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Biennial Problem Identification and Resolution Inspection Report 05000250/2021012 and 05000251/2021012
	ML21125A227
Person / Time
Site:	Turkey Point
Issue date:	05/05/2021
From:	David Dumbacher; NRC/RGN-II/DRP/RPB3
To:	Moul D; Florida Power & Light Co
References
	IR 2021012
	Download: ML21125A227 (20)
	v • d • e

May 5, 2021

SUBJECT:

TURKEY POINT UNITS 3 & 4 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000250/2021012 AND 05000251/2021012

Dear Mr. Moul:

On March 26, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Turkey Point Units 3 & 4 and discussed the results of this inspection with Mr. Michael Pearce and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. 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, Acting 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:

05000250/2021012 and 05000251/2021012

Enterprise Identifier: I-2021-012-0003

Licensee:

Florida Power & Light Company

Facility:

Turkey Point Units 3 & 4

Location:

Homestead, FL 33035

Inspection Dates:

March 08, 2021 to March 26, 2021

Inspectors:

A. Beasten PhD, Resident Inspector

A. Goldau, Operations Engineer

N. Pitoniak, Sr. Fuel Facility Project Inspector

R. Reyes, Resident Inspector

Approved By:

David E. Dumbacher, Chief

Reactor Projects Branch 3

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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 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.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

Main article: IP 71152

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the high head safety injection system and instrument air systems.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Assessment: Based on the samples reviewed, the team determined that the licensees corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensees implementation of the CAP adequately supported nuclear safety.

Effectiveness of Problem Identification: The inspectors determined that the licensee was effective in identifying problems and entering them into the CAP at the appropriate threshold. This conclusion was based on a review of the requirements for initiating action requests (ARs) as described in licensee procedure PI-AA-104-1000, "Condition Reporting,"

and the site's management expectation that employees were encouraged to initiate condition reports. Additionally, site management was actively involved in the corrective action program and focused appropriate attention on significant plant issues. The inspectors reviewed ARs system health trending for Component Cooling Water Systems, High Head Safety Injection, Emergency Diesel Generators, and the Instrument Air System, and performed walkdowns of accessible portions of select systems. Based on the inspectors' reviews and walk downs, the inspectors determined that deficiencies were being identified and placed in the CAP.

Effectiveness of Problem Prioritization and Evaluation: Based on the review of ARs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the AR significance determination guidance in procedure PI-AA-104-1000. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the licensees CAP procedures, including appropriate cause determinations, and performed adequate levels of analysis based on the significance of the issues being evaluated.

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 corrective actions were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed performance indicators, CRs, and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

Assessment 71152B Operating Experience, Self-Assessments, and Audits: The inspectors examined the licensee's program for obtaining and using industry operating experience. This included a review of procedure PI-AA-102, "Operating Experience Program," selected corrective action program action requests, and the licensees operating experience (OE) database to assess the effectiveness of how external and internal OE data was evaluated at the plant. Additionally, the inspectors selected OE documents such as NRC generic communications, licensee event reports, vendor notifications, and plant internal OE items which had been issued since March 2019 to verify that the licensee had appropriately evaluated each notification for applicability to the station, and whether issues identified through these reviews were entered into the CAP.

The inspectors determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The inspectors verified that ARs were created to document areas for improvement and findings resulting from self-assessments and verified that actions had been completed consistent with those recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.

The inspectors determined that the station's processes for the use of industry and NRC operating experience information and for the performance of audits and self-assessments were effective and complied with all regulatory requirements and licensee standards. The implementation of these programs adequately supported nuclear safety. The inspectors concluded that operating experience was adequately evaluated for applicability and that appropriate actions were implemented to address lessons learned as needed. The inspectors determined that the licensee was effective at performing self-assessments and audits to identify issues at a low level, properly evaluated those issues, and resolved them commensurate with their safety significance.

Assessment 71152B Safety Conscious Work Environment: Based on a sample of at least 20 individuals interviewed from a cross-section of plant employees, the inspectors found no evidence of challenges to the safety conscious work environment. Employees interviewed appeared knowledgeable of avenues to raise safety concerns and appeared willing to raise nuclear safety concerns through at least one of the several means available.

EXIT MEETINGS AND DEBRIEFS

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

On March 26, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Michael Pearce and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Turkey Point - 2021012
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \| 26 \|
2021 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 10(0) 11(0) 12(0) 40(0) 90(0) Security 401(0) 420(0) Operator Exams 301(0) Emergency Planning Other

IR 05000250/2021012