-1005
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetrati on 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 re cordable indication. Accepted for continued service by additional evalua tion (AR 02403288) and verbal authorization of NRC Relief Request No.19
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Contro l Activities.
The inspectors evaluated the licensees boric acid corrosion co ntrol program performance, through photographs provided for the Reactor Vesse l 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 inspect ion results and Action Request (AR) initiations.
- Review of engineering boric acid AR evaluations and dispositio ns associated with:
AR 02365843-01, Active borated water leak of 20 drops/min ute, Unit 2 Line No.
CS-76 AR 02392964-01, Wet boric acid found on the 2A Low Pressu re Safety Injection (LPSI) pump AR 02402992, - White Residue - 2B2 Cold Leg Nozzle to Mai n 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 Examin ation Activities.
- Major Scope: Bobbin Coil,100% Full Length, Active Tubes Each s team generator (SG) for wear, Array Probe, HL and CL expansion trans itions 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 Inspec tion &
Repair
- Review of AIM 210711013-2Q-1, Screening Chart Basis for Condit ion Monitoring of St. Lucie Unit 2 Steam Generators for the Septemb er 2021 Inspection
- OE Review: AR No. 01730372, San Onofre Steam Generator Tube Le ak
71111.11Q - Licensed Operator Requalification Program and Licen sed 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 per formance in the control room during:
- Interim pressurization of the Unit 2 safety injection tanks (S IT) 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 re fueling outage SL2-26 on August 27-28, 2021
- Unit 2 startup and power ascension activities following refuel ing outage SL2-26 on September 29, 2021
Licensed Operator Requalification Training/Examinations (IP Sec tion 03.02) (1 Sample)
(1) The inspectors observed and evaluated an operating crews r esponse 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 star t in required time on September 27, 2021 (3) AR 2400485, entry into 2-AOP-18.01, Instrument Air Malfunct ion on September 30, 2021
71111.13 - Maintenance Risk Assessments and Emergent Work Contr ol
Risk Assessment and Management Sample (IP Section 03.01) (6 Sam ples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure config uration changes and appropriate work controls were addressed:
(1) Unit 1 elevated risk with the 1B EDG OOS for planned mainte nance on July 15, 2021, and Unit 2 elevated risk with the 2AA 125 VDC battery charger O OS for emergent repairs on July 15, 2021 (2) Unit 2 elevated risk with the 2B CS, 2B high pressure safet y 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 monit oring system on July 27, 2021 (3) Unit 1 elevated risk with the 1A EDG OOS for planned mainte nance from August 2-6, 2021 (4) Unit 1 and Unit 2 elevated risk for the 1B and 2B startup t ransformers OOS for planned maintenance and Unit 1 additional elevated risk for bat tery charger 1AB OOS for a load test on August 18, 2021 (5) Unit 2 yellow shutdown safety assessment (SSA) with the rea ctor coolant system (RCS) depressurized and level lowered to support reactor head r emoval 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 Assessm ents
Operability Determination or Functionality Assessment (IP Secti on 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and acti ons associated with the following operability determinations and functionality assessme nts:
(1) AR 2398812, little to no seal packing gland leak-off flow f or 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 Septem ber 21, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Sect ion 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent m odifications:
(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 ac tivities 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 isolat ion 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 4 0687482, 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 elec tronic governor control unit replacements on September 27, 2021 (7) WO 40755282, 1A fire water pump repair on September 27, 202 1 (8) WO 40628431, Unit 2 safety linear power range detector numb er 5 for uncompensated ion chamber replacement and associated WO 4071779 1, install de-calibration factors for reactor protection system channel A on September 28, 2021
(9) WO 40710305, Unit 2 startup range nuclear instrument channe l 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 act ivities 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) (6 Samples)
(1) 2-OSP-59.01A, 2A Emergency Diesel Generator Monthly Surveil lance, fast start from the control room on July 6, 2021 (2) 1-SMI-09.05C, 1C Auxiliary Feedwater Pump Flow Channel Chec k 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 Maintena nce, 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, Attachme nt 8, 2A High Pressure Safety Injection System Leak Test on September 21, 202 1
Containment Isolation Valve Testing (IP Section 03.01) (1 Sampl e)
(1) 2-OSP-68.01, Integrated Leak Test, on September 22, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observ ation (IP Section 03.01) (1 Sample)
(1) On October 14, 2021 the inspectors evaluated an emergency r esponse drill that included a loss of coolant accident (LOCA), reactor trip, and s afety injection. The scenario included situations that resulted in declarations of U nusual 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 ma gnitude and extent of radiation levels and the concentrations and quantities of radio active materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radi ation 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 Ca nal
Electronic Alarming Dosimeter Alarms
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 03.0 3) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
(1) Observed licensee surveys of potentially contaminated mater ial 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 du ring the Unit 2 refueling outage.
Radiological Hazards Control and Work Coverage (IP Section 03.0 4) (3 Samples)
The inspectors evaluated in-plant radiological conditions durin g 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 S ection 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following Hig h 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 Technicia n Proficiency (IP Section 03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation pro tection 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 plann ing for:
(1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1 004)
(2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-10 30)
(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 21-3 001, Rev. 0)
(5) SL2-26 RCB Scaffold Install/Remove ALARA Package (RWP 21-30 18, Rev. 0)
Verification of Dose Estimates and Exposure Tracking Systems (I P Section 03.02) (3 Samples)
The inspectors evaluated dose estimates and exposure tracking f or:
(1) SL1-30 Reactor Disassembly/Assembly ALARA Package (RWP 21-1 004) and the respective radiological outcome evaluation.
(2) SL1-30 RCB Scaffold Install/Remove ALARA Package (RWP 21-10 30) 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 Sect ion 03.03) (2 Samples)
The inspectors reviewed as low as reasonably achievable practic es 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 Radiolo gical Work Controls while staff was performing area radiation surveys and switch ad justment activities.
(2) The inspectors reviewed RWP 21-3008 (LHRA) Reactor Head (Re move / Replace).
All Associated Activities and obs erved Radiological Work Controls while staff was performing area radiation surveys and performed the reactor hea d lift.
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protect ion technician performance during:
(1) RWP 21-2004 (LHRA) Proximity Switch for Transfer Cart in Tr ansfer Canal - All Associated Activities
71124.03 - In-Plant Airborne Radioactivity Control and Mitigati on
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following per manently 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 U nits 1 and 2
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following tem porary ventilation systems:
(1) HEPA Unit 004 staged in Unit 1 Cavity to support Reactor Di sassembly (2) HEPA Unit 058 supporting filter changeout in the Steam Generator Blowdown Building
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sam ple)
(1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Sectio n 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 pertain s 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 pertain s 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 impleme ntation.
(1) The inspectors reviewed the following:
Whole Body Counts
- Whole Body Count (WBC) data and exposure investigation informa tion for Personal Contamination Event (PCE)21-005
- WBC data and exposure investigation information for facial con tamination associated with CR 02347965
No internal dose assessments were available for review during t he inspection that used in-vitro monitoring or air sampling and Derived Air Concen tration (DAC)-hour monitoring.
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situa tions:
(1) * Dose assessment and implementation of fetal monitoring for one declared pregnant worker.
- Multi-badging and calculation of Effective Dose Equivalent (ED EX) for workers who were monitored under RWP 2-2144 (Upender Bracket Replacemen t),
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 inst rumentation 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 Control led Area (RCA) exit point.
(4) Personnel Contamination Monitors (PCMs) at the RCA exit poi nt.
(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 fol lowing 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 submitt als listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Sect ion 02.04) (2 Samples)
(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 Se ction 02.15) (1 Sample)
(1) November 1, 2019 - October 31, 2021
PR01: Radiological Effluent Technical Specifications/Offsite Do se Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effl uent 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 Sampl es)
The inspectors reviewed the licensees implementation of its co rrective action program related to the following issues:
(1) AR 2400507, 1A EDG uncontrolled load swings during functional te st (2) Several issues documented in the licensee's corrective acti on program related to equipment issues identified during refueling outage SL2-26 acti vities. 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 Surveill ance Requirement 4.3.1.1 was identified for the licensees failure to complete Unit 2 tr ip circuit breaker (TCB)
surveillance testing that independently verified that both unde rvoltage and shunt trip actuation circuits were functional.
Description: On July 29, 2021, the licensee completed post-mai ntenance testing for reactor trip switchgear TCBs 1, 2, 3, 5, 6, and 7. The post-maintenanc e testing included a functional test from the reactor turbine generator board (RTGB) in the Uni t 2 control room that tripped the TCBs one channel at a time from the RTGB. The post-mainten ance test was completed because the TCBs were replaced with spare breakers that had pre ventive maintenance performed in accordance with 0-SME-66.04, Inspection of the Rea ctor Trip Switchgear (RTSG) Breakers." The inspectors noted that 0-SME-66.04 verifi ed independent operability of the undervoltage and shunt trips of the TCB in a test cubicl e. The inspectors questioned if the RTSG cubicles included contacts, relays, or other circuit p ortions that would go untested if only using a test cubicle to verify the surveillance requiremen t to verify the independent operability of the undervoltage and shunt trips. The surveilla nce requirement to verify the independent operability of the undervoltage and shunt trip func tionality is specified in Technical Specification Table 4.3-1, Reactor Protective Instrum entation Surveillance Requirements, Functional Unit 12, Reactor Trip Breakers, Note 6, and states: in accordance with the surveillance frequency control program and following m aintenance or adjustment of the reactor trip breakers, the channel functional test shall in clude 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 indepe ndently.
The licensee entered this issue into the corrective action prog ram as AR 2403473 on September 8, 2021. At the time of discovery, Unit 2 was shutdo wn for refueling outage PSL2-26 and the reactor was defueled. The licensee verified th at this issue did apply to Unit 1 because 0-SME-66.04 is a common unit procedure. However, Uni t 1 Technical Specifications do not include a similar surveillance requiremen t to verify the independent operability of the undervoltage and shunt trip functions. None theless, unlike the Unit 2 RPS Trip Status Panel, the Unit 1 RPS Trip Status Panel includes li ghts that indicate the individual status of the undervoltage and shunt trip coils and the individ ual 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 investigat ion and determined that the inadequate surveillance testing of Unit 2 TCBs was caused by in appropriately removing TCB tests performed in a legacy RPS Logic Matrix surveillance proce dure 2-1400059. The licensee credited those tests performed during maintenance acti vities without conforming the maintenance testing to technical specification surveillance req uirements. 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' undervol tage and shunt trips operated independently. All Unit 2 RTSG TCBs were tested per the applic able new section in 0-SME-66.04 and 2-OSP-63.01 in WO 40792125 during PSL 2-26 prior to m aking the control element assembly drive system capable of withdrawal on Septembe r 26, 2021.
Corrective Action References: AR 2403473 Performance Assessment:
Performance Deficiency: The licensee's failure to verify the i ndependent operability of the Unit 2 TCB undervoltage and shunt trip functions was a performa nce deficiency.
Screening: The inspectors determined the performance deficienc y 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 initiati ng 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 operabilit y 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, Th e Significance Determination Process for Findings At-Power. Using the screening questions i n 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 func tions were subsequently verified during subsequent surveillance testing on September 26, 2021.
Cross-Cutting Aspect: Not Present Performance. No cross-cuttin g 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 w ith a procedure upgrade project in 2008.
Enforcement:
Violation: Unit 2, TSSR 4.3.1, stated in part, that each react or protective instrumentation channel shall be demonstrated operable by the performance of th e 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 unde rvoltage and shunt trips.
Contrary to the above, from about 2008 until August 28, 2021, w hen Unit 2 entered Mode 3 and the TCBs were opened to begin SL2-26, the licensee failed t o include verification of the independent operability of the undervoltage and shunt trips.
Enforcement Action: This violation is being treated as a non-c ited 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 Occupationa l Radiation Safety inspection results to Dan DeBoer, Nuclear Site Vice President a nd 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 a nd other members of the licensee staff.
- On October 13, 2021, the inspectors presented the integrated i nspection results to Dan DeBoer, Nuclear Site Vice President and other members of the li censee staff.
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