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	Quarter	Site	Title	Description
05000250/FIN-2013003-01	2013Q2	Turkey Point	Failure to Promptly Identify and Correct a Pressure Boundary Through Wall Leak on the 3A CCW Pump Casing Vent Pipe	The NRC identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct a through wall pressure boundary leak on the 3A component cooling water (CCW) pump casing vent piping that affected system operability. The inspectors determined that the licensees failure to identify and correct a through wall leak on an ASME Code Class pressure boundary was a performance deficiency. The condition was entered in the licensee corrective action program (CAP) as action request 01883690 and the pipe was replaced. The performance deficiency was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the mitigating systems cornerstone attribute of equipment performance and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inspectors determined that the licensees failure to identify a system pressure boundary leak precluded evaluations and repairs necessary to assure the reliability of the component cooling water system. The inspectors evaluated the finding using IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Tables 2 and 3, dated June 19, 2012, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 for the Mitigating Systems Cornerstone, dated June 19, 2012. The inspectors answered yes to the Exhibit 2 question A.1 because the system maintained its functionality. As a result, the inspectors determined the finding to be of very low safety significance (Green). This finding was associated with a cross-cutting aspect in the corrective action program component of the problem identification and resolution area. Specifically, the licensee failed to consider the potential for system pressure boundary leakage when evaluating the operability of the component cooling water system
05000250/FIN-2013003-02	2013Q2	Turkey Point	Licensee-Identified Violation	Turkey Point Unit 3 and 4 Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented as referenced in Florida Power and Light (FPL) Quality Assurance Topical Report (QATR). FPL QATR states that Regulatory Guide 1.33, Quality Assurance Program Requirements, is applicable in establishing procedural controls. Regulatory Guide 1.33 states in part, that safety related activities will be covered by written procedures. Turkey Point instrumentation and controls maintenance procedures 3-SMI-041.11A, Pressurizer Level Protection Operational Test Channel I LT- 459 and 3-SMI-041.104, Pressurizer Level Protection Channel I Loop Calibration LT- 459 both specified the use of a Fluke Model 8842A multimeter designed for the application. Contrary to the above, the maintenance technicians used a Fluke Model 8846A multi-meter which had different impedance characteristics than the Model 8842A and had not been evaluated for use in this application. The operational test with the wrong meter resulted in unsatisfactory results requiring an instrument calibration. The calibration and return to service of the instrument with the incorrect Fluke meter resulted in resetting the instrument set point to 92.262 percent level, which exceeded the technical specification limit of 92.2 percent. This finding is of very low safety significance because it did not affect the function of other systems used to shutdown the reactor, did not add positive reactivity, or result in mismanagement of reactivity by the operators as screened in IMC 0609 Appendix A, Exhibit 2, Section C, Reactivity Control Systems. This event is documented in the licensee corrective action program as action request number 01836648.
05000250/FIN-2013002-01	2013Q1	Turkey Point	Failure to Implement Timely Corrective Actions to Test Molded Case Circuit Breakers	The NRC identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to establish a test program to demonstrate that safety-related 120 VAC and 125 VDC molded case circuit breakers (MCCBs) would be able to reliably perform their intended safety functions, specifically protective tripping. The team identified that since 2005 and 2006, when the lack of periodic testing of the molded case circuit breakers was identified, no interim measures were taken to correct the nonconforming condition. Additionally, the team identified that the licensee failed to scope the protective tripping function of the MCCBs in the maintenance rule program. Upon identification by the team, the licensee entered these issues into their correction action program as ARs 1675539, 1676808, 1788355, and 1852219. As immediate corrective actions, the licensee tested 35 breakers which performed satisfactorily. The results of this testing and an action to develop a long-term test program for the entire 120 VAC and 125 VAC MCCBs were documented in AR 1852219. A license amendment will also be pursued to allow for more TS outage time in order to remove and replace the more difficult MCCBs. The licensees failure to implement prompt and effective corrective actions to ensure that safetyrelated molded case circuit breakers were adequately tested was a performance deficiency. The performance deficiency was more than minor because it adversely affected the mitigating systems cornerstone attribute of equipment performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with NRC Inspection Manual Chapter 0609.04, Initial Screening and Characterization of Findings, the inspectors conducted a Phase 1 Significance Determination Process screening using Exhibit 2 of Appendix A to Manual Chapter 0609 and determined the finding to be of very low safety significance (Green) because it was a qualification deficiency confirmed not to result in the loss of operability or functionality. Because the licensee did not ensure that the necessary resources were available and adequate to maintain long term plant safety through the minimization of preventative maintenance deferrals, this finding is assigned a cross-cutting aspect in the resources component of the human performance area.
05000250/FIN-2013002-02	2013Q1	Turkey Point	Noncompliance with Radiological Barrier	A self-revealing non-cited violation (NCV) of Technical Specification (TS) 6.12.1 was identified when a worker did not comply with a radiological barrier and entered a high radiation area (HRA) without proper authorization. Specifically, the worker entered the HRA without receiving a HRA briefing, and subsequently received a dose rate alarm. Upon identification, the licensee immediately restricted the workers access to the Radiological Controlled Area (RCA). This condition has been placed into the licensees Corrective Action Program (CAP), under Action Request (AR) 01852456. The finding was determined to be more than minor because it was related to the Occupational Radiation Safety cornerstone attribute of Program and Process, and adversely affected the cornerstone attribute to ensure the adequate protection of worker health and safety, because the worker was not made knowledgeable of the radiological conditions. Additionally, the finding was similar to IMC 0612, Appendix E, Example 6.h, which describes an improper entry into an HRA. The finding was evaluated in accordance with IMC 0609, Appendix C, where it was determined to be Green because it did not involve ALARA planning or work controls, was not an overexposure, did not contain a substantial potential for an overexposure, and the ability to assess dose was not compromised. The inspectors determined that this issue had a crosscutting aspect in the Work Practices component of the Human Performance area because the licensee did not communicate radiological conditions to the worker through a pre-job brief.
05000250/FIN-2013002-03	2013Q1	Turkey Point	Willful Violation of Radiological Barrier	A self-revealing Severity Level (SL) IV non-cited violation (NCV) of Technical Specification (TS) 6.8, Procedures, was identified on June 6, 2012, when a worker willfully bypassed a radiological barrier and entered a posted high radiation area (HRA) without proper authorization. Specifically, the worker entered the HRA without receiving a HRA briefing and being issued a key as required by licensee procedure RP-SR-103-1002, High Radiation Area Controls and subsequently received a dose rate alarm. Upon identification, the licensee immediately restricted the workers access to the radiological controlled area (RCA) and placed this issue into the corrective action program (CAP) as action request (AR) 01773513. Due to the willful nature of the workers actions, the inspectors determined the performance deficiency was more than minor in accordance with the guidance contained in Chapter 2 of the Enforcement Manual, Revision 8. This willful finding involved an isolated act of a low-level nonsupervisory individual. It was addressed promptly by appropriate corrective actions, there was no actual safety significance and the underlying technical significance was low. Therefore, the inspectors concluded this finding was Severity Level IV, consistent with Section 2.2.2 of the Enforcement Policy, dated January 28, 2013. There was no cross-cutting aspect because this performance deficiency was dispositioned using traditional enforcement.
05000250/FIN-2013002-04	2013Q1	Turkey Point	Failure to Correct FLOW-INDUCED Vibration Leads to CCW Piping Weld Failures	A self-revealing non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to implement corrective actions that addressed low stress high cycle fatigue of component cooling water (CCW) relief valve RV-4- 747B piping caused by flow induced vibration. As a result, CCW system flow induced vibration resulted in weld cracks and system pressure boundary leakage in November 2012. The licensee repaired the weld failures and installed a pipe support on the line to minimize flow induced vibration on the associated pipe in February 2013 during a scheduled refueling outage. The licensee documented this condition in their corrective action program as action request (AR) 1824939. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to implement corrective actions to address CCW system flow induced vibration resulted in weld cracks and CCW system pressure boundary leakage in November 2012. The inspectors evaluated the finding under the mitigating systems cornerstone and used Inspection Manual Chapter (IMC) 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1, Checklist 4, PWR Refueling Operation, dated May 25, 2004. The inspectors determined the finding was of very low safety significance (Green) because the finding did not require a quantitative assessment of risk significance since each item on the Checklist 4 was met during the time the condition existed and while the 4B residual heat removal (RHR) train was removed from service to repair the weld leak. The finding was associated with a crosscutting aspect in the corrective action program component of the problem identification and resolution area because the licensee did not complete engineering evaluations necessary to support modifications that would prevent CCW system RV-4-747B piping weld failures caused by flow induced vibration.
05000250/FIN-2012005-01	2012Q4	Turkey Point	Failure to Verify 1B Feedwater Heater Drain Valve Closed	A self-revealing finding was identified when the licensee failed to follow procedure 0-ADM-222, Drain and Vent Rig Controls, while installing a temporary drain hose on Turkey Point Unit 4 in-service equipment. Operations and maintenance workers failed to verify a drain line flow path was isolated on the 1B feed water heater prior to removing a pipe valve cap that resulted in an unexpected lowering of condenser vacuum. Operators took action to close the open drain line isolation valve and terminate the plant transient. The licensee captured this condition in their corrective action program as AR 1819010. The licensees failure to verify the closed position of 1B feed water heater drain valve 4- 30-128, as required by procedure 0-ADM-222, prior to removing the pipe cap was a performance deficiency. The inspectors determined the performance deficiency was more than minor using IMC 0612, Appendix B, Issue Screening, because the performance deficiency was associated with the configuration control attribute of the initiating events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to verify the position of 4-30-128 resulted in lowering condenser vacuum that could have led to a reactor trip and the unavailability of the main condenser. The inspectors evaluated the finding using the significance determination process for findings at power of IMC 0609, Appendix A, Exhibit 1, Transient Initiators. The inspectors determined the finding was of very low safety significance (Green) because the finding did not result in a reactor trip and a loss of mitigation equipment relied upon to transition the plant to a stable shutdown condition. The finding was associated with a cross-cutting aspect in the work practices component of the human performance area because the licensee did not define and effectively communicate expectations, or follow the procedural requirement to physically verify valve position during the drain hose installation work.
05000250/FIN-2012011-02	2012Q3	Turkey Point	Inadequate Corrective Actions Following Identification of a NON-CONSERVATIVE Technical Specification	An NRC identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensees failure to take timely corrective action to address a nonconforming condition of Technical Specification (TS) 3/4.5.2 S R4.5.2a. The non-conservative TS was identified and placed in the corrective action program in 2006 as CR 2006-22868. TS 3.5.2 SR 4.5.2a was determined to be non-conservative and the corrective action to submit a TS amendment to address the non-conservative TS was not implemented. The licensee is scheduled to submit the license amendment in the fourth quarter of 2012, as referenced in AR 1790829. The inspectors determined that the licensees failure to timely correct a condition adverse to quality associated with the non-conservative TS was a performance deficiency. The performance deficiency was more than minor because if left uncorrected the failure to implement timely corrective actions has the potential to lead to a more significant safety event in that the unit could be placed in an unanalyzed condition for up to 24 hours. The inspectors determined that the finding was of very low safety significance because there has been no loss of safety system function. The inspectors determined that this finding directly involved the crosscutting area of Problem Identification and Resolution, component of the CAP and an aspect in taking appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity.
05000250/FIN-2012004-01	2012Q3	Turkey Point	Operation at power with Unit 3 feedwater flow transmitter connected incorrectly	A self-revealing, non-cited violation (NCV) of Turkey Point Technical Specification (TS) 3.3.1 Reactor Trip System Instrumentation was identified when process tubing to a Unit 3 feedwater flow transmitter was found incorrectly installed. As a result, one channel of reactor protection was not operable when required. When control room indications of erratic feedwater flow were noted, the applicable technical specification action was entered, bistables were tripped, and the process tubing misalignment was corrected. The problem was documented in the corrective action program as action request (AR) 1800833. Failure to adequately perform maintenance and to verify proper alignment of flow transmitter FT-3-476 process tubing after replacement was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone which ensures the reliability of systems that respond to initiating events, such as the reactor protection system. The finding was screened using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2. Because the finding affected only a single reactor protection system (RPS) trip initiator and other redundant trips or diverse methods of reactor shutdown were not affected, the finding was determined to be of very low safety significance (Green). The finding was assigned a cross-cutting aspect in the Work Practices component of the Human Performance area (H.4.a) because the licensee did not establish human error prevention techniques, such as self and peer checking and proper documentation of activities to prevent incorrect installation of the flow transmitter.
05000250/FIN-2012011-01	2012Q3	Turkey Point	Failure to Translate Design Basis Requirements Into Plant Procedures and Calculations for CCW Heat Balance Equation	An NRC identified non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified for the licensees failure to translate the worse-case total post-accident ICW flow rate for CCW heat exchangers, as documented in calculation PTN-4FSM-04-003 Revision 2, into surveillance, 3/4-OSP-030.4, CCW Heat Exchanger (HX) Performance Test. In addition, the licensee failed to incorporate seasonal salinity variances into calculation PTN-BFJM-96-004, HX3 and HX4 Computer Code Verification. The effects of these two discrepancies was a reduction in maximum allowed canal temperature margin by approximately1.5% or 1.5 degrees Fahrenheit. The licensee entered this issue into their corrective action program (CAP) as Condition Report (CR) 1789995.The failure to maintain the CCW heat balance calculation to ensure the plant could meet their design basis to perform heat removal for normal cool down of the facility, and to mitigate the effects of accident conditions within acceptable limits is a performance deficiency. The inspectors determined that the performance deficiency was more than minor because the calculation errors impacted the Mitigating Systems cornerstone objective to ensure the capability of the CCW system to respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of Design Control. The inspectors determined that this finding did not have a cross-cutting aspect, because the finding was determined not to be indicative of current licensee performance.
05000250/FIN-2012004-02	2012Q3	Turkey Point	Licensee-Identified Violation	The licensee identified that Unit 3 train 2 auxiliary feedwater flow control valve FCV-3- 2832 was rendered inoperable when a maintenance technician installed a cap over the solenoid vent port. The cap was installed after removal of test equipment. Turkey Point Technical Specification 6.8.1 requires that procedures required by the FPL Quality Assurance Topical Report (QATR) be maintained and implemented. The topical report includes procedures for control of maintenance and specifies that maintenance procedures contain instructions in sufficient detail to permit maintenance work to be performed correctly. The licensee met this requirement, in part, with work order 40181373-01, written for the investigation and testing of train 2 auxiliary feedwater flow control valve (FCV-3-2832) following observed erratic operation. After the testing was completed, the work order required the maintenance technician to un-install the test equipment. Contrary to the above, on September 18, 2012, work order 40181373-01 did not contain instructions in sufficient detail to un-install the test equipment correctly, and a technician mistakenly placed a cap over a solenoid vent line for FCV-3-2832, making the valve unable to close after being opened by an actuation signal. The error was discovered by the licensee during a planned auxiliary feedwater test conducted the next day. When discovered, the licensee entered the appropriate technical specification action, removed the cap to restore operability to the valve, and demonstrated operability by completing a surveillance test. The inspectors evaluated the event using NRC Inspection Manual 0612, Power Reactor Inspection Reports; Inspection Manual Chapter 0609.04, Initial Characterization of Findings; and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2. The performance deficiency was more than minor because it was associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. The finding was screened as being of very low safety significance (Green) when all screening questions in IMC 0609 Appendix A were answered no . Because this violation was of very low safety significance and was entered in the licensees corrective action program as AR 1804442, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
05000250/FIN-2012003-01	2012Q2	Turkey Point	Failure to Perform an Analysis for the Permanent Removal of Main Steam Pipe Whip Restraints	The inspectors identified a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to perform an analysis for the removal of the Unit 3 main steam pipe whip restraints. These restraints are credited for mitigating high energy line breaks with a potential consequence of an unrestrained pipe break outside of containment. The licensee entered the issue into the corrective program as action request AR1757120 and revised the modification package to reinstall the pipe whip restraints prior to Unit 3 start-up. The team determined that the licensees failure to perform an analysis, as required by procedure ENG-QI 1.0, Design Control, for the permanent removal of main steam pipe whip restraints is a performance deficiency. The performance deficiency was more than minor because it affected the Mitigating Systems cornerstone attribute to ensure the availability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the lack of pipe whip restraints would adversely affect the capability of equipment required to mitigate high energy line break events. The team screened the finding in accordance with IMC 0609, Significance Determination Process, Attachment 4, Phase 1-Initial Screening and Characterization of Findings, and determined the finding was of very low safety significance because it was a design deficiency confirmed not to result in a loss of safety function, since the deficiency was identified and corrected before the modification was implemented. The team identified a crosscutting aspect in the decision making component of the human performance area.
05000250/FIN-2012003-02	2012Q2	Turkey Point	Licensee-Identified Violation	TS 6.12.2 requires, that each High Radiation Area (HRA) with dose rates greater than 1000 mrem/hour at 30 centimeters shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry. Contrary to the above, on April 28, 2012, while performing assigned locked high radiation area door checks in the Unit 3 containment, a Senior RP Technician identified the Unit 3 reactor sump area door could be partially opened due to the placement of the padlock and chain near the hinge. Immediate corrective actions were taken upon discovery and documented in AR01760652. The violation was evaluated using the Occupational Radiation Safety Significance Determination Process and was determined to be of very low safety significance (Green) because this finding did not involve ALARA planning or work controls, was not an over-exposure, did not have a substantial potential for overexposure, and the ability to access dose was not compromised.
05000250/FIN-2012002-01	2012Q1	Turkey Point	Emergency lighting to auxiliary feedwater area disabled	The inspectors identified a non-cited violation of the Units 3 and 4 operating licenses condition 3.D, Fire Protection, when the licensee failed to provide emergency lighting in the common auxiliary feedwater (AFW) cage and other areas. The electrical panel that supported normal lighting in the area was taken out of service for maintenance thus placing the emergency lights on battery power until the batteries depleted and the areas became dark, impacting the ability of operators to complete manual actions in the area, if needed. The licensee documented the issue in the corrective action program (CAP) as AR 1738082. The inspectors determined that the failure to provide emergency lighting in areas requiring local manual actions to safely mitigate certain fire events, and the associated access/egress routes, was a performance deficiency. The issue was more than minor because the objective of the Mitigating System Cornerstone to ensure the availability of fire protection equipment was affected when emergency lighting was not provided. The inspectors assessed the finding using NRC Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, and assigned a low degradation rating because of the reasonable likelihood that plant operators would obtain alternate lighting and complete the prescribed manual actions. The finding screened as having very low safety significance. The cross cutting aspect of Work Control Planning, (H.3(a)), was assigned because the licensee did not use risk insights, did not assess environmental conditions (lighting) that may have impacted human performance, and did not plan for contingencies nor compensatory actions when the normal lighting was removed from service leading to loss of emergency lighting
05000250/FIN-2012002-02	2012Q1	Turkey Point	Control power cables repeatedly submerged in ground water, contrary to design	A self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified when FPL did not maintain safety-related power cables in the environment for which they were designed and tested. Specifically, 125 volt DC control power cables feeding various safety related components and cables supporting other risk significant equipment had been repeatedly submerged in ground water for extended periods of time and this submergence had the potential to affect the ability of the cables to perform safety related functions. The issue was entered into the licensees CAP as AR 1717619. Although predominantly Unit 3 cables were submerged, because equipment is shared, both units were affected. Allowing water accumulation in the manhole(s) after disabling of the sump pump without compensatory measures to keep the safety related and risk significant cables dry resulted in subjecting the cables to an environment for which they were not designed, and was a performance deficiency. The finding was more than minor because it challenged the reliability of systems that respond to initiating events to prevent undesirable consequences, which is an attribute of the Mitigating Systems cornerstone. The inspectors evaluated the finding in accordance with IMC 0609.04, Phase 1, Initial Screening and Characterization of Findings. The finding was of very low safety significance because it did not represent an actual loss of safety function or contribute to external event core damage sequences. The finding had a cross-cutting aspect in Problem Identification and Resolution, Corrective Action Program, (P.1(c)), because FPL did not thoroughly evaluate submerged cables such that the resolutions addressed causes and extent of conditions, including evaluating for operability.
05000250/FIN-2012002-03	2012Q1	Turkey Point	Licensee-Identified Violation	The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for disposition as an NCV. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization. FPL implements this requirement, in part, with procedure ENG-QI 1.7, Quality Instruction Design Input/Verification, which states engineering methods employed shall ensure that design inputs are correctly translated into new designs and design changes, and that design verification activities are correctly performed. Contrary to the above, engineering methods employed did not ensure that design inputs were correctly translated into the A auxiliary feedwater pump design change nor were design verification activities correctly performed on engineering design change package PCM 2005-029. As a result, on February 3, 2012, during a design review while developing a modification package for the A auxiliary feedwater pump, FPL identified a design calculation error in the 2005 modification package for the A auxiliary feed water pump. The pump modification raised the pump power requirements. The revised design horsepower output specified for the turbine accounted for the increased pump power demand, but failed to account for recirculation flow, turbine lube oil coolers flow, and instrument uncertainties. When identified by FPL, a prompt operability determination was completed. FPL determined that although there was a reduction in margin, the required auxiliary feed water turbine horsepower remained bounded by vendors design limits. This issue was entered into the corrective action program as AR 1731117. The finding was screened as having very low safety significance (Green) using NRC Inspection Manual Chapter 0609 SDP Phase 1 screening because the finding did not result in an inoperable auxiliary feedwater pump, did not affect functionality of the system, and the design basis continued to be met.
05000250/FIN-2011005-03	2011Q4	Turkey Point	Failure to make a required 8 hour NRC report for major loss of emergency assessment capability	The inspectors identified an Apparent Violation of 10 CFR 50.72(b)(3)(xiii) when a major loss of emergency assessment capability was not reported to the NRC within 8 hours. The TSC ventilation system was identified as being in a degraded condition from December 4, 2010 until July 13, 2011, affecting the habitability of the TSC for emergency responders, and the occurrence was not reported. The issue was identified to the licensee by the inspectors after review of NRC Event Notification 47387. The finding was more than minor because it impacted the NRCs regulatory process, which relies on certain events being properly reported to the NRC. Because this finding impacted the regulatory process, it was evaluated using traditional enforcement and is being considered for escalated enforcement action in accordance with NRCs Enforcement Policy. No cross-cutting aspect associated with this issue was identified.
05000250/FIN-2011005-02	2011Q4	Turkey Point	Failure to maintain TSC habitability	The licensee identified an Apparent Violation (AV) of 10 CFR Part 50.54(q), for failure to follow and maintain in effect emergency plans which require that adequate emergency facilities and equipment to support the emergency response are provided and maintained. Specifically, during the periods from December 4, 2010 to July 13, 2011, and from October 10 to October 28, 2011, the licensee failed to maintain a fully functional Technical Support Center when portions of its ventilation system were removed from service without compensatory measures. As a result, had the facility been required, personnel assigned to respond in the TSC would not have been protected from radiological hazards that would occur in some accidents. The licensee documented this issue in their corrective action program as AR 1701357. The finding was more than minor because it affected the Emergency Preparedness Cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The Emergency Preparedness cornerstone was affected in that during the time the Technical Support Center was not functional, it did not meet 10 CFR 50.47(b)(8) Planning Standards program elements in that personnel assigned to the TSC during an emergency may not have been protected from radiological hazards. This finding was evaluated in accordance with Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Section 4.8 and Emergency Preparedness Significance Determination Process, Sheet 1, Failure to Comply, and determined to be a finding of low to moderate safety significance (White) because there was a loss of the planning standard. The two events, December 2010 to July 2011, and October 2011, were assessed as a single finding with a common performance deficiency. The cause of the finding is related to the Problem Identification and Resolution cross-cutting area, in that the licensee did not thoroughly evaluate problems with the TSC ventilation system as necessary, including properly classifying, prioritizing, and evaluating for operability and reportability, conditions adverse to quality.
05000250/FIN-2011005-01	2011Q4	Turkey Point	Failure to Correct Valve Deficiency Results in Both Headers of Intake Cooling Water Inoperable	A self-revealing non-cited violation of 10 CFR 50 Criterion XVI was identified when the licensee failed to repair a degraded butterfly valve in the Unit 3 intake cooling water system. On August 11, 2011, failure of this valve led to a loss of intake cooling water (ICW) flow to the component cooling water heat exchangers. The licensee documented the failure in their corrective action program as AR 01680272 and initiated a cause investigation. An NRC special inspection of this occurrence was documented in NRC Inspection Report 05000250/2011013. The licensees failure to take prompt corrective actions for a degraded valve, though it had been identified in 2007 as vibrating excessively, was a performance deficiency. This performance deficiency was considered more than minor because it could be reasonably viewed as a precursor to a significant event, the loss of all intake cooling water. A Senior Reactor Analyst in a Phase 3 risk assessment, determined the increase in risk to either unit was of very low risk significance i.e., Green. Unit 3 risk was assessed because the event occurred on that unit; however Unit 4 risk was also assessed because the same vulnerability existed on the ICW valves on that unit (e.g., similar design, maintenance history, etc.). The main contributors to the low risk results were: 1) the recovery probability of the ICW system, given the extended time available to operators before a RCP seal LOCA could occur; and 2) the multiple redundant sources available to cool the core should the CCW system fail. The dominant core damage scenarios were valid demands for a reactor trip followed by the failure to recover ICW proceeding to a RCP seal LOCA and core damage. The inspectors determined that the cause of this finding was related to the Problem Identification and Resolution cross cutting area when the licensee failed to take appropriate corrective action to address safety issues (valve fluttering) in a timely manner, commensurate with the safety significance.
05000250/FIN-2011008-02	2011Q3	Turkey Point	Molded Case Circuit Breaker Testing	The age range of approximately 511 safety-related MCCBs at Turkey Point is twenty to forty years - some are original plant equipment, some were installed in the 1980s, and the remainder in the early 1990s. With the exception of bench testing prior to installation, no testing/maintenance has been performed on the breakers. MCCBs are susceptible to age related failures such as, overheating due to loose connections and long term grease hardening. Overheating can exceed material temperature ratings, distort motor control center case and operating mechanism tolerances, and result in hardening/baking of grease. Long term grease hardening can result in the breaker failing to open or a delay in opening during a downstream electrical fault. NRC Information Notice (IN) 93-64, Periodic Testing and Preventive Maintenance of Molded Case Circuit Breakers, states, in part: MCCB preventive maintenance practices can mitigate the effects of aging and help ensure continued MCCB reliability, and that certain standard MCCB tests (such as individual pole resistance, 300 percent thermal overload and instantaneous magnetic trip tests) performed periodically were found effective along with the additional techniques of infrared temperature measurement and vibration testing. Also, EPRI NP-7410, Section 7.3.1, states, that ensuring that all MCBs are periodically exercised is considered a vital part of a maintenance program, applicable to all breakers regardless of their safety classification. In addition, EPRI/NMAC NP-7410-V3, Section 7.3.1, states that safety related MCCB cycling/trip testing should be performed on a 4 to 6 year frequency. In 2005 and 2006, during Turkey Points preventive maintenance optimization (PMO) project, the licensee identified the lack of a testing program for safety-related 120vac and 120vdc MCCBs which resulted in the creation of a preventative maintenance (PM) program for the breakers. The PMs for the 120Vac breakers were to include a periodic inspection and electrical test to verify functionality. The PMs for the 125Vdc breakers were to replace each individual breaker. However, the licensee suspended the PMs, in part, because of scheduling challenges associated with Technical Specification (TS) restrictions the TS has a two hour action statement associated with the deenergization of the ac or dc load centers. In 2008, in response to the cancelled PMs, CAR 08-069 was created and assigned as a Turkey Point Excellence (TPE) project. TPE considered several options, and decided on a one-time replacement of the vital 120Vac and 125Vdc breakers. In 2010, the licensee initiated AR 1649834 because the funding for the TPE project was terminated. This AR created a new long term asset management initiative to re-target the project in future years. In 2011, ECR 1657020 was created for a one-time replacement of the MCCBs and entered into the licensees long term asset management program (PTN-11-0177 (U3) and PTN -11-0179(U4). The team identified that since 2005/2006 when the lack of periodic testing of the MCCBs was identified; no interim measures were taken to correct the nonconforming condition. Specifically, on multiple occasions since 2005, the licensee failed to take adequate actions to ensure the reliability and capability of the MCCBs to perform their design function while pursuing long term strategies. Additionally, the team identified that the licensee failed to scope the protective tripping function of the MCCBs in the Maintenance Rule program. These issues were entered into the licensees corrective action program as ARs 1675539 and 1676808 which include developing an interim strategy that is to consider visual inspections augmented by thermography, planned cycling, and testing of the MCCBs.
05000250/FIN-2011004-02	2011Q3	Turkey Point	Licensee-Identified Violation	TS 3.3.3.3(a) requires, in part, the accident monitoring instrumentation channels shown in Table 3.3-5, including the main steam line (MSL) high range-noble gas effluent monitor, to be operable. Contrary to this, on October 1, 2010, licensee evaluation of design bases for the proposed replacement of the MSL high range-noble gas effluent monitor common to Units 3 and 4, i.e., Radiation Monitor (RAD)-6426 with Data Acquisition Monitor (DAM)-1 and High Range Noble Gas Detector Assembly SA-9, determined that the current configuration of the sample line and monitor system failed to meet the TS operability requirements. Specifically, the licensee determined that noble gas samples collected from each of the U3 and U4 steam lines would not be representative of noble gases released from the MSL safety valves and/or atmospheric dump valves during postulated emergency plan scenarios. Further, licensee evaluations indicated that the subject monitoring system had not met the TS requirement since it was installed in 1981. The inspectors determined that this finding is more than minor. Initial NRC concerns and licensee commitment for proposed sampling and estimating noble gas quantities released via steam pathways in accordance with NUREG 0578 were documented in letters dated March 10, 1980, March 28, 1980, and August 20, 1980, from Robert E. Uhrig, Vice President, Florida Power and Light to the Office of Nuclear Reactor Regulation Projects and Licensing Offices. The inspectors noted that the subject correspondence documented that subsequent to installation, operating tests were to be conducted for the purpose of correlating noble gas activities in steam samples with flow out of the system through the MSL safety relief or atmospheric dump valves to demonstrate proper operation. However, licensee representatives stated that their reviews of monitor operability determined that neither test records nor other correlation data were found which demonstrated completion of the proposed initial operating tests for the installed monitoring system. The inspectors noted that proper oversight and review of those initial post startup tests, if conducted, potentially could have identified the design inadequacies subsequent to sample line and monitoring systems installation. Further, the inoperable monitor had a credible impact on equipment maintained to support emergency response dose calculation capabilities in accordance with Emergency Plan Implementing Procedure 20126, Offsite Dose Calculations. The finding was considered to have very low safety significance (Green) because the licensee had alternate methods for estimating effluent releases from the MSL atmospheric dump and/or release valves. This issue and corrective actions were documented in the licensees corrective action program as Condition Report (CR) Numbers 572823, 585330, and 596361.
05000250/FIN-2011004-01	2011Q3	Turkey Point	Failure to control defective component results in safety system surveillance failure	A Self-revealing Non-cited violation of Technical Specification requirements was identified for failure to implement procedures to control a defective component and prevent its use in a safety-related system. Specifically, the licensee installed a solenoid valve, known to be defective in the valve actuator for the Unit 3 B emergency containment cooler and the valve subsequently failed a surveillance requirement. The issue was documented in the licensees corrective action program as CR1682798 and corrected by replacing the defective solenoid valve prior to returning the system to service. The failure to identify and control the solenoid valve after having received information that the valve was defective was a performance deficiency. The performance deficiency was determined to be more than minor because it adversely affected the safety related emergency containment cooler system which is used to protect the public from radionuclide releases caused by accidents. The finding was screened using IMC 0609, Significance Determination Process (SDP), Attachment 0609.04 for the Containment Barrier and was screened as of very low safety significance (Green). The inspectors determined that the cross-cutting aspect of Problem Identification and Resolution was affected when the licensee did not identify the defective component in the corrective action program in a timely manner after having received notification from the vendor of a component defect.
05000250/FIN-2011003-01	2011Q2	Turkey Point	Failure to properly perform a procedure results in damage to an RHR pump	A self-revealing, non-cited violation (NCV) of Technical Specifications 6.8.1.a, Procedures, was identified when operators did not properly align the RHR system from shutdown cooling mode to injection mode. As a result, the 4A RHR pump was left running with no suction source causing a failure of the pump mechanical seal and minor flooding in the Unit 4, A RHR pump room. The pump was not available for either injection or shutdown cooling operations until the seal was replaced. The issue was documented in the corrective action program as AR 1644427 and a root cause investigation was initiated. Failure to properly align the RHR system to the injection lineup was contrary to plant procedures and was a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System Cornerstone and resulted in damage to an RHR pump. The finding was screened using IMC 0609, Appendix A, Phase 1, and because there was no loss of safety function with the alternate RHR pump remaining operable, the finding was determined to be of very low safety significance. The finding affected the cross-cutting area of Human Performance, Work Practices because personnel did not adequately implement error prevention techniques, such as pre-job briefings, self and peer checks, and proper documentation of activities
05000250/FIN-2011002-03	2011Q1	Turkey Point	None	Technical Specification 5.2.1.f requires the containment steel liner to have a nominal thickness of 0.25 inches. Contrary to the above, on October 22, 2010, during a planned inspection, FPL found corrosion in the lower liner plate at the -15 foot level with areas of the liner to be below 0.25 inches. The liner was backed by concrete and no direct path to the environment was identified. FPL repaired the liner and planned to recoat the lower cavity area in a future outage. FPL contracted an evaluation of the liner holes to radiological consequence of an accident and found the contribution to dose from the degradation to be negligible. The finding was screened as Green using NRC Inspection Manual Chapter 0609, Attachment 0609.04, SDP Phase 1 screening because the finding did not result in any loss of containment barrier function.
05000250/FIN-2011002-02	2011Q1	Turkey Point	None	10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances. Contrary to the above, on September 21, 2010, an unplanned reactor trip occurred while the quarterly surveillance for the Channel II High Pressurizer Pressure Protection Loop (P-4-456) was in progress. The licensee determined the root cause to be inadequate inspection and installation criteria used for ELCO connectors because acceptance criteria and method of verification where not addressed by procedures. The issue was screened to be of very low safety significance (Green). When identified, the licensee took corrective actions to add ELCO connector inspection requirements to a plant procedure and conduct formal training for maintenance personnel to properly inspect and mate connectors. The issue was documented in AR 00581322. Because the licensee identified the issue and documented it into their corrective action program, and because the finding is of very low safety significance, this violation is being treated as a licensee identified NCV consistent with the NRC Enforcement Policy.
05000250/FIN-2011002-01	2011Q1	Turkey Point	Failure to Monitor a Reactivity Change Results in Power Operation Above 100 Percent	The inspectors identified a non-cited violation (NCV) of Technical Specifications 6.8.1.a, Procedures, when operators did not adequately monitor reactor power nor the position of valve TC-3-144A, a valve which affects reactivity, during a letdown valve inservice test. As a result, the Unit 3 hourly average reactor power increased above 100 percent for about 40 minutes. When identified to the licensee by the inspectors, the issue was documented in the corrective action program as AR 1643603. Failure to maintain positive control of reactor power was contrary to plant procedures and was a performance deficiency. The issue was more than minor because it resulted in reactor operation at 100.05 percent power for about 40 minutes. The finding involved configuration control affecting reactivity and was assigned to the Barrier Integrity Cornerstone. In accordance with screening criteria in IMC 0609, Appendix A, Phase 1, for degraded fuel barrier, the issue screened as Green. The finding was determined to be of very low safety significance because throughout the incident, thermal power remained bounded by the reactor safety analyses limit of 102% and no safety limits were exceeded. The finding affected the cross-cutting area of Human Performance, Work Practices, (H.4(a)) when operating personnel were not aware of reactor status, and human error prevention techniques, such as holding pre-job briefings, self and peer checking, and proper documentation of activities were not adequate to assure plant activities were properly performed.
05000250/FIN-2010005-04	2010Q4	Turkey Point	Inadequate implementation of corrective actions fail to correct a condition adverse to quality	The inspectors identified an NCV of 10 CFR, Part 50, Appendix B, Criterion XVI, for the licensees failure to implement timely corrective actions to address conditions adverse to quality on the Unit 3 fuel handling manipulator crane. As a result, a lack of calibration on the manipulator crane load cell affected fuel handling interlock setpoints that protect the fuel during fuel handling activities. In addition, an inadequate testing procedure led to a procedure change implemented in the field without proper review and approval. The licensee entered this violation in their corrective action program as AR 592683. Although the event occurred on Unit 3, similar procedures existed on Unit 4. The inspectors determined that the licensees failure to implement timely corrective action for lack of calibration on the manipulator crane load cell affecting fuel handling interlock setpoints and other deficiencies to be a performance deficiency. The finding was greater than minor because the Barrier Integrity Cornerstone was affected which provides reasonable assurance that physical design barriers protect the public from radionuclide releases. The finding affects the attributes of configuration control and procedure quality. The inspectors evaluated the finding using Manual Chapter 0609 SDP Phase 1 and determined that it was of very low safety significance because there were no actual challenges to the fuel barrier. The finding had cross-cutting aspect in the area of problem identification and resolution (P.1(d)) because the licensee failed to implement prescribed corrective actions to address adverse trends in a timely manner when the load cell interlock setpoints drifted.
05000250/FIN-2010005-03	2010Q4	Turkey Point	Welders failed to measure preheat and interpass temperatures	The inspectors identified a Non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings associated with licensee contract personnels failure to adhere to welding procedures during the 2010 Unit 3 refueling outage. Specifically, welders failed to measure preheat and interpass temperatures in ASME safety class containment spray pump lines using contact pyrometers, thermocouples, or temperature indicating crayons as required by procedure. As part of the immediate corrective actions, the licensee conducted a stand-down for welders to reinforce procedural compliance expectations. The licensee performed an extent of condition evaluation and entered the issue into their corrective action program as AR 585550. The inspectors determined that the finding was more than minor because if left uncorrected, it would have become a more significant safety concern. Specifically, the failure to adhere to the welding procedures for temperature measurement affected the assurance that appropriate welding temperatures were maintained. Inadequate temperatures during welding can result in stainless steel sensitization and susceptibility of the weld to failure from intergranular stress corrosion cracking (IGSCC) affecting the containment spray system. The inspectors also determined that this finding impacted the Barrier Integrity Cornerstone human attribute and affected the cornerstone objective of ensuring the physical barriers protect the public from radionuclide releases caused by accidents. The finding was determined to be of very low safety significance because the finding did not result in an actual loss of operability or functionality of containment spray system per Table 4a, NRC Inspection Manual Chapter 0609, Attachment 4. The cause of the finding is related to the cross-cutting aspect of Human Performance, Work Practices (H.4(c)), because licensee personnel failed to ensure supervisory and management oversight activities of their contractors such that nuclear safety was ensured.
05000250/FIN-2010005-05	2010Q4	Turkey Point	Licensee-Identified Violation	Turkey Point Technical Specification 6.8.1.a, states that written procedures required by the Quality Assurance Topical Report (QATR) shall be implemented. The QATR commits to use the procedures in Appendix A of Regulatory Guide 1.33, which includes in Section 1.c, Equipment control (tagging). FPL implements this requirement, in part, with procedure 0-ADM-212.1, Operations In-plant Equipment Clearance Orders, which requires in Step 5.1.9, that Prior to approving an equipment clearance order, it shall be determined the impact on equipment availability to meet technical specifications. Contrary to the above, during preparation and execution of equipment clearance order 3- 10-01-001, for the Unit 3 high head safety injection system, the impact on equipment available to meet Unit 4 Technical Specifications requirements was not determined prior to approval. As a result, while implementing the clearance order, the Unit 4 high head safety injection system was rendered inoperable for a period of 36 minutes, until the manual isolation valve 3-867 was shut, as required by the clearance. The technical specification impact, diversion of Unit 4 high head safety injection to Unit 3 and entry of Unit 4 into TS 3.0.3 for 36 minutes, was determined after the clearance was implemented. When identified by the licensee during operator surveillance of control room indications, the manual valve was promptly shut in accordance with the clearance. The event was documented in the corrective action program as AR 584026 and an investigation was initiated. A regional Senior Reactor Analyst evaluated the performance deficiency under the Phase 3 protocol of the Significance Determination Process. Based upon the results of this evaluation, the performance deficiency was characterized as of very low safety significance (Green). The NRCs most current Probabilistic Risk Assessment model for Turkey Point was used to perform the evaluation. The basic event for the common cause failure of the High Head Safety Injection valves, 843A and B, was set to always occur in the model as the surrogate for the performance deficiency. The major evaluation assumptions included a one hour exposure time and no potential to re-position either of the two valves during the exposure time. The dominant accident sequence was a Small Break Loss of Coolant Accident followed by operators failing to use the High Head Safety Injection hot leg injection path, given a failure of the cold leg injection path due to the performance deficiency.
05000250/FIN-2010005-02	2010Q4	Turkey Point	Scaffold blocked access to fire areas used in a control room evacuation event	The inspectors identified a Non-cited violation (NCV) of Turkey Point License Condition 3.D, Fire Protection, when scaffolding was placed as a barricade against personnel access to doors to fire zones 108B and 104. The barricade impeded access to the 3B and 3A DC Equipment rooms through doors that are used in the event of a control room evacuation event and may have delayed or prevented operator actions to mitigate a potential fire. When identified to the licensee, the scaffolding was promptly removed and the problem was documented in AR 594112. The issue was more than minor because the objectives of the Mitigating Systems Cornerstone were affected. Using NRC Manual Chapter 0609, Appendix F, the inspectors assigned a moderate degradation rating to the deficiency because of the likely inability of the plant operators being able to implement the procedural actions within the licensee stipulated time. A regional Senior Reactor Analyst evaluated the performance deficiency under the Phase 3 protocol of the Significance Determination Process. Based upon the results of that evaluation, the performance deficiency was characterized as of very low safety significance (Green) for both units. The evaluation was performed via hand calculation using elements of NRC Manual Chapter 0609, Appendix F, NUREG-6850 as amended by Frequently Asked Questions under the National Fire Protection Association 0805 pilot program. A simplified Reactor Coolant Pump (RCP) seal Loss of Coolant Accident (LOCA) failure probability based upon Westinghouse high temperature seals was used. Key human failure probabilities were estimated using standard techniques. Conditional core damage probabilities, due to a spurious Safety Injection, were derived from the licensee\'s most current model results. Major assumptions and dominant accident sequence for Units 3 and 4 were discussed and included in analysis section of 1R05 in the inspection report. The cause of the finding was related to the cross-cutting aspect of Human Performance, Work Control (H.3(a)) when the scaffold-barricade was constructed without a planned contingency or compensatory measure to assure that the fire mitigation activity could be accomplished within design time constraints.
05000250/FIN-2010005-01	2010Q4	Turkey Point	Inappropriate procedure guidance results in degradation of boration flow path and loss of charging flow	The inspectors identified a Non-cited violation (NCV) of Technical Specification 6.8.1, Procedures, when plant alarm response and off-normal procedures were not adequate to prevent lifting of a charging relief valve. As a result, during operations to assure adequate seal injection flow, a charging throttle valve was shut causing lifting of a charging system relief, diversion of charging flow, and degradation of the boration flow path. When identified to the licensee by the inspectors during review of charging system anomalies, the licensee documented the occurrence in the corrective action program as CR 595200 and upgraded procedures. Although the event occurred on Unit 3, similar procedures existed on Unit 4. While attempting to regulate RCP seal injection flow, operators shut charging throttle valve HCV-3-121. This was a performance deficiency, in that it caused lifting of the charging relief valve(s), diversion of charging flow, and subsequent failure of a charging relief valve. The relief valve failure reduced the reliability of charging flow to the loops and affected the ability of the charging system to perform its design functions including providing for reactivity control, maintaining the proper water inventory in the reactor coolant system, and providing RCP seal injection flow. The issue was more than minor. The finding was screened as Green using NRC Inspection Manual Chapter 0609, Attachment 0609.04, SDP Phase 1 screening because the finding did not result in any loss of function, with some level of charging or seal flow remaining throughout the event. All screening questions were answered No. The Mitigating Systems cornerstone was affected when charging capability and the boration flow path was degraded by diversion of flow through the relief valve back to the charging pump suction. The finding affected the cross-cutting aspect of Human Performance, Resources, when operating procedures did not adequately provide accurate guidance to prevent mis-operation (shutting) of the charging throttle valve.
05000259/FIN-2010006-05	2010Q3	Browns Ferry	Failure to maintain an Adequate Surveillance Procedure to Prevent an Unplanned HPCI Isolation	The inspectors identified a self-revealing non-cited violation of Technical Specifications 5.4.1.a, Procedures, for an inadequate surveillance procedure used to test High Pressure Coolant Injection (HPCI) pressure switches that led to an unplanned HPCI system isolation and HPCI system being declared inoperable. This finding was entered into the licensees corrective action program as PER 239313. The inspectors determined the failure to establish an adequate procedure used for connecting and disconnecting VOMs during testing of pressure switches on the HPCI system was a performance deficiency. The performance deficiency was more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective in that the licensee did not ensure reliability and availability of the HPCI system to respond to initiating events to prevent undesirable consequences. The inspectors determined the finding was of very low safety significance because HPCI was out of service for a total of about 12 hours and did not exceed its TS allowed outage time per TS 3.5.1.c. The inspectors determined that this finding directly involved the cross-cutting area of Human Performance, component of Resources and aspect of Complete Documentation because the licensee failed to provide an adequate procedure to perform the HPCI surveillance test.
05000259/FIN-2010006-01	2010Q3	Browns Ferry	Failure To Correct The EECW Valves Throttled Below Analyzed Condition	The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to adequately evaluate and take prompt corrective actions to address a condition adverse to quality related to two Emergency Equipment Cooling Water (EECW) system flow control valves determined to have been throttled below the analyzed 0.125 inch gap for a period of approximately three months. This condition restricted the flow to the cooler due to flow blockage which could have resulted in inoperability of the downstream safety-related Core Spray (CS) pump room heat exchangers. This finding was entered into the licensees corrective action program as PER 257029. The inspectors determined that the licensees failure to promptly address an identified deficiency associated with safety related equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of the Core Spray system to respond to initiating events to prevent undesirable consequences; (i.e., core damage) , since it resulted in 2 valves in the core spray system remaining throttled below their analyzed seat to disc clearance for several months after the licensee became aware of this condition, thus subjecting these valves to an increased likelihood of clogging with debris and affecting the reliability of the system. The inspectors determined that the finding was of very low safety significance because the finding was not a design deficiency, did not result in an actual loss of system or single train function, and was not potentially risk significant due to external events. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the Corrective Action Program and aspect of Through Evaluation of Identified Problems because the licensee did not perform a thorough evaluation of identified problems such that the resolutions address causes and extent of conditions.
05000259/FIN-2010006-06	2010Q3	Browns Ferry	Inadequate Maintenance Procedure for Siemens Horizontal Vacuum Circuit Breakers Circuit Breakers	The inspectors identified a non-cited violation of Technical Specification (TS) 5.4.1 for the licensees failure to have adequate preventative maintenance procedures for Siemens Horizontal Vacuum Circuit Breakers. Plant procedure EPI-0-000-BKR015, 4KV Wyle/Siemens Horizontal Vacuum Circuit Breaker (Type-3AF) and Compartment Maintenance, Revision 28, did not provide specific guidance for checking the tightness of the closing spring charging motor mounting bolts. As a result, on June 15, 2010 while the 3C RHR pump was in service for suppression pool cooling, the charging motor in the pump breaker cubicle became detached from its mount. The charging spring failed to recharge and the pump would not have restarted if needed following a trip of the circuit breaker. The licensee reattached the charging motor and restored the 3C RHR pump to service. The licensee also revised procedure EPI-0-000-BKR015 to include instructions for ensuring the charging motor was securely fastened to the circuit breaker. This finding was entered into the licensees corrective action program as PER 234443. The inspectors determined that the failure to have an adequate maintenance procedure for circuit breaker maintenance was a performance deficiency. This performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Procedure Quality and adversely affected the cornerstone objective in that the PM procedure for the breaker did not assure the 3C RHR pump could perform its intended safety functions. The inspectors determined that the finding was of very low safety significance because it did not result in inoperability of a safety function for greater than the allowed technical specification outage time and was not potentially risk-significant due to external events. The inspectors determined that this finding directly involved the crosscutting area of Human Performance, component of Resources and aspect of Complete Documentation because the licensee did not maintain adequate plant procedures for equipment maintenance. Specifically, procedure EPI-0-000-BKR015, Revision 28 did not contain guidance for checking the charging motor bolt tightness resulting in the 3C RHR pump charging motor becoming detached and adversely affecting train operability.
05000259/FIN-2010006-02	2010Q3	Browns Ferry	Failure to Implement the Provisions of Preventative Maintenance (PM) Program Which Contributed to a Manual Reactor Scram	The inspectors identified a finding for the licensees failure to implement the applicable provisions of the Tennessee Valley Authority (TVA) Preventative Maintenance (PM) Program to replace the coil in the solenoid valve controlling the opening of the Unit 3 Condensate Demineralizer bypass valve on the specified PM frequency. Failure of this coil was identified as a contributing cause in Root Cause Analysis for PER 200203, Unit 3 Manual Scram Due to Lowering Reactor Water Level. This finding was entered into the licensees corrective action program as PER 245390. The inspectors determined that the licensees failure to implement the TVA PM program was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Initiating Events cornerstone attribute of Equipment Performance, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during at power operations, since failure to implement the provisions of the PM program increased the likelihood of a component failure which contributed to a plant transient. Specifically the failure of the solenoid coil contributed to a reactor trip. The inspectors determined that the finding was of very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment or functions were not available. The inspectors determined that this finding directly involved the cross-cutting area of Human Performance, component of Work Practices and aspect of Procedural Compliance because licensee personnel failed to follow the guidance contained in the Preventive Maintenance program resulting in a plant transient.
05000259/FIN-2010006-03	2010Q3	Browns Ferry	Failure to Correct a Condition Adverse to Quality Associated with the 2D Residual Heat Removal (RHR) Room Cooler	The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality by failing to implement adequate corrective actions to address degradation in the performance of the 2D RHR room cooler. On July 17, 2009, the 2D RHR room cooler thermal overload failed due to high mechanical vibrations, which the licensee failed to identify and correct prior to a subsequent failure on August 19, 2009. This finding was entered into the licensees corrective action program as PER 261728. The inspectors determined that the licensees failure to implement adequate corrective actions after the 2D RHR motor trip on July 17, 2009 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone in that it adversely affected the reliability of the 2D RHR room cooler to respond to initiating events. The inspectors determined that the finding was of very low safety significance because it did not result in inoperability of a safety function for greater than the allowed technical specification outage time. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the Corrective Action Program and aspect of Appropriate and Timely Corrective Actions because the licensee did not implement appropriate and timely corrective actions to resolve a condition adverse to quality. Specifically, the problem with the 2D RHR room cooler was not adequately addressed after the motor trip on July 17, 2009.
05000250/FIN-2010004-01	2010Q3	Turkey Point	Failure to provide adequate instructions when working on the reactor protection system results in reactor trip	A self-revealing non-cited violation (NCV) of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified when the licensee started corrective maintenance on the Unit 4 reactor protection system with an inadequate procedure. As a result, a reactor trip occurred when a reactor trip circuit was not placed on bypass as an initial condition needed to safely complete the work. During the event investigation, the licensee determined that neither the work order, nor the pre-job review identified the need to place the affected train of the reactor protection system on the bypass breaker. The finding was determined to be more than minor because it affects the Initiating Events cornerstone attribute of procedure quality and adversely affected the cornerstone objective to limit the likelihood of an event that upsets plant stability by resulting in a reactor trip. The finding was evaluated in accordance with IMC 0609, Attachment 4, and determined to be of very low safety significance (Green) per SDP Phase 1 determination because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of Human Performance, Work Control H.3(b) because the licensee did not appropriately coordinate work activities by incorporating actions to address the need to keep personnel apprised of the operational impact of work and plant conditions that may affect work activities, resulting in a reactor trip.
05000250/FIN-2010004-04	2010Q3	Turkey Point	Licensee-Identified Violation	Technical Specification 3.8.1.1.b requires restoration of an inoperable diesel generator to operable status within 14 days or be in at least hot standby within the next 6 hours. Contrary to the above, from April 27 through May 10, 2010, the unit 4A emergency diesel generator was inoperable approximately 16.9 days because of speed sensing magnetic pickup damage due to it being set too close to the engine flywheel during maintenance. When identified by the licensee during a surveillance test, the licensee entered the issue in the corrective action program as AR 406620 and corrected the condition. Additional corrective actions were implemented under the AR. A regional Senior Reactor Analyst performed a Phase III evaluation under the Significance Determination Process. The dominant internal events accident sequence was a single unit loss of offsite power followed by the common cause failure of all the emergency diesel generators with a failure to recover offsite power or an emergency diesel generator before core damage two hours later. Assumptions of the evaluation included that common cause would be considered and, recovery of the failed diesel generator would not be considered. The exposure time for the evaluation was 16.9 days. Based upon this evaluation the performance deficiency was characterized as a finding of very low safety significance.
05000250/FIN-2010004-03	2010Q3	Turkey Point	Licensee-Identified Violation	Technical Specification 3.8.1.1.b requires restoration of an inoperable diesel generator to operable status within 14 days or be in at least hot standby within the next 6 hours. Contrary to the above, during the approximate 1.5 month period prior to June 7, 2010, a period in excess of 14 days, the Unit 3 B emergency diesel generator was inoperable because of a failed fuel oil transfer pump and Unit 3 was not placed in hot standby as required. When identified by the licensee during a surveillance test, the licensee entered the issue in the corrective action program as AR 406564 and corrected the condition by replacing the failed transfer pump. This violation was of very low safety significance (Green) because alternate methods of filling the fuel oil day tank using available transfer pumps were proceduralized and available. Further corrective actions to develop a preventive maintenance activity to prevent similar failures were planned.
05000250/FIN-2010004-02	2010Q3	Turkey Point	Licensee-Identified Violation	Technical Specification 3.8.1.1.b requires restoration of an inoperable diesel generator to operable status within 14 days or be in at least hot standby within the next 6 hours. Contrary to the above, during the period July 28, 2009 thru August 12, 2009, a period in excess of 14 days, the Unit 4 B emergency diesel generator was inoperable because of a faulty fuel strainer and Unit 4 was not placed in hot standby as required. When identified by the licensee during a surveillance test, the licensee entered the issue in the corrective action program as CR 2009-13740 and corrected the condition by replacing the entire fuel strainer assembly. A regional Senior Reactor Analyst performed a Phase III evaluation under the Significance Determination Process. The dominant internal events accident sequence was a single unit loss of offsite power followed by the common cause failure of all the emergency diesel generators with a failure to recover offsite power or an emergency diesel generator before core damage two hours later. Assumptions of the evaluation included that common cause would be considered and, recovery of the failed diesel generator would not be considered. The exposure time for the evaluation was 14.3 days. Based upon this evaluation the performance deficiency was characterized as a finding of very low safety significance (Green). Further corrective actions to modify the strainer were planned.
05000259/FIN-2010006-04	2010Q3	Browns Ferry	Failure to Correct a Condition Adverse to Quality Associated Cooling Water Flow Degradation in the 1B Core Spray Room Cooler	The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a condition adverse to quality and implement adequate corrective actions for the degraded 1B Core Spray (CS) room cooler. The licensee failed to implement adequate correct actions to address the inability of the room cooler perform its design function with degraded cooling water flow prior to its loss of function on June 25, 2010. The licensee has since replaced the cooler in order to provide additional flow margin. The failure to take adequate corrective actions to address the potential high river temperature along with degraded heat exchanger flow was a performance deficiency. The performance deficiency was more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely affected the availability of the 1B CS room cooler to respond to initiating events. The inspectors determined that a Phase 2 screening was required because the 1B division of core spray was inoperable for greater than the 7 day technical specification allowed out of service time. Using the pre-solved Phase Two significance determination worksheet, the inspectors determined that the finding was of very low safety significance. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the Corrective Action Program and aspect of Appropriate and Timely Corrective Actions because the licensee did not implement appropriate and timely corrective actions to resolve a condition adverse to quality. Specifically, the licensee failed to address the debris fouling of the 1B CS room cooler prior to its failure on June 25, 2010.
05000250/FIN-2010004-05	2010Q3	Turkey Point	Licensee-Identified Violation	10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances. The licensee implements this requirement, in part, with administrative procedure 0-ADM-503, Temporary System Alteration, which requires that a temporary system alteration design review be performed to ensure that the design of the alteration is consistent and compatible with the system and complies with the component design basis. Contrary to the above, from September 2 to 6, 2010, a temporary alteration was installed on the 3B and 4A vital batteries without a design review to assure the installation was consistent with the design basis. When the unauthorized modification was identified to the licensee by a plant operator during rounds, the structures were removed and an evaluation initiated. The licensee determined that the batteries affected remained capable of their design function and this issue was documented into the corrective actions program as AR 577944. The finding was more than minor using NRC Manual Chapter 0612, Appendix E, Example 4.a because there were previous examples where the licensee failed to perform engineering evaluations for plant activities (NRC Inspection Reports.
05000250/FIN-2010003-01	2010Q2	Turkey Point	Failure to perform adequate surveys to ensure proper estimation of radionuclide concentrations in mechanical filter waste shipments	The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 20.1501(a) for the failure to perform adequate surveys to meet the requirements of 10 CFR Part 20 Appendix G. 10 CFR Part 20 Appendix G states that shippers of radioactive waste must identify and quantify radionuclides contained in each waste container. Specifically, the inspectors determined that the use of resin samples to characterize three shipments of mechanical filters in calendar years 2008 and 2009 was inadequate to ensure proper identification and quantification of the radionuclides present in each container. The licensee entered the issue into their corrective action program as condition report (CR) number 2009-32955 The finding is more than minor because it is associated with the Public Radiation Safety cornerstone attribute of Programs and Processes and adversely affects the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. The finding was assessed using the Public Radiation Safety Significance Determination Process (SDP). Based on the fact that subsequent follow up analyses demonstrated that none of the filter waste was under-classified, the finding was determined to be of very low safety significance (Green). This finding has a crosscutting aspect of Human Performance, Decision Making (H.1(b)), because the decision to use resin samples to characterize filter shipments was based on incorrect assumptions, i.e., that spent resin samples would be representative of the filter waste stream, and those assumptions were not demonstrated to be conservative prior to implementation.
05000250/FIN-2010003-02	2010Q2	Turkey Point	Failure to implement TS requirements regardin rod position indication	A Self-Revealing Non-cited Violation of Technical Specification 3.1.3.1.b requirements was identified on Unit 3 when position indication for two rod control cluster assemblies (RCCs) drifted out of tolerance with the associated rod group position indication. Contrary to technical specification requirements, rod positions were neither re-aligned with the group counter nor was reactor power reduced to less than 90 percent within the allowed one hour action time with a potential consequence of challenging accident analysis assumptions. The issue was documented in the corrective action program as CR 2010-14724 The finding was more than minor because if inaccurate rod position indication was left uncorrected, there was a possibility of an adverse affect of an actual rod misalignment beyond that assumed in accident analyses. The Initiating Events cornerstone was affected because rod position alignment assures that accident analysis assumptions are maintained. The inspectors evaluated the finding using NRC Inspection Manual 0609, Attachment 0609.04, Initial Screening and Characterization of Findings and classified the finding of very low safety significance (Green) using the Transient Initiator tool. The cross-cutting aspect of Human Performance, Decision Making (H.1.a) was affected when supervisory personnel did not implement their roles and authorities to ensure safety by implementing Technical Specification requirements.
05000250/FIN-2010006-02	2010Q2	Turkey Point	Licensee-Identified Violation	Technical Specification 6.8.1 requires that procedures required by the Florida Power and Light Quality Assurance Topical Report (QATR) be implemented. The QATR includes procedures listed in Appendix A of NRC Regulatory Guide 1.33 Revision 2. Contrary to the above, on November 26, 2009, during PMT of the New Analog Rod Position Indication System (NARPI), the control room received indication that the H6 and H10 control rods dropped from the fully withdrawn position and did not enter the required off-normal procedure ONOP-28.3, Dropped RCC, when the two control rods (H6 and H10) were confirmed to be dropped during the Unit 4 Outage. The licensee eventually entered the procedure when directed by management and tripped the reactor as required by the procedure. The non-compliance was identified by the licensee following issuance of LER 2010-001-0 on January 25, 2010, and entered into the corrective action process. During the post modification test Unit 4 was in Mode 3 (Hot Standby) and was borated such that all control rods could be withdrawn and the reactor would not go critical, eliminating any safety concern with two dropped control rods. The issue was screened to be of very low safety significance (Green). The issue was documented in condition report 2010-3782 and additional corrective actions were identified. Because the licensee identified the issue and documented it in their corrective action program and because the finding is of very low safety significance, this violation is being treated as a licensee-identified NCV consistent with Section VI.A of the NRC Enforcement Policy.
05000250/FIN-2010006-01	2010Q2	Turkey Point	Inadequate procedure implementation resulting in snubber failure	The NRC identified a non-cited violation of 10 CFR 50, Appendix B, Criterion V, for the licensees failure to implement procedures during a visual inspection of safety related seismically qualified snubber SN-4-1039. Specifically, the licensee failed to identify missing, detached, loosened support items, or full thread engagement of all mechanical connections that led to a snubber failure as prescribed in procedure 0-OSP-105.1, Visual Inspection, Removal and Reinstallation of Mechanical Shock Arrestors, section 7.2.1.3.d. The snubber would not have been able to perform its design function to arrest shocks of the main steam piping to the C Steam Generator during seismic events or transients, such as sudden isolation of the main steam isolation valve. The licensee implemented immediate corrective actions which included replacing the snubber in containment, adding specific instructions in procedure 0-OSP-105.1 to specifically inspect the locking ring and correct installation, and to include emphasis on FPL expectations from vendor provided snubber inspection services. The licensee documented this in condition report CR 2008-31372. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone in that the licensee did not ensure reliability of the snubber to respond to initiating events to prevent undesirable consequences in that the snubber would not have been able to perform its design function to arrest shocks of the main steam piping to the C Steam Generator during seismic events or transients. The finding was screened using Manual Chapter 0609.04, \"Phase 1 Initial Screening and Characterization of Findings,\" and was determined to have a very low safety significance (Green) because the system remained operable and capable of meeting its design function with no loss of safety function of the C main steam system. This finding was reviewed for cross-cutting aspects and none were identified. (4OA2).
05000250/FIN-2010002-02	2010Q1	Turkey Point	Licensee-Identified Violation	Technical Specification 3.9.13 requires that with one containment radiation monitor out of service during core alterations, core alterations may continue as long as the containment ventilation isolation valves be maintained shut and within one hour, operate the control room ventilation system in the recirculation mode. Contrary to the above, on April 1, 2009, and on prior occasions, core alterations continued with one channel of control room isolation actuation out of service and without the control room ventilation in the recirculation mode. The non-compliance was identified during review of plant conditions while performing engineered safeguards integrated testing with the plant in Mode 6 refueling. The redundant radiation monitoring and actuation channel remained available and had an event occurred, operators would have been able to use standby Self-contained breathing apparatus (SCBA) assuring the safety function. The issue was screened to be of very low safety significance (Green). When identified, the licensee placed the control room in recirculation and isolated the ventilation valves. The issue was documented in condition report 2009-9899 and additional corrective actions were specified. Because the licensee identified the issue and documented it into their corrective action program, and because the finding is of very low safety significance, this violation is being treated as a licensee identified NCV consistent with Section VI.A of the NRC Enforcement Policy
05000250/FIN-2010008-02	2010Q1	Turkey Point	Failure to correct Boraflex degradation in the SFP in a timely manner	The inspectors identified an AV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to effectively correct a condition adverse to quality involving degradation of Boraflex neutron absorber material in the Unit 3 SFP, such that in November 2009 two spent fuel pool storage cells L38, F19 with Boraflex degradation greater than that assumed in the criticality analyses had been allowed to remain inservice even after the licensee had revised SFP management controls. When brought to the attention of the licensee by the NRC, condition report 2009-34470 was written to document the non-compliance. The finding was more than minor because, if left uncorrected, it would become a more significant safety concern since it could not be determined if other, untested storage rack locations could be more degraded. In addition, the finding impacted the initiating event cornerstone objective of limiting events that challenge safety functions; for example, preventing criticality in an area not designed for criticality. Because probabilistic risk assessment tools were not suited for this finding, the inspectors evaluated the finding using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. Because the Boraflex degradation resulted in a significant loss of margin to criticality, NRC management concluded the finding was preliminarily greater than Green. The inspectors determined that the cross-cutting aspect of Problem Identification and Resolution (P.1(d)) is applicable to this issue because the licensee did not implement effective corrective action for degradation of Boraflex neutron absorber material
05000250/FIN-2010008-01	2010Q1	Turkey Point	Failure to perform adequate written 50.59 evaluation.	The inspectors identified an AV of 10 CFR 50.59(d)(1) for failure to maintain records that include a written evaluation which provides the bases for the determination that a change, test, or experiment does not require a license amendment. Specifically, the licensee received NRC approval to make changes to the facility via license amendment No. 234 dated July 17, 2007, involving the design of the spent fuel pool storage racks, including the use of Metamic inserts and other hardware, administrative controls and testing methods, to assure that the spent fuel remains within design limits. Subsequent to the NRCs approval, the licensee determined that Metamic inserts could not be installed by the date approved by the NRC. However, the licensee maintained no written evaluation which provided the bases for the determination that the change to the design of the spent fuel pool storage racks, without the use of Metamic inserts, did not require a license amendment pursuant to paragraph (c)(2) of 10 CFR 50.59.The finding was more than minor because it impacted the regulatory process which depends on plant activities being properly evaluated and, when required, reviewed and approved by NRC. Because this finding impacted the regulatory process, it was evaluated using traditional enforcement and is being considered for escalated enforcement action in accordance with NRCs Enforcement Policy. The inspectors determined that the cross-cutting aspect of Human Performance, (H.4(c)) is applicable to this issue because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported, when errors in administering Technical Specification requirements and programmatic controls which assure safety were not effectively implemented.
05000250/FIN-2010002-01	2010Q1	Turkey Point	Failure to implement design controls in a temporary modification.	The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for failing to maintain control of temporary equipment installed on unit 4 A residual heat removal pump piping when the permanent component cooling water flow indication to the pump seal failed high. Operators were using a controlotron as a compensatory measure to verify adequate cooling flow to the unit 4A residual heat removal pump seal and to assure operability of the unit 4A residual heat removal pump. If the controlotron had failed, the operators would not have received a component cooling water low flow alarm in the control room, lack of cooling flow to the pump would have gone undetected, and operability of the residual heat removal pump could have been affected. The inspectors identified the licensee failed to follow the temporary system alteration procedure to ensure design adequacy and to determine if the alteration required a 10 Code of Federal Regulations (CFR) 50.59 evaluation and NRC approval. The licensee documented this in the corrective action program as condition report 2010- 479. The finding is more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone in that it reduced the reliability of the 4A residual heat removal pump with the permanent flow indicator out of service while using an unevaluated controlotron to determine continued operability of the 4A residual heat removal pump. The inspectors screened the finding using NRC Inspection Manual Chapter 0609, Significance Determination of Reactor Inspection Findings for At Power Operations, Phase 1 screening. The finding was of very low safety significance because the design or qualification deficiency did not result in actual loss of operability or functionality of the pump. The cross cutting aspect of Human Performance, Work Practices (H.4(b)) was affected. (1R18)

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