IR 05000250/2020001

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Integrated Inspection Report 05000250/2020001 and 05000251/2020001
ML20128J863
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 05/07/2020
From: Randy Musser
NRC/RGN-II/DRP/RPB3
To: Moul D
Florida Power & Light Co
References
IR 2020001
Download: ML20128J863 (21)
v • d • e


Text

May 7, 2020

SUBJECT:

TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2020001 AND 05000251/2020001

Dear Mr. Moul:

On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On April 27, 2020, the NRC inspectors discussed the results of this inspection with Mr. Brian Stamp, Site Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Turkey Point Units 3 & 4.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Turkey Point Units 3 & 4. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000250 and 05000251 License Numbers: DPR-31 and DPR-41 Report Numbers: 05000250/2020001 and 05000251/2020001 Enterprise Identifier: I-2020-001-0070 Licensee: Florida Power & Light Company Facility: Turkey Point Units 3 & 4 Location: Homestead, FL 33035 Inspection Dates: January 01, 2020 to March 31, 2020 Inspectors: C. Fontana, Emergency Preparedness Inspector W. Loo, Senior Health Physicist J.D. Orr, Senior Resident Inspector J. Reyes, Resident Inspector J. Rivera, Health Physicist S. Sanchez, Senior Emergency Preparedness Inspector Approved By: Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Turkey Point Units 3 & 4, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Human Performance Error Rendered the 3B Emergency Diesel Generator Unavailable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.22 Systems NCV 05000250/2020001-01 Complacency Open/Closed A self-revealing, Green, Non-cited violation (NCV) of of Technical Specification (TS) 6.8.1,

Procedures and Programs, was identified when a nuclear station operator failed to complete a procedure step in 3-OSP-023.1, "Diesel Generator Operability Test," to open and lock open the right-side air start isolation valve after it was closed for engine barring.

Human Performance Error Causes a Turbine Runback to 85 Percent Power Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71111.22 NCV 05000251/2020001-02 Complacency Open/Closed A self-revealing, Green, Non-cited violation (NCV) of TS 6.8.1, Procedures and Programs, was identified when a reactor operator failed to adequately complete a surveillance procedure step in procedure 4-SMI-072.03A, "Steam Pressure Analog Channel Operational Test (ACOT), Protection Channel IV," to place the steam dump to condenser (SDTC) pressure control in manual mode.

Additional Tracking Items

None.

PLANT STATUS

Unit 3 operated at or near rated thermal power (RTP) for nearly the entire inspection period.

Unit 3 was down-powered beginning on March 28, 2020, to initiate the shutdown sequence for a refueling outage (PT3-31), which officially began on March 30, 2020 when the unit was shutdown.

Unit 4 began the inspection period at RTP. On February 18, 2020, the unit experienced an automatic turbine runback to 85 percent power due to an operator error while transferring steam dumps control to manual for an associated instrument surveillance activity. The unit was returned to RTP several hours later, on the same day and remained at or near RTP for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week during which they conducted plant status activities as described in IMC 2515, Appendix D, and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to reschedule the inspection to a later date.

REACTOR SAFETY

71111.04 - Equipment Alignment

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

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

(1) Unit 3 and Unit 4 component cooling water (CCW) system while the 4B CCW header was supplying cooling water to the 3A and 3B high head safety injection (HHSI)pumps on January 14, 2020 and Unit 3 and Unit 4 CCW after the 3B CCW header was restored to a normal alignment for cooling water to the 3A and 3B HHSI pumps on January 15, 2020
(2) 4B emergency diesel generator (EDG) while the 4A EDG was out of service (OOS)for testing on January 21, 2020
(3) Unit 3 and Unit 4 EDG fuel oil transfer system after transferring fuel oil from the Unit 3 diesel oil storage tank to the 4A EDG diesel oil day tank on January 23 and 24, 2020
(4) Unit 3 and Unit 4 startup transformers, and the 3A, 3B, 4A, and 4B HHSI pumps while the 3A EDG was OOS on January 28, 2020
(5) Unit 3 and Unit 4, 125 volt (V) direct current (DC) vital electrical distribution system while the 4A, 125 VDC battery was OOS on February 11, 2020

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 Samples)

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

(1) Fire zones (FZ) 30, 31, 38, and 40 for the Unit 3 and Unit 4 containment spray pump rooms and the pipe and valve rooms on January 9, 2020
(2) FZ's 29, 42, and 118 for the Unit 3 and Unit 4 spent fuel pit areas and the auxiliary building roof on January 17, 2020
(3) FZ's 77, 89, 113 and 116 for the Unit 3 and Unit 4 condensate storage tank areas and the feedwater platforms on January 23, 2020
(4) FZ 122 for the electric and diesel driven fire water pumps and raw water tanks area on January 27, 2020
(5) FZ's 79, 84, 114 and 115 for the outdoor area west of Unit 4 containment, combined Unit 3 and Unit 4 auxiliary feedwater (AFW) pump area, and the Unit 3 and Unit 4 main steam header platforms on February 4, 2020
(6) FZ's 43, 56, and 57 for the Unit 3 and Unit 4 spent fuel pit heat exchanger rooms and the Unit 3 new fuel room on February 25, 2020
(7) FZ's 72, 73, 133 - 136, and 138 - 141 for the Unit 3 and Unit 4 EDG buildings on March 9, 2020

71111.06 - Flood Protection Measures

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

The inspectors evaluated internal flooding mitigation protections in the:

(1) Main control room, the Unit 3 and Unit 4 reactor protection equipment rooms, electrical equipment room and the vital 125 V DC battery rooms on January 29 and

February 3, 2020 Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Manholes 302 and 306 associated with cables to and from the 3B, 4 kilovolt (kV) vital switchgear room on March 12, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) The Unit 4 CCW heat exchangers on January 22 and 28, 2020

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during entry into off-normal operating procedure 0-ONOP-003.19, 125 V DC System - Location of Grounds for a ground on the 4B, 125 V DC load center on January 28, 2020.

The inspectors additionally observed and evaluated licensed operator performance in the Control Room immediately following a 15 percent power turbine runback and entry into off-normal operating procedure 4-ONOP-089, Turbine Runback on February 18, 2020.

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

(1) The inspectors observed and evaluated a requalification training simulator scenario administered to an operating crew on February 3, 2020

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) AR 2337205, Unit 3 EDG Maintenance Rule Unavailability Criteria (Event date was December 3, 2019) completed on March 3, 2020
(2) AR 2345790, AFW Nitrogen Pressure Controller Malfunction (Event date was February 24, 2020) completed on March 25, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

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

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

(1) 3B CCW supply header to the 3A and 3B HHSI pumps OOS on January 13 and 14, 2020
(2) 3A2, 125 V DC battery charger, 3E240A load center and switchgear rooms air condition system chiller package 2A, 3A charging pump, CV-3-2816 AFW flow control valve to 3A steam generator, 4CD diesel-driven instrument air compressor, and E234 water chiller unit for the electrical equipment room air handling unit V78, OOS on February 11, 2020
(3) 3A2, 125 V DC battery charger, 3E240A load center and switchgear rooms air conditioning system chiller package 2A, 3A charging pump, 4B ICW header basket strainer, and the E234 water chiller unit for the electrical equipment room air handling unit V78, OOS on February 12, 2020
(4) Unit 4 startup transformer, 3A2 125 V DC battery charger, 3E240A load center and switchgear rooms air conditioning system chiller package 2A, 3A charging pump, E234 water chiller unit for the electrical equipment room air handling unit V78, and the 4B CCW heat exchanger OOS on February 13, 2020
(5) AFW train 1, 4B emergency containment cooler, 4A EDG, 4A CCW heat exchanger, 4A HHSI pump, E234 water chiller unit for the electrical equipment room air handling unit V78, and the 4CM motor driven instrument air compressor OOS on February 24, 2020
(6) 3CM motor driven instrument air compressor, 3B1 battery charger, E234 water chiller unit for the electrical equipment room air handling unit V78, and 3E240A load center and switchgear rooms air conditioning system chiller package 2A OOS on March 5, 2020

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) AR 2339496, RV-6401C, relief valve for AFW pump C, failed set pressure/seat leakage test on February 3, 2020
(2) AR 2343931, NRC question regarding smoke migration between fire zones on February 4, 5, and 13, 2020
(3) AR 2345790, AFW nitrogen pressure controller malfunction on March 27, 2020
(4) AR 2349783, Prompt operability determination for AFW, (hand indicating controller),

HIC-3-140A failed to go in manual on March 25 and 27, 2020

(5) AR 2347348, Prompt operability determination for flaw identified on ICW piping upstream of valve 3-50-406 on March 23 and 24, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

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

(1) 4-OP-047, CVCS - Charging and Letdown, Section 7.5, Charging Pump Post-Maintenance Run-In, after 4B charging pump relief valve maintenance, work order (WO) 40598088, on January 13, 2020
(2) 3-OSP-075.1, Auxiliary Feedwater Train 1 Operability Verification, after HIC-3-1401A, AFW train 1 flow control valve to 3A steam generator, replacement, WO 40598088, on February 18, 2020
(3) 4-OSP-075.6, Auxiliary Feedwater Train 1 Backup Nitrogen Test, after AFW nitrogen pressure controller replacement, WO 40661062, on March 2, 2020
(4) 4-OSP-019.1, Intake Cooling Water (ICW) Inservice Test, Section 7.3, ICW Pump 4C and Discharge Check Valve Test, after pump and motor replacement, WO 40560696, on March 13, 2020

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)

(1) (Partial)

The inspectors evaluated refueling outage (PT3-31) activities from March 30, 2020 to the end of the quarter on March 31, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22
(1) 3-OSP-075.1, Auxiliary Feedwater Train 1 Operability Verification and 3-OSP-075.6, Auxiliary Feedwater Train 1 Backup Nitrogen Test on January 13, 2020
(2) 3-OSP-300.3, Safe Shutdown and Alternate Shutdown Operability Test, Section 7.16 EDG 3B Breaker, 3AB20, Normal/Isolate Switch Test (Online) and 3-OSP-023.1 Diesel Generator (3B) Operability Test on January 27 and 28, 2020
(3) 3-OSP-023.1, Diesel Generator Operability Test, 3A EDG, on March 16 and 17, 2020
(4) 4-SMI-072.03A, Steam Pressure ACOT, Protection Channel IV, on

February 18, 19 and 20, 2020 Inservice Testing (IP Section 03.01) (3 Samples)

(1) 4-OSP-206.2, Quarterly Inservice Valve Testing, Section 7.5, Chemical and Volume Control, and Section 7.8 H2/O2 Gas Analyzer, on January 27 and 28, 2020
(2) 3-OSP-019.1, Intake Cooling Water Inservice Test, Section 7.1 Intake Cooling Water Pump 3A and Discharge Check Valve Test, on February 6, 2020
(3) 0-ADM-547, Gas Accumulation Management Program, Attachment 5, Unit 4 SI Gas Accumulation Monitoring Points, monitoring points P-27, P-28, and P-29 and 4-OSP-062.2A, Safety Injection Pump 4A Group B Pump Test on February 28, 2020

71114.02 - Alert and Notification System Testing

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

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of February 10, 2020.

71114.03 - Emergency Response Organization Staffing and Augmentation System

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

(1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of February 10, 2020.

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of February 10, 2020. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

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

(1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of February 10, 2020.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors evaluated the emergency preparedness drill in the simulator control room, the technical support center, and the emergency operations facility on February 27,

RADIATION SAFETY

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walk Downs and Observations (IP Section 02.01) (1 Sample)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

(1)

  • R-14, Process Radiation Monitoring System: Plant Vent Gas Monitor
  • R-18, Process Radiation Monitoring System: Liquid Waste Monitor
  • RAD-3-6418, Process Radiation Monitoring System: Unit 3 Spent Fuel Pit Monitor Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed gaseous and liquid effluent monitor instrument calibrations or tests by reviewing information not limited to but including alarm set points, periodicity, National Institute of Standards and Traceability for sources used.

(1)

  • R-14, Process Radiation Monitoring System: Plant Vent Gas Monitor (Work Order Packages 40444700 01, February 1, 2017; and 40551763 01, September 28, 2019)
  • R-18, Process Radiation Monitoring System: Liquid Waste Monitor (Work Order Packages 40522637 01, May 2, 2018; and 40633508 01, January 8, 2020)
  • RAD-3-6418, Process Radiation Monitoring System: Unit 3 Spent Fuel Pit Monitor (Work Order Packages 40400517 01, December 7, 2016; and 40530544 01,

October 23, 2018) Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed radioactive effluent sampling and analysis activities.

(1) Radioactive Effluent Sampling and Analysis Activities
  • A Monitor Tank, February 4, 2020
  • Unit 3 Spent Fuel Pool SPING, February 4, 2020
  • F-Gas Decay Tank, February 6, 2020 Effluent Discharges None were available for review during this inspection period.

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed flow rates for effluent stack and related vent flow and surveillances.

Inspectors also reviewed maintenance and methodologies for one or two high-range effluent monitors (or other effluent/process monitor) relied on in emergency operating procedures for decision making.

(1)

  • V8A, Auxiliary Building Exhaust Fan (Work Order Packages 40597438 01, February 1, 2019; 40607369 01, May 9, 2019; 40612835 01, August 13, 2019;

===40664047 01, December 12, 2019)

  • Unit 3 R-3-11 and R-3-12 Process Radiation Monitoring System: Containment Gas and Particulate Radiation Monitors (Work Order Packages 40479396 01, January 12, 2018; and 40604956 01, November 21, 2019)

Dose Calculations (IP Section 02.05) ===

Main article: IP 40664

The inspectors reviewed required annual reports for changes, release permits and the offsite dose calculation manual for changes and results.

(1) Liquid and Gaseous Discharge Permits
  • Gas Permit Post-Release Final Report, Permit Number: G-2020-013, Plant Vent (F-GDT), February 6, 2020

71124.07 - Radiological Environmental Monitoring Program

Site Inspection (IP Section 02.01) (1 Sample)

The inspectors evaluated the radiological environmental monitoring program implementation.

(1) The inspectors reviewed the following:

Walkdowns, Calibrations, and Maintenance Record Review

  • Direct Radiation Thermoluminesent Dosimeter (TLD) Locations N-2 (Convoy Point), NNW-2 (North Canal Drive), NW-1 (Entrance Road), SW-1 (On Site), and WNW-2 (Palm Drive)
  • Air Sampling Station Locations T51 (Bayfront Park), T58 (Entrance Road), T41 (Palm Drive), and T-72 (Land Utilization Entrance)

Environmental Sample Collections and Preparation Observation

  • Surface Water Sample Collection Locations T42 (Biscayne Bay) and T81 (Card Sound)
  • Broad Leaf Vegetation Collection Locations T40 (SW 117th Street Extension) and T41 (Palm Drive)

Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement

  • AR 02277139, the semi-annual collection of blue crab crustacea was unable to be obtained, August 23, 2018
  • AR 02314352, two air sampler flow meters failed and one TLD lost, May 14, 2019
  • AR 02332880, the result of the reading of a TLD element was unusually high, October 24, 2019 Sampling Program for the Potential of Licensed Material Entering Groundwater
  • Reactor Water Storage Tank (RWST) Suction and Discharge Piping
  • RWST Discharge Isolation Valves

Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees continuing implementation of the voluntary Nuclear Energy Institute (NEI) Ground Water Protection Initiative.

OTHER ACTIVITIES - BASELINE

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

EP01: Drill/Exercise Performance (IP Section 02.12) ===

Main article: IP 71151
(1) EP01: Drill & Exercise Performance for the period January 1, 2019, through

December 31, 2019 EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) EP02: Emergency Response Organization Drill Participation for the period January 1, 2019, through December 31, 2019

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) EP03: Alert & Notification System Reliability for the period January 1, 2019, through December 31, 2019

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)

(1) Unit 3 January 2019 through December 2019.
(2) Unit 4 January 2019 through December 2019.

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(2 Samples)

(1) Unit 3 January 2019 through December 2019.
(2) Unit 4 January 2019 through December 2019.

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 3 January 2019 through December 2019.
(2) Unit 4 January 2019 through December 2019.

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) April 2019 to December 2019

71152 - Problem Identification and Resolution

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

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

(1) AR 2343456, simulated Hurricane Dorian effect on Turkey Point. This issue was selected to verify that Turkey Point was adequately protected and would remain safely shutdown for a hurricane of this magnitude had it directly passed over the site.

Florida Power & Light (FPL) compared the results of this analysis to the flood hazard reevaluation that was performed in

INSPECTION RESULTS

Human Performance Error Rendered the 3B Emergency Diesel Generator Unavailable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71111.22 Systems NCV 05000250/2020001-01 Complacency Open/Closed A self-revealing, Green, Non-cited violation (NCV) of of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified when a nuclear station operator failed to complete a procedure step in 3-OSP-023.1, "Diesel Generator Operability Test," to open and lock open the right-side air start isolation valve after it was closed for engine barring.

Description:

On January 27, 2020, plant operators intended to perform and complete 3-OSP-023.1, Diesel Generator Operability Test, for the 3B emergency diesel generator (EDG). The operability test was intended to satisfy a routine monthly Technical Specification (TS) surveillance test and a post-maintenance test for its associated output breaker maintenance. Prior to starting the EDG, the EDG is manually barred over with the cylinder test cocks open to inspect for water or oil that may have collected in any piston cylinder due to internal component failure. If no abnormal conditions are identified, the cylinder test cocks are closed, and operators align either the left-side or right-side air start system for starting on an alternating monthly basis. The right-side air start system was intended to be used for starting the 3B EDG for the operability test.

Procedure step 7.2.2.13.d. stated if the right-side is to be used for this run, then perform the following:

(1) Lock open Starting Air PCV-3-194B Outlet Isolation, 3-70-257B. Contrary to step 7.2.2.13.d.(1), the assigned nuclear station operator failed to implement self checking verification techniques and procedure adherence techniques, and 3-70-257B was left in the closed position following the engine barring steps. When control room operators attempted to remotely start the 3B EDG, the 3B EDG locked-out. The locked-out condition is expected for a failure of the air start system. Operators promptly investigated the locked-out condition and noted that 3-70-257B was not locked open.

At 0445 hours0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> on January 28, 2020, the 3B EDG lock-out relay was reset, the EDG was restored to a normal standby alignment with both left-side and right-side air start systems aligned for automatic starting, and the 3B EDG was declared available but still TS inoperable.

In total, the 3B EDG incurred an additional six hours of unavailability due to the operator procedure error.

Corrective Actions: FPL initiated AR 2342597 to document the human performance error and to initiate corrective actions. Appropriate corrective actions were assessed to those persons directly involved with the human performance error. 3-OSP-023.1, Diesel Generator Operability Test, for the 3B EDG was satisfactorily completed at 0018 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> on January 29, 2020, and the 3B EDG was declared operable.

Corrective Action References: AR 2342597

Performance Assessment:

Performance Deficiency: The operators' failure to lock open starting air PCV-3-194B outlet isolation, 3-70-257B as instructed in procedure 3-OSP-023.1, Diesel Generator Operability Test, was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 3B EDG remained unavailable when starting air PCV-3-194B outlet isolation, 3-70-257B was left closed and the 3B EDG unnecessarily incurred six hours of unavailability due to the human performance error.

Significance: The inspectors screened this finding using IMC 0609, Attachment 4, Initial Characterization of Findings, for Mitigating Systems, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and determined the finding to be of very low safety significance (Green) because the finding did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The inspectors reviewed this performance deficiency for cross-cutting aspects as required by IMC 0310, Aspects Within the Cross-Cutting Areas. The operators failed to follow the procedure as instructed and did not adequately implement appropriate error reduction tools to ensure starting air PCV-3-194B outlet isolation, 3-70-257B was locked open.

Enforcement:

Violation: Turkey Point Nuclear Generating Units 3 and 4, TS 6.8.1.a, in part states, written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures required by the Quality Assurance Topical Report.

NextEra Quality Assurance Topical Report, Appendix B, Procedures, in part states, NextEra Energy commits to use Appendix A, of Regulatory Guide 1.33, as guidance for establishing the types of procedures that are necessary to control and support plant operation.

Regulatory Guide 1.33, Appendix A, 3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems includes s.(2)(a) emergency diesel generators. FPL implemented 3-OSP-023.1, "Diesel Generator Operability Test," to provide instructional guidance for testing the operability of the Unit 3 EDGs and various support components to satisfy TS surveillance requirements. Procedure step 7.2.2.13.d. stated if the right side is to be used for this run, then perform the following:

(1) Lock open Starting Air PCV-3-194B Outlet Isolation, 3-70-257B.

Contrary to the above, on January 27, 2020, FPL personnel failed to implement self checking verification techniques and procedure adherence techniques, and 3-70-257B was left in the closed position in lieu of the required locked open position.

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

Human Performance Error Causes a Turbine Runback to 85 Percent Power Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71111.22 NCV 05000251/2020001-02 Complacency Open/Closed A self-revealing, Green, Non-cited violation (NCV) of TS 6.8.1, Procedures and Programs, was identified when a reactor operator failed to adequately complete a surveillance procedure step in procedure 4-SMI-072.03A, "Steam Pressure Analog Channel Operational Test (ACOT), Protection Channel IV," to place the steam dump to condenser (SDTC) pressure control in manual mode.

Description:

On February 18, 2020, while Unit 4 was operating at 100 percent reactor power, instrument and control (I&C) technicians were performing engineered safety features actuation system (ESFAS) surveillance tests to verify operability of, and calibrate, safety-related pressure transducer instrumentation. While calibrating a steam header pressure transducer, Unit 4 experienced an automatic turbine runback. During the immediate response to the turbine runback, reactor operators took manual action to close the steam dump valves. Control rods inserted automatically in response to the runback to control reactor coolant system temperature. Reactor operators entered off-normal operating procedure 4-ONOP-089, Turbine Runback. The runback terminated at 85 percent power.

FPLs investigation identified that the reactor operator did not complete a required step in the surveillance procedure to align the SDTC pressure control to manual operation in preparation for steam header pressure instrument calibrations. Safety-related surveillance procedure, 4-SMI-072.03A, Steam Pressure ACOT, Protection Channel IV, in part, aligns the SDTC controller to preclude the steam dump valves from opening in response to calibration activities. Procedure section 4.1, Preparation and Test Equipment Setup, subsection step 4.1.6.A, required the reactor operator to; place steam dump to condenser pressure in manual, and set controller demand meter indication to minimum (zero or less). FPL in reviewing this issue, discovered step 4.1.6.A was initialed as completed, but the operator only set the controller demand meter indication to minimum and failed to place the SDTC pressure control in manual.

When I&C technicians raised simulated steam header pressure above the automatic steam dump pressure setpoint, the steam dump valves opened resulting in additional steam demand. This caused additional feedwater flow to maintain programmed steam generator water levels. The additional feedwater flow reduced the suction pressure to the steam generator feedwater pumps. This in turn caused the automatic opening of the feedwater heater bypass valve, which is an input to the automatic turbine runback circuit. The turbine control system responded in automatic and reduced turbine load to 85 percent turbine power.

Corrective Actions: FPL initiated AR 2345097 to document the human performance error, entry into the off-normal operating procedure and to initiate corrective actions. Appropriate corrective actions were assessed to those persons directly involved with the human performance error. Procedure 4-SMI-072.03A was revised to separate step 4.1.6.A into two separate action items, each, requiring an independent verification: specifically, one action to place steam dump to condenser pressure in manual, and a second action to, set controller demand meter indication to minimum (zero or less).

Corrective Action References: AR. 2345097

Performance Assessment:

Performance Deficiency: The reactor operator's failure to correctly set the SDTC controller in manual as instructed in surveillance procedure 4-SMI-072.03A, "Steam Pressure ACOT, Protection Channel IV," was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the operator failed to align the SDTC pressure control to the manual position and resulted in a 15 percent turbine runback during calibration of a pressure transducer.

Significance: The inspectors screened this finding using IMC 0609, Attachment 4, Initial Characterization of Findings, for Initiating Events, and IMC 0609, Appendix A, The Significance Determination Process For Findings At-Power, and determined the finding to be of very low safety significance (Green) because the finding, when screened as a transient initiator, did not cause both a reactor trip AND the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g., loss of condenser, loss of feedwater).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The inspectors reviewed this performance deficiency for cross-cutting aspects as required by IMC 0310, Aspects Within the Cross-Cutting Areas. The operator failed to follow the procedure as instructed and did not adequately implement appropriate error reduction tools to ensure the SDTC pressure control was properly placed in manual.

Enforcement:

Violation: Turkey Point Nuclear Generating Units 3 and 4, TS 6.8.1.a, in part states, written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures required by the Quality Assurance Topical Report.

NextEra Quality Assurance Topical Report, Appendix B, Procedures, in part states, NextEra Energy commits to use Appendix A of Regulatory Guide 1.33 as guidance for establishing the types of procedures that are necessary to control and support plant operation. Regulatory Guide 1.33, Appendix A, item 8, Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, subsection B.1.s, includes procedures for surveillance testing of the Nuclear Steam Supply System. FPL implemented procedure 4-SMI-072.03A, "Steam Pressure ACOT, Protection Channel IV," to provide instructions for the analog channel operational test (ACOT) of the protection instrumentation channel IV, associated with steam pressure protection and steam break pressure protection, to satisfy technical specification surveillance requirements. Procedure step 4.1.6.A provided instructions to place Steam Dump to Condenser Pressure Control in manual and set controller demand meter indication to minimum (zero or less)."

Contrary to the above, on February 18, 2020, during surveillance testing using procedure 4-SMI-072.03A, step 4.1.6.A, FPL personnel failed to properly align the SDTC pressure control in manual.

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

EXIT MEETINGS AND DEBRIEFS

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

  • On April 27, 2020, the inspectors presented the integrated inspection results to Mr. Brian Stamp, Site Director, and other members of the licensee staff.
  • On February 6, 2020, the inspectors presented the RP Inspection Exit Meeting inspection results to Mr. Grant Melin, Maintenance Director, and other members of the licensee staff.
  • On February 13, 2020, the inspectors presented the Emergency Preparedness Program Inspection inspection results to Mr. Brian Stamp, Site Director, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.06 Miscellaneous Offsite Dose Calculation Manual for Gaseous and Liquid Current Rev.

Effluents from the Turkey Point Plant Units 3 and 4 26

71124.06 Procedures 0-NCOP-003 Preparation of Liquid Release Permits Rev. No. 5B

71124.06 Procedures 0-NCOP-006 Preparation of Gas Release Permits Rev. No. 6

71124.06 Procedures 0-NCOP-067 Process Radiation Monitors Setpoint Determination Rev. No. 3

71124.06 Procedures 0-NCZP-051.3 Obtaining Plant Effluent Samples Via the SPING Monitors Rev. No. 9

During Non-Accident Conditions

71124.06 Procedures CY-TP-104-0045 Monitor Tank Sampling Rev. No. 2

71124.07 Corrective Action AR 02314227 60M Met Tower Temperature Indication Failing 05/13/2019

Documents Intermittingly

71124.07 Corrective Action AR 02330483 10M Tower Wind Direction Indicator Is Not Functioning 10/06/2019

Documents

71124.07 Corrective Action AR 02334877 Intermittent Fail Low of All 60 Meter Tower Channels 11/09/2019

Documents

71124.07 Corrective Action AR 02337206 60M/10M Tower Temp Reads Bad 12/03/2019

Documents

71124.07 Corrective Action AR 02343628 As-left values to MET Tower calibration records not 02/05/2020

Documents documented accurately

Resulting from

Inspection

71124.07 Corrective Action AR 02343840 Unusual number of recent condition reports written for 02/06/2020

Documents failed MET tower sensors

Resulting from

Inspection

71124.07 Procedures 0-PMI-103.04 South Dade Met Tower Instrument Calibration Rev. 2A

71124.07 Procedures Quality Procedure A Radiological Environmental Monitoring Program Rev. 6

71124.07 Self- AR 02268857 State of Florida BRC REMP Program South Region 06/06/2018

Assessments Biennial Assessment

71151 Miscellaneous Gas Permit Post- SFP3 SPING 12/31/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Release Data,

Permit Number: G-

2019-137

71151 Miscellaneous Liquid Permit Post- R-18 Liquid Effluent Monitor 12/21/2019

Release Data,

Permit Number: L-

2019-129

71151 Procedures ADM-25.02 NRC Performance Indicators Rev. No. 39

18

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