IR 05000250/2013005

IR 05000250-13-005, 05000251-13-005, 05000250/2013502 and 05000251/2013502; 10/01/2013 - 12/31/2013; Turkey Point Nuclear Plant, Units 3 & 4; Integrated Inspection

ML14031A306
Person / Time
Site:	Turkey Point
Issue date:	01/31/2014
From:	Rich D NRC/RGN-II/DRP/RPB3
To:	Nazar M Florida Power & Light Co
References
IR 13-502, IR-13-005
Download: ML14031A306 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 31, 2014

SUBJECT:

TURKEY POINT NUCLEAR PLANT - NRC INTEGRATED INSPECTION REPORT 05000250/2013005, 05000251/2013005, 05000250/2013502 AND 05000251/2013502

Dear Mr. Nazar:

On December 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Turkey Point Plant Units 3 and 4. On January 15, 2014, the NRC inspectors discussed the results of the inspection with Mr. Kiley and other members of your staff.

Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding did not involve a violation of NRC requirements.

If you disagree with the cross-cutting aspect assignment or the finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II; and the NRC resident inspector at the Turkey Point Power Plant.

As a result of the Safety Culture Common Language Initiative, the terminology and coding of cross-cutting aspects were revised beginning in calendar year (CY) 2014. New cross-cutting aspects identified in CY 2014 will be coded under the latest revision to Inspection Manual Chapter (IMC) 0310. Cross-cutting aspects identified in the last six months of 2013 using the previous terminology will be converted to the latest revision in accordance with the cross-reference in IMC 0310. The revised cross-cutting aspects will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the CY 2014 mid-cycle assessment review. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs 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 NRCs 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/

Daniel W. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-250, 50-251 License Nos.: DPR-31, DPR-41

Enclosure:

Inspection Report 05000250/2013005, 05000251/2013005, 05000250/2013502, 05000251/2013502 w/Attachment: Supplemental Information

REGION II==

Docket Nos: 50-250, 50-251 License Nos: DPR-31, DPR-41 Report Nos: 05000250/2013005, 05000251/2013005, 05000250/2013502, and 05000251/2013502 Licensee: Florida Power & Light Company (FP&L)

Facility: Turkey Point Plant, Units 3 & 4 Location: 9760 S. W. 344th Street Homestead, FL 33035 Dates: October 1 to December 31, 2013 Inspectors: T. Hoeg, Senior Resident Inspector M. Endress, Resident Inspector P. Capehart, Senior Operations Engineer (Section 1R11)

D. Lanyi, Operations Engineer (Section 1R11)

D. Bacon, Operations Engineer (Section 1R11)

J. Laughlin, Emergency Preparedness Inspector (Section 1EP4)

Approved by: Daniel W. Rich, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000250/2013005, 05000251/2013005; 10/01/2013 - 12/31/2013; Turkey Point Nuclear

Plant, Units 3 & 4; Followup of Events and Notices of Enforcement Discretion.

The report covered a three month period of inspection by the resident inspectors, regional specialist inspectors, and a headquarters specialist inspector. One Green finding was identified.

The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, or Red) and determined using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP) dated June 2, 2011. The cross-cutting aspect was determined using IMC 310, Components Within the Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements were dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision

Cornerstone: Initiating Events

Green: A self-revealing finding was identified for the licensees failure to provide adequate test precautions, limitations, and instructions for performing harmonic testing on the Unit 4 turbine generator control circuitry while in Mode 1 operation. As a result, 480 volt load center voltage was lowered enough to initiate a degraded voltage signal to the 4B safety related 4 kV bus sequencer which tripped reactor coolant pumps causing a reactor trip due to low reactor coolant system flow. This issue was placed in the licensees corrective action program as action request (AR) 1867690. Corrective actions included performing a root cause evaluation and a revision to procedure WM-AA-100-1000, Work Activity Risk Management, to include additional guidance involving online maintenance and risk insights when planning maintenance on the main generator.

The licensees failure to provide adequate test precautions, limitations, and instructions for performing harmonic testing on the Unit 4 turbine generator control circuit was a performance deficiency. Specifically, TI-246904-01, 3rd Harmonic Relay Test, did not provide adequate instructions to prevent creating a degraded voltage condition and the test was classified in error as low risk rather than high risk per licensee procedure WM-AA-100-1000, Work Activity Risk Management. The inspectors determined the performance deficiency was more than minor using IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, because the performance deficiency was associated with the procedure quality 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 have an adequate procedure for controlling the turbine generator harmonic testing resulted in a reactor trip due to the loss of reactor coolant pumps from 4B sequencer 4 kV bus stripping. The inspectors evaluated the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, 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 control component of the human performance area because the licensee failed to include the proper risk insights for work activities related to nuclear safety and prevent a subsequent reactor trip H.3(a). Section 4OA3.

Licensee Identified Violations

None

REPORT DETAILS

Summary of Plant Status

Both Unit 3 and Unit 4 began this inspection period at 100 percent of Rated Thermal Power (RTP) where they remained throughout this inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity (Reactor-R)

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

During the month of November, the inspectors reviewed and verified the status of actions taken by the licensee for winter readiness prior to the onset of cool weather. The inspectors reviewed licensee procedure OP-AA-102-1002, Seasonal Readiness, 7, Cold Weather Readiness Check List, and Attachment 14, Turkey Point Site Specific Guidance. The inspectors reviewed system health reports and open corrective action program action requests for the emergency diesel generators and auxiliary feed water pumps to determine if any deficiencies existed that could affect operation of equipment immersion heaters. The inspectors performed walk downs of systems that could be affected by cold weather as outlined in the licensee site specific guidance including the following areas:

• Unit 3 and Unit 4 emergency diesel generators

• Auxiliary feed water pumps

• Unit 3 and Unit 4 charging pumps

• Unit 3 and Unit 4 boric acid storage tanks

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Equipment Walk downs (Quarterly)

a. Inspection Scope

The inspectors conducted three partial alignment verifications of the safety-related systems listed below. These inspections included reviews using plant lineup procedures, operating procedures, and piping and instrumentation drawings, which were compared with observed equipment configurations to verify that the critical portions of the systems were correctly aligned to support operability. The inspectors also verified that the licensee had identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers by entering them into the corrective action program (CAP). Documents reviewed are listed in the Attachment.

• Auxiliary Feed Water (AFW) Train II while Train I was out of service (OOS)

• 4A Emergency Diesel Generator (EDG) while the 4B EDG was OOS

• 4B EDG while the 4A EDG was OOS

b. Findings

No findings were identified.

.2 Equipment Alignment (Semi-annual)

a. Inspection Scope

The inspectors conducted one complete system alignment walk down of the 4B intake cooling water (ICW) system. The inspectors conducted a detailed review of the alignment and condition of the 4B ICW system to verify its capability to meet its design basis function. The inspectors utilized licensee procedure 4-NOP-019, Intake Cooling Water System, and Drawing 5614-M-3019, Intake Cooling Water System, to verify the system alignment was correct. During the walkdown, the inspectors verified, as appropriate, that: 1) valves were correctly positioned and did not exhibit leakage that would impact their function, 2) electrical power was available as required, 3) major portions of the system and components were correctly labeled, cooled, and ventilated, 4) hangers and supports were correctly installed and functional, 5) essential support systems were operational, 6) ancillary equipment or debris did not interfere with system performance, 7) tagging clearances were appropriate, and 8) valves were locked as required by the licensees locked valve program. Other items reviewed included the operator workaround list, the temporary modification list, system health reports, system description, and open maintenance work orders. In addition, the inspectors reviewed the licensees CAP to ensure that the licensee was identifying and resolving equipment alignment problems.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Fire Area Walk downs

a. Inspection Scope

The inspectors toured the following four plant areas to evaluate conditions related to control of transient combustibles, ignition sources, material condition, and operational status of fire protection systems including fire barriers used to prevent fire damage and propagation. The inspectors reviewed these activities using provisions in the licensees procedure 0-ADM-016, Fire Protection Plan and 10 CFR Part 50, Appendix R. The licensees fire impairment lists were routinely reviewed. In addition, the inspectors reviewed the condition report database to verify that fire protection problems were being identified and appropriately resolved. The inspectors accompanied fire watch roving personnel on a tour of fire protection impairments and risk significant fire areas to assure monitoring of area status and to verify proper identification and handling of transient combustibles. The following areas were inspected:

• Unit 4 EDG fire zone 133

• Unit 4 4B 4kV switchgear room fire zone 67

• Cable spreading room fire zone 98

• Unit 3 and 4 control room zone 106

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors conducted walk downs of the following areas subject to internal flooding to ensure that flood protection measures were in accordance with plant design specifications. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Appendix 5F, Internal Plant Flooding, that discussed protection of areas containing safety-related equipment that could be affected by internal flooding. Specific plant attributes that were checked included structural integrity, sealing of penetrations, and control of foreign material and debris. Documents reviewed are listed in the

. The following areas were inspected:

• Unit 3 and 4 High Head Safety Injection (HHSI) pump rooms

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review

a. Inspection Scope

On November 19, 2013, the inspectors assessed licensed operator performance in the plant specific simulator during a licensed operator continuing training scenario. The training scenario was started with the unit at 100 percent power and steady state conditions. Event simulations were accomplished using Simulator Evaluation PTN 750201601, Dropped Rod with Loss of Feedwater and Anticipated Transient Without Scram (ATWS). Operators responded to the simulation using off-normal procedures 3-ONOP-059.8, Power Range Nuclear Instrumentation Malfunction, and 3-ONOP-028.3, Dropped RCC. Emergency procedures used by the crew to safely mitigate the events included 3-EOP-E-0, Reactor Trip, 3-EOP-FR-S-1, Response to Nuclear Power Generation/ATWS, and 3-EOP-FR-H-1, Response to Loss of Secondary Heat Sink. The inspectors specifically checked that the simulated emergency classification of Alert was done in accordance with licensee procedure, 0-EPIP-20101, Duties of the Emergency Coordinator.

The simulator board configurations were compared with actual plant control board configurations concerning recent power up rate modifications. The inspectors specifically evaluated the following attributes related to operating crew performance and the licensee evaluation:

• Clarity and formality of communication

• Ability to take timely action to safely control the unit

• Prioritization, interpretation, and verification of alarms

• Correct use and implementation of off-normal and emergency operating procedures and emergency plan implementing procedures

• Control board operation and manipulation, including high-risk operator actions

• Oversight and direction provided by shift supervisor, including ability to identify and implement appropriate TS actions and emergency plan classification and notification

• Crew overall performance and interactions

• Evaluators control of the scenario and post scenario evaluation of crew performance

b. Findings

No findings were identified.

.2 Control Room Observations

a. Inspection Scope

The inspectors performed the following focused control room observations and assessed licensed operator performance in the control room. These observations included daily routine surveillance testing, response to alarms, communications, shift turnovers, and coordination of plant activities. These observations were conducted to verify operator compliance with station operating guidelines, such as use of procedures, control and manipulation of components, and communications. On December 30, 2013, the inspectors did a focused observation on Unit 4 consisting of a reactor coolant system primary water dilution per 0-OP-046, Chemical Volume Control System Boron Concentration Control. Specifically, the inspectors observed the reactor operators performing the pre-job brief per 0-ADM-200, Attachment 7, Planned Reactivity Manipulations for Maintaining Steady State Plant Conditions and verified the operators complied with the applicable procedure during the evolution.

The inspectors focused on the following conduct of operations attributes as appropriate:

• Operator compliance and use of procedures

• Control board manipulations

• Communication between crew members

• Use and interpretation of plant instruments, indications and alarms

• Use of human error prevention techniques

• Documentation of activities, including initials and sign-offs in procedures

• Supervision of activities, including risk and reactivity management

b. Findings

No findings were identified.

.3 Biennial Requalification

a. Inspection Scope

The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of October 21, 2013, the inspectors reviewed documentation, interviewed licensee personnel, and observed the administration of operating tests associated with the licensees operator requalification program. Each of the activities performed by the inspectors was done to assess the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. The evaluations were also performed to determine if the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and Inspection Procedure 71111.11, Licensed Operator Requalification Program. The inspectors also evaluated the licensees simulation facility for adequacy for use in operator licensing examinations using ANSI/ANS-3.5, 1998 American National Standard for Nuclear Power Plant Simulators for use in Operator Training and Examination. The inspectors observed two crews during the performance of the operating tests. Documentation reviewed included written examinations, Job Performance Measures (JPMs), simulator scenarios, licensee procedures, on-shift records, simulator modification request records, simulator performance test records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records. The records were inspected using the criteria listed in Inspection Procedure 71111.11. Documents reviewed documented are listed in the Attachment.

b. Findings

No findings were identified.

.4 Annual Review of Licensee Requalification Examination Results

a. Inspection Scope

On September 20, 2013, the licensee completed the annual requalification operating examinations required to be administered to all licensed operators in accordance with 10 CFR 55.59(a)(2). The inspectors performed an in-office review of the overall pass/fail results of the individual operating examinations and the crew simulator operating examinations in accordance with Inspection Procedure (IP) 71111.11, Licensed Operator Requalification Program. These results were compared to the thresholds established in Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Appendix I, Operator Requalification Human Performance Significance Determination Process.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed a known equipment problem associated with the Unit 4 auxiliary feed water system and the performance history trend associated with the Unit 3 intake cooling water system to verify that the licensees maintenance efforts met the requirements of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and licensee procedure NAP-415, Maintenance Rule Program Administration. The inspectors focused on maintenance rule scoping, characterization of maintenance problems and failed components, risk significance, determination of a(1) or a(2) performance criteria classification, corrective actions, and the appropriateness of established performance goals and monitoring criteria. The inspectors also interviewed responsible engineers and observed or reviewed corrective maintenance activities. The inspectors verified that equipment problems were being identified and appropriately entered into the licensee corrective action program. The inspectors used the licensee maintenance rule data base, system health reports, maintenance rule unavailability status reports, and the corrective action program as sources of information on tracking and resolution of issues.

• 4C S/G AFW Steam Supply Valve MOV-4-1406 Malfunction, AR 1925605

• Unit 3 Intake Cooling Water (ICW) System

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors completed in-office reviews and control room inspections of the licensees risk assessment of four emergent or planned maintenance activities. The inspectors verified the licensees risk assessment and risk management activities using the requirements of 10 CFR 50.65(a)(4); the recommendations of Nuclear Management and Resource Council 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3; and procedures 0-ADM-068, Work Week Management; WM-AA-1000, Work Activity Risk Management; and O-ADM-225, On Line Risk Assessment and Management. The inspectors also reviewed the effectiveness of the licensees contingency actions to mitigate increased risk resulting from the degraded equipment and the licensee assessment of aggregate risk using procedure OP-AA-104-1007, Online Aggregate Risk. The inspectors discussed the on-line risk monitor (OLRM) results with the control room operators and verified all applicable out of service equipment was included in the OLRM calculation. The inspectors evaluated the following four risk assessments during the inspection period:

• 4C Component Cooling Water (CCW) pump, 4B Containment Spray (CS) pump, and 4C charging pump OOS

• 4A CCW pump, 4A Intake Cooling Water (ICW) pump, and 4B emergency containment cooler OOS

• 3A charging pump, 3A CS pump, and 3C CCW heat exchanger OOS

• 3B EDG and 3B ICW header OOS

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors evaluated the technical adequacy of licensee evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred for four operability evaluations described in the ARs listed below. The inspectors reviewed applicable sections of the final safety analysis report to determine if the system or component remained available to perform its intended function. In addition, when applicable, the inspectors reviewed compensatory measures implemented to verify that the affected equipment remained capable of performing its design function. The inspectors also reviewed a sampling of condition reports to verify that the licensee was routinely identifying and correcting any deficiencies associated with operability evaluations.

• AR 1913062, Maintenance surveillance procedures not in accordance with current license basis

• AR 1859006, 3A and 3B EDG radiator support structure

• AR 1917112, Startup transformer breaker potential technical specification noncompliance

• AR 1921626, Excessive leakage from POV-4-4882

b. Findings

No findings were identified.

1R19 Post Maintenance Testing

a. Inspection Scope

For the three post maintenance tests and associated work orders (WO) listed below, the inspectors reviewed the test procedures and either witnessed the testing or reviewed test records to determine whether the scope of testing adequately verified that the work performed was correctly completed and demonstrated that the affected equipment was operable. The inspectors verified that the requirements in licensee procedure 0-ADM-737, Post Maintenance Testing, were incorporated into the test requirements. The inspectors reviewed the following WOs consisting of three inspection samples:

• WO 40218943, 4A intake cooling water pump motor repair and inspection

• WO 40271241, 4A CCW heat exchanger clean and inspection

• WO 40276916, Unit 4 AFW Train I steam supply repair

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors either reviewed or observed the following five surveillance tests to verify that the tests met the technical specification requirements, the final safety analysis report description, the licensees procedural requirements, and demonstrated the systems were capable of performing their intended safety functions and operational readiness. In addition, the inspectors evaluated the effect of the testing activities on the plant to ensure that conditions were adequately addressed by the licensee staff and that after completion of the testing activities, equipment was returned to the positions/status required for the system to perform its safety function. The inspectors verified that surveillance issues were documented in the CAP. The inspectors reviewed the following tests:

Surveillance Test:

• 4-OSP-023.1, 4A EDG monthly test In-Service Tests:

• 3-OSP-050.2B, 3B RHR pump and valve in-service test (IST)

• 4-OSP-075.6, AFW Train I valve IST and backup nitrogen test

• 3-OSP-075.1, AFW Train I pump IST RCS Leak Detection Test:

• 4-OSP-041.1, Unit 4 reactor coolant system leak rate calculation Findings No findings were identified.

Cornerstone: Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The NSIR headquarters staff performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) and the Emergency Plan located under ADAMS accession numbers ML130380289, ML131440168, ML13220A054, ML13256A009, and ML13346A493, as listed in the Attachment.

The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these revisions are subject to future inspection. Documents reviewed are listed in the Attachment. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill

a. Inspection Scope

On December 12, 2013, the inspector observed an emergency preparedness drill and the performance of the licensees emergency response organization. The drill included a simulated ammonium hydroxide spill outside the 3B 4kV bus room, a small break loss of coolant accident (SBLOCA) from a Unit 3 RCS safety valve failing open followed by a RCS depressurization and PRT rupture resulting in a RCS barrier failure requiring a Site Area Emergency declaration and notification to state of Florida, county officials, and the NRC per licensee procedure 0-EPIP-20101, Duties of the Emergency Coordinator. The scenario progressed to the loss of a third RCS barrier requiring a General Emergency declaration and an additional notification to the state of Florida and the NRC. The inspector observed the crew in the plant simulator including simulated implementation of emergency procedures and staff in the Technical Support Center (TSC) using the event classification guidelines and emergency response procedures. During the drill, the inspectors observed the simulator and TSC staff verify that emergency classification and notifications were made in accordance with the licensee emergency plan implementing procedure 0-EPIP-20101. The inspector attended the licensees post drill critique, reviewed the licensees critique items, and discussed inspector observations with the licensee to verify that drill issues were identified and captured in the corrective action program.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification (IP 71151)

Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors reviewed licensee submittals for the Unit 3 and Unit 4 performance indicators (PIs) listed below for the period October 1, 2012, through September 30, 2013, to verify the accuracy of the PI data reported during that period. Performance indicator definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and licensee procedure 0-ADM-032, NRC Performance Indicators Turkey Point, were used to check the reporting for each data element. The inspectors checked operator logs, plant status reports, condition reports, system health reports, and PI data sheets to verify that the licensee had identified the required data, as applicable. The inspectors interviewed licensee personnel associated with performance indicator data collection, evaluation, and distribution.

• Emergency AC power

• Residual heat removal system

• Heat removal system

• High pressure injection system

• Cooling water system

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (IP 71152)

.1 Daily Review

a. Inspection Scope

As required by Inspection Procedure 71152, Identification and Resolution of Problems, and to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a screening of items entered daily into the licensees corrective action program. This review was accomplished by reviewing daily printed summaries of ARs and by reviewing the licensees electronic AR database.

Additionally, RCS unidentified leakage was checked on a daily basis to verify no substantive or unexplained changes. Documents reviewed are listed in the Attachment.

b. Findings

No findings were identified.

.2 Annual Sample: Apparent Cause Evaluation Associated With Valve Misposition on Unit

3 RWST

a. Inspection Scope

The inspectors selected AR 01912475, Unit 3 RWST Lowered Followed by Rising Level in Unit 3 SFP, for a more in-depth review of the circumstances and the corrective actions that followed. On October 15, 2013, while performing 3-NOP-033 for placing Unit 3 Refueling Water Storage Tank (RWST) on purification, valve 3-798E (SFP Demineralizer return to SFP Isolation valve) was left one turn open. The discrepancy was discovered when the RWST minimum level alarm was received. At about the same time, the Unit 3 Spent Fuel Pool High level alarm was received. Once it was discovered that 3-798E was open, the valve was closed and the Unit 3 RWST Purification pump was secured in accordance with 3-NOP-033. The licensee then restored the RWST level to its normal band with procedure 0-OP-046 CVCS Makeup to the RWST. As a result, the RWST level lowered to approximately 321,600 gallons, which was still greater than the Technical Specification 3.5.4 required RWST level of greater than or equal to 320,000 gallons.

The inspectors reviewed the licensees evaluation of the event and the associated corrective actions taken or planned. The inspectors reviewed licensee performance attributes associated with complete and accurate information of the problem, 10 CFR 50.72 reporting requirements, identification of the root and contributing causes, and planning or completion of assigned corrective actions. The inspectors interviewed plant personnel and evaluated the licensees administration of this selected condition report in accordance with their corrective action program as specified in licensee procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205, Condition Evaluation and Corrective Action.

b. Findings and Observations

No inspector findings were identified. The licensee determined the apparent cause of the event was due to the control room operators not adequately monitoring plant indications during alignment of SFP and RWST valves. The inspectors noted that the licensee identified contributing causes to be that the operator performing the valve manipulations believed that the valve was shut based on change in torque required to rotate the valve handle and did not verify it was fully shut, and that there were no cautions or notes in the procedure to monitor RWST level on DCS following realignment.

Immediate corrective actions for this event included an operations department human performance evaluation and event review by operations personnel, an extent of condition review to determine if other RWST inventory losses had similar contributing causes, and to review and enhance Unit 3 and Unit 4 NOP-033 procedures with cautions to trend RWST level during purification evolutions.

.3 Semi-Annual Trend

a. Inspection Scope

The inspectors performed a review of the licensees corrective actions documents and work request documents, attended shift plant status meetings, and discussed plant operations with the operating staff to identify trends that could indicate the existence of a more significant safety issue. This review was focused on the trend of equipment mispositions due to inadvertent contact and component misposition during operation.

The inspectors review was focused on the repetitive nature of several valve, breaker, and switch mispositions and the associated action requests, causal analyses, and corrective actions. The inspectors review nominally considered the six month period from July 1 to December 31, 2013. The inspectors reviewed the licensees trend AR 1904700 which documented a common cause evaluation for recent equipment mispositions. The inspectors evaluated the effectiveness of the licensees corrective actions and the significance of the problem including attributes such as accurate documentation, reportability, and problem resolution.

b. Findings and Observations

No inspector findings were identified. The licensees common cause evaluation determined that the most common cause of the events was related to human performance and failure of supervision to be focused on all aspects of the job; specifically providing guidance on how to identify and eliminate items that could lead to a component misposition and identify actions to mitigate the resulting consequences of any unexpected misposition event. In particular, the licensee determined that procedural guidance was less than adequate and did not provide adequate checks and balances to develop troubleshooting guidance when the risk was identified as low/medium for work on/around risk significant systems and components. The inspectors did not identify any trends not observed by the licensees trending activities.

4OA3 Follow-up of Events and Notice of Enforcement Discretion (IP 71153)

.1 (Closed) Licensee Event Report (LER) 05000251/2013-002-00, Reactor Trip Due to

Loss of Offsite Power Resulting from Generator Testing On April 19, 2013, Unit 4 was in Mode 1 at 30 percent reactor power while the licensee performed harmonic generator testing on the main generator. During the test, main generator exciter voltage was lowered enough to initiate an unplanned load center degraded voltage signal to the 4B sequencer which initiated bus stripping and loading of the safety related 4kV buses to their respective EDG. The reactor tripped due to loss of the reactor coolant pumps (RCPs), which were tripped by the 4B sequencer during bus stripping. The plant entered 4-EOP-ES-0.2, Natural Circulation Cooldown, due to the loss of the running RCPs. The degraded voltage relays, sequencer, and EDGs all performed their intended function. The EDG start-up and reactor scram initially gave the appearance to the operating crew that there was a loss of offsite power and the crew declared an Unusual Event, but offsite power was never lost.

a. Inspection Scope

During the week of November 11, 2013, the inspectors followed up on this LER. The inspectors reviewed the licensees root cause evaluation and corrective actions for this event as documented in AR 1867690. The licensees root cause evaluation identified the root causes of the event to be that: 1) the test instruction did not provide adequate precautions and limitations to prevent lowering load center bus voltages to the point of initiating 4 kV bus stripping, and 2) the management team, operations personnel, work control personnel, and control room operators executing the harmonic test failed to identify the risk associated with performance of the test and take appropriate measures to prevent any unplanned consequences. Corrective actions included a revision to procedure WM-AA-100-1000, Work Activity Risk Management, to include additional guidance involving online maintenance and risk insights when planning maintenance on the main generator.

b. Findings

Introduction:

A green self-revealing finding was identified for the licensees failure to provide adequate test precautions, limitations, and instructions for performing harmonic testing on the Unit 4 turbine generator control circuitry while in Mode 1 operation. As a result, 480 volt load center voltage was lowered enough to initiate a degraded voltage signal to the 4B safety related 4 kV bus sequencer which tripped the RCPs causing a reactor trip due to low RCS flow.

Description:

On April 19, 2013, Unit 4 was in Mode 1 at 30 percent reactor power while performing turbine generator harmonic testing on Unit 4 by lowering main generator exciter voltage to provide a MVAR output range for data collection. In the process of performing this testing, the voltage was lowered enough to initiate an unplanned load center degraded voltage signal to the 4B safety related 4 kV bus sequencer which initiated bus stripping and loading of the safety related 4kV buses to their respective EDGs. The reactor tripped as designed due to the loss of the RCPs which were tripped by the 4B bus sequencer during 4 kV bus stripping. The degraded voltage relays, sequencer, and EDGs all performed their intended safety function. The EDGs automatic start-up and reactor scram initially gave the appearance to the operating crew that there was a loss of offsite power, but offsite power was never lost. The licensee entered this event into their corrective action program as AR 1867690 and conducted a root cause evaluation (RCE).

The RCE determined the root causes of the event to be that: 1) the test instruction did not provide adequate precautions and limitations to prevent lowering load center bus voltages to the point of initiating 4 kV bus stripping, and 2) the management team, operations personnel, work control personnel, and control room operators executing the harmonic test failed to identify the risk associated with performance of the test and take appropriate measures to prevent any unplanned consequences. Specifically, the test instruction, TI-246904-01, 3rd Harmonic Relay Test, did not provide adequate instructions to prevent creating a degraded voltage condition. Also, the test was classified as low risk rather than high risk per licensee procedure WM-AA-100-1000, Work Activity Risk Management. The inspectors determined that the licensee classification of the test as low risk was in error and not in accordance with licensee procedure WM-AA-100-1000. Procedure WM-AA-100-1000, Section 1.0, defines high risk work as work that could cause a reactor plant or safety system actuation if an error is made. The inspectors determined that if the testing was classified as high risk in accordance with the subject procedure, then a more robust Plant Test Procedure (PTP)would have been used in place of a Test Instruction (TI) and would have provided additional precautions and limitations regarding degraded voltages and impact on plant operation.

Analysis:

The licensees failure to provide adequate test precautions, limitations, and instructions for performing harmonic testing on the Unit 4 turbine generator control circuit while in Mode 1 operation was a performance deficiency. Specifically, TI-246904-01, 3rd Harmonic Relay Test, did not provide adequate instructions to prevent creating a degraded voltage condition during the test and the work activity was classified in error as low risk rather than high risk contrary to licensee procedure WM-AA-100-1000, Work Activity Risk Management. The inspectors determined the performance deficiency was more than minor using IMC 0612, Appendix B, Issue Screening (September 7, 2012),because the performance deficiency was associated with the procedure quality 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 have an adequate procedure for conducting the turbine generator harmonic testing resulted in a reactor trip due to the loss of RCPs from 4B sequencer 4 kV bus stripping. The inspectors evaluated the significance of the finding using Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power (June 9, 2012), 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 control component of the human performance area because the licensee failed to include the proper risk insights for work activities related to nuclear safety and prevent a subsequent reactor trip

H.3(a).

Enforcement:

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. The licensee entered this issue into the corrective action program as AR 1867690. Because this finding did not involve a violation and was of very low safety significance, it was identified as Finding (FIN): (05000251/2013005-01, Inadequate Test Precautions, Limitations, and Instructions for Performing Harmonic Testing on the Unit 4 Turbine Generator)

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period the inspectors conducted observations of security force personnel activities to ensure that the activities were consistent with the licensee security procedures and regulatory requirements relating to nuclear plant security.

These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status reviews and inspection activities.

b. Findings

No findings were identified.

.2 (Closed) Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions

Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations

a. Inspection Scope

The inspectors independently verified that the licensees proposed interim actions would perform their intended function for flooding mitigation using the following methods:

• Visual inspection of the flood protection feature was performed if the flood protection feature was relevant. External visual inspection for indications of degradation that would prevent its credited function from being performed was performed.

• Reasonable simulation

• Flood protection feature functionality was determined using either visual observation or by review of other documents.

The inspectors verified that issues identified were entered into the licensee's corrective action program.

b. Findings

No findings were identified.

4OA6 Meetings

Exit Meeting Summary

The resident inspectors presented the inspection results to Mr. Kiley and other members of licensee management on January 15, 2014. The inspectors asked the licensee whether any of the material examined during the inspection should be considered proprietary information. The licensee did not identify any proprietary information.

ATTACHMENT: SUPPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel:

F. Banks, Quality Manager C. Cashwell, Radiation Protection Manager T. Conboy, Plant General Manager P. Czaya, Licensing C. Domingos, Engineering Director T. Eck, Security Manager M. Epstein, Emergency Preparedness Manager D. Funk, Operations Manager M. Jones, System Engineering Manager M. Katz, Maintenance Manager M. Kiley, Site Vice-President S. Mihalakea, Licensing N. Rios, Chemistry Manager D. Sluzka, Work Controls Manager B. Stamp, Training Manager R. Tomonto, Licensing Manager M. Wayland, Operations Director NRC personnel:

J. Hanna, Senior Risk Analyst, Division of Reactor Safety S. Sandal, Senior Project Engineer LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened and Closed 05000251/2013005-01 FIN Inadequate Test Precautions, Limitations, and Instructions for Performing Harmonic Testing on the Unit 4 Turbine Generator (Section 4OA3.1)

Closed 05000251/2013002-00 LER Reactor Trip Due to Loss of Offsite Power Resulting From Generator Testing (Section 4OA3.1)05000250, 251/2515/190 TI Inspection of the Licensees Proposed Interim Actions as a Result of the Near-Term Task Force Recommendation 2.1 Flooding Reevaluation (Section 4OA5.2)

LIST OF

DOCUMENTS REVIEWED

Action Requests:

01929777 01927263 01923001 01922877 01920328

01928475 01927551 01921807 01922376 01918654

01927548 01922061 01919795 01918812 01918224

01922054 01919970 01918604 01918648 01908115

01919841 01918334 01915803 01917697 01928064

01918272 01916611 01910953 01911987 01916088

01916512 01910953 01922363 01926868 01908524

01910991 01912475 01921626 01916434 01922417

01929610 01904700 01916706 01910583

01928244 01916537 01908613 01867690

01916276 01908606 01919470 01927861

01908526 01922589 01927705 01927953

01922418 01927707 01927356 01927443

01929859 01927281 01927437 01922762

Section 1R04: Equipment Alignment

P&ID 5610-M-3075, Auxiliary Feedwater (AFW) System Turbine Drive for AFW Pumps

Turkey Point System Description 117, Auxiliary Feedwater System

P&ID 5614-M-3022, Emergency Diesel Engine and Oil System

4-OP-023, Emergency Diesel Generator

4-NOP-022, Emergency Diesel Generator Fuel Oil System

4-OSP-075.5, Auxiliary Feedwater System Flow Path Verification

Section 1R05: Fire Protection

0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions

P&ID 5610-E-301, Grounding Notes, Symbols & Details

Section 1R06: Flood Protection Measures

Drawing 5610-C-1695, Network of Barriers for External Flood Protection

0-SMM-102.1, Flood Protection Stop Log and Penetration Seal Inspection

Section 1R11: Licensed Operator Requalification

Records:

License Reactivation Packages (5)

LORP Training Attendance records (11 cycles for Shift 2: LOCT 121-126, 130, 13A-13D)

Medical Files (15)

Remedial Training Records (7)

Feedback Summaries: 2 year LOCT Feedback Report with beginning date of Dec. 12, 2011

Written Examinations:

Exams 1-2, 2013 Annual Operating Test

Procedures:

0-NTP-004, Implementation

0-ADM-315, Licensed Operator Continuing Training Program

0-ADM-305, Simulator Configuration Management

SEI-004, Simulator Discrepancy Reporting

SEI-025, Simulator Operability Testing

TR-AA-221, Simulator Change Control

SEI-009, Simulator Physical Fidelity Validation

0-NTP-005, Evaluation

0-NTP-008, Conduct of Simulator Training

0-NTP-011, Training Performance Monitoring

0-NTP-016, LOCT Exam Development and Administration

TR-AA-230-1008, Simulator Scenario Based Testing and Validation

0-ADM-305, Simulator Configuration Management

SEI-09, Simulator Physical Fidelity Validation

SEI-25, Simulator Operability Testing

SEI-26, Simulator Verification and Validation Testing

SEI-31, Simulator / Plant Comparisons

TR-AA-221, Simulator Change Control

Simulator Steady State Tests:

Reduced Power (> 50%) Steady State Test, SST-002

Simulator Normal Evolution Tests:

Plant Shutdown from rated power to HSB, NPE-005

Plant Startup from HSB to rated power, NPE-003

Core Performance Test and transients

Plant Startup from Cold S/D to HSB, NPE-002

Plant Shutdown from Hot Standby to Cold Shutdown, NPE-006

Core Performance Test and transients

Simulator Transient Tests:

TRN-006 (2011), Turbine Trip Which Does Not Cause Automatic Reactor Trip

TRN-009 (2011), Main Steam Line Break Inside Containment

TRN-002, (2013), Loss of Normal and Emergency Feedwater

TRN-005, (2013), Trip of Any Single Reactor Coolant Pump

TRN, Maximum Design Load Rejection

Simulator Scenario Based Tests:

SBT Loss of CCW/Loss of Vacuum/ LBLOCA

SBT Loss of all AC/ Loss of all Feedwater

SBT Depressurization of all Steam Generators

SBT Pressurizer Steam Space LOCA

SBT RCP Seal Failure / Small Break LOCA

SBT Ruptured-Faulted Steam Generator Inside Containment

SBT Respond to Continuous Rod Withdrawal

SBT Power C 4KV Bus from Opposite Units Transformer

SBT Respond to Loss of RHR

SBT Shutdown Containment Purge

SBT Reestablish Charging Following a Charging Pump Failure

JPM Packages:

Reviewed, 2013 Annual Operating Exam Week 1 JPMs

Reviewed, 2013 Annual Operating Exam Week 2 JPMs

Scenario Guides:

Observed, 2013 Annual Operating Exam Week 1

Reviewed, 2013 Annual Operating Exam Week 2

Section 1R12: Maintenance Effectiveness

Action Request 01921801, Continuing Degradation of 3A ICW Pump

Unit 3 Health Report for Intake Cooling Water System

3-OSP-030.1, Component Cooling Water Pump Inservice Test

Section 1R15: Operability Evaluations

EN-AA-203-1001, Operability Determinations and Assessments

0-ADM-226, Operability Screening and Condition Reports

0-ADM-213, Technical Specification Related Equipment Out of Service Logbook

Section 1EP4: Emergency Action Level and Emergency Plan Changes

Change Packages:

0-EPIP-20101, Duties of Emergency Coordinator, Revision 9

0-EPIP-20132, Technical Support Center (TSC) Activation and Operation, Revision 4

Radiological Emergency Plan, Revisions 57, 58, 59, 60

0-EPIP-20126, Off-Site Dose Calculations - Extended Power Uprate, Revision 5

0-EPIP-20101, Duties of Emergency Coordinator, Revisions 12, 14

0-EPIP-20126, Off-Site Dose Calculations - Extended Power Uprate, Revision 7

Section 4OA3: Follow-up of Events and Notice of Enforcement Discretion

P&ID 5614-E-28, Electrical Auxiliaries Loss of Voltages Bus 4B

4-ONOP-090, Abnormal Generator MW/MVAR Oscillation

WO 40158812, Support Gen Power Stabilizer Tests

WM-AA-100-1000, Work Activity Risk Management

RCE - 3rd Harmonic Test (Unit 4 Reactor Trip)

LIST OF ACRONYMS

AR Action Request

CAP Corrective Action Program

CCW Component Cooling Water

CFR Code of Federal Regulations

EAL Emergency Action Level

EDG Emergency Diesel Generator

IST Inservice Testing

MVAR Factor of Voltage Output or Excitation

NAP Nuclear Administrative Procedure

NRC Nuclear Regulatory Commission

PI Performance Indicator

P&ID Piping and Instrumentation Drawing

RCE Root Cause Evaluation

RCP Reactor Coolant Pump

RCS Reactor Coolant System

U3 Unit 3

U4 Unit 4

UFSAR Updated Final Safety Analysis Report

WO Work Order

Attachment