IR 05000250/2022001

Integrated Inspection Report 05000250/2022001 and 05000251/2022001

ML22130A562
Person / Time
Site:	Turkey Point
Issue date:	05/11/2022
From:	David Dumbacher NRC/RGN-II/DRP/RPB3
To:	Coffey B Florida Power & Light Co
References
05000250/2022001, 05000251/2022001, IR 2022001
Download: ML22130A562 (18)

Text

SUBJECT:

TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2022001 AND 05000251/2022001

Dear Mr. Coffey:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On April 14, 2022, the NRC inspectors discussed the results of this inspection with Mr. Michael Pearce and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Turkey Point Units 3 & 4.May 11, 2022 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000250 and 05000251

License Numbers: DPR-31 and DPR-41

Report Numbers: 05000250/2022001 and 05000251/2022001

Licensee: Florida Power & Light Company

Facility: Turkey Point Units 3 & 4

Location: Homestead, FL 33035

Inspection Dates: January 01-March 31, 2022

Inspectors: P. Cooper, Senior Reactor Inspector J. Diaz-Velez, Senior Health Physicist M. Endress, Senior Resident Inspector C. Fontana, Emergency Preparedness Inspector T. Morrissey, Senior Construction Inspector R. Reyes, Resident Inspector J. Rivera, Health Physicist S. Sanchez, Senior Emergency Preparedness Inspector

Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Turkey Point Units 3 & 4, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report Section: 7115

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000250,05000251/20 LER 2021-002-00 for Turkey 71153 Closed 21-002-00 Point, Units 3 and 4,

Unrecognized Technical Specification Surveillance Requirement Non-Compliance

PLANT STATUS

Unit 3 operated at or near rated thermal power for the entire inspection period.

Unit 4 began the inspection period at rated thermal power. On March 11, 2022, the unit was down powered to 44 percent for main steam safety valve (MSSV) testing. Following MSSV testing, the unit was down powered to zero percent for a scheduled refueling outage on March 12, 2022. The unit remained shutdown for a refueling outage for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 4 A and B Intake Cooling Water (ICW) pumps and headers while the C ICW pump was out of service (OOS), on January 12, 2022.

(2) Unit 3 B Emergency Diesel Generator (EDG) while the 3A EDG was OOS, on January 18, 2022.

(3) Unit 3 and Unit 4 Auxiliary Feedwater (AFW) pumps A and B on Train 1 and 2, respectively, while the C AFW pump was OOS for maintenance, on March 2, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Units 3 and 4 Steam Generator Feedwater pump rooms (Fire Zone (FZ) 069 and 066), on February 07, 2022

(2) Units 3 and 4 Turbine Lube Oil reservoirs area (FZs 081 and 076), on February 9, 2022

(3) Unit 3A, 3B, 4A, and 4B EDG rooms (FZs 73, 72, 138, and 133), on March 03, 2022

(4) Units 3 and 4 Control Room (FZ 106), on March 12, 2022

(5) Unit 4 Containment (FZ 59), on March 28, 2022

(6) Unit 3 and Unit 4 Condensate Storage Tank cages (FZ 89 and 77), on March 28, 2022.

(7) Unit 3 and Unit 4 480V Load Center and 4160KV Switch Gear 2nd floor elevations (FZs 095, 096, 093, and 094), on March 29, 2022.

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the on-site fire brigade training and performance during an announced fire drill on February 22, 2022.

===71111.08P - In-service Inspection Activities (PWR)

PWR In-service Inspection Activities Sample (IP Section 03.01)===

(1) The inspectors verified that the reactor coolant system boundary, steam generator tubes, reactor vessel internals, risk significant piping system boundaries, and containment boundary are appropriately monitored for degradation by reviewing the following activities from March 14 to April 7, 2022:

1. Ultrasonic Examination a. 14"-RHR-1401-3, Pipe to Elbow, ASME Class 1 (reviewed)b. 14"-RHR-1401-4, Elbow to Pipe, ASME Class 1 (reviewed)c.

10"-SI-1401-16, Elbow to Pipe, ASME Class 1 (reviewed)d. 10"-SI-1401-17, Elbow to Elbow, ASME Class 1 (reviewed)e. 10"-SI-1401-18, Elbow to Branch Connection, ASME Class 1 (reviewed)2. Visual Examination a. Bottom Mounted Instrument Nozzle Penetrations, PEN01 - PEN50, ASME Class 1 (reviewed)3. Eddy Current Testing (ECT)a. SG 4A, tube R037C071, ASME Class 1 (observed)b. SG 4B, tube R034C046, ASME Class 1 (observed)c.

SG 4C, tube R034C053, ASME Class 1 (observed)

The inspectors also evaluated the licensees boric acid control program performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during the following evolutions:

Unit 4 down power to 17%, reactor trip and execution of EOP-E0, Reactor Trip and Safety Injection, on March 11, 2022 Unit 3 reactor coolant system (RCS) dilution and Unit 4 outage operations maintaining RCS inventory below 5% pressurizer level in preparation for reactor head lift, on March 16, 2022

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a training simulator scenario administered to an operating crew on January 31, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Unit 3 ICW leak repair

(2) AR 1953341 and 1977207, and evaluations EVAL-PTN-051-0034 and EVAL-PTN-051-00343, Containment Purge Valves Maintenance Rule a(1) action plan

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 3 and Unit 4 online risk assessment while the 4C ICW pump, 3B2 Circulating Water pump, 4B Component Cooling Water (CCW) heat exchanger, and the Unit 4 motor-driven instrument air compressor were OOS, on January 12, 2022

(2) Unit 3 and Unit 4 online risk assessment while the 4CM motor-driven instrument air compressor, MOV-4-535 Pressurizer Power Operated Block Valve (PORV),

PCV-4-456 Pressurizer PORV, 3A and 4A Emergency Containment Coolers (ECC),and 3B EDG were OOS, on January 24, 2022

(3) Unit 3 and Unit 4 online risk assessment while the 3A EDG, 3C ECC, 3A ICW header, and the 4B ECC OOS, on February 14, 2022

(4) Unit 3 and Unit 4 online risk assessment while the 4B EDG, 4B HHSI pump, and the Unit 3 Train 1 AFW system was OOS, on March 07, 2022

(5) Unit 3 online risk assessment and Unit 4 refueling outage yellow risk assessment while Unit 4 had the RCS inventory below 5% level in the pressurizer and one Unit 4 HHSI pump unavailable to Unit 3 while using it to fill the Unit 4 accumulators, on March 16, 2022

(6) Unit 3 online risk assessment and Unit 4 shutdown risk assessment while the Unit 4 was in yellow shutdown condition while the 4B ICW header, 4B and 4C ICW pumps, and the 4B EDG were unavailable, on March 23, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (8 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) AR 02414956, CV-4-2908 4C ECC outlet failed to open

(2) AR 02426335, CV-4-2903 4B ECC inlet shows dual indication

(3) AR 02416897, Past Operability Review for removed missile barrier for unknown period of time

(4) AR 02418762, CCW flowrate during 3A CCW pump in-service test (IST)

(5) AR 02418474, Potential Non-compliance with Technical Specifications for containment airlock testing

(6) AR 02420519, Electrical-driven pump discharge pressure did not meet functional criteria

(7) AR 02420308, While troubleshooting the 4C steam generator high steam flow spiking associated with channel IV, upon connecting a power supply, all channel III high steam flow channels tripped

(8) AR 02418421, Outage ECO 28-01 Mode 3 possible TS 3.0.3 entry

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Work order (WO) 40622437 and 0629865, Unit 4C ICW pump replacement and lift, and IST per 4-OSP-019.1, Intake Cooling Water In-service Test (Section 7.3, ICW pump 4C test), performed on January 14, 2022

(2) WO 40740105, C AFW pump 3CR relay replacement. Post-maintenance test performed within work order on March 02, 2022

(3) WO 40781211 and 40818153, Unit 3B Charging Pump coupling change, suction stabilizer preventive maintenance and oil change, and tested using 3-OSP-047.1B, Charging Pump 3B Group A Pump Test, performed on March 4, 2022

(4) WO 40758139, repair limit switch on the Unit 4 power operated relief valve PCV-4-456 and test as described in work order

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage PT4-33 activities from March 11-31, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (5 Samples)

(1) 4-OSP-055.1, ECC Operability Test (4A ECC), performed on January 24, 2022

(2) 3-OSP-075.1, AFW Train 1 Operability Verification (Section 7.1 AFW Pump A operability test), performed on February 12, 2022

(3) 3-OSP-023.1, Diesel Generator Operability Test (Unit 3A EDG semi-annual rapid start test), performed on February 14, 2022

(4) 3-OSP-075.2, AFW Train 2 Operability Verification (Section 7.1 B pump and Section 7.2 C pump), performed on March 02, 2022

(5) 4-OSP-072.6, Main Steam Safety Valve Set Point Surveillance Using Team Trevitest Mark VIII Equipment (for relief valves RV-4-1401, 1405, 1406, 1407 and 1410) on March 25, 2022

In-service Testing (IP Section 03.01) (2 Samples)

(1) 4-OSP-019.1, ICW IST (Section 7.2, 4B ICW Pump test), performed on January 19, 2022

(2) 3-OSP-030.1, Component Cooling Water Pump IST (Section 7.1 CCW pump 3A test),performed on February 11, 2022

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) 4-OSP-051.5, Local Leak Rate Test Penetration 19A for Containment Spray (4-890A, MOV-4-880A, 4-883M), performed on March 15, 2022

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of January 10, 2022.

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Response Organization during the week of January 10, 2022.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of January 10, 2022. This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of the emergency preparedness program during the week of January 10, 2022.

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) observed the Emergency Preparedness drill in the control room simulator and the technical support center, on February 23,

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) workers exiting the Radiological Control Area (RCA) during Unit 4 outage

(2) workers exiting containment during Unit 4 outage

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Unit 4 outage reactor head lift

(2) Unit 4 outage bottom mount inspection

(3) Unit 4 outage steam generator secondary side activities High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) North Evaporator Room in Radwaste Building

(2) Unit 4 RHR Charging Pump Room

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials in the following areas:

(1) Dry Waste Storage

(2) Long Term Storage Yard

(3) Radwaste Building

Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) North and South Filling Rooms in Radwaste Building

Waste Characterization and Classification (IP Section 03.03) (1 Sample)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Part 51 Sample S1-20-0056 - Dry Active Waste

Shipping Records (IP Section 03.05) (5 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) PTN-M-21-034 - LSA

(2) PTN-W-22-001 - Limited Quantity

(3) PTN-M-22-016 - LSA

(4) PTN-W-21-003 - LSA

(5) PTM-W-22-002 - Limited Quantity

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===

(1) Unit 3 (January 1-December 31, 2021)

(2) Unit 4 (January 1-December 31, 2021)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 3 (January 1-December 31, 2021)

(2) Unit 4 (January 1-December 31, 2021)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 3 (January 1-December 31, 2021)

(2) Unit 4 (January 1-December 31, 2021)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) November 1, 2021-February 28, 2022.

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) November 1, 2021-February 28, 2022.

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) January 1-September 30, 2021

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1-September 30, 2021

EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) January 1-September 30, 2021

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) The inspectors selected several ARs related to previously identified structural deficiencies and areas of aging related degradation associated with the Unit 3 and Unit 4 intake structure.

Unit 3 Intake Structure: AR 1767712, 1767745, 1767748, 1767757, 1767763,

===1767769, 1767776, 1767784, 1767788, 1767794, 1767796, 1767802, 1768139, 1768146, 1768154, 1768157, 2359905 Unit 4 Intake Structure: AR 1788004, 1788007, 1788011, 1788013, 1788018, 1788020, 1788021, 1843890, 1843895, 1843898, 1843907, 1843912, 1843915

These ARs were selected for follow-up to verify the licensees corrective actions were appropriate to maintain structural integrity of the intake structure.

71153 - Follow Up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02)===

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000250/2021-002-001, Unrecognized Technical Specification Surveillance Requirement Non-Compliance (ADAMS Accession No. ML21154A110). The inspector conclusions associated with this LER are documented in the Inspection Results Section of this report.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92709 - Licensee Strike Contingency Plans Licensee Strike Contingency Plans

(1) On February 15, 2021, at midnight, the contract between the International Brotherhood of Electrical Workers (IBEW) and Florida Power and Light (FPL) expired.

In preparation, inspectors verified that FPL had established a qualification program to ensure that non-bargaining unit personnel would be properly qualified to assume union positions should a strike or lockout have actually occurred. Inspectors verified that the non-bargaining unit watch standers had completed the qualification requirements and verified that licensed operators had active licenses. Inspectors also verified that the required supply chains would not be interrupted if picket lines were established. Additionally, inspectors were in place to assess actual licensee performance in the area of operations and maintenance should a strike/lockout occur. A strike/lockout did not occur and both sides came to a verbal agreement on February 15,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Violation: Technical Specification Surveillance Requirement 4.3.1.1 requires, in part, that each Reactor Trip System instrumentation channel and interlock and the automatic trip logic shall be demonstrated OPERABLE by the performance of the reactor trip system instrumentation surveillance requirement specified in Table 4.3-1. Table 4.3-1, functional unit 20, Automatic Trip and Interlock Logic, specifies that each train shall be tested in accordance with the Surveillance Frequency Control Program. Licensee administrative procedure 0-ADM-235, Technical Specification Surveillance Frequency Control Program, revision 20, Attachment 1, in effect at the time, specified a 92-day frequency for Surveillance Requirement 4.3.1.1. TS Surveillance Requirement 4.0.2 allows a maximum allowable extension of 25 percent to this frequency which would allow 115 days between surveillance performances. Functional Unit 20 includes trip functions Reactor Coolant Low Flow and Reactor Coolant Pump Breaker Open. These two trip functions are not required and are bypassed when power is raised above 45 percent (P-8). If either unit power is lowered below 45 percent power and the surveillances had not been performed within 115 days, then the Reactor Coolant Low Flow and Reactor Coolant Pump Breaker Open functions are inoperable due to not being within their surveillance frequency. With two channels of a function inoperable, TS 3.0.3 should be entered requiring, in part, that the unit be placed in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. One channel inoperable requires entry into TS 3.3.1, Action 8, that requires, in part, that the unit be placed in Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Contrary to the above, over the last 3 years, when unit power was lowered below 45 percent (greater than 115 days of performing the surveillances), the licensee failed to enter TS 3.0.3 when two trains were inoperable three times for Unit 3 (September 2018, September 2019, and March 2020) and one time for Unit 4 (March 2019). For Unit 3, the licensee also failed one time to enter TS 3.3.1 (one train inoperable, May 2019).

Significance/Severity: Green. The failure to enter TS 3.3.1 and TS 3.0.3, as applicable, when one or two trains of Automatic Trip and Interlock Logic functions (Reactor Coolant Low Flow and Reactor Coolant Pump Breaker Open) were no longer considered operable was a performance deficiency. The performance deficiency was more than minor since it was associated with Human Performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events. This violation is of very low safety significance (GREEN) based on the results of the IMC 0609, Appendix A, Exhibit 2 -

Mitigating Systems Screening Questions. Specifically, there was no loss of safety function for the two Automatic Trip and Interlock Logic functions. The surveillance requirements of these functions were subsequently performed satisfactory in each instance.

Corrective Action References: CR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 14, 2022, the inspectors presented the Emergency Preparedness Program inspection results to Mr. Michael Pearce and other members of the licensee staff.

On March 25, 2022, the inspectors presented the Radiation Protection inspection results to Michael Pearce and other members of the licensee staff.

On April 14, 2022, the inspectors presented the integrated inspection results to Mr. Michael Pearce and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.01 Corrective Action ARs 02413089, 03/22/2022

Documents 02419467,

2420079, and

2422265.

Corrective Action ARs 02421103 03/24/2022

Documents and 02422256.

Resulting from

Inspection

Procedures NISP-RP-006 Personnel Contamination Monitoring Rev. 1

RP-AA-103-1002 High Radiation Area Controls Rev. 12

RP-AA-104-1000 ALARA Implementing Procedure Rev. 18

71124.08 Corrective Action ARs 2389749, Various

Documents 2411841,

2414214,

2394781,

2417126,

2417540, and

2417951.

Procedures 0-ADM-607 SOLID RADIOACTIVE WASTE MINIMIZATION PROGRAM Rev. 0A

0-ADM-608 WASTE STREAM EVALUATION Rev. 1A

0-HPA-045 PROCESS CONTROL PROGRAM Rev. 0A

0-HPS-044.1 Exclusive Use Vehicle Inspection Rev. 1B

0-HPS-044.10 ACCIDENTS INVOLVING THE TRANSPORTATION OF Rev. 1C

RAD MATERIALS

0-HPS-053.6 Postings and Controls for Resin Transfers Rev. 3

0-NCOP-500 DTS WPS Media Addition 03/11/2005

0-NCOP-501 DTS WPS Media Sluice Rev. 1

0-NCOP-502 DTS Media Dewatering Rev. 1

0-NCOP-504 DTS Waste Processing System Operations Rev. 1

0-NCOP-506 Operation of the Primary Fillhead and Resin Liner 07/11/2009

3-NOP-061.07A CVCS DEMINERALIZER 3A RESIN TRANSFERS Rev. 8

RP-AA-108-1002 SHIPMENT OF RADIOACTIVE MATERIAL Rev. 17

Inspection Type Designation Description or Title Revision or

Procedure Date

RP-AA-108-1003 RADIOACTIVE MATERIALS SURVEYS FOR SHIPMENT Rev. 11

RP-AA-108-1004 PACKAGING RADIOACTIVE MATERIALS FOR SHIPMENT Rev. 4

71151 Corrective Action AR 02413983 AR 02413983 12/15/2021

Documents

Miscellaneous OpenEMS Permit Gas Permit Post-Release Final Report 12/22/2021

Number: G-2021-

079

OpenEMS Permit Gas Permit Post-Release Final Report 03/17/2022

Number: G-2022-

005

OpenEMS Permit Liquid Permit Post-Release Data 12/22/2021

Number: L-2021-

170

OpenEMS Permit Liquid Permit Post-Release Data 03/17/2022

Number: L-2022-

038

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