Text

October 30, 2007

Florida Power and Light CompanyATTN:Mr. J.A. Stall, Senior Vice PresidentNuclear and Chief Nuclear OfficerP.O. Box 14000Juno Beach, FL 33408-0420

SUBJECT: TURKEY POINT NUCLEAR PLANT - INTEGRATED INSPECTION REPORT05000250/2007004 AND 05000251/2007004

Dear Mr. Stall:

On September 30, 2007, the US Nuclear Regulatory Commission (NRC) completed aninspection at your Turkey Point Units 3 and 4. The enclosed integrated inspection reportdocuments the inspection findings which were discussed on October 18, 2007, with Mr. W.Jefferson and other members of your staff.The inspection examined activities conducted under your license as they related to safetyand compliance with the Commission's rules and regulations and with the conditions of yourlicense. The inspectors reviewed selected procedures and records, observed activities, andinterviewed personnel.Based on the results of this inspection, the inspectors identified one Severity Level IVviolation of NRC requirements. Also there were three NRC-identified findings and one self-revealing finding. Four of these findings were determined to involve violations of NRCrequirements. However, because of the very low safety significance and because the issueswere entered into your corrective action program, the NRC is treating the violations and the findings as non-cited violations consistent with Section VI.A.1 of the NRC EnforcementPolicy. If you wish to contest these non-cited violations, you should provide a responsewithin 30 days of the date of this inspection report, with the basis for your denial, to theNuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement,United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRCResident Inspector at Turkey Point.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter andits enclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of the NRC's document FP&L2system (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/

Steven J. Vias, ChiefReactor Projects Branch 3Division of Reactor ProjectsDocket Nos. 50-250, 50-251License Nos. DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2007004 and 05000251/2007004

w/Attachment:

Supplemental Information FP&L2system (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/

Steven J. Vias, ChiefReactor Projects Branch 3Division of Reactor ProjectsDocket Nos. 50-250, 50-251License Nos. DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2007004 and 05000251/2007004

w/Attachment:

Supplemental InformationG PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE G NON-SENSITIVEADAMS: G YesACCESSION NUMBER:_________________________OFFICERII:DRPRII:DRPRII:DRPRII:DRSRII:DRSRII:DRSRII:DRSSIGNATUREJSS1 by emailMCBSPS by emailJER6CMF1LFL forLFLNAMESStewartMBarillasSSanchezJRivera-OrtezCFletcherBMillerLLakeDATE10/29/200710/30/200710/29/200710/22/200710/22/200710/22/200710/22/2007 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO OFFICERII:DRSRII:DRSRII:DRSRII:DRSRII:DRPSIGNATURECAP3RBR1 forRKH1 by emailAND by emailSONNAMECPeabodyGKuzoRHamiltonANielsenSNinhDATE10/22/200710/24/200710/23/200710/23/200710/29/200711/ /200711/ /2007E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNOOFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML073030412.wpd FP&L3cc w/encl:William Jefferson, Jr.Site Vice PresidentTurkey Point Nuclear PlantFlorida Power and Light CompanyElectronic Mail DistributionJames ConnollyLicensing ManagerTurkey Point Nuclear PlantFlorida Power and Light CompanyElectronic Mail DistributionDon E. GrissetteVice President, Nuclear Trainingand Performance ImprovementTurkey Point Nuclear PlantFlorida Power and Light CompanyElectronic Mail DistributionMichael O. PearcePlant General ManagerTurkey Point Nuclear PlantFlorida Power and Light CompanyElectronic Mail DistributionWilliam E. Webster, Vice PresidentNuclear OperationsSouth RegionFlorida Power & Light CompanyElectronic Mail DistributionMark Warner, Vice PresidentNuclear Operations SupportFlorida Power & Light CompanyElectronic Mail DistributionRajiv S. KundalkarVice President - Nuclear TechnicalServicesFlorida Power & Light CompanyElectronic Mail DistributionM. S. Ross, Managing AttorneyFlorida Power & Light CompanyElectronic Mail DistributionMarjan Mashhadi, Senior AttorneyFlorida Power & Light CompanyElectronic Mail DistributionAttorney GeneralDepartment of Legal AffairsThe CapitolTallahassee, FL 32304William A. PassettiBureau of Radiation ControlDepartment of HealthElectronic Mail DistributionAlejandro SeraMiami-Dade CountyEmergency Management CoordinatorElectronic Mail DistributionCounty ManagerMiami-Dade County111 NW 1st Street, 29th FloorMiami, FL 33128Craig Fugate, DirectorDivision of Emergency PreparednessDepartment of Community AffairsElectronic Mail DistributionCurtis IvyCity Manager of HomesteadElectronic Mail Distribution FP&L4Letter to J.from Steven J. Vias dated October 30, 2007Distribution w/encl:B. Mozafari, NRRC. Evans (Part 72 Only)L. Slack, RII EICSOE Mail (email address if applicable)RIDSNRRDIRSPUBLIC EnclosureU.S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket Nos:50-250, 50-251License Nos:DPR-31, DPR-41Report No:05000250/2007004, 05000251/2007004Licensee:Florida Power & Light Company (FP&L)Facility:Turkey Point Nuclear Plant, Units 3 & 4Location:9760 S. W. 344th StreetFlorida City, FL 33035Dates:July 1 to September 30, 2007 Inspectors:J. Stewart, Senior Resident InspectorM. Barillas, Resident InspectorS. Sanchez, Resident Inspector, St. LucieJ. Rivera-Ortiz, Reactor Inspector (1R08)C. Fletcher, Reactor Inspector (1R08)B. Miller, Reactor Inspector (1R08)L. Lake, Sr. Reactor Inspector (1R08)C. Peabody, Reactor Inspector (4OA5)G. Kuzo, Senior Health Physicist (Sections 2OS2, 2PS1, 4OA1 ) R. Hamilton, Senior Health Physicist, (Sections 2OS1, 4OA1) A. Nielsen, Health Physicist (Sections 2PS2)Accompanied By:R. Torres, General Engineer - NSPDPApproved by:S. J. Vias, Chief Reactor Projects Branch 3Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000250/2007-004, 05000251/2007-004; 7/1/2007 - 9/30/2007; Turkey Point NuclearPower Plant, Units 3 and 4; Inservice Inspection, Refueling and Other Outage Activities,Radioactive Material Processing and Transportation, Problem Identification and Resolution, andEvent Follow-upThe report covered a three month period of inspection by resident inspectors, region basedreactor inspectors, and health physicists. One non-cited Severity Level IV (SL IV) violation andthree non-cited violations were identified. The significance of most findings is identified by theircolor (Green, White, Yellow, Red) using IMC 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level afterNRC management review. The NRC's program for overseeing the safe operation ofcommercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process",Revision 4, dated December 2006.A.Inspector Identified & Self-Revealing Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation (NCV) of 10 CFR50.55a(g)(4) for the failure to perform periodic leakage testing of buried pipingportions of the Intake Cooling Water system as required by Section XI of theASME Code for the third 10-year Inservice Inspection interval for Units 3 and 4. The licensee entered this issue into their corrective action program for resolution.This finding is more than minor because it affects the Equipment Performanceattribute of the Mitigating Systems cornerstone objective of ensuring availability,reliability, and capability of systems that respond to initiating events to preventundesirable consequences. This finding is of very low safety significancebecause it was not a design issue resulting in a loss of operability, did notrepresent an actual loss of a system's safety function, did not result in exceedinga technical specification (TS) allowed outage time, and did not affect externalevent mitigation. The inspectors determined that this finding had no cross-cuttingaspect. (Section 1R08) *No Color: The inspectors identified a non-cited, SL IV violation of TS 6.8.5 wheninappropriate blanket overtime was authorized for thirty-eight electricalmaintenance personnel for the entire Unit 3 fall 2007 refueling outage. Thisissue was promptly discussed with licensee management, the authorization wasrescinded, and action was taken by the licensee to manage overtime inaccordance with the technical specification requirements. The licensee enteredthis issue into their corrective action program for resolution.This finding was evaluated using traditional enforcement since it impacted theregulatory process in that the non-compliance with technical specifications wasauthorized at an executive level, which could become a more significant safetyconcern. This finding is of very low safety significance because there were no 3Enclosureactual adverse plant or equipment conditions attributed to worker fatigue. (Section 1R20)*Green.The inspectors identified a finding when the licensee did not identify andcorrect an adverse trend of recurring problems with the alternate shutdowncommunications system. When identified, the licensee entered the issue into thecorrective actions program and initiated a review of reliability issues with thecommunications equipment.The finding is more than minor because it affects the availability and reliability ofthe communications system used by plant operators to mitigate certain firescenarios. The issue was of very low safety significance because an alternatecommunications system (radios) was available, if needed. The cause wasrelated to the cross-cutting area of problem identification and resolution becausethe adverse trend of problems with alternate shutdown communications had notbeen identified nor corrected by the licensee commensurate with its safetysignificance. (IMC 305, P.1 (d)) (4OA2)*Green. A self-revealing NCV of 10 CFR 50, Appendix B, Criterion IV,Procurement Document Control, was identified for improper inserts having beenprocured and installed in the Unit 3 and Unit 4 rod position circuitry. The insertswere not qualified for the reactor environment and sequentially failed, causingloss of multiple rod position circuits on Unit 3 requiring reactor shutdown. Whenidentified, the affected electrical connectors were replaced with qualified splices. The licensee entered this issue into their corrective action program for resolution.The failure is more than minor because the reliability of the mitigating rod positionindication system is affected. The finding was of very low safety significancebecause redundant measures of assuring plant shutdown and control usingboration were available. The inspector determined that this finding had no cross-cutting aspect. (4OA3)

Cornerstone: Public Radiation Safety (PS)

Green.

The inspectors identified an NCV of 10 CFR Part 71.5(a)(1)(v) for thefailure of the licensee to follow Department of Transportation (DOT) regulationsfound in 49 CFR Part 172.201(d) which require shipping papers associated withthe transport of radioactive material to contain an emergency response telephonenumber. All radioactive waste shipments made from November 2006 untilSeptember 2007 had an incorrect emergency response phone number listed onthe official shipping papers. The licensee entered the issue into the correctiveaction program under condition report (CR) Number 2007-28133 and intended tocorrect future shipping papers.

4EnclosureThe finding is more than minor because it is associated with the Public RadiationSafety cornerstone attribute and adversely affects the cornerstone objective ofensuring adequate protection of public health and safety from exposure toradioactive materials released into the public domain. Based on the facts thatemergency response recommendations required by 49 CFR Part 172.602 were included in the paperwork package for each shipment and that there were noaccidents on public roadways that would have required the use of the emergencyresponse phone number, the finding was determined to be of very low safetysignificance (Green). This finding has a crosscutting area of human performancewith work practices aspect (IMC 305, H.4 (a)), because the incorrect emergencyresponse phone number was the result of a transposition error which was notprevented by the use of self and peer checking human error preventiontechniques. (Section 2PS2)

B.Licensee Identified Violations

None

Enclosure

REPORT DETAILS

Summary of Plant Status:Unit 3 operated at full power throughout the inspection period with the following exception: OnSeptember 2, Unit 3 reduced power to 50 percent for testing of main steam safety valves, thenproceeded to shutdown the plant for the Cycle 23 refueling outage. The reactor remainedshutdown for the remainder of the period. Unit 4 operated at full power throughout the inspection period with the following exceptions: OnJuly 22, Unit 4 was shutdown, then cooled to Mode 5 to replace the rod position indicationcircuit connectors at the top of the reactor vessel coil stacks. The unit went critical on July 27and returned to full power on July 28. On September 26, power was reduced to 58 percent dueto a ground that was later found on the C condensate pump power leads. The ground wasisolated and reactor power was returned to 100 percent.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (Reactor-R)1R04Equipment Alignment.1Partial Equipment Walkdowns

a. Inspection Scope

The inspectors conducted three partial alignment verifications of the safety-relatedsystems listed below. These inspections included reviews using plant lineupprocedures, operating procedures, and piping and instrumentation drawings, which werecompared with observed equipment configurations to verify that the critical portions ofthe systems were correctly aligned to support operability. The inspectors also verifiedthat the licensee had identified and resolved equipment alignment problems that couldcause initiating events or impact the capability of mitigating systems or barriers byentering them into the corrective action program.*Unit 3 Auxiliary feedwater, train 2 in accordance with licensee procedure 3-OSP-075.2, Auxiliary Feedwater Train 2 Operability Verification, following asurveillance on the system*Unit 3 Component cooling water and associated intake cooling water headersduring 3B heat exchanger mechanical cleaning, per work order 36019763.Licensee procedure 0-PMM-030.1, Component Cooling Water Heat ExchangerCleaning was used in the walkdown*Unit 4 4160 volt electrical distribution using licensee procedure 4-OP-005, 4160Volt Buses A, B, and D, when the Unit 3 C transformer was removed fromservice for maintenance and testing

b. Findings

No findings of significance were identified..2Complete System Walkdown

a. Inspection Scope

The inspectors conducted a detailed walkdown/review of the alignment and condition ofthe Unit 3 intake cooling water system to verify the capability of the system to meet itsdesign basis function to remove the heat from the component cooling water systemduring accident conditions to support both reactor heat removal and containment heatremoval requirements. The inspectors utilized licensee procedure 3-OP-019, IntakeCooling Water, and drawing 5613-P-633-S (Unit 3 Intake Cooling Water System), as wellas other licensing and design documents, when verifying that the system alignment. During the walkdown, the inspectors verified, as appropriate, that: (1) valves werecorrectly positioned and did not exhibit leakage that would impact the function of anyvalve; (2) electrical power was available as required; (3) major portions of the systemand components were correctly labeled, cooled and ventilated; (4) hangers and supportswere correctly installed and functional; (5) essential support systems were operational;(6) ancillary equipment or debris did not interfere with system performance; (7) taggingclearances were appropriate; and (8) valves were locked as required by the licensee'slocked valve program. Pending design and equipment issues were reviewed todetermine if the identified deficiencies significantly impacted the system's functions. Items included in this review were the operator workaround list, the temporarymodification list, system health reports, system description, and outstandingmaintenance work requests/work orders. In addition, the inspectors reviewed thelicensee's corrective action program to ensure that the licensee was identifying andresolving equipment alignment problems.

b. Findings

No findings of significance were identified.1R05Fire Protection

a. Inspection Scope

.1Fire Area WalkdownsThe inspectors toured the following nine plant areas during this inspection period toevaluate conditions related to control of transient combustibles and ignition sources, thematerial condition and operational status of fire protection systems including fire barriersused to prevent fire damage or fire propagation. The inspectors reviewed theseactivities using licensee procedure 0-ADM-016, Fire Protection Plan, and 10 CFR Part

0, Appendix R. The licensee's fire impairment lists, updated on an as-needed basis,were routinely reviewed. In addition, the inspectors reviewed the condition reportdatabase to verify that fire protection problems were being identified and appropriatelyresolved. The following areas were inspected:*Unit 3 emergency diesel generator rooms*Cable spreading room*Unit 4 residual heat removal pump rooms*3A and 3B battery rooms*4A and 4B battery rooms*Unit 3 4160 volt switchgear rooms*Unit 4 4160 volt switchgear rooms*Unit 4 intake cooling water pump area*Main control rooma.FindingsNo findings of significance were identified.1R07Heat Sink Performance

a. Inspection Scope

The inspectors witnessed heat exchanger cleaning activities on the 4B componentcooling water heat exchanger and the Unit 4 component cooling water heat exchangerperformance test. On August 16, 2007, the inspectors observed maintenance personnelperform heat exchanger cleaning under work order 37008257. The inspectors verifiedthat activities were conducted in accordance with licensee procedure 0-PMM-030.1,component cooling water heat exchanger cleaning. The inspectors checked monitoringand trending of heat exchanger performance done weekly using licensee procedure 3/4-OSP-030.4, Component Cooling Water Heat Exchanger Performance Testing, andverified the operational readiness of the system should it be needed for accidentmitigation. The inspectors verified that the licensee employed a heat transfer methoddescribed in EPRI-NP-7552, heat exchanger performance monitoring guidelines. Theinspectors walked down portions of the cooling systems for integrity checks and toassess material condition. Maintenance rule monitoring of the system was verified. Theinspectors verified that significant heat sink issues were entered into the correctiveaction program.b. FindingsNo findings of significance were identified.

R08 Inservice Inspection (ISI) Activities

.1 Inservice Inspection activities other than Steam Generator Tube Inspections, (PWR)Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control Program

a. Inspection Scope

The inspectors reviewed the implementation of the licensee's ISI program for monitoringdegradation of the reactor coolant system (RCS) boundary and risk significant pipingboundaries during the Unit 3 Fall 2007 refueling outage. The inspectors' activitiesconsisted of an on-site review of nondestructive examination (NDE) and weldingactivities to evaluate compliance with the applicable edition of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code, Sections V, IX, and XI(Code of record for Turkey Point fourth 10-year ISI interval was 1998 Edition with 2000Addenda), and to verify that indications and defects (if present) were appropriatelyevaluated and dispositioned in accordance with the requirements of the ASME Code,Section XI acceptance standards. The inspectors' review of NDE activities consisted of the examinations described belowincluding the review of their corresponding procedures, NDE reports, equipment andconsumables certification records, personnel qualification records, calibration reports,and calibration block fabrication drawings (as applicable).*Direct observation of ultrasonic (UT) examination of welds 10"-SI-1301-2 and10"-SI-1301-3 (Category R-A welds, 10-inch pipe-to-elbow, Safety Injection (SI)System, ASME Class 1)*Direct observation of liquid penetrant (PT) examination of welds 3-CRDM-68, 3-CRDM-66, and 3-CRDM-64 (Category B-O welds, Control Rod Drive Mechanismnozzles, Reactor Coolant System (RCS), ASME Class 1)*Documentation review of UT examination of weld 8"-RHR-1301-2 (Category R-Aweld, 8-inch pipe, Residual Heat Removal (RHR) System, ASME Class 1)The inspectors' review of recordable indications included a sample from NDE activitiesperformed during last refueling outage to verify that the evaluation and disposition ofindications were in accordance with the applicable edition of ASME Code,Section XI,Article IWC-3000. The inspectors selected the following component for review: *Weld 3-SGB-P: UT indications in a upper shell to head weld (category C-A weld,secondary side of Steam Generator B, ASME Class 2)The inspectors' review of welding activities included a sample of welds performed sincethe beginning of the last refueling outage for ASME Class 1 and 2 piping to evaluatecompliance with procedures and the ASME Code. The inspectors reviewed work orders,

construction code reconciliation records, weld process control reports, weldingprocedures, procedure qualification records, certified material test reports for fillermaterial and repair base material, welder qualification records, NDE reports, and NDEpersonnel qualification records for the following welds:*FW-1, FW-2, and FW-3: Repair of 3-inch pipe segment upstream MOV-3-535,RCS, ASME Class 1 (Final NDE: PT examination) *2"-SI-1303-106 and 2"-SI-1303-206: Replacement of valve 3-873C, 2-inchdiameter pipe, Safety Inspection (SI) System, ASME Class 1 (Final NDE: PTexamination) *2"-SI-2309-506, 2"-SI-2309-606, and 2"-SI-2309-706: Replacement of valve 3-873C, 2-inch diameter pipe, SI System, ASME Class 2 (Final NDE: PTexamination) The inspectors also reviewed the results of the Intake Cooling Water (ICW) pipinginspections performed during the third 10-year ISI interval to verify compliance with therequirements of the ASME Code,Section XI, Article IWA-5244 for Class 3 piping. Documents reviewed are in the attachment.b.FindingsIntroduction: The inspectors identified a Green non-cited violation (NCV) of 10 CFR50.55a(g)(4) having very low safety significance for failure to perform periodic leakagetesting of buried piping sections of the ICW system as required by Section XI of theASME Code for the third 10-year ISI interval for Units 3 and 4.

Description:

On August 29, 2007, the inspectors identified that the licensee had notperformed the required periodic pressure drop test or change in flow rate test for buriedpiping portions of the ICW system during the third 10-year ISI interval for Units 3 and 4 inaccordance with the 1989 Edition of the ASME Code,Section XI, Article IWA-5244. Thelicensee was committed to this code edition for the third interval on each unit. Both unitsare currently in the fourth ISI interval and the one-year period allowed to submit forregulatory relief following the third interval had expired at the time of this inspection. Thefailure to perform the requirements of IWA-5244 constitutes a violation of the ASMECode. The Code required testing for buried piping that is isolable by means of valves. The licensee had not performed this leakage testing because they did not consider thebutterfly isolation valves in the system to be sufficient for use as isolation valves.The buried ICW piping is carbon steel and lined with concrete. Periodic visualinspections of the internal surfaces are conducted via crawl through inspections thatprimarily look for spalling of the concrete lining. There are no internal or externalinspections performed that could identify small through-wall flaws from which leakagecould occur. System flow tests were successfully completed on a quarterly basis to

verify sufficient flow was maintained. However, and notwithstanding, the primary meansof confirming pressure retaining integrity of buried piping is through the periodic leakagetesting required by Section XI of the ASME Code.Analysis: The inspectors determined the failure to perform the required periodic testingof ICW buried piping was a performance deficiency. This finding was more than minorbecause it affects the Equipment Performance attribute of the Mitigating Systemscornerstone objective of ensuring availability, reliability, and capability of systems thatrespond to initiating events to prevent undesirable consequences. Should a significantleak or rupture occur due to undetected degradation, this piping could not reliably delivercooling water to the CCW heat exchangers which, in turn, cool mitigating systemcomponents that are needed to respond to an initiating event. This finding wasevaluated using Phase 1 of Inspection Manual Chapter 0609, Significance DeterminationProcess (SDP). This finding is of very low safety significance (Green) because it wasnot a design issue resulting in a loss of operability, did not represent an actual loss of asystem's safety function, did not result in exceeding a technical specification (TS)allowed outage time, and did not affect external event mitigation. The inspectorsdetermined that this finding had no cross-cutting aspect.Enforcement: 10 CFR 50.55a(g)(4) requires, in part, that throughout the service life of aboiling or pressurized water reactor facility, components classified as ASME Code Class1, 2, and 3 must meet the requirements set forth in Section XI of the ASME Code. The1989 Edition of Section XI, IWA-5244, Buried Components states "(a) In nonredundantsystems where the buried components are isolable by means of valves, the visualexamination VT-2 shall consist of a leakage test that determines the rate of pressureloss. Alternatively, the test may determine the change in flow between the ends of theburied components..." Contrary to this, the licensee failed to perform the required testingon buried portions of the Class 3 ICW system during the third 10-year ISI interval forUnit 3 (02/22/1994 - 02/21/2004) and Unit 4 (4/15/1994 - 4/14/2004) for which the 1989Edition of the ASME Code was applicable. Therefore, because this finding is of very lowsafety significance (Green) and because this issue was entered into the licensee'scorrective action program (CR 2007-26148), it is being treated as a Non-Cited Violation(NCV) consistent with Section VI.A.1 of the Enforcement Policy. This NCV is identifiedas NCV 050000250,251/2007004-01, Failure to Perform Required ASME Code SectionXI Leakage Testing..2 PWR Vessel Upper Head Penetration (VUHP) Inspection Activitiesa.Inspection ScopeThe inspectors reviewed licensee procedures and the results of all visual inspectionsperformed since the Unit 3 Fall 2004 refueling outage (procedure 0-OSP-041.26) toidentify potential boric acid leaks from pressure-retaining components above the VUH asrequired by NRC Order EA-003-09. The inspectors also reviewed the licensee'seffective degradation years calculation, which was performed to determine the VUH's

susceptibility category and its examination requirements. There were no volumetric orbare metal visual exams scheduled for the Fall 2007 refueling outage.

b. Findings

No findings of significance were identified.3 Boric Acid Corrosion Control (BACC) Inspection Activities

a. Inspection Scope

The inspectors reviewed the licensee's BACC program activities to ensureimplementation with commitments made in response to NRC Generic Letter 88-05,"Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary," and applicableindustry guidance documents. Specifically, the inspectors performed an on-site recordreview of procedures, personnel qualifications, and the results of the licensee'scontainment walkdown inspections performed during the Unit 3 Fall 2007 outage. Theinspectors also conducted an independent walkdown of the reactor building to evaluatecompliance with licensee's BACC program requirements and verify that degraded ornon-conforming conditions, such as boric acid leaks identified during the containmentwalkdown, were properly identified and corrected in accordance with the licensee'sBACC and Corrective Action Programs.The inspectors reviewed a sample of engineering evaluations completed for evidence ofboric acid found on systems containing borated water to verify that the minimum designcode required section thickness had been maintained for the affected components. Theinspectors selected the following evaluations for review:*CR 2007-27330, Boric acid indications found on components during reactorcoolant system cooldown containment walkdown*CR 2007-26978, Boric acid indication at pipe cap downstream of valve 3-547A

CR 2007-7322, Boric acid indications on the bolted flange connections of valveTCV-3-143, non-regenerative heat exchanger outlet to volume control tank*CR 2006-10654, Boric acid indications on D-3 high pressure fitting on the Unit 3seal table

b. Findings

No findings of significance were identified

===.4 Steam Generator (SG) Tube Inspection Activities

a. Inspection Scope

The inspectors reviewed licensee documentation and performed direct observation oflicensee and vendor activities related to the eddy current examination (ECT) of Unit 3SGs A, B, and C tubes during the Fall 2007 refueling outage to verify that inspectionactivities were being conducted in accordance with Technical Specifications andapplicable industry standards.===

The inspectors' document review covered the vendor'sinspection plan, pre-outage degradation assessment, pre-outage condition monitoringand operational assessment, inspection procedures, site specific ECT techniquevalidation, examination technique specification sheets (ETSS), ECT probe certificates ofcompliance, and personnel qualifications. The inspectors performed direct observationof data acquisition activities along with verification of equipment settings for ongoingdata acquisition. The inspectors also reviewed ECT electronic data for SG-A tubesR37C47, R31C44, R12C19; SG-B tubes R30C42, R34C53, R39C64; and SG-C tubesR32C19, R20C67, R29C73, and R34C31 to verify the adequacy of the licensee'sprimary, secondary, and resolution analyses. In addition, the inspectors reviewed asample of visual inspection activities of the SG-B secondary side to verify that foreignparts were identified and proper corrective actions were taken in accordance with thelicensee's Steam Generator Secondary Side Integrity Plan.

b. Findings

No findings of significance were identified..5 Identification and Resolution of Problems

a. Inspection Scope

The inspectors performed a review of ISI-related problems, including welding, BACC,and SG ISI that were identified by the licensee and entered into the corrective actionprogram as Condition Reports (CRs).The inspectors reviewed the CRs to confirm that the licensee had appropriatelydescribed the scope of the problem and had initiated corrective actions. The review alsoincluded the licensee's consideration and assessment of operating experience eventsapplicable to the plant. The inspectors performed this review to ensure compliance with10CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. Thecorrective action documents reviewed by the inspectors are listed in the reportattachment.

b. Findings

No findings of significance were identified.

==R11 Licensed Operator Requalification Program

a. Inspection Scope

On July 12, 2007, the inspectors observed and assessed licensed operator performancein the plant specific simulator.==

The simulated events were completed in accordance withthe licensee's Emergency Preparedness, Team Bravo drill. The inspectors observed theoperator's use of 3-ONOP-100, Fast Power Reduction, 3-EOP-E-0, Reactor Trip andSafety Injection, 3-EOP-E-3, Steam Generator Tube Rupture. The operator's actionswere checked to be in accordance with licensee procedures. Event classifications(Unusual Event and Alert) were checked for proper classification and completion of statenotification forms. The licensee simulated emergency plan notifications. The simulatorboard configurations were compared with actual plant control board configurationsconcerning recent plant modifications. The inspectors specifically evaluated thefollowing attributes related to operating crew 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 operationprocedures; 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 andimplement appropriate technical specification actions, regulatory reportingrequirements, and emergency plan classification and notification*Crew overall performance and interactions

b. Findings

No findings of significance were identified.1R12Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the following four equipment problems and associatedcondition reports to verify that the licensee's maintenance efforts met the requirementsof 10 CFR 50.65 Requirements for Monitoring the Effectiveness of Maintenance atNuclear Power Plants and Administrative Procedure 0-ADM-728, Maintenance RuleImplementation. The inspectors' efforts focused on maintenance rule scoping,characterization of maintenance problems and failed components, risk significance,determination of (a)(1) classification, corrective actions, and the appropriateness ofestablished performance goals and monitoring criteria. The inspectors also interviewedresponsible engineers and observed some of the corrective maintenance activities. Theinspectors checked that when operator actions were credited to prevent failures, the

operator was dedicated at the location needed to accomplish the action in a timelymanner, and that the action was governed by applicable procedures. Furthermore, theinspectors verified that equipment problems were being identified and entered into thecorrective action program. The inspectors used licensee engineering procedure EDI-ENG-025, Management and Administration of Maintenance Rule Processes, and theapplicable system health reports in the reviews.*CR 2007-20954, Boric acid storage tank level below technical specificationlimits*CR 2006-24561, Unit 3 Rod M-6 position indication inoperable*CR 2007-15763, 4A emergency diesel generator fails to start duringsurveillance test*CR 2007-21655, MOV-3-1403 auxiliary feedwater steam supply valve fails tostroke after maintenance

b. Findings

No findings of significance were identified.1R13Maintenance Risk Assessments and Emergent Work Controla.Inspection ScopeThe inspectors completed in-office reviews and control room inspections of thelicensee's risk assessment of five emergent or planned maintenance activities. Theinspectors verified the licensee's risk assessment and risk management activities usingthe requirements of 10 CFR 50.65(a)(4); the recommendations of Nuclear Managementand Resource Council 93-01, Industry Guidelines for Monitoring the Effectiveness ofMaintenance at Nuclear Power Plants, Revision 3; and Procedures 0-ADM-068, WorkWeek Management and O-ADM-225, On Line Risk Assessment and Management. Theinspectors also reviewed the effectiveness of the licensee's contingency actions tomitigate increased risk resulting from the degraded equipment. The inspectorsevaluated the following risk assessments during the inspection:*July 9, Unit 3 risk assessment when left side starting air for 3B emergency dieselgenerator was removed from service to replace the air tank relief while auxiliaryfeedwater valve MOV-3-1403 was removed from service for starter replacement.*August 1, Unit 3 risk assessment after failure of 3CD air compressor when thetemporary air compressor was disconnected to allow heavy loads on condensateroad.*August 9, Unit 4 risk assessment after the 4A CCW pump was declaredinoperable due to an empty outer bearing trico oiler identified on the pump.*August 14, risk assessment and management after 230 KV Lindgren line isolatedcausing Galloway tap breaker cycling (CR 2007-24504)

September 11, Unit 4 risk assessment and management when the Unit 3A 4160volt bus was removed from service for maintenance. The inspector also checkedstatus of switchyard work and its impact on the Unit 4 risk assessment.b.FindingsNo findings of significance were identified.1R15Operability Evaluations

a. Inspection Scope

For the four operability evaluations described in the CRs listed below, the inspectorsevaluated the technical adequacy of the evaluations to ensure that TS operability wasproperly justified and the subject component or system remained available such that nounrecognized increase in risk occurred. The inspectors reviewed the UFSAR to verifythat the system or component remained available to perform its intended function. Inaddition, the inspectors reviewed compensatory measures implemented to verify that thecompensatory measures worked as stated and the measures were adequatelycontrolled. The inspectors also reviewed a sampling of condition reports to verify thatthe licensee was identifying and correcting any deficiencies associated with operabilityevaluations.*CR 07-20863, Lubrication of the starter contacts for auxiliary feedwater steamsupply valve, MOV-3-1403*CR 2007-22670, 3A emergency diesel generator fuel oil leak between day tankand skid tank, the leak size was determined to be undetectable and the leak ratewas found to be less than one drop per week from a carbon steel mechanicalconnection. No cracking was found and there was no propagation mechanism. The licensee wrote work request 37008781 to tighten the mechanical fitting at thenext availability*CR 2007-24022, Oil level in 4A CCW pump outboard oiler found empty*CR 2007-23420, missing bolts on 4A CCW/ICW basket strainer

b. Findings

No findings of significance were identified.1R19Post Maintenance Testinga.Inspection ScopeFor the five post maintenance tests listed below, the inspectors reviewed the testprocedures and either witnessed the testing and/or reviewed test records to determinewhether 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 0-ADM-737, PostMaintenance Testing, were incorporated into test requirements. The inspectorsreviewed the following work orders (WO) and/or surveillance procedures (OSP):*Unit 3, WO 35018629, timed stroke test open and shut following MOV-3-843Agrease inspection,*Unit 4, WO 36024998-3, sealing of control room barrier electrical conduit 106F-355, done in accordance with licensee procedure 0-CME-016, Fire BarrierBreach and Closure,*Unit 3, WO 37005475, timed stroke open and shut following starter inspection onmotor operated valve, MOV-3-1403. Condition report CR2007-20730 wasreviewed by the inspectors. The report was written after the MOV failed to openduring a surveillance test following the maintenance,*Unit 3, WO 37014965, stroke open and close following starter contactreplacement on AFW steam supply valve MOV-3-1403, and*Unit 4, WO 37004782, leak check on ICW/CCW basket strainer BS-4-1403following annual preventive maintenance.b.FindingsNo findings of significance were identified.1R20Refueling and Other Outage Activities.1Unit 4 Short Notice Outagea. Inspection ScopeThe inspectors observed the licensee's Unit 4 outage activities for the short noticeoutage done to repair rod position indication connectors. In particular, the inspectorsobserved or reviewed the following outage related activities:*Outage risk management,*Reactor plant shutdown and cooldown per operating procedure 4-OSP-041.7,Reactor Coolant System Heatup and Cooldown Temperature Verification,*Licensee's boric acid corrosion walkdown inside containment,*Configuration control including reactor coolant system overpressure protection,*Readiness of containment sump for restart (foreign materials walkdown),*Reactor plant restart and return to power operations, and *Problem identification and resolution during the outage.

b. Findings

No findings of significance were identified.

.2 Unit 3 Refueling OutageFor the Unit 3 refueling outage that started on September 3, the inspectors evaluatedactivities as described below, to verify the licensee considered risk in developingschedules, adhered to administrative risk reduction methodologies, and adhered tooperating license and Technical Specification requirements that maintained defense-in-depth..2.01Review of Outage Plan

a. Inspection Scope

Prior to the outage, the inspectors reviewed the licensee's outage plan and riskmanagement activities. Licensee procedure O-ADM-051, Outage Risk Assessment andControl, and various maintenance schedules were reviewed to verify that the licenseehad performed adequate risk assessments and had implemented risk-managementstrategies as required by 10 CFR 50.65(a)(4).

b. Findings

No findings of significance were identified..2.02Monitoring and Shutdown Activities

a. Inspection Scope

The inspectors observed portions of the plant shutdown and cooldown in accordancewith FPL procedure 3-GOP-305, Hot Standby to Cold Shutdown, to verify that cooldownrestrictions and similar procedural requirements were followed and that other riskreduction activities were done in accordance with the licensee's plans and procedures.

b. Findings

No findings of significance were identified..2.03Licensee Controls of Outage Activitiesa.Inspection ScopeThroughout the outage, the inspectors observed the items or activities described below,to verify that the licensee maintained defense-in-depth commensurate with the outagerisk-control plan for key safety functions and applicable technical specifications whentaking equipment out of service:

Clearance and foreign material exclusion activities*Reactor coolant system instrumentation management*Configuration of electrical systems*Decay heat removal operations*Spent fuel cooling operations*Inventory management including controls to minimize any loss of inventoryevents*Reactivity controls*Containment closure as required by technical specificationsThe inspectors also reviewed the licensee's responses to emergent work andunexpected conditions, to verify that resulting configuration changes were controlled inaccordance with the outage risk control plan, and to verify that control-room operatorswere kept cognizant of the plant configuration.b.FindingsNo findings of significance were identified..2.04Reduced Inventory and Mid-loop Conditionsa.Inspection ScopeThe inspectors checked the licensee's preparations for reduced inventory operations,including ability to close the equipment hatch within time constraints, control of reactorparameters, including core exit thermocouples, procedure compliance for control ofreactor water level, and oversight of the drainage evolution. The licensee did not drainto the mid-loop condition during the outage.b.FindingsNo findings of significance were identified..2.05Refueling Activitiesa.Inspection ScopeThe inspectors observed fuel handling operations (removal and insertion) and otherongoing activities to verify that those operations and activities were being performed inaccordance with technical specifications and approved procedures. Also, theinspectors observed refueling activities to verify that the location of the fuel assemblieswas tracked, from core offload through core reload. Checks were made of foreignmaterial controls in vicinity of the open reactor vessel.

b. Findings

No findings of significance were identified..2.06Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed outage related items that had been entered into the licensee'scorrective action program to verify that the licensee had identified and resolvedproblems at an appropriate threshold. Specific activities reviewed included:*CR 2007-27481, Thermowell TE-3-420A/B water intrusion*CR 2007-27681, Overtime authorization for electrical departmentAdditionally, the inspectors reviewed the licensee's crane and heavy lift activities. Theinspectors reviewed Final Safety Analysis Report (FSAR) Appendix 5I and the designbasis documents related to control of heavy loads, and 10 CFR 50.59 PlantChanges/Modifications associated with the containment polar crane. The inspectorsnoted that the licensee had not done a heavy load analysis. The inspectors reviewedplant procedures 3-GMP-051.1, Reactor Polar Crane Inspection and PeriodicMaintenance, 0-ADM-717, Heavy Load Handling, and 0-GMM-043.8, Reactor VesselHead Lifting. The inspectors verified the licensee has a polar crane preventivemaintenance program in place, the vessel head lift procedures conform to heavy loadhandling commitments, a safe load path is in place, and crane operator training andqualifications meet ANSI B30.2-1976 standards. The inspectors observed the reactorvessel head lift and movement during the unit 3 outage to verify procedures werefollowed.

b. Findings

Introduction:

(No color) A Non-Cited Violation (NCV) of Technical Specification (TS)6.8.5 was identified by the inspectors when a blanket authorization was granted to theelectrical department allowing them to exceed the working hour guidelines for the plantstaff who perform safety-related functions.Description: On September 2, 2007 Unit 3 began its refueling outage. During review of the licensee's refueling outage activities on September 11, 2007, the inspectorsidentified that thirty-eight electrical maintenance personnel had been authorizedovertime by a blanket memorandum (Inter-Office Correspondence, Vice-PresidentTurkey Point, signed September 9, 2007). The inspectors noted that the memorandumauthorized workers to exceed the licensee's established limits for the duration of theoutage and had not been done in accordance the technical specification requirement forovertime management. The inspectors discussed this issue with licensee management

and the authorization was rescinded. Plant management stated that they did not intendto authorize overtime in excess of procedural guidelines for the duration of the outage. The inspectors reviewed TS 6.8.5 which requires administrative procedures that limitworking hours. Plant procedure QI I-PTN-1, Organization, implements the requirementand states the following overtime limits:1.No more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months worked in any 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period.2.No more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months worked in any consecutive 7 day period.3.At least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months break in between work periods.Any deviations from the working hour guidelines shall be authorized by an appropriatedepartment manager or higher level management, in accordance with establishedprocedures and with documentation stating the reason for granting the deviation. The Inter-Office Correspondence gave blanket authorization to exceed all of the statedlimits. The inspectors determined that this practice would be in violation of the technicalspecification because established procedures were not followed. NRC Generic Letter82-12, Nuclear Power Plant Staff Working Hours, specified limits on overtime and statedthat deviations from the limits were to be for "very unusual circumstances".Analysis: The inspectors concluded that blanket authorization for the electricaldepartment that covered the entire Unit 3 refueling outage period did not follow technicalspecification required procedures. This issue was evaluated using traditionalenforcement since it impacted the regulatory process in that the non-compliance withtechnical specification required processes was authorized at an executive level, whichcould become a more significant safety concern. The violation affected the MitigatingSystems cornerstone and was of very low safety significance because there were noactual adverse plant or equipment conditions identified that the licensee attributed tofatigue. When identified, action was taken to manage overtime in accordance with thelicensee's procedure and technical specifications. This violation is in the licensee'scorrective action program as CR 2007-27681.

Enforcement:

Turkey Point Technical Specification 6.8.5 requires that any deviationfrom working hour guidelines be authorized in accordance with established proceduresand that routine deviation from the guidelines shall not be authorized. The licenseeimplements this requirement using administrative procedures QI I-PTN-1, Organization,which provides the licensee's overtime limits and an individual form to be used fordeviation authorization from the limits. Contrary to the above, in an executive memorandum signed on September 9, 2007, a blanket overtime authorization (noindividual forms) was granted which allowed routine deviation from the overtime limitsduring the Unit 3 outage. When identified to the licensee by the inspectors, theauthorization was rescinded and the issue documented in the corrective action programas CR 2007-27681. Because this violation was of very low safety significance and hadbeen entered into the licensee's corrective action program, the issue is being treated as

a non-cited violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy:NCV 05000250/2007004-02, Inappropriate Blanket Overtime Authorization.1R22Surveillance Testinga.Inspection ScopeThe inspectors either reviewed or witnessed the following three surveillance tests toverify that the tests met the technical specifications, the FSAR, the licensee's proceduralrequirements and demonstrated the systems were capable of performing their intendedsafety functions. In addition, the inspectors evaluated the effect of the testing activitieson the plant to ensure that conditions were adequately addressed by the licensee staffand that after completion of the testing activities, equipment was returned to thepositions/status required for the system to perform its safety function. The inspectorsverified that surveillance issues were documented in the corrective action program.*Unit 4, 4-OSP-023.1, Diesel Generator Operability Test, Section 7.2, 4B EDGNormal Start Test*Unit 4, 4-OSP-206.1, Inservice Valve Testing - Cold Shutdown, Section 7.8 ,Fail-safe testing of POV-4-2600, 2601, 2602, and 2603. (IST, containmentisolation)*Unit 3, 3-OSP-023.1, Diesel Generator Operability Test, Section 7.2, 3B EDGNormal Start Testb.FindingsNo findings of significance were identified.1R23Temporary Plant Modificationsa.Inspection ScopeThe inspectors reviewed the temporary modification listed below to ensure that it did notadversely affect the operation of the affected systems. Design documentation, includingthe 10 CFR 50.59 screening and technical specifications were checked for properimplementation. The inspectors walked down the installation during plant tours anddiscussed system status with engineering and operations personnel. *Temporary System Alteration 07-15, Independent power supply for spent fuelcooling pump 3P212B from load center 4C

b. Findings

No findings of significance were identified.

Cornerstone:

Emergency Preparedness1EP6Drill Evaluation

.1 Emergency Preparedness Drilla.Simulator Based Emergency Drill Inspection ScopeOn July 12, 2007, the inspectors observed the licensee simulator based drill thatincluded evaluation of licensed operator event classification.

Results of the drill were used by the licensee as inputs into the Drill/Exercise Performance and EmergencyResponse Organization Drill Participation Performance Indicators. The simulationinvolved a Notice of Unusual Event declaration for steam generator tube leakage abovetechnical specification limits and an Alert for a steam generator tube rupture. TheTechnical Support Center and Emergency Offsite Facility were staffed after the AlertDeclaration in accordance with licensee procedures. Subsequently, a simulated loss ofoffsite power occurred driving the plant to a Site Area Emergency. The inspectorsobserved the Unusual Event and Alert classification and notifications in accordance withlicensee procedure 0-EPIP-20101, Duties of the Emergency Coordinator. At theconclusion of the drill, the inspectors discussed the drill with plant staff and noted thatlicensee identified problems were documented in the corrective actions program.

b. Findings

No findings of significance were identified.2.

RADIATION SAFETY

Occupational Radiation Safety (OS) Cornerstone2OS1Access Control To Radiologically Significant Areas

a. Inspection Scope

Access Controls: During the weeks of September 10, 2007, and September 24, 2007,licensee activities for controlling and monitoring worker access to radiologicallysignificant areas and tasks associated with the Unit 3, Refueling Outage 23 (U3R23)were evaluated. The inspectors evaluated changes to, and adequacy of proceduralguidance; directly observed implementation of established administrative and physicalradiological controls; appraised radiation worker and technician knowledge of andproficiency in implementing radiation protection activities; and assessed radiation worker(radworker) exposures to radiation and radioactive material.

The inspectors reviewed licensee procedures regarding access control to radiologicallysignificant areas. Selected procedural details for posting, surveying, and access controlto airborne radioactivity, radiation area, high radiation area (HRA), locked high radiationarea (LHRA), and very high radiation area (VHRA) locations were reviewed anddiscussed with cognizant licensee representatives. The inspectors evaluated radiationwork permit (RWP) controls and observed several work evolutions to assess HealthPhysics Technician (HPT) proficiency and radiation worker (radworker) practices. Theobserved work evolutions included removal of a steam generator hand hole cover, sumpmodifications, installation of robotic eddy current equipment into the steam generator,motor operated valve testing and repairs to a process monitor. Additionally the RWPsfor HPT support, seal table work, reactor disassembly and reactor cavitydecontamination were reviewed. The selected RWPs were assessed for adequacy ofaccess controls and specified electronic dosimeter (ED) alarm setpoints againstexpected work area dose rates and work conditions. The inspectors observed theradiation protection (RP) coverage being provided by the facilities remote monitoringfacility and interviewed the supervisor of the facility to determine the capabilities, amountof redundancy and contingencies in the event of loss of video, audio or telemetrycommunications or the loss of power. Access control procedures for posted LHRA andVHRA locations were reviewed and discussed with selected RP management,supervision, and technicians.During facility tours, the inspectors evaluated selected radiological postings, barricades,and surveys associated with radioactive material storage areas and radiologicallysignificant areas within the Unit 3 (U3) and Unit 4 (U4) reactor auxiliary building (AB)areas, U3 and U4 spent fuel pool (SFP) buildings, Radioactive Waste Processing facility,and the U3 reactor containment building (RB). The inspectors conducted independentdose-rate measurements at various building locations and work areas, and comparedthose results to licensee radiation survey map data. The inspectors independentlyassessed implementation of LHRA controls, and evaluated the adequacy of thelicensee's LHRA and VHRA key controls through procedural reviews, supervisoryinterviews, and facility tours.During the inspection, the proficiency and knowledge of the radiation workers and RPstaff in communicating and applying radiological controls for selected tasks wereevaluated. The inspectors attended RWP/ pre-job briefings for selected work activities. Radiological worker and RP technician training/skill levels, procedural adherence, andimplementation of RWP-specified access controls, including those associated withchanging radiological conditions, were observed and evaluated by the inspectors duringselected job site reviews and tours within the licensee's radiological control area. Inaddition, the inspectors interviewed selected management personnel regardingradiological controls associated with work activities.Radiation protection activities were evaluated against Updated Final Safety AnalysisReport (UFSAR) Section 12, Radiation Protection; TS Sections 6.8.1, Procedures, and6.12, High Radiation Area; 10 CFR 19.12; 10 CFR Part 20, Subparts B, C, F, G, H, and

J; and approved licensee procedures. The procedures and records reviewed are listedin section 2OS1 of the report Attachment.Problem Identification and Resolution: CRs associated with access control toradiologically significant areas, radiation worker performance, and RP technicianproficiency were reviewed and assessed. The CRs listed in the Attachment werereviewed and evaluated in detail during inspection of this program area. The inspectorsassessed the licensee's ability to identify, characterize, prioritize, and resolve theidentified issues in accordance with Florida Power and Light - Nuclear AdministrativeProcedure (NAP)-204, Condition Reporting, Revision 13.The inspectors completed 21 of the required 21 samples for Inspection Procedure (IP)71121.01.

b. Findings

No findings of significance were identified.2OS2 ALARA Planning and Controlsa. Inspection ScopeAs Low As Reasonably Achievable (ALARA). Inspectors reviewed ALARA programguidance and its implementation for ongoing U3R23 job tasks. The inspectorsevaluated the accuracy of ALARA work planning and dose budgeting, observedimplementation of ALARA initiatives and radiation controls for selected jobs in-progress,assessed the effectiveness of source-term reduction efforts, and reviewed historicaldose expenditure information. Projected dose expenditure estimates detailed in ALARA planning documents werecompared to actual dose expenditures, with noted differences discussed with cognizantALARA staff or job sponsors. Changes to dose budgets relative to changes in job scopeand emergent work also were discussed. The inspectors attended pre-job briefings andevaluated the communication of ALARA goals, RWP requirements, and industrylessons-learned to job crew personnel. The implementation and effectiveness of ALARA planning and program initiatives duringwork in progress were evaluated. The inspectors made direct field or closed-circuit-video observations of work activities involving sump modifications, steam generatormaintenance activities, weld overlay work, coatings refurbishment work, pressurizer andvalve maintenance activities. For the selected tasks, the inspectors evaluated radworkerand HPT job performance; extent of management oversight; individual and collectivedose expenditure versus percentage of job completion; surveys of the work areas,appropriateness of RWP requirements, and adequacy of implemented engineeringcontrols. The inspectors interviewed radworkers, job sponsors, and management

regarding understanding of dose reduction initiatives and their current and expected finalaccumulated occupational doses at completion of the job tasks. Implementation and effectiveness of selected program initiatives with respect to source-term reduction were evaluated. Shutdown chemistry program actions and cleanupinitiatives, and their effect on U3 RB and the U3 AB area dose rates were compared toprevious refueling outage trending data. The effectiveness of selected shieldingpackages installed for the current outage was assessed through reviews of surveyrecords and comparisons with observed dose rates. Cobalt reduction initiatives andtheir implementation for U3 valve maintenance and/or replacement activities wereevaluated and discussed with both ALARA and maintenance staff.The plant collective exposure history for calendar years (CY) 2004 through CY 2006,based on the data reported to the NRC pursuant to 10 CFR 20.2206 (c), was reviewedand discussed with licensee staff, as were established goals for reducing collectiveexposure. Dose rate trending data for selected in-plant monitoring points and/orequipment, e.g., steam generators, were reviewed and compared to data collected fromprevious U3 outages. The inspectors reviewed procedural guidance for, and examineddose records of declared pregnant workers to evaluate assessment and assignment ofgestation dose, as applicable.ALARA program activities and their implementation were reviewed against 10 CFRPart 20 and approved licensee procedures. In addition, licensee performance wasevaluated against Regulatory Guide (RG) 8.8, Information Relevant to Ensuring thatOccupational Radiation Exposures at Nuclear Power Stations will be As Low AsReasonably Achievable; RG 8.10, Operating Philosophy for Maintaining OccupationalRadiation Exposures As Low As is Reasonably Achievable; and RG 8.13, InstructionConcerning Prenatal Radiation Exposure. Procedures and records reviewed within thisinspection area are listed in Section 2OS2 of the report AttachmentProblem Identification and Resolution. Licensee CAP documents associated withALARA activities were reviewed and assessed. The inspectors evaluated the licensee'sability to identify, characterize, prioritize, and resolve the identified issues in accordancewith NAP-204, Condition Reporting, Rev. 13. The inspectors also discussed post-jobreviews with licensee supervisors and evaluated whether issues were appropriatelyentered in the CAP. Specific self-assessments and CR documents reviewed in detail forthis inspection area are identified in Section 2OS2 of the report Attachment.The inspectors completed 15 of the required line-item samples, and 5 of the optionalline-item samples detailed in IP 71121.02.b. FindingsNo findings of significance were identified.

Cornerstone:

Public Radiation Safety (PS)2PS1Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systemsa.Inspection ScopeCurrent licensee programs for monitoring, tracking, and documenting the results of bothroutine and abnormal liquid releases to onsite and offsite surface and ground waterenvirons were reviewed and discussed in detail. Recent changes to the Offsite DoseCalculation Manual (ODCM) regarding recently established groundwater monitoringwells, and any abnormal liquid releases and corrective actions including the status of10 CFR 50.75.g spill data were discussed with responsible licensee representatives. Inaddition, radioanalytical results from selected groundwater monitoring wells, man-holes,and surface drain samples collected from monitoring locations within the ownercontrolled area were discussed in detail. All tritium and gamm-emitting radionuclideconcentration results were significantly less that detection levels or below establishedODCM limits. Licensee current capabilities and routine surveillances to minimize andrapidly identify any abnormal leaks from liquid radioactive waste tanks, processing lines,and spent fuel pools were reviewed and discussed in detail. In addition, the inspectorsreviewed and discussed current licensee guidance for reporting any potential releases tooffsite groundwater environsThe inspectors completed the two of the specified radiation protection line-item samplesdetailed in IP 71122.01.b.FindingsNo findings of significance were identified.2PS2Radioactive Material Processing and Transportation

a. Inspection Scope

Waste Processing and Characterization. During inspector walk-downs, accessiblesections of the liquid and solid radioactive waste (radwaste) processing systems wereassessed for material condition and conformance with system design diagrams. Inspected equipment included liquid waste demineralizer skids; resin transfer piping;resin and filter packaging components; and abandoned distillate demineralizers. Theinspectors discussed component function, processing system changes, and radwasteprogram implementation with licensee staff.The 2006 Radioactive Effluent Report and radionuclide characterizations from 2005 -2007 for each major waste stream were reviewed and discussed with radwaste staff. For Primary Resin and Dry Active Waste (DAW) the inspectors evaluated analyses forhard-to-detect nuclides, reviewed the use of scaling factors, and examined comparison

results between licensee waste stream characterizations and outside laboratory data. Waste stream mixing and concentration averaging methodology for resinous waste wasevaluated and discussed with licensee staff. The inspectors also reviewed thelicensee's procedural guidance for monitoring changes in waste stream isotopicmixtures.Radwaste processing activities and equipment configuration were reviewed forcompliance with the licensee's Process Control Program (PCP) and Final SafetyAnalysis Report (FSAR), Chapter 11. Waste stream characterization analyses werereviewed against regulations detailed in 10 CFR Part 20, 10 CFR Part 61, and guidanceprovided in the Branch Technical Position on Waste Classification and Waste Form. Reviewed documents are listed in Section 2PS2 of the report Attachment.

Transportation The inspectors directly observed preparation activities for a shipment ofcontaminated laundry. The inspectors noted package markings and placarding,performed independent dose rate measurements, and interviewed shipping techniciansregarding DOT regulations. Five shipping records were reviewed for consistency with licensee procedures andcompliance with NRC and DOT regulations. The inspectors reviewed emergencyresponse information, DOT shipping package classification, radiation survey results, andevaluated whether receiving licensees were authorized to accept the packages. Forselected shipment records, the licensee's handling of Type B shipping casks wascompared to Certificate of Compliance (CoC) requirements. In addition, training recordsand training curricula for individuals currently qualified to prepare shipments ofradioactive material were reviewed.Transportation program implementation was reviewed against regulations detailed in10 CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178; as well as the guidanceprovided in NUREG-1608. Training activities were assessed against 49 CFR Part 172Subpart H. Documents reviewed during the inspection are listed in Section 2PS2 of thereport Attachment.Problem Identification and Resolution Selected CRs in the area of radwaste/shippingwere reviewed in detail and discussed with licensee personnel. The inspectorsassessed the licensee's ability to characterize, prioritize, and resolve the identifiedissues in accordance with licensee procedure NAP-204, Condition Reporting, Rev. 13. The inspectors also evaluated the scope of the licensee's internal audit program andreviewed recent assessment results. Documents reviewed for problem identification andresolution are listed in Section 2PS2 of the report Attachment.The inspectors completed 6 of the required samples specified in IP 71122.02.

b. Findings

Introduction:

The inspectors identified a Green Non-Cited Violation (NCV) of 10 CFRPart 71.5(a)(1)(v) for the failure to following DOT regulations found in 49 CFR Part172.201(d) that require shipping papers associated with the transport of radioactivematerial to contain an emergency response telephone number.

Description:

During a review of the records package for radioactive waste shipmentnumber 2006-059, the inspectors noted that the emergency response telephonenumber listed on the official shipping paper (NRC Form 540) was incorrect. Theemergency contact was listed as "control room", however the associated phone numberwas for an on-site facsimile machine. The licensee performed an extent of conditionreview and determined that the incorrect phone number had been entered into theshipping database in November 2006, and that all subsequent shipments of radioactivewaste contained the wrong contact number on the official shipping papers. Beginningwith waste shipment 2006-059, there were a total of 23 shipments made with theincorrect emergency response number.

Analysis:

The inspectors determined that this finding is a performance deficiencybecause licensees are expected to adhere to the regulations of 10 CFR Part 71 and thedeficiency was reasonably within the licensee's ability to foresee and correct. Thefinding is more than minor because it is associated with the Public Radiation Safetycornerstone attribute of Transportation Programs and Processes and adversely affectsthe cornerstone objective of ensuring adequate protection of public health and safetyfrom exposure to radioactive materials released into the public domain as a result ofroutine civilian nuclear reactor operation. The emergency response telephone numberon the official shipping paper must be accurate so that emergency responders canquickly contact knowledgeable licensee staff in the event of an accident on publicroadways. The finding was assessed using the Public Radiation Safety SignificanceDetermination Process (SDP). Based on the fact that emergency responserecommendations required by 49 CFR Part 172.602 were included in the paperworkpackage for each shipment and the fact that there were no accidents on public roadwaysthat would have required the use of the emergency response phone number, the findingwas determined to be of very low safety significance (Green). The inspectors noted thatthe licensee corrected the emergency response phone number in their shippingdatabase as part of the immediate corrective actions and thus helped to mitigate thepotential consequences of this issue. This finding has a crosscutting area of HumanPerformance with Work Practices aspect (IMC 305, H.4 (a)), because the incorrectemergency response telephone number was the result of a transposition error whichwas not prevented by the use of self and peer checking human error preventiontechniques.

Enforcement:

10 CFR Part 71.5 (a)(1)(v) requires licensees to comply with theapplicable requirements of the DOT regulations in 49 CFR Parts 107, 171 through 180. 49 CFR Part 172.201(d) requires shipping papers to contain an emergency response

telephone number. Contrary to this, from November 2006 until September 2007, 23shipments of radioactive waste were sent for processing/disposal without containing alegitimate emergency response phone number on the shipping papers. Because thefailure to comply with 10 CFR Part 71.5 was of very low safety significance and hasbeen entered into the licensee's corrective action program as CR 2007-28113, thisviolation is being treated as an NCV, consistent with Section VI.A of the NRCEnforcement Policy: NCV 50-250, 251/2007004-03: Failure to Include an AccurateEmergency Response Telephone Number on Radioactive Waste Shipping Papers.4.OTHER ACTIVITIES4OA1Performance Indicator VerificationInitiating Events and Mitigating Systems Cornerstones

a. Inspection Scope

The inspectors checked licensee submittals for the Unit 3 and Unit 4 PIs listed below forthe period July 1, 2006, through June 30, 2007, to verify the accuracy of the PI datareported during that period. Performance indicator definitions and guidance contained inNEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Rev. 4 andlicensee procedure 0-ADM-032, "NRC Performance Indicators Turkey Point," were usedto check the reporting for each data element. The inspectors sampled licensee eventreports (LERs), operator logs, plant status reports, CRs, and performance indicator datasheets to verify that the licensee had identified the cumulative safety systemunavailability and required hours, as applicable. The inspectors discussed the PI datawith licensee personnel associated with performance indicator data collection andevaluation.*Unplanned Scrams and Scrams with Loss of Normal Heat Removal (zero occurrences)*Unplanned Power Changes per 7000 critical hours*Safety System Functional Failures*Mitigating Systems Performance Indicators (MSPI) Emergency AC Power System*MSPI High Pressure Injection System*MSPI Heat Removal System*MSPI Residual Heat Removal System*MSPI Cooling Water Systems

b. Findings

No findings of significance were identified.

OA1Performance Indicator Verification

a. Inspection Scope

The inspectors sampled licensee data for the performance indicators (PIs) listed below,to verify the accuracy of the PI data reported during that period, PI definitions andguidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory AssessmentIndicator Guideline," Rev. 4, were used to screen each data element.Occupational Radiation Safety Cornerstone The inspectors reviewed the OccupationalExposure Control Effectiveness PI results for the Occupational Radiation SafetyCornerstone from January 1, 2006 through August 2007. For the assessment period,the inspectors reviewed electronic dosimeter alarm logs and CRs related to exposuresignificant area controls. The inspectors also reviewed licensee procedural guidancefor collecting and documenting PI data. Report section 2OS1 contains additionaldetails regarding the inspection of controls for exposure significant areas. Documentsreviewed are listed in sections 2OS1, 2OS2, 2PS2, and

4OA1 of the report Attachment.Public Radiation Safety Cornerstone

The inspectors reviewed the Radiological ControlEffluent Release Occurrences PI results for the period of January 1, 2006 throughAugust 2007. For the assessment period, the inspectors reviewed monthly andquarterly dose calculations to the public, out-of-service effluent radiation monitors,selected compensatory sampling data, and selected CRs related to RadiologicalEffluent Technical Specifications/Offsite Dose Calculation Manual issues. Theinspectors also reviewed licensee procedural guidance for collecting and documentingPI data. Documents reviewed are listed in section 2PS1 and

4OA1 of the reportAttachment. The inspectors completed the two specified radiation protection line-item samplesdetailed in IP 71151. 4OA2 Problem Identification and Resolution

.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 humanperformance issues for follow-up, the inspectors performed a screening of itemsentered daily into the licensee's corrective action program. This review wasaccomplished by reviewing daily printed summaries of condition reports and byreviewing the licensee's electronic condition report database. Additionally, reactorcoolant system unidentified leakage was checked on a daily basis to verify nosubstantive or unexplained changes.

b. Findings

No findings of significance were identified.

===.2 Annual Sample Review

a. Inspection Scope

The inspectors selected the following condition reports for detailed review anddiscussion with the licensee.===

The condition reports were reviewed to ensure that anappropriate evaluation was performed and appropriate corrective actions were specifiedand prioritized. Other attributes checked included disposition of operability, resolutionof the problem including cause determination and corrective actions. The inspectorsevaluated the condition reports in accordance with the requirements of the licensee'scorrective actions process as specified in NAP-204, Condition Reporting. Theinspectors reviewed the cumulative effects of the operator workarounds that were inplace to verify that those effects could not increase an initiating event frequency, affectmultiple mitigating systems, or affect the ability of operators to properly respond to planttransients and accidents. The inspectors also reviewed operator workarounds to verifythat the licensee was identifying operator workaround problems at an appropriatethreshold and entering them in the corrective action program.*CR 2007-16269, Alternate shutdown communications box internals missing*CR 2007-17324, Root cause evaluation for multiple rod position indicationfailures

b. Findings

Introduction:

The inspectors identified a Green finding of very low safety significanceinvolving FPL procedure NAP-404, Condition Reporting, in that FPL did not takecorrective actions to address recurring problems identified during testing of thealternate shutdown panel communication phones. As a result, the communicationsystem had not demonstrated satisfactory operation during routine surveillance tests fora number of years. During this period, the licensee was able to demonstrate that analternate radio communication system was available and could be used to assure thesafety function would be accomplished, if needed.Description: On May 27, 2007, operators were attempting to complete surveillance test3-OSP-300.4, Dedicated Alternate Shutdown Communications Operability Test, when itwas discovered that the communication headset and handset for the Unit 3 alternateshutdown panel was not in place and missing. Operators could not identify any openwork document, tagging, or out-of-service tracking for the missing equipment. Oninvestigation, the licensee found that the equipment had been removed for repair for

about three months after being found inoperable earlier in the year. When identified,the equipment was restored within a few hours. Subsequently, the inspectors initiated a review of licensee's testing of thecommunication equipment. No satisfactorily completed test was found going back to2001. The licensee entered this problem into the corrective action program asCR2007- 17682. A detailed review of testing and repairs done by the licensee foundthe following: Date Deficiency6/25/07U-3 Control room headset will not transmit.6/25/07U-3 Turbine deck headset cannot hear.6/25/07Cannot hear on U-3 AFW cage headset.6/25/07U-3 Low volume on horn speaker and headset in BAST room.6/25/07U-3 Horn speaker not working on RHR pump room mezzanine.6/25/07Horn not working in the U-3 RHR HX room.6/25/07U-4 Headset ear pieces fell of in 4B 4KV and 3B 4KV rooms.6/25/07U-4 RHR HX room speaker not working.6/25/07U-4 Volume for speaker and headset low in BAST.6/25/07U-3 3B 4KV room box was missing the headset connector.11/30/05The U-3 TSC headset not working during a walkthrough for training.11/16/05U-3&4 The TSC headsets did not work during a walkthrough fortraining.8/7/05U-3 TSC communications box not working. (WO 35017387 wasgenerated above after this WR was entered. The equipment failedagain and was fixed under this WO the second time.)8/7/05U-4 4B 4KV Box not working.8/7/05U-4 TSC communications box not working. (PWO 35017837 wasgenerated above after this WR was entered. The equipment failedagain and was fixed under this PWO the second time.)2/4/04U-3 3A 4KV Horn speaker not working.2/4/04U-3 Containment hatch missing headset jack.2/4/04U-3 TSC headset not working.2/4/04U-3 Aux building headset was not working.11-23-03Unit 3, missing headset jack, one speaker and two headsets do notwork The inspectors questioned the reliability of the communications system and wereinformed that hand held radios could be used by operators, if the installedcommunications system or any part of the system was not functional. The inspectorschecked the ability of radios to be used throughout the plant, and walked down theradio repeater system to verify its independence and power supply.Analysis: FPL procedure NAP-204, Condition Reporting, specifies that the Station IssueTracking and Information System (SITRIS) shall be used to document and resolve

conditions adverse to quality, including issues within the purview of regulatoryprograms. The alternate shutdown system is specified by 10 CFR 50, Appendix R. The licensee's failure to identify and correct repeated reliability problems with theremote shutdown communications equipment was a noncompliance with the licenseeprocedure and was a performance deficiency in the Mitigating Systems cornerstone. The finding was more than minor because it affected the availability and reliability of thecommunications system designated for use in licensee procedure 0-ONOP-105,Control Room Evacuation. The finding was only of very low safety significancebecause redundant communications equipment (radios) were available during periodswhen the designated communication equipment was nonconforming, and the radioscould be used with the operable alternate shutdown equipment to safely shutdown thereactor plant. The cause of the finding is related to the cross-cutting area of problemidentification and resolution because the adverse trend of problems with alternateshutdown communications had not been identified nor corrected commensurate with itssafety significance (IMC 305, P.1(d)).Enforcement: No violation of regulatory requirements occurred. The inspectorsdetermined that the non-conformances and their resolution although specified by thelicensee to be documented in accordance with licensee procedure, NAP-204,Corrective Actions, were not required by regulations because fire protection equipmentis not covered by 10CFR50, Appendix B requirements. The licensee entered this issueinto the corrective actions program as CR 2007-17682. This issue is being attached as(FIN) 50-250,251/2007004-04: Recurring Problems with Alternate ShutdownCommunication Equipment.4OA3Event Follow-up.1 (Closed) Licensee Event Report 50-250/2007-002-00, Completion of ShutdownRequired by Technical Specifications due to Inoperable Rod Position Indication for TwoControl Rods in the Same Control Bank (Closed) Unresolved item (URI) 50-250&251/2007-03-03 Incorrect ConnectorComponents Cause Inoperability of Multiple Rod Position Circuits On September 1, 2006, the rod position indication for control rod M-6 in Control Bank Cwas declared inoperable due to erratic oscillation above and below the actual rodposition. Similarly, the rod position indication for rods G-5 and E-5 in Control Bank Aand Shutdown Bank B were declared inoperable on May 1, and June 2, 2007,respectively. On June 6, the RPI for control rod F-4 in Control Bank C became erratic,operators declared the rod inoperable, Technical Specification 3.0.3 was entered, andUnit 3 was shutdown to Mode 3.

The inspectors observed the reactor shutdown andevaluated operator response to the failed RPIs. The inspectors also monitored thelicensee investigation and determination of root cause. The licensee found that cableconnectors in the rod position indication circuit contained neoprene inserts, which werenot capable of retaining physical properties in the high temperature reactor

environment. The neoprene inserts inspected by the licensee for the affected circuitswere discolored and degraded indicating breakdown of the neoprene. The degradedneoprene was found to be conductive and corrosive. The connectors were located atthe top of the reactor pressure vessel coil stacks, a high temperature, high radiationarea during reactor operation. The licensee subsequently learned that an error duringprocurement of the cable connectors led to use of neoprene instead of an appropriatesilicone insert. All of the affected connectors were removed and replaced with qualifiedsplices. The licensee continued to evaluate various programmatic improvements toprevent procurement problems from recurring in CR 2007-17324. The LER and theunresolved item are closed. Findings are discussed below:

b. Findings

Introduction:

A Green Self-Revealing NCV was identified when the licensee did notappropriately specify and procure connectors to be used in rod position indicationcircuitry in the high temperature, high radiation environment atop the reactor head. Asa result, Unit 3 was shutdown after entering Technical Specification 3.0.3, for multipleinoperable rod position indication circuits. Later, Unit 4 was preemptively shutdown toremove the improper materials.Description: On June 6, Turkey Point Unit 3 was operating at 100% power whenoperators observed that the rod position indication for control rod F-4 was oscillatingabove and below 218 steps. After investigation that included verification that the rodwas it its correct 218 step position, the RPI was declared inoperable. Because the RPIfor control rod M-6, in the same group had been inoperable since September 1, 2006,operators entered Technical Specification 3.0.3 and initiated a plant shutdown to Mode3. At the time of the shutdown, additional RPIs for rods G-5 and E-5 were inoperabledue to erratic behavior and were being compensated as required by technicalspecifications. On investigation the licensee found that an improper insert was used in RPI circuitconnectors located at the top of the reactor pressure vessel. The improper insert,neoprene, was not designed to withstand the high temperatures and operating reactorradiation which caused the neoprene to breakdown and create a corrosive andconductive environment that ultimately resulted in failed rod position indication. Theproper insert had not been used due to faulty procurement during the reactor pressurevessel head replacements for Units 3 and 4 in 2004 and 2005 respectively.

Analysis:

Because neoprene could not withstand the operating plant high temperaturesand radiation, use of the material in the quality related rod position indication circuitswas a performance deficiency. The finding was more than minor and affected theMitigating Systems cornerstone because its use caused faulty rod position indicationwhich challenged the ability of operators to mitigate rod misalignments and failure of therods to insert on a trip (faulty rod bottom indication). The finding was only of very lowsafety significance because redundant indication of rod misalignment or indication offailure of the rods to insert would be available from both the incore and excore nucleardetection systems.

The inspectors noted that the failed indications and reactor shutdown of Unit 3 had anadditional consequence that use of the boric acid inventory to assure unit 3 shutdowndepleted the acid available for Unit 4, if it had been needed in an emergency. Duringthe period of depleted acid inventory, operators appropriately implemented technicalspecification tracking and the inventory was restored prior to action statementexpirations. Emergency injection of boric acid is used for reactivity excursion eventsincluding multiple stuck rod occurrences. The inspectors determined that this findinghad no cross-cutting aspect.Enforcement: 10 CFR 50, Appendix B, Criterion IV, Procurement Document Control,states, in part, that measures shall be established to assure that adequate quality isincluded in documents for the procurement of equipment. FPL implements thisrequirement, in part, by implementing quality instruction, QI 4-PTN-1, ProcurementControl, which states, in part, that when determining ordering requirements, appropriatedesign requirements shall be used. Contrary to the above, appropriate designrequirements were not used in ordering connectors to be used in the Unit 3 and Unit 4replacement rod position indication circuitry. Instead, procurement documents alloweda neoprene insert to be used in the connectors which was not suitable for theapplication and eventually caused failure of multiple rod position indications. Theviolation existed from the time of application during reactor head replacement outagesin 2004 and 2005, until the connectors were removed from the circuits and replaced bysplices during unit outages in 2007.

Because the failure to appropriately procureconnectors was of very low safety significance, and had been entered into thelicensee's corrective actions program as CR 2007-17324, this violation is being treatedas a Non-Cited violation consistent with Section VI.A of the NRC Enforcement Policy. NCV 50-250,251/2007004-05: Failure to Appropriately Procure Replacement PartsLeads to Reactor Shutdown..2 (Closed) Unresolved Item 05000250,251/2007-03-04, Availability and Functionality ofUnit 3 and Unit 4 Alternate Shutdown SystemsThe unresolved item was issued after the inspector questioned the functionality of thealternate shutdown communications system. The licensee provided information thatdemonstrated that an alternate radio communications system was available and couldbe used by plant operators for alternate shutdown, if needed. A finding related to thisissue is documented in Section

4OA2 of this report.

The unresolved item is closed.4OA5Other ActivitiesTI 2515/166 Pressurixed Water Reactor Containment Sump Blockage (NRC GenericLetter 2004-02)

a. Inspection Scope

The inspectors reviewed Unit 3 implementation of commitments documented in theirSeptember 1, 2005, response to Generic Letter 2004-02, Potential Impact of DebrisBlockage on Emergency Recirculation During Design Basis Accidents at PressurizedWater Reactors. Areas reviewed included: Permanent modification of the ContainmentRecirculation Sump to include a large-area, complex geometry passive strainer

assembly including a cross connect under the fuel transfer canal between the Northand South containment sumps as well as replacement of fibrous and particulateinsulation with reflective metal insulation. The inspectors reviewed the corresponding Modifications Packages (PC/Ms), and theircorresponding 10 CFR 50.59 evaluations. The inspectors conducted a visual walkdownto verify the installed sump strainer assembly configuration and that insulationreplacements were consistent with drawings and specifications provided in themodifications packages.

b. Findings and Observations

No findings of significance were identified.

The inspectors determined the following answers to the Reporting Requirementsdetailed in TI 2515/166-05 issued 5/16/07:05.aFPL implemented plant modifications and procedure changes at TurkeyPoint committed to in their GL 2004-02 response for Unit 3. A list ofmodifications for Turkey Point 3 is in the attachment to this report.05.bFPL updated the Turkey Point 3 licensing bases to reflect the correctiveactions taken in response to GL 2004-02.05.cNo extensions of 12/31/2007 deadline for GL 2004-02 commitmentcompletions have been applied for or granted to Turkey Point Unit 3. Turkey Point Unit 4 has received an extension and will complete its GL2004-02 committed modifications and procedural changes during theSpring 2008 Refueling Outage.TI 2515/166 will remain open until December 31, 2007 for Turkey Point Unit 3 whileongoing chemical effects testing to validate the design are being performed.4OA6ExitExit Meeting SummaryThe resident inspectors presented the inspection results to Mr. Jefferson and othermembers of licensee management on October 18, 2007. The inspectors asked thelicensee whether any of the material examined during the inspection should beconsidered proprietary information. The licensee did not identify any proprietaryinformation.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Antignano, Fire Protection Supervisor

J. Alvarez, Acting Corrective Actions Supervisor

R. Barnes, Training Manager

G. Hettel, Maintenance Manager

J. Connolly, Interim Licensing Manager

R. Hughes, Acting Engineering Manager

D. Hoffman, Operations Superintendent

W. Jefferson, Site Vice-President

E. Lyons, Engineering (BACC)

R. Pell, Acting Operations Manager

K. O'Hare, Radiation Protection and Safety Manager

M. Pearce, Plant General Manager

W. Pravat, Work Controls Manager

D. Sluszka, Radiation Protection Manager

G. Warriner, Emergency Preparedness Manager

W. Webster, Senior Vice President, Operations

NRC personnel

S. Vias, Chief, Branch 3, Division of Reactor Projects

R. Torres, NRC Nuclear Safety Professional Development Program

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSEDOpenTemporary Instruction (TI) 2515/166Pressurized Water Reactor Containment Sump Blockage(NRC Generic Letter 2004-02) Unit 3 (Section 40A5)

Opened and Closed

050000250,251/2007004-01NCVFailure to Perform Required ASME Code SectionXI Leakage Testing (Section 1R08).05000250/2007004-02 NCVInappropriate Blanket Overtime Authorization.(Section IR20)050000250, 251/2007004-03NCVFailure to Include an Accurate EmergencyResponse Telephone Number on RadioactiveWaste Shipping Papers (Section 2PS2).0500000250,251/200704-04FINRecurring Problems with Alternate ShutdownCommunication Equipment. (Section 4OA2)

A-2Attachment05000250,251/2007004-05 NCVFailure to Appropriately Procure ReplacementParts Leads to Reactor Shutdown. (Section 4OA3)

Closed

050000250/2007002-00LERCompletion of Shutdown Required by TechnicalSpecifications due to Inoperable Rod Position Indication for Two Control Rods in the SameControl Bank (Section 4OA3)050000250,251/200703-03 URIIncorrect Connector Components CauseInoperability of Multiple Rod Position Circuits(Section 4OA3)05000250,251/200703-04 URIAvailability and Functionality of Unit 3 and Unit 4Alternate Shutdown Systems (Section 4OA3)

Attachment

LIST OF DOCUMENTS REVIEWED

Section 1R08: Inservice Inspection ActivitiesProceduresNDE 5.4, "Ultrasonic Examination of Austenitic Piping Welds," Revision 17

NDE 3.3, "Liquid Penetrant Examination Solvent Removable - Visible Dye Technique,"Revision 9NDE 5.1, "Ultrasonic Examination of Pressure Vessel Welds," Revision 11

54-ISI-24-30, "Written Practice for Personnel Qualification in Eddy Current Examination,"Revision 12/14/0654-ISI-400-15, "Multi-Frequency Eddy Current Examination of Tubing," Revision 7/17/06

51-5022683-05, "Turkey Point Unit 3 and 4 Eddy Current Data Analysis Guidelines, Fall 2007,"Revision 6/15/07Welding Procedure Specification - 43, Revision 11

0-OSP-041.26, "Containment Visual Leak Inspection," Revision 6/28/2007

0-ADM-537, "Turkey Point Nuclear Plant, Boric Acid Corrosion Control Program Procedure,"Revision 10/20/2006Corrective Action DocumentsCR 2006-8035CR 2007-18169CR 2007-16766CR 2007-27546CR 2007-28338CR 2006-8621CR 2004-12917CR 2006-9040CR 2007-20760CR 2007-27751CR 2007-27654CR 2007-28134CR 2007-29183

CR 2007-29036CR 2007-29298

CR 2007-29337Other RecordsPT Examination Reports: 3.3-004, 3.3-005, and 3.3-006

UT Examination Reports: 5.4-002, 5.4-001, and 5.1-001

Certification for PT Examination Consumables: Batch No. 05L17k, 04C15K, and 90J046

A-4AttachmentCertification for UT Examination Couplant: Batch No. 01225NCertification for UT Transducers: 00X6D8 and 00X6DC

Fabrication Drawings for Calibration Blocks:

UT-27 and UT-41

Welding Procedure Qualification Records: PQR N335, Revision 0; PQR 8.8-4; PQR 8.8-3,PQR N140, Revision 0; and PQR N334, Revision 0

Certified Material Test Reports for Welding Filler Metal UTC Nos.

460927 and 465675UT Instrument Linearity Record for Instrument Sonic 136/Serial No. 136P1200E081441

Work Order

36008818-01, "3"-RC-2501R-22 Piping, Pressurizer PORV Block Valve

MOV-3-535"Work Order

36007812-02, "SI to Loop C Cold Leg Check Valve" Turkey Point Unit 3 Cycle 22 System Pressure Testing Final Report for Refueling Outagedates: 3/6/06-5/10/06Boric Acid Corrosion Control Program Quick Hit Self Assessment Plan and Report for Perioddates: 7/1/07-7/31/07CSI-NDE-07-006, "Turkey Point Unit 3

EOC-22 - Eddy Current Examination ImplementationPlan for Steam Generator Tubing," Revision 0PTN-ENG-SES J-07-018, "Degradation Assessment for Turkey Point Unit 3 and 4 SteamGenerators, Update for the Turkey Point Unit 3 End-of-Cycle 22 Refueling Outage," Revision 0ENG/CSI-NDE-99-051, "Turkey Point Units 3 and 4 Steam Generator Secondary Side IntegrityPlan," Revision 851-5029214-07, "Qualified Eddy Current Techniques for Turkey Point (PTN) Units 3 and 4,"Revision 7PTN-ENG-SES J-05-006, "Condition Monitoring and Operational Assessment for the TurkeyPoint Unit 3 Steam Generators Based on Eddy Current Examination, End of Cycle 20, October2004," Revision 051-5002881-00, "Appendix H Equivalency, MRPC Exams Probe Extensions, Cable Length andMotor Unit Length," Revision 0 51-500-1223-00, "Appendix H Equivalency Cable Lengths," Revision 0

51-5014354-00, "Eddy Current Probe Extension Cable Comparison," Revision 0

ETSS No. 1 - Bobbin Standard ASME Code Examination, Revision 0

A-5AttachmentETSS No. 2 - MRPC TTS and Special Interest, Revision 0ETSS No. 3 - Low Row U-bend MR Plus Point exam and Special Interest, Revision 0

Data Analysis Personnel Qualification Records for Primary and Secondary Analysts, Primaryand Secondary Resolution Analysts, and Qualified Data AnalystsInstrument Calibration Certificates for Eddy Current Testers, Model MIZ-80iD

Certificate of Conformance for ECT probes 680PP and 720UL

Section 2OS1: Access Controls to Radiologically Significant AreasProcedures, Manuals, and Guidance Documents0-Administrative Procedure (ADM)-038,

PTN Industrial Diving Operations, 08/31/050-ADM-604, Radiological Protection Guidelines and Practices, 02/28/07C0-Health Physics Administrative Procedure (HPA)-021, Radiation Protection Restricted Area

Key Control, 08/03/060-HPA-031, Personnel Monitoring of Internal Dose, 04/09/070-HPA-031.2, Multibadge Exposure Monitoring, 09/26/06C0-Health Physics Surveillance Procedure (HPS)-020, Radiation Surveys, Dated 08/07/00C0-HPS-021, Surface Contamination Surveys, 04/24/070-HPS-022, Airborne Contamination Surveys and Remote Containment Air Sampling,

04/09/070-HPS-025.1, General Posting Requirements for Radiological Hazards, 10/24/060-HPS-025.2, Posting and Survey Requirements for Fuel Movement, 03/21/070-HPS-053.6, Postings and Controls for Resin Transfers, 04/10/07C0-HPS-055, Steam Generator Radiation Protection Work Controls, 03/21/070-HPS-104, Radiography Operations, 08/16/050-HPS-105, Surveys for Chemical Crud burst and Cleanup of the Reactor Coolant System (RCS), 10/23/060-HPS-106, Survey & Posting Guidelines for Plant Evolutions, 04/08/05Licensee Records and DataIntake Evaluation For Ingestion on 3/15/06Memo to file: Diver Exposure Considerations from Tritium Exposure, Dated 3/6/2007Summary of Internal Doses of Divers from Tritium Exposure, Covering period of 11/2-16/2006HP-301.1-5,8, Various Checklists for draining or refilling Corrective Action Program (CAP) DocumentsQAO-PTN-06-005, Chemistry and Effluents Audit, June 20, 2006

PTN-07-03, Radiation Protection Functional Area Audit,

April 30, 2007

06-0003, PTN Nuclear Assurance Quality Report, 2006 Radiological Work Permit Reviews,

01/09/0606-0030, PTN Nuclear Assurance Unit 3 Quality Report, Radiological Controls For Unit 3

Cycle 22 Refueling Outage, 04/27/0606-0072, PTN Nuclear Assurance Quality Report, Unit 4 Cycle 23 Refueling Outage (U4R23)

Radiation Protection, 12/19/06

A-6Attachment07-0010, PTN Nuclear Assurance Quality Report, Radiation Protection And RW TrainingProgram, 02/28/07 07-0013, PTN Nuclear Assurance Quality Report, External Radiation Dose Control, 02/28/0707-0032, Nuclear Assurance Quality Report, ODCM - Radioactive Effluent Releases,

05/23/07CR 2006-7095, Shielding could not be installed as planned.CR 2006-8469, Work Created a Physically Restricted (Narrow) Walkway in Unit 3

Containment

CR 2006-10655, Electronic Dosimeters in Multiple Extremity

Dosimetry Packs Not Turned

On.CR 2006-22755, Hotspot Discovered During Survey of a Posted High Radiation AreaCR 2006-23127, Untimely Survey of Dewatered HICCR 2006-31441, Worker Briefed Using a Survey From Previous Day In Which Conditions Had

Changed.CR 2006-31649, Administrative Key Issue Problem

CR 2007-2308, Improper Software Classification

Section 2OS2: As Low As Reasonably AchievableProcedures, Instructions, and Guidance Documents0-Administrative Procedure (ADM)-602,

ALARA Program, 02/09/06C0-Nuclear Chemistry Operating Procedure(NCOP)-001.1, Primary Chemistry Control During

Shutdown, 06/27/070-Health Physics Procedure (HPA)-072, Installation, Control, and Removal of Permanent and

Temporary Shielding, 04/07/03CSpecification (SPEC)-C-003, Lead Shielding Installation, Turkey Point Units 3 & 4, Rev. 2

U3R23RP Pre-Outage PlanRecords and Data Reviewed2007 U3 Refuel Outage, ALARA Report, 09/10-14/07 and 09/24-282007 U-3 R23 Outage Dose Reporting by RWP; 09/10-14/07 and 09/24-28 Major Job Comparison U3 R23 (estimate), U3 R22 by RWP, 09/11/07ALARA Review Number (No.) 2007-011, Pressurizer Relief Tank (PRT) Asbestos Abatement,08/24/07ALARA Review N0. Containment Coatings, 09/05/07ALARA Review No. 2007-013, Emergency Sump ModificationALARA Review No. 2007-015, Reactor Coolant Pump (RCP) Bowl Insulation Removal/Installation, 08/24/07ALARA Review No. 2007-021, Steam Generator Bundle Flush, Sludge Lance, and FOSAR during the U3 refueling outage, 08/20/07ALARA Review No. 2007-022, Valve Maintenance in U3 during the U3R23RFO, 08/24/07ALARA Review No. 2007-024, Insulation Removal and Installation in U3 Containment duringthe U3R23RFO, 08/20/07ALARA Review No. 2007-025, Scaffold Installation and Removal in Unit 3 Containment during the U3R23 RFO,

RWP-2007-3012, 08/20/07ALARA Review No. 2007-027, Remove and Replace all Three S/G Strongbacks andDiaphragms, RWP No. 2007-3072, 08/20/07ALARA Review No. 2007-028, Eddy-current testing of all three S/Gs, Includes RP Surveysand Job Coverage, Shield Door Installation and Removal, QC Inspections, and Nozzle

A-7Attachment

Cover Installation and Removal, RWP No. 2006-4075, 08/20/07ALARA Review No. 2007-029, Remove Replace the Support Pins (Split Pins), 08/20/07 ALARA Review Board Meeting Minutes, 08/20/07; Split Pins (2007-029), Insulation (2007-024) Scaffold (2007-025, and Steam Generators (20070021, -028, -029)ALARA Review Board Meeting Minutes, 08/24/07; PRT Asbestos Abatement (2007-011),Sump Modification (2007-013), Core Bore (2007-014), RCP Insulation (2007-015), AND

Valves (2007-022)ALARA Review Board Meeting Minutes, 09/05/07; Containment Coatings and Annual Reviewof Radworker Training and Effectiveness,

U3

EOC 22, Steam Generator Activities, Pre-Job Exposure Estimate, 07/25/07Temporary Shielding Request (TSR) Number (No.) 2007-24, Reactor sump mod core bore hole fuel movement, 09/03/07TSR No. 2007-25, U3 Containment 14', Install Temporary Lead Sheilding in Cavity DrainValve Area, 09/08/07 TSR No. U3 Containment 14' Pressurizer Line Shielding, in accordance with

SPEC-C-003,09/09/07Unit 3 (U3) Crud Cleanup Trend U3R23 2007Unit 3 (U3) Crud Cleanup Trend U3R22 2006SFP Activity, 12/14/05-08/06/07Drawing No. 5610-M-900-3, Pressurizer Safety Relief Valve

RV-3-551A,B,&C;

RV-4-551A,B,&C, Rev 2 & Rev. 5Drawing No. 6610-M-900-3, Y-Globe Valve, Full Port Socket Ends

SS 14' IMP TEE Non-Cobalt TH'D Backseat Size: 2' CL:1878 Declared Pregnant Worker Log Sheets and Supporting Dosimetry Documents, NovemberNovember 2005 through September 2007HP Survey Log No. 07-4935, U3 Steam Generator A, 09/12/07HP Survey Log No. 07-4922, U3 Steam Generator B, 09/12/07HP Survey Log No. 07-4890, U3 Steam Generator A, 09/12/07HP Survey U3 Steam Generator A, 10/05/04HP Survey U3 Steam Generator B, 10/05/04HP Survey U3 Steam Generator C, 10/05/04CAP DocumentsQuality Assurance Audit

PTN-07-03, Radiation Protection Functional Area Audit, 04/30/07CR2006-7095, Engineering specification C-003 Does Not Allow Hanging Temporary Shielding on the Pressurizer Spray Lines at the Top of the Pressurizer and on 455A/B at the Same

Time, 03/09/06CR 2006-32447, A Steam Generator Manway Removal Delayed Due to Misplaced Shield

Doors, 11/08/06CR 2006-33757, WHT Sludge Limits Processing of Radwaste and Increased /changeout of

Inlet Filters Added to Doses Received by Personnel Processing, 11/17/06CR 2007-7136, Containment Briefing Enhancement, 03/09/07CR 2007-12498, ALARA Review Paperwork is not Consistently Documented in RWP

Packages as Required, 04/25/07CR 2007-14390, Abandoned Plant Equipment is Causing Unnecessary Exposure, 05/09/07

A-8Attachment

Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and MonitoringSystemsProcedures, Instructions, and Guidance Documents0-ADM-115, Notification of Plant Events, 09/11/070-NCAP-103, Secondary Radiochemistry Sampling and Analysis, 06/07/06Records and Data ReviewedPTN - Tritium Summary Results, April 2006 - May 2007Tritium Activity Calculation Worksheet, Manhole Sample Results, 09/27/07

CAP DocumentsCR 2006-13488, Sampling man holes in the RCA, 05/03/06CR 2006-17093, Implementation of Industry Initiative on Inadvertent Releases intoGroundwater, 05/10/06CR 2006-17607, Implementation of NEI Institute Industry Initiative on Managing Situations

Involving Inadvertent Radiological Releases into Groundwater, 06/07/06CR 2006-18007, Radioactive containments and drain on RWST recirc pumps and sampling system inadequate to prevent contamination of ground.

Potential source for ground water contamination, 06/12/06CR 2006-21168, Ground-water contamination due to undetected leakage of radioactive water,

07/20/2006CR 2007-00721, Equipment deficiency causing contamination at the RWST pump area,01/09/07CR 2007-3306, Back leakage of radioactive water into abandoned equipment

NP-922,02/02/07CR 2007-30281, Tritium samples of manholes in the RCA not being performed when water is found in the manholes, 09/26/07

Section 2PS2: Radioactive Material Processing and TransportationProcedures, Instructions, and Guidance Documents0-HPS-040.7, Marking, Labeling and Placarding for Radioactive Waste/Material Shipments,

9/22/040-HPS-040.8, Radioactive Waste/Material Surveys for Shipments, 9/22/040-HPS-044.2, Characterizing Radioactive Material/Waste for Transport, 11/21/050-HPS-044.9, Radioactive Material/Waste Shipment Documentation, 11/21/05

Nuclear Training Department Lesson Plan No.

2402080, Radioactive Material Shipping,

3/7/070-HPA-045, Process Control Program, 11/20/02NAP-204, Condition Reporting, Rev. 13Records and Data ReviewedShipment 2005-055, Dewatered filters, 6/2/05Shipment 2005-081, Primary resin, 7/13/05Shipment 2005-101, High-rad trash, 9/9/05Shipment 2006-059, Core exit thermocouple waste spools, 11/16/06Shipment 2007-011, Refueling outage equipment, 3/12/07

10 CFR Part 61 Radioactive Waste Stream Analysis Reports, DAW, 10/31/04 and 3/28/06;

A-9Attachment

Primary Resin, 6/9/06; Resin, 11/8/062006 Annual Radioactive Effluent Release ReportNew York State Department of Labor Radioactive Materials License No. 2684-3943, 7/22/04Torque Wrench Calibration Data Sheet, M779, 8/10/05CoC No. 9168, Model No. CNS 8-120B Shipping Package, Rev. 15CAP DocumentsCR 2006-9123, Rad trash bags <1 mrem/hr found in "Green Is Clean" sealand, 03/24/06CR 2006-19158, New resin storage cask does not have the required lifting beam, 06/19/06CR 2006-34270, Steel radwaste liner was deformed upon receipt at Studsvik, 11/22/06CR 2007-7629, Administrative discrepancies found between PCP and FSAR requirements,

3/15/07CR 2007-15609, Shipment receipt survey not performed in a timely manner, 05/18/07CR 2007-28133, Radwaste shipments did not contain an accurate emergency response number on the official shipping papers, 09/12/07PTN-07-03, Radiation Protection Functional Area Audit, 04/30/07WMG 07-090-RE-081, Independent Assessment of 10

CFR 61 Compliance and Radioactive

Materials Shipping Program, August 2007

Section 4OA1: Performance Indicator VerificationRecords and Data ReviewedCAP DocumentsCR 2006-4100,

R-3-18 Out of Service, 02/13/06CR 2006-8065, Early termination of 'B' Monitor Tank Release, 03/15/06CR 2006-8084, Count rate increased during liquid release to warning level, 03/16/08CR 2006-8462, PRMS radiation Monitor R-3-18 declared inoperable, 03/18/06CR 2006-00396, Radioactive gas release during VCT purge, 01/06/06CR 2006-5948, High than expected dose rates in U3 Emergency Escape Hatch, 02/28/06Gas Gamma Beta Dose Summary Sheets, December 2006, and August 2007Iodine Dose Summary Sheets, December 2006, and August 2007Liquid Dose Summary Sheets, December 2006, and August 2007Plant Modification Packages (4OA5)PC/M 06-030, Containment Recirculation Sump Debris

GSI-191 Resolution, Rev. 0PC/M 06-075, Containment Recirculation Sump Cross-Connect Core Bore, Rev. 1PC/M 07-006, Reactor Coolant Pump & Pressurizer Surge Line Insulation Replacement, Rev. 0

AttachmentStatus of

GL 2004-02 Commitments for Turkey Point 3GL 2004-02 REQUESTACTIONS IMPLEMENTEDSTATUSGL 2004-02 Request2(b)-AA generaldescription of animplementation schedulefor all corrective actions,including any plantmodifications that youidentified whileresponding to thisgeneric letter.@To date FPL has implementedthree PC/Ms at Turkey Point 3 tocomply with

GSI-191, including:*06-030, AContainmentRecirculation SumpDebris

GSI-191Resolution@*06-075, AContainmentRecirculation SumpCross-Connect CoreBore@*07-007, AReactor CoolantPumps and PressurizerSurge Line InsulationReplacement@These three PC/Ms are scheduled to becompleted during the current outage

PTN3-23 (Fall 2007).

As of 9/24/2007 PC/M 06-030is approximately 90% field installationcomplete (Remainder to be completed by10/1/2007) while 07-006 and 06-075 are100% complete in the field with papercloseout in progress.GL 2004-02 Request2(f)- AA description of theexisting or plannedprogrammatic controlsthat will ensure thatpotential sources ofdebris introduced intocontainment (e.g.,insulations, signs,coatings and foreignmaterials) will beassessed for potentialadverse effects on theECCS and CSSrecirculation functions.@Turkey Point 3 and 4 have anaggressive program that ensuresthe materials in the containmentbuilding remain within the boundsof the

GSI-191 analysis.

Thisincludes detailed cleanliness anddebris inspections, controls oninsulation and coatings work, andengineering design controlprocedure, including:*0-ADM-730, ForeignMaterials ExclusionControls*QI 2-PTN-4Housekeeping*0-SMM-051.3,Containment CloseoutInspection*0-SMM-050.1ContainmentRecirculation SumpScreen Inspection*SPEC-M-068, ThermalInsulation at Turkey Point Units 3 & 4*0-ADM-701.1, DesktopInstructions for PWO

Planning and Assembly ofWork Packages.*SPEC-C-034, ProtectiveCoatings for ServiceLevel 1 ApplicationsInside the ReactorContainment Building.*Engineering QI 1.8,Design/OperabilityReference Guide*0-ADM-730 B no additional changes*QI 2-PTN-4B no additional changes*0-SMM-051.3 B revise to reflectchanges in the containment sumpstrainer configuration and ensurerefueling cavity drain covers areremoved prior to operation.

Will becompleted prior to containmentcloseout during the fall 2007 outage.*0-SMM-050.1 B procedure beingmodified to incorporate inspection ofnew sump strainer system.

Will becompleted prior to containmentcloseout during fall 2007 outage.*SPEC-M-068 B changes in progressto evaluate insulation changes incontainment.

To be completed by12/31/2007.*0-ADM-701.1 B minor changes willbe processed to direct work packageplanners to Insulation SpecificationM-068 for guidance on replacementof insulation inside containment. This action will be completed by12/31/2007.*SPEC-C-034 B revised to incorporateGSI-191 requirements for unqualifiedcoatings in containment.

Noadditional changes.*QI 1.8 B revised to review newdesigns for affect on debrisgeneration, debris transport, orrecirculation functions.

No additionalchanges.

Attachment

LIST OF ACRONYMS

ALARAAs Low As Reasonably AchievableASMEAmerican Society of Mechanical EngineersCAPCorrective Action ProgramCFRCode of Federal RegulationsCRCondition ReportDOTDepartment of TransportationHPAHealth Physics Administrative ProcedureHPSHealth Physics Surveillance ProcedureHPTHealth Physics TechnicianHRAHigh Radiation AreaNAPNuclear Administrative ProcedureNDENondestructive ExaminationNCVNon-cited violationPIPerformance IndicatorPSPublic Radiation SafetyRWPRadiation Work PermitRPRadiation ProtectionSDPSignificance Determination ProcessTSTechnical SpecificationFSARFinal Safety Analysis Report

IR 05000250/2007004

Text

Dear Mr. Stall:

Enclosure:

w/Attachment:

Enclosure:

w/Attachment:

SUMMARY OF FINDINGS

Cornerstone: Mitigating Systems

Cornerstone: Public Radiation Safety (PS)

B.Licensee Identified Violations

REPORT DETAILS

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

a. Inspection Scope

R08 Inservice Inspection (ISI) Activities

.1 Inservice Inspection activities other than Steam Generator Tube Inspections, (PWR)Vessel Upper Head Penetration Inspections, and Boric Acid Corrosion Control Program

a. Inspection Scope

Description:

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

b. Findings

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

b. Findings

a. Inspection Scope

b. Findings

Introduction:

Enforcement:

b. Findings

Cornerstone:

.1 Emergency Preparedness Drilla.Simulator Based Emergency Drill Inspection ScopeOn July 12, 2007, the inspectors observed the licensee simulator based drill thatincluded evaluation of licensed operator event classification.

b. Findings

RADIATION SAFETY

a. Inspection Scope

b. Findings

Cornerstone:

a. Inspection Scope

b. Findings

Introduction:

Description:

Analysis:

Enforcement:

a. Inspection Scope

b. Findings

a. Inspection Scope

4OA1 of the report Attachment.Public Radiation Safety Cornerstone

4OA1 of the reportAttachment. The inspectors completed the two specified radiation protection line-item samplesdetailed in IP 71151. 4OA2 Problem Identification and Resolution

.1 Daily Review

a. Inspection Scope

b. Findings

a. Inspection Scope

b. Findings

Introduction:

b. Findings

Introduction:

Analysis:

4OA2 of this report.

a. Inspection Scope

b. Findings and Observations

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

NRC personnel