Text

Official Exhibit - NRC-025-00-BD01 - Florida Power and Light, Root Cause Evaluation for CR Number 1979235, Canal Temperature Exceeded 100 Degrees F (Nov. 21, 2014) (ADAMS Accession No. ML15128A656)
	ML16015A371
Person / Time
Site:	Turkey Point
Issue date:	11/21/2014
From:	; NRC/OGC
To:	; Atomic Safety and Licensing Board Panel
	SECY RAS
References
	50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, RAS 28493
	Download: ML16015A371 (43)
	v • d • e

NRC-025 Submitted Nov. 10, 2015 TurkeyPointLANPEm Resource From: Hoeg, Tim Sent: Friday, November 21, 2014 8:23 AM To: Sandal, Shane Cc: Klett, Audrey; Endress, Matthew

Subject:

FW: Canal Chemistry INPO team presentation Attachments: RCE 1979256 Canal.pdf; TP Cooling Canal.docx FYI. Additional info provided by FPL regarding UHS. I thought you might be interested.

Tim Hoeg United States Nuclear Regulatory Commission Official Hearing Exhibit Senior Resident Inspector In the Matter of: FLORIDA POWER & LIGHT COMPANY Region II, Division of Reactor Projects (Turkey Point Nuclear Generating, Units 3 and 4)

U.S. Nuclear Regulatory Commission ASLBP #: 15-935-02-LA-BD01 Docket #: 05000250 & 05000251 Exhibit #: NRC-025-00-BD01 Identified: 1/4/2016 Turkey Point Nuclear Station Office: 305-245-7669 Admitted: 1/4/2016 Withdrawn:

9760 SW 344th ST. Fax: 305-247-0224 Rejected: Stricken:

Homestead, FL 33035 Other:

From: Tomonto, Bob [1]

Sent: Friday, November 21, 2014 8:12 AM To: Hoeg, Tim; Endress, Matthew

Subject:

FW: Canal Chemistry INPO team presentation From: Scroggs, Steven Sent: Friday, November 21, 2014 8:09 AM To: Tomonto, Bob

Subject:

FW: Canal Chemistry INPO team presentation Best Regards, Steve O: 561-694-5051 Please consider the environment before printing this email From: Barnes, Philip R Sent: Wednesday, November 19, 2014 12:53 PM To: Mowbray, Michael; Rios, Nelayne; Scroggs, Steven Cc: Shafer, Sam; Conboy, Thomas; Domingos, Christopher; Alvarez, Jose

Subject:

Canal Chemistry INPO team presentation The Chemistry evaluator will be presenting the canal root cause evaluation (attached) to the entire INPO evaluation team tomorrow. Also attached are his notes, taken mostly from the root cause, with some additional information added. I would encourage each of you to make sure you read this write-up and read the root cause before speaking with INPO so you understand what has already been said. We did a lot of good work in response to the canal issues and are continuing to do a lot of good work, but it is definitely in the correction mode. The root cause is focused on the lack 1

of prevention & detection. The Chemistry evaluator is focusing on questioning why Chemistry Department didnt have controls in place to detect this sooner. The Gap Focus Area is in CY.2 Chemistry Controls. Ive pasted the PO&C below for convenience.

Phil PERFORMANCE OBJECTIVE (CY.2)

Chemistry personnel maintain proper chemistry conditions during all phases of plant operations.

CRITERIA

1. Chemistry personnel proactively monitor, evaluate, and trend chemistry results to control chemistry parameters within a technically defined range and take actions to prevent or minimize the ingress of contaminants.

2. Chemistry personnel promptly communicate recommendations to resolve adverse chemistry trends, anomalous conditions, and out-of-specification parameters.

3. Chemistry personnel control makeup water closely to ensure it is consistently of high quality.

4. Chemistry personnel maintain and use off-normal procedures to address abnormal conditions and have contingency plans for minimizing chemistry excursions and restoring plant systems to normal operating conditions.

5. Chemistry personnel evaluate diesel fuel oil conditions to ensure a high quality of fuel oil is maintained during normal and accident conditions.

6. Chemistry personnel monitor specific parameters to validate that intended cooling water treatment is effective.

Philip R Barnes Design Engineering Manager Turkey Point Nuclear Plant 305-246-6820 (w) 305-219-8157 (c) philip.r.barnes@fpl.com 2

Hearing Identifier: TurkeyPoint_LA_NonPublic Email Number: 52 Mail Envelope Properties (E4001ACB4EB7EE4394ABF252F664CA6A175844A9FB)

Subject:

FW: Canal Chemistry INPO team presentation Sent Date: 11/21/2014 8:22:46 AM Received Date: 11/21/2014 8:22:59 AM From: Hoeg, Tim Created By: Tim.Hoeg@nrc.gov Recipients:

"Klett, Audrey" <Audrey.Klett@nrc.gov>

Tracking Status: None "Endress, Matthew" <Matthew.Endress@nrc.gov>

Tracking Status: None "Sandal, Shane" <Shane.Sandal@nrc.gov>

Tracking Status: None Post Office: R2CLSTR01.nrc.gov Files Size Date & Time MESSAGE 3412 11/21/2014 8:22:59 AM RCE 1979256 Canal.pdf 385832 TP Cooling Canal.docx 630670 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Turkey Point Canal Temperature Exceeded 100 degrees F.

Event Date:

CR Number: 1979256 Root Cause Team Name Dept/Group Management Sponsor Jose Alvarez PID Team Leader / RCE Juan Cuan PID Evaluator Team Members Luis Reyes-Trujillo Operations Olga Hanek Licensing Mike Mowbray Engineering Root Cause Evaluator: Date:

Print/Sign Management Sponsor: Date:

Print/Sign MRC Chair: Date:

Print/Sign Electronic Signature may be obtained by assigning actions in NAMS.

Refer to PI-AA-202-1000 for details.

The root cause process is designed to be self critical to drive improvement. As such, specific organizational and/or programmatic causes within the plants span of control are identified. The root cause process determines a functional cause and not a legal or contractual cause.

PI-AA-100-1005-F01, Revision 6 Page 1

1.0 Executive Summary On July 20, 2014 at 1452 , Turkey Point Units 3 and 4 entered the Action for Technical Specification (TS) 3.7.4, Ultimate Heat Sink (UHS) which requires both units to be placed in Hot Standby within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The action was entered because the UHS temperature exceeded the limit of 100 degrees Fahrenheit (F) due to a natural event. This event was reported to the NRC in accordance with 10 CFR 50.72(b)(3)(v)(B) because UHS capability to remove residual heat was impacted. At 1800 the NRC verbally approved a natural event Notice of Enforcement Discretion (NOED) which increased the ultimate heat sink temperature from 100 degrees F to 103 degrees F and prevented the shutdown of both units.

During 2014, 0-ONOP-.011.1 (Intake Canal Low Level or High Temperature) was entered 22 times prior to the event. The first entry was on June 7, 2014 with a maximum temperature of 96.11 degrees F. The last entry occurred on July 19, 2014 at 1655 with a temperature of 99.7 degrees F culminating in the event being evaluated.

This root cause was chartered to understand the organizational drivers of this event as opposed to the actual technical or scientific causes of the rise in cooling canal water temperature.

Through its investigation the root cause team determined that the organization has not recognized signals that would indicate a need for further investigation of the Cooling Canal System (CCS), or are have not been monitoring key factors that should be been used to assess the CCSs ability to meet its mission as the UHS.

These examples are:

x Monitoring cooling canal water temperature and acting on rising canal water temperatures - Average canal temperatures have shown periodic all-time highs over the last 5 years; however, the all-time highs have been consistent since September 2013 through today.

x Monitoring cooling canal Level (volume of water) and acting on reduced water levels x Algae concentrations are not being measure or tracked on an ongoing bases x Other cooling canal water parameters were not being used to assess the health of the CCS (Example Salinity)

PI-AA-100-1005-F01, Revision 6 Page 2

Root Cause:

Lack of a Program that monitors the overall health of the CCS and its impact on the plants ability to meet Technical Specification 3/4.7.4, Ultimate Heat Sink requirements.

CAPR:

Establish and implement a Program evaluates the condition of the Cooling Canal System and determines if it is capable of meeting the Technical Specification 3/4.7.4, Ultimate Heat Sink requirements through the following CAPR actions:

x Create and implement Program Charter that periodically evaluates the condition of the Cooling Canal System and determine if it is capable of meeting Technical Specification 3/4.7/4, Ultimate Heat Sink requirements.

x Assign muti-discipline membership x Proceduralize Charter PI-AA-100-1005-F01, Revision 6 Page 3

2.0 Report

1. Event Description The Cooling Canal System (CCS) serves as the Ultimate Heat Sink (UHS) for the two fossil units (Units 1 and 2) and the two nuclear units (Units 3 and 4). The CCS/UHS temperature is monitored every shift by a reading that is taken at TI-3-3605 and TI-4-3605. Additional monitoring can also be provided by using TE-6907 (Sea Water to TPCW Heat Exchanger).

0-ONOP-011.1, Intake Canal Low Level or High Temperature, is entered whenever UHS temperature exceeds 96 degrees F per Attachment 2 of the procedure. This portion of the procedure has been in effect since 2009.

Data available from PI Process Book for the TI-3/4-3605 Temperatures shows that we have entered the 0-ONOP-011.1 as follows:

During 2009, 0-ONOP-.011.1 was not entered, but data was only available for November and December.

During 2010, 0-ONOP-.011.1 was entered 7 times. The maximum indicated temperature was 97.23 degrees F.

During 2011, 0-ONOP-.011.1 was entered once. The maximum indicated temperature was96.17 degrees F.

During 2012, 0-ONOP-.011.1 was not entered. The maximum indicated temperature was 95.5 degrees F.

During 2013, 0-ONOP-.011.1 was entered once. The maximum indicated temperature was 96.16 degrees F. (This is with both Units 3 and 4 operating after EPU modifications completed)

During 2014, 0-ONOP-.011.1 was entered 22 times prior to the event. The first entry was on June 7, 2014 with a maximum indicated temperature was 96.11 degrees F. The last entry occurred on July 19, 2014 at 1655 with a temperature of 99.7 degrees F culminating in the event below.

PI-AA-100-1005-F01, Revision 6 Page 4

On July 20, 2014 at 1452, Turkey Point Units 3 and 4 entered the Action for Technical Specification (TS) 3.7.4, Ultimate Heat Sink which requires both units to be placed in Hot Standby within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and Cold Shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The action was entered because UHS temperature exceeded the limit of 100 degrees F due to a natural event. This event was reported to the NRC in accordance with 10 CFR 50.72(b)(3)(v)(B) because UHS capability to remove residual heat was impacted. At 1800 the NRC verbally approved a natural event Notice of Enforcement Discretion (NOED) which allows the ultimate heat sink temp to exceed 100 degrees F up to 103 degrees F and prevented the shutdown of both units. The event description is augmented by events surrounding the condition of the CCS and not just the temperature aspect. An assumption was made that other conditions in the system may affect temperature.

A search of the Corrective Action Program (CAP) identified multiple Action Requests (ARs) documenting other issues related to the CCS and changes in the CCS conditions. The following provides a summary of the issue and the related disposition.

7/18/2009 (AR 00467529)

Issue: No guidance exists on how to handle elevated Ultimate Heat Sink Temperatures.

Result: 0-ONOP-011.1 was revised to provide guidance for actions to be taken when UHS temperature exceeds 96 degrees F. The guidance was based on the EPU Cooling Canal System Modeling Report dated January 13, 2008, from Golder Associates, as a basis.

2/1/2012 (AR 01730294)

Issue: During Diving Inspections visibility at intake structure virtually zero.

Result: Walk down of areas performed by Land Utilization and cited silt in the water was causing poor visibility due to high wind and recent rain fall.

7/10/2012 (AR 01783358)

Issue: Reports cooling canal system water quality poor for some time and mentions scarcity of fish and crocodile sighting.

Result: Evaluation concluded that Turkey Point is in full compliance of Industrial Waste Water (IWW) permit FL0001562.

8/6/2012 (no AR found):

Issue: Algae bloom occurred, 682,873 Cell/ml.

PI-AA-100-1005-F01, Revision 6 Page 5

Results: Monitoring showed algae count decreased to 309,311 Cells/ml on 9/18/2012, no further action or readings taken till 4/24/2014.

4/23/2014 (AR 01960954)

Issue: Water consistency in the canal may be contributing to poor heat exchanger performance.

Result: Algae, caused by elevated Condensate dissolved Oxygen has resulted in increased hydrazine consumption. Hydrazine thermally decomposes to ammonia, which is released to the canal system and becomes a nutrient for the algae.

5/2/2014 (AR 01963338)

Issue: Cooling canal salinity highest since 2010 based on quarterly environmental monitoring program.

Result: Prompt Operability Determination (POD) performed, centered on effects to heat exchangers and decrease in maximum allowable ICW temperature.

5/15/2014 (AR 01966207)

Issue: Requests evaluation of online risk analysis based on degraded cooling canal condition.

Results: Routine Work Assignment created (open status) to consider suggested improvements to online risk analysis.

6/24/2014 at 1810 Issue: Ultimate Heat Sink temperature at 98.31 Degrees F.

Results: Notified Systems to reduce load by 200 MWe on Unit 1, which was completed at 1941.

6/25/2014 (AR 01974347)

Issue: 0-ONOP-011.1 Intake Canal High Temperature procedure was created pre-EPU conditions. Since EPU the thermal output from Units 2, 3, and 4 has changed and warrants a reassessment to direct actions to reflect current plant conditions PI-AA-100-1005-F01, Revision 6 Page 6

Results: Several modifications to this procedure were made under PCRs 1974593/1974463, with additional modifications to be completed following revision of the associated technical specification which revised the UHS temperature limit to 104 degrees F permanently. (Only deals with load reduction) 6/27/104 (AR 01975112)

Issue: Emergency project to implement EC 281963: chemically treat the cooling canal system for elevated algae.

Result: Chemical addition started, algae concentration has decreased from 1,876,961 (cells/ml) to 1,270,000. This is above 9/18/2012 reading of 309,311.

7/14/2014 (AR 01978076)

Issue: Correlation of unit generation to Ultimate Heat Sink temperature questioned.

Result: Ultimate Heat Sink temperature changes were observed to not correlate strongly with MW loading. This condition is the subject of a company-wide mitigation effort, no AR referenced. (Condition Evaluation completed on 8/8/2014)

2. Problem Statement Ultimate Heat Sink Temperature exceeded 100 deg. F Technical Specification 3/4.7.4 limit. This caught the organization by surprise and constitutes a violation of TS 3/4.7.4 and resulted in a Licensee Event Report.

3. Analysis A. Analysis Methodology A Fault Tree analysis chart was used to identify factors that affect canal heating and cooling. A support refute matrix was used to summarize results of findings for various factors identified.

PI-AA-100-1005-F01, Revision 6 Page 7

Based on the Fault Tree analysis we examined the following available parameters and attempted to determine if they could have been triggers for further evaluation of the condition of the cooling canal system to meet UHS requirements:

x Plant Generation (thermal load to CCS/UHS) x Canal Level x Algae x Salinity B. Plant Generation The CCS was designed and built to support generation cooling for Units 1, 2, 3 and 4. The CCS is the UHS for the nuclear units, Units 3 and 4. Original Megawatt (MW) generation for the site was 400 MW each for Units 1 & 2 and 600 MW each for Units 3 & 4. Technical Specification 3/4.7.4, Ultimate Heat Sink was added to the Turkey Point Units 3 and 4 Technical Specifications in August 1990. TS 3/4.7.4 Limiting Condition of Operation limits the UHS average supply water temperature (from cooling canals) to less than or equal to 100 degrees F. Several changes have occurred since implementation of TS 3/4.7.4. The nuclear units were upgraded in 1996 and again in 2012-2013. Current generation capability is Unit 1 400 MW, and Units 3 and 4 835 MW each. Exceeding the UHS limit had not occurred in the sites history until the event under investigation.

TS 3/4.7.4 UHS compliance is monitored based on temperature readings from (ESOMS ICW Temperature) TI-3-3605 and TI-4-3605 which are taken every shift during Operator Rounds. UHS temperatures can also be measured from TE-*-6907 which provides more continuous data and is consistent with the data from TI-3-3605 and TI-4-3605. The following UHS Canal Historical Temperature is based on information from the TE-*-6907.

PI-AA-100-1005-F01, Revision 6 Page 8

Monthly Average Canal Temperature Year\Month 1 2 3 4 5 6 7 8 9 10 11 12 2008 81.1 85.4 89.0 90.8 90.2 87.1 83.3 76.8 76.1 2009 74.8 74.2 77.0 80.6 85.8 89.6 91.8 91.7 89.6 87.0 78.8 77.0 2010 69.2 71.5 74.1 80.5 87.6 92.3 90.7 92.3 88.2 82.1 77.4 67.7 2011 73.4 78.4 78.6 84.2 85.7 88.0 91.1 91.8 90.5 82.3 79.1 76.9 2012 75.2 78.3 78.8 80.5 78.8 85.5 90.1 89.9 88.8 84.3 75.2 75.6 2013 76.5 76.3 73.9 83.5 85.8 90.6 90.6 92.3 91.6 88.0 82.4 82.1 2014 77.8 85.4 84.7 89.1 89.5 93.8 95.5 Several factors that should be taken into consideration when reviewing the historical canal temperature data include:

On December 28, 2010 generation was stopped on Unit 2 reducing the cooling burden on the CCS.

From February 26, 2012 to September 5, 2012 Unit 3 was not generating power due to an Extended Power Upgrade (EPU) refueling outage. This temporarily reduced the cooling burden on the Cooling Canal System.

PI-AA-100-1005-F01, Revision 6 Page 9

From November 5, 2012 to April 17, 2013 Unit 4 was not generating power due to an EPU refueling outage. This reduced the cooling burden on the CCS.

Historically a general guidance has existed that a reduction in 200 MW equates to a 1 degree F reduction in CCS/UHS temperature. This was supported by an evaluation that was performed as to the impact of the EPU modifications on cooling canal temperatures (we would only see about a one degree F increase). From the above information you would have expected to have a corresponding decrease in overall temperature after the shutdown of Unit 2 and during the long EPU outages, but that is not the case, especially during the months of July, August and September.

The TE-*-6907 temperatures were used to calculate a historical monthly average CCS/UHS temperature from 2008 through 2014. The monthly average temperatures have shown periodic all-time highs over the last 5 years; however, the all-time highs have been consistent since September 2013 through July 2014. . Although all-time high temperatures may occur occasionally, the monthly all-time high record CCS/UHS temperatures since September 2013 should have triggered an investigation.

Assessment: Based on the information above, the thermal heat load from plant operations may have a short term effect (based on 1 degree F per 200 MW) on the canal temperature and not a long term effect.

This was also identified in AR 0197876 originated on 7/14/2014.

Monthly average temperatures started to show periodic all-time highs over the last 5 years and consistently increasing beginning with September 2013 and continuing through July 2014. Although all-time highs may occur occasionally, the monthly all-time high record CCS/UHS temperatures trend since September 2013 should have triggered an investigation.

C. Canal Level The extent to which canal level is monitored and enters into the plants operational scope is strictly based on its effect on the pumps taking suction at the intake structure. From this stand point, 0-ONOP-011.1 (Intake Canal Low Level or High Temperature) illustrates this perspective with the following note:

PI-AA-100-1005-F01, Revision 6 Page 10

The monitoring of canal level is based on, but not limited to, the Auxiliary Operator Rounds Module. Once per day the Operator records this information and the first trigger point for attention is a reading greater than 18 feet. This reading is the distance from the bottom of the grating at the intake structure to the water level at the intake. Entry into the pertaining ONOP is not until 199 or per Shift Managers discretion. Land Utilization also takes readings on canal level at certain points throughout the canal system; this data, however, is not available for action plans to mitigate canal abnormalities for Control Room Operation of the Plant. (Data from land Utilization could be useful here)

Other data systems used to monitor plant parameters (referring to Pi) also do not have a quick access link to canal level data.

A search into the Narrative logs Module for 0-ONOP-011.1 in conjunction with canal level gives 69 search hits from the time period of 2004 until present time. Only 5 of these entries pertain to canal level and all predate 2008. These entries in their majority concern themselves with suction to the screen wash pumps.

The data below was taken from a monitoring station in the middle of the Turkey Point cooling canal system. It shows that rain fall for 2014 has been very low, and that the canal water level is also low. This data is currently being captured to satisfy South Florida Water Management District required the implementation of a Groundwater, Surface Water and Ecological Monitoring Plan (GSWEMP). This could have been used as a trigger that conditions have changed that could have impact on the Ultimate Heat sink.

Canal Level Relative to NAVD88 Year Rain Fall (inches)

(feet) 2011 52 Not available.

2012 74.2 -0.47 2013 19.6 -0.65 2014 4 -0.88 PI-AA-100-1005-F01, Revision 6 Page 11

Assessment:

Canal level data and mitigating strategies present at Turkey Point are based on Intake Cooling Water (ICW) pump needs and reporting requirements. Currently, no data are used for prognostication of a potential negative correlation between canal level and UHS temperature.

D. Algae This is not a parameter that was measured on a continuing basis. The first measurements of algae were taken in August of 2012 after AR 1783358 was written questioning the quality of the CCS water. The AR evaluation concluded that Turkey Point was in full compliance of IWW permit FL0001562. A subsequent sample was taken in September of 2012. No other measurements were taken until April 2014 in response to AR 01960954 when an algae bloom was observed. AR1960954 investigated the contribution of the observed CCS biological fouling on the CCW heat exchanger tubes. The investigation found that the CCS is a living marine ecosystem containing numerous species of algae.

The evaluation centered on the cause of the algae and no analysis was performed on any perceivable impact on the CCS to dissipate the heat.

The following chart plots CCS algae concentration vs the temperature of the canal at the intake. This does not show a strong correlation between algae concentration and canal temperature, although both parameters have been shown to have an impact on heat exchanger performance.

Assessment:

PI-AA-100-1005-F01, Revision 6 Page 12

The investigation in response to the observed high level of algae was centered on the cause of the high algae concentration and the corrective actions necessary to eliminate the algae, but could have triggered an analysis on the health of the CCS and its ability to meet the Ultimate Heat Sink requirements.

E. Other Cooling Canal Parameters The CCS/UHS is a closed loop canal system fed by groundwater flow from the underlying shallow aquifer. The canal system is fed primarily by rainfall and groundwater from the Biscayne aquifer, which consists of saline water flowing west from Biscayne Bay and fresh water flowing east from the Everglades. The water quality and water level in the CCS is affected by the interaction between the external groundwater from the vicinity and the CCS water.

For most of its operating history, monitoring of the CCS was limited to that required by the National Pollutant Discharge Elimination System (NPDES) permit. In accordance with the NPDES, the following information is required to be collected:

Monitoring Requirements Monitoring Requirements OUI-1* OUI-2**

Parameters Monitoring Sample Type Monitoring Sample (units) Frequency Frequency Type Temperature (F), Monthly Instantaneous N/A N/A Water Solids, Total Quarterly Grab Semiannually Grab Suspended (MG.L) pH (SU) Quarterly Grab Monthly Grab Salinity (PPT) Quarterly Grab N/A N/A Specific Quarterly Grab Quarterly Grab Conductance (UHMO/CM)

Copper, Total Semiannually Grab Semiannually Grab Recoverable (UG/L)

Iron, Total Semiannually Grab N/A N/A Recoverable (MG/L)

Zinc, Total Semiannually Grab Semiannually Grab Recoverable(UG/L)

Lead, Total N/A N/A Semiannually Grab Recoverable 9UG/L)

Oil and Grease N/A N/A Semiannually Grab (MG/L)

Sample Point OUI-1: Cooling water discharge prior to entering the feeder canal within the closed loop CCS.

PI-AA-100-1005-F01, Revision 6 Page 13

- Sample Point OUI-2: Discharge from the two solids settling basins or neutralization basin prior to mixing with water in the closed loop CCS.

In addition to the NDPES required data, a 1983 agreement between FPL and the South Florida Water Management District defined a groundwater monitoring program and interceptor ditch operation requirements. The groundwater monitoring program requires monitoring of multiple wells four times per year. The data collected includes: 1) ground elevation (feet), 2) surface water elevation, 3) conductivity and temperature (measured at one foot intervals for the total well depth), 4) two water samples per well for chloride content.

As a result of the Turkey Point EPU Project, the South Florida Water Management District required the implementation of a Groundwater, Surface Water and Ecological Monitoring Plan (GSWEMP). The purpose of the GSWEMP is to track the movement of salt water into the freshwater aquifers along the coastal United States. The GSWEMP requires monitoring 48 parameters related to water quality, water level/flow and biology parameters both inside and outside the CCS.

Water quality monitoring data includes temperature, water level, specific capacity, pH, Dissolved Oxygen (DO), Biological Oxygen Demand (BOD), and salinity. A total of 75 water quality sample locations with quarterly sampling requirements are part of the GSWEMP. In addition, continuous monitoring equipment was installed in July 2010 to monitor temperature, specific conductance, and water level collecting over 12,000 data points daily.

Historically, monitoring of the CCS has been performed to meet the requirements of the NDPES, the groundwater monitoring program and most recently, the GSWEMP. CCS conditions and the effects of all the measured parameters on the CCS performance as the UHS of the nuclear plants has not been analyzed.

One of the other cooling canal monitoring parameters that could be used to determine the health of the Ultimate Heat Sink is salinity. The CCS water salinity is considered a hyper saline environment with salinities greater than 35 g/L, the salinity for seawater. Based on data available, the CCS salinity has increased greatly over the years of operation. Within the past 10 years, salinity in the CCS has ranged between 42 and 69 g/L. However, salinity levels have greatly increased above the 69 g/L since December 2013 with an observed salinity of 85 g/L in August 2014. The increased CCS temperatures lead to an increased rate of evaporation, leaving dissolved solids behind and increasing the CCS salinity.

PI-AA-100-1005-F01, Revision 6 Page 14

This was another parameter that could have triggered an investigation regarding changing CCS conditions.

Assessment:

CCS parameters are being measured to satisfy environmental requirements. However, analysis of the CCS parameters available has not been performed to anticipate changes in CCS conditions and its ability to meet the UHS requirements. As an example, one of the parameters monitored is salinity. As previously discussed, salinity has greatly increased since September 2013 and it could possibly be used as a surrogate to canal volume/level since higher than normal salinity concentrations is most likely a result of high evaporation levels with low fresh water replenishment from rainfall and the Floridian aquifer.

There was no attempt made to correlate the increasing salinity levels to CCS/UHS performance.

PI-AA-100-1005-F01, Revision 6 Page 15

F. Summary Causal Discussion Support/Refute Conclusion Factor Plant Plant Supported Generation generation While the plants thermal outputs are a Currently the only causes thermal contributor to the CCS temperature, they are tie of UHS output to the not the main driver. This can be seen in the temperature to Cooling Canal Canal Historical Temperature graph in section generation only System (CCS). 3.B. showing wide variation between summer exists in 0-ONOP-As the amount months and winter months. In addition AR 011.1 where UHS of generation 1978076 questioned the correlation of unit temperature limits increases so generation to Ultimate Heat Sink temperature exist and action does the intake since temperature kept rising while one of the guidance provided.

temperature. nuclear units was at 50% and the fossil units not generating. No Program Though thermal output may not be a main correlates driver, the monitoring of thermal output to generation output UHS temperature could have been used as a to UHS trigger to further investigate why the temperature as an correlation was different from the expected, indication of especially during the winter months CCS/UHShealth/

(November and December 2013) when UHS performance.

temperatures were above normal. This is evidenced in the Monthly Average Canal Temperature chart in section 3.B.

Canal The level of Supported No Program Level water in the Canal level is measured by Operations to monitors the CCS canal affects assure that sufficient amount of water exists to level and how that the volume support plant operations. affects the CCS available for Land utilization measures canal level at UHS capability.

cooling, the less several points along the CCS, this data is used volume the less for reporting purposes only.

time it takes to circulate around the CCS. This lessens the time to dissipate stored heat.

Algae The amount of Supported No Program algae in the Algae is not a parameter that was being monitors the algae CCS has a monitored on a regular basis, this does not level and how that direct impact exists as a parameter for decision making nor affects the CCS on heat is it required for reporting needs. However UHS capability.

exchanger its presence does impact the water quality, PI-AA-100-1005-F01, Revision 6 Page 16

efficiency. which can be seen visually, and usually There is a belief appears when water temperatures are high and that the algae there is a lack of fresh water. This should also affects have been an indication that the CCS is not CCS experiencing normal environmental temperature due conditions.

to the darkening of the water, thus absorbing more heat and increasing mass thus retaining more heat.

Other CCS There are other Supported No Program Parameters CCS For most of its operating history, monitoring monitors salinity parameters that of the CCS was performed by Land level and how that could be used Utilization and limited to that required by the affects the CCS to further National Pollutant Discharge Elimination UHS capability.

determine the System (NPDES) permit.

health of the One of the parameters monitored is salinity.

system. Salinity could be used as a surrogate to canal volume/level since higher than normal concentrations is most likely a result of high evaporation levels with low fresh water replenishment such as rainfall. Thus affecting available water and increasing flow lessening cooling time of the CCS water.

PI-AA-100-1005-F01, Revision 6 Page 17

G.

Conclusion:

Engineering is responsible for CCW and TPCW systems performance. CCS temperature, salinity, turbidity and specific heat are variables that contribute to CCW and TPCW performance. Land Utilization is responsible for performing CCS maintenance to ensure plant operation is not impacted. Land Utilization is also responsible for the collection and reporting of data required by the environmental permits. Operations monitors UHS temperature but only to determine if we are operationally within the technical specification limits. They also monitor intake level but only view this as a requirement for proper pump performance. There is no single owner or system engineer that is responsible for analyzing all the parameters affecting CCS performance as it pertains to UHS requirements. Nuclear Oversight does not routinely perform evaluations on the canal system but it is being considered under AR 192493 -06.

Based on information above the Root Cause of this event is -

Lack of a Program that monitors the overall health of the CCS and its impact on the plants ability to meet Technical Specification 3/4.7.4, Ultimate Heat Sink requirements.

4. Causal Factor Categorization A. Address each category - People, Programmatic, Organizational and Equipment based on the analysis.

(1) People: No human performance deficiencies were found during this analysis.

(2) Programmatic: The Root Cause ties to Insufficient Program Details: This occurs when a program is vague regarding what is required in a particular situation, or does not address specific aspects of program implementation, monitoring, or evaluation.

PI-AA-100-1005-F01, Revision 6 Page 18

(3) Organizational: The Root Cause ties to Poor Program Evaluation Process: This area is very similar to the program monitoring/ management. This area is reactive, in that a program failure occurs before action is taken. (insufficient program design).

(4) Equipment: No equipment deficiencies were found during this analysis.

5. Evaluation Attributes Causal Factor Characterization (Each causal factor identified is listed and classified in the appropriate People, Programmatic, Organizational and Equipment categories.)

Cause Type Cause Statement Category Root Cause (RC1) Lack of a Program that monitors the Programmatic/Organizational overall health of the CCS and its impact on the plants ability to meet Technical Specification 3/4.7.4, Ultimate Heat Sink requirements.

A. Previous Occurrences Review of temperatures going back to late 2009 does not show the Cooling Canal System reaching the 100 Degree F threshold prior to this event.

B. Extent of Condition The condition is where we exceeded Technical Specification 3/4.7.4, Ultimate Heat Sink requirements. The CCS is the Ultimate Heat Sink for both nuclear units. The only other Technical specification that is similar to the UHS would be containment temperature. This is currently being monitored and the components that drive containment temperature, CCW and Containment Cooling, are continuously monitored.

No further actions needed.

C. Extent of Cause The root cause for this evaluation is:

PI-AA-100-1005-F01, Revision 6 Page 19

Lack of a Program that monitors the overall health of the CCS and its impact on the plants ability of meeting Technical Specification 3/4.7.4, Ultimate Heat Sink requirements.

This cause could apply to containment temperature, which is not a system. But the factors that affect containment temperature have programs that monitor them closely. This would be Component Cooling and Containment Cooling.

No further actions needed.

D. Safety Culture Evaluation The safety culture evaluation is addressed in this report indicating the results of the evaluation and the corresponding corrective actions.

E. Risk/Consequence A narrative describing the actual or potential risk associated with the event from a safety perspective (nuclear, radiological and/or industrial).

6. Operating Experience A search was performed on the INPO database for reports in ICES that contained any of the following with no time frame specified:

x Elevated x Intake x Temperature ICES #244637 On 8/14/201 Bruce Power Units 3 and 4 were operating at high power when intake temperature began to rise causing outfall temperature to approach the Ministry of the Environment (MOE) limit. Both units were derated per procedure within the limits of available reactivity, but the resulting outfall temperature reduction was not sufficient to compensate for the rising intake temperature. Unit 3 was subsequently shut down to avoid exceeding the MOE outfall temperature limit.

Bruce A is located on the shores of Lake Huron, one of the great lakes. Lake Huron (and hence intake) temperature over a typical summer range from 10C to 24C and can change from one to the other over a relatively short time frame, sometimes on the order of hours. Bruce A has a MOE limit on the outfall of 32.2C averaged from midnight to midnight. Response to rising lake PI-AA-100-1005-F01, Revision 6 Page 20

temperature includes curtailing boiler blowdowns and derating units as permitted by the available reactivity.

In the shifts leading to this event, lake temperatures were approximately 21-22C. Late on 13 August 2010, the lake temperature began to rise, eventually reaching 23C. Outfall temperature exceeded the 32.2C limit at 0300 on 14 August 2010 and remained above that limit for the rest of the day.

Both units were derated by 5 percent full power which reduce the outfall temperature, but not sufficiently to reduce the 24hr average temperature below the MOE limit. An Operational Decision Making (ODM) meeting was held and the decision was made to take Unit 3 off line. The resulting reduction the outfall temperature brought the 24hr average outfall temperature to 32.1C which was below the MOE limit.

Assessment:

This event is based on conditions of Lake Huron which is not in the control of the plant, therefore no additional lessons learned for PTN, our procedures already have power reduction as part of actions to be taken.

ICES # 244622 On 08/12/10 at 2050 hours0.0237 days 0.569 hours 0.00339 weeks 7.80025e-4 months , the LaSalle Ultimate Heat Sink exceeded the 101.25oF limit per Technical Specification 3.7.3. LaSalle was in this Required Action for approximately 3 1/2 hours and exited all associated time clocks when the lake cooled. The extremely high lake temperature necessitated load reductions on both units prior to reaching the Technical Specification limit.

Prior to this event, Unit 1 was at 76% power due to a lost steam packing exhauster loop seal while Unit 2 was at 82% Power due to elevated main condenser backpressure.

The Root Cause of the event was the environmental weather conditions for several days preceding the event. Specifically, low wind speed, high air temperature, high humidity, and high intensity of solar radiation negatively affecting normal lake evaporation and diminishing the convective cooling mechanism of the lake.

This event also resulted in a fish impingement that affected the WS system.

This condition caused the WS strainers to experience high differential pressure and a reduced WS supply pressure to both units. As a result, power was lowered to support manual backwashes of the WS strainers.

Consequences: Both the units entered into a 12-hour shutdown action PI-AA-100-1005-F01, Revision 6 Page 21

statement and required action to mitigate the impingement on the WS strainers. This was not an SOER or Level 1 or 2 IER.

Assessment:

This event is based on conditions of their cooling pond, which is in the control of the plant, being impacted by the environment and deemed not preventable. Lessons Learned include the need to have contingency plans for manual operator actions to backwash critical cooling systems' screens and strainers pre-briefed by the crews with pre-established specific trigger points.

This is not a condition that existed at the time of the PTN event.

ICES # 307248 On July 16, 2013, Pilgrim Unit 1 Salt Service Water inlet temperature exceeded 74.9 degrees F as measured by a calibrated instrument taken locally at screenwash discharge. This exceeded the Tech Spec limit for Ultimate Heat Sink temperature resulting in entry into a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months active shutdown LCO. Cause: The apparent cause for entering the shutdown LCO was sustained increased seawater surface temperature due to hot summer weather conditions and the contribution from recirculation of water from the plant's outfall due to wind and tidal conditions. Consequences: Inlet temperatures above 75 degrees F render the salt service water (SSW) system inoperable requiring entry into a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months cold shutdown LCO.

Assessment:

This event is based on environmental conditions and deemed not preventable. No lessons learned for PTN. This was not an SOER or Level 1 or 2 IER.

Conclusion No failure in the OE program was found.

7. Lessons Learned As part of lessons learned, the team found that there were a lot of issues previously identified related to CCS conditions and analysis that had been performed before and after the event. It would have been an advantage to the team if they were provided with a list of contacts of all personnel that had been involved so as to lessen the burden in data gathering.

8. Proof Statement:

PI-AA-100-1005-F01, Revision 6 Page 22

Ultimate Heat Sink is caused by: Lack of a Program that monitors Temperature exceeded the overall health of the CCS 100 deg. F. which is a and its impact on the plants violation of Technical ability of meeting Technical Specifications 3/4.7.4. Specification 3/4.7.4, Ultimate This has resulted in a Heat Sink requirements.

Licensee Event Report.

(Problem Statement) (Root Cause) and is corrected by: Create and implement Program Charter that periodically evaluates the condition of the Cooling Canal System and determine if it is capable to meet Technical Specification 3/4.7/4, Ultimate Heat Sink requirements.

(CAPR)

PI-AA-100-1005-F01, Revision 6 Page 23

9. Corrective Actions Category Causal Statement NAMS Corrective Action / Assignment Assignment Assigned Asgn# Type Dept or /

Individual and Due Date Root Cause(s) Lack of a Program 8 Create and implement Program Charter that CAPR Bertelzon that monitors the periodically evaluates the condition of the 10/30/2014 overall health of the Cooling Canal System and determine if it is CCS and its impact capable of meeting Technical Specification on the plants ability 3/4.7/4, Ultimate Heat Sink requirements.

of meeting Charter membership should be as follows:

Technical Specification Land Utilization - Program Owner (Chair) 3/4.7.4, Ultimate Engineering - Member Heat Sink requirements. Operations - Member Chemistry - Member Meeting frequency to be no less than 4 times a year.

Parameters to be evaluated should be as a minimum those identified in this RCE.

9 Assign person to program Owner CAPR Katz PI-AA-100-1005-F01, Revision 6 Page 24

Category Causal Statement NAMS Corrective Action / Assignment Assignment Assigned Asgn# Type Dept or /

Individual and Due Date 10/15/2014 10 Assign Engineering Member CAPR Domingos 10/15/2014 11 Assign Operations Member CAPR Wayland 10/15/2014 12 Assign Chemistry Member CAPR Rios 10/15/2014 13 Proceduralize Charter CAPR Berttelson 11/30/2014 Extent of none Condition Extent of none Cause PI-AA-100-1005-F01, Revision 6 Page 25

Safety Culture none Evaluation Effectiveness Perform Effectiveness Review in accordance to EFR Cuan Review the plan. This is to be performed 12 months 12/12/2015 after the closure of the last corrective action.

Other PI-AA-100-1005-F01, Revision 6 Page 26

10. Deferral Justification The condition of the canal is currently being evaluated, corrective actions are in place to provide water to the canal system. A license amendment was approved setting the new UHS temperature at 103 Degrees F. so the likelihood of the site exceeding the UHS requirement is low.

11. Effectiveness Review Plan x Review all CAPR and CA to ensure satisfactory completion. Success Criteria is all CAPR and CA correctly implemented.

x Review CR database to identify any LER due to exceeding UHS temperature requirements. Success Criteria is to have none.

12. Attachments x Root Cause Charter x Fault Tree (Attachment B) x Nuclear Safety Culture Evaluation PI-AA-100-1005-F01, Revision 6 Page 27

ROOT CAUSE CHARTER Facility/CR Number: PTN / AR 1979256 (1980468 & 1980469)

Manager Sponsor: Jose Alvarez, Performance Improvement Manager Brief Event

Description:

A 8 hr. Non- Emergency 10CFR50.72(b)(3)(v)(B), RHR Capability Detail Event

Description:

At 1454 on 20 July 2014, Turkey Point Units 3 and 4 entered the Action for Technical Specification (TS) 3.7.4, Ultimate Heat Sink (UHS). The action was entered because UHS temperature exceeded the limit of 100 degrees F due to a natural event. This report is in accordance with 10 CFR 50.72(b)(3)(v)(B) because UHS capability to remove residual heat is impacted. At 1800 the NRC verbally approved a natural event Notice of Enforcement Discretion (NOED) which allows the ultimate heat sink temp to exceed 100 degrees F up to 103 degrees F. Unit power levels have been maintained at Unit 3 100% and Unit 4 95%.

Problem Statement:

Ultimate Heat Sink Temperature exceeded 100 deg. F. which is a shutdown requirement per Technical Specifications 3/4.7.4. This has resulted in a Licensee Event Report.

Investigation Scope and Methodology:

The root cause team will use, but not limited to, the following assessment tools:

x Interviews will be conducted and written documentation reviewed for data gathering x A time line will be developed x Causal Analysis performed using the following o Barrier Analysis / Why Analysis o Event Causal Factor Charting The root cause scope will include:

x Determine the facts leading up to and causing the event x Review written documents associated with the event x Programmatic and organizational factors that influenced behaviors x Nuclear Safety Review Team Members:

Team Leader _Juan Cuan_______, Performance Improvement (Root Cause Evaluator)

Team Member _Mike Mowbray_____________, Engineering Team Member _Luis Reyes_________ ____, Operations Team Member _Olga Hanek _____________, Licensing

Milestones: Date Day Date Assigned Date 7/31/14 0 Status Update Date 8/14/14 14 Draft Report Date 8/25/14 25 Final Report Date 8/30/14 30 Communications Plan:

Sponsor Approval: _____________________ Date: ___________

MRC Approval: _____________________ Date: ___________

ATTACHMENT B Canal Intake Temperature at 100 Deg, F.

Canal Canal Cooling Heating Absorption Absorption of of Long- Plant Rain Wind Flow Short-wave wave Generation radiation radiation Canal

Pumps 1 2 3 4 Level Canal Water Ambient Solar Condition Temperature Index Algae Salinity Conductivity

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 1 of 6)

INTRODUCTION The safety culture evaluation is performed for each root cause evaluation. The safety culture evaluation is also performed for apparent cause evaluation when addressing a NRC finding.

The purpose of a safety culture evaluation is to determine if the organization has a healthy bias towards nuclear plant safety, and demonstrates their commitment to nuclear safety culture as an overriding priority across the Reactor Oversight Program cornerstones of safety. The intent of the evaluation is to ensure the analysis assesses the root cause(s) to the Nuclear Safety Cross-Cutting Aspects and the corresponding corrective actions are aligned to mitigate repetitive events.

The following definitions are provided as an aide to understanding and performing the safety culture evaluation.

Safety Culture: The core values and behaviors resulting from a collective commitment by leaders and individuals to emphasize safety over competing goals to ensure protection of people and the environment.

Cross-Cutting Area: Fundamental performance characteristics that extend across all of the Reactor Oversight Program cornerstones of safety. These areas are human performance (HU), problem identification and resolution (PI&R), and safety conscious work environment (SCWE).

Cross-Cutting Aspect: A performance characteristic that is the most significant contributor to a performance deficiency.

PI-AA-100-1005-F03, Revision 1

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 2 of 6)

PROCESS The Safety culture evaluation should be performed after the analysis has been done, and the root cause(s) have been determined.

1. Evaluate the root cause(s) with respect to the NRC Cross-Cutting Areas to determine if the cause(s) align with one or more of the safety culture cross cutting aspects (i.e., is there a relationship between the cause and the aspect).

2. Using the table below (Nuclear Safety Culture Evaluation Table), document the results of this evaluation.

3. Validate that corrective actions associated with the root cause(s) adequately address any identified relationships. If the existing actions do not adequately address the identified relationship, revise the actions or initiate new actions.

4. Provide a summary of the completed nuclear safety culture evaluation in the root cause report (refer to PI-AA-100-1005 F01). Clearly document the results of the evaluation, include discussion on how the team came to the conclusions of the evaluation, and list any additional actions that were developed or modified as a result of the evaluation.

During the evaluation, consider the following:

From the NRCs perspective, these components and their defining aspects make up the management system" model for commercial nuclear power operation.

x If the root cause(s) identified by the analysis do not line up with any of the checklist aspects, this may be indicative of flaws in the analysis approach or conclusions and warrants further review.

x If there are aspects that appear to be strongly related to facts discussed in the analysis, but they are not aligned with any of the identified root cause(s) this may be indicative of flaws in the analysis approach or conclusions and warrants further review.

PI-AA-100-1005-F03, Revision 1

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 3 of 6)

Nuclear Safety Culture Evaluation Table 06.01 Human Performance (H)

Criteria Comment H.1 Resources: Leaders ensure that personnel, equipment, procedures, and N/A other resources are available and adequate to support nuclear safety (LA.1).

H.2 Field Presence: Leaders are commonly seen in the work areas of the N/A; all permit requirements plant observing, coaching, and reinforcing standards and expectations. have been met. Violation of Deviations from standards and expectations are corrected promptly. UHS TS 3/4.7.4 occurred Senior managers ensure supervisory and management oversight of work when the canal temperature exceeded 100 degrees F.

activities, including contractors and supplemental personnel (LA.2).

H.3 Change Management: Leaders use a systematic process for evaluating N/A and implementing change so that nuclear safety remains the overriding priority (LA.5).

H.4 Teamwork: Individuals and work groups communicate and coordinate There is no Program that their activities within and across organizational boundaries to ensure analyzes all the CCS data nuclear safety is maintained (PA.3). collected per the NPDES and Conditions of Certification.

Engineering is responsible for CCW and TPCW systems performance. UHS temperature, salinity, turbidity and specific heat are variables that contribute to CCW and TPCW performance. The causes of the UHS conditions are not looked at by Engineering.

CCS data is collected by the Environmental JB department for purposes of meeting environmental permit requirements with no acceptance criteria or thresholds requirements. The analysis identified this as the root cause. CAPR requires creation of a comprehensive program with a cross-functional membership to analyze all contributors to CCS UHS performance. The CAPR addresses this issue.

H.5 Work Management: The organization implements a process of N/A; This event was not planning, controlling, and executing work activities such that nuclear caused by a work activity safety is the overriding priority. The work process includes the issue.

identification and management of risk commensurate to the work and the need for coordination with different groups or job activities (WP.1).

H.6 Design Margins: The organization operates and maintains equipment N/A No design margin within design margins. Margins are carefully guarded and changed only exceeded.

through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment (WP.2).

H.7 Documentation: The organization creates and maintains complete, N/A Data collected for accurate and, up-to-date documentation (WP.3). environmental permit requirements is available for analysis.

PI-AA-100-1005-F03, Revision 1

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 4 of 6)

H.8 Procedure Adherence: Individuals follow processes, procedures, and N/A 0-ONOP-011.1 and work instructions (WP.4). permit requirements were met.

H.9 Training: The organization provides training and ensures knowledge N/A transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values (CL.4).

H.10 Bases for Decisions: Leaders ensure that the bases for operational N/A Current 0-ONOP-011.1 and organizational decisions are communicated in a timely manner places decision on NPS who (CO.2). consults with management to implement power reductions as necessary to address UHS temperature concerns.

H.11 Challenge the Unknown: Individuals stop when faced with uncertain N/A conditions. Risks are evaluated and managed before proceeding (QA.2).

H.12 Avoid Complacency: Individuals recognize and plan for the possibility N/A of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools (QA.4).

H.13 Consistent Process: Individuals use a consistent, systematic approach N/A to make decisions. Risk insights are incorporated as appropriate (DM.1).

H.14 Conservative Bias: Individuals use decision making-practices that N/A 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 (DM.2).

PI-AA-100-1005-F03, Revision 1

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 5 of 6) 06.02 Problem Identification and Resolution (P)

Criteria Comment P.1 Identification: The organization implements a corrective action program N/A; Multiple ARs regarding with a low threshold for identifying issues. Individuals identify issues CCS conditions have been completely, accurately, and in a timely manner in accordance with the generated over the past 5 program (PI.1). years P.2 Evaluation: The organization thoroughly evaluates issues to ensure that N/A, evaluations of ARs were resolutions address causes and extent of conditions commensurate with performed appropriately for their safety significance (PI.2). the conditions identified.

P.3 Resolution: The organization takes effective corrective actions to N/A no deficiency in address issues in a timely manner commensurate with their safety corrective actions found.

significance (PI.3).

P.4 Trending: The organization periodically analyzes information from the N/A corrective action program and other assessments in the aggregate to identify programmatic and common cause issues (PI.4).

P.5 Operating Experience: The organization systematically and effectively N/A; the CCS is unique in the collects, evaluates, and implements relevant internal and external industry and there were none operating experience in a timely manner (CL.1). that were SOER or Levelel 1 or 2 IER.

P.6 Self-Assessment: The organization routinely conducts self-critical and N/A objective assessments of its programs and practices (CL.2).

06.03 Safety Conscious Work Environment (S)

Criteria Comment S.1 SCWE Policy: The organization effectively implements a policy that N/A supports individuals rights and responsibilities to raise safety concerns, and does not tolerate harassment, intimidation, retaliation, or discrimination for doing so (RC.1).

S.2 Alternate Process for Raising Concerns: The organization effectively N/A implements a process for raising and resolving concerns that is independent of line management influence. Safety issues may be raised in confidence and are resolved in a timely and effective manner (RC.2).

S.3 Free Flow of Information: Individuals communicate openly and candidly, N/A both up, down, and across the organization and with oversight, audit, and regulatory organizations (CO.3).

PI-AA-100-1005-F03, Revision 1

NUCLEAR SAFETY CULTURE EVALUATION FORM (Page 6 of 6) 06.04 Supplemental Cross-Cutting Aspects (X)

Criteria Comment X.1 Incentives, Sanctions, and Rewards: Leaders ensure incentives, N/A sanctions, and rewards are aligned with nuclear safety policies and reinforce behaviors and outcomes that reflect safety as the overriding priority (LA.3).

X.2 Strategic Commitment to Safety: Leaders ensure plant priorities are N/A aligned to reflect nuclear safety as the overriding priority (LA.4).

X.3 Roles, Responsibilities, and Authorities: Leaders clearly define roles, No comprehensive program responsibilities, and authorities to ensure nuclear safety (LA.6). for CCS UHS exists; there is no single owner responsible for UHS performance.

CAPR addresses this aspect X.4 Constant Examination: Leaders ensure that nuclear safety is constantly N/A scrutinized through a variety of monitoring techniques, including assessments of nuclear safety culture (LA.7).

X.5 Leader Behaviors: Leaders exhibit behaviors that set the standard for N/A safety (LA.8).

X.6 Standards: Individuals understand the importance of adherence to N/A All permit requirements nuclear standards. All levels of the organization exercise accountability and procedures were met for shortfalls in meeting standards (PA.1).

X.7 Job Ownership: Individuals understand and demonstrate personal N/A responsibility for the behaviors and work practices that support nuclear safety (PA.2).

X.8 Benchmarking: The organization learns from other organizations to N/A continuously improve knowledge, skills, and safety performance (CL.3).

X.9 Work Process Communications: Individuals incorporate safety N/A communications in work activities (CO.1).

X.10 Expectations: Leaders frequently communicate and reinforce the N/A expectation that nuclear safety is the organizations overriding priority (CO.4).

X.11 Challenge Assumptions: Individuals challenge assumptions and offer N/A opposing views when they think something is not correct (QA.3).

X.12 Accountability for Decisions: Single-point accountability is maintained N/A 0-ONOP-011.1 placed for nuclear safety decisions (DM.3). responsibility of TS 3.7.4 UHS TS compliance on NPS who consults with plant management.

PI-AA-100-1005-F03, Revision 1

Turkeey Point Plant Evvaluation - 11/20 0/2014 Turkey Point Cooling g Canal Event Description D n -July 20,, 2014 Intake canal low lev vel or high temperaturre ONOP wasw entered d 22 times during d a sixx-week pe eriod culminnating with entering Te ech Spec fo or ultimate heat h sink (U UHS) which h requiress both units be placed in hot stand dby with 122 hours0.00141 days 0.0339 hours 2.017196e-4 weeks 4.6421e-5 months . A NOED wass verbally given from thee NRC whic ch increased d the UHS temperaturre limit from m 100 degre ees to 103 degreess.

Junee 7, 2014 ONOP enterred with a maximum m te emperature of 96.11 de egrees

July 19, 2014 ONOP O enterred with a maximum m te emperature e of 99.7

Roott cause was s chartered to understtand the org ganizationa al drivers of these ONO OP evennts.

An ACE A was peerformed in April 2014 after the firrst symptom ms of degra adation of CCW C heat exchangerrs was obse erved - focused on alg gae bloom System Overview The coo oling canal system s represents a 168 mile serries of cana als that take e plant cooling water discharge fro om two fosssil units, one e cogen pla ant, and two o nuclear plants p with non normal external e ma akeup and routes r the water w back to the intakke for coolin ng water to o the two nucllear units.

During this period water w from a neighborring canal system from m a governm ment authorrity (100 million gallonss per day) was w used to o provide makeup m (diluution) to inccrease cana al water levvels and deecrease sallinity conceentrations.

Turkey Point Plant Evaluation - 11/20/2014 Causes and Contributors Station Apparent Cause: Elevated dissolved oxygen concentrations requiring additional hydrazine (which breaks down into ammonia) resulted in additional nutrients in the canal system increased the algae blooms. Contributing was algae impacted heat transfer areas in the condensers and heat exchangers compounded with lowering inventory in the canal establishing conditions permitted concentration of nutrients.

Station Root Cause: Lack of a program that monitors the overall health of the cooling canal system and its ability to meet UHS requirements.

Additional Conclusions Heat exchangers and condensers have been routinely cleaned yearly at a frequency to prevent entering emerging actions to address loss of heat transfer.

Containment cooling was affected by increased CCW temperatures requiring a temporary modification to supplement CCW cooling to improve CCW performance. Hours are logged when containment temperature exceeds 120 degrees and hours were logged during this period. At no time did the limit of 125 degrees occur.

Operations monitors cooling canal for temperaturefor UHS tech spec requirements and level to determine if it meets net pump suction head requirements.

There is no single owner or system engineer responsible for analyzing all the factors affecting cooling canal performance for the UHS. NOS does not perform evaluations of the canal system.

Chemistry does not perform any testing of intake cooling water (ICW) or circulating water. The only analysis was of water discharged back into the canals for compliance with established discharge permits.

As a result of the EPU project, South Florida Water management District required a groundwater, surface water, and ecological monitoring plan. The purpose of the plan was to monitor the movement of salt water into the freshwater aquifers.

This plan is implemented by the land utilization department and focused on the environmental parameters. Data monitored under the plan was not reviewed for impacts to the cooling canals water ability to cool power block equipment.

An amertap system was used for maintaining condenser cleanliness and equipment issues affected operation of the system. Repairs could not be accomplished until the next refueling outage.

Normally salinity concentrations are at two times what is present in the marine environment. During this period salinity approached three times the concentration in the marine environment.

Turkey Point Plant Evaluation - 11/20/2014 Chemistry was not a team member working on the root cause. Their function of monitoring and treating service water or circulating water was not seen as primary function.

Starting placing sea grass removed from the intake directly back into the discharge part of the cooling canal as a mulch with a new system put in place during EPU was not fully evaluated by engineering. The sea grass historically was disposed external to the cooling canal system.However, there were historical periods when the sea grass had been macerated in the past and returned to the canal system with no impact to cooling canal quality. The sea grass is a potential nutrient for activity in the canal system.

Fossil operation has decreased and impacts flow back into the cooling canal system. Additionally, the two EPU outages resulted in extended operation with no flow from one of the nuclear plants. This affects the flow through the canal system which can promote more algae.

Additional Information Monitoring the cooling canal system for its ability to provide UHS cooling requirements has not been performed. An action coming out of the root cause is to perform UHS performance monitoring. A charter group has been formed that includes land utilization, engineering, operations, and chemistry will evaluate the condition of the cooling canal and its ability to meet UHS requirements.

Cooling canal temperature exceeded normal high temperatures and canal water levels reached new lows in 2014.

For the new monitored parameters thresholds for action have not been established for each parameter. One parameter very important is for pH limits.

No actions for addressing the cause of the more tenacious scale forming in heat transfer areas. Understanding the cooling canal tendencies for depositing calcium deposits can allow actions to lower the tendencies.

More tenacious scrapers have been employed to remove scale in the heat exchangers.

More tenacious amertap balls included line striped carborundum balls in the condensers.

The station currently has a team reviewing options to improve canal system performance and to prevent unit downpower. Plans include sediment removal and permanent supplemental cooling including drilling new wells to provide a continuous makeup source of fresh, cooler water into the canal. We expect that at least two wells will be flowing water before June 2015.

Turkey Point Plant Evaluation - 11/20/2014 NRC-025 Submitted Nov. 10, 2015 TurkeyPointLANPEm Resource From: Hoeg, Tim Sent: Friday, November 21, 2014 8:23 AM To: Sandal, Shane Cc: Klett, Audrey; Endress, Matthew

Subject:

FW: Canal Chemistry INPO team presentation Attachments: RCE 1979256 Canal.pdf; TP Cooling Canal.docx FYI. Additional info provided by FPL regarding UHS. I thought you might be interested.

Tim Hoeg United States Nuclear Regulatory Commission Official Hearing Exhibit Senior Resident Inspector In the Matter of: FLORIDA POWER & LIGHT COMPANY Region II, Division of Reactor Projects (Turkey Point Nuclear Generating, Units 3 and 4)

U.S. Nuclear Regulatory Commission ASLBP #: 15-935-02-LA-BD01 Docket #: 05000250 & 05000251 Exhibit #: NRC-025-00-BD01 Identified: 1/4/2016 Turkey Point Nuclear Station Office: 305-245-7669 Admitted: 1/4/2016 Withdrawn:

9760 SW 344th ST. Fax: 305-247-0224 Rejected: Stricken:

Homestead, FL 33035 Other:

From: Tomonto, Bob [2]