IR 05000250/2022002

Integrated Inspection Report 05000250/2022002 and 05000251/2022002

ML22224A051
Person / Time
Site:	Turkey Point
Issue date:	08/12/2022
From:	David Dumbacher NRC/RGN-II/DRP/RPB3
To:	Coffey B Florida Power & Light Co
References
IR 2022002
Download: ML22224A051 (12)

Text

SUBJECT:

TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2022002 AND 05000251/2022002

Dear Mr. Coffey:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On July 14, 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.

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, 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: 05000250/2022002 and 05000251/2022002

Licensee: Florida Power & Light Company

Facility: Turkey Point Units 3 & 4

Location: Homestead, FL

Inspection Dates: April 01, 2022 to June 30, 2022

Inspectors: W. Deschaine, Senior Resident Inspector M. Endress, Senior Resident Inspector J. Hickman, Acting Senior Resident Inspector R. Reyes, Resident Inspector

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 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

Type Issue Number Title Report Section Status LER 05000250/2021-003-00 LER 2021-003-00 for Turkey 71153 Closed Point Unit 3 regarding Auxiliary Feedwater Actuation due to Feedwater Isolation During Plant Shutdown

PLANT STATUS

Unit 3 began this inspection period at 100 percent of rated thermal power (RTP) where it remained throughout this inspection period. Unit 4 began this inspection period in a refueling outage at 0 percent RTP. Unit 4 returned to 100 percent of RTP on April 11, 2022, where it remained for the rest 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 activities described in IMC 2515, Appendix D, Plant Status, 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 the seasonal extreme weather conditions prior to the onset of summer hot weather, seasonal heavy rain, and hurricane season for the following systems and areas where Unit 3 and Unit 4 systems are located:

intake cooling water (ICW) system and intake structure auxiliary feedwater (AFW) system emergency diesel generator (EDG) buildings component cooling water (CCW) systems auxiliary building roof

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to tropical storm Alex on June 03, 2022.

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) A and B AFW pumps with C AFW out of service (OOS) for maintenance on April 18, 2022 (2) 4B EDG while the 4A EDG was OOS for testing on April 12, 2022 (3) 3B residual heat removal (RHR) train while the 3A RHR train was OOS for testing on April 20, 2022 (4) unit 3A containment spray pump (CSP) while the 3B CSP was OOS for maintenance on April 29, 2022 (5) 4A EDG, unit 4 startup transformer and unit 3 transfer switch while the 4B EDG was OOS for maintenance on May 04 and 05, 2022

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

(1) The inspectors evaluated system configurations during a complete walkdown of the unit 3 and unit 4 instrument air (IA) system on June 01 to June 30, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) unit 3B and unit 4B motor control centers, and plant computer room, fire zones (FZs)

063 and 061, on April 05, 2022 (2) unit 3 main, startup and auxiliary transformer areas, FZs 086 and 087, on May 05, 2022 (3) unit 4 main, startup and auxiliary transformer areas, FZs 081 and 082, on May 05, 2022 (4) unit 3 and unit 4 charging pump rooms, FZs 045 and 055, on May 17, 2022

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) unit 3 and unit 4 safety injection (SI) pump rooms

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)

The inspectors observed and evaluated licensed operator performance in the control room during:

(1) unit 4A, B and C reactor coolant pump (RCP) loop sweeps, reactor head venting, and 4A CSP dynamic venting on April 05, 2022

unit 4 reactor physics testing and startup, entrance into Mode 2 on April 09, 2022 unit 4 turbine overspeed test coordination, blowdown adjustment, and power ramp operations on April 10, 2022 unit 3 and unit 4 during a shared system train 1 quarterly surveillance of the AFW system on June 15, 2022

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

(1) The inspectors observed and evaluated a training simulator scenario administered to an operating crew on May 10, 2022

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) action requests (ARs) 2384252, 2426694, 2383277 and 1966380, maintenance rule evaluation for surveillance and post maintenance test failures of valve 3-759A, RHR heat exchanger A outlet valve (2) AR 2392108 and evaluation PTN-013-LD-02363, 3 CD IA compressor (a)(1)

evaluation

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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) unit 3 online risk assessment and unit 4 outage risk assessment while the train 2 AFW system was OOS for testing, and the emergent issue associated with entering technical specification (TS) 3.0.3 on unit 4 for an inoperable RHR system on April 07, 2022 (2) unit 3 and unit 4 online risk assessment while the 4B EDG was out of service for maintenance and the 4B SI pump not capable of being powered from its associated diesel generator, on May 02, 2022 (3) unit 3 and unit 4 on-line risk assessment while the 3A SI pump and 3B CCW heat exchanger were OOS for maintenance on May 17, 2022 (4) unit 3 and unit 4 on-line risk assessment while the 4A EDG, 4A1 battery charger, Unit 4 AFW train 1, and 4B CCW heat exchanger was OOS on May 23 and 24, 2022 (5) unit 3 and unit 4 on-line risk assessment while train 1 of the AFW system, 3A ICW pump, 3A CCW heat exchanger were OOS on June 15, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

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

(1) AR 2384252, operability on 3-759A, RHR heat exchanger A outlet valve, difficult to operate and will not close (2) AR 2427867, prompt operability determination for corrosion identified on conduit support for the 3C ICW pump motor (3) AR 02428727, 02427078, 4B EDG operability due to breaker to switchgear white light found off after testing

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) design equivalent change (DEC) 296152, Install Permanent Bypass Breaker Contacts on Test Points to Support Reactor Protection System Testing (2) DEC 297448, Unit 4 Containment Moisture Barrier Removal (3) DEC 292067, Install Permanent Strong Back Configuration to Replace the Sheared Hold Down Bolt for the 3A ICW Pump

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (9 Samples)

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

(1) work order (WO)# 40781283, unit 4 RHR venting using 4-OSP-202.2, RHR pump and pipe venting and ultrasonic testing, after identifying gas in the system on April 07, 2022 (2) WO# 4075478402, 4075478702, 4076412502, AFW valves CV-2816, 2817 and 2818 and test on April 08, 2022 (3) WO# 4081993516, 4081993529, 4081993532, MOV-4-744B repair and cleaning on April 19, 2022 (4) WO# 40733055, unit 3 ICW header leak repair on April 20, 2022 (5) WO# 40765373, post maintenance testing of valve 3-759A, RHR heat exchanger outlet valve, after performing maintenance on valve wheel and reach rod gear boxes, on April 20, 2022 (6) WO# 40784487 and 4069548301, test per 3-OSP-068.5B, 3B Containment Spray Pump Inservice Test, after completing preventive maintenance of inspecting and lubricating pump coupling on April 29, 2022 (7) WO# 4078730501, test per 4-OSP-023.1, Diesel Generator Operability Test (7.2 4B EDG Normal Start Test), after completing maintenance on the engine governor on May 09, 2022

(8) WO# 4072714801, testing of valve MOV-4-1405 after starter inspection, on May 25, 2022 (9) WO# 40770010, P210B Inspect 4B RHR Motor, post maintenance testing performed per MA-AA-203-1000, Maintenance Testing, on July 10, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) 0-OSP-040.19, Low Power Physics Testing, on April 10, 2022 (2) 4-OSP-041.17, RCS/RHR LOOP Pressure Boundary Leak Test, on April 28, 2022

Inservice Testing (IP Section 03.01) (4 Samples)

(1) 4-OSP-064.1, SI Check Valve Full-Flow Test, on April 01, 2022 (2) 4-OSP-062.4, Safety Injection System - Full Flow Test, on April 25, 2022 (3) 3-OSP-019.1, Intake Cooling Water In-service Test, June 16, 2022 (4) 3-OSP-075.6, Auxiliary Feedwater Train 1 Backup Nitrogen Test (Pump A Test), on June 15, 2022

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) unit 3, April 1, 2021 through March 31, 2022 (2) unit 4, April 1, 2021 through March 31, 2022

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) unit 3, April 1, 2021 through March 31, 2022 (2) unit 4, April 1, 2021 through March 31, 2022

71152A - Annual Follow-up Problem Identification and Resolution

Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)

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

(1) The inspectors reviewed AR 2406811, unit 3 steam generator level rise and AFW actuation during cool down. The inspectors reviewed the cause of the failed equipment that resulted in the AFW actuation and reviewed the corrective actions that were completed to address the cause.

71152S - Semiannual Trend Problem Identification and Resolution

Semiannual Trend Review (Section 03.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program, for the period of October 2021 to April 2022, for potential adverse trends in the area of risk assessments that might be indicative of a more significant safety issue. The inspectors identified an adverse trend in the licensees processing of on-line and outage risk assessments, which is discussed in the results section of this report.

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000250/2021-003-00, Auxiliary Feedwater Actuation due to Feedwater Isolation During Plant Shutdown (ADAMS Accession No. ML21336A205): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

INSPECTION RESULTS

Minor Violation 71152S During the period of October 2021 to April 2022, the inspectors identified the following five examples in which the licensee failed to perform adequate on-line and outage risk assessments:

1. On October 25, 2021, the licensee failed to assess the increase in risk to the unit 4 core damage frequency (CDF) prior to performing maintenance on the Unit 3 3B 4160-Volt safety-related switchgear. The inspectors identified that the risk configuration was not correctly reflected in the online CDF risk calculation. Specifically, the 3B switchgear should have been entered in the online risk monitor (OLRM) as unavailable, to correctly model the increase in CDF to unit 4 despite the fact that unit 3 was in an outage mode.

2. On January 24, 2022, the licensee failed to properly assess change in unit 3 and unit 4 CDF with the motor driven 4CM IA compressor OOS for maintenance. Specifically, the licensee found that the unavailable 4CM was initially added to the OLRM but was mistakenly removed during a subsequent entry into the application software.

3. On March 16, 2022, the licensee failed to assess the increase in CDF when surveillance testing on the unit 4 SI pumps resulted in a configuration that would not allow the unit 4 SI pumps to automatically inject to unit 3 on an SI actuation. Additionally, the inspectors assessed that operator actions would be needed to restore the unit 4 SI system from this configuration to be ready and available to inject to unit 3 if needed for accident mitigation. The timing to complete these operator actions had not been validated.

4. On March 16, 2022, the inspectors noted that 4B EDG and 4B SI pump were not shown as unavailable on the OLRM with the 4B EDG sequencer OOS for maintenance. Through discussions with the licensee's subject matter expert (SME),

the inspectors learned that the CDF was calculated correctly; when entering the 4B

EDG sequencer tagout into the OLRM, the software takes into consideration that the 4B EDG and 4B SI pump unavailability and calculates the CDF for that configuration. However, the inspectors identified that control room operators did not fully understand the risk configuration and were not aware the corresponding 4B EDG and 4B SI pump were also unavailable during the sequencer tagout.

5. On April 07, 2022, during surveillance testing on the RHR system, with unit 4 in mode 4, both trains of the RHR system were found to be inoperable due to gas voiding. Unit 4 entered TS 3.0.3. for an inoperable RHR flow path to the reactor coolant system.

The inspectors determined that the licensee failed to assess the increase in risk upon identifying the RHR system was unavailable and prior to performing maintenance on the RHR system.

Screening: The inspectors determined the performance deficiency was minor. Title 10 Code of Federal Regulations (10 CFR) 50.65 (a)(4) states, Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety. The inspectors determined that the licensees repeated failures to assess and manage the increase in risk that could result from the proposed maintenance activities as required by 10CFR 50.65(a)(4) were performance deficiencies that were within the licensees ability to prevent. The inspectors assessed, however, that none of the performance deficiencies were more than minor due to the quantitative change in CDF not being significant when the risk assessments were corrected. Additionally, with respect to the RHR system inoperability, due to the very short period of increased risk and the licensee's operability evaluation concluding that the RHR system was operable, the inspectors assessed that performance deficiency was not more than minor.

The licensee entered this adverse trend in risk assessments into the CAP as AR 2431897. The individual occurrences were entered into the CAP as ARs 2409012, 2416919, 2424119, 2425926, and 2429857.

Enforcement: This failure to comply with 10 CFR 50.65 (a)(4) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Inadequate Online and Outage Risk Assessments 71152S The inspectors identified an adverse trend in the licensees processing of on-line and outage risk assessments and determined that control room operators had some lack in knowledge in understanding and assessing reactor core damage frequency risk. Most of the issues related to assessing risk on shared systems between unit 3 and unit 4. Unique design and reactor safety features of Turkey Point units 3 and 4 include the usage of shared systems. As a result, there are few times that the units operate in a higher CDF status, i.e., outside the normal operational green risk band. Risk significant shared systems include the EDGs, SI, AFW, and IA. The inspectors determined a potential programmatic issue in processing risk assessments and/or the understanding of assessing CDF risk.

The licensee acknowledged the adverse trend and entered this issue into the CAP as AR 2431897.

EXIT MEETINGS AND DEBRIEFS

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

On July 14, 2022, the inspectors presented the integrated inspection results to Mr.

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

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