IR 05000250/2021004

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Integrated Inspection Report 05000250/2021004 and 05000251/2021004
ML22032A251
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 02/02/2022
From: David Dumbacher
NRC/RGN-II/DRP/RPB3
To: Coffey B
Florida Power & Light Co
References
IR 2021004
Download: ML22032A251 (22)


Text

February 2, 2022

SUBJECT:

TURKEY POINT UNIT 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2021004 AND 05000251/2021004

Dear Mr. Coffey:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Unit 3 & 4. On January 26, 2022, the NRC inspectors discussed the results of this inspection with Mr. Michael Pearce, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation, or the significance or severity of the violation 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 Unit 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 Unit 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/

David E. Dumbacher, 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: 05000250/2021004 and 05000251/2021004

Enterprise Identifier: I-2021-004-0034

Licensee: Florida Power & Light Company

Facility: Turkey Point Unit 3 & 4

Location: Homestead, FL 33035

Inspection Dates: October 1, 2021 to December 31, 2021

Inspectors: P. Cooper, Senior Reactor Inspector J. Diaz-Velez, Senior Health Physicist M. Endress, Senior Resident Inspector M. Kennard, Senior Operations Engineer W. Pursley, Health Physicist R. Reyes, Resident Inspector J. Rivera, Health Physicist J. Viera, Senior Operations Engineer

Approved By: David E. Dumbacher, 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 Unit 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

Debris and Unsecured Equipment in the RHR Pump Rooms Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71152 Systems NCV 05000250,05000251/2021004-01 Management Open/Closed The NRC identified an adverse trend in the licensees ability to maintain the RHR pump rooms in compliance with housekeeping and conduct of maintenance procedures that prevent debris such as tie wraps, working gloves, pipe insulation, scaffold poles, tools, and uncontrolled and unsecured miscellaneous equipment from posing challenges to the screen and sump pump systems in the Unit 3 and Unit 4 RHR pump rooms. An NRC identified green non-cited violation (NCV) of Technical Specification 6.8.1 was identified for the licensees failure to implement required housekeeping and maintenance controls in the RHR pump rooms, as specified by procedures MA-AA-100-1008, Station Housekeeping and Material Control, and procedure MA-AA-100, Conduct of Maintenance.

PLANT STATUS

Unit 3 began the inspection period at 100 percent rated thermal power. The unit was down powered to zero percent power for a scheduled refueling outage on October 9, 2021. The unit was returned to rated thermal power on November 24, 2021, and remained at or near rated thermal power for the remainder of the inspection period.

Unit 4 operated at or near rated thermal power for the entire 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 activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities, and completed on-site portions of IPs. 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.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:

Auxiliary Feedwater (AFW) pump room, on December 14, 2021 Unit 3 3A and 3B Emergency Diesel Generator (EDG) rooms, on December 23, 2021 Unit 4 4A and 4B EDG rooms, on December 23, 2021

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 3A and 3C Component Cooling Water (CCW) pumps; and 3A, 3B, and 3C CCW heat exchangers, while the 3A Residual Heat Removal pump (RHR), 3B CCW pump and the safety-related 3B 4kv bus were out of service (OOS) and Unit 3 was in single RHR train operation, on October 14, 2021.
(2) 3A, 4A, and 4B safety-related 4160-volt switchgears; 3A, 4A, and 4B High Head Safety Injection (HHSI) pumps, while the 3B HHSI pump and 3B safety-related 4160 switchgear was OOS, on October 25, 2021.
(3) Unit 3A, 3B, and Unit 4A HHSI pumps, Unit 3 and Unit 4 Refueling Water Storage Tanks (RSWT), and 3B RHR pump, while the 4B HHSI pump, 3A RHR pump and B AFW pumps were OOS, on November 10, 2021.

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 3 RHR system, on November 2-4, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

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) Unit 3 and 4 Start-up transformer, Main transformer, and Auxiliary transformer areas, on October 13-14, 2021.

71111.08P - Inservice Inspection Activities (PWR) PWR Inservice Inspection Activities Sample (IP Section 03.01)

(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation by reviewing the following activities from October 11-28, 2021:

1. Ultrasonic Examination a. 10"-SI-1301-17, Pipe to Elbow, ASME Class 1 (reviewed)b. 10"-SI-1301-18, Elbow to Elbow, ASME Class 1 (reviewed)c.

10"-SI-1301-20, Elbow to Elbow, ASME Class 1 (reviewed)d. 10"-SI-1301-21, Pipe to Branch Connection, ASME Class 1 (reviewed)e. 3-PCW-4, Head to Lower Shell, ASME Class 2 (reviewed)2. Visual Examination a. Bottom Mounted Instrument Nozzle Penetrations, PEN01, PEN12, PEN16, PEN27, PEN35, PEN38, PEN 46, and PEN50, ASME Class 1 (reviewed)3. Eddy Current Testing (ECT)a. SG 3A, tube R001C013, ASME Class 1 (observed)b. SG B, tube R004C077, ASME Class 1 (observed)

The inspectors also evaluated the licensees boric acid control program performance.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." During the week of November 29, 2021, the inspector performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.

The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam completed on November 29, 2021.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

71111.11B - Licensed Operator Requalification Program and Licensed Operator

Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

The inspectors completed an inspection to verify the licensees ability to evaluate the performance of their licensed operators during the conduct of examinations, to assess their ability to properly develop and administer requalification annual operating tests and biennial written examinations, to evaluate the performance of the control room simulator and their testing and maintenance of the simulator, to ensure that licensed individuals satisfy the conditions of their licenses, and to assess their effectiveness in ensuring that operator license conditions are satisfied.

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on September 23, 2021

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test

The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security

The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations

The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions

The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator

The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution

The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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 Unit 3 reactor physics tests and start-up through MODE 2 and criticality on November 19, 2021.

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

(1) The inspectors observed and evaluated Just-In-Time training in the simulator for a down-power and unit manual trip for the upcoming refueling outage administered to an operating crew on October 1, 2021.

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) Maintenance Rule Functional Failure (MRFF) AR 2358251 - Degraded Cables at Location Manhole 320 and AR 2397255 - MRFF for Manholes 306 and 320, Due to Failure to Maintain Structural Integrity
(2) AR 02377877, HAS-016A Train A Post Accident Hydrogen Monitor South Bottle Isolation Valve is Leaking Oxygen

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:

(1) Degraded coatings and rust on containment liner: CR 02408675 (39 level),

===02408750 (58 level), 02408244 (14 level), and 02407783 (moisture barrier)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01)===

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) Unit 3 shutdown risk assessment during Mode 6 yellow risk profile, due to the reactor coolant system (RCS) drained below the flange for reactor head removal, and Unit 4 online risk assessment while operating at full rated power, on October 13, 2021.
(2) Unit 3 shutdown risk assessment during defueled yellow risk profile due the RCS drained down to hot leg mid-nozzle, the 3B safety-related 4160-volt switchgear and the 3A EDG OOS; Unit 4 online risk assessment with the containment radiation monitors R-11/12 OOS, on October 21, 2021.
(3) Unit 3 shutdown risk assessment during defueled yellow risk profile due to the 3B safety-related 4160-volt switchgear OOS, and Unit 4 online risk assessment while operating at full rated power with the 3B HHSI pump unavailable, on October 25, 2021.
(4) Unit 3 shutdown risk assessment while in MODE 5 and Unit 4 online risk assessment while operating a full rated power with the 3A RHR, 4B HHSI pump, B AFW pump, and the unit 4 pressurizer power operated relief valve block valve OOS, on November 10, 2021.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

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

(1) AR 02408108, Unit 3 3A RHR Pump Seal has Leakage
(2) AR 02408714, MOV-3-863 Test Acceptance Criteria Not Met
(3) AR 02409956, 3A EDG Coolant Return Coupling Leak
(4) AR 02411149, Identified 3" Long Boric Acid Accumulation Below the Canopy Seal Weld on Control Rod Drive Mechanism (CRDM) 15
(5) AR 02411150, Identified Boric Acid Leak on Core Exit Thermocouple (CET) 57; AR 02411154, Identified Boric Acid Leakage at Swage Lock Fitting on CET 51
(6) AR 02411240, Identified Boric Acid Residue on the Reactor Vessel Stud Insulation Package

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) EC 296594, U4 Containment Impressed Current Cathodic Protection (ICCP)

Discontinuity

(2) EC 296989, Abandonment of CET TE-3-39E (H-9) and TE-3-49E (N-8)

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) WO 40795920, 40724574, and 40724651, Post Maintenance Tests for Seal Replacement using surveillance procedure 3-OSP-050.2C, Residual Heat Removal Train A Comprehensive Test - Cooldown Alignment, on October 30, 2021.
(2) WO 40785630, 40789708 Post Maintenance Tests for Cable 3AB06/3AB06-3C03/002, on November 8, 2021.
(3) WO 40785630, 40789708 Post Maintenance Tests for Cable 3AB01/3AB01-3B06/001, on November 9, 2021.
(4) WO 40151537 and 40151538, Post Maintenance Tests for Containment Spray Piping Modification EC 291279, on November 5, 2021.
(5) WO 4067079701, 4067079702 and 4067079703, Replace positioner and perform calibration of actuator on air operated valve CV-3-2816, steam generator Train 1 AFW control valve, and test per MA-AA-100-1013, Air Operated Valve Diagnostic Testing and Inspection; and 3-OSP-075.10, AFW Flow Control Valve Operability Test, on November 11, 2021.
(6) WO 4080235802 and 4080235202, NOP/NOT post maintenance leak tests on CET-51 and CET-57, after repairing through-wall leak and swage lock fitting boron leaks and abandoning the CETs by cutting and caping tubes using swage lock fittings, on November 19, 2021.

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated PT3-32 activities from October 8-November 22, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 3-OSP-072.6, Main Steam Safety Valve Setpoint Surveillance Using Team Trevistest Mark Viii Equipment, (for relief valves RV-3-1400, RV-3-1401, RV-3-1402, and RV-3-1407), on October 8, 2021.
(2) 3-OSP-203.1, Train A Engineered Safeguards Integrated Test, completed November 1-9, 2021.
(3) 3-OSP-023.1, 3B EDG Normal Start Test, on November 29, 2021.

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) 3-OSP-051.5, Local Leak Rate Tests (Penetration 53 - PAC Vent), on October 21,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials, and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) workers exiting the RCA during Unit 3 refueling outage
(2) licensee surveys of potentially contaminated material leaving the RCA
(3) workers exiting Unit 3 containment during Unit 3 refueling outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) RWP No. 21-3100, Refueling Activities, Rev. 1
(2) RWP No. 21-3105, CET Replacement, Rev. 2
(3) RWP No. 21-3002, Radiation Protection Outage Containment Activities (Bulk Work),

Rev. 0 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Radwaste Building High Level Storage Area (LHRA)
(2) Auxiliary Building Unit 4 Base and Cation Room (LHRA)
(3) Auxiliary Building Basement (LHRA)
(4) Radwaste Building South Filling Room (LHRA)
(5) Unit 3 Containment

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.02 - Occupational ALARA Planning and Controls

Radiological Work Planning (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensees radiological work planning by reviewing the following ALARA plans.

(1) ALARA Plan U3R32 Core Exit Thermocouple Replacement
(2) ALARA Plan U3R32 Secondary Side Steam Generator Work
(3) ALARA Plan U3R32 Cont. Spray Pipe Replacement
(4) ALARA Plan U3R32 Reactor Sump Work-Non-Legacy Boric Acid

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)

The inspectors reviewed the following as low as reasonably achievable planning documents:

(1) ALARA Plan U3R32 Reactor Sump Work-Non-Legacy Boric Acid
(2) ALARA Plan U3R32 Secondary Side Steam Generator Work
(3) ALARA Plan U3R32 Core Exit Thermocouple Replacement

Additionally, the inspectors reviewed the following radiological outcome evaluations:

(4) U4R32 Refueling Activities, Including Fuel Cleaning and All Support Work Outage Critique
(5) U4R32 Reactor Sump Work-Non-Legacy Boric Acid Post Job Review

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (3 Samples)

The inspectors reviewed as low as reasonably achievable practices and radiological work controls including:

(1) RWP 21-3024, Bottom Mounted Instrumentation Project (BMI) including MIMS Troubleshoot and Repair Work
(2) RWP 21-3020, Unit 3R32 Steam Generator Secondary Side Work, Including All Support Work
(3) RWP 21-3105, Core Exit Thermocouple Replacement

Radiation Worker Performance (IP Section 03.04) (1 Sample)

(1) RWP 21-3100 and 21-3024, which included Unit 3 reactor reassembly, reactor head set, reactor cavity drain down, Tri-Nuke filter removal, under vessel inspection activities, upper internals move and general work in the reactor cavity

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Control Room Emergency Ventilation System

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Portable HEPA Unit No. 022

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee's external dosimetry program.

Internal Dosimetry (IP Section 03.03) (1 Sample)

The inspectors evaluated the following internal dose assessments:

(1) The inspectors reviewed the following:

Whole Body Counts Condition Report 20352998 and results of in-vivo analysis performed on April 16, 2020 Condition Report 20370956 and results of two in-vivo analyses performed on October 10, 2020

In-Vitro Internal Monitoring Licensee performed no In-Vitro analysis during the period covered by the inspection.

Dose Assessments Performed Using Air Sampling and Derived Air Concentration-Hour Monitoring Licensee did not perform any DAC-Hr assignments during the period covered by the inspection.

Special Dosimetric Situations (IP Section 03.04) (3 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Licensees implementation of requirements to manage radiation protection of declared pregnant workers for two workers
(2) Licensee calculations of EDEX from multi-dosimetry results for RWP 20-3100, Unit 3 Reactor Head Set, April 14, 2020
(3) Licensees application of multibadging requirements to determine EDEX for workers on RWP 21-3100, Unit 3 Reactor Head Set, November 3, 2021.

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (9 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Telepole in calibration lab
(2) AMP-100 in calibration lab
(3) Ludlum 9-3 in calibration lab
(4) RadEye-G in calibration lab
(5) Cronos at RCA exit
(6) ARGOS at RCA exit
(7) GEM-5 at PA exit
(8) Control Room ARM
(9) Unit 3 SFP ARM

Calibration and Testing Program (IP Section 03.02) (13 Samples)

The inspectors evaluated the calibration and testing of the following radiation detection instruments:

(1) MGP Instruments Telepole WR, SN #6601-090
(2) Canberra/Mirion Model 2250 Fastscan 2 - Whole Body Counter, SN #13000003
(3) Canberra/Mirion Model 2250 Fastscan 2 - Whole Body Counter, SN #97-7040
(4) Unit 3 - Containment High-Range Radiation Monitor, RAD-3-6311A
(5) Unit 3 - Containment High-Range Radiation Monitor, RAD-3-6311B
(6) Unit 4 - Containment High-Range Radiation Monitor, RAD-3-6311A
(7) Unit 4 - Containment High-Range Radiation Monitor, RAD-3-6311B
(8) Mirion AMP-200, GM Tube-Based Ratemeter and Area Monitor, SN #7705-020
(9) Canberra ARGOS 5AB, SN #0904-108
(10) Cronos Gamma Object/Tool Monitor, SN #1394
(11) GEM-5, Gamma Exit Monitor, SN: 1212-220
(12) Ludlum Model 9-3, Ion Chamber Survey Meter, SN #322843
(13) Thermo-Scientific Model RadEye G, SN #30042

Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Unit 3 - Spent Fuel Pool Vent Stack Radiation Monitor (RAD-3-6418 [SPING])

Calibration, dated May 20, 2020

(2) R-18 Liquid Effluent Process Radiation Monitor Calibration dated, July 6, 2021
(3) R-18 Liquid Effluent Process Radiation Monitor Calibration dated, January 8,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05)===

(1) Unit 3 (October 1, 2020-September 30, 2021)
(2) Unit 4 (October 1, 2020-September 30, 2021)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)

(1) Unit 3 (October 1, 2020-September 30, 2021)
(2) Unit 4 (October 1, 2020-September 30, 2021)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 3 (October 1, 2020-September 30, 2021)
(2) Unit 4 (October 1, 2020-September 30, 2021)

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 3 (October 1, 2020-September 30, 2021)
(2) Unit 4 (October 1, 2020-September 30, 2021)

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 3 (October 1, 2020-September 30, 2021)
(2) Unit 4 (October 1, 2020-September 30, 2021)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 2020-October 2021

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) February 2020-October 2021

71152 - Problem Identification and Resolution (PI&R)

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in material left unsecured in the RHR Pump rooms that might be indicative of a more significant safety issue.

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) RHR system alignment during plant cooldown to prevent gas voiding in piping, AR

INSPECTION RESULTS

Debris and Unsecured Equipment in the RHR Pump Rooms Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71152 Systems NCV 05000250,05000251/2021004-01 Management Open/Closed The NRC identified an adverse trend in the licensees ability to maintain the RHR pump rooms in compliance with housekeeping and conduct of maintenance procedures that prevent debris such as tie wraps, working gloves, pipe insulation, scaffold poles, tools, and uncontrolled and unsecured miscellaneous equipment from posing challenges to the screen and sump pump systems in the Unit 3 and Unit 4 RHR pump rooms. An NRC identified green non-cited violation (NCV) of Technical Specification 6.8.1 was identified for the licensees failure to implement required housekeeping and maintenance controls in the RHR pump rooms, as specified by procedures MA-AA-100-1008, Station Housekeeping and Material Control, and procedure MA-AA-100, Conduct of Maintenance.

Description:

On September 22, 2021, and November 2, 2021, NRC inspectors identified debris, tools, and uncontrolled and unsecured miscellaneous equipment (here-in referred to as debris) in the RHR pump rooms. This debris had the potential to partially clog the screen and sump pump system and render the flood mitigation feature unable to perform its function. In both examples, there was no engineering evaluation performed to support that the debris would not degrade the systems flood mitigation function. The licensees immediate actions included removing all debris from the RHR pump rooms. No past operability issues were identified for these two examples, as it was determined there was not enough debris to clog the RHR sump screens during a design basis flood event.

During the period of April 26, 2019, and November 2, 2021, 9 examples of debris were identified in the RHR pump rooms. Of these examples, four were identified by NRC inspectors, one by the RHR system engineer, three by operations personnel, and one by the Nuclear Assurance Organization. Additionally, the corrective action program (CAP)management review board had also identified an adverse trend associated with debris issues in the RHR pump rooms. In reviewing the RHR system performance history, the inspectors found that two NRC-identified non-cited violations associated with debris issues in the RHR pump rooms had been written: NCV 05000251/2019010-01, Inadequate Maintenance Procedures to Ensure Flood Protection for the 4A and B RHR Trains; and NCV 05000251/2016003-01, Failure to Provide Adequate Flood Protection for the 4A RHR Train. After each example, the licensees immediate actions included removing the debris from the RHR pump rooms to eliminate any potential challenges to the screen and sump pump system. In general, short term corrective actions included writing night orders to inform and remind plant personnel to maintain the RHR pump rooms free of debris. Long term corrective actions included installing signs in the RHR pump room doors to inform personnel to not leave debris in the rooms and, for interim periods, completing additional walkdowns in the RHR pump rooms to verify no debris was left in the rooms.

Overall, the repeated debris issues stemmed from the licensees non-compliance with station procedures that provide controls and prohibit debris from being left in the RHR pump rooms due to flooding mitigation required for protection of the RHR pumps. The inspectors concluded that a long-term adverse trend existed in the mishandling of debris in the RHR pump rooms. Despite the numerous issues that were entered into the CAP, the licensee had not been able to implement adequate controls to prevent debris accumulation and was repeatedly in noncompliance with station procedures that prohibit debris in the RHR pump rooms. Although no operability issues have been identified, if this adverse trend is not corrected, it has the potential to degrade the ability of the RHR room screen sump pump system from performing its flood mitigation function, which can consequently impact the operability of the RHR pumps.

Corrective Actions: After each incident the licensee immediately removed the debris from the RHR pump rooms.

Corrective Action References: AR 2404885

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees repeated failures to adequately implement station housekeeping and conduct of maintenance procedures, MA-AA-100-1008 and MA-AA-100, to maintain the RHR pump rooms free of debris and unsecured equipment was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to maintain the RHR pump rooms free of debris as required by station procedures led to unnecessary potential flood mitigation challenges to both Units in the RHR pump rooms.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was screened using IMC 0609, Attachment 4, Initial Characterization of Findings, Table 2, under the mitigating systems cornerstone for external event (flood), dated December 13, 2019, and IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 4 for external events, dated November 30, 2020.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. This finding was assigned a cross cutting aspect associated with the work management element of the human performance area because the licensee failed to adequately implement a process to control work activities in a high-risk flood area and did not adequately identify and manage risk associated with the flood-sensitive area (H.5).

Enforcement:

Violation: Technical Specification (TS) 6.8.1 requires that written procedures, required by the licensees Quality Assurance Topical Report (QATR), be established, implemented, and maintained. The QATR includes procedures listed in Appendix A of NRC Regulatory Guide 1.33, Revision 2, dated February 1978, including procedures for the control of maintenance. The QATR also commits to NRC Regulatory Guide 1.39, Revision 2, dated September 1977, specifying housekeeping requirements for operating nuclear power plants.

The licensee implements TS 6.8.1 requirements, in part, using NextEra Fleet Administrative Procedures MA-AA-100-1008, Station Housekeeping and Material Control; and MA-AA-100, Conduct of Maintenance. Step 4.4.1.c, of procedure MA-AA-100-1008 specifies Equipment shall not be left unattended (unsecured) in any area that has a sump pump installed to mitigate flooding of safety related equipment such as RHR, HHSI, Condensate, and Auxiliary Building, unless an Engineering evaluation is performed. Additionally, Step 5.6.1.D of MA-AA-100 specifies, Equipment shall not be left unattended in any area that has a sump pump installed to mitigate flooding of safety related equipment such as RHR, HHSI Condensate and Auxiliary Building unless an engineering evaluation is performed. Contrary to this requirement, from April 26, 2019, through November 2, 2021, 9 examples were identified in the Unit 3 and Unit 4 RHR pump rooms where the licensee had failed to establish required housekeeping and conduct of maintenance controls to ensure equipment was not left unattended (unsecured) to prevent flood protection devices that mitigated flooding of safety related equipment from being damaged or clogged, and none of the examples had engineering evaluations. After each example the licensee took immediate corrective actions to remove the debris from the RHR pump rooms.

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 September 22, 2021, the inspectors presented the Exit inspection results to Mr.

Michael Pearce, Site Vice President, and other members of the licensee staff.

On November 9, 2021, the inspectors presented the RP inspection exit inspection results to Mr. Michael Pearce and other members of the licensee staff.

On January 26, 2022, the inspectors presented the integrated inspection results to Mr.

Michael Pearce and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P NDE Reports Test #03-RCS-Final NOP/NOT Visual Examination Record (VT-2), CET 51, 11/18/21

4150-L-01 (Data CET 57, and CRDM No. 15, Seal Weld of Latch Assembly to

Sheet# 03-RCS-Adaptor Area Examination and other RVCH Areas

4150-L-01)

71111.11B Miscellaneous Administrative 01046031106, 02046031106, 01041046101, 02041046101

JPM's

Control room and ID 24030008300, 14003011101, 01046006100,

in-plant JPM's 010150005505, 24030009301, 14200014303, 01005015503,

200035502

Operator Medical medical records

Records

(8 records)

Operator Reactivation documents

Reactivation

Documentation

Operator Operator remediation records

Remediation

Records

2019-2021

Operator Time on License Maintenance Records

Shift (License

Maintenance)

records

RO Written Biennial written exam

Exam X

RO Written Biennial written exam

Exam Y

Simulator ID: 8300, 6901, 3500, 4901

Scenarios

Simulator Testing Simulator testing documents

Documentation

Inspection Type Designation Description or Title Revision or

Procedure Date

SRO Written Biennial written exam

Exam X

SRO Written Biennial written exam

Exam Y

Training Licensed Operator Training Attendance 2019-2021

Attendance

(8 samples)

71124.01 Corrective Action AR 02403796 09/10/2021

Documents

Corrective Action AR 02410183 11/03/2021

Documents AR 02410224 11/03/2021

Resulting from AR 02410757 11/08/2021

Inspection

Procedures 0-HPT-020 Operation of the MGPI Self Reading Dosimeter Models Rev. 3

DMC-2000 and DMC-3000

0-ONOP-016.8 Response to a Fire / Smoke Detection System Alarm Rev. 23

Radiation Work 21-0900 Unit 3 or Unit 4 Containment Building Emergency Entry Rev. 0

Permits (RWPs)

71124.02 Corrective Action AR 02410205

Documents

Resulting from

Inspection

Procedures Radiation Work Rev. 4B

Permit Initiation

and Termination

71124.05 Corrective Action AR 02410758 11/08/2021

Documents AR 02410759 11/08/2021

Resulting from

Inspection

Procedures 0-HPT-072 Calibration and Operation of Canberra Personnel Monitors Rev. 5A

RP-TP-105-3007 Operation and Calibration of the GEM-5 Gamma Exit Rev. 6

Monitor

19