IR 05000250/2024001
| ML24129A212 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/10/2024 |
| From: | Renee Taylor NRC/RGN-II/DRP/RPB3 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2024001 | |
| Download: ML24129A212 (17) | |
Text
SUBJECT:
TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2024001 AND 05000251/2024001
Dear Bob Coffey:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On April 18, 2024, the NRC inspectors discussed the results of this inspection with Mr. Michael Strope, Site Vice President, 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.
May 10, 2024 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, Ryan C. Taylor, 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:
05000250/2024001 and 05000251/2024001
Enterprise Identifier:
I-2024-001-0036
Licensee:
Florida Power & Light Company
Facility:
Turkey Point Units 3 & 4
Location:
Homestead, FL 33035
Inspection Dates:
January 01, 2024 to March 31, 2024
Inspectors:
A. Donley, Senior Resident Inspector
J. Hickman, Senior Resident Inspector
B. Kellner, Senior Health Physicist
M. Kennard, Senior Operations Engineer
A. Knotts, Resident Inspector
C. Safouri, Senior Resident Inspector
J. Walker, Senior Emergency Preparedness Inspector
Approved By:
Ryan C. Taylor, 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
Unidentified Degraded Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024001-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Turkey Point Unit 3 operating license Condition 3.D, Fire Protection, for the licensee's failure to implement and maintain in effect all provisions of the approved fire protection program.
Specifically, the licensee failed to maintain a fire barrier wall in the Unit 3 pipe and valve (P&V) room in accordance with all required design parameters as specified by 0-ADM-016,
Fire Protection Program, for a functional fire barrier.
Additional Tracking Items
None
PLANT STATUS
Unit 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 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
71111.04 - 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)3A emergency diesel generator (EDG) following restoration after a major maintenance work window on January 25, 2024 (2)3B EDG following restoration after a major maintenance work window on February 15, 2024
- (3) C auxiliary feedwater (AFW) pump alignment to train 1 during A AFW pump terry turbine replacement on February 24, 2024
- (4) AFW train 1 following A AFW pump restoration and during C AFW pump terry turbine replacement on March 5, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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 zones 72, 73, 131, Unit 3 A and B EDGs and radiator fan cooling rooms on February 7, 2024 (2)fire zones 15,16, Unit 4 residual heat removal rooms A and B on March 19, 2024 (3)fire zone 40, Unit 3 P&V room on March 29, 2024
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 AFW pump testing on February 27, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated crew training PTN OPS 2023 CPE-1 on February 14, 2024.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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 elevated risk due to extended maintenance outage of the 3A EDG on January 12, 2024
- (2) Unit 3 elevated risk due to extended maintenance outage of the 3B EDG on February 9, 2024
- (3) Unit 4 high risk associated with containment entry at power due to emergent repair of failed FT-4-425, reactor coolant system (RCS) loop B flow transmitter, on February 21, 2024
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)action request (AR) 2476298, containment process radiation monitors (R-11/R-12)sensitivity requirements for RCS operational leakage detection
- (2) AR 2477624, boric acid to blender flow control valve (FCV-4-113A) modulating excessively during volume control tank auto makeups
- (3) AR 02480642, 3B EDG air start shutoff valve, 3-70-257B, leaking air at valve body
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) Work order (WO) 40953081, like for like limit switch replacement on CV-4-2803, instrument air to containment header isolation valve
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) (7 Samples)
- (1) WO 40957889, 3A EDG operability test after completion of major maintenance window
- (2) WO 40813125, 3B EDG 36 month preventive maintenance and overspeed test on February 15, 2024
- (3) WO 40792866, 3C intake cooling water pump operability test following pump replacement
- (4) WO 40965739, RCS loop B flow transmitter, FT-4-425, electronics assembly replacement after flow transmitter failed low
- (5) WO 40958705 and 40881906, on Unit 3, AFW train 1 testing following the A AFW terry turbine replacement
- (6) WO 40966442, containment entry at rated thermal power to repair sheared sensing line to the 4B steam generator steam flow transmitter, FT-4-484, on February 28, 2024
- (7) WO 40946263, on Unit 4, AFW train 2 testing following C AFW terry turbine replacement
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)4-OSP-051.2, Containment Personnel Air Lock Seal Vacuum Test, on February 23, 2024 (2)4-OSP-023.1, Diesel Generator Operability Test, for the 4B EDG rapid start, on March 04, 2024 (3)4-SMI-071.10A, F-484 Steam Generator 4B Steam Flow and F-487 Steam Generator 4B Feedwater Flow Channel Operational Test, on March 21, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)3-OSP-030.1, Component Cooling Water (CCW) IST, for the 3B CCW pump, on March 26, 2024
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of January 22, 2024.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of January 22, 2024.
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 January 22, 2024. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of January 22, 2024.
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) The inspectors evaluated the 2024 off-year exercise drill on February 20,
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)===
- (1) Unit 3 (January 1, 2023 through December 31, 2023)
- (2) Unit 4 (January 1, 2023 through December 31, 2023)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)
- (1) Unit 3 (January 1, 2023 through December 31, 2023)
- (2) Unit 4 (January 1, 2023 through December 31, 2023)
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
- (1) Unit 3 (January 1, 2023 through December 31, 2023)
- (2) Unit 4 (January 1, 2023 through December 31, 2023)
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) October 1, 2022 through September 30, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) October 1, 2022 through September 30, 2023 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) October 1, 2022 through September 30,
INSPECTION RESULTS
Unidentified Degraded Fire Barrier Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024001-01 Open/Closed None (NPP)71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Turkey Point Unit 3 operating license Condition 3.D, Fire Protection, for the licensee's failure to implement and maintain in effect all provisions of the approved fire protection program.
Specifically, the licensee failed to maintain a fire barrier wall in the Unit 3 pipe and valve (P&V) room in accordance with all required design parameters as specified by 0-ADM-016, Fire Protection Program, for a functional fire barrier.
Description:
While conducting a fire walkdown on February 9, 2024, of the Unit 3 P&V room, the inspectors identified an empty hole in the south wall, that did not have a fire penetration label, looked to proceed all the way through to a metal sheet/plug, had no seal material, and contained degraded wood-like material. There was no fire barrier impairment for what looked to be an open penetration. The south wall of the Unit 3 P&V room is a fire barrier between the Unit 3 P&V room and the north and south auxiliary building hallway. According to pre-fire plan, PFP-AB-18, Revision 2, both fire areas have a high risk impact on the conditional core damage probability and the PFP states "core damage probability increases to a severe level should a fire extend beyond this fire area."
Corrective Actions: The inspectors notified the licensee, and they declared the barrier non-functional, created fire protection impairment 14582, initiated a fire rove, and entered the issue into their corrective action program. The licensee also created work orders to fix/close the penetration. The licensee was unable to identify when or why the penetration was opened in the wall.
Corrective Action References: AR 2478849
Performance Assessment:
Performance Deficiency: The licensees failure to ensure that all fire barriers protecting safety-related areas are always functional as required by Section 5.6.5, Fire Rated Assemblies, in licensee procedure 0-ADM-016, Fire Protection Program, Rev 039, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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 functional integrity of the fire barrier penetration ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility.
The fire barrier did not meet all its required parameters for a functional barrier for a design basis fire.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was assigned to category 1.4.4 Fire Confinement with a High Degradation rating because greater than 30% of the required concrete depth was missing. The inspectors concluded that the finding was of very low safety significance (Green) when a regional senior risk analyst reviewed the results of the licensees fire probabilistic risk assessment (PRA)-based risk evaluation and determined the fire PRA was capable of adequately evaluating the risk associated with the finding and the delta CDF was less than 1E-6 (Step 1.5.1).
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. The licensee was unable to identify when or why the penetration was opened and it has likely been present for longer than three years.
Enforcement:
Violation: Turkey Point Unit 3 operating license Condition 3.D, states in part, that the licensee shall implement and maintain in effect, all provisions of the approved fire protection program, as approved in applicable NRC Safety Evaluation Reports (SER). Licensee procedure, 0-ADM-016, Fire Protection Program, Rev 039, is one of the fire protection program implementing documents described in the SER. 0-ADM-016, Section 5.6.5,Fire Rated Assemblies, requires, that all fire rated assemblies (walls, floors, ceilings, fire barrier penetration seals, raceway protection, and other fire barriers) separating fire areas or otherwise protecting specified nuclear safety functions and all sealing devices in fire rated assembly penetrations (fire doors, fire windows, fire dampers, cable, piping, and ventilation duct penetration seals) shall be functional. With one or more of the Group 2 required fire rated assemblies and/or sealing devices non-functional, within eight hours, the licensee is required to establish a fire watch on at least one side of the affected assembly.
Contrary to the above, prior to February 9, 2024, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in 0-ADM-016, as approved in applicable NRC SERs. Specifically, the licensee failed to ensure that the fire wall in the Unit 3 P&V room was functional when an unknown, unlabeled open penetration was discovered without the proper fire protection impairment or compensatory measures implemented.
Enforcement Action: This violation is being treated as an NCV, 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 April 18, 2024, the inspectors presented the integrated inspection results to Mr.
Michael Strope, Site Vice President, and other members of the licensee staff.
- On January 25, 2024, the inspectors presented the emergency preparedness program inspection results to R. Montgomery, Acting Site Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS Inspectors reviewed the reports from Institute on Nuclear Power Operations that were issued during the previous inspection period.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Requests
280219
Procedures
3-OSP-023.01
Diesel Generator Operability Test
Procedures
3-OSP-075.5
Auxiliary Feedwater System Flowpath Verification
Procedures
4-OSP-075.5
Auxiliary Feedwater System Flowpath Verification
Corrective Action
Documents
Resulting from
Inspection
Action Requests
2478849, 02478382, 02478452, 02480063
Fire Plans
PFP-3-EDG-18
Unit 3 Emergency Diesel Generator Building
Fire Plans
Unit 3&4 Auxiliary Building
Fire Plans
Unit 3 and 4 Auxiliary Building Pre-Fire Plan
Miscellaneous
5610-016-DB-001
Fire Protection System NFPA 805 Design Basis
Miscellaneous
PTN-BFJR-24-
007
Fire Zone 40 Barrier Risk Assessment
Procedures
0-ADM-016
Procedures
0-ADM-16.1
Transient Combustible and Flammable Substance Program
Procedures
0-ADM-16.3
Fire Protection Impairments
Procedures
0-ONOP-016.10
Safe Shutdown Manual Actions
Procedures
0-ONOP-016.8
Response to a Fire/Smoke Detection System Alarm
Procedures
0-SFP-016.3
Fire Barrier, Structural Steel, Curbs, Drains, And Physical
Separation Inspection
2A
Work Orders
Work Orders
40468234
Procedures
3-OSP-075.9
Corrective Action
Documents
Resulting from
Inspection
Action Requests
2478611, 02478838, 02478845, 02478849
Procedures
0-ADM-009
Containment Entries When Containment Integrity is
Established
Procedures
3-OP-023
Procedures
OP-AA-102-1003-
Guarded Equipment Log
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
F-02
Calculations
PTN-BOHN-20-
001
Containment Radiation Monitors (R-11/R-12) Setpoint
Evaluation for Replacement Mirion Monitors
Corrective Action
Documents
Action Requests
00462994, 02478854
Work Orders
Work Requests
256425
Corrective Action
Documents
Action Requests
2469899, 02469244, 02177625
Corrective Action
Documents
Resulting from
Inspection
Action Requests
2476806
Engineering
Changes
295050
Corrective Action
Documents
Action Requests
2477878, 02479907, 02480526, 02480527, 02480494,
2480949, 02480298, 02480424, 02480711, 02482442,
2463398
Corrective Action
Documents
Resulting from
Inspection
Action Requests
2480719
Procedures
0-ADM-009
Containment Entries When Containment Integrity Is
Established
Procedures
3-OP-023
01/23/2024
Work Orders
Work Orders
40808591, 40962714, 40693340, 40964228, 40963613,
40881911, 40883453, 40959235
Corrective Action
Documents
25425
Alert notification system computer
04/26/2022
Corrective Action
Documents
2432948
EP Siren failed scheduled test due to lightning strike
08/25/2022
Procedures
6.80.01-L
Transmission & Substation Siren System Availability Test
Procedure Nuclear Field Operations
2/30/15
Procedures
6.80.02-I
Transmission & Substation Siren Maintenance Procedure
3/18/2013
Procedures
6.80.05-D
Transmission & Substation Master Siren Control System
2/22/2008
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Maintenance Procedure Technical Services
Procedures
FEMA-43
Public Alert and Notification System for the Turkey Point
Plant
2/2024
Miscellaneous
23 ERO Roster
Miscellaneous
4Q2023
Quarterly Off Hours Telephone Test
Procedures
0-EPIP-20104
Emergency Response Organization Notification/Staff
Augmentations
Rev. 7
Procedures
0-EPIP-20201
Maintaining Emergency Preparedness - Radiological
Emergency Plan Training
Rev. 12
Procedures
Turkey Point Radiological Emergency Plan
Rev. 75
Procedures
Emergency Action Level Technical Bases Document
Rev. 2
Procedures
F668
Turkey Point Plant Emergency Action Level Matrix [HOT]
Rev. 18
Procedures
F669
Turkey Point Plant Emergency Action Level Matrix [COLD]
Rev. 12
Corrective Action
Documents
AR 02417104, 02417433, 02470818, 02418512, 02441917,
2443712, 02445839, 02446328, 024450990, 02461278,
2401120, 02463634, 02464396, and 02464213.
Various
Corrective Action
Documents
2412913
10CFR50.54(q) Screening for procedure revision of 0-EPIP-
20112, Communications Network, Revision 8 due changes in
the emergency plan communications network.
10/10/2023
Corrective Action
Documents
2450495
10CFR50,54(q) screening for 0-EPIP-20125, Off-Site Dose
Assessment Using the Unified User Interface (URI), Revision
to clarify the last Irradiated input in reference to spent fuel
.accidents.
10/10/2023
Corrective Action
Documents
2451175
0CFR50.54(q) screening for 0-EPIP-20134, Offsite
Notifications and Protective Action Recommendations,
Revision 14 due to Replacement of Emnet Communications
System with Satellite Communications
03/31/2023
Corrective Action
Documents
2463634
U3 SFP High Range NGM RAD-3-6418B Failed
08/02/2023
Corrective Action
Documents
2470818
RAD-3-6418A and RAD-3-6418B Nonfunctional
10/26/2023
Corrective Action
Documents
2413269
10CFR50.54(q) screening for 0-EPIP-20110, Criteria for and
Conduct of Owner Controlled Area Evacuation, Revision 1B
to streamline ERO to support 1 Fleet 1 Team
09/20/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2438125
10CFR50.54(q) screening for 0-EPIP-20101, Duties of
Emergency Coordinator, Revision 34 Streamline ERO to
support 1 Fleet 1 Team and replace the Manual Call-out
system using pagers with the Autodialer/Emergency Recall
System [All Call]
08/25/2023
Miscellaneous
November 2022 Emergency Preparedness Drill Report
11/03/2022
Miscellaneous
HP-9:15
1st and 3rd Quarter 2023 Quarterly Emergency Locker
Inventory Record
Various
Procedures
0-EPIP-1302
Core Damage Assessment
Revision 8
Procedures
0-EPIP-1302
Core Damage Assessment
Revision 7
Procedures
0-EPIP-20125
Off-Site Dose Assessment Using the Unified RASCAL
Interface (URI)
Revision 6
Procedures
0-EPIP-20125
Off-Site Dose Assessment Using the Unified RASCAL
Interface (URI)
Revision 7
Procedures
0-EPIP-20129
Emergency Response Team - Radiological Monitoring
Revision 4
Procedures
0-EPIP-20134
Offsite Notifications and Protective Action Recommendations
Revision 14
Procedures
0-EPIP-20134
Offsite Notifications and Protective Action Recommendations
Revision 15
Self-Assessments
22 Turkey Point Emergency Preparedness Regulatory
Annual Review [Nuclear Assurance Group]
09/01/2022
Self-Assessments
Unusual Event December 8, 2022 Final Report (Critique)
2/10/2022
Corrective Action
Documents
Action Requests
2480407
Miscellaneous
Off Year Exercise
24 Drill Report
71151
Corrective Action
Documents
Resulting from
Inspection
Action Requests
2480113