IR 05000250/2014009

IR 05000250/2014009 & 05000251/2014009; on July 14-18, 2014 and July 28-31, 2014; Turkey Point Nuclear Plant, Units 3 and 4; Biennial Inspection of the Problem Identification and Resolution Program

ML14255A139
Person / Time
Site:	Turkey Point
Issue date:	09/12/2014
From:	Steven Rose Reactor Projects Branch 7
To:	Nazar M Florida Power & Light Co
References
IR 2014009
Download: ML14255A139 (18)

Text

ptember 12, 2014

SUBJECT:

TURKEY POINT NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000250/2014009 AND 05000251/2014009

Dear Mr. Nazar:

On July 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution inspection at your Turkey Point Nuclear Plant Units 3 and 4. On July 31, 2014, the NRC inspection team discussed the results of this inspection with Mr.

Mike Kiley and other members of your staff. Following completion of additional post-inspection review of information by the NRC in the Region II office, a final exit was held by telephone with Mr. Jose Alverez on September 3, 2014, to provide an update on changes to the preliminary inspection findings. The inspectors documented the results of this inspection in the enclosed inspection report.

Based on the inspection samples, no findings or violations of more than minor significance where identified. The inspectors determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the inspectors assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the inspectors determined that your staffs performance was adequate to support nuclear safety.

The inspectors also evaluated other processes your staff used to identify issues for resolution.

These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The inspectors determined that your stations performance in each of these areas supported nuclear safety.

Finally, the inspectors determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the inspectors observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Steven D. Rose, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos.: 50-250, 50-251 License Nos.: DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2014009 and 05000251/2014009 w/Attachment: Supplemental Information

REGION II==

Docket No.: 50-250, 50-251 License No.: DPR-31, DPR-41 Report No.: 05000250/2014009 and 05000251/2014009 Licensee: Florida Power & Light Company (FPL)

Facility: Turkey Point Nuclear Plant, Units 3 and 4 Location: 9760 S.W. 344th St Homestead, FL 33035 Dates: July 14 - 18, 2014 July 28 - 31, 2014 Inspectors: N. Staples, Senior Project Inspector, Team Leader S. Ninh, Senior Project Engineer C. Rapp, Senior Project Engineer M. Schwieg, Resident Inspector N. Pitoniak, Fuel Facilities Inspector Approved by: Steven D. Rose, Chief, Reactor Projects Branch 7 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000250/2014009, 05000251/2014009; July 14 - 31, 2014; Turkey Point Nuclear Plant,

Units 3 and 4; Biennial Inspection of the Problem Identification and Resolution Program.

The inspection was conducted by two senior project engineers, one senior project inspector, a fuel facilities inspector, and a resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner. However, the inspectors did identify deficiencies in the areas of identification of problems and effectiveness of corrective actions.

The inspectors determined that overall audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.

Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.

REPORT DETAILS

4OA2 Problem Identification and Resolution

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily use of action requests (ARs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed ARs that had been issued between June 2012 and July 2014, including a detailed review of selected ARs associated with the following risk-significant systems: Emergency Diesel System, Auxiliary Feedwater and Component Cooling Water Systems. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the inspectors selected a representative number of ARs that were identified and assigned to the major plant departments, including emergency preparedness, health physics, chemistry, and security. These ARs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected ARs, verified corrective actions were implemented, and attended meetings where ARs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.

The inspectors conducted plant walk-downs of equipment associated with the selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed ARs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.

Control room walk-downs were also performed to assess the main control room deficiency list and to ascertain if deficiencies were entered into the CAP. Operator workarounds and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field.

The inspectors conducted a detailed review of selected ARs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the ARs and the guidance in licensee procedure PI-AA-100-1005, Root Cause Analysis, and PI-AA-100-1007, Apparent Cause Evaluation. The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent of condition, and extent of cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience items, including NRC generic communications to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.

The inspectors reviewed site trend reports to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.

The inspectors reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included Management Review Committee (MRC)meetings and Nuclear Safety Culture Monitoring Panel meeting.

Documents reviewed are listed in the Attachment.

b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating ARs as described in licensee procedures PI-AA-204, Condition Identification and Screening Process, managements expectation that employees were encouraged to initiate ARs for any reason, and the relatively few number of deficiencies identified by inspectors during plant walkdowns not already entered into the CAP. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.

Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.

The inspectors identified three examples where NRC identified issues were not addressed in accordance with procedure LI-AA-201, Regulatory Preparation and Response, Rev. 17, section 4.10, which stated in part, Upon receipt of the inspection report, the Licensing organization shall initiate an action request (AR) to ensure the following actions have been or will be completed: A) each violation/finding has been entered into the corrective action program; B) the causal evaluation of the AR addresses the issues identified in the violation/finding, including the assigned cross-cutting aspect (CCA). Procedure 0-ADM-32.1, Management of NRC Findings and Violations, stated in section 4.3 Condition Report (CRs) for NRC green findings and NCVs are assigned significance level (SL) 2 in accordance with PI-AA-204. The assigned responsible licensing engineer (RLE) shall ensure that CRs for NRC green findings and NCVs are assigned as SL 2. Failure to follow procedures LI-AA-201 and 0-ADM-32.1 for disposition of NRC identified findings, violations, and CCAs was a performance deficiency (PD).

• The inspectors identified a performance deficiency while reviewing the licensees response to NRC Inspection Report 2014008-01, which discussed a self-revealing finding. Specifically, no actions were performed to address the assigned cross-cutting aspect of H.8, Procedural Adherence. This failure to follow procedure LI-AA-201 for disposition of NRC identified findings, violations, and CCAs was a performance deficiency (PD). AR 1873643 was generated to address the issue. This performance deficiency was considered minor because there was no adverse impact on cornerstone objectives. This minor violation has been entered in the CAP as AR 01980782.

• The team identified the licensee failed to follow procedure LI-AA-201 for disposition of NRC identified findings, violations, and CCAs identified in IR 2013004-04. The licensee generated AR 1868533 to address the issue.

However, the AR generated as a result of IR 2013004-04 did not ensure that the failure to control a wiring configuration was addressed in AR 1868533. As a result, corrective action to prevent recurrence (CAPR) 1 (revised surveillance procedure OSP-041.4 to perform a monthly surveillance to be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of all completed maintenance) was determined to be the corrective action addressing Root Cause 1 (Inadequate procedure compliance by supplemental personnel). Although this CA would verify if a wiring configuration problem existed, it did not address issues with contractors maintaining wiring configurations. This performance deficiency was considered minor because there was no adverse impact on cornerstone objectives. This minor violation was entered into the CAP as AR 01981473.

• Inspection Report 2014007-01 documented a Green NCV of TS 6.8.1, Procedures and Programs, for the licensees failure to implement procedure 0-ADM-232, Time Critical Action Program. The inspection team reviewed ARs 1944453, 1943425, 1943697, 1945532, 1943321 all of which were determined to be significance level 3 ARs. ARs 1966734, 1966737 were generated after the IR was issued. The team determined that the CCA (H.8 Procedural adherence) and NCV were addressed, but the AR for the NCV was not put into the CAP as a SL 2. This performance deficiency was considered minor because there was no adverse impact on cornerstone objectives. This minor violation has been entered in the CAP as AR 1981127.

These three performance deficiencies were screened as minor violations in accordance with IMC 0612 Appendix B, Issue Screening, and not subject to enforcement in accordance with the NRCs Enforcement Policy.

Problem Prioritization and Evaluation Based on the review of ARs sampled, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the AR significance determination guidance in PI-AA-204, Condition Identification and Screening Process. The inspectors determined that adequate consideration was given to system or component operability and associated plant risk.

The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures and assigned cause determinations were appropriate, considering the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with procedures PI-AA-100-1005, and PI-AA-100-1007.

Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, ARs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.

In addition, the inspectors identified a performance deficiency associated with the licensees effectiveness of corrective actions. This violation was screened as minor in accordance with IMC 0612 Appendix B, Issue Screening, and is not subject to enforcement in accordance with the NRCs Enforcement Policy.

• The inspectors determined a performance deficiency for not following PI-AA-205 for completing Corrective Actions (CAs) existed. Specifically, the inspectors identified that the closed action for AR 1897687 (to perform an evaluation to determine if reactor operators were being trained in a manner that would cause them to misclassify an Emergency Action Level due to RCS leak rate) was declined and closed as no further action. This was determined to be contrary to the guidance of PI-AA-205, Condition Evaluation and Corrective Action, Rev. 25, section 4.10 that requires corrective action closure only if the CA is completed as prescribed or appropriate justification and approval for intent of change is documented. This performance deficiency was considered minor because there was no adverse impact on cornerstone objectives. This minor violation has been entered into the licensees CAP as AR 01980782.

.2 Use of Operating Experience

a. Inspection Scope

The inspectors examined licensee programs for reviewing industry operating experience, reviewed licensee procedure PI-AA-102, Operating Experience Program, reviewed the licensees operating experience database to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since July 2012 to verify whether the licensee had appropriately evaluated each notification for applicability to the Turkey Point Nuclear plant, and whether issues identified through these reviews were entered into the CAP.

Documents reviewed are listed in the Attachment.

b. Assessment Based on a review of documentation related to the review of operating experience issues, the inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry operating experience (OE)was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure.

In addition, operating experience was included in root cause evaluations in accordance with licensee procedure PI-AA-102, Operating Experience Program.

c. Findings

No findings were identified.

.3 Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self-assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure 0-ADM-533, CAP Guidance and Performance Assessment and Trending Analysis, Revision 9.

Documents reviewed are listed in the Attachment.

b. Assessment The inspectors determined that the scopes of assessments and audits were adequate.

Self-assessments were generally detailed and critical, as evidenced by findings consistent with the inspectors independent review. The inspectors verified that ARs were created to document all areas for improvement and findings resulting from the self-assessments and verified that actions were completed consistently with those recommendations. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends, as evidenced by the ARs reviewed that were initiated as a result of adverse trends.

c. Findings

No findings were identified.

.4 Safety-Conscious Work Environment

a. Inspection Scope

The inspectors interviewed several on-site workers regarding their knowledge of the corrective action program at Turkey Point and their willingness to write ARs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP coordinator. Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were properly reviewed and that identified deficiencies were resolved and entered into the CAP when appropriate.

Documents reviewed are listed in the Attachment.

b. Assessment Based on the interviews conducted and the ARs reviewed, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees.

Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On July 31, 2014, the inspectors presented the inspection results to Mr. Kiley and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee. A re-exit was conducted with Mr. Alverez via telephone on September 03, 2014, to discuss the final results of the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

J. Alvarez, Performance Improvement

T. Jones, Operations Shift Manager

M. Kiley, Site Vice President

B. Kline, Fleet FAC Coordinator

S. Mihalakea, Performance Improvement

C. Navarro, Performance Improvement

B. Tomonto, Licensing Manager

R. Valmonte, Project Engineer

NRC personnel

T. Hoeg, Senior Resident Inspector

M. Endress, Resident Inspector

S. Rose, Chief, Branch 7, Division of Reactor Projects

LIST OF REPORT ITEMS

Opened and Closed

None

Closed

None

Discussed

None