IR 05000335/2024011

From kanterella
Revision as of 22:59, 3 October 2024 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Biennial Problem Identification and Resolution Inspection Report 05000335/2024011 and 05000389/2024011
ML24262A044
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 09/18/2024
From: Renee Taylor
NRC/RGN-II/DRP/RPB3
To: Coffey B
Florida Power & Light Co
References
IR 2024011
Download: ML24262A044 (18)
v • d • e


Text

SUBJECT:

SAINT LUCIE UNITS 1 & 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000335/2024011 AND 05000389/2024011

Dear Bob Coffey:

On June 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution (PI&R) inspection at Saint Lucie Units 1 & 2. On June 28, 2024, and August 8, 2024, the NRC inspectors discussed the results of this inspection with Mr. Thad Edmonds, Operations Director, Mr. Tim Falkiewicz, Regulatory Affairs Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations PI&R program to confirm that the station was complying with NRC regulations and licensee standards. The team evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed the stations audits and self-assessments, and its use of industry and NRC operating experience information. Based on the samples reviewed, the team determined that the stations program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.

Additionally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment (SCWE) and interviewed station personnel to evaluate the effectiveness of these programs. The team reviewed corrective actions in progress to address SCWE challenges that the station identified prior to our onsite PI&R inspection. Based on the teams observations and the results of these interviews, the team found some challenges to the stations SCWE and concluded that a chilled work environment exists within the Saint Lucie Operations Department. The majority of Operations personnel interviewed expressed that they do not feel free to raise nuclear safety concerns using all available avenues without fear of retaliation. NRC shared this information with you and your senior staff.

The NRC defines SCWE as a work environment in which employees are encouraged to raise nuclear safety concerns, are free to raise concerns to both their management and the NRC without fear of retaliation, where concerns are promptly reviewed, given the appropriate priority, and appropriately resolved, and where timely feedback is provided to those raising concerns. To the contrary, a chilled work environment is defined as an environment where raising nuclear safety concerns to the employer or to the NRC is being suppressed or is discouraged and September 18, 2024 where employees fear retaliation for raising concerns and it is not isolated (e.g., multiple individuals, functional groups, shift crews, or levels of workers within the organization are affected).

Whenever NRC staff identifies a chilled work environment, we evaluate the appropriate enforcement actions available, including the use of a chilling effect letter (CEL) as discussed in the NRC Enforcement Manual (ADAMS Accession No. ML23360A760) and NRC Allegation Manual (ADAMS Accession No. ML17003A227). This guidance ensures that our staff considers the many factors contributing to a licensees environment for raising nuclear safety concerns when evaluating enforcement action. Specifically, when a licensee recognizes that an environment is chilled and applies corrective actions, NRC guidance advises NRC staff not to intervene, but rather to allow a licensees actions time to take effect. Historically, the NRC has observed faster resolution to chilled work environments when a licensee takes ownership of the situation, with NRC providing independent oversight.

The NRC is aware that the site has corrective actions in progress to address the SCWE challenges that they identified prior to the onsite PI&R inspection. Furthermore, the site has created an action to ensure that the SCWE challenges identified by the PI&R inspection team are addressed. Because of the recency of these actions, we have determined that it is premature to assess the effectiveness of the sites corrective actions. The NRC has determined that it is appropriate to perform Inspection Procedure 93100, "Safety-Conscious Work Environment Issue of Concern Follow-up," at a future date to evaluate the effectiveness of the sites proposed corrective actions. In the meantime, our onsite resident inspectors, sensitive to SCWE concerns, will continue to independently monitor and provide insight to NRC management regarding SCWE trends at Saint Lucie that could prompt additional NRC actions such as the use of a CEL.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Saint Lucie Units 1 & 2.

If you disagree with a 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 Saint Lucie Units 1 & 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Ryan C. Taylor, 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: 05000335/2024011 and 05000389/2024011

Enterprise Identifier: I-2024-011-0033

Licensee: Florida Power & Light Company

Facility: Saint Lucie Units 1 & 2

Location: Jensen Beach, FL

Inspection Dates: June 10, 2024 to June 28, 2024

Inspectors: S. Bruneau, Resident Inspector N. Childs, Senior Project Engineer (Team Lead)

R. Mathis, Senior Construction Inspector J. Nadel, Reactor Inspector (Safety Culture Assessor)

J.R. Reyes, Project Engineer M. Riley, Senior Project Engineer

Approved By: Ryan C. Taylor, 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 a biennial problem identification and resolution (PI&R) inspection at Saint 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

Failure to Perform Engineering Evaluations on Ladders Located Near Safety-Related Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152B Systems NCV 05000335,05000389/2024011-01 Resolution Open/Closed The NRC identified a Green finding and associated non-cited violation (NCV) of Technical Specifications (TS) 6.8.1, "Procedures and Programs," when the licensee failed to complete engineering evaluations in accordance with site procedures MA-AA-100-1008, "Station Housekeeping and Material Control," and QI-13-PSL-2, "Housekeeping and Cleanliness Control Methods St. Lucie Plant," for ladders that were touching or installed near safety-related equipment to ensure there would be no adverse impact during a design-basis seismic event that would render the equipment inoperable.

Failure to Demonstrate Maintenance Rule (a)(2) Performance of the Unit 1 ECCS Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.2] - 71152B NCV 05000335/2024011-02 Evaluation Open/Closed The NRC identified a Green finding and associated NCV of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear plants," paragraph (a)(2) when the licensee failed to demonstrate that the performance of the Unit 1 emergency core cooling system (ECCS) ventilation system was being effectively controlled through the performance of appropriate preventive maintenance.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000335,05000389/20 Operating Experience 71152B Open 24011-03 Review of Action Request (AR) 02439818

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)

Main article: IP 71152
(1) The inspectors performed a biennial assessment of the effectiveness of the licensees PI&R program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
  • Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
  • Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
  • Safety-Conscious Work Environment (SCWE): The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B

1) Problem Identification and Resolution Effectiveness

Problem Identification: The team determined that the licensee was effective in identifying problems and entering them into the CAP at the appropriate threshold. This conclusion was based on a review of the requirements for initiating condition reports (CRs) as described in licensee procedure PI-AA-104-1000, Condition Reporting. Additionally, site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Problem Prioritization and Evaluation: Based on the review of condition reports and work orders, the inspectors concluded that problems were generally prioritized and evaluated in accordance with licensee guidance. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the licensees CAP procedures, and cause determinations were appropriate and considered the significance of the issues being evaluated. However, in the area of problem evaluation, the inspectors documented two NCVs of very low safety significance (Green) in the Results section of this report regarding the following:

(1) failure to evaluate the emergency core cooling (ECCS) ventilation system for maintenance rule (a)(1); and
(2) failure to evaluate temporarily installed ladders near safety-related equipment. The licensee initiated CR 02489624 and CR 02489625 to address these issues.

Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that, generally, corrective actions were effective, timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected.

The team determined that the licensee was generally effective in developing corrective actions that were appropriately focused.

Based on the samples reviewed, the team determined that the licensees CAP complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.

2) Use of Operating Experience

The team determined that the stations processes for the use of industry and NRC operating experience information were generally effective and complied with regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The team concluded that, in general, operating experience was adequately evaluated for applicability and that appropriate actions were implemented in accordance with applicable procedures. However, the inspectors documented an unresolved item (URI) in the Results section of this report regarding the review of operating experience detailing single point vulnerabilities in ESFAS components. The licensee initiated CR 02489622 to address the issue.

3) Self-Assessments and Audits

The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluate those issues, and resolve them commensurate with their safety significance. The self-assessments and audits were adequately self-critical and performance-related issues were being appropriately identified.

The inspectors verified that action requests were created to document areas for improvement and findings and verified that actions had been completed consistent with those recommendations.

4) Safety-Conscious Work Environment

The team interviewed approximately twelve individuals from the Engineering, Maintenance, Chemistry, and Radiation Protection departments. Based on interview responses, the team determined that most staff from these departments were willing to raise nuclear safety concerns to management without fear of retaliation. However, the team noted that most of those interviewed were hesitant to utilize the employee concerns program (ECP) as an avenue to raise nuclear safety concerns. The team also determined that most were not sure of how to submit an anonymous nuclear safety concern. Furthermore, those who did know how to submit a nuclear safety concern anonymously were hesitant to use the system due to a perceived lack of anonymity.

Additionally, an NRC-qualified safety culture assessor led a focused assessment of SCWE within the Operations organization. This focused assessment was initiated in part, due to an increased number of anonymous action request (AR) submissions regarding the environment for raising concerns within the Operations organization. The team interviewed approximately seventy-five individuals within the Operations organization across eighteen group and individual interviews.

The majority of Operations staff interviewed stated that they would raise nuclear safety concerns to direct supervision. However, the majority expressed reluctance to raise nuclear safety concerns to management above the senior license holder due to fear of retaliation and the belief that the concerns would not be acted upon or effectively resolved if they were not in alignment with production goals. Some Operations staff interviewed stated they were aware of incidents in which senior managements reactions to individuals raising nuclear safety concerns could be perceived as retaliation. These incidents occurred during recent refueling and forced outages and were perceived as site and fleet managers attempting to exert undue control or influence over NRC-licensed plant operators with the singular focus of furthering production goals. These incidents were widely known due to their documentation in anonymous ARs. As a result, the team determined that these senior management behaviors had created a chilled work environment within the Operations organization since the majority of operators would not use this pathway to raise nuclear safety concerns.

In addition, the team determined that the willingness of Operations staff to report nuclear safety concerns to the ECP was impacted. In interviews, the team learned that most operators had lost trust in the ECP because they did not believe that their identity would be kept confidential, nor did they believe the ECP would effectively resolve their concerns. Many of those interviewed were aware of a loss of confidentiality associated with a previous anonymous AR in which the identity of the anonymous individual was revealed.

Some interviewees had used the ECP and had a negative experience, which resulted in them no longer trusting the program.

The team noted that the anonymous ARs reviewed were being written outside the normal process for submitting anonymous concerns. Operations staff did not view the proceduralized anonymous concern submission process via the third-party software EthicsPoint, as an effective way to have their concerns heard and resolved. The staff did not trust the anonymity of EthicsPoint because one has to be logged into their work account to access the EthicsPoint link or use a personal device where they worry their IP address could be captured by the system. So, Operations staff developed a workaround where a union member would document an AR in the CAP on behalf of the individual who wished to be anonymous. This resulted in the anonymous AR being reviewed and visible to the entire site. In contrast, anonymous concerns submitted through the EthicsPoint software are forwarded by the third-party to site or fleet ECP personnel for disposition. Anonymous concerns submitted in this manner would only be documented in the CAP, and visible to the entire site, if they met the requirements for documentation as a condition adverse to quality.

The team reviewed the licensees internal assessments that were completed in May/June 2024 in preparation for the PI&R inspection and in response to the Operations work environment anonymous ARs. The inspectors noted that these assessments identified SCWE challenges within the Operations organization similar to those identified by the PI&R team.

The inspectors also reviewed the licensees two corrective action plans resulting from their assessments (CRs 02486822 and 02488583). The corrective action plans included actions to: implement a targeted improvement plan for Operations leadership to improve leadership skills; improve trust and respect between the Operations leadership team and staff; improve the operational decision-making process; and implement communications regarding the authority of the senior licensed individual onsite with respect to decision-making regarding plant operations. The team noted that the corrective action plans were still under development at the time of the onsite PI&R inspection. Following the PI&R exit meeting, the licensee initiated CR 02490514 to ensure that the Operations SCWE challenges identified by the PI&R team would be addressed.

Failure to Perform Engineering Evaluations on Ladders Located Near Safety-Related Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71152B Systems NCV 05000335,05000389/2024011-01 Resolution Open/Closed The NRC identified a Green finding and associated NCV of TS 6.8.1, "Procedures and Programs," when the licensee failed to complete engineering evaluations in accordance with site procedures MA-AA-100-1008, "Station Housekeeping and Material Control," and QI-13-PSL-2, "Housekeeping and Cleanliness Control Methods St. Lucie Plant," for ladders that were touching or installed near safety-related equipment to ensure there would be no adverse impact during a design-basis seismic event that would render the equipment inoperable.

Description:

NRC inspectors identified the following instances of ladders located near safety-related equipment for extended periods of time without engineering evaluations:

  • On February 5, 2024, the inspectors identified an extension ladder in the Unit 2 auxiliary feed pump room that was within reaching distance of the auxiliary feed pumps. The ladder was tied off at the top but not at the bottom. The licensee placed this issue into their CAP as AR 02478387.
  • On February 12, 2024, the inspectors identified an unrestrained rolling ladder in the Unit 2 cable spreading room near switchgear. This was entered into the licensee's CAP as AR 02479003.
  • On February 21, 2024, the inspectors identified a ladder in the Unit 1 emergency diesel fuel oil storage tank area. The ladder was cable locked to the hand wheel of valve V17209, which was an isolation valve for the diesel fuel-oil storage tank truck fill connection; however, it was not secured or restricted to prevent movement and interaction with nearby safety-related equipment. The licensee entered this issue into their CAP as AR 02479640.
  • On April 9, 2024, the inspectors identified a temporarily installed extension ladder in the Unit 1 emergency core cooling system room near the high head safety injection pumps. The licensee entered this issue into their CAP as AR 02485395.
  • On April 11, 2024, the inspectors identified five extension ladders leaning against safety-related piping in the Unit 2 component cooling water system room. The licensee entered this issue into their CAP as AR 02485395.

In all of the cases identified by the inspectors, the licensee identified that the ladders were being used on a temporary basis to complete surveillances or preventive maintenance activities and were not removed after the activities were completed. Most of the ladders had been installed in place for numerous years with no documentation describing controls for any of the ladders. Most of the ladders were tied off at the bottom and top but none had engineering evaluations to ensure there would not be any interaction with safety-related equipment during a design-basis seismic event, as required by procedures.

Procedure MA-AA-100-1008, Section 4.6, Item 1, requires that "The use, location and deployment of ladders, tools, drums, storage cabinets, office materials, temporary / portable equipment (such as wheeled tables, hand trucks, etc.) shall be controlled to the extent required to prevent conditions which may create a potential for adverse interaction with safety-related equipment and components during a design-basis seismic event." Item 2 requires that "When locating temporary items near safety-related equipment and components, the duration shall be kept to a minimum. Should there be a need to leave portable items in the power block other than those associated with a specific work task unmonitored for an indefinite period of time, an engineering evaluation of the item shall be requested. The evaluation shall address provisions for location, restraint, tagging, and document updates to show the item on applicable drawings, as required." Procedure QI-13-PSL-2, Section 5.16.3.B, requires that "When locating temporary items near safety-related equipment and components, the duration shall be kept to a minimum. Should there be a need to leave portable items in the 805 Power Block, other than those associated with a specific work task unmonitored for an indefinite period of time, an engineering evaluation of the item shall be requested. The evaluation shall address provisions for location, restraint, tagging, and document update to show the item on the applicable drawings, as required."

Corrective Actions: The licensee completed a plant sweep and subsequently removed all temporary ladders in the plant. The licensee completed engineering evaluations before reinstalling temporary ladders.

Corrective Action References: CR 02489625

Performance Assessment:

Performance Deficiency: The licensees failure to complete engineering evaluations on temporarily installed ladders located near safety-related structures, systems, and components, as required by procedures MA-AA-100-1008, "Station Housekeeping and Material Control," and QI-13-PSL-2, "Housekeeping and Cleanliness Control Methods," was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, not tracking, inspecting or completing engineering evaluations of temporarily installed ladders that are touching or placed near safety-related SSCs could allow ladders to interact with safety-related equipment resulting in equipment being rendered inoperable during a design-basis seismic event.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance (Green) because the finding did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time or two separate safety systems out-of-service for greater than their TS allowed outage time.

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Loss of control of ladders in the plant has been a programmatic long-term issue that continues to challenge the licensee, and previous corrective actions have not been effective as the issues continue to surface. The inspectors noted that there had been three NRC identified Green NCVs over the last 10 years relating to control of ladders:

(1) NCV 05000335,389/2012-005;
(2) NCV 05000335,389/2014-007; and
(3) NCV 05000335,389/2015-001.
Enforcement:

Violation: TS 6.8.1, "Procedures and Programs," requires, in part, that written procedures be implemented covering activities referenced in Regulatory Guide 1.33, Revision 2, dated February 1978, including safety-related activities carried out during operation of the reactor plant. Section 9.a, "Procedures for Performing Maintenance," states in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Section 4.6 of procedure MA-AA-100-1008 and section 5.16 of procedure QI-13-PSL-2 require, in part, that locating temporary items near safety-related equipment and components shall be kept to a minimum duration. Should there be a need to leave portable items in the power block other than those associated with a specific work task unmonitored for an indefinite period of time, an engineering evaluation of the item shall be requested. The evaluation shall address provisions for location, restraint, tagging, and document update to show the item on applicable drawings, as required.

Contrary to the above, from February 5, 2024, through April 11, 2024, NRC inspectors identified temporarily installed ladders that were not in compliance with MA-AA-100-1008 and QI-13-PSL-2. Specifically, engineering evaluations were not completed to ensure the ladders would not interact with safety-related equipment during a design-basis seismic event.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Demonstrate Maintenance Rule (a)(2) Performance of the Unit 1 ECCS Ventilation System Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [P.2] - 71152B NCV 05000335/2024011-02 Evaluation Open/Closed The NRC identified a Green finding and associated NCV of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear plants," paragraph (a)(2) when the licensee failed to demonstrate that the performance of the Unit 1 emergency core cooling system (ECCS) ventilation system was being effectively controlled through the performance of appropriate preventive maintenance.

Description:

On August 31, 2022, with Unit 1 in Mode 1 at 100% power, charcoal samples were taken for the ECCS ventilation system, HVE-9A and HVE-9B, in accordance with the ventilation filter testing program and TS 4.7.8.1.b. On September 3, 2022, laboratory test results determined that the charcoal adsorber ventilation filters failed to meet the required performance efficiency. Therefore, both trains of the Unit 1 ECCS ventilation system were considered inoperable on August 31, 2022, and resulted in a loss of the Unit 1 ECCS ventilation system function, which placed the unit in TS limiting condition for operation (LCO)3.0.3. TS LCO 3.0.3 entry would have required the unit to be in cold shutdown (Mode 4)within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />, however, the unit had already established Mode 4 in preparation for a refueling outage at the time the test results were obtained.

The ECCS ventilation system is scoped under the maintenance rule (MR) with a MR function to "provide air supply, ventilation and filtration to permit proper functioning of ECCS equipment and limit release of radioactivity during operation following a design-basis event." The MR evaluation for this issue, EVT-25-2022-45191, stated that the maintenance strategy for the charcoal adsorber units was run-to-failure and filters would only be replaced when sampling failed to meet acceptance criteria. Despite the MR system function being lost due to the run-to-failure maintenance strategy, the licensee concluded that the failure of each ventilation system train was not a maintenance preventable functional failure, no reliability criteria had been exceeded, and that the system could remain in MR (a)(2).

Corrective actions from the August 2022 event included changing the charcoal adsorber filters on both ECCS ventilation system trains prior to returning Unit 1 to service. Additionally, the licensee changed the maintenance strategy on replacement of the charcoal filter units by eliminating the run-to-failure strategy and implemented PMs to replace the filters periodically.

Despite these corrective actions, the inspectors determined that the licensee had not adequately addressed the MR aspects of the ECCS ventilation system functional failure.

Specifically, the licensee did not recognize that MR (a)(2) system performance demonstration was no longer met when the charcoal adbsorber ventilation filters failed to meet the required performance efficiency resulting in the loss of both trains of the Unit 1 ECCS ventilation system. The licensee concluded that the system could remain in (a)(2) and failed to place the Unit 1 ECCS ventilation system into MR (a)(1) status to establish MR(a)(1) goals and monitoring.

Corrective Actions: Following inspector questioning, the licensee initiated CR 02489624 to complete a MR (a)(1) evaluation of the issue, which was completed on July 19, 2024, and determined that the Unit 1 ECCS ventilation system should have been placed into MR (a)(1).

Any additional actions will be tracked by CR 02489624.

Corrective Action References: CR 02489624

Performance Assessment:

Performance Deficiency: The licensee's failure to demonstrate that the performance of the Unit 1 ECCS ventilation system was being effectively controlled through the performance of appropriate preventive maintenance was a performance deficiency. Specifically, following the complete loss of the Unit 1 ECCS ventilation system function on August 31, 2022, system performance indicated that the SSC was not being effectively controlled through appropriate preventive maintenance, and that the Unit 1 ECCS ventilation system should have been evaluated for placement into maintenance rule (a)(1) for goals and monitoring.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the ECCS ventilation system function to provide air supply, ventilation and filtration to permit proper functioning of ECCS equipment and limit release of radioactivity during operation following a design-basis event was lost on August 31, 2022, due to the performance deficiency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 3, Barrier Integrity, for "Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building," the inspectors determined the finding to be of very low safety significance (Green)because the finding only represented a degradation of the radiological barrier function.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. After loss of the ECCS ventilation system function, the licensee did not thoroughly evaluate the maintenance rule aspects of the failure.

Enforcement:

Violation: 10 CFR 50.65(a)(1) requires, in part, that holders of an operating license shall monitor the performance or condition of SSCs within the scope of the monitoring program as defined in 10 CFR 50.65(b) against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. 10 CFR 50.65 (a)(2) states, in part, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.

Contrary to the above, since September 3, 2022, the licensee failed to recognize that the loss of the Unit 1 ECCS ventilation system function on August 31, 2022, invalidated the demonstration that the performance of the system was being effectively controlled through the performance of appropriate preventive maintenance, and did not place the system into maintenance rule (a)(1) for goals and monitoring.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Unresolved Item Operating Experience Review of Action Request (AR) 71152B (Open) 02439818 URI 05000335,05000389/2024011-03

Description:

Inspectors reviewed AR 02439818 which documented operating experience from Waterford Unit 3 where the site experienced closure of the main steam isolation valves (MSIVs) and one of the main feedwater isolation valves (MFIVs) unexpectedly, resulting in an automatic reactor trip from 100% power. The event was caused by a defective actuation relay within the ESFAS cabinet. The normally energized relay coil opened, which resulted in the valve closures. Further investigation determined that the relay was a single point vulnerability (SPV).

Saint Lucies screening of the operating experience determined the issue was potentially applicable to their site, but no corrective actions were needed. The inspectors questioned how this conclusion was reached since no evaluation was documented. As a result of inspector questioning, the licensee re-opened AR 02439818, performed the evaluation, and determined that there were several SPVs in the U1 and U2 ESFAS system that could result in a plant trip at 100% power, similar to the event at Waterford. The licensee also determined that there were no preventive maintenance activities in place to periodically replace the actuation relays (or actuation modules) of the ESC SA and SB cabinets, where the SPVs were identified.

On July 28, 2024, with Unit 1 in Mode 1 at 100% power, Saint Lucie Unit 1 automatically tripped due to an inadvertent MSIV closure followed by unexpected closure of both MFIVs, similar to the event discussed in the Waterford operating experience. The inspectors determined that an unresolved item was warranted to determine if a performance deficiency exists in connection with the Unit 1 trip and review of the operating experience item as it pertains to performing preventive maintenance on ESFAS relays.

Planned Closure Actions: The inspectors plan to review the licensee's evaluation of AR 02439818, troubleshooting efforts for the Unit 1 trip, and preventive maintenance activities for SPVs in the ESFAS system.

Licensee Actions: The licensee re-opened AR 02439818 to perform the operating experience evaluation and initiated CRs 02488326 and 02489622 to address the issues identified.

Corrective Action References: CR 02488326 and CR

EXIT MEETINGS AND DEBRIEFS

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

  • On June 28, 2024, the inspectors presented the biennial PI&R inspection results to Mr.

Thad Edmonds, Operations Director, and other members of the licensee staff.

  • On August 8, 2024, the inspectors presented updated PI&R inspection results to Mr. Tim Falkiewicz, Regulatory Affairs Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Calculations L-MECH-CALC-Evaluation of the Calculations Made by Florida Power and Revision 19

017 Light for the Minimum and Maximum Torque Requirements

of the Butterfly Motor Operated Valves in the Generic Letter 89-10 Program at St. Lucie Unit 2

PSL-2FSM-22-Evaluation of Stem Torque Requirements for Unit 2 MV-07-Revision 0

007 sA/2B using the EPRI MOV Butterfly Valve Performance

Prediction Methodology

Corrective Action Action Requests 2256310, 2288414, 2396931, 2404036, 2404037, 2404038,

Documents (ARs) / Condition 2404040, 2413519, 2423529, 2423704, 2424557, 2426647,

Reports (CRs) 2427736, 2427817, 2428461, 2428567, 2429763, 2430383,

2430383, 2430473, 2430891, 2432098, 2432099, 2432102,

2432107, 2432109, 2432110, 2432587, 2433145, 2434397,

2435731, 2435832, 2435856, 2435857, 2436374, 2436618,

2437086, 2437547, 2438735, 2444696, 2446746, 2448785,

2448971, 2449293, 2450841, 2453515, 2455530, 2460059,

2462486, 2464045, 2469186, 2469312, 2473408, 2478821,

2480285-01, 2485395, 2486981, 2487802, 2488163,

2488164, 2488165, 2488166, 2488346, 2488349, 2488351,

2488353, 2488355, 2489077, 2489624, 2489625

Corrective Action ARs/CRs 2490514, 2488326, 2488330, 2488346, 2488349, 2488351,

Documents 2488353, 2488355, 2489387, 2489622, 2489624, 24889625

Resulting from

Inspection

Engineering PSL-ENG-SEMS-GL 2008-01 Managing Gas Accumulation in ECCS, SDC, Revision 9

Evaluations08-030 and CS Systems

Miscellaneous CID 1503507-2 Log Amplifier Commercial Grade Dedication Package 10/12/2018

CID 347644-2 DC Voltage Sensing Board Commercial Grade Dedication 11/21/2018

Package

CID 86978-2 Power Supply Commercial Grade Dedication Package 05/07/2021

PMC-19-005842 Replace OP-2-0010125A Data Sheet 23 Individual Valve

Tracking PMRQs with Group Tracking

PMID 00031659 MV-08-13

Inspection Type Designation Description or Title Revision or

Procedure Date

PMID 00031661 MV-08-14

PMID 00040474 125V Battery 2D

Work Requests 94237466, 94237468, 94237469, 94237470, 94237471,

(WRs) 94245719

Procedures 1-OSP-03.06A 1A Low Pressure Safety Injection Pump Code Run Revision 16

1-OSP-99.23 Valves Tested During Refueling St Lucie Unit 1 Revision 10

2-OSP-99.23 Valve Tests During Refueling Interval St Lucie Unit 2 Revision 2

ADM-03.10 Gas Accumulation Management Revision 18

ADM-17.33 License Renewal Systems Program Monitoring Revision 15

EN-AA-206 Renewed License Process Revision 14

ER-AA-100-2002 Maintenance Rule Program Administration Revision 15

STD-M-003 Engineering Guidelines for Sizing and Evaluation of Revision 7

Limitorque Motor Operators

Self-Assessments AR 02487947 Radiation Protection Q1 2024 CAP Trend Assessment 06/12/2024

AR 2456989-83 Chemistry Q4 2023 CAP Trend 12/31/2024

AR 2476690 Chemistry Quarterly Trends 02/16/2024

Work Orders 40619883-01, 4080326101, 40961464

14

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000335/2024011&oldid=3669751"