IR 05000335/2021001

Integrated Inspection Report 05000335/2021001 and 05000389/2021001

ML21132A185
Person / Time
Site:	Saint Lucie
Issue date:	05/12/2021
From:	David Dumbacher NRC/RGN-II/DRP/RPB3
To:	Moul D Florida Power & Light Co
References
IR 2021001
Download: ML21132A185 (13)

Text

May 12, 2021

SUBJECT:

ST. LUCIE UNITS 1 & 2 - INTEGRATED INSPECTION REPORT 05000335/2021001 AND 05000389/2021001

Dear Mr. Moul:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at St. Lucie Units 1 & 2. On April 5, 2021, the NRC inspectors discussed the results of this inspection with Mr. Dan DeBoer and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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: 05000335/2021001 and 05000389/2021001 Enterprise Identifier: I-2021-001-0079 Licensee: Florida Power & Light Company Facility: St. Lucie Units 1 & 2 Location: Jensen Beach, FL 34957 Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: C. Fontana, Emergency Preparedness Inspector T. Morrissey, Senior Construction Inspector S. Roberts, Senior Resident Inspector S. Sanchez, Senior Emergency Preparedness Insp S. Sandal, Senior Reactor Analyst J. Walker, Emergency Response Inspector Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

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

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.

Unit 2 began the inspection period at RTP. On January 14, 2021, the unit power was lowered to approximately 10 percent and the turbine generator was taken offline to support the planned removal from service of the 2B2 4160V bus auxiliary transformer feeder breaker that had indications of low SF6 gas pressure. The 2B2 4160V bus was placed on the 2B startup transformer, the turbine generator was placed back online, and the unit was restored to RTP on January 15, 2021. On January 20, 2021, the turbine and reactor automatically tripped from RTP and was stabilized in Mode 3. The turbine trip was due to the loss of power to relays that monitor control rod drive bus voltage when a motor control center (MCC) feeder breaker opened. The licensee identified and corrected a single point vulnerability associated with a loss of one of two power supplies for relays that provide a turbine trip signal if the control rod drive bus loses voltage. The licensee replaced the MCC feeder breaker and the unit was restarted on January 22, 2021 and was restored to RTP on January 24, 2021. On January 28, 2021, the 2B2 4160V bus feeder breaker from the 2B auxiliary transformer was placed back in service with a refurbished breaker. The unit remained at or near RTP for the remainder of the inspection period.

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending adverse cold weather near 40 degrees Fahrenheit, on February 2-3, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (5 Samples)

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

(1) Unit 2, 2A emergency diesel generator (EDG) and 2A startup transformer, while the 2B startup transformer auto swap feature was out of service (OOS) for maintenance, on January 11, 2021

(2) Unit 1, A intake cooling water (ICW) train, while the B ICW train was OOS for maintenance, on January 12, 2021

(3) Unit 2, 2A and 2B charging pumps, while 2B charging pump was OOS for maintenance, on January 20, 2021

(4) Unit 2, 2B EDG train and associated 4160 V bus (2B3), while the 2A EDG was OOS for maintenance, on February 16-18, 2021

(5) Unit 1, 1A component cooling water (CCW) train, while the 1B CCW train was OOS for maintenance, on March 16, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 1, auxiliary feed water (AFW) pump area, on January 23, 2021

(2) Unit 2, 2B EDG room, on February 18, 2021

(3) Unit 1, control element assembly motor-generator area, reactor auxiliary building (RAB), on February 8, 2021

(4) Unit 2, AFW pump area, on March 19, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during two separate unannounced fire drills on February 5, 2021 and February 25, 2021. The inspectors also evaluated the licensee's self-contained breathing apparatus (SCBA)program including storage, training, expectations for use, and maintenance.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, 1A high pressure safety injection (HPSI) pump, 1A low pressure safety injection (LPSI) pump, and 1A containment spray (CS) pump, flood area, on January 28, 2021

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Unit 2, Manholes 299N and 299R containing safety-related cables associated with the AFW system, on March 1, 2021

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) The inspectors evaluated readiness and performance of the 1B CCW heat exchanger (HX) by verifying that periodic maintenance conducted was in accordance with the Electric Power Research Institute (EPRI) HX monitoring guideline, NP-7552, on March 19, 2021

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room when reactor power was lowered to approximately 10 percent RTP in order to remove the main generator from service to support removal of a breaker from service. The inspectors also monitored activities associated with returning the main generator to service, on January 14, 2021.

(2) The inspectors observed and evaluated licensed operator performance in the Unit 2 control room during a reactor startup from a forced outage and power ascension to 100 percent RTP on January 22-23, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) On January 25, 2021, the inspectors observed a licensed operator requalification training evaluation on the control room simulator. The simulated scenario included a loss of the RAB main supply fan, 2A feedwater leak, reactor trip, loss of offsite power (LOOP), loss of the 2A EDG, 2B HPSI valves failing, and steam generator water level in both steam generators less than fifteen percent, requiring once through cooling to be implemented. The LOOP resulted in a notice of unusual event (NOUE)classification and the once through cooling resulted in a site area emergency (SAE)which required a simulated notification to the State of Florida and the NRC.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Action Request (AR) 2376401, Unit 2, 2C charging pump discharge check valve failed open, on February 10, 2021

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) AR 2384001, Unit 2, 2A EDG delta current trip, on March 8, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2, elevated risk with the 2A EDG OOS for planned surveillance; 2-HCV-3625, 2A low pressure safety injection valve, and MV-08-19, 2A steam generator atmospheric dump valve, both OOS for planned maintenance, on January 4, 2021

(2) Unit 2, elevated risk with the 2B startup transformer OOS and planned down power to 10 percent RTP, from January 8-14, 2021

(3) Unit 1, elevated risk while ICW 1B and 1C trains were OOS for planned maintenance, from January 11-12, 2021

(4) Unit 2, elevated risk with the 2A EDG OOS due to emergent maintenance, from February 12-18, 2021

(5) Unit 1, elevated risk during the planned 1B CCW heat exchanger outage, from March 15-17, 2021

(6) Unit 2, elevated risk during the planned 2B EDG outage, from March 21-23, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2, AR 2378281, gas void volume exceeded the acceptance criteria found in 2B LPSI discharge piping, on January 20, 2021

(2) Unit 1, AR 2381764, 1B 125V DC bus ground, on January 28, 2021

(3) Unit 2, AR 2381091, unexpected trip of control room air conditioners HVA-3B and HVA/ACC-3C, on February 1, 2021

(4) Unit 2, AR 2382619, safety injection miniflow valve V3495 stroke time outside allowable stroke time limits, on February 3, 2021

(5) Unit 2, AR 2386766, 2A CCW pump seal leakage, on March 23, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC) 295797 Unit 2 control element drive mechanism control system (CEDMCS) revise power source to undervoltage (UV) relays

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Unit 2, work order (WO) 40760354, 2B charging pump failed to start; troubleshoot/repair, on January 28, 2021

(2) Unit 1, WO 40533869, U1 intake cooling water (AL6XN) piping replacement, on February 16, 2021

(3) Unit 1, WO 40762211, Repair B intake cooling water system debris filter discharge valve HCV-21-7B, on February 17, 2021

(4) Unit 2, WO 40764368, U2 2A EDG delta current trip, on March 1, 2021

(5) Unit 2, WO 40724036, 2B EDG 18-month inspection preventative maintenance, on March 23, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1, 1-OSP-69.14B, ESF - 18 Month Surveillance for EDG Start on SIAS Without LOOP and 24-Hour Load Run - Train B, on January 20, 2021

Inservice Testing (IP Section 03.01) (3 Samples)

(1) Unit 2, 2-OSP-99.08A, "A Train Quarterly Non Check Valve Cycle Test," (valves V3659, V3495, MV-07-1A, and MV-07-2A) on February 1, 2021

(2) Unit 2, 2-OSP-03.06A, "2A Low Pressure Safety Injection Code Run," on February 1, 2021

(3) 0-OSP-37.01, "Emergency Cooling Water Canal - Periodic Test," (performed by Unit 2) on February 24, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) 0-OSP-83.04A(B)(C), "Periodic Testing of the FLEX480V DG A" (B) and (C), on January 6, 2021

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of January 11, 2021.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of January 11, 2021.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of January 11, 2021. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of January 11, 2021.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) On January 25, 2021, the inspectors observed a licensed operator requalification training evaluation on the control room simulator.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

EP01: Drill/Exercise Performance (IP Section 03.12) ===

(1) Unit 1, October 1, 2019, through September 30, 2020 Unit 2, October 1, 2019, through September 30, 2020

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) (2 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

EP02: ERO Drill Participation (IP Section 03.13) (1 Sample)

(1) Unit 1, October 1, 2019, through September 30, 2020 Unit 2, October 1, 2019, through September 30, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (2 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

EP03: Alert & Notification System Reliability (IP Section 03.14) (1 Sample)

(1) Unit 1, October 1, 2019, through September 30, 2020 Unit 2, October 1, 2019, through September 30, 2020

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (2 Samples)

(1) Unit 1, January 1, 2020 through December 31, 2020

(2) Unit 2, January 1, 2020 through December 31, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) AR 2384001, Unit 2, 2A emergency diesel generator delta current trip, on March 24, 2021

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) On January 20, 2021, Unit 2 automatically tripped from RTP when the turbine generator received a trip signal when power was lost to two relays that monitor CEDM system bus voltage. The 2B1 Load Center breaker (Masterpact breaker) 2-40401 was found tripped. Breaker 2-40401 provides power to the 2B2 motor control center (MCC) which in turn provides one of the two sources of power to the undervoltage relays monitoring the CEDM power bus voltages. The breaker was replaced, and the licensee implemented corrective actions to eliminate this single point vulnerability associated with a loss of one source of power to the undervoltage relays. The inspectors reviewed operator performance in response to the trip, operator logs, computer and recorder data, and the post trip report to verify plant equipment and operations personnel responded appropriately. The inspectors provided details regarding operator and equipment performance to NRC management. The inspectors verified the cause of the trip was appropriately resolved prior to unit restart. The unit was restarted on January 22, 2021, and was returned to RTP on January 24,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/194 - Inspection of the Licensees Implementation of Industry Initiative Associated With the Open Phase Condition Design Vulnerabilities In Electric Power Systems (NRC Bulletin 2012-01)

Revision 0 of this Temporary Instruction (TI) was previously inspected, and closed, in Inspection Report 2018002 (ADAMS ML18208A328). However, a subsequent revision to the NEI Voluntary Initiative (Revision 3) provided plants the option of to leave the open phase protection (OPP)system in monitoring mode only in lieu of activating the automatic trip circuitry, provided it was supported by a risk evaluation. Revision 1 (and later Revision 2) of this TI was issued to provide inspection guidance for the new option.

The inspectors reviewed licensee analyses and procedures that demonstrated operator manual actions would successfully mitigate the impact of an Open Phase Condition (OPC). The analyses were reviewed remotely, and the procedures were reviewed and walked down on site. The inspectors completed Section 03.01c of TI 2515/194, Revision 2.

The inspectors verified that modeling used for the OPC reflected the as-designed and as-built plant, assumptions made by the licensee were reasonable, and licensee procedures were adequate to successfully respond to an OPC. The inspectors also verified that human reliability analysis and recovery evaluations were done in accordance with NEI and voluntary initiative guidance.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On April 5, 2021, the inspectors presented the integrated inspection results to Mr. Dan DeBoer and other members of the licensee staff.

• On January 15, 2021, the inspectors presented the Emergency Preparedness Program inspection results to Mr. Dan DeBoer and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed the World Association of Nuclear Operators (WANO) report for the assessment completed in November 2020.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/194 Calculations PSL-BFJR-20- St. Lucie Units 1 and 2 Open Phase Condition Evaluation Revision 1

003

Procedures 1-AOP-53.04 START-UP TRANSFORMER Revision 9

1-ARP-01-A00 CONTROL ROOM PANEL A RTGB-101 Revision 30

1-ARP-01-B00 CONTROL ROOM PANEL B RTGB-101 Revision 37

2-AOP-53.04 START-UP TRANSFORMER Revision 10

2-ARP-01-A00 CONTROL ROOM PANEL A RTGB-201 Revision 31

2-ARP-01-B00 CONTROL ROOM PANEL B RTGB-201 Revision 36

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