IR 05000250/2012011

IR 05000250-12-011, 05000251-12-011, on July 16 - August 2, 2012, Turkey Point Nuclear Plant, Units 3 and 4, Biennial Inspection of the Problem Identification and Resolution Program

ML12279A246
Person / Time
Site:	Turkey Point
Issue date:	10/05/2012
From:	Hopper G Reactor Projects Branch 7
To:	Nazar M Florida Power & Light Co
References
IR-12-011
Download: ML12279A246 (22)

Text

October 5, 2012

SUBJECT:

TURKEY POINT NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000250/2012011 AND 05000251/2012011

Dear Mr. Nazar:

On August 2, 2012, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Nuclear Plant Units 3 and 4. The enclosed report documents the inspection findings, which were discussed via telephone on August 23, 2012, with Mr. Kiley and his staff.

The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at your Turkey Point plant was adequate. Licensee identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems. Corrective actions were generally, implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating experience were generally, reviewed and applied when appropriate. Audits and self-assessments were generally used to identify problems and appropriate actions.

Two NRC identified findings of very low safety significance (Green) were identified during this inspection. Both of these findings were determined to involve violations of NRC requirements.

The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Turkey Point Nuclear Plant. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at the Turkey Point Nuclear Plant.

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

Sincerely,

/RA/

George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects

Docket No. 50-250, 50-251 License No. DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2012011 and 05000251/2012011 w/Attachment: Supplemental Information

REGION II==

Docket No.:

50-250, 50-251

License No.:

DPR-31, DPR-41

Report No.:

05000250/2012011 and 05000251/2012011

Licensee:

Florida Power & Light Company (FPL)

Facility:

Turkey Point Nuclear Plant, Units 3 and 4

Location:

9760 S. W. 344th Street Homestead, FL 33035

Dates:

July 16 - 20, 2012 July 30 - August 2, 2012

Inspectors:

M. Barillas, Resident Inspector, Turkey Point N. Coovert, Fuel Facility Inspector T. Lighty, Project Engineer, Team Leader S. Mendez-Gonzales, Fuel Facility Inspector, in training R. Reyes, Resident Inspector, Saint Lucie R. Taylor, Senior Project Inspector

Approved by:

G. Hopper, Chief, Reactor Projects Branch 7 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000250/2012011, 05000251/2012011; July 16 - August 2, 2012; Turkey Point Nuclear

Plant, Units 3 and 4; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by a senior project inspector, a project engineer, two fuel facility inspectors, and a resident inspector. Two NRC identified findings of very low safety significance (Green) were identified during this inspection. The significance of most findings is identified by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 305, Operating Reactor Assessment Program. The findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

A.

Inspector Identified Findings

Cornerstone: Mitigating Systems

Green.

An NRC identified non-cited violation (NCV) of 10 CFR 50, Appendix B,

Criterion III, Design Control, was identified for the licensees failure to translate the worse case total post accident ICW flow rate for CCW heat exchangers, as documented in calculation PTN-4FSM-04-003 Revision 2, into surveillance, 3/4-OSP-030.4, CCW Heat Exchanger (HX) Performance Test. In addition, the licensee failed to incorporate seasonal salinity variances into calculation PTN-BFJM-96-004,

HX3 and HX4 Computer Code Verification. The effects of these two discrepancies was a reduction in maximum allowed canal temperature margin by approximately 1.5% or 1.5 degrees Fahrenheit. The licensee entered this issue into their corrective action program (CAP) as Condition Report (CR) 1789995.

The failure to maintain the CCW heat balance calculation to ensure the plant could meet their design basis to perform heat removal for normal cool down of the facility, and to mitigate the effects of accident conditions within acceptable limits is a performance deficiency. The inspectors determined that the performance deficiency was more than minor because the calculation errors impacted the Mitigating Systems cornerstone objective to ensure the capability of the CCW system to respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of Design Control. The inspectors determined that this finding did not have a cross-cutting aspect, because the finding was determined not to be indicative of current licensee performance.

• Green An NRC identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensees failure to take timely corrective action to address a nonconforming condition of Technical Specification (TS) 3/4.5.2 S R4.5.2a. The non-conservative TS was identified and placed in the corrective action program in 2006 as CR 2006-22868. TS 3.5.2 SR 4.5.2a was determined to be non-conservative and the corrective action to submit a TS amendment to address the non-conservative TS was not implemented. The licensee is scheduled to submit the license amendment in the fourth quarter of 2012, as referenced in AR 1790829.

The inspectors determined that the licensees failure to timely correct a condition adverse to quality associated with the non-conservative TS was a performance deficiency. The performance deficiency was more than minor because if left uncorrected the failure to implement timely corrective actions has the potential to lead to a more significant safety event in that the unit could be placed in an unanalyzed condition for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that the finding was of very low safety significance because there has been no loss of safety system function. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the CAP and an aspect in taking appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity. P.1(d)

B.

Identification and Resolution of Problems

The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the CAP for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. However, the inspectors did identify minor performance deficiencies in the area of prioritization and evaluation of identified problems.

The inspectors determined that overall; audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. However, the inspectors identified minor performance deficiencies associated with modification program and fire watch program. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a.

Assessment of the Corrective Action Program

(1) Inspection Scope

The inspectors reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between June 2010 and July 2012, including a detailed review of selected CRs associated with the following risk-significant systems and components: Intake Cooling Water (ICW), Radiation Monitors, Appendix R Lighting, and Steam Generator Blowdown Isolation Valves. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of CRs that were identified and assigned to the major plant departments, emergency preparedness, health physics, chemistry, and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walkdowns of equipment associated with the selected systems and components and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

The main control room (MCR) deficiency list was reviewed to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, as well as operability determination evaluations to verify compensatory measures for deficient equipment were implemented and adequate corrective actions were taken to address the degraded equipment.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of the root-cause and apparent cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the CRs and the guidance in licensee procedure PI-AA-100-1005, Root Cause Analysis, and PI-AA-100-1007, Apparent Cause Evaluation. The inspectors assessed if the licensee had adequately determined the causes of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent of condition, and extent of cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included CR screening meetings and Management Review Committee (MRC) meetings.

Documents reviewed are listed in the Attachment.

(2) Assessment

Identification of Issues

The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure PI-AA-204, Condition Identification and Screening Process, managements expectation that employees were encouraged to initiate CRs for any reason, as indicated by the 13000+ CRs initiated in 2011, and the projected number of 18000+ CRs in 2012 due to the extended power uprate. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.

The inspectors identified the following performance deficiencies. These issues were screened in accordance with Manual Chapter 0612, Issue Screening, and were determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.

During a system walk down of the safety related Unit 1 and Unit 2 gas and particulate radiation monitor skids R11/12, the inspectors found two fans in the vicinity of the radiation monitor skids, both located in the auxiliary building in the radiation controlled area (RCA). On Unit 3 the fan was at a distance of five feet from the R11/12 skid. On Unit 4 the fan was three feet from the R12 air sample pump. The inspectors found that in 1999 a mechanical request alteration (MRA) had been implemented for three six-foot fans to provide cooling in the hall way of the auxiliary building. Contrary to the inspector observations, MRA-99-1143 described that the fans were not to be located closer than six-feet from any safety related equipment. The licensees immediate corrective actions included placing the fans in the designated area as describe in the MRA. The licensee wrote AR 01789387, Auxiliary Building Fans Not IAW MRA 99-1143, to address whether the fans could have caused damage to the R11/12 skids under a design basis seismic event. Additionally, the licensee wrote AR 1790103 to address some historical plant misinformation that described the fans were required for R11/12 operability. The licensee completed an analysis to evaluate the potential overturning and sliding of the fans onto the radiation monitors during a seismic event. The licensee concluded that the rocking/sliding of the fans during a postulated seismic event would be negligible. The inspectors determined that there was a performance deficiency in that the licensee failed to maintain the requirements of the MRA to ensure the fans were not placed closer than six feet from safety related equipment. However, the finding is not more than minor because the analysis indicated that during a design basis seismic event, the fans would not have caused damage to the R11/12 radiation monitors.

On April 10, 2012, a fire occurred in the Unit 3 condenser due to an unattended lit acetylene torch. The incident was discussed during interviews for a cause investigation for CR 1754701, multiple fires occurring in the condenser are not being reported. The cause investigation did not find evidence of multiple fires, and even though this incident was revealed during interviews it was never discussed in the cause evaluation. An unattended lit acetylene torch was a violation of 0-ADM-16.5, Compressed Gas Tank Storage Requirements, and is a condition adverse to quality as defined in PI-AA-204.

This procedure violation was never entered into the corrective action process which was a violation of PI-AA-204, and was a performance deficiency. Documentation was later provided that a daily briefing was done to discuss acetylene torch use and proper storage with the contractors working in the area. But the actual acetylene torch incident was not discussed during the debriefs. This issue was considered minor because the fire occurred in an area that had an active fire watch, adequate action was taken to address the fire, no other equipment was affected and there were no other combustibles present. A CR was initiated to evaluate what occurred on April 10, 2012, and to determine if any additional corrective actions were needed to address the unattended acetylene torch.

Prioritization and Evaluation of Issues

Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the CR severity level determination guidance in PI-AA-204, Condition Identification and Screening Process.

Each CR was assigned a severity level at the CAP coordinator (CAPCO) meeting, and adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with PI-AA-100-1005, and PI-AA-100-1007.

Effectiveness of Corrective Actions

Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective. However the team identified two issues related to effectiveness of corrective actions.

(3) Findings

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The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the worse case total post accident ICW flow rate for CCW heat exchangers, as documented in calculation PTN-4FSM-04-003 Revision 2, into surveillance, 3/4-OSP-030.4, CCW Heat Exchanger (HX) Performance Test. In addition, the licensee failed to incorporate seasonal salinity variances into calculation PTN-BFJM-96-004, HX3 and HX4 Computer Code Verification. The effects of these two discrepancies was a reduction in maximum allowed canal temperature margin by approximately 1.5% or 1.5 degrees Fahrenheit.

The licensee performed an immediate and past operability review and subsequently determined the CCW and ultimate heat sink (cooling canal system (CCS)) systems remained operable.

Description:

The inspectors reviewed design basis documents, procedures, and surveillances for both Unit 3 and Unit 4 ICW and CCW systems. To satisfy CCW Technical Specification requirement 3/4.7.2.b.2, the licensee performed surveillance 3/4-OSP-030.4, which determined CCW heat exchanger performance.

The inspectors questioned if large modifications had occurred, or if lessons learned from EPU analyses had changed any software assumptions and inputs for the CCW heat exchanger performance monitoring, and if any findings discovered may have impacted past operability for either units, or if Unit 4 design documents were affected prior to EPU modifications occurring. During the time of the inspection, the licensee was undergoing EPU modifications on Unit 3, with the same modifications to follow on Unit 4. As part of the EPU, the licensee revised calculations M12-183-010 and PTN-BFJM-96-004 to account for EPU conditions. During the review, it was identified that the use of a nominal seawater salinity value of 3.44% was not representative of the actual intake canal water salinity values as it varied seasonally. Data collected by the licensee and their venders to support the EPU calculations indicated that the salinity values were as high as 7.11%. The new value of 7.11% was changed in both the EPU revised calculation and the 3-OSP-030.4 surveillance for Unit 3 but was not translated into the applicable pre-EPU documents for Unit 4.

In addition, the licensee identified three discrepancies in the current revision of the Unit 4 CCW HX performance monitoring program HX4R1, two of which resulted in a reduced maximum allowed canal temperature. These discrepancies also applied to the pre-EPU heat balance calculations for Unit 3, HX3R1, which could have potentially affected past operability. The first discrepancy identified was that HX4R1 utilized a tube-side heat transfer film coefficient correlation that was applicable to fresh water instead of saline ICW. The licensee determined that this discrepancy did not affect the results of the program because the differences were accounted for in the tube-side fouling factor, which was derived by real test data. The second discrepancy identified was that the pre-EPU surveillances 3/4-OSP-030.4, instructed the user to input a minimum assured ICW flow rate of 7700 gpm for each of the two heat exchangers. However, calculation PTN-4FSM-04-003 Revision 2, stated the worst case total post accident ICW flow rate per heat exchanger was 7600 gpm (or 15211 gpm total flow). As a result, the licensee determined this discrepancy had an effect of approximately

.1 % reduction in maximum

allowed canal temperature margin. The third discrepancy was the failure to incorporate the variable salinity value, as high as 7.11%, into the current calculation and program software for Unit 4 when it was identified during pre-EPU calculation reviews for Unit 3.

The licensee determined that this discrepancy had an effect of approximately 1.4%

reduction in maximum allowed canal temperature margin.

The licensee generated a condition report and performed an immediate operability review documented in CR 1789995, 2012 NRC PI&R: CCW HX Performance Monitoring Program Input. In addition, the licensee performed a prompt operability determination (POD) to determine present and past operability. The licensee determined that based upon the best and worst pair heat exchanger performance from January 5, 2010 until August 9, 2012, there was enough margin available even considering the reduction in 1.5 % maximum allowed canal cooling temperature margin.

In addition, the licensee reviewed independent past canal temperatures and salinity values to verify that there were no instances above 7.11% salinity. The report, FPL Turkey Point Annual Monitoring Report for Units 3 and 4 Uprate Project - August 2011, indicated that the highest salinity reading was reported in June 23, 2011, at 6.29%.

However, the licensee generated CR 1796546 to better understand error rates in temperature and conductivity readings, and what impacts existed, if any, on salinity values.

Analysis:

The failure to maintain the CCW heat balance calculation to ensure the plant could meet their design basis to perform heat removal for normal cool down of the facility, and to mitigate the effects of accident conditions within acceptable limits is a performance deficiency. The inspectors determined that the performance deficiency was more than minor because the calculation errors impacted the Mitigating Systems cornerstone objective to ensure the capability of the CCW system to respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of Design Control. The inspectors evaluated the finding using IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, using the Exhibit 2 Worksheet for the Mitigating Systems Cornerstone. The inspectors concluded that the finding was of very low safety significance.

The inspectors determined that this finding did not have a cross-cutting aspect, because the finding was determined not to be indicative of current licensee performance.

Specifically, the design discrepancies identified during this inspection occurred in 2009 and earlier.

Enforcement:

10 CFR Part 50, Appendix B, Criterion III, Design Control requires, in part, that measures shall be established to assure that that applicable regulatory requirements and the design basis, as defined in Part 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Design control measures shall be applied to items such as the following:

reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for inservice inspection, maintenance, and repair; and delineation of acceptance criteria for inspections and tests.

Contrary to the above, on and before August 2, 2012, the licensee failed to assure that the design control measures for ICW, CCW, and the cooling canal system were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to assure that the design basis for the ICW flow rates were correctly translated from calculation PTN-4FSM-04-003 Revision 2 into surveillance, 3/4-OSP-030.4, CCW HX Performance Test. The licensee also failed to assure that salinity deviations identified during the Unit 3 uprate project were included in design documents for current Unit 4 heat balance calculations, pre-EPU conditions. The failure to identify the deviations in ICW flow rates and salinity percentages resulted in a 1.5% or 1.5 degree Fahrenheit reduction in maximum allowed canal temperatures margin, which is a Technical Specification limit. Because this violation was of very low safety significance and was entered into the licensees CAP (CR 1789995), it is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. NCV 05000250/2012011-01; 05000251/2012011-01, Failure to Translate Design Basis Requirements into Plant Procedures and Calculations for CCW Heat Balance Equation.

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An NRC-identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to take timely corrective action to address a nonconforming condition of TS 3/4.5.2 SR 4.5.2a. The non-conservative TS was identified and placed in your corrective action program in 2006 as CR 2006-22868. TS 3.5.2 SR 4.5.2a was determined to be non-conservative and the corrective action to submit a TS amendment to address the non-conservative TS was not implemented. The licensee is scheduled to submit the license amendment 4th quarter 2012 as referenced in AR 17 90829.

Description:

The inspectors identified that the licensee failed to take prompt corrective action for a non-conservative technical specification that was identified in CR 2006-22868. In 2006, the licensee identified that TS 3.5.2 SR 4.5.2a allowed nine valves, which were required to be de-energized in MODES 1, 2, and 3, to be energized for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit temporary operation of these valves for surveillance or maintenance purposes Placing these valves in other than their required positions to support the injection phase of a LOCA invalidates the safety analysis as stated in CR 2006-22868 (AR 4342477). SR 4.5.2a states the following:

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying control room indication that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number

Valve Function

Valve Position 864A and B

Supply from RWST to ECCS Open 862A and B

RWST Supply to RHR pumps Open 863A and B

RHR Recirculation

Closed 866A and B

H.H.S.I. to Hot Legs

Closed HCV-758

RHR HX Outlet

Open

To permit temporary operation of these valves for surveillance or maintenance purposes, power may be restored to these valves for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Allowing temporary operation of these nine valves in Modes 1, 2, and 3 could place the unit in an unanalyzed condition. The non-conservative TS was a non-conforming condition which needed to be corrected. The NRC issued Administrative Letter (AL) 98-10, Dispositioning of Technical Specification that are Insufficient to Assure Plant Safety, to provide guidance on actions for non-conforming TSs. Administrative Letter 98-10, specified that licensees are required to take prompt action to submit a license amendment, with appropriate justification and a schedule, to correct the non-conservative technical specification. AL 98-10 states that administrative controls were adequate short term corrective actions. The AL also states that TS amendments to correct non-conforming conditions should be submitted within a refueling cycle after identification, as documented in the Part 9900: Technical Guidance. However, the licensee did not complete the action to correct the non-conservative technical specification that was identified in 2006. Multiple license amendment requests have been submitted to the NRC between 2006 and July 2012, but none of the amendments included the change to TS 3.5.2 SR 4.5.2a.

Analysis:

The inspectors determined that the licensees failure to correct a condition adverse to quality associated with the non-conservative TS was a performance deficiency. The performance deficiency was more than minor because if left uncorrected the failure to implement timely corrective actions has the potential to lead to a more significant safety event in that the unit could be placed in an unanalyzed condition for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that the finding was of very low safety significance because there had been no loss of safety system function in that no valves had been mispositioned during the exposure period. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the Corrective Action Program and an aspect in taking appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity. P.1(d)

Enforcement:

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criteria XVI, Corrective Action, required that the licensee establish measures to assure non-conformances are promptly identified and corrected. Contrary to the above, on and before August 2, 2012, the licensee failed to submit a TS amendment and promptly correct a nonconforming condition related to Technical Specification SR 4.5.2a which was identified in 2006. Because the finding was of very low safety significance and was entered into the corrective action program as AR 1790829, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy:

NCV 05000250; 251/2012011-02, Inadequate Corrective Actions Following Identification of a Non-conservative Technical Specification.

b.

Assessment of the Use of Operating Experience (OE)

(1) Inspection Scope

The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure PI-AA-102, Operating Experience Program, reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since June 2010 to verify whether the licensee had appropriately evaluated each notification for applicability to the Turkey Point plant, and whether issues identified through these reviews were entered into the CAP. PI-AA-102, Operating Experience Program, was reviewed to verify that the requirements delineated in the program were being implemented at the station. Documents reviewed are listed in the Attachment.

(2) Assessment

Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all root cause evaluations in accordance with licensee procedure PI-AA-100-1005.

(3) Findings

No findings were identified.

c.

Assessment of Self-Assessments and Audits

(1) Inspection Scope

The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure PI-AA-101, Self Assessment and Benchmarking Program.

(2) Assessment

The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that CRs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the CRs reviewed that were initiated as a result of adverse trends.

(3) Findings

No findings were identified.

d.

Assessment of Safety-Conscious Work Environment

(1) Inspection Scope

The inspectors randomly interviewed on-site workers regarding their knowledge of the corrective action program at Turkey Point and their willingness to write CRs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a

sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.

(2) Assessment

Based on the interviews conducted and the CRs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

(3) Findings

No findings were identified.

4OA6 Meetings, Including Exit

On August 2, 2012, the inspectors presented the inspection results to Mr. Kiley and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee. A re-exit was conducted with members of your staff via telephone on August 23, 2011, to discuss the final results of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Alvarez, Performance Improvement

M. Averett, Staff Engineer

L. Bandel

P. Barnes, Modifications Engineering Supervisor

C. Domingos, System Engineering Manager

P. Faulkey, IST Coordinator

J. Garcia, Engineer 1

M. Jones

T. Jones, Operations Shift Manager

B. Kline, Fleet FAC Coordinator

Y. Lorenzo, Construction Supervisor

G. Mendoza, Chemistry Manager

S. Mihalakea

C. Navarro, Performance Improvement

F. Olivo, Operating Experience Coordinator

T. Rohe

R. Smith, ICW/CCW System Engineer

C. Sibley, Maintenance Rule Coordinator

B. Stamp, Training Manager

R. Tomonto, Licensing Manager

R. Valmonte, Project Engineer

NRC personnel

S. Stewart, Senior Resident Inspector

G. Hopper, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened and Closed

05000250, 251/2012011-01 NCV

Failure to Translate Design Basis Requirements into Plant Procedures and Calculations for CCW Heat Balance Equation

05000250; 251/2012011-02 NCV

Inadequate Corrective Actions Following Identification of a Non-conservative Technical Specification

Closed

None

Discussed

None