IR 05000250/2022010

Triennial Fire Protection Inspection Report 05000250/2022010 and 05000251/2022010

ML22332A005
Person / Time
Site:	Turkey Point
Issue date:	11/29/2022
From:	Gerald Mccoy NRC/RGN-II/DRS/EB2
To:	Coffey B Florida Power & Light Co
References
IR 2022010
Download: ML22332A005 (13)

Text

November 29, 2022

SUBJECT:

TURKEY POINT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000250/2022010 AND 05000251/2022010

Dear Bob Coffey:

On October 20, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point and discussed the results of this inspection with Mr. Brian Stamp 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.

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. 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, Gerald J. McCoy, Chief Engineering Br 2 Division of Reactor Safety 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: 05000250/2022010 and 05000251/2022010

Licensee: Florida Power & Light Company

Facility: Turkey Point

Location: Florida City, FL

Inspection Dates: October 03, 2022 to October 21, 2022

Inspectors: L. Jones, Senior Reactor Inspector J. Montgomery, Senior Reactor Inspector M. Singletary, Reactor Inspector D. Strickland, Reactor Inspector

Approved By: Gerald J. McCoy, Chief Engineering Br 2 Division of Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Turkey Point, 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

Failure to Follow Procedure for Diesel Driven Fire Pump Surveillance Results in Pump Runout Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.21N.

Systems NCV 05000250,05000251/2022010-01 Procedure 05 Open/Closed Adherence A self-revealed Green finding and associated non-cited violation (NCV) of Turkey Point Units and 4 Technical Specifications Section 6.8.1a was identified when the licensee failed to follow a procedure for fire pump surveillance.

Failure to Adequately Evaluate a Surveillance Frequency Change to Fire Protection Program Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.

Systems NCV 05000250,05000251/2022010-02 05 Open/Closed The inspectors identified a Green finding and associated NCV of Turkey Point Operating License Condition 3.D when the licensee failed to establish adequate test control for verifying functionality of the 4C Charging Pump Breaker normal/isolate transfer switches.

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.

REACTOR SAFETY

===71111.21N.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Halon 1301 system in FA NN/FZ 108A (Units 3 and 4 A DC Equipment Room)

(2) Very Early Warning Fire Detection System (VEWFDS) in FA U/FZ 67 (4160V Switchgear 4B Room)

(3) Unit 3 125VDC Distribution System

(4) Unit 4 Chemical Volume Control System

Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)

The inspectors verified that the selected process is implemented in accordance with the licensees current licensing basis, ensured that the licensees FPP contains adequate procedures to implement the selected administrative control, and verified that the selected administrative control meets the requirements of all committed industry standards.

(1) NFPA 805 Monitoring Program

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) PTN-FPER-21-006, R0, PTN Fire Protection Evaluation Supporting Removal Of Fire Hose From Hose Stations

(2) PTN-FPER-21-011, R0, PTN Fire Protection Surveillance Optimization - Phase 3 Fire Water Systems

INSPECTION RESULTS

Failure to Follow Procedure for Diesel Driven Fire Pump Surveillance Results in Pump Runout Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.21N.0 Systems NCV 05000250,05000251/2022010-01 Procedure 5 Open/Closed Adherence A self-revealed Green finding and associated non-cited violation (NCV) of Turkey Point Units 3 and 4 Technical Specifications Section 6.8.1a was identified when the licensee failed to follow a procedure for fire pump surveillance.

Description:

On August 17, 2022, surveillance of the Diesel Driven Fire Pump (DDFP) was performed via procedure 0-OSP-016.2, "Diesel Driven Fire Pump Annual Surveillance Test."

Step 7.7 of this procedure stated, Establish initial valve lineup as follows and contains 6 substeps. Five of the substeps involved verifying or manipulating the position of valves. Step 7.7.6 stated, "Unlock Full Flow Recirc[ulation] valve 10-760." The step did not include direction to manipulate the valve. Upon reaching this step of the procedure, the operator unlocked and fully opened valve 10-760. After opening the valve, the operator observed pump discharge pressure of 25 PSIG, which was lower than expected. About 15 minutes after the initial pump start, while the operator consulted with the main control room, the operator observed smoke rising from the pump engine and coolant overflowing from the surge tank.

The pump was secured, declared out of service, and compensatory measures were implemented. By analysis of an oil sample, the pump vendor determined that there was no permanent damage to the engine. Plant personnel subsequently overhauled the pump, and performed a surveillance test, with the pump passing the test satisfactorily.

Corrective Actions: Corrective actions consisted of remediation of the individual operator, as well as a procedure change to move the mis-performed step to a different section of the procedure.

Corrective Action References: ARs 2434543 and 2434544

Performance Assessment:

Performance Deficiency: The licensee's failure to follow procedure in accordance with Technical Specification 6.8.1a 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, there was reasonable doubt whether the pump, following the event, would have been capable of performing its safety function.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using IMC 0609, Appendix F, Attachment 1, the inspectors determined the issue was of very low safety significance (Green) because the resulting non-functional fixed suppression system did not adversely affect the ability of the system to protect equipment important to safe shutdown (Question 1.4.2-A), because a redundant 100% capacity motor driven fire pump was still available.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the diesel driven fire pump was declared out of service as a result of an operator failing to follow a surveillance procedure. During performance of the procedure, the operator also failed to use human error reduction techniques that could have prevented the error.

Enforcement:

Violation: Turkey Point Units 3 and 4 Technical Specifications Section 6.8.1a states, in part, "Written procedures shall be established, implemented, and maintained covering activities referenced by the site Quality Assurance Topical Report." Section A.1 of the site Quality Assurance Topical Report (QATR) states that elements of the Quality Assurance Program are applied to fire protection activities and also states, in part, "NextEra Energy commits to compliance with NQA-1, 1994, Basic Requirement 5." NQA-1-1994, "Quality Assurance Requirements for Nuclear Facility Applications," Basic Requirement 5 states, in part, "Activities affecting quality shall be prescribed by and performed in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances."

Contrary to the above, on August 17, 2022, an activity affecting quality was not performed in accordance with a documented procedure of a type appropriate to the circumstances.

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

Failure to Adequately Evaluate a Surveillance Frequency Change to Fire Protection Program Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N.0 Systems NCV 05000250,05000251/2022010-02 5 Open/Closed The inspectors identified a Green finding and associated NCV of Turkey Point Operating License Condition 3.D when the licensee failed to establish adequate test control for verifying functionality of the 4C Charging Pump Breaker normal/isolate transfer switches.

Description:

The inspectors reviewed test records for the components that can be controlled from the alternative shutdown panel. These tests help to ensure the functionality of those components that are credited for fire scenarios that lead to main control room abandonment.

During a review of the testing documents for the 4C Charging Pump Breaker normal/isolate transfer switch, inspectors noted that the testing frequency was changed from 54 months to 72 months in 2017. The change was approved under a preventative maintenance change request (PMCR) document, ER-AA-204-2006-F02, change evaluation form. According to the PMCR, the surveillance frequency change from 54 months to 72 months was based on the rugged build quality of the switches and the reliable performance history. The change was not identified to affect the fire protection program under section C1 of the PMCR, and therefore, never received a fire protection program evaluation. The original frequency of testing this switch was 18 months, in accordance with a commitment made to the NRC in 1983 regarding alternate shutdown capability. The licensee was unable to provide a justification for the surveillance frequency change from 18 months to 54 months.

In 2021, as part of an unrelated effort, the site performed an evaluation to extend the testing frequency of similar transfer switches that are tested via a different procedure. The evaluation was for changing the testing frequency from 18 months to 36 months. The evaluation for this change stated that the 36-month frequency was established consistent with the guidelines and methodology of EPRI Report TR001006756, Fire Protection Equipment Surveillance Optimization and Maintenance Guide, dated July 2003.

The test frequency changes for the 4C Charging Pump Breaker normal/isolate transfer switches from 18 months to 54 months, and subsequently from 54 months to 72 months were not adequately evaluated and is not consistent with the 36-month test frequency established for other similar components.

Corrective Actions: The licensee wrote a CR to track the issue and evaluate current and recommended PM frequencies.

Corrective Action References: AR 2439940

Performance Assessment:

Performance Deficiency: The licensee's failure to establish test control in accordance with Turkey Point Operating License Condition 3.D was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment 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 PD resulted in a meaningful and substantive reduction in margin with respect to an acceptable testing frequency.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using IMC 0609, Appendix F, Attachment 1, the inspectors determined the issue was of very low safety significance (Green) because inspectors assigned the fining a Low degradation rating (Question 1.3.1-A).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Turkey Point Unit 4 OLC 3.D required, in part, for the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48(c),

National Fire Protection Association Standard NFPA 805, as specified in the license amendment request dated June 28, 2012. Section 4.7.3 of the June 28, 2012 license amendment request stated that FPL will maintain the existing Fire Protection Quality Assurance (QA) Program. The QATR also states that selected elements of the QA program are applied to fire protection activities. QATR Section B.8, Test Control states, in part, Testing programs are established and implemented to demonstrate that items subject to the provisions of this QATR will perform satisfactorily in service. These programs include criteria for determining when testing is required, such as operational tests, to demonstrate that performance of plant systems is in accordance with design intent.

Contrary to the above, since 2017, the licensee failed to adequately implement a testing program that included criteria for determining when testing the 4C Charging Pump isolation capability is required to demonstrate that performance of plant systems is in accordance with design intent.

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 October 20, 2022, the inspectors presented the triennial fire protection inspection results to Mr. Brian Stamp and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Corrective Action AR 2434543 Spilled Coolant and Smoke from DDFP Surveillance During 8/17/2022

Documents Run

AR 2434544 DDFP Motor Smoke and Low Discharge Press During Run 8/17/2022

AR 2436974 TSC Plant Page Speaker Unintelligible 09/21/2022

CR 01-0326-2 6/20/2001

CR 2007-26147 Cable Spreading Room Halon Bottle Charge Labels 8/29/2007

Corrective Action AR 2438754 Emergency Light EL085-30 in the 3A DC Equipment Room 10/5/2022

Documents only has one light bulb.

Resulting from AR 2438917 Drawing 5610-E-1397 Sheet 1 identifies dampers that are 10/6/2022

Inspection affected by Halon System Initiation. 0-ONOP-016.8

for FZ 108A and 108B identifies dampers that

are

affected by Halon initiation. These two documents do not

match....

AR 2438918 NRC Identified DBD Valves Not in ONOP 10/11/2022

AR 2438922 New 'A' Series padlock needed for the SNPO Shelter ICCS 10/6/2022

Box.

AR 2438998 5610-016-DB-001 and 0-ONOP-105 Need Revisions 10/7/2022

AR 2439145 The NRC questioned if Code NFPA 76 should be 10/11/2022

referenced in Appendix G, Code Of Record of 5610-016-

DB-001, despite being referenced in EC 282418

AR 2439940 ALT SHUTDOWN PANEL PM CHANGE NOT EVALUATED 10/20/2022

PER FP PROGRAM

Drawings 5613-M-3047 Chemical and Volume Control System Charging and Rev. 24

Letdown, Sheet 1

5613-M-3047 Chemical and Volume Control System Charging and Rev. 59

Letdown, Sheet 2

5613-M-3047 Chemical and Volume Control System Charging and Rev. 32

Letdown, Sheet 3

5614-M-3047 Chemical and Volume Control System Charging and Rev. 24

Letdown, Sheet 1

5614-M-3047 Chemical and Volume Control System Charging and Rev. 69

Inspection Type Designation Description or Title Revision or

Procedure Date

Letdown, Sheet 2

5614-M-3047 Chemical and Volume Control System Seal Water Injection Rev. 29

to RCP, Sheet 3

Engineering EC-296561 Alternate Shutdown Surveillance extension Rev. 0

Changes PCR 2291468 Enhancement adds guidance to prevent water hammer Rev. 23

when starting a Charging pump and starting a CCW pump.

(AR 224498224498

PTN-FPER-21-PTN Fire Protection Evaluation Supporting Removal of Fire 8/19/2021

006 Hose from Hose Stations

PTN-FPER-21-PTN Fire Protection Surveillance Optimization-Phase 3 Fire 9/2/2021

011 Water Systems

Engineering 5610-016-DB-001 Fire Protection System NFPA 805 Design Basis

Evaluations 5610-E-2000A Nuclear Safety Capability Fire Shutdown Analysis Essential Rev. 13

Cable List

5610-M-722B Nuclear Safety Capability Fire Safe Shutdown Analysis Rev. 8

(NSCA)

5610-M-723A Nuclear Safety Capability Fire Shutdown Analysis Essential Rev. 7

Equipment List

ER-AA-204-2006-PMCR Change Evaluation Form for 45007 and 45008 Rev. 3

F02 Norm/Isolate Transfer Switch Test PM

PTN-BFJR-16-Turkey Point Units 3 and 4 Fire Probabilistic Risk Rev. 2

034 Assessment Fire Scenario Report NUREG/CR-6850 Tasks

and 11

PTN-BFJR-16-Turkey Point Nuclear Plant FPRA Summary Report Rev. 3

057

PTN-FPER-11-NFPA 805 Recovery Action Feasibility Evaluation Rev. 1

2

Miscellaneous 5177-265-EG-22 Circuit Breaker/Fuse Coordination Study Rev. 9

5614-E-25 Reactor Auxiliaries Charging Pump 4P201C Breaker 45008 Rev. 8

JPM Adjust Reactor Cooling Pump Seal Injection JPM Rev. 0

24047033101

JPN-PTN-SEMJ-Turkey Point Plant Units 3 and 4 Safety Evaluation Rev. 0

89-109

Turkey Point Amendment

Inspection Type Designation Description or Title Revision or

Procedure Date

Nuclear Plant Nos. 288

Units 3 and 4 and 282

Technical

Specifications

Turkey Point 05/17/2021

Units 3 and 4

Updated FSAR

Procedures 0-ADM-016 Fire Protection Program Rev. 33

0-ADM-232 Time Critical Operator Action Program Rev. 16

0-ONOP-025.3 DC Equipment and Inverter Rooms Supplemental Cooling Rev. 4A

0-OSP-200.1 Schedule of Plant Checks and Surveillances Rev. 39

3-OSP-300.1 Alternate Shutdown Panel 3C264 Operability Test Rev. 15A

4-OSP-300.3 Safe Shutdown and Alternate Shutdown Operability Test Rev, 4A

4-OSP-300.4 Dedicated Alternate Shutdown Communications System 08/18/2022

Operability Test

EN-AA-202-1004 Fire Protection Screening Rev. 13

EN-AA-203-1100- NFPA 805 Monitoring Program Phase 2/3: Screening and Rev. 7

F01 Risk Target Values

FP-AA-104-1006 Implementation of the NFPA 805 Monitoring Program Rev. 5

FPL-1 Quality Assurance Topical Report Rev. 28

O-ONOP-016.10 Safe Shutdown Manual Actions Rev. 44A

O-ONOP-105 Control Room Evacuation Rev. 26A

Self-Assessments AR #02424658-Turkey Point Fire Protection Program Focused Self- 08/18/2022

Assessment

Work Orders 4083617702 PT-4-406 Failing - Replace Transmitter 09/01/2022

10