IR 05000250/2023001
| ML23132A307 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/12/2023 |
| From: | David Dumbacher Division Reactor Projects II |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2023001 | |
| Download: ML23132A307 (14) | |
Text
SUBJECT:
TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2023001 AND 05000251/2023001
Dear Bob Coffey:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On April 18, 2023, the NRC inspectors 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.
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 Units 3 & 4.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Turkey Point Units 3 & 4.
May 12, 2023
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:
Report Numbers:
05000250/2023001 and 05000251/2023001
Enterprise Identifier:
I-2023-001-0036
Licensee:
Florida Power & Light Company
Facility:
Turkey Point Units 3 & 4
Location:
Homestead, FL
Inspection Dates:
January 01, 2023, to March 31, 2023
Inspectors:
D. Bacon, Senior Operations Engineer
M. Endress, Senior Resident Inspector
P. Gresh, Emergency Preparedness Inspector
J.R. Reyes, Resident Inspector
A. Richardson, Physical Security Inspector
J. Tornow, Physical Security Inspector
J. Walker, Senior Emergency Preparedness 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 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
Inadequate Maintenance Rule Scoping of a Residual Heat Removal (RHR) Train
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000250,05000251/2023001-01
Open/Closed
[H.1] -
Resources
The NRC identified a finding and associated Green non-cited violation (NCV) of 10 CFR 50.65
(a)(2), for the licensees failure to demonstrate that the performance of an RHR train was
being effectively controlled through the performance of appropriate preventive maintenance,
such that structures, systems, and components (SSCs) remained capable of performing their
intended functions. Specifically, the licensee failed to establish and perform adequate
preventive maintenance activities to ensure that RHR heat exchanger A isolation valve
3-759A remained capable of performing its intended design function to close when directed by
emergency operating procedures (EOPs).
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
05000250,05000251/20
22011-03
Containment Purge Valve
Seat Leakage Integrity After
Seismic Events
Closed
PLANT STATUS
Units 3 and 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 DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 4B emergency diesel generator (EDG) while the 4A EDG was out of service
(OOS) for testing, on January 17, 2023
(2)
Unit 4B, 3A, and 3B high head safety injection (HHSI) pumps while the 4A HHSI
pump was OOS for maintenance, on January 18, 2023
(3)
Unit 3A, 3B component cooling water (CCW) pumps while the 3C was OOS for a 3D
4kV bus outage, on February 8, 2023
(4)
Unit 3A and 3B intake cooling water (ICW) pumps while the safety-related 3D 4kV
switchgear and the 3C ICW pump were OOS, on February 9, 2023
(5)
Unit 3A, 3B and 4A HHSI pumps while the 4B EDG and the 4B HHSI pump were
OOS, on March 7, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Fire zone (FZ) 055 and 045, Unit 3 and Unit 4 charging pump rooms, on
January 17, 2023
(2)
FZ 113, Unit 4 condensate storage tank cage, laydown, and feed water platform area,
on January 31, 2023
(3)
FZ 098, Unit 3 and Unit 4 cable spreading room, on February 1, 2023
(4)
FZ 70 and 71, Unit 3 safety-related 4kV switchgear rooms A and B, on February 27,
2023
(5)
FZ 027, 026, and 019, Unit 4 West and North electrical penetration rooms and Unit 3
West electrical penetration room, on March 7, 2023
(6)
FZ 092, 091, and 084, Unit 4 condensate pump pit and auxiliary feed pump cage, on
March 13, 2023
(7)
FZ 011 and 012, Unit 3 RHR heat exchanger and pump room, on March 15, 2023
(8)
FZ 086 and 087, Unit 3 main, startup, and auxiliary transformer, on March 30, 2023
(9)
FZ 081 and 083, Unit 4 main, startup, and auxiliary transformer, on March 30, 2023
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 a control room operator briefing to perform the 4B EDG in-service test
surveillance and EDG control board walkdown, on January 31, 2023. Inspectors also
observed and evaluated licensed operator performance in the control room during
restoration of the 3D 4kV bus following a planned maintenance outage, on
February 9, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed and evaluated a hostile action based drill scenario in the
simulator on February 14, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following SSCs
remain capable of performing their intended function:
(1)
Action request (AR) 2406410, 4B EDG exceeded maintenance rule unavailability
criteria; EVAL-PTN-022-02782, (a)(1) evaluation for the 4B EDG
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to
ensure the following SSC remains capable of performing its intended function:
(1)
Work order (WO) 40828365, Unit 3 RHR 3-759A valve linkage repair
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 and Unit 4 online risk assessment while the control room air handling unit
E-16A, Unit 4 diesel instrument air compressor 4CD, and the 4B charging pump were
OOS, on January 05, 2023
(2)
Unit 3 and Unit 4 online risk assessment while the 4A HHSI pump and Unit 4 diesel
instrument air compressor 4CD were OOS, on January 17, 2023
(3)
Unit 3 and Unit 4 online risk assessment while the 4A and 3A emergency
containment coolers, 4C diesel instrument air compressor, and the 4C CCW heat
exchanger were OOS, on January 23, 2023
(4)
Unit 3 and Unit 4 online risk assessment while the 3D safety-related 4Kv switchgear,
3C CCW pump, 3C ICW pump, station blackout crosstie, and the diesel-driven 4CD
instrument air compressor were OOS, on February 08, 2022
(5)
Unit 3 and Unit 4 online risk assessment while the 4B EDG, 4B HHSI pump, and the
4C CCW heat exchanger were OOS, on March 7, 2023
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 02446517 - 4A 480V load center ground/HI temp; AR 02446516 - entrance into
off-normal operating procedure 0-ONOP-006, "480 Volt Load Center Ground
Isolation," on January 22, 2023
(2)
AR 02447609, FCV-3-6278A failed to stroke closed in a timely manner, on February
7, 2023
(3)
AR 02449259, 3C charging pump motor vibration measurement rise, on
February 23, 2023
(4)
AR 2450051, RHR operability issue, March 6, 2023
(5)
AR 02451132, 3A EDG right side cranking motor isolation valve air leak, on
March 16, 2023
(6)
AR 2451502, control room emergency ventilation system D-3 damper failed closed;
AR 2451789, D-2 open and emergency filter flow, on March 20 and 21, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary modification:
(1)
TMD 298138, Unit 4 4A reactor coolant pump remote fill temporary modification
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (4 Samples)
(1)
4A HHSI pump PMT per 0-CME-062.01, "Safety Injection Pump Motor Overhaul"; and
4-OSP-062.2D, "Safety Injection Pump 4A Comprehensive Pump Test," after
replacing the pump motor, on January 19, 2023
(2)
WO# 40771450, Unit 3 AFW MOV-3-1405 starter inspection, on January 19, 2023
(3)
Unit 3D 4KV safety-related switchgear breaker inspection, maintenance, and testing
per WO# 40678595, 40678365, 40678596, and 40678593, on February 10, 2022
(4)
Unit 3-759A RHR heat exchanger outlet valve linkage and actuator repair per WO# 40823307 and tested per 3-OSP-050.11, "RHR/SI Manual Valve Operability Test," on
March 09, 2023
Surveillance Testing (IP Section 03.01) (2 Samples)
(1)
4B EDG surveillance test per 4-OSP-023.1, "Diesel Generator Operability Test,"
Section 7.2, "4B EDG Normal Start Test," performed on January 31, 2023
(2)
3-SMI-059.08C, "Unit 3 Quarterly N-3-43 Detector Currents," on February 6, 2023
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
(1)
The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and
Emergency Plan Implementing Procedure changes during the week of
February 13, 2023. This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1
Sample)
(1)
Quarterly emergency preparedness drill with a hostile action component in the
scenario, on January 11, 2023. The drill simulated a hostile force intrusion into the
plant that required a reactor trip and appropriate security response. No radioactive
release was simulated in this drill.
71114.07 - Exercise Evaluation - Hostile Action (HA) Event
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
(1)
The inspectors evaluated the biennial emergency plan exercise during the week
of February 13, 2023. The scenario began with a simulated report from the field that a
hostile action was occurring inside the protected area, thus meeting the criteria for
declaration of a Site Area Emergency. Subsequently, a simulated explosion occurred
in the Unit 2 fuel handling building, causing damage to the spent fuel pool system
along with increasing radiation levels inside the building. When effluent radiation
levels reached a prescribed threshold, conditions for a General Emergency were met,
and the Offsite Response Organizations were able to demonstrate their ability to
implement emergency actions.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
(1)
The inspectors reviewed and evaluated in-office, the proposed scenario for the
biennial emergency plan exercise at least 30 days prior to the day of the exercise.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 3 (January 1, 2022 through December 31, 2022)
(2)
Unit 4 (January 1, 2022 through December 31, 2022)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2
Samples)
(1)
Unit 3 (January 1, 2022 through December 31, 2022)
(2)
Unit 4 (January 1, 2022 through December 31, 2022)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 3 (January 1, 2022 through December 31, 2022)
(2)
Unit 4 (January 1, 2022 through December 31, 2022)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
(1)
Unit 3 (October 1, 2021, through December 31, 2022)
Unit 4 (October 1, 2021, through December 31, 2022)
EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1
Sample)
(1)
Unit 3 (October 1, 2021, through December 31, 2022)
Unit 4 (October 1, 2021, through December 31, 2022)
EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
(1)
Unit 3 (October 1, 2021, through December 31, 2022)
Unit 4 (October 1, 2021, through December 31, 2022)
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (2 Samples)
(1)
The inspectors selected AR 2451900 and AR 2450051 for maintenance rule scoping
issues with 3-759A (RHR 'A' heat exchanger outlet isolation). These ARs were
selected for follow-up to verify the licensees corrective actions were appropriate to
ensure that performance of the RHR / low head safety injection (LHSI) system train
was being controlled effectively by preventive maintenance.
(2)
The inspectors selected AR 2435084, inconsistency in logging SSC unavailability;
and AR 2446819, validation of submitted unavailability data, for performance indicator
impact due to improperly tracked equipment unavailability. These ARs were selected
for follow-up to verify the licensee's corrective actions were appropriate and to ensure
that performance indicator data was calculated and reported accurately.
INSPECTION RESULTS
Inadequate Maintenance Rule Scoping of a Residual Heat Removal (RHR) Train
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000250,05000251/2023001-01
Open/Closed
[H.1] -
Resources
The NRC identified a finding and associated Green non-cited violation (NCV) of 10 CFR
50.65 (a)(2), for the licensees failure to demonstrate that the performance of an RHR train
was being effectively controlled through the performance of appropriate preventive
maintenance, such that SSCs remained capable of performing their intended functions.
Specifically, the licensee failed to establish and perform adequate preventive maintenance
activities to ensure that RHR heat exchanger A isolation valve 3-759A remained capable of
performing its intended design function to close when directed by emergency operating
procedures (EOPs).
Description: During testing on February 7, 2021, and November 10, 2021, Turkey Point
experienced failures of valve 3-759A to close. At the time, the licensee attributed the failures
to a lack of preventive maintenance being performed on the valve.
The RHR system at Turkey Point serves as the LHSI system in the short-term following a loss
of coolant accident (LOCA) and serves as a portion of the emergency core cooling system
(ECCS) when aligned for long-term core cooling. When aligning for long-term core cooling,
the normal LHSI path is isolated, and the discharge of the RHR/LHSI pumps is redirected to
the suction of the HHSI pumps and the containment spray (CS) pumps; this is known as
piggyback mode. The piggyback mode of operation is established by closing both RHR
discharge to cold leg isolation valves, MOV-3-744A and MOV-3-744B, which are arranged in
parallel, and opening RHR alternate discharge isolation valves, MOV-3-863A and MOV-3-
863B; this completely isolates the cold leg injection path and creates a suction path to the
The design and licensing bases for the Turkey Point ECCS require both the 3-759A and 3-
759B manual valves to be closed for piggyback mode with a postulated single failure of either
MOV-3-744A or MOV-3-744B to close. This is to ensure that the ECCS safety-related
recirculation cooling function remains available.
A specific post-accident function of the 3-759A and 3-759B valves is described in item D.7 of
updated final safety analysis report (UFSAR) Table 6.2-9 (a), Single Failure Analysis - Safety
Injection System. The table states that if an RHR pump injection line isolation valve (inside
containment) fails to close, then there are two parallel valves, 3-759A and 3-759B, that are
both required to close for piggyback recirculation. 3-759A and 3-759B are equipped with
reach rods for manual isolation capability.
The 3-759A and 3-759B valves have a safety-related function to close if either
MOV-3-744A or MOV-3-744B fails to close as expected in order to ensure at least one train
or subsystem of the ECCS remains available for the ECCS recirculation function. In other
words, 3-759A and 3-759B are redundant to MOV-3-744A & MOV-3-744B and would
constitute a separate train or subsystem capable of performing the safety function if the other
train or subsystem is incapable of performing the function. The closure of the MOV-3-744A,
MOV-3-744B, 3-759A, and 3-759B are directed by the stations EOPs. The step to close 3-
759A and 3-759B is directed by an action known as a response not obtained (RNO) step,
which would be taken if either MOV-3-744A or MOV-3-744B fails to close. The RNO step is a
provision in the EOP that intends to ensure the postulated single failure will be
accommodated without loss of the remaining train or subsystem function as required by the
stations design.
Turkey Points maintenance rule program monitors the RHR/ECCS on a train basis, where
each trains required functions are monitored with both reliability and unavailability criteria.
The licensee is required to track the number of failures that cause loss of the trains functions
and limit unavailability of the trains. Turkey Point defined two trains in their maintenance rule
program, PTN-3-(050-BP)-FN02(3A), and PTN-3-(050-BP)-FN02(3B), to be monitored to
provide the function to Provide long-term recirculation cooling following design-basis
accident (DBA) (standby). However, the trains were not defined in the maintenance rule
program to include the redundancy described in UFSAR Table 6.9-2(a), item D.7.
Specifically, the licensee had not included MOV-3-744A and MOV-3-744B in one train, and 3-
759A and 3-759B in the other train.
When the licensee evaluated the February 7, 2021, and November 10, 2021 test failures to
determine if they constituted a maintenance rule functional failure (MRFF) or a maintenance
preventable functional failure (MPFF) of the train, their conclusion was that neither constituted
an MRFF or an MPFF since both MOV-3-744A and MOV-3-744B remained operable during
the test conditions and the train safety function would have been met. When making this
determination, the licensee had not fully considered the train or subsystem safety function.
The true demand condition for the tested 3-759A and 3-759B valves is to close when directed
by the EOPs due to a failure of either of the MOV-3-744A or MOV-3-744B valves. The tests
conducted on February 7, 2021, and November 10, 2021, revealed that 3-759A would not
have performed its design function to close when directed by the EOPs.
The inspectors considered that the 3-759A valve function to close to perform the train safety-
related function of recirculation/piggyback mode should have been included in the licensees
consideration of what constituted a train failure as described in the UFSAR and EOPs. The
inspectors noted that the 3-759A test failures resulted in a lack of demonstration that the
performance of the train was being controlled effectively by adequate preventive
maintenance.
Corrective Actions: The licensee entered this issue into the corrective action program and
performed a past operability evaluation.
Corrective Action References: AR 2451900 and AR 2450051
Performance Assessment:
Performance Deficiency: The licensee failed to demonstrate that the performance of the
RHR/LHSI system train was being controlled effectively by preventive maintenance.
Specifically, adequate preventive maintenance activities were not established and performed
to prevent functional failures of the train.
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. The performance deficiency was similar to IMC 0612, App E,
more than minor example 8.c., which states in part that effective control of equipment
performance or condition of equipment that should have constituted one of the monitored
trains was not demonstrated due to multiple failures of the equipment. In this case, the
credited subsystem which provided for the ECCS containment recirculation mode of
operation was not being monitored.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., The Significance Determination Process (SDP) for Findings At-Power. A
Regional Senior Reactor Analyst (SRA) performed a detailed risk assessment using
SAPHIRE 8 Version 8.2.6 and Turkey Point Unit 3 and 4 SPAR Model Version 8.80, dated
May 26, 2022. The exposure time was set to one year (maximum allowed for an SDP) since
3-759A has been known to be stuck in the open position since at least 2021. The SPAR
model only models 3-759 A/B as a normally open valve which could fail closed and MOV-3-
744A/B as a normally closed valve that fails to open; these are the safety-related functions of
the valves during the injection phase. The function of both valves to fail to close is not
modeled directly. However, the high pressure recirculation function does require manual
operator actions to realign the system. Thus, the close function of these valves is indirectly
modeled in the term HPI-XHE-XM-RECIRC as operators have to manually shut MOV-3-
744A/B and if unsuccessful, manually close both 3-759A and 3-759B as directed by 3/4-EOP-
ES 1.3. The SRA adjusted HPI-XHM-XM-RECIRC (Operator Fails to Start/Control High
Pressure Recirc - PWR) from 4E-3 to 4E-2 to account for a random failure of MOV-3-744A or
MOV-3-744B or a loss of offsite power and failure of an EDG to run, resulting in a loss of the
normal bus after the injection phase was commenced. The dominant accident sequence was
a small break LOCA with a failure of operators to manually refill the Unit 3 refuel water
storage tank, failure to cross-connect with Unit 4 high pressure injection, and failure to
manually align for high pressure recirculation. The change in core damage frequency was
less the 1E-6 which corresponds to a finding of very low safety significance (Green).
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment,
procedures, and other resources are available and adequate to support nuclear safety. The
performance deficiency represents current licensee performance since the failures of 3-759A
and the subsequent MRFF and MPFF determinations occurred within the last three years.
Enforcement:
Violation: 10 CFR 50.65 (a)(2) requires, Monitoring as specified in paragraph (a)(1) of this
section is not required where it has been demonstrated that the performance or condition of a
structure, system, or component is being effectively controlled through the performance of
appropriate preventive maintenance, such that the structure, system, or component remains
capable of performing its intended function. Contrary to the above, the licensee did not
demonstrate that the performance of the RHR train was being effectively controlled through
the performance of appropriate preventive maintenance, such that SSCs remained capable of
performing their intended functions. Specifically, the licensee failed to establish and perform
adequate preventive maintenance activities to ensure that RHR heat exchanger A isolation
valve 3-759A remained capable of performing its intended design function to close when
directed by EOPs. When considered with other experienced failures of the train, the
licensee had not demonstrated that train performance was being effectively controlled
through adequate preventative maintenance.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2
of the Enforcement Policy.
Containment Purge Valve Seat Leakage Integrity After
Seismic Events
URI 05000250,05000251/2022011-03
Description: Unresolved Item (URI) 05000250,05000251/2022011-03 was opened in
inspection report 05000250, 251/2022011 (ADAMS Accession No. ML22353A077) to review
additional information from the licensee concerning correspondence with the NRC regarding
leak tight seismic qualification of the containment purge valves.
The URI was resolved after reviewing and discussing Safety Evaluation Report (SER) "SER
for Turkey Point 3 and 4 on Containment Isolation Dependability by Demonstration of
Containment Purge and Vent Valve Operability (TAC Nos. 49917 and 49919)," which was not
available during the inspection. Section 4.4 of the SER stated, "The staff finds that seismic
qualification for the containment purge and vent valves has been addressed by the applicant
in their September 17, 1982, and March 4, 1983, submittals."
No violations were identified. This URI is considered closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 18, 2023, the inspectors presented the integrated inspection results to
Michael Pearce and other members of the licensee staff.
On February 16, 2023, the inspectors presented the Emergency Preparedness Exercise
inspection results to Michael Pearce and other members of the licensee staff.