IR 05000250/2023002

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Integrated Inspection Report 05000250/2023002 and 05000251/2023002
ML23225A002
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 08/14/2023
From: David Dumbacher
Division Reactor Projects II
To: Coffey B
Florida Power & Light Co
References
IR 2023002
Download: ML23225A002 (1)


Text

August 14, 2023

SUBJECT:

TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2023002 AND 05000251/2023002

Dear Mr. Bob Coffey:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On July 13, 2023, the NRC inspectors discussed the results of this inspection with Mr. Mike Durbin 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, Signed by Dumbacher, David on 08/14/23 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: 05000250/2023002 and 05000251/2023002 Enterprise Identifier: I-2023-002-0030 Licensee: Florida Power & Light Company Facility: Turkey Point Units 3 & 4 Location: Homestead, FL 33035 Inspection Dates: April 01, 2023 to June 30, 2023 Inspectors: J. Diaz-Velez, Senior Health Physicist M. Endress, Senior Resident Inspector J.R. Reyes, Project Engineer J. Rivera, Health Physicist M. Schwieg, Senior Reactor 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

None.

PLANT STATUS

Unit 3 started the period operating at or near rated thermal power (RTP). On April 8, 2023, Unit 3 shut down to 0 percent RTP and commenced a refueling outage. Unit 3 returned to 100 percent of RTP on May 13, 2023, where it remained for the rest of the inspection period.

Unit 4 operated at or near RTP 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, observed risk-significant activities, and completed onsite 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 hurricane season for the following areas:

Intake structure and canal perimeter fencing Discharge structure area Start-up transformer, main and auxiliary transformer areas Emergency diesel generator (EDG) building areas and 3A, 3B, 4A, 4B engine rooms

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

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

(1) Unit 3 and Unit 4 auxiliary feedwater (AFW) train 2 while train 1 was out of service (OOS) for testing, on April 3, 2023
(2) Unit 4, 4B EDG ready lineup after completing the monthly surveillance, on April 5, 2023
(3) Unit 3, 3A and 3B spent fuel pool (SFP) pumps and heat exchangers after installation of a temporary modification to provide power to the 3A SFP pump from the 3B 4160V safety-related switchgear, on April 20, 2023
(4) Unit 4, 4B EDG standby alignment while the 4A EDG was OOS for testing, on May 22, 2023

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 4 condensate storage tank area, fire zone (FZ) 077, on April 3, 2023
(2) Unit 3, 3A and 3B 4160V switchgear rooms, FZ 070 and 071, on April 19, 2023
(3) Unit 3 containment, FZ 060, on April 24, 2023
(4) 3A, 4B, 3B, 4A, and D-52 spare safety-related station batteries, FZs 103, 102, 110, 109, and 025A, on May 30 and 31, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill by the Unit 4 hydrogen instrument panel, on June 13, 2023.

===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system (RCS) boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from April 15, 2023 to April 26, 2023.

PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01) ===

The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:

(1) Ultrasonic examinations on reactor head closure bolts Visual examination of the reactor head bare metal inspection Welding activities on the H-6 seal table repair PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection

Activities (IP Section 03.02) (1 Sample)

The inspectors verified that the license conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:

(1) Reactor vessel upper head control rod drive mechanism penetrations PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)

The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:

(1) Action Request (AR) 02350719, seal table inactive brown boric acid centered around H-6 evaluation Containment spray and injection pumps walkdown PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)

The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:

(1) Steam generator A - U Bend in rows 1-10 Steam generator B - U Bend in rows 1-10 Steam generator C - U Bend in rows 1-10

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 the following evolutions:

1. Unit 3 cool down with two residual heat removal (RHR) pumps operating while in Mode 5 and yellow shut down risk condition due to pressurizer inventory level less than 5 percent (cold calibration), and in preparation to enter Mode 6, on April 10, 2023 2. Unit 3 plant heat up, transition to Mode 4, and accumulator filling with high head safety injection (HHSI) pumps, on May 2, 2023 3. Unit 3 main steam isolation valve bypass, power increase, and turbine startup, on May 6, 2023 4. Verification of Unit 3A, 3B and 4B EDG; 3A, 3B, 4A and 4B HHSI pump electrical standby alignment while the Unit 4A EDG was OOS and unavailable during surveillance testing, on May 22, 2023

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

(1) The inspectors observed and evaluated licensed operator requalification scenarios in the simulator, on June 14, 2023.

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 remain capable of performing their intended function:

(1) AR 2458383, Unit 3, 3CM instrument air motor compressor condition monitoring failure criteria exceeded, review for a(1) monitoring
(2) AR 2441899, PTN QSPDS-1D-01, maintenance rule re-scoping of the Qualified Safety Parameter Display system based on updated probabilistic risk analysis system information

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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 yellow shut down risk assessment while in Mode 5 with RCS inventory at less than 5 percent pressurizer cold calibration level; Unit 4 online risk assessment while in Mode 1 with the 3CD motor-driven air compressor and 4CD diesel-driven instrument air compressor OOS for testing, on April 10, 2023
(2) Unit 3 shut down risk assessment during yellow risk condition while the 3A 4160V safety-related switchgear, the 3A and 3B intake cooling water pumps, and the H-load center were unavailable; and Unit 4 online risk assessment while in Mode 1 with the 3A HHSI pump and 3A EDG OOS, on April 18 and 19, 2023
(3) Unit 4 online risk assessment; and Unit 3 Mode 4 qualitative risk assessment while in yellow risk due to the 3A and 3B RHR pumps being unavailable, and the 3B EDG unavailable to both Unit 3 and Unit 4, on May 2, 2023
(4) Unit 3 and Unit 4 online risk assessment with 3-757B RHR heat exchanger inlet isolation valve; 3-752B 3B RHR pump inlet valve; and MOV-878A HHSI unit cross-connect valve OOS for maintenance and testing, on May 31, 2023
(5) Unit 3 and Unit 4 online risk assessment with the 3A2 station battery charger; 3B charging pump; 4CD diesel instrument air compressor; 4B component cooling water heat exchanger; CV-3-2827 main steam to condenser; and MOV-878B HHSI cross-connect valve OOS, on June 07, 2023
(6) Unit 3 and Unit 4 online risk assessment with the following safety-related common systems OOS for maintenance and/or testing: the control room emergency ventilation system, HHSI pump unit cross-connect valve MOV-878A, B diesel-driven standby steam generator feed pump, and the auxiliary feedwater train 1, on June 28, 2023

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 02453312, air leak at 3A EDG right side starting air shutoff valve 3-70-257A; AR

===02451132, air leak at 3A EDG starting air compressor discharge braided hose

(2) AR 02454258, 3B EDG frequency monitoring relay failure
(3) AR 02454582, 3A EDG instrument air leak on CV-3-2046A (day tank oil fill line)

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 or permanent modifications:

(1) TMD 298571 - Unit 3 nuclear instrument audio count rate remote speaker alternative inside Unit 3 containment

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated Unit 3 refueling outage activities from April 8 to May 6, 2023.

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)

(1) Replace the 3A EDG generator bearing housing and fuel oil skid tank level switches per work order (WO) 40651864-01 and 40854246-01, respectively; test per WO

===40651864-03, PDM vibration data; and 3-OSP-023.1, Diesel Generator Operability Test, on March 25, 2023

(2) Replace and test the 3B EDG frequency monitoring relay per maintenance procedure 3-PME-023.02, Emergency Diesel Generator Electrical Maintenance; and WO #40876724-03, on April 13, 2023
(3) Replace the 3A and 3B intake cooling water pump discharge check valve, elbow, and expansion joint per WO 40811955 and 40811957, on April 27 and 28, 2023
(4) 3-OSP-075.4, Auxiliary Feedwater Auto-Start Test, after completing preventive maintenance on the system control valves per WO#40805385-01 on May 01, 2023
(5) Replacement of the 4A EDG K1 relay in the automatic voltage regulator control system, test per 4-OSP-023.1 (section 7.1 normal start test), on June 25, 2023 Surveillance Testing (IP Section 03.01) ===
(1) 4-OSP-075.2, Auxiliary Feedwater Train 2 Operability Verification, completed on April 03, 2023
(2) 3-OSP-072.6, Main Steam Safety Valve Setpoint Surveillance Using Team Trevitest Mark V111 Equipment (RV-3-1403,1405, 1408, 1412, and 1413), completed on April 07, 2023
(3) 4A EDG monthly operability test per 4-OSP-023.1, on May 22, 2023
(4) Unit 3, Cycle 33 Low Power Physics Testing per 0-OSP-040.19, performed on May 5, 2023

Inservice Testing (IST) (IP Section 03.01) (2 Samples)

(1) 3-OSP-203.2, Train B Engineered Safeguards Integrated Test, performed on April 12, 2023
(2) 3-OSP-041.17, RCS / RHR Loop Pressure Boundary Leak Test, performed on May 03, 2023

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

(1) 3-OSP-051.5, Local Leak Rate Tests, Containment Penetration 6 - Nitrogen Supply to Pressurizer Relief Tank, completed on April 12, 2023

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Emergency preparedness drill from Emergency Operating Facility, on June 6,

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) (2 Samples)

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

(1) Surveys of personnel leaving the radiologically (RCA), and surveys of potentially contaminated material leaving the RCA
(2) Surveys of containers leaving the RCA to be shipped (Shipment PTN-M-23-022) to another licensed facility (including truck surveys)

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

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

(1) Radiation Work Permit (RWP) 23-3010, Task 4, Contingency Thimble Tube Modification
(2) RWP 23-2325, Task 1, 3B RCP Prep and Rig New Pump - Set New Pump Assembly
(3) RWP 23-3033, Task 2, Outage Scaffolding Support Higher Dose Areas (HRA)
(4) RWP 23-3019, Task 3, B/C Steam Generators - Primary Side Eddy Current Work

[locked high radiation area (LHRA)]

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 (HRAs)and Very High Radiation Areas:

(1) RWP 23-3010, Task 4, Contingency Thimble Tube Modification (HRA)
(2) 3B RCP Prep and Rig New Pump - Set New Pump Assembly (LHRA)
(3) B Steam Generator - Primary Side Eddy Current Work (LHRA)
(4) Radwaste Building (RWB) Tunnel (LHRA)
(5) RWB North Evap Room (LHRA)

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.

71124.03 - 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. 001

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 how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (3 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Internal dose assessment related to AR 02411401, dated February 11, 2022
(2) Internal dose assessment related to AR 02423630, dated April 20, 2022
(3) Internal dose assessment related to AR 02410290, dated February 11, 2022

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

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker (DPW) dosimetry record for DPW declared on April 14, 2022
(2) Radworker dosimetry record for an effective dose equivalent for external radiation exposure (EDEX) on March 14, 2022 and April 2, 2022
(3) Radworker dosimetry record for an EDEX exposure on March 14, 2022

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) Portable ion chambers ready for use in the instrumentation lab
(2) Telepole radiation survey meters ready for use in the instrumentation lab
(3) Portable Geiger counters ready for use in the instrumentation lab
(4) Portable gamma dose rate meters ready for use in the instrumentation lab
(5) Portable neutron survey meters ready for use in the instrumentation lab
(6) Personnel contamination monitors located at the RCA exit point
(7) Portal monitor located at the RCA exit point
(8) Tools and equipment monitors located at the RCA exit point
(9) Area radiation monitors in the auxiliary building and control room

Calibration and Testing Program (IP Section 03.02) (12 Samples)

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

(1) Ludlum 9-3 ion chamber, HPI no. 1584
(2) Telepole II, HPI no. 1703
(3) Ludlum 12 ratemeter, HPI no. 1472
(4) RadEye G gamma dose rate meter, HPI no. 1548
(5) REM Ball neutron survey meter, HPI no. 1668
(6) AMS-4 continuous air monitor, HPI no. 2502
(7) Electronic dosimeter serial no. 01970980
(8) GEM-5 PM, HPI no. 1561
(9) ARGOS-5AB PCM, HPI no. 1476
(10) Cronos-4 TEM, HPI no. 1394
(11) FASTSCAN 1 whole body counter
(12) Unit 3 containment high range radiation monitor Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)

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

(1) Channel R-18 - waste disposal liquid effluent monitor
(2) Plant vent stack process radiation monitor no. RAD-6304-B

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) ===

(1) Unit 3 (April 1, 2022 through March 31, 2023)
(2) Unit 4 (April 1, 2022 through March 31, 2023)

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

(1) Unit 3 (April 1, 2022 through March 31, 2023)
(2) Unit 4 (April 1, 2022 through March 31, 2023)

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

(1) March 1, 2022 through March 24,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On July 13, 2023, the inspectors presented the integrated inspection results to Mr. Mike Durbin, Executive Director of Organizational Effectiveness, and other members of the licensee staff.

On April 26, 2023, the inspectors presented the Unit 3 ISI inspection results to Mr. Chad Mynhier, Site Engineering Director, and other members of the licensee staff.

On May 24, 2023, the inspectors presented the RP Occupational Radiation Safety Baseline Inspection results to Mr. Michael Pearce, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.08P Procedures ER-AP-116-1000 BORIC ACID CORROSION CONTROL PROGRAM 8

NDE 3.5 Liquid Penetrant Examination in Accordance with 6

Construction Codes

NDE 5.8 Straight Beam Ultrasonic Examination of Bolts and Studs 13

WPS-43 WELDING PROCEDURE SPECIFCATION 12

71124.01 Corrective Action 02421310, Various Various

Documents 024211722,

2424001,

2424018,

2424855,

2428361,

2429965,

2431606,

2434965,

2435226,

2439431,

2439867,

2441317, and

2455138

71124.04 Corrective Action AR 02410023, Various Various

Documents 02410290,

2410615,

2411401,

2416044,

2419467,

2420079,

240784,

2420933,

2422642,

2423620,

2423630,

2423801,

Inspection Type Designation Description or Title Revision or

Procedure Date

2436916, and

2439754.

Miscellaneous 10 CFR 61 10 CFR 61 Analysis for 2020 DAW & 2020 RAM 03/25/2020

Analysis for 2020

DAW & 2020

RAM

CFR 61 10 CFR 61 Analysis for 2022 RAM/DAW 03/22/2022

Analysis for 2022

RAM/DAW

71124.05 Corrective Action AR 02455518 NRC IDENTIFIED RP INSTRUMENT CALIBRATION 05/02/2023

Documents DEFICIENCY

Resulting from

Inspection

Procedures 0-HPT-018.3 Calibration and Operation of the MGP Instruments Telepole Rev. 4

and Telepole II Wide Range Telescoping Survey Meter

14