IR 05000250/2014004
| ML14296A129 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/23/2014 |
| From: | David Dumbacher NRC/RGN-II/DRP/RPB3 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| IR 2014004 | |
| Download: ML14296A129 (30) | |
Text
UNITED STATES tober 23, 2014
SUBJECT:
TURKEY POINT NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000250/2014004 AND 05000251/2014004
Dear Mr. Nazar:
On September 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Nuclear Generating Station, Units 3 and 4. On October 9, 2014, the NRC inspectors discussed the results of this inspection with Mr. Kiley and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance (Green)
in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violations or significance of these NCVs, 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, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Turkey Point Nuclear Generating Station. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
David Dumbacher, Branch Chief (Acting)
Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-250, 50-251 License Nos. DPR-31, DPR-41
Enclosure:
Inspection Report 05000250/2014004, 05000251/2014004 w/Attachment: Supplemental Information
REGION II==
Docket Nos: 50-250, 50-251 License Nos: DPR-31, DPR-41 Report No: 05000250/2014004, 05000251/2014004 Licensee: Florida Power & Light Company (FP&L)
Facility: Turkey Point Nuclear Generating Station, Units 3 & 4 Location: 9760 S. W. 344th Street Homestead, FL 33035 Dates: July 1, 2014 to September 30, 2014 Inspectors: T. Hoeg, Senior Resident Inspector M. Endress, Resident Inspector D. Mas-Penaranda, Resident Inspector T. Lighty, Reactor Inspector (1R15, 1R18, 4OA2.3)
C. Jones, Senior Construction Inspector (4OA3.1, 4OA7)
Approved by: David Dumbacher, Branch Chief (Acting)
Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000250/2014004, 05000251/2014004; 07/01/2014 - 09/30/2014; Turkey Point Nuclear
Generating Station, Units 3 & 4; Problem Identification and Resolution.
The report covered a three-month period of inspection by the resident inspectors and two regional inspectors. One Green non-cited violation was identified. The significance of inspection findings are identified by their color (Green, White, Yellow, or Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP) dated June 2, 2011. All violations of NRC requirements were dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
A self-revealing, non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to implement corrective actions to prevent water intrusion into electrical conduits that affected safety related equipment. Specifically, the licensee failed to establish corrective actions to prevent water intrusion into the power supply for the Unit 3 B train (3B) pressurizer back-up heaters. After discovery of the condition, the licensee completed immediate corrective actions to apply waterproofing sealant to an unsealed condulet elbow that was the source of the pressurizer back-up heater water intrusion. The licensee entered this issue into their corrective action program as ARs 1985831 and 1986395.
This finding was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to implement corrective actions to prevent water intrusion events which resulted in the inoperability of 3B pressurizer back-up heaters. The inspectors evaluated the significance of the finding under the mitigating systems cornerstone using Table 2 of Attachment 4 (dated June 19, 2012) and Exhibits 2 and 4 of Appendix A (dated June 19, 2012) to Inspection Manual Chapter 0609, Significance Determination Process, (dated June 2, 2011). The inspectors determined the finding was of very low safety significance (i.e., Green)because the exhibit criteria did not screen to a detailed risk assessment. A cross-cutting aspect was not identified because this performance deficiency occurred in 2007 and there have been no recent opportunities for the licensee to apply current processes and procedures for this issue. Therefore, the inspectors concluded that the performance deficiency was not indicative of current licensee performance. (Section 4OA2.2)
Licensee-Identified Violations
One violation of very low safety significance was identified by the licensee and has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into their corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 3 began the inspection period at 100 percent of rated thermal power (RTP). On July 26, 2014, power was lowered to 75 percent of RTP due to elevated ultimate heat sink cooling canal temperatures. On August 5, 2014, power was raised back to full RTP. On August 11, 2014, the unit was manually tripped due to a loss of instrument air pressure. On August 15, 2014, the unit returned to 100 percent of RTP. On August 21, 2014, power was lowered to 70 percent of RTP due to elevated ultimate heat sink cooling canal temperatures. On August 26, 2014, power was returned to 100 percent of RTP and remained there through the end of this inspection period.
Unit 4 began the inspection period at 100 percent of RTP. On July 26, 2014, power was lowered to 75 percent of RTP due to elevated ultimate heat sink cooling canal temperatures.
On July 30, 2014, was raised back to full RTP. On August 21, 2014, power was lowered to 70 percent of RTP due to elevated ultimate heat sink cooling canal temperatures. On August 26, 2014, power was returned to 100 percent of RTP. On September 22, 2014, the unit was shut down for a scheduled refueling outage where it remained through the end of this inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (R)
1R04 Equipment Alignment
.1 Partial Equipment Walk downs (Quarterly)
a. Inspection Scope
The inspectors conducted four partial alignment verifications of the safety-related systems listed below. These inspections included reviews using plant lineup procedures, operating procedures, and piping and instrumentation drawings, which were compared with observed equipment configurations to verify that the critical portions of the systems were correctly aligned to support operability. The inspectors also verified that the licensee had identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers by entering them into the corrective action program (CAP).
- 4A emergency diesel generator (EDG) while the 4B EDG was out of service (OOS)
- 4B intake cooling water (ICW) train while the 4A ICW train was OOS
b. Findings
No findings were identified.
.2 Equipment Alignment (Semi-Annual)
a. Inspection Scope
The inspectors conducted one complete system alignment walk down of the 4A residual heat removal (RHR) system train while the 4B train was out of service for testing. The inspectors conducted a detailed review of the alignment and condition of the 4A RHR system to verify its capability to meet its design basis functions. The inspectors utilized licensee procedure 4-OP-050, Residual Heat Removal System, Drawing 5614-M-3050, Residual Heat Removal System Drawing, as well as other licensing and design documents to verify the system alignment was correct. During the walk down, the inspectors verified, as appropriate, that:
- (1) valves were correctly positioned and did not exhibit leakage that would impact their function,
- (2) electrical power was available as required,
- (3) major portions of the system and components were correctly labeled, cooled, and ventilated,
- (4) hangers and supports were correctly installed and functional,
- (5) essential support systems were operational, (6)ancillary equipment or debris did not interfere with system performance,
- (7) tagging clearances were appropriate, and
- (8) valves were locked as required by the licensees locked valve program. Other items reviewed included the operator workaround list, the temporary modification list, system health reports, system description, and outstanding maintenance work requests/work orders. In addition, the inspectors reviewed the licensees CAP to ensure that the licensee was identifying and resolving associated equipment alignment problems.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Fire Area Walk Downs
a. Inspection Scope
The inspectors toured the following five plant areas to evaluate conditions related to control of transient combustibles, ignition sources, and the material condition and operational status of fire protection systems including fire barriers used to prevent fire damage and propagation. The inspectors reviewed these activities using provisions in the licensees procedure 0-ADM-016, Fire Protection Plan, and 10 CFR Part 50, Appendix R. The licensees fire impairment lists were routinely reviewed. In addition, the inspectors reviewed the condition report database to verify that fire protection problems were being identified and appropriately resolved. The inspectors accompanied fire watch roving personnel on a tour of fire protection impairments and risk-significant fire areas to ensure monitoring of area status and to verify proper identification and handling of transient combustibles. The following areas were inspected:
- 3A EDG Room, Fire Zone 73
- 3B EDG Room, Fire Zone 72
- Unit 3 West electrical penetration room, Fire Zone 19
- Unit 4 switchgear room 4A, Fire Zone 68
- Unit 3 480 volt load center room A and B, Fire Zone 95
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
On August 20, 2014, the inspectors observed an unannounced fire drill that took place in the station power block at Hazmat Building B-24. The drill was observed to evaluate the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief meeting and took appropriate corrective actions as required. Specific attributes evaluated were:
- (1) proper wearing of fire protective gear and self-contained breathing apparatus,
- (2) proper use and layout of fire hoses, (3)employment of appropriate fire-fighting techniques,
- (4) sufficient fire-fighting equipment brought to the scene,
- (5) effectiveness of command and control, (6)search for victims and propagation of the fire into other plant areas,
- (7) smoke removal operations,
- (8) utilization of pre-planned strategies,
- (9) adherence to the pre-planned drill scenario, and
- (10) drill objectives. The inspectors also observed the operation of a fire hydrant and charging of fire hoses and actual discharging of water from fire hose nozzles to the open lot area adjacent to building B-24.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding
a. The inspectors conducted walk downs of the following areas subject to internal flooding to ensure that flood protection measures were in accordance with design specifications. The inspectors reviewed the Turkey Point Updated Final Safety Analysis Report (UFSAR), Appendix 5F, Internal Plant Flooding, that discussed protection of areas containing safety-related equipment that could be affected by internal flooding. Specific plant attributes that were checked included structural integrity, sealing of penetrations, sump pump configurations, and control of debris.
Operability of sump systems, including alarms were verified to be in working order.
This review constituted one inspection sample.
- Unit 3 and Unit 4 4160 volt switchgear room
- Unit 4 RHR pump room
b. Findings
No findings were identified.
.2 Underground Manhole Inspections
a. Inspection Scope
The inspectors performed underground cable manhole inspections including checking for accumulated water and cable inspections in accordance with WO 40291853, Wet Drain Severity 3 Manhole Inspections. The following areas were inspected and associated records were reviewed for completion of one inspection sample:
- Manholes 329, 404, 657, 701, 713, 714, 734, and 738
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors verified heat exchanger performance monitoring and testing of the component cooling water (CCW) system safety related heat exchangers for Unit 3 and 4. The licensees testing verified adequate heat transfer from the component cooling water system to the intake cooling water system. The inspectors checked that monitoring and trending of heat exchanger performance was done at an appropriate interval and that the licensee routinely verified the operational readiness of the system should it be needed for accident mitigation. The inspectors walked down portions of the cooling systems for integrity checks and to assess operational lineup and material condition. On a routine frequency, the inspectors monitored the licensees maintenance associated with heat exchanger cleaning and fouling prevention including the 4B and 4C heat exchanger cleaning during the weeks of July 28, 2014, and August 4, 2014, respectively. In addition, the following two heat exchanger performance test procedures were reviewed by the inspectors for completeness. This review constituted one inspection sample.
- 3-OSP-030.4, Unit 3 A/B/C CCW Heat Exchanger Performance Test, completed 7/19/2014
- 4-OSP-030.4, Unit 4 A/B/C CCW Heat Exchanger Performance Test, completed 7/28/2014
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
Resident Inspector Quarterly Review
.1 Simulator Performance
a. Inspection Scope
On September 9, 2013, the inspectors assessed licensed operator performance in the plant specific simulator during a licensed operator continuing training scenario.
The training scenario was started with the unit in Mode 3, Hot Standby conditions.
Event simulations were accomplished using Simulator Training Plan PTN 760200101 LOC 14D, Reactor and Turbine Startup with Failures. Operators responded to the simulation using normal procedures 3-GOP-301, Hot Standby to Power Operations, OP-AA-100-1000, Conduct of Operations, and OP-AA-103-1000 Reactivity Management. The inspectors checked that the reactor startup and reactivity management was done in accordance with licensee procedures and as discussed in their crew briefings. Specifically, the inspectors observed the reactor plant operators performing planned reactivity manipulations and verified the operators complied with the applicable procedure for the reactor start up evolution.
The simulator board configurations were compared with actual plant control board configurations. The inspectors specifically evaluated the following attributes related to operating crew performance and the licensee evaluation:
- Clarity and formality of communication
- Ability to take timely action to safely control the unit
- Prioritization, interpretation, and verification of alarms
- Correct use and implementation of procedures
- Control board operation and manipulation, including high-risk operator actions
- Oversight and direction provided by shift supervisor, including ability to identify and implement appropriate Technical Specification (TS) actions
- Crew overall performance and interactions
- Evaluators control of the scenario and post scenario evaluation of crew performance
b. Findings
No findings were identified.
.2 Control Room Performance
a. Inspection Scope
The inspectors performed the following two focused control room observations and assessed licensed operator performance in the control room. These observations included daily routine surveillance testing, response to alarms, communications, shift turnovers, coordination of plant activities, mode changes, and response to off normal plant conditions. These observations were conducted to verify operator compliance with station operating guidelines, proper procedure use and adherence, control and manipulation of components, and control room communications.
On August 11, 2014, the inspectors did a focused observation of Unit 3 control room operations following a manual reactor trip and automatic safety injection that resulted from a loss of instrument air pressure. The inspectors responded to the control room and observed a loss of instrument air pressure on Unit 3. The inspectors observed the operating crew attempting to restore instrument air pressure per procedure 3-ONOP-013, Loss of Instrument Air. The instrument air pressure could not be restored and the crew manually tripped the reactor when air pressure reached 65 pounds per square inch gauge (psig). The crew entered procedures 3-EOP-ES-0.1, Reactor Trip Response, and 3-EOP-E-0, Reactor Trip or Safety Injection.
Specifically, the inspectors observed the reactor operators performing the post trip actions and response to a loss of instrument air pressure.
On August 13, 2014, the inspectors observed a reactor startup per procedure 3-GOP-301, Hot Standby to Power Operations. The inspectors reviewed the expected critical boron concentration calculation and the control rod pull sequence plan used during the observed reactor startup. The inspectors reviewed the recorded reactor startup physics data to ensure it was as calculated by the licensee reactor engineering staff.
The inspectors focused on the following conduct of operations attributes as appropriate:
- Operator compliance and use of procedures
- Control board manipulations
- Communication between crew members
- Use and interpretation of plant instruments, indications and alarms
- Use of human error prevention techniques
- Documentation of activities, including initials and sign-offs in procedures
- Supervision of activities, including risk and reactivity management
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the following three equipment problems documented in action reports to verify that the licensees maintenance efforts met the requirements of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and licensee procedure ER-AA-100-2002, Maintenance Rule Program Administration. The inspectors efforts focused on maintenance rule scoping, characterization of maintenance problems and failed components, risk significance, determination of a(1) classification, corrective actions, and the appropriateness of established performance goals and monitoring criteria. The inspectors also interviewed responsible engineers and observed some of the corrective maintenance activities. The inspectors verified that equipment problems were being identified and entered into the corrective action program. The inspectors used licensee maintenance rule data base, system health reports, and the corrective action program as sources of information on tracking and resolution of issues.
- AR 01983650, 3A Charging Pump Functional Failure
- AR 01942421, 4B Component Cooling Water Pump Unavailability Time
- AR 01961417, Radiation Detector RD-4-12 Functional Failure
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors completed in-office reviews and control room inspections of the licensees risk assessment of emergent or planned maintenance activities. The inspectors verified the licensees risk assessment and risk management activities using the requirements of 10 CFR 50.65(a)(4), the recommendations of Nuclear Management and Resource Council 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3, and procedures 0-ADM-068, Work Week Management, WM-AA-1000, Work Activity Risk Management, and O-ADM-225, On Line Risk Assessment and Management. The inspectors also reviewed the effectiveness of the licensees contingency actions to mitigate increased risk resulting from the degraded equipment and the licensee assessment of aggregate risk using FPL procedure OP-AA-104-1007, Online Aggregate Risk. The inspectors evaluated the following six risk assessments during the inspection period:
- 4A EDG, 4CM instrument air compressor (IAC), R-11 containment radiation monitor, and 4B emergency containment cooler (ECC) OOS
- 3C CCW heat exchanger, 3B EDG, 3B high head safety injection (HHSI) pump, 3B pressurizer heaters OOS
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
For the six operability evaluations described in the action requests (AR) listed below, the inspectors evaluated the technical adequacy of licensee evaluations to ensure that Technical Specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors reviewed the UFSAR to verify that the system or component remained available to perform its intended function. In addition, when applicable, the inspectors reviewed compensatory measures implemented to verify that the plant design basis was being maintained. The inspectors also reviewed a sampling of condition reports to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations.
- AR 1978164, 3A emergency diesel generator starting air pressure low
- AR 1985630, Unit 3 increased containment air temperatures
- AR 1983650, 3A charging pump tripped on low demand
- AR 1983906, Unit 3 containment air atmosphere feed and bleed
- AR 1992496, 4C intake cooling water pump vibration
- AR 1989631, Unit 3 turbine stop valve closure
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
The inspectors reviewed the following three temporary plant modifications. Each modification was performed in accordance with licensee procedure 0-ADM-503, Temporary System Alterations. The inspectors reviewed the 10 CFR 50.59 screening and technical evaluation to verify that the modification had not affected system operability or availability. The inspectors reviewed associated plant drawings and UFSAR documents impacted by this modification and discussed the changes with licensee personnel to verify that the installation was consistent with the modification documents. The inspectors walked down available portions of the modification to determine if it was installed in the field as described in the subject Engineering Change (EC). Additionally, the inspectors verified that problems associated with the modifications were being identified and entered into the licensees corrective action program.
- EC 281963, Remediation of High Algae Concentration in Cooling Canals
- EC 282082, Unit 3 Containment Atmosphere Instrument Air Bleed Modification
- EC 282256, Unit 3 Intake Cooling Water Basket Strainer Modification
b. Findings
No findings were identified.
1R19 Post Maintenance Testing
a. Inspection Scope
For the five post maintenance tests and associated work orders (WO) below, the inspectors reviewed the test procedures and either witnessed the testing or reviewed test records to determine whether the scope of testing adequately verified that the work performed was correctly completed and demonstrated that the affected equipment was operable. The inspectors used licensee procedure 0-ADM-737, Post Maintenance Testing, in their assessments.
- WO 40123843, Unit 3 reactor protection system relay RT-10-A replacement
- WO 40329702, Unit 3 turbine stop valve 3-10-10 maintenance
- WO 40291230, Unit 4 charging flow instrument F-4-122 maintenance
- WO 40287059, 4B residual heat removal pump motor maintenance
- WO 40335576, Unit 3 auxiliary feed water system Train I controller maintenance
b. Findings
No findings were identified.
1R20 Refueling Outage Activity
.1 Unit 4 Refueling Outage PT4-28
a. Inspection Scope
Outage Planning, Control and Risk Assessment During daily outage planning activities by the licensee, the inspectors reviewed the risk reduction methodology employed by the licensee during refueling outage (RFO)
PT4-28 meetings including outage control center (OCC) morning meetings, operations daily team meetings, and schedule performance update meetings. The inspectors examined the licensee implementation of shutdown safety assessments during PT4-28 in accordance with administrative procedure ADM-051, Outage Risk Assessment and Control, to verify if a defense in depth concept was in place to ensure safe operations and avoid unnecessary risk. In addition, the inspectors regularly monitored outage planning and control activities in the OCC, and interviewed responsible OCC management personnel during the outage to ensure system, structure, and component configurations, and work scope were consistent with TS requirements, site procedures, and outage risk controls.
Monitoring of Shutdown Activities The inspectors performed walk downs of important systems and components used for residual heat removal from the reactor core and spent fuel pool during the shutdown period including the intake cooling water system, component cooling water system, and spent fuel pool cooling system.
Outage Activities The inspectors examined outage activities to verify that they were conducted in accordance with TS, licensee procedures, and the licensees outage risk control plan.
Some of the more significant inspection activities accomplished by the inspectors were as follows:
- Walked down selected safety-related equipment clearance orders
- Verified operability of reactor coolant system pressure, level, flow, and temperature instruments during various modes of operation
- Verified electrical systems availability and alignment
- Verified shutdown cooling system and spent fuel pool cooling system operation
- Evaluated implementation of reactivity controls
- Reviewed control of containment penetrations
- Examined foreign material exclusion (FME) controls put in place inside containment (e.g., around the refueling cavity, near sensitive equipment and RCS breaches) and around the spent fuel pool (SFP)
- Verified workers fatigue rule was properly managed Refueling Activities and Containment Closure The inspectors witnessed selected fuel handling operations being performed in accordance with TS and applicable operating procedures from the main control room and refueling bridge inside the containment building. The inspectors also examined licensee activities to control and track the position of each fuel assembly. The inspectors evaluated the licensees ability to close the containment equipment, personnel, and emergency hatches in a timely manner per procedure 0-ADM-051, Outage Risk Assessment and Control.
Corrective Action Program The inspectors reviewed ARs generated during PT4-28 to evaluate the licensees threshold for initiating ARs. The inspectors reviewed ARs to verify priorities, mode holds, and significance levels were assigned as required. Resolution and implementation of corrective actions of several ARs were also reviewed for completeness. The inspectors routinely reviewed the results of quality assurance (QA) daily surveillances of outage activities.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors either reviewed or observed the following six surveillance tests to verify that the tests met the technical specification requirements, the final safety analysis report description, the licensees procedural requirements, and demonstrated the systems were capable of performing their intended safety functions and operational readiness. In addition, the inspectors evaluated the effect of the testing activities on the plant to ensure that conditions were adequately addressed by the licensee staff and that after completion of the testing activities, equipment was returned to the positions or status required for the system to perform its safety function. The inspectors verified that surveillance issues were documented in the licensee corrective action program. The inspectors verified that surveillance issues were documented in the CAP. The inspectors reviewed the following tests:
Surveillance Test:
- 4-OSP-023.1, 4B Emergency Diesel Generator Operability Test
- 3-OSP-055.1, 3C Emergency Containment Cooler Operability Test
- 4-OSP-023.1, 4A Emergency Diesel Generator Operability Test In-Service Test:
- 0-OSP-075.12, Auxiliary Feedwater System Manual Valve Operability Test Containment Isolation Valve Test:
- 4-OSP-051.5, Unit 4 Local Leak Rate Tests, Containment Spray Penetration Valves 4-890B, 4-883N, and 4-880B RCS Leak Detection Test:
- 3-OSP-041.1, Unit 3 Reactor Coolant System Leak Rate Test
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification (IP 71151)
a. Inspection Scope
The inspectors checked licensee submittals for the performance indicators (PIs) listed below for the period July 1, 2013, through June 31, 2014, to verify the accuracy of the PI data reported during that period. Performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedure 0-ADM-032, NRC Performance Indicators Turkey Point, were used to check the reporting for each data element. The inspectors reviewed operator logs, plant status reports, condition reports, licensee event reports, system health reports, and PI data sheets to verify that the licensee had identified the required data, as applicable. The inspectors interviewed licensee personnel associated with performance indicator data collection, evaluation, and distribution.
- Unit 3 Safety System Functional Failures
- Unit 4 Safety System Functional Failures
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution (IP 71152)
.1 Daily Review
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a screening of items entered daily into the licensees corrective action program. This review was accomplished by reviewing daily printed summaries of ARs and by reviewing the licensees electronic AR database. Additionally, RCS unidentified leakage was checked on a daily basis to verify no substantive or unexplained changes.
b. Findings
No findings were identified.
.2 Annual Sample: Water Intrusion Affecting 3B Back-up Pressurizer Heaters
a. Scope
The inspectors selected action request (ARs) 1985831 and 1986395 for a more in-depth review of the circumstances and the corrective actions that followed. On August 20, 2014, the 3B pressurizer back-up heaters tripped unexpectedly during Unit 3 operation in Mode 1 at 100 percent reactor power. The breaker thermal overload device for 480 volt load center breaker 30408 was found tripped.
The inspectors reviewed the licensees evaluation of the event and the completed and planned corrective actions. The inspectors reviewed licensee performance attributes associated with the complete and accurate documentation of the problem, 10 CFR 50.72 reporting requirements, identification of the root and contributing causes, and planning or completion of assigned corrective actions. The inspectors interviewed plant personnel and evaluated the licensees administration of this selected condition report in accordance with their corrective action program as specified in licensee procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205, Condition Evaluation and Corrective Action.
b. Findings
Introduction:
A Green, self-revealing, non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to implement corrective actions to prevent water intrusion into electrical conduits that affected safety related equipment. Specifically, the licensee failed to identify and correct an unsealed condulet to prevent water intrusion into the power supply for the Unit 3 B train (3B) pressurizer back-up heaters. This issue was documented in the licensees corrective action program as ARs 1985831 and 1986395.
Description:
On August 20, 2014, the 3B pressurizer back-up heaters tripped unexpectedly during operation in Mode 1 at 100 percent reactor power. The breaker thermal overload device for 480 volt load center breaker 30408 was found tripped.
Plant operators took action to reset the breaker thermal overload device and attempted to reclose the breaker without success. The operators declared the 3B pressurizer back-up heaters bank inoperable and entered Technical Specification (TS) 3.4.3 for the pressurizer and the associated limiting condition of operation.
The licensee determined that water intrusion into the power supply distribution cabinet caused a short to ground and tripped breaker 30408. The water entered the distribution cabinet from a horizontally run conduit 3F1601 located above the cabinet in the Unit 3 South electrical penetration room. The licensee determined the water had entered the conduit through a threaded connection on top of a pull box elbow condulet (A3F1602) outside of the penetration room which was exposed to the outside environment. At the time, the licensee was implementing temporary plant modification EC 282169, Supplemental External Cooling for Unit 3 Containment, by spraying the Unit 3 containment building with water. The water spray ran down a vertical section of conduit and exposed the unsealed threaded condulet connection to a constant stream of water. Following discovery of this condition, the licensee secured the water spray on Unit 3 containment to prevent further water intrusion. The licensee applied a silicone sealant to the threaded connection of the elbow condulet and drained the water from the conduit. The panel was dried out and the associated circuitry was meggered satisfactorily with the exception of two breakers which were removed from the circuit. The 3B pressurizer back-up heater bank was measured to have a 325 kilowatt (kW) capacity. The minimum required TS capacity for the bank is 125 kW. The licensee returned the heater bank to service and exited the TS on August 22, 2014. The licensee entered the issue into the corrective action program as ARs 1985831 and 1986395.
The inspectors reviewed the licensees corrective action program history for other examples of water intrusion events and noted that on June 1, 2007, the input breaker to the safety related 4B1 125 VDC battery charger was found open in a tripped condition. Further investigation by the licensee in 2007 determined water leaking from an electrical conduit located above the battery charger had leaked into the battery charger causing the input breaker to trip. The water was rainwater that had entered the conduit from a degraded seal on an electrical junction box that was exposed to the outside environment. This issue was documented in the licensees corrective action program as 2007-16980. The inspectors noted that although the licensees evaluation of the 2007 water intrusion event resulted in walkdowns of electrical equipment that were susceptible to possible water intrusion, the licensee did not walkdown and examine the condition of the pressurizer heater conduits which were exposed to the outside environment. The inspectors concluded that the licensee did not identify or correct the missing waterproof seal on pull box elbow condulet A3F1602 to prevent water intrusion from affecting the operability of the pressurizer back-up heaters.
Analysis:
The failure to take corrective actions to prevent water intrusion into electrical conduits affecting safety related equipment was a performance deficiency.
This finding was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to identify and correct an unsealed electrical conduit to prevent water intrusion that resulted in the inoperability of 3B pressurizer back-up heaters. The inspectors evaluated the significance of the finding under the mitigating systems cornerstone using Table 2 of Attachment 4 (dated June 19, 2012) and Exhibits 2 and 4 of Appendix A (dated June 19, 2012) to Inspection Manual Chapter 0609, Significance Determination Process, (dated June 2, 2011). The inspectors determined the finding was of very low safety significance (i.e., Green) because the exhibit criteria did not screen to a detailed risk assessment. A cross-cutting aspect was not identified because this performance deficiency occurred in 2007, and there have been no recent opportunities for the licensee to apply current processes and procedures for this issue. Therefore, the inspectors concluded that the performance deficiency was not indicative of current licensee performance.
Enforcement:
10 CFR 50 Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, in 2007, the licensee determined that electrical equipment (conduits, junction boxes, etc.) exposed to the outside environment were susceptible to water intrusion that could affect safety related systems, but failed to identify and correct an unsealed pull box elbow condulet (A3F1602) to prevent water intrusion into the pressurizer back-up heater power circuit. The failure to identify and correct unsealed condulet A3F1602 resulted in water intrusion into the condulet on August 20, 2014, which rendered the 3B pressurizer back-up heaters inoperable for approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
The violation was entered into the licensees corrective action program as ARs 1985831 and 1986395. (NCV 05000250/2014004-01, Failure to Identify and Correct Unsealed Condulet to Prevent Water Intrusion)
.3 Annual Sample: Unit 3 Containment Temperature
a. Inspection Scope
The inspectors selected action request (AR) 01985630, Unit 3 Containment Temperature, for a more in-depth review of the circumstances, evaluations, and actions. The action request report was reviewed to verify that an appropriate evaluation was performed and that containment temperatures were being monitored with consideration for instrument uncertainty. The inspectors evaluated the licensees assessment of operability and reviewed past operability determinations. The inspectors interviewed plant personnel and evaluated the condition report in accordance with the requirements of the licensees corrective action process as specified in procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205, Condition Evaluation and Corrective Action.
b. Findings and Observations
No findings were identified. The licensee determined, based on calculations, that the higher temperatures in containment (120-125 degrees F) during the summer months were offset by the cooler containment temperatures during the last Unit 3 refueling outage (104 degrees F); therefore, the 14 days that temperatures exceeded 120 degrees F had minimal impact on containment equipment. The inspectors noted that the licensees evaluation concluded there was no consequence associated with the higher containment temperatures and confirmed the evaluation addressed the most limiting components by spot checking the environmental qualification (EQ) database and verifying the most limiting EQ components were included.
.4 Annual Sample: Review of Operator Workarounds
a. Inspection Scope
The inspectors reviewed the licensees operator workaround (OWA) program described in procedures OP-AA-108, Oversight and Control of Operator Burdens, to verify the licensee was identifying workarounds at the appropriate threshold, entering them into their corrective action program, and planning or taking appropriate corrective actions. The inspectors performed an evaluation of the potential cumulative effect of all open operator burdens.
b. Findings and Observations
No findings were identified. The inspectors determined the licensee had identified and screened potential equipment deficiencies at an appropriate level. The deficiencies that were determined to meet a threshold based on operator impact were placed on an operator burden aggregate impact list maintained by the shift technical advisor (STA). The STA and operating crews routinely reviewed the list to maintain it up to date and to determine if an aggregate impact exists. The inspectors reviewed the list and determined a number of open operator burdens were documented including two on Unit 3, two on Unit 4, and one common to both units. The inspectors reviewed the associated operator burden screening checklists to determine completeness and accuracy. The inspectors determined that none of the equipment deficiencies on the aggregate impact lists were screened out as an operator work around classification on either unit. All five deficiencies were screened as operator challenges that did not affect technical specifications or emergency operating procedures. The inspectors determined there was no aggregate impact on either unit from the operator challenges and the conditions were entered in the licensee corrective action program with corrective actions being planned or scheduled to repair the deficiencies.
4OA3 Event Followup (IP 71153)
.1 (Closed) LER 05000251/2014-001-00, Incorrect Feed Water Flow Transmitter
Calibration Caused RPS Channels to be Inoperable On April 25, 2014, the licensee discovered that three Unit 4 feed water flow transmitters were calibrated incorrectly in April of 2013. The transmitters zero calibration point had been adjusted higher than allowed by the technical specification safety set point limits. In addition, an extent of condition review by the licensee determined that the same condition existed on Unit 3 for one feed water flow transmitter in 2012. As a result, the associated instrumentation was inoperable for a period of approximately 50 days for Unit 4 and approximately 162 days for Unit 3 and not in compliance with technical specification 3.3.1, which required an inoperable channel be placed in the tripped condition within six hours of discovery. The function of the subject instrumentation is to provide a steam flow feed flow mismatch reactor protection system trip. The licensee determined the root cause of the event was an inadequate Engineering Technical Response Memorandum (ETRM) that did not prevent its usage to change the design configuration of the plant. Corrective actions were performed in accordance with AR 1961512 and included revising the ETRM process to prevent altering the design of plant equipment, provided training to affected staff regarding usage of the ETRM process and performing maintenance on reactor protection system instrumentation. The enforcement aspects associated with the LER are discussed in Section 4OA7 of this report. This LER is closed.
.2 Notice of Enforcement Discretion (NOED) 14-2-001 Review
a. Inspection Scope
In May 2014, the licensee, Florida Power and Light (FPL) Company, noted a marked increase in the concentration of algae in the Turkey Point ultimate heat sink cooling canal system. The increased algae concentration resulted in increased solar heating of the water in the canal system. The algae concentration and temperatures remained higher than normal continuing into summer months. As a result, FPL anticipated exceeding the maximum allowable temperature specified by TS limit condition of operation (LCO) 3.7.4, Ultimate Heat Sink. The TS 3.7.4 LCO did not allow continued operation of Turkey Point Units 3 and 4 with ultimate heat sink temperature above 100 degrees F. On July, 10, 2014, FPL submitted a license amendment request to the NRC to increase the ultimate heat sink temperature limit from 100 degrees F to 104 degrees F (ADAMS Accession No. ML14196A006). On July 20, 2014, at 2:54 p.m., Turkey Point Unit 3 and 4 declared TS LCO 3.7.4 not met when the ultimate heat sink temperature exceeded 100 degrees F. If the temperature was not restored, it would have required both units be shut down and placed in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The licensee requested that the NRC exercise discretion to not enforce compliance with the required actions of TS 3.7.4 since it would result in the unnecessary shutdown of both units without a corresponding health and safety benefit when operation of the units was essential for maintaining grid voltage stability. The NRC granted approval of the NOED at 6:00 p.m. on July 20, 2014 (ADAMS Accession Nos. ML14204A652 and ML14213A069).
The NOED period ended when the NRC issued a license amendment under exigent circumstances for Turkey Point on August 8, 2014, which raised the technical specification maximum temperature limit for the ultimate heat sink from 100 degrees F to 104 degrees F (ADAMS Accession No. ML14199A107).
b. Findings
Introduction:
The inspectors identified an unresolved item (URI) regarding Turkey Point NOED 14-2-001 granted on July 20, 2014.
Description:
The inspectors reviewed Turkey Point NOED 14-2-001 and related documents to determine the accuracy and consistency with the licensees assertions and implementation of the licensees compensatory measures and commitments during the period of enforcement discretion, those of which included, in part, keeping a third CCW heat exchanger in service, increased frequency of CCW heat exchanger performance tests and cleaning, increased heat sink and system temperature monitoring and management oversight, just-in-time operator training, and minimizing the performance of risk-significant maintenance activities. Additional NRC inspection is required to conduct a review of the LER, root cause, and planned corrective actions. This URI is identified as URI 05000250, 251/2014004-02, Turkey Point Notice of Enforcement Discretion (NOED) 14-2-001 due to Exceeding Ultimate Heat Sink Temperature.
4OA6 Meetings
Exit Meeting Summary
The resident inspectors presented the inspection results to Mr. Kiley and other members of licensee management on October 9, 2014. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary information. The licensee did not identify any proprietary information.
4OA7 Licensee Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements that met the criteria of the NRC Enforcement Policy for disposition as a non-cited violation.
Turkey Point Nuclear Generating Unit 3 and Unit 4 Technical Specification (TS) 3.3.1 required, in part, that the reactor trip system instrumentation channels and interlocks of Table 3.3-1 shall be operable. Contrary to the above, for approximately 50 days from April 2013 until June 2013, the steam versus feed water flow mismatch reactor trip functions associated with Unit 4 feed water flow instruments F-4-487, F-4-496, and F-4-497 were inoperable because they exceeded their TS allowed actuation set points specified by TS Table 2.2-1, and the affected channels were not placed in trip within six hours or the unit placed in cold shutdown as required by TS. Additionally, for approximately 162 days from August 2012 until February 2013, the steam-feed water flow mismatch reactor trip function associated with Unit 3 feed water flow instrument F-3-476 was inoperable because it exceeded its TS allowed actuation set point and the affected channel was not placed in trip within six hours and the unit placed in cold shutdown as required by TS.
The inspectors assessed the significance of the violation using Inspection Manual Chapter 0609 Attachment 4, Appendix A and Exhibit 2 (June 19, 2012). The inspectors noted that the diverse low-low steam generator level reactor trip safety function was not affected by the inoperable feed water flow instruments and the violation did not represent a complete loss of the anticipatory steam versus feed water flow mismatch reactor trip function. Therefore, the inspectors concluded that violation was of very low safety significance (i.e., Green) because the violation was not associated with a significant functional degradation of the reactor protection system. The licensee completed immediate corrective actions following discovery of the condition to adjust the affected instruments to within TS allowed values and entered the issue into the corrective action program as action request (AR) 1961512.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- C. Cashwell, Radiation Protection Manager
- F. Banks, Quality Manager
- P. Czaya, Licensing
- M. Jones, System Engineering Manager
- M. Kiley, Site Vice-President
- N. Rios, Chemistry Manager
- S. Mihalakea, Licensing
- A. Katz, Maintenance Manager
- D. Sluzka, Work Controls Manager
- R. Tomonto, Licensing Manager
- R. Smith, Engineering
- C. Domingos, Engineering Director
- M. Wayland, Operations Director
- B. Stamp, Training Manager
NRC personnel
- J. Hanna, RII Senior Risk Analyst, Division of Reactor Projects
- S. Sandal, RII Senior Project Engineer, Division of Reactor Projects
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000250, 251/2014004-02 URI Notice of Enforcement Discretion (NOED)
due to Exceeding Ultimate Heat Sink Temperature (Section 4OA3.2)
Opened and Closed
- 05000250/2014004-01 NCV Failure to Identify and Correct Unsealed Condulet to Prevent Water Intrusion (Section 4OA2.2)
Closed
- 05000250, 251/2014-001-00 LER Incorrect Feed Water Flow Transmitter Calibration Caused RPS Channels to be Inoperable (Section 4OA3.1)