IR 05000335/2009005

Download: ML100200695

Text

January 21, 2010

Mr. Mano Nazar Executive Vice President Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT: ST. LUCIE NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000335/2009005, 05000389/2009005

Dear Mr. Nazar:

On December 31, 2009, the US Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Plant. The enclosed inspection report documents the inspection results, which were discussed on January 7, 2010, with Mr. Hicks and other members of your staff.

The inspection examined activities conducted under your license as they related to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents one inspector identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating the finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the St. Lucie facility. In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region II, and the NRC Resident Inspector at St. Lucie. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

FP&L 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Marvin D. Sykes, Chief Rector Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2009005, 05000389/2009005

w/Attachment:

Supplemental Information cc w/encl: (See page 3)

FP&L 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Marvin D. Sykes, Chief Rector Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-335, 50-389 License Nos.: DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2009005, 05000389/2009005

w/Attachment:

Supplemental Information cc w/encl: (See page 3)

XG PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE XG NON-SENSITIVE ADAMS: XG Yes ACCESSION NUMBER:ML100200695______ XG SUNSI REVIEW COMPLETE OFFICE RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE PCH1 TLH4 by phone SPS by phone MDS NAME PHiggins THoeg SSanchez MSykes DATE 01/20/2010 01/20/2010 01/20/2010 01/20/2010 1/ /2010 1/ /2010 1/ /2010 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: I:\RPB3\STLUCIE\REPORTS\2009\INSPECTION REPORT 09-05.DOC FP&L 3 cc w/encl: Richard L. Anderson Site Vice President St. Lucie Nuclear Plant Electronic Mail Distribution Robert J. Hughes Plant General Manager St. Lucie Nuclear Plant Electronic Mail Distribution Mark Hicks Operations Manager St. Lucie Nuclear Plant Electronic Mail Distribution Rajiv S. Kundalkar Vice President - Fleet Organizational Support Florida Power & Light Company Electronic Mail Distribution Eric Katzman Licensing Manager St. Lucie Nuclear Plant Electronic Mail Distribution Abdy Khanpour Vice President Engineering Support Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 McHenry Cornell, Director Licensing and Performance Improvement Florida Power & Light Company Electronic Mail Distribution Alison Brown Nuclear Licensing Florida Power & Light Company Electronic Mail Distribution Mitch S. Ross Vice President and Associate General Counsel Florida Power & Light Company Electronic Mail Distribution Marjan Mashhadi Senior Attorney Florida Power & Light Company Electronic Mail Distribution William A. Passetti, Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution Ruben D. Almaguer, Director Division of Emergency Preparedness Department of Community Affairs Electronic Mail Distribution J. Kammel Radiological Emergency Planning Administrator Department of Public Safety Electronic Mail Distribution Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power & Light Company Electronic Mail Distribution Senior Resident Inspector St. Lucie Nuclear Plant U.S. Nuclear Regulatory Commission P.O. Box 6090 Jensen Beach, FL 34957-2010 (Vacant) Vice President Nuclear Plant Support Florida Power & Light Company Electronic Mail Distribution Faye Outlaw County Administrator St. Lucie County Electronic Mail Distribution Jack Southard Director Public Safety Department St. Lucie County Electronic Mail Distribution FP&L 4 Report to Mano Nazar from Marvin Sykes dated January 20, 2010.

SUBJECT: ST. LUCIE NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000335/2009005, 05000389/2009005 Distribution w/encl: C. Evans, RII EICS L. Slack, RII EICS OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMStLucie Resource Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket Nos: 50-335, 50-389 License Nos: DPR-67, NPF-16 Report No: 05000335/2009005, 05000389/2009005 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Nuclear Plant, Units 1 & 2 Location: 6351 South Ocean Drive Jensen Beach, FL 34957 Dates: October 1 to December 31, 2009 Inspectors: T. Hoeg, Senior Resident Inspector S. Sanchez, Resident Inspector M. Bates, Senior Operations Engineer M. Meeks, Operations Engineer Approved by: M. Sykes, Chief Reactor Projects Branch 3 Division of Reactor Projects

Enclosure SUMMARY OF FINDINGS IR 05000335/2009-005, 05000389/2009-005; 10/01/2009 - 12/31/2009; St. Lucie Nuclear Plant, Units 1 & 2; Identification and Resolution of Problems.

The report covered a three month period of inspection by resident inspectors and region based inspectors. One Green NCV was identified. The significance of most findings is identified by their color (Green, White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP); the cross-cutting aspect was determined using IMC 305, Operating Reactor Assessment Program; and findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process", and Revision 4, dated December 2006. A. NRC-Identified and Self-Revealing Findings Cornerstone: Initiating Events Green. An inspector identified non-cited violation of Technical Specification 6.8.1.a and Regulatory Guide 1.33 was identified for an inadequate safety-related maintenance procedure. Specifically, the inspectors identified that during reassembly of Reactor Coolant Pump (RCP) 2B2 in July 2009 mechanical maintenance procedure MMP-01.17,

"Reactor Coolant Pump Model N-9000 Seal Removal and Installation," Revision 10, instructed the licensee to utilize a method of checking the RCP coupling alignment that was not in accordance with Byron Jackson Technical Manual 741-N-0001/4, Revision 23. The procedure instructed the maintenance workers to measure the shaft coupling flange face gap clearance rather than measuring the concentricity/runout of the coupling flanges as required in the subject vendor technical manual. This resulted in the RCP running with increased vibrations and ultimately requiring a plant shutdown to perform repairs. This issue was entered into the Corrective Action Program (CAP) as Condition Reports 2009-28512 and 2009-22728 This finding is more than minor because it is associated with procedure quality attribute and affected the objective of the Reactor Safety/Initiating Event Cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the subject RCP maintenance procedure did not require the measurement of coupling run-out whenever the coupling is disassembled in accordance with the vendor technical manual requirements which resulted in an unplanned plant shutdown. The finding was determined to be of very low safety significance since it did not contribute to both the likelihood of a reactor trip and that mitigation equipment or functions would not be available. The inspectors determined that the cause of this finding has a crosscutting aspect in the area of human performance associated with the resources attribute, in that the maintenance procedure instructions were not complete or accurate to ensure proper RCP coupling alignment. (IMC 0305 aspect H.2.c). (Section 4OA2.2) B. Licensee Identified Violations None.

Enclosure REPORT DETAILS Summary of Plant Status: Unit 1 began the period at full Rated Thermal Power (RTP) and on October 19 was downpowered to 45% to repair a main feedwater lube oil pump. The unit was returned to full RTP on October 22. On November 17 Unit 1 was downpowered to 65% to perform repairs on a turbine building cooling water heat exchanger drain line. The unit was returned to full RTP on November 20. On December 16 Unit 1 was downpowered to 68% in response to a dropped control element assembly during scheduled rod testing. The unit was returned to full RTP on December 16 and operated at full RTP for the remainder of the period. Unit 2 began the period at full RTP and essentially operated at full power for the entire period. 1. REACTOR SAFETY Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (Reactor-R) 1R04 Equipment Alignment .1 Partial Equipment Walkdowns a. Inspection Scope The inspectors conducted two partial alignment verifications of the safety-related systems listed below. These inspections included reviews using plant lineup procedures, operating procedures, and piping and instrumentation drawings, which were compared with observed equipment configurations to verify that the critical portions of the systems were correctly aligned to support operability. The inspectors also verified that the licensee had identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers by entering them into the corrective action program (CAP). * 2B Emergency Core Cooling System (ECCS) While 2A ECCS Out of Service (OOS) * 1B Emergency Diesel Generator (EDG) While 1A EDG OOS b. Findings No findings of significance were identified. .2 Complete System Walkdown a. Inspection Scope The inspectors conducted a detailed walkdown/review of the alignment and condition of the Unit 1 Auxiliary Feedwater (AFW) system to verify its capability to meet its design basis function. The inspectors utilized licensee procedure 1-NOP-09.11, Auxiliary Feedwater System Initial Alignment, and drawing 8770-G-080, Unit 1 Feedwater and Condensate System Piping and Instrumentation Drawing, as well as other licensing 4 Enclosure and design documents to verify the system alignment was correct. During the walkdown, the inspectors verified, as appropriate, that: (1) valves were correctly positioned and did not exhibit leakage that would impact their function; (2) electrical power was available as required; (3) major portions of the system and components were correctly labeled, cooled, and ventilated; (4) hangers and supports were correctly installed and functional; (5) essential support systems were operational; (6) ancillary equipment or debris did not interfere with system performance; (7) tagging clearances were appropriate; and (8) valves were locked as required by the licensee's locked valve program. Pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the system's functions. Items included in this review were the operator workaround list, the temporary modification list, system health reports, system description, and outstanding maintenance work requests/work orders. In addition, the inspectors reviewed the licensee's CAP to ensure that the licensee was identifying and resolving equipment alignment problems. b. Findings No findings of significance were identified. .3 Complete System Walkdown a. Inspection Scope The following write-up documents a complete system walkdown that was performed by the inspectors during the second quarter of 2009, but was not documented in St. Lucie Inspection Report 2009-003.

The inspectors conducted a detailed walkdown/review of the alignment and condition of the 2B Component Cooling Water (CCW) system to verify its capability to meet its design basis function. The inspectors utilized licensee procedure 2-NOP-14.01, Component Cooling Water System Initial Alignment, and drawing 2998-G-083, Unit 2 Component Cooling Water System Piping and Instrumentation Drawing, as well as other licensing and design documents to verify the system alignment was correct. During the walkdown, the inspectors verified, as appropriate, that: (1) valves were correctly positioned and did not exhibit leakage that would impact their function; (2) electrical power was available as required; (3) major portions of the system and components were correctly labeled, cooled, and ventilated; (4) hangers and supports were correctly installed and functional; (5) essential support systems were operational; (6) ancillary equipment or debris did not interfere with system performance; (7) tagging clearances were appropriate; and (8) valves were locked as required by the licensee's locked valve program. Pending design and equipment issues were reviewed to determine if the identified deficiencies significantly impacted the system's functions. Items included in this review were the operator workaround list, the temporary modification list, system health reports, system description, and outstanding maintenance work requests/work orders. In addition, the inspectors reviewed the licensee's CAP to ensure that the licensee was identifying and resolving equipment alignment problems.

5 Enclosure b. Findings No findings of significance were identified.

1R05 Fire Protection .1 Fire Area Walkdowns a. Inspection Scope The inspectors toured the following five plant areas during this inspection period to evaluate conditions related to control of transient combustibles and ignition sources, the material condition and operational status of fire protection systems including fire barriers used to prevent fire damage or fire propagation. The inspectors reviewed these activities against provisions in the licensee's procedure AP-1800022, Fire Protection Plan, and 10 CFR Part 50, Appendix R. The licensee's fire impairment lists, updated on an as-needed basis, were routinely reviewed. In addition, the inspectors reviewed the Condition Report (CR) database to verify that fire protection problems were being identified and appropriately resolved. The following areas were inspected: * Unit 2 Reactor Auxiliary Building (RAB) 19.5 Foot Elevation * Unit 1 ECCS Pump Rooms * Unit 2 RAB 43.0 Foot Elevation * Unit 2 'A' Vital Battery Room * Unit 2 Main Control Room b. Findings No findings of significance were identified. .2 Fire Protection - Drill Observation a. Inspection Scope The inspectors observed one fire drill during this inspection period. On October 7, 2009, an unannounced fire drill took place in the Unit 1 Chemical Laboratory. The drill was observed to evaluate the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. Specific attributes evaluated were: (1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use and layout of fire hoses; (3) employment of appropriate fire fighting techniques; (4) sufficient fire fighting equipment brought to the scene; (5) effectiveness of command and control; (6) search for victims and propagation of the fire into other plant areas; (7) smoke removal operations; (8) utilization of pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill objectives.

6 Enclosure b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification Training Program .1 Resident Inspector Quarterly Review a. Inspection Scope On December 8, 2009, the inspectors observed and assessed licensed operator actions during a simulated steam generator tube rupture and subsequent reactor trip training exercise. The exercise was performed in conjunction with St. Lucie Plant 4th quarter emergency preparedness training drill. The inspectors also reviewed simulator physical fidelity and specifically evaluated the following attributes related to the operating crews' performance:

• Clarity and formality of communication * Ability to take timely action to safely control the unit * Prioritization, interpretation, and verification of alarms * Correct use and implementation of off-normal and emergency operation procedures; and emergency plan implementing procedures * Control board operation and manipulation, including high-risk operator actions * Oversight and direction provided by supervision, including ability to identify and implement appropriate technical specification actions, regulatory reporting requirements, and emergency plan classification and notification * Crew overall performance and interactions * Effectiveness of the post-evaluation critique. b. Findings No findings of significance were identified. .2 Licensed Operator Requalification a. Inspection Scope The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of November 16, 2009, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensee's operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, "Operators' Licenses." The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," and Inspection Procedure 71111.11, "Licensed Operator 7 Enclosure Requalification Program." The inspectors also evaluated the licensee's simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5-1998, "American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination." The inspectors observed two (2) crews during the performance of the operating tests. Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11. Documents reviewed during the inspection are documented in the List of Documents Reviewed. b. Findings No findings of significance were identified.

1R12 Maintenance Effectiveness a. Inspection Scope The inspectors reviewed system performance data and associated CRs for the two systems listed below to verify that the licensee's maintenance efforts met the requirements of 10 CFR 50.65 (Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants) and licensee Administrative Procedure ADM-17-08, Implementation of 10CFR50.65, Maintenance Rule. The inspectors' efforts focused on maintenance rule scoping, characterization of maintenance problems and failed components, risk significance, determination of a(1) and a(2) classification, corrective actions, and the appropriateness of established performance goals and monitoring criteria. The inspectors also interviewed responsible engineers and observed some of the corrective maintenance activities. The inspectors also attended applicable expert panel meetings and reviewed associated system health reports. The inspectors verified that equipment problems were being identified and entered into the licensee's CAP. * Unit 1 125 Volt Direct Current System * Unit 2 Containment Spray System b. Findings No findings of significance were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control a. Inspection Scope The inspectors completed in-office reviews, plant walkdowns, and control room inspections of the licensee's risk assessment of three emergent or planned maintenance activities. The inspectors verified the licensee's risk assessment and risk management activities using the requirements of 10 CFR 50.65(a)(4); the recommendations of 8 Enclosure Nuclear Management and Resource Council 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3; and licensee procedure ADM-17.16, Implementation of the Configuration Risk Management Program. The inspectors also reviewed the effectiveness of the licensee's contingency actions to mitigate increased risk resulting from the degraded equipment. The inspectors interviewed responsible Senior Reactor Operators on-shift, verified actual system configurations, and specifically evaluated results from the online risk monitor (OLRM) for the combinations of out of service (OOS) risk significant systems, structures, and components (SSCs) listed below: * Auxiliary Spray Valve, 2B Charging Pump, and 2B EDG OOS * 2A Charging Pump, 2C AFW Pump, Atmospheric Dump Valve MV-08-19A, Auxiliary Spray Valve, and 1A EDG OOS * 2B EDG and 2B ECCS Pumps OOS b. Findings No findings of significance were identified. 1R15 Operability Evaluations a. Inspection Scope The inspectors reviewed the following six condition report (CR) interim dispositions and operability determinations to ensure that operability was properly supported and the affected SSCs remained available to perform its safety function with no increase in risk. The inspectors reviewed the applicable UFSAR, and associated supporting documents and procedures, and interviewed plant personnel to assess the adequacy of the interim disposition. * CR 2009-29969, 1A Intake Cooling Water (ICW) Pump Seal Water Inlet Line Failure * CR 2009-30759, 1B EDG Fuel Oil Transfer Pump Started Inadvertently * CR 2009-31688, Air In Unit 1 Component Cooling Water (CCW) System * CR 2009-28926, Unit 1 AFW Actuation System Cabinet 'A' Trip Lamp Lit for Steam Generator Delta Pressure * CR 2009-32033, Unit 1 Containment Isolation Valve MV-18-1 Leaking By Its Seat and Pressurizing Containment * CR 2009-33262, Kilowatt (kW) Spikes Greater Than 300 kW During 2B EDG Run b. Findings No findings of significance were identified 9 Enclosure 1R18 Plant Modifications a. Inspection Scope The inspectors reviewed the documentation for a permanent modification to the 1A emergency diesel generator fuel oil day tank level control system. The plant change modification (PCM) was performed in accordance with PCM 09115M to correct known level control problems associated with Murphy float switch level control devices. The inspectors reviewed the 10 CFR 50.59 screening and evaluation, fire protection review, environmental review, and license renewal review, to verify that the modification had not affected system operability/availability. The inspectors reviewed associated plant drawings and UFSAR documents impacted by this modification and discussed the changes with licensee personnel to verify that the installation was consistent with the modification documents. The inspectors walked down the modification to determine if it was installed in the field as described in the subject PCM. Additionally, the inspectors verified that problems associated with modifications were being identified and entered into the CAP. b. Findings No findings of significance were identified.

1R19 Post Maintenance Testing a. Inspection Scope For the six post maintenance tests (PMTs) listed below, the inspectors reviewed the test procedures and either witnessed the testing and/or reviewed test records to determine whether the scope of testing adequately verified that the work performed was correctly completed and demonstrated that the affected equipment was functional and operable. The inspectors verified that the requirements of licensee procedure ADM-78.01, Post Maintenance Testing, were incorporated into test requirements. The inspectors reviewed the following work orders (WO) and/or work requests (WR): * WO 39017915, 1A EDG Level Switch Modification * WO 38014240, Unit 2 Valve V3551 Stem Lubrication * WO 38018595, Valve MV-18-18A Relay Replacement * WO 39022540, 2A Steam Generator Blowdown Sample Valve FCV-23-7 Stem Lubrication * WO 38012890, 2A CCW Heat Exchanger Cleaning * WO 38024573, 1A ICW Pump Seal Replacement b. Findings No findings of significance were identified.

10 Enclosure 1R22 Surveillance Testing a. Inspection Scope The inspectors either reviewed or witnessed the following three surveillance tests to verify that the tests met the TS, the UFSAR, the licensee's procedural requirements, and demonstrated the systems were capable of performing their intended safety functions and their operational readiness. In addition, the inspectors evaluated the effect of the testing activities on the plant to ensure that conditions were adequately addressed by the licensee staff and that after completion of the testing activities, equipment was returned to the positions/status required for the system to perform its safety function. The tests reviewed included one in-service test (IST) surveillance. The inspectors verified that surveillance issues were documented in the CAP. * 2-OSP-59.01A, 2A EDG Monthly Code Run * 2-OSP1.03, Reactor Coolant System Inventory Balance * 2-OSP-2.01B, 2B Charging Pump Quarterly Code Run b. Findings No findings of significance were identified. 1EP6 Drill Evaluation Emergency Preparedness Drill a. Inspection Scope On October 7, 2009, the inspectors observed licensed operators in the simulator, technical support center staff, and the emergency operations facility staff during a drill of the site emergency response organization. The drill included a fire in the 2B emergency diesel generator room and loss of feedwater event followed by a loss of coolant accident. During the drill the inspectors assessed operator actions to verify that emergency classifications and notifications were made in accordance with licensee emergency plan implementing procedures (EPIPs) and 10 CFR 50.72 requirements. The inspectors specifically reviewed the Site Area Emergency and General Emergency classifications and notifications were in accordance with licensee procedures EPIP-01, Classification of Emergencies and EPIP-02, Duties and Responsibilities of the Emergency Coordinator. The inspectors also observed whether (1) the initial activation of the emergency response centers was timely and as specified in the licensee's emergency plan; (2) the required TS actions for the drill scenario were reviewed to assess correct implementation; (3) the licensee identified critique items were discussed and reviewed to verify that drill weaknesses were identified and captured in the CAP.

On December 8, 2009, the inspectors observed licensed operators in the simulator and other personnel in the technical support center during a drill of the site emergency response organization. The drill included a steam generator tube leak followed by a fuel 11 Enclosure handling accident and loss of off-site power. During the drill the inspectors assessed operator actions to verify that emergency classifications and notifications were made in accordance with licensee emergency plan implementing procedures and 10 CFR 50.72 requirements. The inspectors specifically reviewed the Alert and Site Area Emergency classifications and notifications were in accordance with licensee procedures EPIP-01, Classification of Emergencies, and EPIP-02, Duties and Responsibilities of the Emergency Coordinator. The inspectors also observed whether (1) the initial activation of the emergency response centers was timely and as specified in the licensee's emergency plan; (2) the required TS actions for the drill scenario were reviewed to assess correct implementation; (3) the licensee identified critique items were discussed and reviewed to verify that drill weaknesses were identified and captured in the CAP. On March 11, 2009, the inspectors observed a training evolution of the emergency preparedness organization associated with more restricted use of site access and control when responding to reactor plant emergencies with possible plant security related challenges and restrictions. The inspectors observed portions of the training performed in a classroom environment at the St. Lucie nuclear training facility. b. Findings No findings of significance were identified. 4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification Initiating Events and Mitigating Systems Cornerstones a. Inspection Scope The inspectors checked licensee submittals for the performance indicators (PIs) listed below for the period October 2008 through September 2009, to verify the accuracy of the PI data reported during that period. Performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedures ADM-25.02, NRC Performance Indicators, and NAP-206, NRC Performance Indicators, were used to check the reporting for each data element. The inspectors checked operator logs, plant status reports, condition reports, system health reports, and PI data sheets to verify that the licensee had identified the required data, as applicable. The inspectors interviewed licensee personnel associated with performance indicator data collection, evaluation, and distribution. * Unit 1 Mitigating Systems Performance Indicators * Unit 2 Mitigating Systems Performance Indicators b. Findings No findings of significance were identified.

12 Enclosure 4OA2 Identification and Resolution of Problems .1 Daily Review a. Inspection Scope As required by Inspection Procedure 71152, Identification and Resolution of Problems, and to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a screening of items entered daily into the licensee's CAP. This review was accomplished by reviewing daily printed summaries of CRs and by reviewing the licensee's electronic CR database. Additionally, reactor coolant system unidentified leakage was checked on a daily basis to verify no substantive or unexplained changes. b. Findings No findings of significance were identified. .2 Annual Sample: 2B2 Reactor Coolant Pump High Vibrations a. Inspection Scope The inspectors selected CR 2009-22728, "2B2 RCP Motor Vibrations Trending Up Slowly," for a more in-depth review of the circumstances that led up to the condition and the corrective actions that followed. The inspectors reviewed the licensee's evaluation of the event and the associated corrective actions. The inspectors interviewed plant personnel and evaluated the licensee's administration of this selected condition report in accordance with their CAP as specified in licensee procedures PI-AA-204, "Condition Identification and Screening Process," and PI-AA-205, "Condition Evaluation and Corrective Actions." b. Findings and Observations Introduction: The inspectors identified a Green non-cited violation of Technical Specification (TS) 6.8.1.a and Regulatory Guide 1.33, for an inadequate safety-related maintenance procedure. Specifically, the inspectors identified that during reassembly of Reactor Coolant Pump (RCP) 2B2 in July 2009 mechanical maintenance procedure MMP-01.17, "Reactor Coolant Pump Model N-9000 Seal Removal and Installation", Revision 10, instructed the licensee to utilize a method of checking the RCP coupling alignment that was not in accordance with Byron Jackson Technical Manual 741-N-0001/4, Revision 23. The procedure instructed the maintenance workers to measure the shaft coupling flange face gap clearance rather than measuring the concentricity/runout of the coupling flanges as required in the Byron Jackson vendor technical manual.

13 Enclosure Description: On July 13, 2009, Unit 2 was shutdown to remove and replace the shaft seal on the 2B2 RCP due to a seal injection line nozzle weld failure. Replacement of the seal required disassembly and reassembly of the pump/motor coupling. Upon return of the 2B2 RCP to service after the shutdown, the pump vibration levels were higher than normal (reaching 25 mils). As a result, the licensee added a counterweight to the coupling in an attempt to reduce the vibration levels. Following the addition of the counterweight, the vibration level on the pump was reduced while the vibrations on the motor increased as expected. The pump and motor vibration levels were within allowable limits and the licensee continued to monitor vibrations following the reactor startup on July 27, 2009. On September 7, 2009, the vibration level on the 2B2 RCP motor reached an alarm set point of 15 mils. On September 10, 2009, the unit was shutdown to troubleshoot and repair the 2B2 RCP vibrations. During the week of September 10, 2009, the inspectors began to review Work Order (WO) 39016719, Task 03, 2B2 RCP Coupling Work, which was performed in July 2009 following the shaft seal replacement. The inspectors determined that the RCP coupling alignment section 6.11 of safety-related maintenance procedure MMP-01.17, "RCP Model N-9000 Seal Removal and Installation," was not performed in its entirety. The inspectors determined that concentricity coupling alignment checks described in sections 6.11.8 through 6.11.11 were not performed, and instead the licensee used a feeler gage method described in procedure section 6.11.8 to measure coupling face gaps. The inspectors also reviewed the associated Byron Jackson Technical Manual 741-N-0001/4, Revision 23, and noted that there were no instructions or guidance for using a feeler gage methodology to ensure proper RCP coupling alignment during reassembly. The procedure allowance for the maintenance technicians to measure the shaft coupling flange face gap clearance rather than measuring the concentricity/runout of the coupling flanges was in contrast to the subject vendor technical manual. The inspectors concluded that had the vendor manual action to perform a coupling concentricity/runout check been required instead of the feeler gauge methodology, the high vibrations experienced on the 2B2 RCP would have been prevented and a unit shutdown would not have been necessary to effect repairs. The licensee performed a root cause evaluation for the 2B2 RCP high vibrations and concluded that the cause for the high RCP motor vibration was that the procedure for RCP assembly did not require the coupling runout always be measured upon assembly which agreed with the inspectors findings. A contributing cause was the addition of a counterweight to the coupling to compensate for the runout. Corrective actions to prevent recurrence include a revision to the RCP maintenance procedure to require the measurement of coupling runout whenever the coupling is disassembled. Analysis: The inspectors determined that maintenance procedure MMP-01.17, "Reactor Coolant Pump Model N-9000 Seal Removal and Installation," Revision 10, failed to require Byron Jackson Technical Manual 741-N-0001/4, Revision 23, instructions to perform a RCP coupling concentricity/runout check and was considered a performance deficiency. This finding is more than minor because it is associated with procedure quality attribute and affected the objective of the Reactor Safety/Initiating Event Cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the subject RCP maintenance procedure did not require the measurement of coupling run-

14 Enclosure out whenever the coupling is disassembled in accordance with the vendor technical manual requirements which resulted in an unplanned plant shutdown. Using Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheet, this finding was determined to be of very low safety significance since it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available in the Initiating Events Cornerstone. The inspectors determined that the cause of this finding has a crosscutting aspect in the area of human performance associated with the resources attribute, in that the safety-related maintenance procedure instructions were not complete or accurate to ensure proper RCP coupling alignment. (IMC 0305 aspect H.2.c). Enforcement: TS 6.8.1.a requires that written procedures shall be established, implemented, and maintained, covering the activities specified in Regulatory Guide 1.33, Revision 2, February 1978. Contrary to this requirement, the licensee failed to ensure Byron Jackson Technical Manual 741-N-0001/4, Revision 23, coupling alignment requirements were incorporated into safety-related maintenance procedure MMP-01.17,

"Reactor Coolant Pump Model N-9000 Seal Removal and Installation," Revision 10. This failure caused high vibrations on the 2B RCP which resulted in a Unit 2 shutdown on September 10, 2009. Since the licensee entered the issue into their CAP as condition reports 2009-28512 and 2009-22728 and the finding is of very low safety significance (Green), this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000338/2009005-01: Inadequate Reactor Coolant Pump Maintenance Procedure. .3 Semi-Annual Trend Review: Failure of 1A Charging Pump to Start a. Inspection Scope As required by Inspection Procedure 71152, Identification and Resolution of Problems, the inspectors reviewed the licensee's CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors selected charging pump failures for trending due to a couple of recent failures associated with the starting of the 1A charging pump. The inspectors' review was focused on repetitive equipment issues, but also considered the results of daily inspector CR item screening discussed in Section 4OA2.1 above, plant status reviews, plant tours, document reviews, and licensee trending efforts. The inspectors' review nominally considered the six month period of April through September 2009. Corrective actions associated with a sample of the issues identified in the licensee's CAP were reviewed for adequacy. b. Findings and Observations No findings of significance were identified.

15 Enclosure O4A3 Event Follow-up .1 Unit 1 Downpower Due to a Dropped Control Element Assembly (CEA)

a. Inspection Scope On December 16, 2009, the inspectors observed licensee activities following an unexpected dropped CEA during periodic rod testing. While performing quarterly rod testing per operations surveillance procedure 1-OSP-66.01, Full Length CEA Test, CEA 18 dropped to the bottom of the core while attempting to insert the rod for testing. The inspector observed control room response to the dropped rod and entry into off-normal procedure 1-0110030, CEA Off-Normal Procedure. The control rod could not be restored to its program position within 60 minutes and required a reactor plant downpower to less than 70 percent power. The inspectors reviewed operator actions taken in accordance with applicable procedures and reactor plant system response to the downpower. The inspectors observed troubleshooting of the dropped rod condition and the discovery of a loose fuse block neutral terminal lug in the associated rod control cabinet, followed by recovery of the subject control rod and its return to its normal position. The licensee entered this event in their corrective action program as condition report 2009-35048.

b. Findings No findings of significance were identified. 4OA5 Other Activities Quarterly Resident Inspector Observations of Security Personnel and Activities a. Inspection Scope During the inspection period the inspectors conducted observations of security force personnel activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours. These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities. b. Findings No findings of significance were identified.

16 Enclosure 4OA6 Meetings Exit Meeting Summary Resident Inspection The resident inspectors presented the inspection results to Mr. Hicks and other members of licensee management on January 7, 2010. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary information. The licensee did not identify any proprietary information. ATTACHMENT: SUPPPLEMENTAL INFORMATION Attachment KEY POINTS OF CONTACT Licensee personnel: C. Ali, Licensing Engineer R. Anderson, Site Vice President E. Belizar, Projects Manager D. Calabrese, Emergency Preparedness Manager D. Cecchett, Licensing Engineer J. Connor, Engineering Manager - Programs T. Cosgrove, Site Engineering Director B. Hughes, Plant General Manager A. Day, Chemistry Manager M. Delowery, Maintenance Manager S. Duston, Training Manager K. Frehafer, Licensing Engineer D. Hanley, Maintenance Programs Supervisor J. Heinold, Chemistry Technical Supervisor M. Hicks, Operations Manager D. Huey, Work Control Manager J. Klauck, Assistant Operations Manger J. Kramer, Site Safety Manager R. McDaniel, Fire Protection Supervisor M. Moore, Radiation Protection Manager P. Paradis, Fix-It-Now Team Supervisor T. Patterson, Performance Improvement Department Manager J. Porter, Design Engineering Manager M. Snyder, Site Quality Assurance Manager G. Swider, Systems and Component Engineering Manager T. Young, Security Manager NRC personnel: M. Sykes, Chief, Branch 3, Division of Reactor Projects S. Ninh, Senior Project Engineer, Division of Reactor Projects W. Rogers, Senior Risk Analyst, Division of Reactor Safety LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened and Closed 05000389/2009005-01 NCV Inadequate Safety-Related Maintenance Procedure to Properly Align the 2B2 Reactor Coolant Pump/Motor Shaft Coupling Assemblies (4OA2.2) Closed None Discussed None Attachment LIST OF DOCUMENTS REVIEWED Nuclear Policy Procedure NP-910, Plant Readiness for Operations St. Lucie Nuclear Oversight Report PSL-09-064, Fire Protection Audit St. Lucie Daily Quality Summaries Health Physics Procedure HPP-4, Scheduling of Health Physics Activities Operations Department Policy OPS-119, Standing Orders/Night Orders St. Lucie Radiation Protection Department Night Order, 2009-023 Condition Reports 2009-35506 2009-35495 2009-35442 2009-35417 2009-35273 2009-35254 2009-35054 2009-35048 2009-35037 2009-35005 2009-34995 2009-35839 2009-35853 2009-34986 2009-34977 2009-34868 2009-34818 2009-34726 2009-34698 2009-34694 2009-34642 2009-34515 2009-34488 2009-34361 2009-34350 2009-35863 2009-34268 2009-34237 2009-33288 2009-33262 2009-33233 2009-33163 2009-33107 2009-33013 2009-31354 2009-31217 2009-32932 2009-32784 2009-32727 2009-32630 2009-32609 2009-32600 2009-32574 2009-32430 2009-32355 2009-32347 2009-32178 2009-31630 2009-31418 2009-30759 2009-30543 2009-30080 2009-30060 2009-29995 2009-29875 2009-29847 2009-29790 2009-29332 2009-29096 2009-29090 2009-29048 2009-28512 2009-28233 Section 1R11: Licensed Operator Requalification Records: License Reactivation Packages (9). Medical Files (20). Remedial Training Records (7).

Watchstanding Records (9). Training Feedback Summaries Written Examinations: LOCT Biennial Written Exam, 0820085C-R, 09/18/2008.

LOCT Biennial Written Exam, 0820085F-R, 09/16/2008. Procedures: Administrative Procedure - ADM-18.05, Implementation of the Systematic Approach to Training, Revision 9, Effective Date 03/16/09. Administrative Procedure - 0005720, Licensed Operator Continuing Training Program, Revision 61, Effective Date 10/06/09.

Nuclear Administrative Procedure - NAP-408, Licensed Maintenance and Activation Program, Revision 9, Effective Date 09/24/2009.

3 Attachment Training Guideline - TG-004, Written Examination Development, Administration and Control, Revision 23, Effective Date 10/05/2009. Training Guideline - TG-004, Written Examination Development, Administration and Control, Revision 24, Effective Date November 2009.

Training Guideline - TG-007, Systematic Evaluation of Training Effectiveness, Revision 17, Effective Date 07/07/09. Training Guideline - TG-022, Security Provisions for Licensed Operator Examinations, Revision 17, Effective Date 12/29/08. Training Guideline - TG-023, Simulator Scenario Based Testing, Revision 6, Effective Date 10/05/09. Training Guideline - TG-024, Conduct of Simulator Training, Revision 10, Effective Date 12/29/08. Quality Instruction Procedure - QI-3-PR/PSL-3, Simulator Design Management Configuration Control and Operation, Revision 10A, Effective Date 08/04/08. Simulator Engineering Instruction - SEI-04, Simulator Discrepancy Report, Revision 4, Effective Date 05/07/08.

Simulator Engineering Instruction - SEI-09, Simulator Configuration Control, Revision 5, Effective Date 05/07/08. Simulator Malfunction Tests: MAL-007, Rupture of the Instrument Air Header, Revision 0, Effective Date 03/22/90.

MAL-008, Loss of Instrument Air Compressors, Revision 0, Effective Date 05/23/90. Simulator Transient Tests: 2008 run of TRN-001, Reactor Trip, Revision 9, Effective Date 07/09/07. 2009 run of TRN-001, Reactor Trip, Revision 9, Effective Date 07/09/07.

2008 run of TRN-002, Loss of Main Feedwater Pumps From 100% Power with Failure of all Emergency Feedwater, Revision 9, Effective Date 07/09/07. 2009 run of TRN-002, Loss of Main Feedwater Pumps From 100% Power with Failure of all Emergency Feedwater, Revision 9, Effective Date 07/09/07.

Simulator Scenario Based Tests: Scenario Based Testing/Validation Records for LOCT Annual Exam Simulator Scenario, 0815027, Revision 11. Scenario Based Testing/Validation Records for LOCT Annual Exam Simulator Scenario, 0815010, Revision 17.

Simulator Deficiency Reports & Simulator Work Orders: Reviewed paper documentation of approximately two years of simulator deficiency reports/work orders. Simulator Scenarios Reviewed: LOCT Annual Exam Simulator Scenario, 0815027, Revision 11, 10/21/09.

LOCT Annual Exam Simulator Scenario, 0815010, Revision 17, 10/29/09. LOCT Annual Exam Simulator Scenario, 0815028, Revision 10. LOCT Annual Exam Simulator Scenario, 0815009, Revision 16B, 10/06/09. LOCT Annual Exam Simulator Scenario, 0815016, Revision 14. LOCT Annual Exam Simulator Scenario, 0815018, Revision 15A, 10/06/09.

4 Attachment LOCT Annual Exam Simulator Scenario, 0815020, Revision 18. LOCT Annual Exam Simulator Scenario, 0815024, Revision 13. Job Performance Measures Reviewed: Job Performance Measure, PSL OPS 0821010A, Verify RAS - Unit 2, Revision 17, 10/02/09. Job Performance Measure, PSL OPS 0821118, Restore Power to 2B3 4.16KV Bus from Offsite - Unit 2, Revision 13, 10/07/09. Job Performance Measure, PSL OPS 0821013A, Verify CSAS- Unit 1, Revision 10, 06/17/09. Job Performance Measure, PSL OPS 0821042, Transfer Letdown Pressure Control to the Alternative PCV - Unit 1, Revision 14, 09/30/09. Job Performance Measure, PSL OPS 0821072, Start 2B EDG Locally During SBO - Unit 2, Revision 12, 07/07/05. Job Performance Measure, PSL OPS 0821025A, Align ECCS for Hot and Cold Leg Injection - Unit 1, Revision 10, 08/20/09. Job Performance Measure, PSL OPS 0821046, Respond to Loss of 1A CCW Heat Exchanger - Unit 1, Revision 15, 09/30/09.

Job Performance Measure, PSL OPS 0821114, Restoration of Electrical Equipment Room Ventilation - Unit 1, Revision 15, 10/08/09. Condition Reports: Condition Report, 2009-32667, Simulator DCS Malfunction During Annual Operating Exam Administration, Origination Date 11/16/2009. Condition Report, 2009-27153, LOR Pre-Inspection Recommendations, Origination Date 09/24/2009. LIST OF ACRONYMS CAP Corrective Action Program CCW Component Cooling Water CFR Code of Federal Regulations CR Condition Report ECCS Emergency Core Cooling System IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission UFSAR Updated Final Safety Analysis Report WO Work Order CRDM Control Rod Drive Mechanism TS Technical Specifications IST Inservice Testing NAP Nuclear Administrative Procedure