IR 05000250/2024011
| ML24211A039 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/06/2024 |
| From: | James Baptist NRC/RGN-II/DRS/EB1 |
| To: | Coffey B Florida Power & Light Co |
| References | |
| IR 2024011 | |
| Download: ML24211A039 (22) | |
Text
SUBJECT:
TURKEY POINT NUCLEAR PLANT, UNITS 3 & 4 - COMPREHENSIVE ENGINEERING TEAM INSPECTION (CETI) INSPECTION REPORT 05000250/2024011 AND 05000251/2024011
Dear Bob Coffey:
On June 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Nuclear Plant, Units 3 & 4 and discussed the results of this inspection with Michael Strope 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 one was determined to be Severity Level IV.
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 Nuclear Plant, 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 Nuclear Plant, Units 3 & 4.August 6, 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, James B. Baptist, Chief Engineering Branch 1 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: 05000250/2024011 and 05000251/2024011
Enterprise Identifier: I-2024-011-0022
Licensee: Florida Power & Light Company
Facility: Turkey Point Nuclear Plant, Units 3 & 4
Location: Homestead, FL 33035
Inspection Dates: June 10, 2024 to June 28, 2024
Inspectors: D. Burgess, Reactor Inspector W. Deschaine, Senior Project Engineer W. Erling, Reactor Inspector C. Even, Senior Reactor Inspector T. Fanelli, Senior Reactor Inspector C. Franklin, Reactor Inspector A. Rosebrook, Senior Reactor Analyst C. Safouri, Senior Resident Inspector T. Su, Reactor Inspector
Approved By: James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) inspection at Turkey Point Nuclear Plant, 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
Failure to Ensure Quality of Commercial Grade Items to be used as Basic Components Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71111.21M NCV 05000250,05000251/2024011-01 Management Open/Closed Introduction: The NRC identified a Green non-cited violation (NCV) of Title 10 CFR Part 50,
Appendix B, Criterion III, Design Control," for the failure to translate the requirements from Part 21 and the station Quality Assurance Topical Report (QATR), FPL-1, to ensure that purchased components met the requirements of commercial grade items before they could be dedicated as basic components and installed in the U3 & U4 DC switchgear.
Failure to Perform an auditable 10 CFR 50.59 Evaluation Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21M Systems Severity Level IV Conservative NCV 05000250,05000251/2024011-02 Bias Open/Closed Introduction: The NRC identified a Green Severity Level IV non-cited violation (NCV) of 10 CFR 50.59(d)(1), for the failure to perform an auditable change evaluation that demonstrated changes to the site emergency diesel generators (EDGs) preventative maintenance (PM)frequencies were acceptable to the site licensing basis and did not require a license amendment.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000250,05000251/20 Circuit Breaker Quality as a 71111.21M Closed 24010-06 Basic Component
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
===71111.21M - Comprehensive Engineering Team Inspection
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Structures, Systems, and Components (SSCs) (IP section 03.01)===
For each component sample, the inspectors reviewed the licensing and design bases. The inspectors reviewed a sample of operator actions, corrective action program documents, internal and external operating experience, test records, preventive maintenance records, work orders, aging management programs, and performed a walkdown of the component or procedure. Additional component specific design attributes reviewed by the inspectors are:
- (1) Eagle 21
- Process Medium
- Energy Source
- Controls
- Operator Actions
- Design
- (2) FCV-113A&B/114A&B Blender Flow to Charging Pump/ Blender Flow to VCT
- Process Medium
- Energy Source
- Controls
- Operator Actions
- Design
- Work Orders review
- (3) HV-3/4-759A Manual Isolation for RHR Recirculation Loops
- Controls
- Operator Actions
- Installed Configuration
- Process Medium
- Energy Source
- Procedures Review
- Design
- (5) Safety Related Batteries 3A, 3B, 3/4D, 4A, 4B
- Process Medium
- Energy Source
- Component Degradation
- Design
- Testing
- (6) POV-3/4-4883 Turbine Plant Cooling Water (TPCW) Intake Cooling Water (ICW)
Isolation valve
- Process Medium
- Energy Source
- Design
- Environmental qualification
- Controls
- Operation
- Design
- Testing
- (8) Startup Transformer Control Circuits
- Controls
- Operation
- Design
- Testing
- (9) Unit 3 Diesels
- Controls
- Operation
- Design
- Testing
- (10) U4 Diesels
- Controls
- Operation
- Design
- Testing
Modifications (IP section 03.02) (3 Samples)
- (1) DCP 0000291559 Unit 3 Containment Atmosphere Radiation Monitor (RD-3-11/RD-3-12) Replacement
- (2) DCP 0000297330 Extend the Interval of The Selected Unit 4 Emergency Diesel Generators
- (3) DCP 0000295196 Disable Unit 3 Medium Runback on CV-3-2011 Opening
10 CFR 50.59 Evaluations/Screening (IP section 03.03) (14 Samples)
- (1) DCP 0000299394 Update Calculation PTN-BFJI-95-006 PER AR 02473538
- (2) DCP 0000290647 Unit 4 Source Range and Intermediate Range Cable Replacement with New Organic Cables. N-31 / N-35; N-32 / N-36
- (3) DCP 0000297103 Permanently Disable Low Pressure Feedwater Heaters Bypass Valve CV-4-2011
- (4) DCP 0000296425 Protection Change for 4P19B Motor Replacement (Breaker 40558)
- (6) DCP 0000293425 Revise Control Circuitry for U3 Swing ECC Fan (3b - 3v30b) In Accordance with AR 2219505
- (8) DCP 0000293991 Unit 4 Low Pressure Turbine Pre and Post Replacement Performance Testing
- (9) DCP 0000285668 Low Pressure Turbine Replacement - Turkey Point Unit 4
- (10) DCP 0000293337 Pipe Modification Downstream MOV-3-832 AR 02316085 WO40666137
- (11) DCP 0000298560 Modify Spare Valve Stem CAT ID 9100687-1 for use on HCV-3-13
- (12) DCPs 0000298116 and 0000298486 Extend the Maintenance Interval of the Unit3 3A Emergency Diesel Generator
- (13) DCP 0000297138 Lower the Supply Regulator Settings on CV-3-4658A/B and Revise
===02171-TR-003
- (14) DCP 0000296607 Extend the Interval of The Selected Unit 4 Emergency Diesel Generators Maintenance Activities - One-Time Variance for 4B EDG 36-Month and Mech Governor Replacement PMS
Operating Experience Samples (IP section 03.04)===
- (1) OpEx smart sample PRA Configuration Control
- (2) Check valve testing for AFW
INSPECTION RESULTS
Failure to Ensure Quality of Commercial Grade Items to be used as Basic Components Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.3] - Change 71111.21M NCV 05000250,05000251/2024011-01 Management Open/Closed
Introduction:
The NRC identified a Green non-cited violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control," for the failure to translate the requirements from Part 21 and the station Quality Assurance Topical Report (QATR), FPL-1, to ensure that purchased components met the requirements of commercial grade items before they could be dedicated as basic components and installed in the U3 & U4 DC switchgear.
Description:
Title 10 CFR Part 21, § 21.3 Definitions specifies, in part, Commercial grade item.
- (1) Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics [CCs] of the item cannot be verified). In addition, § 21.3 stated, in part, In all cases, the dedication process must be conducted in accordance with the applicable provisions of 10 CFR Part 50, appendix B. To verify the basis of commercial grade items, Florida Power & Lights (FPL) QATR, Section A.7, Regulatory Commitments, is committed to using the Electric Power Research Institute (EPRI) report 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications. The EPRI report section 3.1, Commercial-Grade Items, specified, in part, that it is important to recognize that a commercial-grade item cannot be dedicated if any critical characteristic of the item cannot be verified. The realization that a commercial-grade item cannot be dedicated should be self-evident if the dedication process is correctly performed. In addition, the EPRI report specified technical evaluations and Item equivalency evaluations (IEEs) to ensure purchased items meet the requirements of 10 CFR Part 21. The CCs that would need to be verified included, but were not limited to, the quality of the operating mechanisms, pivot mechanisms, greases, springs, current carrying conductors, contacts, and the fit of these parts and mechanisms together inside the MCCBs, etc...
FPL purchased and installed MCCBs that were intended to replicate the I-T-E Imperial circuit breakers that are installed in the U3 & U4 safety-related DC switchgears, on both trains in both units. The purchase was from a small local, unofficial, and unverified, manufacturer, purportedly Miami Circuit Breaker Inc (MBI). During the 2024 Aging Focused Engineering Inspection (FEI), an Unresolved Item (URI) was identified related to the quality assurance (QA) of the MCCBs, Circuit Breaker Quality as a Basic Component URI 05000250,05000251/2024010-06. The item was unresolved pending further inspection and to allow the licensee to perform a commercial-grade survey of MBI. However, MBI is no longer in business and cannot provide any traceability or records to justify the MCCBs as commercial-grade items.
In 2014, FPL performed an IEE that determined that the MBI MCCBs were equivalent alternate items to the I-T-E Imperial MCCBs. However, the IEE documented that the MBI MCCBs were not listed by Underwriters Laboratories (UL), but the I-T-E Imperial MCCBs were UL listed and are traceable to I-T-E Imperial manufacturing facilities. A UL Listing is a certification that the MCCBs have undergone testing by UL that ensured that they meet specific safety standards and were manufactured in compliance with ULs quality control standards, which ensure that defects or failures to comply were identified and corrected.
Because FPL did not perform required in-process inspections and verifications (commercial-grade surveys), to ensure that defects or failures to comply were identified and corrected, the MBI MCCBs could not be considered commercial-grade items as specified by 10 CFR part 21. Therefore, they could not be dedicated as basic components in accordance with Part 21 and the EPRI report.
FPL cited certain acceptance criteria from NRC Bulletin 88-10 Nonconforming Molded-Case Circuit Breakers, to accept the MCCBs without the required verifications. The bulletin was issued because of counterfeit MCCBs that displayed low quality and high failure rates prior to 1988. The bulletin specified that untraceable MCCBs of low quality and high failure rates should be removed from service and reported to the NRC. The MBI MCCBs were untraceable to any certified manufacturer and displayed low quality and high failure rates upon initial examination at the FPL corporate commercial-grade dedication (CGD) facility. The bulletin specifically required MCCBs purchased after 1988 to fully meet the minimum applicable industry codes and standards prior to being upgraded to basic components. This would meet the requirement for commercial-grade item outlined in Part 21.
The requirement to meet minimum applicable industry codes and standards was also specified in the QATR, Section A.7, which committed to quality assurance requirements for electrical equipment (RG 1.30-1972, ML081270243, and IEEE 336-1971, IEEE Standard for Installation, Inspection, and Testing requirements for Instrumentation, and Electric Equipment During the Construction of Nuclear Power Generating Stations). The IEEE 336 standard specified, in part, that the applicable published codes, standards, and guides shall be used.
In cases where codes or standards were intended to cover the manufacturing phase of an item, these codes shall be used as guides. The CGD facility did not meet these standards.
The team determined that the designation of basic components for these MCCBs did not meet the requirements of 10 CFR Part 21 or the site QATR.
Corrective Action References: AR 2482016 and AR 02489598
Performance Assessment:
Performance Deficiency: The failure to translate the requirements from Part 21 and the station QATR, FPL-1, to ensure that purchased components met the requirements of commercial grade items before they could be dedicated as basic components and installed in the U3 & U4 DC switchgear 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 Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the absence of QA for the MCCBs increased the likelihood of external events (fire) from a malfunction of the DC switchgear, thus increasing the likelihood of events that upset plant stability and challenge critical safety functions.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 1
- Initiating Events Screening Questions, Item E. The finding was a deficiency that affects External Event Initiators (Fire). Perform a detailed risk evaluation.
A regional senior reactor analyst (SRA) performed a detailed risk assessment using the guidance in IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, IMC 0609 Appendix F, Fire Protection Significance Determination Process, and the Risk Assessment of Operational Events Handbook (RASP Manual) Volume 1 - Internal Events. In this case a population of 37 120V DC molded case circuit breakers that cannot be considered reliable when they do not meet 10 CFR Part 21 and QATR requirements, they needed to be evaluated. The SRA used SAPHRIE 8 Version 8.2.10 and the Turkey Point Units 3 and 4 SPAR model revision 8.81 dated 7/28/23. The exposure period is 1 year, the maximum allowed by the SDP, since all the breakers have been in service for greater than 1 year. The SRA assumed the failure mode would be 1) the breaker fails to trip on a fault and 2) failure to remain closed under accident loading. The SRA modelled these failures by adjusting the failure rates of the dc buses that the breakers were installed in (Buses 3D01, 4D01, 3D23, 4D23.) The SRA conservatively chose to increase the failure rate for these buses by 2 orders of Magnitude (X100) by adjusting terms DCP-BDC-LP-D3A DIVISION 3A 125 V DC POWER BUS 3A FAILS, DCP-BDC-LP-D3B DIVISION 3B 125 V DC POWER BUS 3B FAILS, DCP-BDC-LP-D4A DIVISION 4A 125 V DC POWER BUS 4A FAILS, and DCP-BDC-LP-D4B DIVISION 4B 125 V DC POWER BUS 4B FAILS from 1.71 E-5 to 1.71 E-
3. This conservatively bounds the uncertain reliability, models the effects of both failure
modes, and takes into account none of the breakers have failed under normal operational loading. The dominate accident sequence was a loss of 3D23 dc bus, failure of the B turbine driven auxiliary feedwater pump to run, and failure of the operators to manually control MFW bypass air operated valves. The resulting change in core damage frequency was approximately 1.94 E-7. Since the risk from internal events was greater than 1 E-7, Internal fire, flooding and seismic sequences were also considered. The licensees PRA model was considered best available information for internal fire effects of the PD because the licensees fire PRA has been reviewed by the NRC as part of the NFPA 805 license amendment and is Regulatory Guide 1.200 compliant. The licensee contracted a third-party vendor to adjust the fire PRA to reflect the PD and rerun and quantify the model. The licensee assumed a Fire Initiation frequency change of a factor of 10 for the affected busses and did a partial fraction for the number of Miami Breaker to total breakers in each affected switchgear. The dominant fire sequence was a fire in Switchboard 3D23 due to an uncleared electrical fault. Change in Core damage frequency was determined to be approximately 2.65 E-7 on Unit 3 and 3.11 E-7 on Unit 4. The SRA reviewed the third-party evaluation, concurred with the approach and assumptions made, and agreed that the results seemed reasonable. Change in risk due to internal flooding or seismic was minimal. The risk from internal events and internal fire/flooding/seismic were added together and determined to be less than 1 E-6 event per year and therefore, the SDP characterized the finding as very low safety significance (Green).
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Leaders did not use systematic processes to evaluate changes that required work groups to communicate across and coordinate their activities within and across organizational boundaries so that nuclear safety remains the overriding priority.
Enforcement:
Violation: 10 CFR Part 50 Appendix B, Criterion III, Design Control, states, in part, that Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.
Contrary to the above, from 2014 to the present, the licensee failed to assure that applicable regulatory requirements and the design bases, for commercial-grade items and basic components, were correctly translated into procedures and failed to properly select and review the suitability and applicability of procured safety-related molded case circuit breakers.
Specifically, regulatory requirements from 10 CFR Part 21 for commercial-grade items and the design bases, that assure the quality of electrical equipment, were not correctly translated into the evaluation and commercial-grade dedication of alternative molded case circuit breakers, and the molded case circuit breakers were not properly reviewed for suitability as basic components in the DC power systems.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
The disposition of this finding and associated violation closes URI:
05000250,05000251/2024010-06.
Failure to Perform an auditable 10 CFR 50.59 Evaluation Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.21M Systems Severity Level IV Conservative NCV 05000250,05000251/2024011-02 Bias Open/Closed
Introduction:
The NRC identified a Green Severity Level IV non-cited violation (NCV) of 10 CFR 50.59(d)(1), for the failure to perform an auditable change evaluation that demonstrated changes to the site emergency diesel generators (EDGs) preventative maintenance (PM)frequencies were acceptable to the site licensing basis and did not require a license amendment.
Description:
10 CFR 50.59(d)(1) requires, in part, that a written evaluation which provides the basis pursuant to 50.59(c)(2) for not requiring a license amendment. Specifically, why an engineering change (EC) is not a more than minimal increase in the frequency or likelihood of an accident or malfunction, respectively, prior to implementing a change to the sites EDG preventative maintenance (PM) frequencies. The site used an Electric Power Research Institute (EPRI) report, 1002936, Reliability and Preventive Maintenance: Balancing Risk and Reliability, to guide the change evaluation. However, CFR 50.59.(c)(2)(i) and
- (ii) questions were not supportable by the evaluation presented.
The site developed an EC to the EDG PM task intervals. This moved the PM task intervals from 24-months to approximately 48 to 52-months, which could include a 4-month grace period, which would provide a low reliability profile overall that would be adverse to the 50.59(c)(2) questions. Instead, the site used 12-month increments to build the reliability profile, which did not represent the overall change in reliability. First, using the change from 24 to 36 months then again using the change from 36 to 48-months. The team determined, that the total change of approximately 52-months could provide an unacceptable answer to the more than minimal increase in the likelihood of a malfunction of the EDGs, and thus effect a more than minimal increase in the frequency of an accident.
Additionally, for the more than minimal increase in the frequency of an accident, the site failed to consider DBEs in the site licensing basis i.e. a Station Blackout (SBO) for this question. The site is committed to using Nuclear Energy Institute (NEI) 96-07, for analyzing 50.59 questions. In section 3.2, Accident Previously Evaluated in The FSAR (As Updated),the NEI document specified, that accidents also include new transients or postulated events added to the licensing basis based on new NRC requirements and reflected in the UFSAR pursuant to 10 CFR 50.71(e), e.g., ATWS and SBO. Site procedure, EN-AA-203-1202-004, identified SBO for consideration in these evaluations. The team determined that the EC did not appropriately consider DBEs, such that, the EC conclusions were auditable, acceptable to the site licensing basis, and not require a license amendment. This was a performance deficiency and impacted the NRC regulatory process because the changes were already implemented.
Corrective Actions: was entered into the corrective action program which documents the action to review the evaluation and provide any additional information that is necessary to clarify the conclusions.
Corrective Action References: AR 2489515
Performance Assessment:
Performance Deficiency: The failure to perform an auditable change evaluation that demonstrated changes to the site EDGs PM frequencies were acceptable to the site licensing basis and did not require a license amendment was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control 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, making changes to the EDG PM task frequencies without first demonstrating that the changes did not increase the frequency of occurrence of an accident and increases the likelihood of occurrence of a malfunction affected the reliability of EDGs.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Exhibit 2, A.1, If the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or PRA functionality? - YES --> GREEN
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop.
The licensees decision-making practices did not emphasize the prudent choice to justify the change safe using the 50.59 process instead of simply allowing PM processes to infer the change was unsafe in order to stop
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: Enforcement Policy example 6.1.d.2 - Severity Level IV, because it resulted in a condition evaluated as having very low safety significance (i.e., Green) by the SDP.
Violation: Title 10 CFR 50.59, "Changes, Test, and Experiments," Section (d)(1) requires, in part, the licensee to maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant 10 CFR 50.59(c). These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section.
Contrary to 50.59(d)(1), since 2022, the site failed to provide a basis for determining that the change to the EDG PM task interval would not result in a more than minimal, increases in the frequency of occurrence of an accident [(c)(2)(i)] and increases in the likelihood of occurrence of a malfunction of the site EDGs [(c)(2)(ii)], which would have required a license amendment.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item Circuit Breaker Quality as a Basic Component 71111.21 (Closed) URI 05000250,05000251/2024010-06 M
Description:
The inspectors reviewed the procurement and dedication of 125 VDC MCCBs used as replacements for ITE circuit breakers in the 3D23 Vital DC switchboard. The documentation provided to the team left concerns related to the dedication processes used to confirm the breaker quality as a basic component. The traceability and provenance of the MCCBs are in question. The licensee has experienced a significant level of inferior quality with these MCCBs prior to have the distributor weed out bad quality MCCBs before shipping them to the site. The CGD used Bulletin 88-10 to justify the acceptability of apparent gaps in the MCCB traceability and provenance. However, BUL 88-10 specified that molded-case CBs installed in safety-related applications after August 1, 1988, should be:
1. Manufactured by and procured from a CBM under a 10 CFR 50, Appendix B, program; or 2. Procured from a CBM or others with verifiable traceability to the CBM, in compliance with applicable industry standards, and upgraded to safety-related by the licensee or others using an acceptable dedication program. The NRC encourages addressees to significantly upgrade their dedication programs through a joint industry effort to ensure their adequacy and consistency. The NRC will monitor these industry initiatives and if they are not sufficient or not timely, or if problems with the dedication of commercial grade equipment for safety related use continue, the NRC will take appropriate regulatory actions.
(BUL 88-10, Nonconforming Molded-Case Circuit Breakers, accession number ML031220261)
Closure: NCV 05000250,05000251/2024011-01, in this report, closes this URI.
Corrective Action References: AR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 28, 2024, the inspectors presented the design basis assurance inspection (teams) inspection results to Michael Strope and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21M Calculations 110-023-AW1 Evaluation of Stroke Rev. 3
Time and Actuator
Capability for DC
Motor-Operated
Valves at Turkey
Point
71111.21MCalculations Surveillance Test Rev. 2
PTN-BFJI-95-006 Acceptance Criteria
for Eagle 21
Comparator
Setpoints
71111.21MCalculations Velan-MOV Thrust Rev. 1
PTN-BFJM-92-020 Calculation
71111.21MCalculations MOV Program: NRC Rev. 1
PTN-BFSM-11-020 Generic Letter 89-10
MOV Design Basis
Differential Pressure
Determination - Post
71111.21MCalculations NRC Generic Letter Rev. 4
PTN-BFSM-11-021 89-10 MOV Thrust
Calculation Post-EPU
71111.21MCalculations NRC Generic Letter Rev. 6
PTN-BFSM-11-022 89-10 MOV Actuator
Evaluation Post-EPU
71111.21MCalculations Turkey Point's MOV Rev. 18
SPEC-M-050 Thrust and Torque
Setting Document
71111.21M 02476587 02477437
Corrective 02477624 02477922
Action 02480612 02484027
Documents 02375514 02384843
2455012 01970269
Inspection Type Designation Description or Title Revision or
Procedure Date
2390825 02392930
2397818 02399580
2409042 02412125
2429690 02455877
2456938 02463036
2465350 02465351
2475781 02476564
2441201 02448047
2476671 02480663
2403807 02415057
2421570 02430425
2430732
71111.21M 5610-M-1100-71 Model D100-60 Rev. 8
Drawings Operator 3/4" -
1500LB U.S.A. STD
Valve Assembly
71111.21MDrawings Chemical and Rev. 33
5610-M-3046 Volume Control
System - Boric Acid
System
71111.21MDrawings 4" Globe Valves, Rev. 3
5610-M-34-31 Pressure Seal, Motor
Operator
71111.21MDrawings Boron Concentration Rev. 18
5610-T-D-19 Control System
71111.21MDrawings Auxiliary Feedwater Rev. 36
5610-T-L1 Pump Start Logic,
P&I Control System
71111.21MDrawings Feedwater & Rev. 5
5613-E-26 SH 12d Condensate Auxiliary
Feedwater to Stem
Gen Control Valve
71111.21MDrawings Feedwater & Rev. 10
5613-E-26 SH 12f Condensate Auxiliary
Inspection Type Designation Description or Title Revision or
Procedure Date
Feedwater Pump
Steam Supply D.C.
MOV-3-1403
71111.21MDrawings Instrument Air Rev. 18
5613-M-3013 System Auxiliary
Building
71111.21MDrawings Primary Water Rev. 20
5613-M-3020 Makeup System
71111.21MDrawings Primary Makeup Rev. 37
5613-M-3020 Water System
71111.21MDrawings Component Cooling Rev. 28
5613-M-3030 Water System
71111.21MDrawings Chemical and Rev. 61
5613-M-3047 Volume Control
System - Charging
and Letdown
71111.21MDrawings Boric Acid Blend Rev. 5
5613-M-430-202 System
71111.21MDrawings Component Cooling Rev. 7
5613-P-632-S Water System No. 30
Outside Containment
Stress Problem
CCW-47
71111.21MDrawings Valve Assembly 3/4" Rev. 2
w/SMB-00 Operator
71111.21M DCP MNR 294879 Replacement of Rev. 3
Engineering Electrical Penetration
Changes Assemblies T4P31
and T4P32
71111.21MEngineering Protection Change Rev. 0
Changes for 4V64B Motor
DEC 0295942 Replacement
(Breaker 45211)
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21MEngineering Replacement of Rev. 4
Changes Hagan Modules with
Phases 5, 6, 7 (Unit
3)
71111.21MEngineering PTN UNIT 3 -
Changes REROUTE 3A RCP
EC 283348 CONTROL CABLE
OUT OF FIRE AREA
H (NFPA 805).
71111.21MEngineering Low Pressure Rev. 8
Changes Turbine Replacement
EC 285668 - Turkey Point Unit 4
71111.21MEngineering Unit 4 Source Range Rev. 2
Changes and Intermediate
EC 290647 Range Cable
Replacement With
New Organic Cables.
N-31 N-35 N-32 N-36
71111.21MEngineering Unit 3 Containment Rev. 9
Changes Atmosphere
EC 291559 Radiation Monitor
(RD-3-11/RD-3-12)
Replacement
71111.21MEngineering Pipe Modification Rev. 0
Changes Downstream MOV-3-
EC 293337 832
71111.21MEngineering Revise Control Rev. 0
Changes Circuitry for U3 Swing
3v30b) In
Accordance with AR
219505
71111.21MEngineering Unit 4 Low Pressure Rev. 1
Inspection Type Designation Description or Title Revision or
Procedure Date
Changes Turbine Pre and Post
EC 293991 Replacement
Performance Testing
71111.21MEngineering Revise Control Rev. 0
Changes Circuitry for U4 Swing
71111.21MEngineering 10 CFR 50.59 Rev. 2
Changes Screening Form for
EC 294879 EC 294879
71111.21MEngineering Disable U3 Medium Rev. 3
Changes Runback on CV3-
EC 295196 2011 Opening
71111.21MEngineering Protection Change Rev. 0
Changes for 4P19B Motor
EC 296425 Replacement
(Breaker 40558)
71111.21MEngineering One-Time Variance Rev. 0
Changes for 4B EDG 36-Month
EC 296607 and Mech Governor
Replacement PMS
71111.21MEngineering Permanently Disable Rev. 1
Changes Low Pressure
Bypass Valve CV-4-
2011
71111.21MEngineering Lower the Supply Rev. 0
Changes Regulator Settings
EC 297138 On CV-3-4658A/B
and Revise 02171-
TR-003
71111.21MEngineering Extend the interval of Rev. 0
Changes the selected Unit 4
EC 297330 emergency diesel
Inspection Type Designation Description or Title Revision or
Procedure Date
generators
maintenance
activities
71111.21MEngineering Reinforcement of Rev. 0
Changes Bonnet On POV-4-
EC 297411 2602
71111.21MEngineering Replace Manual Rev. 2
Changes Operator on Valve 3-
EC 297540 759A
71111.21MEngineering Extend the Rev. 9
Changes Maintenance Interval
EC 298116 of the Unit 3A
Emergency Diesel
Generator
71111.21MEngineering Extend the Rev. 10
Changes Maintenance Interval
EC 298486 of the Unit 3A
Emergency Diesel
Generator
71111.21MEngineering Modify Spare Valve Rev. 0
Changes Stem from CAT ID
EC 298560 9100687-1 for use on
HCV-3-137
71111.21MEngineering Repair of Flange Rev. 0
Changes Face Rubber Lining
EC 298565 Using Duromar-UW
on Valve POV-3-
4883
71111.21MEngineering Safety Classification Rev. 1
Changes Change for the CVCS
EC 299158 Boric Acid Addition
System and
Components
71111.21MEngineering Update Calculation Rev. 0
Inspection Type Designation Description or Title Revision or
Procedure Date
Changes PTN-BFJI-95-006 Per
71111.21M Eval 48568 Evaluation 48568 is
Engineering initiated to address
Evaluations concerns on OSDD
74355
71111.21MEngineering Item Equivalency 09/07/2017
Evaluations Evaluation
IEE 345509
71111.21MEngineering PTN-ENG-SEES-02-Rev. 0
Evaluations 0009, Extend the
PTN-ENG-SEES-02-Interval of the
0009, EC 297330 Selected Unit 4
Emergency Diesel
Generators
Maintenance
Activities
71111.21MEngineering Westinghouse Rev. 1
Evaluations Setpoint Methodology
WCAP-12745 for Protection
Systems Turkey
Point Units 3 & 4
Thermal Uprate
Project
71111.21MEngineering Westinghouse Rev. 3
Evaluations Setpoint Methodology
WCAP-17070 for Protection
Systems Turkey
Point Units 3 & 4
(Power Uprate to
2644 MWt - Core
Power)
71111.21M 5610-003-DB-002 Component Design Rev. 16
Miscellaneous Requirements
Inspection Type Designation Description or Title Revision or
Procedure Date
Document Vital
AC/DC System
71111.21MMiscellaneous Component Design 4/26/2022
5610-019-DB-002 Requirements
Document ICW
71111.21MMiscellaneous Emergency Power 5/9/2019
5610-023-DB-002 System
71111.21MMiscellaneous Chemical and Rev. 15
5610-046-DB-001 Volume Control
System
71111.21MMiscellaneous Design Basis 04/17/2013
5610-075-DB-001 Document: Auxiliary
Feedwater System
71111.21MMiscellaneous Component Design 04/17/2013
5610-075-DB-002 Requirements
Document: Auxiliary
Feedwater System
71111.21MMiscellaneous Technical Repair Rev. 2
AA1027 Guidelines for the
Limitorque MOD
71111.21MMiscellaneous CPED Miami Circuit 02/15/2022
CPED Miami Circuit Breaker PO Binder
Breaker PO Binder Cat Cat ID 345524-2
ID 345524-2
71111.21MMiscellaneous Turkey Point Nuclear
Model Change Database Model Change
Database dated
5/14/24
71111.21MMiscellaneous Purchase Order 30A 04/07/2015
PO 02337034 Miami Breaker
71111.21MMiscellaneous Purchase Order 50A 08/01/2016
PO 02355835 Miami Breaker
71111.21MMiscellaneous Commercial Grade 02/08/2022
PO 02434742 Dedication Package
Inspection Type Designation Description or Title Revision or
Procedure Date
PO 02434742 20A
Circuit Breakers
71111.21MMiscellaneous Job Performance Rev. 0
PTN TCA-01.1 Measure: Mode 1,
Unintentional Boron
Dilution
71111.21MMiscellaneous Job Performance Rev. 0
PTN TCA-1-SNPO Measure: Stop
Primary Water
Pumps to Stop
Dilution
71111.21MMiscellaneous PTN 30A Breaker CC 03/13/2014
TIMQ141 - PE with UL Short Circuit
Characteristic Test
Identification
71111.21MMiscellaneous PTN 50A Breaker CC 08/07/2014
TIMQ141 - PE with UL Short Circuit
Characteristic Test
Identification
71111.21MMiscellaneous Limitorque Instruction Rev. 10
V000218 and Maintenance
Manual
71111.21M 0-ADM-232 Time Critical Rev. 19
Procedures Operator Action
Program
71111.21MProcedures In-Service Testing Rev. 46
0-ADM-502 (IST) Program
71111.21MProcedures Inservice Testing - Rev. 5
0-ADM-539-005 Condition Monitoring
of Check Valves
71111.21MProcedures Motor Operated Rev. 5
0-GME-102.10 Valve Operator,
Inspection and
Overhaul SMB-00
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21MProcedures Agastat Time Delay Rev. 33
0-GMP-102.3 Relay Calibration
71111.21MProcedures CVCS - Boron Rev. 40
0-OP-046 Concentration
Control
71111.21MProcedures 480 V Motor Control Rev. 16
0-PME-007.02A Center (MCC) Starter
Maintenance ITE
Series Starters
71111.21MProcedures Auxiliary Feedwater Rev. 2
0-PMM-075.10 Pump Discharge
Inspection
71111.21MProcedures Response to Nuclear 7
3-EOP-FR-S.1 Power
Generation/ATWS
71111.21MProcedures Emergency Boration Rev. 7
3-ONOP-046.1
71111.21MProcedures Auxiliary Feedwater Rev. 22
3-OSP-075.2 Train 2
Operability
Verification
71111.21MProcedures Auxiliary Feedwater Rev. 6
3-OSP-075.4 Auto-Start Test
71111.21MProcedures Auxiliary Feedwater Rev. 36
3-OSP-075.6 Train 1 Backup
Nitrogen Test
71111.21MProcedures Auxiliary Feedwater Rev. 32
3-OSP-075.7 Train 2 Backup
Nitrogen Test
71111.21MProcedures AFW Overspeed Test Rev. 11
3-OSP-075.9
71111.21MProcedures Inservice Valve Rev. 20
3-OSP-206.1 Testing - Cold
Inspection Type Designation Description or Title Revision or
Procedure Date
Shutdown
71111.21MProcedures Auxiliary Feedwater Rev. 46
4-OSP-075.6 Train 1 Backup
Nitrogen Test
71111.21MProcedures Auxiliary Feedwater Rev. 46
4-OSP-075.7 Train 2 Backup
Nitrogen Test
71111.21MProcedures PRA 17
EN-AA-105-1000 CONFIGURATION
CONTROL AND
MODEL
MAINTENANCE
71111.21MProcedures Maintenance Testing Rev. 20
71111.21MProcedures Maintenance Testing Rev. 19
71111.21MProcedures Item Equivalency Rev. 2
NSC-PP-024 Evaluation Process
71111.21MProcedures Inservice Testing Rev. 9
PTN-IST-PLAN Program Fifth Ten
Year Interval
71111.21MProcedures Procurement Rev. 22
QI-4-NSC-9 Engineering Control
71111.21M 40600276-01,
Work Orders 40600276-05,
40600276-06,
40600276-07,
40600276-08,
40680266-01,
40771842-01,
40804866-01,
40825160-01,
40827439-01,
40844802-01,
Inspection Type Designation Description or Title Revision or
Procedure Date
40855248-01,
40857453-01,
40881907-01,
40888808-01,
40888809-01,
40907626-01,
40946262-01,
40946267-01,
40855248-01
23