IR 05000335/2017007

NRC Evaluation of Changes, Tests, and Experiments Report No. 05000335/2017007 and 05000389/2017007

ML17202G462
Person / Time
Site:	Saint Lucie
Issue date:	07/21/2017
From:	Bartley J NRC/RGN-II/DRS/EB1
To:	Nazar M Florida Power & Light Co
References
IR 2017007
Download: ML17202G462 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION uly 21, 2017

SUBJECT:

ST. LUCIE PLANT - NRC EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS REPORT NUMBER 05000335/2017007 AND 05000389/2017007

Dear Mr. Nazar:

On June 9, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your St. Lucie Plant Units 1 and 2 and discussed the results of this inspection with Mr. D. DeBoer and other members of your staff. Additional inspection results were discussed with Mr. D. DeBoer and other members of your staff on July 20, 2017. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 50-335, 50-389 License Nos. DPR-67, NPF-16

Enclosure:

Inspection Report 05000335/2017007 and 05000389/2017007, w/Attachment:

Supplemental Information

REGION II==

Docket Nos.: 050000335, 05000389 License Nos.: DPR-67, NPF-16 Report Nos.: 05000335/2017007, 05000389/2017007 Licensee: Florida Power & Light Company (FP&L)

Facility: St. Lucie Plant, Units 1 & 2 Location: 6501 South Ocean Drive Jensen Beach, FL 34957 Dates: June 5 - June 9, 2017 Inspectors: G. Ottenberg, Senior Reactor Inspector (Lead)

R. Patterson, Reactor Inspector M. Greenleaf, Reactor Inspector S. Downey, Senior Reactor Inspector (Trainee)

Approved by: Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report (IR) 05000335/2017-007, 05000389/2017-007; 06/05/2017 - 06/09/2017;

St. Lucie Plant, Units 1 and 2; NRC Evaluations of Changes, Tests, and Experiments.

The inspection activities described in this report were performed between June 5 and June 9, 2017, by four Nuclear Regulatory Commission (NRC) inspectors from Region II. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using IMC 0609, Significance Determination Process dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310,

Components Within the Cross Cutting Areas dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

No findings were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments

a. Inspection Scope

Evaluations of Changes, Tests, and Experiments: The inspectors reviewed six safety evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR) 50.59, Changes, tests, and experiments, to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed sixteen screenings and zero applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issues requiring the changes, tests or experiments were resolved;

• the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation used to support the change was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000.

This inspection constituted 22 evaluations, screenings, and/or applicability determination samples as defined in Inspection Procedure (IP) 71111.17-05. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified. However, the following unresolved item (URI) was identified.

(Opened) Question Regarding Adequacy of Evaluation of Hot Leg Injection Actions

Introduction:

The team identified an unresolved item (URI) regarding the adequacy of a 10 CFR 50.59 evaluation performed for procedures related to post-accident hot leg injection (HLI) alignment.

Description:

Engineering Change (EC) 284437, Evaluation of Actions Required to Mitigate Hot Leg Injection Single Failure Vulnerability, revision 0, was created to proceduralize actions needed to mitigate a single failure vulnerability associated with HLI by installing temporary power jumpers to valves in the HLI flow path. The actions in the procedures were generated to provide specific direction to operators and maintenance personnel to install electrical jumper cabling to provide power to un-powered motor operated valves in the HLI flow paths in case one of the electrical power trains was disabled as a result of a postulated single failure. Certain electrical single failures could disable both the primary and alternate methods of aligning coolant injection into the reactor coolant system hot legs, which is needed to preclude boron precipitation, which could interrupt long term core cooling during postulated design basis accidents. The electrical single failures of concern were described in St. Lucie Unit 1 licensee event report 2011-003-01, Long-Term Post-LOCA Hot Leg Injection Single Failure Vulnerability.

The inspectors noted that the St. Lucie Unit 1 UFSAR sections 8.3.1.2.1, 8.3.1.2.2, and 8.3.1.2.3, Redundancy, Electrical Separation, and Physical Separation, respectively, did not explicitly account for the installation of electrical jumper cables to provide power between the electrical trains as described in the newly created procedures. The inspectors also noted that the guidance in NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, revision 1, section 4.3.2, Does the Activity Result in More Than a Minimal Increase in the Likelihood of Occurrence of a Malfunction of an SSC Important to Safety? considers a reduction in system/equipment redundancy, diversity, separation, or independence, as a more than minimal increase and would require NRC review and approval prior to implementation. The inspectors were unable to locate all relevant licensing basis documents regarding HLI action requirements for redundancy, and electrical and physical separation, or prior NRC approvals of these actions during the inspection. Review of these documents is needed to determine if the licensees response in Question 2 of the 50.59 evaluation was adequate in its conclusion that a more than minimal increase in the likelihood of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the UFSAR did not exist.

Additionally, the inspectors noted that the St. Lucie Unit 1 UFSAR Table 15.4.1-11, LOCA Dose Summary, contained results of consequence analyses, but only provided results for offsite consequences and the control room. At the time of the inspection, it was unclear to inspectors how the dose consequences due to actions outside of the control room had previously been evaluated. Further, the inspectors noted that the St.

Lucie Unit 1 UFSAR, Table 12.1-11, Areas Identified in Shielding Review as Requiring Accessibility Following an Accident, did not identify the electrical bus rooms, where the jumpers would be installed, nor the operational support center (OSC) where the jumpers are stored, as requiring occupancy post-accident. The guidance in NEI 96-07, revision 1, section 4.3.4, Does the Activity Result in More Than a Minimal Increase in the Consequences of a Malfunction? utilizes the guidance in section 4.3.3 for determining if a more than minimal increase in the consequence of a malfunction existed. The guidance in section 4.3.3 stated, Activities affecting on-site dose consequences that may require prior NRC approval are those that impede required actions inside or outside the control room to mitigate the consequences of reactor accidents. For changes affecting the dose to operators performing required actions outside the control room, an increase is considered more than minimal if the resultant mission dose exceeds applicable GDC 19 criteria. Review of the licensees 50.59 evaluation determined that the evaluation only addressed the potential for offsite dose increases and did not address the potential increase in dose resulting from the procedural actions for installation of the jumpers, which are performed outside of the control room. Additional review is needed to determine if onsite dose assessment of the actions was previously addressed by the licensee or considered by the NRC.

This issue is a URI pending the determination of whether a performance deficiency or violation of NRC requirements exists. (URI 05000335/2017007-01, Question Regarding Adequacy of Evaluation of Hot Leg Injection Actions)

4OA6 Meetings, Including Exit

On June 9, 2017, the inspectors presented inspection results to Mr. D. DeBoer and other members of the licensees staff. On July 20, 2017, a re-exit meeting was conducted via teleconference to present the final inspection results to Mr. D. DeBoer and other members of the licensees staff. The inspectors verified no proprietary information was retained or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

D. DeBoer, PSL Site Director

D. Cecchett, Nuclear Licensing Principal

S. Cornell, Nuclear Staff Engineer

T. Falkiewicz, Nuclear Engineer I

K. Frehafer, Nuclear Licensing Principal

W. Laframboise, Nuclear Engineering Site Manager- Design

R. Raldiris, Nuclear Engineer Principal

M. Snyder, Nuclear Site Licensing Manager

NRC personnel

D. Beaulieu, Reactor Operations Engineer

P. Buckberg, Project Manager

T. Morrissey, Senior Resident Inspector, St. Lucie Plant

L. Suggs, Chief, Projects Branch 3

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000335/2017007-01 URI Question Regarding Adequacy of Evaluation of Hot Leg Injection Actions (Section 1R17.b.1)