IR 05000250/2024003
| ML24317A212 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/13/2024 |
| From: | Tom Stephen NRC/RGN-II/DORS |
| To: | Coffey B Florida Power & Light Co |
| References | |
| EPID I-2024-003-0013 IR 2024003 | |
| Download: ML24317A212 (1) | |
Text
SUBJECT:
TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2024003 AND 05000251/2024003 AND NOTICE OF VIOLATION
Dear Bob Coffey:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On October 15, 2024, the NRC inspectors discussed the results of this inspection with Mr. Michael Strope, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The enclosed report discusses a violation associated with a finding of very low safety significance (Green). The NRC evaluated this violation in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that this violation did not meet the criteria to be treated as a non-cited violation (NCV) because it involved the failure to restore compliance with a previous NRC-identified Green NCV within a reasonable period of time (NCV 05000250/05000251/2021004-01, "Debris and Unsecured Equipment in the RHR Pump Rooms," issued on February 2, 2022). Specifically, the station failed to correct a condition adverse to quality associated with unsecured debris found in the Unit 3 residual heat removal heat exchanger room, which pre-dated the completion of corrective actions from the NCV. The violation is cited in the enclosed Notice of Violation (Enclosure 1) and the circumstances surrounding it are described in detail in the enclosed inspection report (Enclosure 2). You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
Additionally, two findings of very low safety significance (Green) are documented in this report.
These findings involved violations of NRC requirements. We are treating these violations as NCVs consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Turkey Point Units 3 & 4.
November 13, 2024 If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Turkey Point Units 3 & 4.
This letter, its enclosure, and your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Thomas A. Stephen, Chief (Acting)
Project Branch 6 Division of Operating Reactor Safety Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41
Enclosures:
1: Notice of Violation 2: Inspection Report 05000250,251/2024003
Inspection Report
Docket Numbers:
05000250 and 05000251
License Numbers:
Report Numbers:
05000250/2024003 and 05000251/2024003
Enterprise Identifier:
I-2024-003-0013
Licensee:
Florida Power & Light Company
Facility:
Turkey Point Units 3 & 4
Location:
Homestead, FL 33035
Inspection Dates:
July 01, 2024 to September 30, 2024
Inspectors:
A. Donley, Senior Resident Inspector
A. Knotts, Resident Inspector
M. Read, Sr. Resident Inspector
R. Reyes, Project Engineer
Approved By:
Thomas A. Stephen, Chief (Acting)
Projects Branch 6
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Turkey Point Units 3 & 4, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Implement One Hour Compensatory Action for Fire Detector Out of Service in High Risk Fire Zone Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250,05000251/2024003-01 Open/Closed
[H.13] -
Consistent Process 71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Turkey Point license condition 3.D, Fire Protection, for the licensee's failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to implement the compensatory measure of an hourly fire rove after the failure of a fire detector in a high-risk fire zone.
Unsecured Debris in the 3B RHR Pump Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024003-02 Open/Closed
[H.2] - Field Presence 71111.06 The inspectors identified a Green non-cited violation (NCV) of Improved Technical Specification (ITS) 5.4.1, for the licensees failure to implement maintenance requirements specified by procedure MA-AA-100, "Conduct of Maintenance Nuclear Fleet." Specifically, the licensee failed to maintain the 3B residual heat removal (RHR) pump room in accordance with conduct of maintenance procedures that prevent debris from posing operational challenges to the screen and sump pump systems in this room.
Unsecured Debris in the Unit 3 RHR Heat Exchanger Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000250/2024003-03 Open
[P.3] -
Resolution 71152A The inspectors identified a green cited violation of 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, for the licensees failure to correct a condition adverse to quality.
Specifically, the licensee failed to correct and maintain the Unit 3 residual heat removal heat exchanger (RHR HX) room in compliance with housekeeping and conduct of maintenance procedures which prevent unsecured debris from posing challenges to the screen and sump pump systems in this room. A green notice of violation (NOV) was identified for the licensees failure to restore compliance from previously identified violations when debris was found in the Unit 3 RHR HX room after the licensee implemented corrective actions.
Additional Tracking Items
None.
PLANT STATUS
Unit 3 and 4 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather from a tropical storm warning and tornado watch issued due to Hurricane Helene on September 25, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Intake cooling water (ICW) header A and B alignment following 3C intake cooling water pump inservice test on July 24, 2024 (2)4B Emergency Diesel Generator (EDG) following completion of major maintenance window on August 02, 2024
- (3) Unit 4A and 4B component cooling water (CCW) trains while the 4C pump was out for maintenance on August 06, 2024
- (4) Unit 3 CCW and intake cooling water systems during the 3B ICW pump replacement on August 13, 2024
- (5) Unit 3A residual heat removal (RHR) standby alignment after 3A RHR pump inservice test on September 11, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (10 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire zones 70, 71, 95 and 96, 3A and 3B 4160V switchgear rooms and Unit 3 480V load centers rooms on July 24, 2024
- (2) Fire zones 61, 62, and 63, Unit 3 reactor control rod equipment room, Unit 4 reactor control rod equipment room and computer room on July 19, 2024
- (3) Fire zone 80, Unit 3 and Unit 4 main, auxiliary and startup transformers on August 01, 2024
- (4) Fire zone 118, auxiliary building roof on August 02, 2024
- (5) Fire zone 58, Unit 3 and Unit 4 auxiliary building common corridor on August 02, 2024
- (6) Fire zone 98, Unit 3 and Unit 4 cable spreading room and motor generator rooms on August 8, 2024
- (7) Fire zones 69 and 83, Unit 3 steam generator feed pump room and instrument air equipment area on August 09, 2024
- (8) Fire zone 133, 4B EDG room on August 15, 2024
- (9) Fire Zone 11, 12, and 13, Unit 3 RHR rooms on August 21, 2024
- (10) Fire zones 79 and 79A, outdoor area West of Unit 4 containment on September 20, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the: 3A and 3B RHR pump rooms Unit 3 RHR heat exchanger room
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 4B CCW heat exchanger
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during:
- reactivity dilution operation on Unit 3, and restoration of circulating water pump 3A1 following biological intake fouling event on September 18, 2024, and
- 30 MW turbine load and 4% reactor power change on Unit 4 as part of main turbine bearing vibration failure investigation process field action request on September 26, 2024
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator continued training scenario in the simulator on August 27, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) AR 2489971, maintenance rule evaluation, EVT-061-2024-50816, 4B RHR pump room sump pump A failure on July 3, 2024
- (2) AR 2467223, maintenance rule evaluation, EVAL-PTN-019-03122, 3A ICW pump maintenance preventable functional failure on September 19, 2023 and AR 2470164, a(1) evaluation for exceeding unavailability hours
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Work order (WO) 40882476, concrete and anchor replacement of 3B ICW pump base, on August 22, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 3 emergent high risk and containment entry at full power due to PT-3-456, pressurizer pressure transmitter, failed low on July 3, 2024
- (2) Unit 4 planned high risk for containment entry at full power to install temporary modification to reduce excessive sensing line vibrations on FT-4-484, steam generator B main steam line flow transmitter, on July 11, 2024
- (3) Unit 3 and Unit 4 online risk assessment while the 3C ICW pump, 3B ICW header, and the 3C charging pump were out of service on July 23, 2024
- (4) Unit 3 and Unit 4 elevated risk due to breaker racking issues during the 4B EDG maintenance outage on July 30, 2024
- (5) Unit 3 and Unit 4 online risk assessment while the Unit 4 auxiliary feedwater (AFW)train 1, 4CD (diesel) instrument air compressor, 4B CCW Heat exchanger, Unit 3B ICW pump, and the 3A ICW header were out of service on August 21, 2024.
- (6) Unit 3 and Unit 4 online risk assessment while the Unit 3A RHR pump, 4CD instrument air compressor and 4A CCW Heat exchanger were out of service on September 10, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2489114, failure of door 108A-2, auxiliary building roof to DC equipment room door, to open during biannual fire door inspection
- (2) AR 2489737, CV-4-955E, Unit 4 C accumulator sample isolation valve, and associated containment penetration, declared inoperable due to failed valve stroke and loss of position indication
- (3) AR 2492154, gas void found during gas accumulation monitoring program (GAMP)testing at point P25 in RHR system
- (4) AR 2491678, 4B EDG output breaker, 4AB21, closing springs failed to close
- (5) AR 2492174, 4C CCW Pump failed its inservice test run
- (6) AR 2492459, 3-40-2240, instrument air isolation valve to POV 3-4882 and 3-4883, found out of position
- (7) AR 2484782, D52, 125VDC vital spare battery, 18-month test failure
- (8) AR 2495135, inadvertent operator action lowered 4A EDG air flask pressure causing control room alarm
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
- (1) WO 40982883, PT-3-456, unit 3 pressurizer pressure transmitter protection set II, repair and calibration after unexpected failure
- (2) WO 40976915, replacement of TD4, time delay relay 120 VDC cool down timer, following unexpected alarm received during cooldown period after maintenance run of 4B EDG
- (3) WO 40963550, 4B EDG operability tests, after completing critical maintenance management window on July 31, 2024
- (4) WO 40954693, 3B ICW pump operability run following pump replacement on 22 August, 2024
- (5) WO 40992329, 3B RHR breaker PMT following alignment adjustments due to plunger gap identified
Surveillance Testing (IP Section 03.01) (2 Samples)
- (1) Unit 3 and Unit 4 monthly emergency core cooling system GAMP testing on August 5, 2024
- (2) 0-OSP-059.13, Unit 4 Core Map Analyses and Peaking Factors Verification on August 20, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)3-OSP-019.1, Unit 3C Intake Cooling Water In-service Test, on July 23,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 3 (July 1, 2023, through June 30, 2024)
- (2) Unit 4 (July 1, 2023, through June 30, 2024)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) AR 2460841 and 2489971, multiple flow test failures within the past year for the 4B RHR pump room sump pump A
- (2) AR 2486577, issue investigation for housekeeping inside the Unit 3A RHR room
INSPECTION RESULTS
Failure to Implement One Hour Compensatory Action for Fire Detector Out of Service in High Risk Fire Zone Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250,05000251/2024003-01 Open/Closed
[H.13] -
Consistent Process 71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Turkey Point license condition 3.D, Fire Protection, for the licensee's failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to implement the compensatory measure of an hourly fire rove after the failure of a fire detector in a high-risk fire zone.
Description:
On August 2, 2024, during a fire walk down of the auxiliary building corridor (fire zone 058), the inspectors identified a non-functional smoke detector, 39-9, outside of the cold chemistry laboratory. Upon further investigation, the inspectors noted that a system trouble alarm was in at the local alarm panel C299, but no fire impairment (FPI) was posted to identify the out of service smoke detector. The digital display confirmed that detector 39-9 was the cause of the system trouble alarm and indicated that this detector had been out of service since July 31, 2024.
The inspectors reported the observation of a non-functional smoke detector without a posted FPI to the control room. The shift manager verified that the FPI tracker did not contain a FPI for that smoke detector and the control room fire alarm panel, C41, did not report that detector 39-9 was out of service. Operations was unable to verify the non-functional smoke detector in the field, therefore, the inspectors emailed their observations to the fire protection engineer for further review. The engineer was unavailable and did not confirm that detector 39-9 was non-functional until August 7, 2024. Since the non-functional smoke detector was not seen in the control room, the licensee failed to create a FPI and missed a one-hour compensatory action, specifically a fire rove, from July 31 to August 7, 2024.
Corrective Actions: The licensee entered the issue in their corrective action program, created FPI 14677 and implemented a one-hour fire rove. The licensee performed an investigation, with vendor support, to identify the cause for the alarm notification discrepancy between the local fire panel (C299) and the control room panel (C41).
Corrective Action References: AR 02492262
Performance Assessment:
Performance Deficiency: The licensees failure to implement an hourly fire rove for a Function A fire detection instrument in a Group 1 fire detection area, as required by Section 5.6.3, Fire Detection Instrumentation Specifications, in licensee procedure 0-ADM-016, Fire Protection Program, Rev 040, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the missed hourly fire rove compensatory measure for the non-functional smoke detector, 39-9, a Function A fire detection instrument, would have impacted the ability of the fire brigade to respond and prevent the spread of fire in a Group 1 high risk fire zone.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was assigned to category 1.4.2, "Fixed Fire Protection Systems," with a low degradation rating since less than ten percent of smoke or heat detectors were degraded (nonfunctional, misplaced or missing) in the fire zone. Even though the response time of the fire brigade was impacted, the response time was mitigated by other defense-in-depth elements. Specifically, there were other functional fire detection instrumentation available near combustibles of concern in the fire zone. Based on this, the inspectors concluded that the finding was of very low safety significance (Green).
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, control room supervisors did not follow a systematic approach when inadvertent operator action cleared locked in alarms on the C41 panel which masked the non-functional detector 39-9, causing operators to miss the required one hour compensatory action.
Enforcement:
Violation: Turkey Point operating license Condition 3.D, states in part, that the licensee shall implement and maintain in effect, all provisions of the approved fire protection program, as approved in applicable NRC Safety Evaluation Reports (SER). Licensee procedure, 0-ADM-016, Fire Protection Program, Rev 040, is one of the fire protection program implementing documents described in the SER. Section 5.6.3.1, Fire Detection Instrumentation Specifications, requires that with any Function A or Function B fire detection instruments in any Group 1 Fire Detection area nonfunctional, confirm at least one alternate coverage device is available within one hour and shiftly thereafter or establish a one hour compensatory fire watch to inspect the zones while the instrument is out of service.
Contrary to the above, from July 31 to August 7, 2024, the licensee failed to implement and maintain in effect all provisions of the approved fire protection program as described in 0-ADM-016, as approved in applicable NRC SERs. Specifically, the licensee failed to either verify an alternate coverage device within one hour and shiftly thereafter or establish a one-hour compensatory fire watch patrol when detector 39-9 was discovered by the inspectors to be non-functional.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unsecured Debris in the 3B RHR Pump Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024003-02 Open/Closed
[H.2] - Field Presence 71111.06 The inspectors identified a Green non-cited violation (NCV) of Improved Technical Specification (ITS) 5.4.1, for the licensees failure to implement maintenance requirements specified by procedure MA-AA-100, "Conduct of Maintenance Nuclear Fleet." Specifically, the licensee failed to maintain the 3B residual heat removal (RHR) pump room in accordance with conduct of maintenance procedures that prevent debris from posing operational challenges to the screen and sump pump systems in this room.
Description:
On August 15, 2024, the inspectors performed a walkdown of the Unit 3 RHR pump and heat exchanger rooms. The inspectors identified bagged insulation material, covered by a large unsecured tarp in the 3B RHR ten-foot elevation area and a sizable amount of unsecured, bagged insulation material in the 3B RHR pump room. All material discovered on the floors of the 3B RHR area had posted signage which stated, "staged per Work Order 40858373." The material staged in the 3B RHR pump room was dated July 15, 2024, and the material staged in the ten-foot area was dated July 16, 2024. The control room was informed, and the licensee took action to document the discrepancy in AR 02492940 and immediately corrected the deficiency. The bags and tarps staged in the 3B RHR pump area were not properly controlled in accordance with station procedures. This material had the potential to move during a flooding event and could have resulted in blocked sump pump screens; thereby impacting the ability of the sump pumps to perform their function.
Corrective Actions: The licensee documented the issue in their corrective action program, secured the bagged insulation material and removed of the tarps in the 3B RHR area.
Corrective Action References: AR 02492940
Performance Assessment:
Performance Deficiency: The failure to prevent foreign material from potentially affecting the performance of the 3B RHR pump room flood mitigating equipment in accordance with conduct of maintenance procedures MA-AA-100 "Conduct of Maintenance Nuclear Fleet",
Revision 29, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to maintain the 3B RHR pump room free of debris as required by station procedures could have led to potential flood mitigation challenges.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Cornerstone Screening Questions, the finding was screened as having very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event for greater than 14 days.
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.
Specifically, maintenance supervision failed to coach inadequate work practices associated with flood-sensitive areas. Furthermore, leaders did not reinforce the standards and expectations associated with storage and housekeeping requirements in the 3B RHR pump room.
Enforcement:
Violation: Improved Technical Specification (ITS) 5.4.1 requires, in part, that written procedures shall be established, implemented, and maintained, as required by the licensees Quality Assurance Topical Report (QATR), which includes procedures listed in Appendix A of NRC Regulatory Guide 1.33, Revision 2, dated February 1978. Section 9e of Regulatory Guide 1.33 recommends procedures for control of maintenance for operating nuclear power plants. The licensee implements ITS 5.4.1 requirements in procedures MA-AA-100, Conduct of Maintenance. Specifically, step 5.6.1.E of MA-AA-100 specifies, Equipment shall not be left unattended in any area that has a sump pump installed to mitigate flooding of safety related equipment such as RHR, HHSI, Condensate and Auxiliary Building unless engineering evaluation is performed.
Contrary to the above, from July 15 to August 14, 2024, the licensee failed to implement procedures recommended by Regulatory Guide 1.33 as described in the QATR and ITS 5.4.1. Specifically, material was left unattended (unsecured) in the RHR 10 elevation and the 3B pump room which could impacted the flood protection devices ability to mitigate flooding of safety related equipment without an engineering evaluation being performed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unsecured Debris in the Unit 3 RHR Heat Exchanger Room Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NOV 05000250/2024003-03 Open
[P.3] -
Resolution 71152A The inspectors identified a green cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality.
Specifically, the licensee failed to correct and maintain the Unit 3 residual heat removal heat exchanger (RHR HX) room in compliance with housekeeping and conduct of maintenance procedures which prevent unsecured debris from posing challenges to the screen and sump pump systems in this room. A green notice of violation (NOV) was identified for the licensees failure to restore compliance from previously identified violations when debris was found in the Unit 3 RHR HX room after the licensee implemented corrective actions.
Description:
On May 2024 during a walkdown of the Unit 3 RHR HX room, NRC inspectors identified multiple, unsecured bags of debris containing contaminated waste material that were dated August 26, 2021. This debris had the potential to partially clog the screen and sump pump system and render the flood mitigation feature unable to perform its function.
The inspectors reviewed the history of issues surrounding housekeeping and unsecured material storage in the RHR rooms. AR 02404979 written September 23, 2021, documented an adverse housekeeping trend in the RHR rooms and included short term corrective actions to eliminate debris in the Unit 3 RHR heat exchanger room. This corrective action was not effective at removing material, as the date on the unsecured bags of debris pre-dates the action completion date of December 6, 2021. Additionally, the inspectors found three NRC-identified non-cited violations (NCV) associated with unsecured debris in the RHR:
ML22032A251, NCV 05000250/05000251/2021004-01, Debris and Unsecured Equipment in the RHR Pump Rooms; ML19105B281, NCV 05000251/2019010-01, Inadequate Maintenance Procedures to Ensure Flood Protection for the 4A and B RHR Trains; and ML16315A226, NCV 05000251/2016003-01, Failure to Provide Adequate Flood Protection for the 4A RHR Train. AR 02424217 from April 8, 2022, documented long term corrective actions from the 2021 NCV, and included actions for station personnel training and required supervisors to inspect RHR rooms post work completion. These corrective actions were also not effective at removing the identified debris, as the date on the unsecured debris pre-dates the action completion date of July 27,2023.
The inspectors concluded that despite the numerous issues entered into the corrective action program (CAP), the licensee was unable to implement adequate controls to prevent debris accumulation. Furthermore, the identified debris, dated August 26, 2021, provided evidence that the licensee failed to correct a condition adverse to quality and restore compliance after the completion of corrective actions from previous NCVs and ARs from 2021 and 2022.
Corrective Actions: The licensee removed the bags of contaminated material located in the Unit 3 RHR HX room, performed extent of condition walkdowns of the other rooms with recirculation sumps, and entered the issue into the CAP.
Corrective Action References: AR 02486577
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee's failure to maintain the RHR rooms free of unsecured debris in accordance with station housekeeping and conduct of maintenance procedures MA-AA-100-1008 Station Housekeeping and Material Control, Revision 31 and MA-AA-100 Conduct of Maintenance Nuclear Fleet, Revision 29, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to maintain the Unit 3 RHR heat exchange room free of debris as required by station procedures led to unnecessary potential flood mitigation challenges in the Unit 3 RHR heat exchanger room.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Cornerstone Screening Questions, the finding was screened as having very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event for greater than 14 days.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensees corrective actions did not resolve the deficiencies from previous events to remove debris from the Unit 3 RHR heat exchanger room.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected.
Contrary to the above, from February 2, 2022 to May 17, 2024, the licensee failed to promptly correct a condition adverse to quality associated with the control of unsecured debris material in Unit 3. Specifically, the licensee failed to promptly remove waste bags, dated August 21, 2021, from the Unit 3 RHR heat exchanger room, a condition adverse to quality, which challenged the function of the flood mitigation features in the room. This condition was dispositioned previously as NCV 05000250/05000251/2021004-01 on February 2, 2022. However, on May 17, 2024, the NRC identified that the licensee failed to completely remove the waste bags involved in the NCV, resulting in failure to restore compliance with the applicable requirements within a reasonable time after the first violation was identified.
Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 15, 2024, the inspectors presented the integrated inspection results to Mr.
Michael Strope, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
action request
2496263, 2496330
Procedures
0-ADM-116
Hurricane Season Readiness
Procedures
0-ONOP-103.3
Severe Weather Preparations
Drawings
5613-M-3019
Sheet 1
Intake Cooling Water System
Procedures
3-OSP-019.2
Intake Cooling Water System Flowpath Verification
Procedures
Diesel Generator
Operability Test
4-OSP-023.1
03/04/2024
Corrective Action
Documents
Action Requests
2493159
Corrective Action
Documents
Resulting from
Inspection
Action Request
2492262
Fire Plans
PFP-3-TB-18
Unit 3 Turbine Building
Fire Plans
PFP-3-TB-30
Unit 3 Turbine Building
Fire Plans
PFP-4-EDG-18
Unit 4 Emergency Diesel Generator Building
Fire Plans
PFP-4-TB-18
Unit 4 Turbine Building
Fire Plans
Unite 3&4 Auxiliary Building
Fire Plans
Unit 3&4 Auxiliary Building
Fire Plans
Unit 3&4 Auxiliary Building
Fire Plans
Unit 3 and Unit 4 Control Building
Procedures
0-PME-091.1
Outside Containment Smoke Detector Sensitivity Check and
Calibration
01/19/22
Procedures
0-PME-091.1
Outside Containment Smoke Detector Sensitivity Check and
Calibration
2/13/17
Procedures
0-SME-091.3
Fire and Smoke Detection System Annual Test Circuits 6,
15, and 32
Procedures
0-SME-091.4
Fire and Smoke Detection System Annual Test Circuits 7, 8,
20, 21, 22, 23 and 39
2/15/2022
Procedures
0-SME-091.6
Fire and Smoke Detection System Annual Test Circuits 26,
6/23/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
27, 29, 30 and 31
Calculations
FPL062-CALC-
2
Effects of Local Intense Precipitation on Critical Selected
Powerblock Rooms
Corrective Action
Documents
Resulting from
Inspection
Action Request
2492940
Engineering
Evaluations
061-WD-02
Maintenance Rule Scope Evaluation
03/22/2016
Engineering
Evaluations
PTN-BFJR-11-
009
Turkey Point Internal Flooding Analysis
Engineering
Evaluations
PTN-ENG-SECS-
15-025
Integrated Assessment Report NEE016-PR-001, Rev. 1, in
response to the 50.54(f) information request
regarding NTTF Recommendation 2.1: Flooding for PTN U3
& U4
Engineering
Evaluations
TP7910030069
Technical Evaluation of the Susceptibility of Safety-Related
Systems to Flooding Caused by the Failure of Non-Category
Systems for Turkey Point Nuclear Power Plant, Units 3
and 4
09/04/1979
Procedures
0-OP-046
CVCS-Boron Concentration Control
Procedures
4-GOP-103
Power Operations to Hot Standby
Procedures
4-NOP-089
Corrective Action
Documents
Resulting from
Inspection
action requests
2493495
Engineering
Changes
298920
Alternate Materials for ICW Pump Hold down bolts and
pump sole plates
Miscellaneous
Testing data
sheet for
Stratarock
Batch Code 102623APR182024APR192025
05/25/2024
Miscellaneous
Product Data
Deep Pour Epoxy
Stratarock Layers of protection for industrial equipment
05/2016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Grout High Flow
Physical and
Chemical
Characteristics
Shipping Records
2468266
Purchase Order
04/26/2024
Corrective Action
Documents
action requests
2489909, 2489978, 2490025
Engineering
Evaluations
Temporary Support for FT-4-484 Tubing
Engineering
Evaluations
EC for SPEC-C-116 for Storing a Miscellaneous Item Inside
Containment
Work Orders
Corrective Action
Documents
action requests
2413443, 2491920, 2478141
Drawings
5614-M-3030
Sheet 1
Component Cooling Water System
Miscellaneous
PTN-FPER-21-
009
PTN Fire Protection Surveillance Optimization-Phase 3 Fire
Rated Assemblies (Fire Doors)
08/02/2021
Procedures
0-ADM-016
3/20/2024
Procedures
0-ADM-016.7
Performance Based Optimization Evaluations for Fire
Protection
Procedures
0-ONOP-105
Control Room Evacuation
Procedures
4-ARP-097.DG
Diesel Generator Panel Annunciator Response
7/23/18
Procedures
4-OP-023
1/23/24
Work Orders
work orders
40872349, 40775766, 40721295, 40949184, 40982810,
40986409, 40874716
Calibration
Records
QI-12-PTN-
1/I9849
M/TE Calibration Data Sheet Pressure/Vacuum Gauge
08/23/2023
Calibration
Records
QI-12-PTN-1E964
Annual Calibration of Megger SST-9203 Solid State Digital
Counter
04/21/2023
Corrective Action
Documents
action requests
2485680, 2489909, 2496181
Miscellaneous
5610-J-844 Sheet
1B
Pressurizer Pressure Protection (P-456)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Control and Calibration of Measuring and Test Equipment
Procedures
User Responsibilities and Control of Measuring and Test
Equipment (MTE)
Work Orders
work orders
40952020, 40952021, 40952022, 40952013, 40952014,
40952015, 40981549
71151
Corrective Action
Documents
Action Requests
2454323
71151
Miscellaneous
Operator Logs
July 1, 2023-June 30, 2024
71151
Procedures
0-ADM-032
NRC Performance Indicators Turkey Point
Corrective Action
Documents
Action Requests
2404979, 2424217
Procedures
Conduct of Maintenance
Procedures
Station Housekeeping and Material Control
Procedures
Issue Investigation Attachment 10 Quality Assessment
Guide
Work Orders
work orders
40845021, 40948121