IR 05000250/2024004
| ML25031A060 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/04/2025 |
| From: | Shawn Smith NRC/RGN-II/DORS/PB5 |
| To: | Coffey R Florida Power & Light Co |
| References | |
| IR 2024004 | |
| Download: ML25031A060 (1) | |
Text
SUBJECT:
TURKEY POINT NUCLEAR GENERATING, UNITS 3 AND 4 - INTEGRATED INSPECTION REPORT 05000250/2024004 AND 05000251/2024004
Dear Robert Coffey:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Nuclear Generating, Units 3 and 4. On January 16, 2025, 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Turkey Point Nuclear Generating, Units 3 and 4.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Turkey Point Nuclear Generating, Units 3 and 4.
February 4, 2025 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Steven P. Smith, Branch Chief Projects Branch 6 Division of Operating Reactor Safety Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000250 and 05000251
License Numbers:
Report Numbers:
05000250/2024004 and 05000251/2024004
Enterprise Identifier:
I-2024-004-0028
Licensee:
Florida Power & Light Company
Facility:
Turkey Point Nuclear Generating, Units 3 and 4
Location:
Homestead, FL 33035
Inspection Dates:
October 01, 2024 to December 31, 2024
Inspectors:
J. Diaz-Velez, Senior Health Physicist
A. Donley, Senior Resident Inspector
A. Knotts, Resident Inspector
D. Orr, Senior Project Engineer
N. Peterka, Sr. Fuel Facility Project Inspector
R. Reyes, Project Engineer
J. Rivera, Health Physicist
S. Roberts, Project Engineer
D. Strickland, Senior Reactor Inspector
Approved By:
Steven P. Smith, Chief
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 Nuclear Generating, Units and 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 Assess Online Risk Before Resulting in Orange Risk Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000251/2024004-01 Open/Closed
[H.12] - Avoid Complacency 71111.13 A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(4)was identified when the licensee failed to adequately assess the risk associated with removing the Unit 4 start up transformer (SUT) from service while in a load-threat condition.
Failure to Implement Corrective Actions to Prevent Failure of the 3A ICW Pump Motor Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024004-03 Open/Closed
[P.2] -
Evaluation 71152A The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion XVI, "Corrective Action," for the licensee's failure to correct a condition adverse to quality which caused the inoperability of a safety component. The 3A intake cooling water (ICW) pump motor failed to start on demand due to a ground in the motor windings caused by moisture, which was attributed to not having functional motor space heaters over a period of two years.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000251/2024004-02 Potential Failure to Classify a Locked High Radiation Area Event as a Performance Indicator Non-Conformance.
71151 Open
PLANT STATUS
Unit 3 started the inspection period at 100 percent rated thermal power (RTP). On October 12th at 0438, Unit 3 experienced a significant condenser tube leak which caused operators to initiate a fast load reduction and manually trip the reactor at 0618. The unit then entered their refueling outage and remained offline until November 21, 2024, when it returned to 100 percent RTP. On December 4th at 1033, Unit 3 tripped from 100 percent RTP due to reactor protection system (RPS) actuation when RPS Channel III experienced a total failure while bistables were tripped on Channel II for planned nuclear instrument calibrations. The unit returned to 100 percent RTP on December 7, 2024. On December 12th at 0953, turbine control valve #1 experienced a significant electrohydraulic fluid leak causing operators to down power the unit to 70 percent RTP in order to close the valve and isolate the leak. The leak was fixed and the unit returned to 100 percent RTP on December 14, 2024, where it remained for the rest of the inspection period.
Unit 4 operated at or near RTP 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 issued due to Hurricane Milton on October 8, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) High head safety injection (HHSI) alignment to Unit 4 with Unit 3 refueling water storage tank (RWST) out of service (OOS) on October 28, 2024
- (2) Safety-related Unit 4A, 4B, and 3A 4160-volt switchgears while the Unit 3B 4160-volt switchgear was OOS on October 31, 2024
- (3) HHSI restoration alignment to Unit 3 following PT3-34 refueling outage on November 14, 2024
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 4 instrument air (IA) system on November 19, 2024.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 Zone 60, Unit 3 containment on October 28, 2024
- (2) Fire Zones 5, 6, and 7, radiation waste collection and processing areas on November 1, 2024
- (3) Fire Zone 138, 4A emergency diesel generator (EDG) room on November 12, 2024
- (4) Fire Zones 067 and 068, Unit 4, 4160-volt switchgear rooms on November 13, 2024
- (5) Fire Zones 106, 108A, and 108B, control room and DC equipment rooms on November 19, 2024
- (6) Fire Zones 081, and 076, Unit 3 and Unit 4 turbine lube oil storage tank areas on November 27, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill at the Unit 4C transformer on October 4, 2024.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 3B component cooling water (CCW) heat exchanger
===71111.08P - Inservice Inspection Activities (PWR) The inspector verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Unit 3 during refueling outage PTN3-34 from October 28 - October 31, 2024.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examination
- 29"-RCS-1308-2, pipe to pipe, ASME Class 1
- 8"-RHR-1301-2, pipe to elbow, ASME Class 1
- 8"-RHR-1302-3, elbow to pipe, ASME Class 1
- In Vessel Inspection, clevis bolts 2-L-1 thru 2-L-4 and 2-R-1 thru 2-R-4 located at 180 deg lower radial support, ASME Class 1
- In Vessel Inspection, clevis bolts 1-L-1 thru 1-L-4 and 2-R-1 thru 2-R-4 located at the 0 deg lower radial support, ASME Class 1 Visual Examination
- 8074-H-327-01, welded double acting restraint, VT-3, Class 3
===80117-H-322-07, welded double acting restraint, VT-3, Class 3
- 80117-H-322-07 IA, Integral Attachment, VT-1, Class 3 Welding Activities
- PTNP470160, Weld Package for CV-3-387 (pre-heat/fit-up/tack FW-25, 34, 37, 38)
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03)===
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- Boric Acid Walkdown - October 30, 2024
- Reviewed action request (AR) 02499928, AR 2499949, and AR 2499948
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
The licensee completed the annual requalification operating examinations and biennial written examinations required to be administered to all licensed operators in accordance with Title 10 of the Code of Federal Regulations 55.59(a)(2), "Requalification Requirements," of the NRC's "Operator's Licenses." The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations, the crew simulator operating examinations, and the biennial written examinations in accordance with Inspection Procedure (IP) 71111.11, "Licensed Operator Requalification Program and Licensed Operator Performance." These results were compared to the thresholds established in Section 3.03, "Requalification Examination Results," of IP 71111.11.
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on June 28, 2024.
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:
1. Unit 3 main condenser waterbox tube rupture resulting in a manual reactor trip
on October 12, 2024
2. Unit 3 cooldown using steam dumps to atmosphere and placing residual heat
removal (RHR) in service for cooldown on October 13, 2024
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator just in time training in the simulator for:
- shutdown for refueling outage on October 12, 2024
- startup from refueling outage on November 13, 2024
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 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 2491780, door 108A-2, high safety significant fire door between the auxiliary building roof and Unit 4 DC equipment room exceeded NFPA 805 unavailability criteria on July 24, 2024
- (2) Maintenance rule EVAL-PTN-019-03122, 3A intake cooling water (ICW) pump return to (a)2 status
- (3) AR 2463290, steam jet air ejector radiation monitor, R-3-15, erratic and spiking indication, and missed condition monitoring failure (CMF) evaluation
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 yellow shutdown risk while in Mode 5 with reactor coolant (RCS) inventory less than 5 percent pressurizer cold calibration level, on 17 October, 2024
- (2) Unit 4 high risk associated with instrumentation and control (I&C) channel 3 steam pressures testing on October 23, 2024
- (3) Unit 4 unplanned entry into orange online risk for startup transformer (SUT) OOS during a load-threat surveillance activity on October 23, 2024
- (4) Unit 4 online risk assessment and Unit 3 yellow shutdown risk while the B standby steam generator feed pump, 3B EDG, 3B safety-related 4kV switchgear, and 3C transformer were OOS for maintenance on October 29, 2024
- (5) Unit 3 high risk associated with troubleshooting and repair of an electrohydraulic oil leak on the turbine control valve #1 that caused an emergent down power, on December 13, 2024
- (6) Unit 4 online risk assessment while 4A RHR pump inoperable due to testing on December 18, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) AR 2496627, 4B EDG cooling water low level alarm during monthly diesel surveillance
- (2) AR 2498638, FT-3-435, RCS loop C protection set II flow transmitter output above as found acceptance criteria
- (3) AR 2496679, functionality assessment for through-wall leak on charging discharge line
- (4) AR 2499076, rod drop rod stop and power range channel deviation alarms caused by, power range channel II, N-4-42, output spiking
- (5) AR 2499419, failed as found local leak rate testing for cannister 53 of penetration 38
- (6) AR 2502584, 4A EDG oil immersion heater not turning on at setpoint causing operator rounds of lube oil temperature to be less than required
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) EC 300075, installation of temporary Team (Furmanite) Enclosure upstream of valve 4-383, charging pump discharge to regenerative heat exchanger root valve, on October 29, 2024
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 3 refueling outage, PT3-34, activities from October 13 to November 15, 2024.
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) (8 Samples)
- (2) WO 40958644, 3B CCW heat exchanger performance test following previous test failure
- (3) WO 40880704, source range channel, N-3-32, calibration following identified deviation
- (4) WO 40907985, 3B ICW 4KV circuit breaker operational test after replacement
- (5) WO 40997800, PCV-3-456 pressurizer pilot operated relief valve (PORV) actuator calibration after failed stroke times
- (6) WO 40994921, POV-3-2604, 3A main steam isolation valve operational and in-service test after replacement of limit switch due to dual indication
- (7) WO 40979691 and 40880604, MOV-3-864B, RWST discharge to safety injection and residual heat removal pumps, operational tests following internal valve inspection activities
- (8) WO 40858332, CV-3-2832, steam generator B train 2 auxiliary feed water control valve, operational test following actuator overhaul
Surveillance Testing (IP Section 03.01) (4 Samples)
(1)4-SMI-072.02A, Steam Pressures Channel Operational Test Protection Channel III, on October 23, 2024 (2)3-OSP-062.4, Safety Injection System - Full Flow Test, on October 24, 2024 (3)3-OSP-050.2E, RHR Check Valve Inservice Testing, on November 4, 2024 (4)3-OSP-203.1, Train A Engineered Safeguards Integrated Test, on October 20, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)3-OSP-206.3, Inservice Valve Testing Hot Standby to Cold Shutdown, close stroke time testing for accumulator discharge isolation valves, on October 29, 2024
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1)3-OSP-051.5, Local Leak Rate Tests, Pen-19B, containment spray, on October 22, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (2 Samples)
The inspectors evaluated:
- (1) Training drill to test the readiness of the new technical support center and operational support center facilities on October 1, 2024
- (2) Training tabletop drill to observe licensee emergency classification and emergency notification processes on December 10,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA) during Unit 3 outage.
- (2) Workers exiting the RCA during Unit 3 outage.
- (3) Workers exiting Unit 3 containment during Unit 3 outage.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Unit 3 Outage Fuel Movement Associated Activities
- (2) Unit 3 Outage Bottom Mounted Instrumentation Project (BMI)
- (3) Unit 3 Outage Scaffold Activities
- (4) Unit 3 Outage Insulation Activities
- (5) Unit 3 Outage Reactor Disassembly and Reassembly Refueling Activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
- (1) Units 3 and 4 Demineralizer Galleries
- (2) High Level Storage Area
- (3) Unit 3 Pipe and Valve Room
- (4) Unit 3 RCS Filter Room Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) RCA outside yard
- (2) Auxiliary Building
- (3) U3 Reactor Building
Radioactive Waste System Walkdown (IP Section 03.02) (3 Samples)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Demineralizer skid in radwaste facility
- (2) Resin liner filling area in radwaste facility
- (3) Dry Active Waste stored in the RCA yard area
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
(1)10 CFR Part 61 Analysis Report for 2023 Dry Active Waste (DAW) and Radioactive Materials (RAM) waste streams, dated 10/09/2023 (HP QA-1000 file)
(2)10 CFR Part 61 Analysis Report for 2022 Dry Active Waste (DAW) and Radioactive Materials (RAM) waste streams, dated 03/22/2022 (HP QA-1000 file)
- (3) Characterizations associated with the following shipments: PTN-W-23-011, PTN-W-23-012, PTN-W-23-017, PTN-W-23-001, and PTN-W-23-016
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) Shipment 17-0877 (receipt), MSRVs received on 10/23/2024
Shipping Records (IP Section 03.05) (5 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) Shipment PTN-W-23-011, Primary Resin, LSA-II
- (2) Shipment PTN-W-23-012, Primary Resin, LSA-II
- (3) Shipment PTN-W-23-017, Secondary Resin, LSA-II
- (4) Shipment PTN-W-23-001, Dry Active Waste (excepted package, limited quantity)
- (5) Shipment PTN-W-23-016, Secondary Resin, LSA-II
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) May 1, 2023 through October 25, 2024 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) May 1, 2023 through September 25, 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 2499834, Battery Pilot Cell Selection Incorrect, which required entry into technical specification surveillance requirement 3.0.3 for missed monthly surveillance, 0-SME-003.07, 125 VDC Station Battery Monthly Surveillance
- (2) AR 2467223, 3A Intake cooling water pump failure due to moisture in the windings, which resulted in the ICW pump not being available and entry into a 14-day shut down action statement to troubleshoot the failure and install a new pump motor.
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in safety related heating, ventilation and air conditioning (HVAC) systems that might be indicative of a more significant safety issue. No negative trends that could lead to a safety significant issue were identified.
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)
- (1) The inspectors evaluated a Unit 3 reactor trip during power range nuclear instrument testing and licensees response on December 4,
INSPECTION RESULTS
Failure to Assess Online Risk Before Resulting in Orange Risk Condition Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000251/2024004-01 Open/Closed
[H.12] - Avoid Complacency 71111.13 A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(4)was identified when the licensee failed to adequately assess the risk associated with removing the Unit 4 start up transformer (SUT) from service while in a load-threat condition.
Description:
On October 23, 2024, the licensee planned to take the Unit 4 start up transformer out-of-service (OOS) for switchyard maintenance. The licensee completed a preliminary online risk assessment with the Online Risk Monitor (OLRM) What If calculation to assess the overall risk of removing the SUT from service. The preliminary risk assessment for the SUT OOS was green, acceptable risk. However, this preliminary risk assessment did not account for the instrumentation and control (I&C) maintenance that was also scheduled that morning. This would have prompted the operator to place the Unit 4 OLRM in a load threat condition. This condition, coincident with the SUT OOS, would have shown risk change to orange, potentially risk significant. Because each maintenance was assessed separately, the operators believed risk would remain green throughout the workday.
Prior to performing switchyard work, permission was granted to commence I&C maintenance that required tripping bistables in the control room. In accordance with 0-ADM-225 Online Risk Assessment and Management, the OLRM must indicate a load threat test/maintenance activity in progress as long as bistables are tripped. Once bistables were tripped for I&C work, the OLRM was updated to reflect a load threat condition, and risk remained green.
As I&C work continued, the control room granted permission for switchyard operators to start work on the Unit 4 SUT, and it was declared inoperable. Once control room personnel verified the SUT was unavailable, they updated the OLRM to reflect the new plant condition. This resulted in an orange, potentially risk significant, risk condition that was not expected by the operators.
The licensee contacted fleet probabilistic risk assessment (PRA) personnel to verify the OLRM results. Fleet PRA personnel confirmed the orange risk condition. The preliminary risk assessment had not considered the load threat condition concurrent with the SUT maintenance. Therefore, the operators realized the What If calculation was improperly performed.
In accordance with 0-ADM-225, step 5.2.10, the licensee requires a risk assessment by the PRA Group and approval by the Site Vice President prior to entering the potentially risk significant (Orange Risk Status) configuration. Neither of these were done because of the sites failure to perform the initial risk assessment during work week planning. Therefore, the maintenance activities should not have been authorized by the control room. Furthermore, section 5.3.16 requires that appropriate risk management strategies be applied as discussed in subsection 5.4" of 0-ADM-225. These strategies were also not implemented as a result of the inadequate preliminary risk assessment.
Corrective Actions: The licensee restored the Unit 4 SUT to service approximately 49 minutes after it was unavailable and documented the issue in the corrective action program.
Corrective Action References: AR 02499166, 02499262
Performance Assessment:
Performance Deficiency: The licensees failure to perform an adequate risk assessment as required by licensee procedure 0-ADM-225, was a performance deficiency. Specifically, the licensee failed to adequately assess the risk associated with removing the Unit 4 SUT from service when there was a load threat condition.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance 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 licensee failed to perform an adequate risk assessment for maintenance activities that resulted in a higher established risk category, the actual risk color was orange and not the expected color green, on October 23, 2024.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix K, Maintenance Risk Assessment and Risk Management SDP. In accordance with PTN-BF-JR-00-005 Rev. 0, if a load-threat surveillance condition is met, 5E-4 per year will be added to the core damage frequency (CDF), thus, the actual CDF was 5.05E-4 per year and the licensee entered orange risk. The inspectors calculated the risk deficit IAW Step 4.2 of Append K and determined the incremental core damage probability deficit was less than 1E-6 due to the licensees quick action in restoring the SUT (e.g., station was only in orange risk for 49 minutes), therefore, the finding screened to Green.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee did not have a plan for the possibility of mistakes during a preliminary OLRM review to ensure that risk was appropriately assessed while the start up transformer was out of service during a load threat condition.
Enforcement:
Violation: 10 CFR 50.65(a)(4) requires, in part, that Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, on October 23, 2024, before performing maintenance the licensee failed to accurately assess and manage the increase in risk that resulted from the proposed maintenance activities. Specifically, the licensee did not accurately assess the risk associated with removing the Unit 4 SUT from service concurrent with a load threat surveillance activity.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Potential Failure to Classify a Locked High Radiation Area Event as a Performance Indicator Non-Conformance.
URI 05000251/2024004-02 71151
Description:
On September 16, 2023, Operations was performing an evolution to re-introduce primary water flow through Unit 4 chemical and volume control system (CVCS) demineralizer 4E, which had just been loaded with fresh resin. Shortly after the evolution began, dose rates in the Unit 4 demineralizer valve gallery, initially posted as a radiation area, rose significantly, which resulted in an auxiliary operator in the demineralizer valve gallery receiving an unexpected dose rate alarm of 1090 mrem/hr with a setpoint of 300 mrem/hr. Dose rates in the area, which were initially less than 100 mrem/hr general area, had increased to greater than 1,000 mrem/hr general area. A follow-up radiological survey indicated dose rates up to 2500 mrem/hr at 30cm. Upon receiving the dose rate alarm, the operator exited the area and reported to radiation protection (RP). RP technicians subsequently secured the area, which included posting it as a locked high radiation area (LHRA).
The licensee determined that the most probable cause was the collapse of an air void in the 4E demineralizer, which had just been filled with fresh resin, causing a migration of radioactive resin from the 4B demineralizer into the letdown line. This caused an unexpected increase in dose rates in the Unit 4 demineralizer valve gallery. The inspectors noted that the licensee had a demineralizer system that was unique from other Westinghouse designs, and that the potential off-normal operating scenarios were not well understood. A contributing factor was that licensee procedure 4-OP-047.3, CVCS - Demineralizer Operations, did not include a requirement to isolate the demineralizers containing radioactive resin from the demineralizer being filled, which would have prevented the event. The NRC therefore issued a self-revealed Green finding and associated NCV 05000251/2023004-06 of Unit 4 Technical Specifications (TS) 6.12, High Radiation Area, for failure to implement an adequate procedure that resulted in an unexpected change in radiological conditions requiring LHRA controls.
Licensees Position:
The licensee reviewed this event against NRC Inspection Procedure (IP) 71151, Performance Indicator Verification, section 03.09, OR01: Occupational Exposure Control Effectiveness, technical specifications, and NEI 99-02 Regulatory Assessment Performance Indicator Guideline, Occupational Exposure Control Effectiveness, Rev. 7. Based on their review, the licensee believes this event does not meet the criteria of occurrences that are required to be counted against the indicator.
Specifically, NEI 99-02 Rev. 7 lists examples of occurrences that are not counted include the following: Occurrences associated with isolated equipment failures. This might include, for example, discovery of a burnt-out light, where flashing lights are used as per technical specification, control for access, or a failure of a lock, hinge, or mounting bolts, when a barrier is checked or tested. The licensee believes this occurrence is associated with a unique legacy Westinghouse Demin system design issue that did not account for backpressure across the system, akin to an equipment malfunction. There is no history at Turkey Point with similar occurrences in the past, Turkey Points practices are consistent with other stations, and there is no industry OE regarding similar events. Therefore, the licensee believes this issue was unique, associated with an equipment malfunction, and was beyond Turkey Points ability to foresee and correct. All proper actions were taken by the workers and the station once radiation levels changed.
The licensee also believes that this position is consistent with NEI 99-02 Frequently Asked Question (FAQ) 98 which describes radiation levels in an area increasing after workers entered the area. The area was posted as a radiation area and had no history of changing radiological conditions during this work activity. The worker took actions consistent with the example above based on the alarm received and RP followed up with the proper programmatic controls associated with LHRA conditions. In this case, the Operator received 4 mRem against a 100 mRem threshold for the Unintended Dose element of this cornerstone.
NRCs Position:
In response to the licensees position:
The inspectors reviewed NEI 99-002, Rev. 7:
This guideline defines TS high radiation areas (HRAs), commonly referred to as LHRAs, as any area, accessible to individuals, in which radiation levels from radiation sources external to the body are in excess of 1 rem (10 mSv) per 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates. This guideline also defines a TS HRAs (> 1 rem per hour) occurrence as a non-conformance with technical specifications applicable to TS HRAs (> 1 rem per hour) that results in the loss of radiological control over work activities in the respective area. The NRC believes that the LHRA event described above meets both of these definitions.
According to this guideline, examples of occurrences that are not counted TS HRAs (> 1 rem per hour) are those associated with isolated equipment failures. As the licensee indicated, this might include, for example, discovery of a burnt-out light, where flashing lights are used as a technical specification control for access, or a failure of a lock, hinge, or mounting bolts, when a barrier is checked or tested. However, the NRC had already determined, upon issuance of the Green NCV discussed above, that a performance deficiency (PD) existed for failure to implement adequate procedures for the CVCS system that was reasonable within the licensees ability to foresee and correct, and that the probable cause of the collapse of an air void in the 4E demineralizer did not constitute an equipment failure. The NRC therefore believes that this example regarding equipment failures does not apply.
The inspectors also reviewed NEI 99-02 FAQ 98:
Question: While individuals were working in an area, the local area radiation monitor alarmed. The workers promptly exited the area and notified health physics. Follow-up surveys by the health physics staff indicated that radiation dose rates in the area had increased to a level in excess of 1 rem per hour. Proper controls and posting were then established for the area. Does this count against the PI?
Response: As described, this occurrence would not appear to be countable against the PI.
The purpose of the area radiation monitors is to alert personnel to increases in radiation levels. It appears that the personnel responded appropriately to the alarm by exiting the area and notifying health physics, and that proper follow-up actions were then taken with regard to implementing controls as required by the technical specifications. However, the circumstances that led to the increase in dose rates and the resultant dose to the individuals should be evaluated per the criteria for the Unintended Dose element of the PI.
In and of themselves, radiation monitoring equipment alarms are not performance deficiencies. These alarms reflect conditions in the area at the time of use. The NRC evaluates radiation monitoring equipment alarms to determine if their actuation is the result of a performance deficiency. In some cases, these alarms could result from situations that do not meet the definition of a performance deficiency as provided in IMC 0612; in which case the scenario described in FAQ 98 would apply. However, because a performance deficiency had already been established and dispositioned as a self-revealed Green finding and associated NCV 05000251/2023004-06, the NRC concludes that FAQ 98 does not apply in this case.
Planned Closure Actions: In accordance with IP 71151, Performance Indicator Verification, section 03.12, the inspectors are opening an unresolved item (URI) to determine if a performance deficiency exists against 10 CFR 50.9, Completeness and Accuracy of Information.
Licensee Actions: The licensee will submit a FAQ to NEI to determine if this LHRA event constitutes a PI non-conformance.
Corrective Action References: IR 2023004 Failure to Implement Corrective Actions to Prevent Failure of the 3A ICW Pump Motor Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000250/2024004-03 Open/Closed
[P.2] -
Evaluation 71152A The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the licensee's failure to correct a condition adverse to quality which caused the inoperability of a safety component. The 3A intake cooling water (ICW) pump motor failed to start on demand due to a ground in the motor windings caused by moisture, which was attributed to not having functional motor space heaters over a period of two years.
Description:
On August 19, 2023, while Unit 3 was operating at full rated thermal power, the 3A intake cooling water (ICW) pump failed to start on demand from the control room. The Unit entered a 14-day shutdown action statement for an inoperable ICW pump. Inspection of the pump motor interior identified salt contamination and significant moisture. The licensee performed a root cause for the motor failure and determined the moisture contamination in the motor windings was due to extended motor operation in a salt-laden moisture environment without functional motor space heaters. The motor space heaters were determined to be non-functional the entire time the motor was installed, 48 months. The 3A ICW pump was inoperable and unavailable for a total of 9 days to complete repairs and testing.
Prior to August 19, 2023, the licensee had identified the non-functional motor space heaters, a condition adverse to quality, and initiated corrective actions but no work was completed. Specifically, on May 20, 2020, during a preventive maintenance activity on the 3A ICW pump motor, the licensee identified that the motor space heater amperage was not within the functional criteria range. Action request (AR) 2357180 was written and an immediate operability determination assessed the pump was operable. Work order (WO)40722152 was generated to repair the heaters. However, the work was not performed prior to the motor failure. In addition, on August 20, 2021, during replacement of 3A ICW pump motor, the licensee again identified that the motor space heaters were not functioning. AR 2401787 was written, an immediate operability determination assessed the pump was operable, and the pump was returned to service without functioning motor heaters. WO 40790408 was generated to repair the heaters and again the work was not completed prior to the motor failure. The space heaters for the 3A ICW pump motor were non-functional, a condition adverse to quality, from at least May 20, 2020, until the pump motor failure on August 19, 2023. Timely corrective actions were not implemented as there were no additional or interim corrective actions specified to address the non-functioning heaters during this time period, which impacted the long-term reliability of the 3A ICW pump.
Corrective Actions: The licensee added procedural steps to the ICW pump motor daily operator rounds to validate motor heater element lights are on for any idle ICW pump motor.
Corrective Action References: ARs 02467223, 2401787, 2357180
Performance Assessment:
Performance Deficiency: The licensee's failure to implement timely corrective actions to prevent the Unit 3A ICW pump motor failure, due to significant moisture intrusion from non-functional motor space heaters, was a performance deficiency that was within the licensee's ability to foresee and correct and should have been prevented. Specifically, the licensee identified twice that the heater elements in the 3A ICW pump motor were not functional, entered these issues into the corrective action program, and generated work orders to repair the heater elements. However, the work orders were not completed, therefore the ICW pump motor was not protected from moisture intrusions during standby operations which eventually caused the failure of the motor.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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 non-functional motor heaters caused unplanned unavailability of the 3A ICW pump when it failed to start on demand.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using the Mitigating Systems screening questions found in Exhibit 2, section A, the inspectors determined the finding screened to Green, because all screening questions were answered no.
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the organization did not thoroughly evaluate the function of the motor winding heaters to ensure the long-term operability of the ICW pump motors was maintained, as directed by procedure 3-NOP-019, Intake Cooling Water System, Step 2.2.2.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," requires, in part, that conditions adverse to quality, such as deficiencies and non-conformances, are promptly identified and corrected. Contrary to the above, between May 20, 2020, and August 19, 2023, the licensee failed to correct a condition adverse to quality. Specifically, the licensee identified and documented that the 3A ICW pump motor heaters were not functional, a condition adverse to quality, twice, and timely corrective actions to repair the motor heaters was not completed. Consequently, a newly refurbished pump motor was installed on the 3A ICW pump and operated for two years without motor heater protection and eventually failed due to moisture in the windings.
Enforcement Action: This violation is being treated as a non-cited violation, 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 January 16, 2025, the inspectors presented the integrated inspection results to Mr.
Michael Strope, Site Vice President and other members of the licensee staff.
- On November 27, 2024, the inspectors presented the radiation protection, occupational radiation safety, and transportation inspection results to Mr. Michael Strope, Site Vice President and other members of the licensee staff.
- On December 10, 2024, the inspectors presented the inservice 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 requests
2497667
Procedures
0-ONOP-103.3
Severe Weather Preparations
Drawings
5613-M-3062
Safety Injection System
Drawings
5614-M-3013
Instrument Air System
Procedures
4-NOP-013.13
Instrument Air System Valve and Breaker Alignments
Procedures
4-OSP-202.1
Safety Injection/Residual Heat Removal/Accumulators
Flowpath Verification
Drawings
5610-E-1635
Fire Detection/Fire Protection Emergency Diesel Generator
Building 4A/4B
Fire Plans
PFP-4-EDG-18
Unit 4 Emergency Diesel Generator Building
Fire Plans
PFP-4-TB-18
Unit 4 Turbine Building
Fire Plans
Unit 3&4 Auxiliary Building
Fire Plans
Unit 3&4 Control Building
Procedures
0-ADM-016.2
Fire Brigade Program
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-091.7
Fire and Smoke Detection System Annual Test Circuits 5
and 19
2/01/2022
Procedures
0-PMM-030.03
Component Cooling Water Pump Overhaul
Procedures
3-OSP-030.1
Component Cooling Water Pump Inservice Test
Procedures
3-OSP-030.4
Component Cooling Water Heat Exchanger Performance
Test
Corrective Action
Documents
Resulting from
Inspection
Inactive boric acid leak boric acid, white in color, was found
on valve 3-201B follower
10/30/2024
Corrective Action
Documents
Resulting from
Inspection
Potential boric acid, white in color, was found on valve RV-3-
28 drain flange.
10/30/2024
Corrective Action
Corrective action for potential boric acid leak following NRC
10/30/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Walkdown
Corrective Action
Documents
action requests
2497833
Procedures
3-GOP-301
Hot Standby to Power Operation
Procedures
3-GOP-305
Hot Standby to Cold Shutdown
09/12/2023
Procedures
3-ONOP-071.1
Secondary Chemistry Deviation From Limits
Procedures
3-OP-050
Residual Heat Removal System
10/31/2023
Corrective Action
Documents
action requests
2495341, 2491277, 2495967, 2475118, 2474982, 2477439,
2479406, 2485628, 2497860, 2497866, 2490496, 2491844,
2492038, 2491539
Corrective Action
Documents
Resulting from
Inspection
action request
2504216
Engineering
Evaluations
033006-RPT-002
NFPA 805 Monitoring Program Phase 2/3: Screening and
Risk Target Values
Engineering
Evaluations
033006-RPT-003
PTN Basis for NFPA 805 Monitoring Database
Engineering
Evaluations
067-2023-49067
CMF Evaluation for R-3-15
01/10/2024
Engineering
Evaluations
067-2024-50564
CMF Evaluation for R-3-15
08/03/2024
Engineering
Evaluations
EVT-067-2024-
49106
CMF Evaluation for R-3-15
01/05/2024
Procedures
Implementation of the NFPA 805 Monitoring Program
Work Orders
work orders
40960933, 40960299, 40995892, 40925958, 40888922
Corrective Action
Documents
action requests
2503531
Engineering
Evaluations
PTN-BFJR-00-
005
Turkey Point 3&4 On-Line Risk Monitor (OLRM) Model
Procedures
0-ADM-051
Outage Risk Assessment and Control
09/24/2024
Procedures
0-ADM-225
On Line Risk Assessment and Management
2/24/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
3-GOP-100
Fast Load Reduction
Procedures
3-ONOP-087
Turbine Oil Leak/Fire
Procedures
3-ONOP-089
Turbine Runback
Corrective Action
Documents
action requests
2492238, 2494065
Corrective Action
Documents
Resulting from
Inspection
action requests
2500383
Miscellaneous
5610-023-DB-002
Turkey Point Units 3 and 4 Emergency Power System
Component Design Requirements
Miscellaneous
5614-M-313
Turkey Point Unit 4 Setpoint List
104
Procedures
4-ARP-097.CR.F
Control Room Response Panel F
Procedures
4-ARP-097.DG
Diesel Generator Panel Annunciator Response
Procedures
4-PMI-023.2
Emergency Diesel Generator Off Line Instrument Calibration
05/30/2023
Work Orders
work orders
40724303, 40724280, 40805842, 40880713, 40905486,
4095192701, 40858974, 40578022
Corrective Action
Documents
Action Request
2496679
Work Orders
Work Orders
40992847
Corrective Action
Documents
action requests
2497991, 2497994, 2499492, 2500085, 2499567
Engineering
Changes
PTN Units 3 and 4 Storage of Miscellaneous Items in
Containment
Procedures
0-OSP-040.19
Low Power Physics Testing
Procedures
3-SMM-051.03
Containment Closeout Inspection
Procedures
Work Hour Controls
Corrective Action
Documents
action request
2499197, 2500763
Corrective Action
Documents
Resulting from
Inspection
action requests
2499851
Procedures
0-ADM-052
In-Service Testing (IST) Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
0-ADM-539
Inservice Testing - Condition Monitoring of Check Valves
Procedures
0-PME-005.02
Installation of Siemens GER and G.E. Magne-Blast 4KV
Breakers Into Cubicle
Procedures
0-PME-005.22
Testing and Independent Verification of Operational Trip
Test
Procedures
3-GOP-305
Hot Standby to Cold Shutdown
9/12/2023
Procedures
3-OP-050
Residual Heat Removal System
10/31/2023
Procedures
3-OSP-041.4
Overpressure Mitigating System Nitrogen Backup Leak and
Functional Test
Work Orders
work orders
40958578, 40957398, 40880346, 40958644, 40960274,
40805405, 40805410, 40858769
Corrective Action
Documents
action requests
2497138
Miscellaneous
October 2024 ERO Drill Report
Corrective Action
Documents
Corrective Action
Documents
ARs # 2423080,
24733,
27999,
2450686,
2451288,
2455690,
2457395,
2457486,
2477273, and
2488374.
Various
71151
Corrective Action
Documents
ARs 02486483
and 02467086
71151
Procedures
CONDITION REPORTING
Rev. 45
71151
Radiation
Surveys
PTN-M-
230917-9
0-RAB-18, Unit 3 & 4 Demineralizer Galleries / RA
09/17/2023
Corrective Action
action requests
2499829
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Work Orders
work orders
40961506, 40957354, 40987470, 40960275, 40961519,
40956199, 40987488, 40987497, 40987461, 40987479
Corrective Action
Documents
Action Request
2499987, 02490586, 02489095, 02488224, 02488225,
2493449, 02492173, 02492339, 02500852, 02500681
Engineering
Changes
300240
Pedestal Reinforcement for E-17A Compressor
2/04/2024
Work Orders
40997086-02
E-17A HPS Valve, Compressor and Refrigerant
Replacement
11/02/2024
Corrective Action
Documents
action request
2502825
Miscellaneous
Post trip Review Restart Report
2/4/2024
Miscellaneous
Reactor Plant Event Notification
2/04/2024