IR 05000039/2018003

Nuclear Regulatory Commission Integrated Inspection Report 05000335/2018003 and 0500039/2018003

ML18313A180
Person / Time
Site:	Saint Lucie, 05000039
Issue date:	11/08/2018
From:	Randy Musser NRC/RGN-II/DRP/RPB3
To:	Nazar M Florida Power & Light Co
References
IR 2018003
Download: ML18313A180 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 8, 2018

SUBJECT:

ST. LUCIE PLANT - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 05000335/2018003 AND 05000389/2018003

Dear Mr. Nazar:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Plant Units 1 and 2. On October 11, 2018, the NRC inspectors discussed the results of this inspection with Mr. DeBoer and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding involved violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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 the St. Lucie Plant.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC resident inspector at the St. Lucie Plant. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16

Enclosure:

IR 05000335/2018003 and 05000389/2018003 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Report Nos: 05000335/2018003, 05000389/2018003 Enterprise Identifier: I-2018-003-0044 Licensee: Florida Power & Light Company (FPL)

Facility: St. Lucie Plant, Units 1 and 2 Location: 6501 South Ocean Drive Jensen Beach, FL 34957 Dates: July 1, 2018 through September 30, 2018 Inspectors: T. Morrissey, Senior Resident Inspector S. Roberts, Resident Inspector R. Carrion, Senior Reactor Inspector (Section 71111.08)

B. Collins, Reactor Inspector (Section 71111.08)

P. Cooper, Reactor Inspector (Section 71003)

Approved by: Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a baseline inspection at St. Lucie Plant Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to meet the Transient Combustible Requirements Specified by NFPA 805 Cornerstone Significance Cross-cutting Report Section Aspect Initiating Events Green [H.5] - Human 71111.05 -

NCV 05000389/2018003-01 Performance, Fire Protection Closed Work Management Quarterly The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.48(c), National Fire Protection Standard NFPA 805, requirements. Specifically, the licensee failed to comply with transient combustible control requirements in high risk fire zones as required by NFPA 805 and implemented by licensee procedure ADM-19.03, Transient Combustible Control.

Additional Tracking Items Type Issue number Title Report Status Section URI 05000335/2015010-001 Implementation of Other Closed Commitments and Aging Activities Management Programs 71003

PLANT STATUS

Unit 1 began the inspection period at rated thermal power (RTP). The unit was at or near RTP for the remainder of the inspection period.

Unit 2 began the inspection period at RTP. On August 26, 2018, the control room operators commenced a planned power reduction and manually tripped the reactor from 25 percent RTP on August 27, 2018 to start a planned refueling outage. At the conclusion of the inspection period the unit had completed the refueling outage and was still shutdown, however, startup activities were underway and the unit was at normal operating temperature and pressure.

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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1, 1A and 1B trains of auxiliary feedwater (AFW) with 1C train AFW out of service (OOS) for maintenance, July 9, 2018

(2) Unit 1, intake cooling water (ICW) B train while A train was OOS for valve MV-21-3A repair, July 25, 2018

(3) Unit 2, 2B train high pressure safety injection (HPSI) while 2A train HPSI was OOS for maintenance, August 7, 2018

(4) Unit 2, 2A train low pressure safety injection (LPSI) while 2B train LPSI was OOS for motor replacement, September 18, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1, Reactor auxiliary building (RAB) 1A and 1B battery rooms, July 11, 2018

(2) Unit 1, 1A and 1B RAB electrical penetration rooms, July 15, 2018

(3) Unit 1, ICW pump and pipe trench, July 27, 2018

(4) Unit 2, RAB 43 foot

(ft) elevation, ventilation room, August 17, 2018

(5) Unit 2, Reactor containment building (RCB) 62 ft elevation, September 6, 2018

(6) Unit 2, RAB 19.5 ft elevation, east-west hallway, zone 51E, September 7, 2018

71111.06 - Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections in the Unit 1 charging pump area, which included checks of building structure drainage sumps, on July 30, 2018.

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated the Unit 2, 2B component cooling water (CCW) heat exchanger (HX) performance from August 29 - September 8, 2018.

71111.08 - Inservice Inspection Activities

The inspectors evaluated Unit 2 pressurized water reactor non-destructive testing by reviewing the following examinations from September 10 - 14, 2018:

(1) Liquid Penetrant Testing (PT)a) Framatome nondestructive evaluation (NDE) Report # D80-00-PT-001, Component ID: Pressurizer / 016-02 B Instrumentation Nozzle, American Society of Mechanical Engineers (ASME) Code Class 1. This review involved a pressure boundary weld.

(reviewed)

(2) Ultrasonic Testing (UT)a) Report # PSL2-UT-18-001; Component ID SI-151-FW-4-R, Pipe to Valve V-3247.

This review involved a pressure boundary weld, ASME Code Class 1. (reviewed)b) Report # PSL2-UT-18-020; Component ID RC-101-1-SW-7, Pipe to Elbow. This review involved a pressure boundary weld, ASME Code Class 1. (reviewed)c) Report # PSL2-UT-18-024; Component ID: MS-32-FW-1-LS, Pipe Longitudinal Seam, ASME Code Class 1. This review involved a pressure boundary weld.

(reviewed)

(3) Visual Testing (VT)a) Report # PSL2-VT-18-006, Component ID: CC-2703-76, Welded Dual Strut Support, ASME Code Class 3 (observed)b) Report # PSL2- VT-18-007, Component ID: CC-2703-76 IA, Welded Attachments, ASME Code Class 3 (observed)

(4) Eddy Current Testing a) Steam generator (SG) A (tubes R83C98, R124C79, R137C80), ASME Code Class 1 (observed)b) SG B (tubes R136C91, R121C100), ASME Code Class 1 (observed)

The Inspectors evaluated the licensees boric acid control program performance.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

On July 9, 2018, the inspectors observed and evaluated a licensed operator crew during an evaluated emergency plan evaluation on the control room simulator. The simulated scenario included multiple component failures and losses which resulted in operators initiating a manual reactor trip followed by a steam generator tube rupture (SGTR). The scenario resulted in a emergency classification which required a notification to the State of Florida and the NRC.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during a planned power reduction and shutdown of Unit 2 to support a refueling outage on August 26-27, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1, action requests (ARs) 2271246 and 2272137, valve MV-21-3 failed to close fully as expected

(2) Unit 1, ARs 2256348, 2266741, 2267408, 2275489, 2276059, 2278450, and 2279416, 1A charging pump failed to start following post-maintenance testing and 1A charging pump reduced flow

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1, Green risk associated with 1A ICW train OOS for planned maintenance, July 25, 2018

(2) Unit 1, Green risk associated with 1B HPSI pump and 1A ICW pump OOS for planned maintenance, July 30, 2018

(3) Unit 2, Green risk associated with 2A HPSI, LPSI, and containment spray pumps OOS for planned maintenance, August 7, 2018

(4) Unit 2, Green risk associated with 2B HPSI and 1B emergency diesel generator (EDG)

OOS for planned maintenance and separately 2B emergency core cooling system (ECCS) and 2B EDG OOS for planned maintenance and testing, August 20 - 22, 2018

(5) Unit 2, Yellow shutdown safety assessment (SSA) with the unit in Mode 5 and the reactor coolant system (RCS) depressurized and drained below the reactor vessel flange to support reactor head removal, August 29 - 31, 2018

(6) Unit 2, Yellow SSA with the unit in Mode 6 and Mode 5 and the RCS depressurized and drained to support reactor head installation and replacement of a pressurizer instrument nozzle, September 22 - 24, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1, AR 2268295, 1A ICW pump motor bearing degradation, July 16, 2018

(2) Unit 1, AR 2269904, 1B safety-related battery has visible swelling at posts (cells 3, 14, 20), July 17, 2018

(3) Unit 1, AR 2271906, main steam piping to 1C AFW pump degraded support, August 15, 2018

(4) Unit 1, AR 2274540, degraded conduit supports for MV-21-03, isolation valve A train ICW to turbine cooling water heat exchanger, August 15, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

Engineering change (EC) 291815, Norm/Isolate Switch SS/177 Replacement (1A charging pump)

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Unit 2, WO 40609806, HCV-09-2A, B header main feed isolation valve (MFIV) hydraulic leak repair, July 2, 2018

(2) Unit 1, WO 40612128, MV-21-3A, train A ICW isolation to turbine cooling water heat exchanger repair, July 26, 2018

(3) Unit 1, WO 40589601, 1A ICW pump motor replacement, August 6, 2018

(4) Unit 1, WO 40578226, 1A charging pump repair, August 15, 2018

(5) Unit 2, WO 40554003, MV-07-2B, B ECCS sump isolation valve, starter mechanical interlock replacement, August 21, 2018

(6) Unit 2, WOs 40533082 and 40533098 for MV-09-09, 2A AFW pump 2A discharge valve to 2A SG, and MV-09-10, 2B AFW pump discharge valve to 2B SG, valve inspections, September 26, 2018

(7) Unit 2, WO 40619929, 2B LPSI motor replacement, September 20, 2018

==71111.20 - Refueling and Other Outage Activities (Partial Sample)

The inspectors evaluated the Unit 2 refueling outage SL2-24 activities from August 27, 2018 through September 30, 2018. Unit 2 was in Mode 3 at normal operating temperature and pressure preparing to startup the unit at the conclusion of the inspection period. The inspectors completed the inspections required by IP 71111.20 with the exception of Section 03.02.e, Startup for entry into Mode 2 and Mode 1 which will be completed during the fourth quarter 2018 inspection period.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine==

(1) Unit 1, 1-OSP-99.09A, A Train Quarterly Check Valve Cycle Test, July 5, 2018

(2) Unit 2, 2-OSP-59.01A, 2A Emergency Diesel Generator Monthly Surveillance, (fast start), July 9, 2018

(3) Unit 2, 2-SMI-64.06, Linear Power Range Safety and Control Channel Monthly Calibration, July 10, 2018

(4) Unit 2, 2-OSP-69.13A, ESF-Staggered 36 Month Surveillance for SIAS/CIS/CSAS Train

A, August 27, 2018 In-service test (1 Samples)

Unit 2, 2-OSP-09.02C, 2C Auxiliary Feedwater Pump Refueling Shutdown Pump and Valve Test, August 27, 2018

Containment Isolation Valve (1 Sample)

Unit 2, 1-OSP-68.02, Local Leak Rate Test (penetration 14), September 4, 2018

71114.06 - Drill Evaluation Emergency Planning Drill

On July 9, 2018, the inspectors observed an evaluated licensed operator crew training during an evaluated emergency plan evaluation on the control room simulator. The simulated scenario included an instrument failure on the SG, loss of an instrument bus, loss of RCPs, which resulted in a manual reactor trip, followed by a SGTR. The scenario resulted in an emergency classification which required a notification to the State of Florida and the NRC.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified the following licensee performance indicators submittals for the periods listed below.

(1) Unit 1 Safety System Functional Failures from July 1, 2017, through June 30, 2018

(2) Unit 2 Safety System Functional Failures from July 1, 2017, through June 30, 2018

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

(1) The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issue. The issue was selected due to its potential impact to the operability of the ECCS ventilation system.

• AR 2266510, Unit 2, RAB ventilation boundary door, RA-83, found closed but unlatched by the NRC resident inspector.

(2) The inspectors reviewed the licensees implementation of its CAP related to the following issues related to corrosion of plant components. The inspectors selected these ARs for further review to determine whether the licensee was properly identifying and correcting plant components degraded by corrosion to ensure continued functionality/operability of the equipment.

• AR 2259832, Unit 2, corrosion on 2B diesel oil storage tank piping

• AR 2269268, Unit 2, corrosion on seismic support for 2A SG atmospheric dump valve downstream piping

• AR 2271795, Unit 1, corrosion on pipe restraint for main steam supply pipe to 1C turbine driven auxiliary feedwater pump

• AR 2261093, Unit 1, ICW drain valve SH21240 and tail piece heavily corroded

• AR 2274540, Unit 1, degraded/broken conduit clamps for conduit that supports safety-related valve MV-21-3

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation

The inspectors evaluated the onsite independent spent fuel storage installation (ISFSI) on July 18, 2018.

71003 - Post-Approval Site Inspection for License Renewal

The inspectors closed the following URI:

(1) Unresolved Item 05000335/2015010-001, Implementation of Commitments and Aging Management Programs

INSPECTION RESULTS

Failure to meet the Transient Combustible Requirements Specified by NFPA 805 Cornerstone Significance Cross-cutting Report Section Aspect Initiating Events Green [H.5] - Human

71111.05 - NCV 05000389/2018003-01 Performance, Fire Protection

Closed Work Management Quarterly The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.48(c), National Fire Protection Standard NFPA 805, requirements. Specifically, the licensee failed to comply with transient combustible control requirements in high risk fire zones as required by NFPA 805 and implemented by licensee procedure ADM-19.03, Transient Combustible Control.

Description:

On August 17, 2018, during a fire inspection walkdown associated with the Unit 2 reactor auxiliary building (RAB) 43 ft elevation, the inspectors identified transient combustible material, which consisted of an approximately 2.5 ft by 3.5 ft piece of 3/4-inch (in.) plywood and two wood pieces 2 in. by 4 in. and 3 ft, in length. This material was located on top of a cable tray in the overhead of the 19.5 ft elevation in the RAB east-west hallway (zone 51E). The inspectors determined that the approximate weight of the wood was 30 pounds. The issue was placed in the CAP as AR 2276502, and the licensee promptly removed the material.

On September 07, 2018, during a fire inspection walkdown of the Unit 2 RAB 19.5 ft elevation east-west hallway (zones 51E and 51W), the inspectors identified two scaffolds installed on August 2, 2018, that utilized pearl weave netting as a safety barrier around the scaffold platform in the overhead. The pearl weave netting extended up above the 28.67 ft elevation where the zones transitioned from ordinary risk fire areas to high risk fire areas.

The licensee immediately removed the pearl weave netting because its use in high risk fire areas was not allowed by the licensees transient combustible procedure. The issue was placed in the CAP as AR 2279680.

During this inspection period, inspectors identified similar pieces of plywood in overhead cable trays in ordinary fire risk areas. These areas included the 1B and 2B safety-related switchgear rooms. The licensee removed the transient combustible plywood pieces and placed the issues in the CAP as ARs 2279193 and 2275979. The inspectors determined that the amount of unattended transient combustibles found in the ordinary fire areas complied with licensee procedure ADM-19.03 Transient Combustible Control, Revision 6, in that it was less than the limit. The inspectors as well as the licensee identified an adverse trend in the area of transient combustible controls. This adverse trend was placed in the CAP as AR 2279680.

Licensee procedure, ADM-19.03, Section 4.0.10A, stated that for high risk fire zones, No unattended transient combustibles are allowed. In addition, ADM-19.03, Attachment 2, Exempt Combustible Material, allowed the use of NFPA 701 rated safety barrier netting (pearl weave) in all fire zones except for high risk fire zones.

The inspectors determined that the approximate 30 pounds of transient combustibles found in zone 51E, above the 28.67 ft elevation, was contrary to what was allowed by ADM-19.03 which specified that no transient combustibles were allowed in high risk fire zones. In addition, the use of pearl weave netting in high risk fire areas was also contrary to what was allowed by ADM-19.03.

Corrective Action(s): The licensees corrective actions included: 1) removing the transient combustibles identified by the inspectors, 2) removing the safety barrier netting from the high risk fire areas, and, 3) completed an extent of condition walkdowns of all RAB overhead fire areas to identify and remove any additional transient combustibles as necessary.

Corrective Action Reference(s): These issues were entered into the licensees CAP in ARs 2275979, 2276502, 2279193, and 2279680

Performance Assessment:

Performance Deficiency: The failure to implement combustible material control requirements as specified in licensee procedure ADM-19.03, Transient Combustible Control, was a performance deficiency. Specifically, the licensee failed to comply with transient combustible control requirements in high risk fire zones as required by NFPA 805 and implemented by licensee procedure ADM-19.03.

Screening: The performance deficiency was more than minor because it adversely impacted the Initiating Events cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations. The combustible materials identified in high risk fire zones contrary to requirements specifically increased the fire ignition frequency of the plant.

Significance: Using Inspection Manual Chapter (IMC) 0609, Attachment 4, Initial Characterization of Findings, Table 2, the finding was determined to require an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review since the issue involved the failure to control transient combustibles. The finding did not meet the criteria to be assigned a low degradation rating (IMC 0609, App. F, question 1.3.1-A). The finding was determined to be of very low safety significance (Green) because, although the finding could result in a more significant fire than previously analyzed, the finding was in an area with adequate automatic detection and suppression (IMC, App. F, question 1.4.1-B).

Cross-cutting Aspect: A cross-cutting aspect in work management, [H.5], was identified because the licensee failed to implement a process of planning, controlling and executing work activities, to ensure transient combustible control requirements were met during work in high risk fire zones.

Enforcement Violation: St. Lucie Nuclear Station, Unit 2, Renewed Facility Operating License Condition 3.E, Fire Protection, required, the licensee, in part, to implement and maintain in effect all provisions of the approved fire protection plan that complied with 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, as specified in the NRC safety evaluation report (SER) dated March 21, 2016. NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, Section 3.3.1.2, Control of Combustible Materials, required, that procedures for the control of transient combustibles shall be developed and implemented. This is performed by licensee procedure ADM-19.03, Transient Combustible Control, revision 6.

Contrary to the above, the licensee failed to implement ADM-19.03, Transient Combustible Control, Revision 6, requirements for high risk fire zones for the control of transient combustibles on August 2, 2018, regarding pearl weave netting and again on August 17, 2018, regarding the 30 pounds of wood transient combustibles. It is unknown when the wood transient combustibles were placed in the area, however the items were removed promptly upon identification.

Enforcement Action: The violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.

Minor performance deficiency 71152 Annual Follow-up Minor Performance Deficiency: The licensees failure to ensure RAB ventilation boundary door RA-83 was closed and latched in accordance with administrative procedure ADM-17.25, Plant Barrier Control, Revision 21, after transiting through the door, was a performance deficiency.

Screening: The inspectors determined the performance deficiency was minor since the licensee was able to show, through completion of ECCS ventilation testing, that the ECCS ventilation system remained operable with the RA-83 door open.

Observations of review of corroded/degraded components 71152 Annual Follow-up The inspectors identified two corroded/degraded components that were previously identified and placed in the CAP, however, the corrective actions to mitigate the corrosion had not been implemented in a timely fashion. In April 2018, the inspectors identified a heavily corroded ICW drain pipe to ICW drain valve SH21240, which was the ICW inlet drain to 1B CCW heat exchanger. The inspectors observations were documented in the CAP as AR 2261093.

The inspectors determined that this same component was previously identified by the licensee as needing coating in June 2016 in AR 2137855. The work order to apply coatings to the pipe/valve was scheduled to work in November 2018. Due to the current degraded condition of the component after two additional years of degradation, the licensee replaced the pipe and valve.

In August 2018, the inspectors found degraded/broken conduit clamps for conduit that supported Unit 1 safety-related valve MV-21-3, turbine cooling water isolation. AR 2274540 documented the inspectors observation. This condition was previously documented by the licensee in October 2015 as AR 2081667. This AR noted that timely repair was necessary to prevent further degradation. The inspectors noted that the WO referenced had not been scheduled. The time delay in mitigating corrosion of components resulted in additional degradation of the components when the licensee subsequently replaced the degraded conduit clamps. Further delay could have potentially lead to the loss of function. For the two examples noted above, no loss of function occurred and therefore no associated violations.

In addition, during the course of NRC baseline inspection system and area walkdowns, the inspectors identified three components that were degraded by corrosion and had not been identified by the licensee nor entered into the licensees CAP. All three items were determined to be operable/functional.

• AR 2259832, Unit 2, corrosion on 2B diesel oil storage tank piping

• AR 2269268, Unit 2, severe corrosion on 2A steam generator atmospheric dump valve downstream piping seismic support

• AR 2271795, Unit 1, severe corrosion on pipe restraint for main steam supply pipe to 1C turbine driven auxiliary feedwater pump The inspectors observations regarding the failure to identify and mitigate corrosion were presented to licensee management. The licensee determined that additional actions were needed to address site corrosion given the normal maintenance activities were not effective.

The licensee initiated AR 2273355 to develop a program to address improving the identification of, prioritization of, and mitigation of corroded components. The program will develop a strategy for using long term coatings such as metalizing/thermal spray that can withstand the corrosive salt environment at St. Lucie.

Unresolved Item Implementation of Commitments and Aging Management 71003, (Closed) Programs License URI 05000335/2015010-001 Renewal

Description:

During the 2015 Post-Approval for License Renewal (Phase 2) Inspection, the team identified a URI associated with the implementation status of various commitments and Aging Management Programs (AMPs). This URI was later discussed in the 2017 Post-Approval for License Renewal (Phase 2) Inspection where several of the pending actions were found to be completed. The commitments associated with the Reactor Vessel Internals Aging Management Program were the remaining items pending resolution.

Corrective Action Reference: The licensee tracked the actions necessary for URI Closure in AR 02094578.

Closure Basis: On May 2, 2018 the NRC issued a letter and enclosure of the Staff Assessment by the Office of Nuclear Reactor Regulation Reactor Vessel Internals Aging Management Plan, (ADAMS Accession No. ML18071A002). This letter documented the NRCs staff review and assessment of the licensees submittal of the St. Lucie Unit 1 and 2, Reactor Vessel Internals Aging Management Plan. The NRC concluded that the licensees Reactor Vessel Internal AMP and the Reactor Vessel Internals Inspection Plan were acceptable and that the licensee had fulfilled their commitments. The inspectors reviewed a sample of work orders associated with the Reactor Vessel Internals Program during the St.

Lucie Unit 1 Inservice Inspection documented in report 05000335/2018001 (ADAMS Accession No. ML18121A344). On the basis of the sample selected for review, the inspectors determined that the licensee had the administrative controls in place and had completed, or was on track, to complete the necessary tasks to meet the license renewal commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license at Saint Lucie Unit 1 and Unit

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On September 14, 2018, the inspectors presented the inservice inspection results to Mr. D. DeBoer and other members of the licensee staff.

On September 27, 2018, the inspectors presented the 71003 URI closure results to Mr. R. Sciscente.

On October 11, 2018 the inspector presented the quarterly resident inspector inspection results to Mr. D. DeBoer and other members of the licensee staff.

LIST OF

DOCUMENTS REVIEWED

Section 71111.04: Equipment Alignment

2-NOP-03.11, LPSI System Initial Alignment

1-NOP-09.11, Auxiliary Feedwater System Initial Alignment

1-NOP-21-12, Intake Cooling Water System Initial Alignment

2-NOP-03.11, High Pressure Safety Injection Initial Alignment

Section 71111.05: Fire Protection

ADM-0005729, Fire Protection Training, Qualification and Requalification

ADM-19.02, Pre-Fire Plan Standard Operating Procedure

Section 71111.06: Flood Protection Measures

1-AOP-24.01, RAB Flooding

8770-G-889, Unit 1 RAB Basement Floor Plan Plumbing and Drainage Drawing

Unit 2 Updated Final Safety Analysis Report (UFSAR), Section 3.4.3, RAB Internal Flooding

Due to Equipment Rupture.

Section 71111.07: Heat Sink Performance

Electric Power Research Institute (EPRI) Heat Exchanger Performance Monitoring Guideline,

NP-7552

Section 71111.08: Inservice Inspection Activities

Procedures

54-ISI-400-022, Areva Inc. Nondestructive Examination Procedure: Multi-Frequency Eddy

Current Examination of Tubing, Revision 022

51-0101361-007, Framatome Inc. Engineering Information Record: Qualified Eddy Current

Examination Techniques for St. Lucie (PSL) Unit 2, Revision 007

51-9269290-000, Areva Inc. Engineering Information Record: St. Lucie SL2-23 Secondary Side

Inspection Final Report, Revision 000

ER-AP-116-1000, Boric Acid Corrosion Control, Revision 2

NDE Manual Examination Procedure 4.1, Component, Support & Inspection, Visual

Examination VT-1, Revision 14

NDE Manual Examination Procedure 4.3, Component, Support & Inspection, Visual

Examination VT-3, Revision 12

Corrective Action Documents

Action Request (AR) 02079327, Assessment No. 02079327, Review of the Recovery Plan

Actions from AR 02079332

AR 02190462, Assignment 02, Unit 2 ISI, RVH & SG Exam (IP7111108P)

AR 02232967, Programs Engineering Water Hammer Evaluation for Unit 2 Reactor Trip, dated

Mar 28, 2018

AR 02259970-01, On 4/17/18, An Active Borated Water Leak Was Observed from Upstream

Tubing/Connections of the Unit 2 V5728 Control Valve.

AR 02259985-01, On 4/17/18, An Active Borated Water Leak Was Observed from Unit 2

V07166 Valve Packing

AR 02266484-01, On 5/31/18, Excessive Boric Acid Residue Was Observed on the Unit 2

V3146 Packing Gland and Valve Body

AR 02279817, Pressurizer Bottom Head Boric Acid Leak at Pressurizer-to-Instrument Nozzle

Non-Destructive Examination (NDE) Reports

Report # PSL2-UT-18-001; Component ID SI-151-FW-4-R, Pipe to Valve V-3247

Report # PSL2-UT-18-020; Component ID RC-101-1-SW-7, Pipe to Elbow

Report # PSL2-UT-18-024; Component ID: MS-32-FW-1-LS, Pipe Longitudinal Seam

Report # PSL2-VT-18-006, Component ID: CC-2703-76, Welded Dual Strut Support

Report # PSL2-VT-18-007, Component ID: CC-2703-76 IA, Welded Attachments

Other Documents

Areva Certificate of Personnel Qualification: ET LIII-QDA (Boudreaux), dated August 18, 2016

Framatome Certificate of Vision Examination (Boudreaux), dated June 14, 2018

Framatome Certificate of Personnel Qualification: ET LIII-QDA (Vojvodic), dated May 17, 2018

Framatome Certificate of Vision Examination (Vojvodic), dated March 23, 2018

Intertek Degradation Assessment for St. Lucie Unit 2 Steam Generators for End-of-Cycle 23

(September 2018 Outage)

L-2014-252, FPL Letter to NRC for Unit 2 Relief Request 2, dated August 1, 2014

NDE Personnel Certifications for

L. Cochran,

E. Fish,

J. Hacker,

B. Knott,

N. Sauter,

M. Smith,

and J. Venegas

NRC Letter to NextEra Energy Approving Proposed Alternative to Use Encoded Phased Array

Ultrasonic Examination Techniques (EPID L-2017-LLR-0081), dated April 25, 2018

Welder Performance Qualifications for

G. Aldana, D. Padgett

Welding Procedure Specification (WPS)-11, Rev.11, Dated 6/21/06

St. Lucie Nuclear Power Plant Unit 2, Fourth Inservice Inspection Interval Program Plan,

Revision 2

Work Order Package WO 40154456-01, U2 SE-02-1; Replace Valve w/Bolted Bonnet Design-

Maint Burden, ASME Class 1

WO 40299552-01, U2; AZ-122, AZ-135, AZ-148 Cut, Weld Pipe Support, Inspect; ASME Code

Class 2

WO 40302487-01, U2 Line #CS-2; Coat and Replace Two Pipe Supports, ASME Code Class 2

WO 40337658-01, 2B ICW CW-72 Discharge of 2B CCW HX Internal, ASME Code Class 3

WO 40417100-01, U2 CW-9: Replace Support CW-3000-77 per AR 02074364, ASME Code

Class 3

WO 40525262-12, U2/ V3247 AN

N. R-50, SI Header 2B2 Check Valve Is Leaking, ASME Code

Class 1

WO 40533220-02, MW SE-02-2 Weld Support; Install Bonnet Seal Weld, Including PT upon

Weld Completion. ASME Code Class 1 Valve

WO 40590618-01, U2: CW-72 - Repair Cracked Welds CW-3002-7900; Weld, ASME Code

Class 3

WO 40621536-01, EC 291956, Pressurizer Instrument Nozzle 016-2B Repair, ASME Code

Class 1

Section 71111.11: Licensed Operator Requalification Program and Licensed Operator

Performance

2-NOP-99.07, Operations Hard Cards

2-AOP-49.02, 120V Instrument AC System (Class 1E) Abnormal Operation

2-AOP-01.10, Pressurizer Pressure and Level Abnormal Operation

2-AOP-99.01, Loss of Tech Spec Instrumentation

2-NOP-01.02, Reactor Coolant Pump Normal Operation

2-EOP-01, Standard Post Trip Actions

2-EOP-04, Steam Generator Tube Rupture

EPIP-01, Classification of Emergencies

EPIP-02, Duties and Responsibilities of the Emergency Coordinator

EPIP-08, Offsite Notifications and Protective Action Recommendations

2-GOP-123, Turbine Shutdown - Full Load to Zero Load

Section 71111.12: Maintenance Effectiveness

ER-AA-100-2002, Maintenance Rule Program Administration

SCEG-004, Guideline for Maintenance Rule Scoping, Risk Significant Determination, and

Expert Panel Activities

Section 71111.13: Maintenance Risk Assessments and Emergent Work Control

OP-AA-104-1007, Online Aggregate Risk

WCG-016, Online Work Management

OM-AA-101-1000, Shutdown Risk Management

ADM-09.23, Outage Risk Assessment and Control

Section 71111.18: Plant Modifications

EN-AA-205-1100, Design Change Packages

Section 71111.20: Refueling and Other Outage Activities

AR 2278058, Jib Crane Failure

ADM-09.23, Outage Risk Assessment and Control

2-GMM-68.02, Emergency Closure of Containment Penetrations, Personnel Hatch, and

Equipment Hatches

2-NOP-01.03, Draining RCS

2-NOP-01.05, Filling and Venting RCS

2-NOP-03.05, Shutdown Cooling

2-GOP-303, Reactor Plant Heatup - Mode 3 < 1750 to Mode 3 > 1750

2-GOP-365, Refueling Sequence Guidelines

2-GOP-403, Reactor Plant Heatup - Mode 4 to Mode 3

2-GOP-504, Reactor Plant Startup - Mode 5 to Mode 4

ADM-09.26, Shutdown Cooling Controls

0-NOP-67.05, Refueling Operation

0-SMM-85.01, Containment Closeout Housekeeping and FME Inspections

0010728, Unit Restart Readiness

Section 71111.22: Surveillance Testing

ADM-29.02, ASME Code Testing of Pumps and Valves

71151: PI Verification Inspection

Procedures, Guidance Documents and Manuals

LI-AA-100-10003, NRC Performance Indicator

16