IR 05000250/2015007
| ML15077A138 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/17/2015 |
| From: | Bartley J NRC/RGN-II/DRS/EB1 |
| To: | Nazar M Nextera Energy |
| References | |
| IR 2015007 | |
| Download: ML15077A138 (19) | |
Text
UNITED STATES rch 17, 2015
SUBJECT:
TURKEY POINT NUCLEAR GENERATING STATION UNITS 3 AND 4 - U.S.
NUCLEAR REGULATORY COMMISSION EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS AND PERMANENT PLANT MODIFICATIONS INSPECTION REPORT 05000250/2015007 AND 05000251/2015007
Dear Mr. Nazar:
On February 6, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Unit 3 and 4 facilities, and 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.
The NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. The NRC is treating this violation as a noncited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, 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 station.
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 Regional Administrator, Region II; and the NRC resident inspector at the Turkey Point station.
2 In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000250, 05000251 License Nos. DPR-31, DPR-41
Enclosure:
IR 05000250/2015007 and 05000251/2015007 w/Attachment: Supplementary Information
REGION II==
Docket Nos.: 50-250, 50-251 License Nos.: DPR-31, DPR-41 Report Nos.: 05000250/2015007, 05000251/2015007 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: January 26, 2015, to February 6, 2015 Inspectors: T. Fanelli, Reactor Inspector (Team Leader)
E. Stamm, Senior Reactor Inspector N. Coovert, Reactor Inspector Approved by: Jonathan H. Bartley, Chief Engineering Branch 1 Division of Reactor Safety Enclosure
SUMMARY
Inspection Report (IR) 05000250/2015007, 05000251/2015007; 01/26/15 - 02/06/15; Turkey
Point Nuclear Generating Station Units 3 & 4; NRC Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.
This report covers a two-week, on-site inspection by three regional inspectors. The inspectors identified one Green non-cited violation (NCV). The significance of inspection findings is indicated by their color (Green, White, Yellow, Red) using the NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross Cutting Areas, dated December 04, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The Nuclear Regulatory Commissions (NRCs) program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 200
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
Green: The NRC identified a Green non-cited violation (NCV) of 10 CFR 50.65,
Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to adequately monitor the performance or condition of the Unit 3 containment atmospheric temperature system against licensee established goals or demonstrate that the performance of the containment atmospheric temperature system was being effectively controlled through preventive maintenance, such that the system remained capable of performing its intended function. Specifically, there were multiple individual component failures on both units since March 2011 and the Unit 3 containment atmospheric temperature system was non-functional from November 5, 2014, to January 17, 2015. In response to the NRC identified issue, the licensee initiated action report (AR) 02023116, and classified the temperature elements into 10 CFR 50.65(a)(1) status on February 23, 2015, under AR 02004990.
The inspectors determined that the performance deficiency was more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone objective. The licensee did not ensure the availability, reliability, and capability of the Unit 3 containment atmospheric temperature system that was used for emergency operating procedures. The inspectors determined the finding to be of very low safety significance (Green) because it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its Technical Specifications (TS)allowed outage time, and it did not represent an actual loss of a non-TS equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect of Evaluation, in the area of Problem Identification and Resolution. Specifically, the licensee failed to thoroughly evaluate issues that were identified in the last three years associated with containment atmospheric temperature system failures to ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance.
[P.2] (Section 1.b.1)
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R17 Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications
a. Inspection Scope
Evaluations of Changes, Tests, and Experiments: The team reviewed seven safety evaluations performed pursuant to Title 10 of the Code of Federal Regulations (CFR)50.59, Changes, tests, and experiments, to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The team also reviewed 13 screenings where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The team reviewed these documents to determine if:
- the changes, tests, or experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;
- the safety issues requiring the changes, tests or experiments were resolved;
- the licensee conclusions for evaluations of changes, tests, or experiments were correct and consistent with 10 CFR 50.59; and
- the design and licensing basis documentation used to support the change was updated to reflect the change.
The team used, in part, Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000.
This inspection constituted 7 evaluation samples and 13 screening and/or applicability determination samples as defined in Inspection Procedure (IP) 71111.17-04.
Permanent Plant Modifications: The team reviewed six permanent plant modifications that had been installed in the plant during the last three years. The modifications reviewed are listed below:
- EC 242408, Containment Spray Pump Full Flow Recirculation Modification, Rev. 0
- EC 242466, PT3-26 GL 2008-01 Vent Valve Installation Inside and Outside Cont.,
Rev. 1
- EC 249693, 3A and 3C load center circuit breakers replacement, Rev. 2
- EC 250386, Add Valve Operator Extension and Hand Wheel to Valve 4-867, Rev. 1
- EC 275133, GL 2008-01 Unit 4 Safety Injection High Vent Point Installations, Rev. 4 The modifications were selected based upon risk significance, safety significance, and complexity. The team reviewed the modifications selected to determine if:
- the supporting design and licensing basis documentation was updated;
- the changes were in accordance with the specified design requirements;
- the procedures and training plans affected by the modification had been adequately updated;
- the test documentation as required by the applicable test programs had been updated; and
- post-modification testing adequately verified system operability and/or functionality.
The team also used applicable industry standards to evaluate acceptability of the modifications and performed walkdowns of accessible portions of the modifications.
Documents reviewed are listed in the Attachment.
This inspection constituted six permanent plant modification samples as defined in IP 71111.17-04.
b. Findings
b.1 Failure to Establish a Reasonable Maintenance Effectiveness Demonstration for Unit 3 Containment Atmospheric Temperature System
Introduction:
The NRC identified a Green non-cited violation (NCV) of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to adequately monitor the performance or condition of the Unit 3 containment atmospheric temperature system against licensee established goals or demonstrate that the performance of the containment atmospheric temperature system was being effectively controlled through preventive maintenance, such that the system remained capable of performing its intended function. Specifically, there were multiple individual component failures on both units since March 2011 and the Unit 3 containment atmospheric temperature system was non-functional from November 5, 2014, to January 17, 2015.
Description:
The containment atmospheric temperature monitoring system included three analog Foxboro Spec 200 instrument loops for each unit. Each instrument loop contained an environmentally qualified resistance temperature detector (RTD)
[temperature elements (TEs)-3(4)-6700, -6701, or -6702] inside containment and the analog SPEC 200 temperature transmitter modules outside of containment. The instrument loops supplied the temperature indications to a digital Foxboro distributed control system (DCS) for temperature indications in the control room. The control room operators use these temperature indications while implementing the emergency operating procedures (EOPs) to determine when adverse containment monitoring conditions exist. To provide the EOP function, it was necessary for an entire instrument loop, from the RTD to the DCS, to function properly.
The inspectors reviewed approximately 18 occurrences over the last three years when one or more temperature loops on either unit were non-functional and in many cases for several months at a time. The licensee documented the failures in condition reports, work orders, and/or operator logs; however, they did not assess the failures to determine if the performance of the Unit 3 containment atmospheric temperature system was being effectively controlled through preventive maintenance. As of November 5, 2014, TE-3-6700 was spiking high, and was determined to be non-functional. At the time, the two other channels, TE-3-6701 and TE-3-6702, were already determined to be non-functional. The Unit 3 containment temperature monitoring system remained in this configuration until January 17, 2015. The licensee documented this system failure in action requests (AR) 2004990 and 2005388, which included the performance of an apparent cause evaluation. The investigation concluded the most probable causes for the multiple failures were aging, obsolescence, reduced reliability of refurbished spare components, and an inadequate preventative maintenance strategy.
The inspectors reviewed the maintenance rule scope bases evaluations for the low safety significant maintenance rule systems, containment normal coolers (system 57)and DCS (system 95). Although both system bases documents included the RTDs, neither of the documents contained licensee-established functional failure criteria for all the components in the containment atmospheric temperature system such that the licensee could effectively monitor the performance of the system. The licensee acknowledged that the containment atmospheric temperature indicators did not have a clearly defined function and associated performance criteria under systems 57 or 95 that allowed the licensee to demonstrate if the performance of the Unit 3 containment atmospheric temperature system was being effectively controlled through preventive maintenance and as a result. The licensee documented the issue in AR 02023116, which determined that the maintenance rule functions which apply for the temperature elements (TEs)-3-6700, -6701, and -6702 were inoperable. Therefore, this condition was considered a maintenance rule functional failure (MRFF) and classified the temperature elements into 10 CFR 50.65(a)(1) status on February 23, 2015, under AR 02004990..
Analysis:
The licensees failure to either monitor the performance or condition of the Unit 3 containment atmospheric temperature system against licensee established goals or to demonstrate that the performance of the containment atmospheric temperature system was being effectively controlled through preventive maintenance, such that the system remained capable of performing its intended functions, was a performance deficiency. This performance deficiency was considered more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not ensure the availability, reliability, and capability of the containment atmospheric temperature system, as indicated by multiple failures and extended unavailability of components needed to perform their intended functions as used in EOPs. The inspectors used IMC 0609, Att. 4, Initial Characterization of Findings, issued June 19, 2012, for Mitigating Systems, and IMC 0609, App. A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its Technical Specifications (TS) allowed outage time, and it did not represent an actual loss of a non-TS equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect of Evaluation, in the area of Problem Identification and Resolution, per IMC 0310, Components Within the Cross-Cutting Areas. Specifically, the licensee failed to thoroughly evaluate issues that were identified in the last three years associated with containment atmospheric temperature system failures to ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance. [P.2]
Enforcement:
Title 10 CFR 50.65 (a)(1), states, in part, that the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65 (b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Title 10 CFR 50.65 (a)(2) states, in part, that monitoring as specified in 10 CFR 50.65 (a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function. Contrary to the above, from the time the licensee first implemented their 10 CFR 50.65 program until February 4, 2015, the licensee failed to monitor the performance or condition of the Unit 3 containment atmospheric temperature system within the scope of the rule as defined by 10 CFR 50.65 (b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that the system was capable of fulfilling its intended function; and failed to demonstrate that the performance or condition of the Unit 3 containment atmospheric temperature system was being effectively controlled through the performance of appropriate preventive maintenance, such that the system remained capable of performing its intended function. The licensee documented the issue in AR 02023116, and classified the temperature elements into 10 CFR 50.65(a)(1) status on February 23, 2015, under AR 02004990. This violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. This issue is identified as NCV 5000250/2015007-01, Failure to Establish a Reasonable Maintenance Effectiveness Demonstration for Unit 3 Containment Atmospheric Temperature System.
b.2 (Opened) Unresolved Item (URI) 5000250, 251/2015007-02, Potential departure from the Eagle 21 design basis
Introduction:
The inspectors identified an Unresolved Item (URI) regarding the licensees compliance with TS and the design bases for the Eagle 21 digital reactor protection system.
Description:
The inspectors reviewed the licensees 10 CFR 50.59 screening associated with the Eagle 21 modifications for the Thermal Over-Power (OPT), Thermal Over-Temperature (OTT) trip functions, and the Main Steam Pressure Lead/Lag module.
These were documented in engineering change packages 246973 for Unit 3 and 246974 for Unit 4. The Eagle 21 was the computerized portion of the reactor protection system.
The inspectors noted that WCAP-12374, Topical Report Eagle-21 Microprocessor-Based Process Protection System, specified design bases compliance with the following:
- IEEE 279-1971, Criteria for Nuclear Power Plant Protection Systems,
- IEEE 603-1980, "IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations,"
- RG 1.153-1985, "Criteria for Power, Instrumentation, and Control Portions of Safety Systems,"
- IEEE 7-4.3.2-1982, "Application Criteria for Programmable Digital Computer Systems In Safety Systems of Nuclear Power Generating Stations," and
- RG 1.152-1985, "Criteria for Programmable Digital Computer System Software in Safety-Related Systems in Nuclear Plants."
Following the extended power uprate (EPU), the licensee determined that the four computerized surveillance tests established to verify the Eagle 21 performance requirements for the (OP & OT) T trips would not pass. The inspectors determined that the licensee changed their procedures to set certain variables to zero in the Eagle 21 computer programs transfer function before performing the surveillance tests. After completing the tests, the licensee re-programmed the zeroed variables to their correct values (the post EPU configurations) before returning the Eagle 21 to service. The inspectors determined that the surveillance tests no longer demonstrated the adequacy of the (OP & OT) T performance requirements or the Eagle 21 final outputs. Because of the inspectors questions, the licensee reevaluated the surveillance testing requirements and captured this issue in AR 2023314, Potential Missed Surveillance on CHs 1, 2 and 3 of Eagle 21. The licensees reevaluation determined that at least one of the tests, the dynamic function surveillance test, could have been performed with the post EPU configuration. In the ARs prompt operability determination, the licensee determined that the surveillance testing changes did not affect plant operability. The inspectors determined that the Eagle 21 design bases required field changes to follow specific design control measures for safety system criteria and computer system requirements including software development, hardware-software integration, computer system validation, and verification. The inspectors could not verify that the licensees Eagle 21 modifications met the specified design bases for the protective functions. The inspectors determined that the licensees failure to perform appropriate surveillance testing of the (OP & OT) T performance requirements as determined by TS was a performance deficiency.
The inspectors opened URI 05000250, 251/2015007-02 to determine if the associated performance deficiency is more than minor. To resolve this URI, the inspectors needs to determine if the design and verification processes used for the modifications met the Eagle 21 design bases requirements in accordance with 10 CFR 50, Appendix B Criterion III. In addition, the inspectors needs to verify the following six items:
- that the as installed (OP & OT) T Eagle 21 configurations were field verified against the design basis from the Updated Final Safety Analysis Report (UFSAR)and TS, in accordance with 10 CFR 50.55a(h)(2), and 10 CFR 50, Appendix B Criterion III,
- that the availability and adequacy of Eagle 21 design bases information was consistent with 10 CFR 50.34(b) and 10 CFR 50.71(e),
- that the Eagle 21 design bases were evaluated in accordance 10 CFR 50.59(c)(2)(i) & (ii),
- the applicability of the licensees commitment to the designed Eagle 21 (OP &
OT) T surveillance testing requirements, trip time response testing,
- that the licensee identified the causes for the failures in the surveillance equipment, and that the licensee can calibrate the equipment to perform the four surveillance tests with post EPU configurations installed in accordance 10 CFR 50, Appendix B Criterion XII, and
- the adequacy of the licensee oversight of Eagle 21 vendor modifications in accordance with 10 CFR 50, Appendix B Criterion VII.
b.3 (Opened) URI 5000251/2015007-03, Required Appendix R Instrumentation Not Functional on Unit 4 Alternate Shutdown Panel
Introduction:
The inspectors identified an URI regarding the processes and procedures used to evaluate the impacts of Appendix R steam generator (S/G) pressure indicators (PIs), when two of three PIs used for the Unit 4 alternate shutdown panel (ASP) 4C264 were designated as non-functional for approximately ten months. Specifically, the lack of the two S/G PIs during a fire event that requires main control evacuation may have adverse impacts on the ability to safely shutdown the plant and the effects of this condition may not have been evaluated.
Description:
The USFAR, Revision C26, Appendix 9.6A, Fire Protection Program Report, Section 5.0, Alternate Shutdown Capability, stated, in part, that instrumentation and controls to achieve and maintain hot standby are provided on the ASP and supplemented by manual actions at local stations for achieving cold shutdown. Table 9.6A-2 in Section 5.0, lists components, instruments, and controls required for alternate shutdown. This table included PI-3(4)-1606/-1607/-1608, S/G pressure for A/B/C respectively.
On January 29, 2015, the inspectors identified there were three ARs/works requests (WRs) on 4-PI-1606 and 4-PI-1607. These were two of the three required Appendix R S/G PIs on the Unit 4 ASP. The ARs were initiated on October 16, 2013; April 24, 2014; and July 13, 2014. At the time of discovery, the licensee did not have compensatory actions in place for this condition.
The licensee captured the inspectors concerns in their corrective action program as AR 02027171, and initiated an apparent cause evaluation. As a result, the licensee performed a calibration check on 4-PI-1607 on February 21, 2015, under work order (WO) 40316782-01 and identified that the surveillance was satisfactory. In addition, they performed corrective maintenance on 4-PI-1606 on February 25, 2015, under WO 40262270-02 and returned the PI to functional status.
Based upon the two non-functional S/G PIs on Unit 4 ASP for approximately ten months, the inspectors requested additional information, including the completed apparent cause evaluation, to determine if the licensee followed their processes and procedures required for Appendix R equipment. This issue is unresolved pending further licensee analysis to resolve the issue and to determine if a performance deficiency exists. This issue is identified as URI 5000251/2015007-02, Required Appendix R Instrumentation Not Functional on Unit 4 Alternate Shutdown Panel.
4OA6 Meetings, Including Exit
On February 6, 2015, the team presented inspection results to Mr. Mike Kiley and other members of the licensees staff. On February 23, the team re-exited the inspection results with Mr. Mike Kiley and members of the licensees staff. The team verified that any proprietary information retained by the inspectors in order to resolve any violations or unresolved items would be disposed of properly upon resolution of the issues.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- D. Agrait, Mechanical Design Engineer
- K. Arsenault, ISI/NDE Coordinator
- A. Baez, System Engineer
- P. Barnes, Design Engineering Supervisor
- A. Carrasquillo, System Engineer
- P. Czaya, Licensing
- A. DeLeon, Engineering
- J. Goad, Mechanical Design Engineer
- M. Guth, Supervisor Licensing
- C. Johnson, Civil/Mechanical Design Supervisor
- R. Leavitt, Electrical Design Engineer
- R. Montolvo, Design Engineer
- C. OFarrill, Nuclear Fuel Manager
- A. Rameriez, System Engineer
- K. Remington, Maintenance Rule Coordinator
- A. Restrepo, PRA Engineer
S. Roberson FPL E I&C Supervisor
- S. Scroggs, Senior Director of Development
- S. Shafer, Operations Shift Manager
- R. Smith, System Engineer
B. Stamp FPL Ops Director
- D. Synder, Fleet BACC Program Owner
- B. Tomanto, Engineering
- T. Wendeln, Simulator Instructor
NRC personnel
Branch
- M. Endress, Resident Inspector, Turkey Point
- T. Hoeg, Senior Resident Inspector, Turkey Point
Branch 3
- A. Sallman, Senior Reactor Systems Engineer, NRR
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
- 05000250/2015007-01 NCV Failure to Establish a Reasonable Maintenance Effectiveness Demonstration for the Unit 3 Containment Atmospheric Temperature System Used in EOPs [Section 1.b.1]
Opened
- 05000250, 251/2015007-02 URI Potential Departure From the Eagle 21 Design Basis [Section 1.b.2]
- 0500025251/2015007-03 URI Required Appendix R Instrumentation Not Functional on Unit 4 Alternate Shutdown Panel
[Section 1.b.3]