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{{Adams | |||
| number = ML16027A147 | |||
| issue date = 01/27/2016 | |||
| title = NRC Integrated Inspection Report 05000250/2015004, 05000251/2015004, October 1, 2015 to December 31, 2015 | |||
| author name = Suggs L | |||
| author affiliation = NRC/RGN-II/DRP/RPB3 | |||
| addressee name = Nazar M | |||
| addressee affiliation = Nextera Energy | |||
| docket = 05000250, 05000251 | |||
| license number = DPR-031, DPR-041 | |||
| contact person = | |||
| document report number = IR 2015004 | |||
| document type = Inspection Report, Letter | |||
| page count = 43 | |||
}} | |||
See also: [[see also::IR 05000250/2015004]] | |||
=Text= | |||
{{#Wiki_filter:UNITED STATES | |||
NUCLEAR REGULATORY COMMISSION | |||
REGION II | |||
245 PEACHTREE CENTER AVENUE NE, SUITE 1200 | |||
ATLANTA, GEORGIA 30303-1257 | |||
January 27, 2016 | |||
Mr. Mano Nazar | |||
President and Chief Nuclear Officer | |||
Nuclear Division | |||
NextEra Energy | |||
P.O. Box 14000 | |||
Juno Beach, FL 33408-0420 | |||
SUBJECT: TURKEY POINT NUCLEAR GENERATING STATION - NRC INTEGRATED | |||
INSPECTION REPORT 05000250/2015004, 05000251/2015004 | |||
Dear Mr. Nazar: | |||
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an | |||
inspection at your Turkey Point Nuclear Generating Station Units 3 and 4. On January 15, | |||
2016, the NRC inspectors discussed the results of the inspection with Mr. Tom Summers and | |||
other members of your staff. The inspectors documented the results of this inspection in the | |||
enclosed inspection report. | |||
NRC inspectors documented one self-revealing finding of very low safety significance (Green) in | |||
this report. The finding involved a violation of NRC requirements. The NRC is treating this | |||
violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement | |||
Policy. | |||
If you contest the violations or significance of these NCVs, 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, U.S. Nuclear | |||
Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at | |||
Turkey Point Nuclear Generating Station Units 3 and 4. | |||
If you disagree with a cross-cutting aspect assignment, 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 Nuclear | |||
Generating Station Units 3 and 4. | |||
M. Nazar 2 | |||
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 Agency wide 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/ | |||
LaDonna B. Suggs, Chief | |||
Reactor Projects Branch 3 | |||
Division of Reactor Projects | |||
Docket Nos.: 50-250, 50-251 | |||
License Nos.: DPR-31, DPR-41 | |||
Enclosure: | |||
IR 05000250/2015004, 05000251/2015004 | |||
w/Attachment: Supplementary Information | |||
cc Distribution via ListServ | |||
ML16027A147 SUNSI REVIEW COMPLETE FORM 665 ATTACHED | |||
OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS | |||
SIGNATURE TLH4 via email MXE2 via email MAB7 via email REW1 via email RXK3 /RA for/ RXK3 PGC1 via email | |||
NAME THoeg MEndress MBates RWilliams BPursley RKellner PCapehart | |||
DATE 1/26/2016 1/26/2016 1/25/2016 1/26/2016 1/26/2016 1/26/2016 1/25/2016 | |||
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO | |||
OFFICE RII:DRP RII:DRS RII:DRS | |||
SIGNATURE LJB4 RXK3 /RA FOR/ CMD4 via email | |||
NAME LSuggs JPanfel CDykes | |||
DATE 1/26/2016 1/26/2016 1/26/2016 | |||
E-MAIL COPY? YES NO YES NO YES NO | |||
M. Nazar 3 | |||
Letter to Mano Nazar from LaDonna B. Suggs January 27, 2016 | |||
SUBJECT: TURKEY POINT NUCLEAR GENERATING STATION - NRC INTEGRATED | |||
INSPECTION REPORT 05000250/2015004, 05000251/2015004 | |||
DISTRIBUTION: | |||
S. Price, RII | |||
L. Gibson, RII | |||
OE Mail | |||
RIDSNRRDIRS | |||
PUBLIC | |||
RidsNrrPMTurkeyPoint Resource | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION II | |||
Docket Nos: 50-250, 50-251 | |||
License Nos: DPR-31, DPR-41 | |||
Report Nos: 05000250/2015004, 05000251/2015004 | |||
Licensee: Florida Power & Light Company (FP&L) | |||
Facility: Turkey Point Nuclear Generating Station, Units 3 & 4 | |||
Location: 9760 S. W. 344th Street | |||
Homestead, FL 33035 | |||
Dates: October 1 to December 31, 2015 | |||
Inspectors: T. Hoeg, Senior Resident Inspector | |||
M. Endress, Resident Inspector | |||
M. Bates, Senior Operations Engineer | |||
R. Williams, Senior Reactor Inspector | |||
B. Pursley, Health Physicist | |||
C. Dykes, Health Physicist | |||
J. Panfel, Health Physicist | |||
B. Kellner, Senior Health Physicist | |||
P. Capehart, Senior Operations Engineer | |||
Approved by: LaDonna B. Suggs, Chief | |||
Reactor Projects Branch 3 | |||
Division of Reactor Projects | |||
Enclosure | |||
SUMMARY | |||
IR 05000250/2015004, 05000251/2015004; 10/01/2015 - 12/31/2015; Turkey Point Nuclear | |||
Generating Station, Units 3 and 4; Refueling Outage & Other Outage Activities. | |||
The report covered a three-month period of inspection by the resident inspectors and specialist | |||
inspectors from the Region II office. One Green non-cited violation (NCV) was identified. The | |||
significance of inspection findings are indicated by their color (i.e., greater than Green, or | |||
Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, | |||
Significance Determination Process, (SDP) dated April 29, 2015. The cross-cutting aspects | |||
were determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December | |||
4, 2014. All violations of NRC requirements were dispositioned in accordance with the NRCs | |||
Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe | |||
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor | |||
Oversight Process, Revision 5. | |||
NRC-Identified and Self-Revealing Findings | |||
Cornerstone: Barrier Integrity | |||
* Green: A self-revealing NCV of Technical Specification (TS) 6.8.1, Procedures and | |||
Programs, was identified when the licensee failed to properly implement procedure | |||
3-PMI-072.6, Steam Dump to Atmosphere Control Loop Calibration. Specifically, the | |||
licensee incorrectly installed a temporary electrical jumper in reactor operator console | |||
3C02 instead of 3C04, in contrast to Step 6.3.2 of 3-PMI-072.6. This action resulted in | |||
actuation of a 3B 4160 volt (V) vital bus lockout circuit causing loss of power to the B | |||
train of Unit 3 (U3) spent fuel pool (SFP) cooling. Immediate corrective actions were | |||
taken to remove the jumper and restore the B train of SFP cooling. The licensee | |||
entered the condition in its corrective action program (CAP) as action request (AR) | |||
02088911 and 02088914. | |||
The performance deficiency was determined to be more than minor because it was | |||
associated with the human performance attribute of the barrier integrity cornerstone and | |||
adversely affected the cornerstone objective to provide reasonable assurance that | |||
physical design barriers (fuel cladding, reactor coolant system (RCS), and containment) | |||
protect the public from radionuclide releases. In addition, the performance deficiency, if | |||
left uncorrected, had the potential to lead to a more significant safety concern. The | |||
finding was screened using IMC 0609, Significance Determination Process, | |||
Attachment 0609.04, Initial Characterization of Findings, Tables 2 and 3, dated July 1, | |||
2012, and Appendix G Attachment 1, Shutdown Operations Significance Determination | |||
Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 4 for Barrier | |||
Integrity, dated May 9, 2014. The inspectors determined the finding was of very low | |||
safety significance (Green) because it was not associated with low temperature over | |||
pressurization, freeze seals, steam generator nozzle dams, criticality, drain down or | |||
leakage paths, or the containment barrier. Furthermore, one train of SFP cooling | |||
remained in operation, the rate of SFP temperature rise was low (~ 2 °F/hour), and | |||
additional methods remained available to limit SFP temperature rise. This finding was | |||
assigned a cross cutting aspect associated with the procedure adherence element of the | |||
human performance area because the licensee failed to correctly execute step 6.3.2 of | |||
procedure 3-PMI-072.6 (H.8). (Section 1R20) | |||
3 | |||
Licensee-Identified Violations | |||
Violations of very low safety or security significance or Severity Level IV that were | |||
identified by the licensee have been reviewed by the NRC. Corrective actions taken or | |||
planned by the licensee have been entered into the licensees CAP. These violations | |||
and corrective action tracking numbers are listed in Section 4OA7 of this report. | |||
REPORT DETAILS | |||
Summary of Plant Status | |||
Unit 3 began this inspection period at 100 percent of Rated Thermal Power (RTP) where it | |||
remained until October 19, 2015, when it was shut down for a scheduled refueling outage | |||
(RFO). Unit 3 was restarted November 29, 2015, and returned to 100 percent of RTP on | |||
December 9, 2015, where it remained through the end of this inspection period. | |||
Unit 4 (U4) began this inspection period at 100 percent of RTP where it remained through the | |||
end of this inspection period. | |||
1. REACTOR SAFETY | |||
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity | |||
1R01 Adverse Weather Protection (IP 71111.01) | |||
.1 Readiness for Seasonal Extreme Weather Conditions | |||
a. Inspection Scope | |||
During the month of December, 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, | |||
Attachment 7, Cold Weather Readiness Check List, and Attachment 14, Turkey Point | |||
Site Specific Guidance. The inspectors reviewed system health reports and open CAP | |||
ARs for the emergency diesel generators (EDGs) and auxiliary feedwater (AFW) 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: | |||
* U3 and U4 EDGs | |||
* AFW pumps | |||
* U3 and U4 charging pumps | |||
* U3 and U4 boric acid storage tanks | |||
b. Findings | |||
No findings were identified. | |||
1R04 Equipment Alignment (IP 71111.04) | |||
.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 | |||
5 | |||
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, by entering them in the CAP, equipment | |||
alignment problems that could cause initiating events or impact the capability of | |||
mitigating systems or barriers. Documents reviewed are listed in the Attachment. This | |||
inspection constitutes three samples. | |||
* 4B EDG while 4A EDG was out of service (OOS) | |||
* 4A and 4B high head safety injection (HHSI) pumps while 3A and 3B HHSI pumps | |||
were OOS | |||
* 3B EDG while 3A EDG was OOS | |||
b. Findings | |||
No findings were identified. | |||
1R05 Fire Protection (IP 71111.05) | |||
.1 Fire Area Walk downs | |||
a. Inspection Scope | |||
The inspectors walked down the following five 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 | |||
inspectors routinely reviewed the licensees fire impairment lists and monitored the | |||
associated corrective actions for completion. The inspectors reviewed the AR report | |||
database to verify that fire protection problems were being identified and appropriately | |||
resolved in the CAP. The inspectors tours of the selected areas verified the fire | |||
protection equipment was installed as shown on the applicable fire plan drawings and | |||
appeared functional and ready for usage. This inspection constitutes five samples. The | |||
following areas were inspected: | |||
* U4 Pipe and Valve Room, Fire Zone 030 | |||
* U3 Containment Building, Fire Zone 060 | |||
* U4 4B Vital Battery Room, Fire Zone 102 | |||
* U3 and U4 Mechanical Equipment Room, Fire Zone 097 | |||
* Auxiliary Building Electrical Equiptment Room, Fire Zone 025 | |||
b. Findings | |||
No findings were identified. | |||
6 | |||
.2 Fire Protection - Drill Observation | |||
a. Inspection Scope | |||
On December 9, 2015, the inspectors observed an unannounced fire drill that took place | |||
within the station power block just outside the 3D31/4D31 non vital 125 VDC switchgear | |||
room in the turbine building. The drill was observed to evaluate the readiness of the | |||
plant fire brigade to fight fires and the control room to make the proper emergency action | |||
level (EAL) classification. The inspectors verified that the licensee staff identified | |||
deficiencies, openly discussed them in a self-critical manner at the drill debrief meeting, | |||
and took appropriate corrective actions as required. Specific attributes evaluated were: | |||
* Proper wearing of fire protective gear and self-contained breathing apparatus | |||
* Proper use and layout of fire hoses | |||
* Employment of appropriate fire-fighting techniques | |||
* Sufficient fire-fighting equipment brought to the scene | |||
* Effectiveness of command and control | |||
* Search for victims and propagation of the fire into other plant areas | |||
* Smoke removal operations | |||
* Utilization of pre-planned strategies | |||
* Adherence to the pre-planned drill scenario | |||
* Drill objective | |||
The inspectors also observed the placement and charging of the fire hoses used to | |||
simulate extinguishing the fire. | |||
b. Findings | |||
No findings were identified. | |||
1R08 Inservice Inspection Activities (IP 71111.08) | |||
a. Inspection Scope | |||
Non-Destructive Examination Activities and Welding Activities | |||
From October 26-29, 2015, the inspectors conducted an onsite review of the | |||
implementation of the licensees inservice inspection (ISI) program for monitoring | |||
degradation of the RCS boundary, risk-significant piping and component boundaries, | |||
and containment boundaries in U3. | |||
The inspectors either directly observed or reviewed the following non-destructive | |||
examinations (NDEs) mandated by the American Society of Mechanical Engineers | |||
(ASME) Boiler and Pressure Vessel Code (Code of Record: 2007 Edition with 2008 | |||
Addenda) to evaluate compliance with the ASME Code, Section XI and Section V | |||
requirements, and if any indications or defects were detected, to evaluate if they were | |||
dispositioned in accordance with the ASME Code or an NRC-approved alternative | |||
requirement. The inspectors also reviewed the qualifications of the NDE technicians | |||
performing the examinations, to determine whether they were current and in compliance | |||
with the ASME Code requirements. | |||
7 | |||
* Ultrasonic Examination of Loop B 18-inch Feedwater Nozzle-to-Pipe weld, | |||
Augmented Examination (observed) | |||
* Ultrasonic Examination (UT) of Loop B 14-inch Feedwater Pipe-to-Elbow weld, | |||
Augmented Examination (observed) | |||
* Visual Examination of the Reactor Pressure Vessel bottom-mounted instrumentation | |||
penetrations (reviewed) | |||
* Visual Examination (VT-3) of Spring Hanger 3-RCH-27, Class 1 Support (observed) | |||
* VT-3 of Dual Spring Hanger VS-1G-12, Class 1 Support (observed) | |||
The inspectors either directly observed or reviewed the following welding activities, | |||
qualification records, and associated documents in order to evaluate compliance with | |||
procedures and the ASME Code, Section XI and Section IX requirements. Specifically, | |||
the inspectors reviewed the work order (WO), repair and replacement plan, weld data | |||
sheets, welding procedures, procedure qualification records, welder performance | |||
qualification records, and NDE reports. | |||
* WO 4030098001, Repair of PZR HTR Sleeve #11, Class 1 (reviewed) | |||
* WO 4029647301, Valve 3-298C Replace Valve, Class 2 (reviewed) | |||
During non-destructive surface and volumetric examinations performed since the | |||
previous RFO, the licensee did not identify any relevant indications that were analytically | |||
evaluated and accepted for continued service; therefore, no NRC review was completed | |||
for this inspection procedure (IP) attribute. | |||
Pressurized Water Reactor Vessel Upper Head Penetration Inspection Activities | |||
The inspectors verified that for the U3 vessel head, a bare metal visual examination and | |||
a volumetric examination were not required during this outage, in accordance with the | |||
requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D). | |||
The licensee did not identify any relevant indications that were accepted for continued | |||
service. Additionally, the licensee did not perform any welding repairs to the vessel | |||
head penetrations since the beginning of the last U3 RFO; therefore, no NRC review | |||
was completed for these IP attributes. | |||
Boric Acid Corrosion Control Inspection Activities | |||
The inspectors reviewed the licensees boric acid corrosion control program activities to | |||
determine if the activities were implemented in accordance with the commitments made | |||
in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor | |||
Pressure Boundary Components in PWR Plants, and applicable industry guidance | |||
documents. Specifically, the inspectors performed an onsite records review of | |||
procedures, and the results of the licensees containment walkdown inspections | |||
performed during the current RFO. The inspectors also interviewed the Boric Acid | |||
Corrosion Control (BACC) program owner, conducted an independent walkdown of | |||
containment to evaluate compliance with licensees BACC program requirements, and | |||
verified that degraded or non-conforming conditions, such as boric acid leaks, were | |||
properly identified and corrected in accordance with the licensees BACC and CAP. | |||
8 | |||
The inspectors reviewed the following engineering evaluations, completed for evidence | |||
of boric acid leakage, to determine if the licensee properly applied applicable corrosion | |||
rates to the affected components; and properly assessed the effects of corrosion | |||
induced wastage on structural or pressure boundary integrity in accordance with the | |||
licensee procedures. | |||
* AR 02014343, Boric Acid Evaluation | |||
* AR 02021132, Boric Acid Evaluation | |||
* AR 02025309, Boric Acid Evaluation | |||
* AR 02038045, Boric Acid Evaluation | |||
The inspectors reviewed the following condition reports (CRs) and associated corrective | |||
actions related to evidence of boric acid leakage, to evaluate if the corrective actions | |||
completed were consistent with the requirements of the ASME Code and 10 CFR Part | |||
50, Appendix B, Criterion XVI. | |||
* AR 02086287, CV-3-2819 has corrosion on electrical connection | |||
* AR 02086292, MOV-3-866B inactive minor dry white boric acid at packing | |||
* AR 02086231, 3-309D inactive minor dry white boric acid at packing | |||
* AR 02086226, 3-306B inactive minor dry white boric acid at packing | |||
* AR 02086218, 3-120G inactive dry white boric acid at D/S pipe cap | |||
* AR 02086240, 3-572 inactive dry white boric acid at packing | |||
* AR 02086239, 3-542, inactive dry white boric acid at packing | |||
Steam Generator Tube Inspection Activities | |||
The inspectors verified that for the U3 steam generator tubes, no inspection activities | |||
were required this RFO, in accordance with the requirements of the ASME Code, the | |||
licensees TS, and Nuclear Energy Institute (NEI) 97-06, Steam Generator Program | |||
Guidelines. | |||
Identification and Resolution of Problems | |||
The inspectors reviewed a sample of ISI-related issues entered into the CAP to | |||
determine if the licensee had appropriately described the scope of the problem, and | |||
had initiated corrective actions. The review also included the licensees consideration | |||
and assessment of operating experience events applicable to the plant. The inspectors | |||
performed this review to ensure compliance with 10 CFR Part 50, Appendix B, Criterion | |||
XVI, Corrective Action, requirements. | |||
b. Findings | |||
No findings were identified. | |||
9 | |||
1R11 Licensed Operator Requalification Program (IP 71111.11) | |||
.1 Licensed Operator Requalification Exam | |||
a. Inspection Scope | |||
Annual Review of Licensee Requalification Examination Results: On December 30, | |||
2015, 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 IP 71111.11, Licensed Operator Requalification Program. These results were | |||
compared to the thresholds established in Section 3.02, Requalification Examination | |||
Results, of IP 71111.11. | |||
b. Findings | |||
No findings were identified. | |||
.2 Resident Inspector Quarterly Review | |||
a. Inspection Scope | |||
The inspectors performed the following inspection sample of a simulator observation and | |||
assessed licensed operator performance while training. These observations included | |||
procedural use and adherence, response to alarms, communications, command and | |||
control, and coordination and control of the reactor plant operations. | |||
On October 8, 2015, the inspectors assessed licensed operator performance in the | |||
plant-specific simulator during a training evolution. The training scenario was started | |||
with the unit in Mode 1 at 100 percent power and included a fire lasting greater than 15 | |||
minutes, a loss of reactor coolant accident (LOCA), a reactor trip, a safety injection, a | |||
residual heat removal (RHR) pump seal failure, and a radiological release to the | |||
environment. | |||
During this simulator observation, the simulator board configurations were compared | |||
with actual plant control board configurations reflecting recent plant changes or | |||
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 | |||
10 | |||
b. Findings | |||
No findings were identified. | |||
.3 Control Room Observations | |||
a. Inspection Scope | |||
The inspectors performed daily assessments of licensed operators in the control room | |||
during their performance of routine operations. These observations included daily | |||
surveillance testing, log keeping, 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. The inspectors also | |||
performed the following three focused control room observations during reactivity | |||
manipulations and Mode changes: | |||
On November 19, 2015, the inspectors performed a focused observation on U4 | |||
consisting of a RCS primary water dilution per 0-OP-046, Enclosure 6, Chemical | |||
Volume Control System Boron Concentration Control. Specifically, the inspectors | |||
observed the reactor operators performance of 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. | |||
On December 1, 2015 and December 2, 2015, the inspectors performed a focused | |||
observation in the U3 control room during low power physics testing in accordance with | |||
procedure 0-OSP-040.19, Low Power Physics Testing. The inspectors observed the | |||
pre-evolution operating crew brief, control rod movements, monitoring of subcritical | |||
multiplication, and data collection. | |||
On December 3, 2015, the inspectors performed a focused observation on U3 during a | |||
reactor startup per procedure 3-GOP-301, Hot Standby to Power Operations. The | |||
inspectors reviewed the expected critical boron concentration calculation and the control | |||
rod pull sequence plan used during the observed reactor startup. The inspectors | |||
reviewed the recorded reactor startup physics data to ensure it was as calculated by the | |||
licensee reactor engineering staff. | |||
This inspection constitutes three samples. 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 | |||
11 | |||
b. Findings | |||
No findings were identified. | |||
.4 Biennial Requalification | |||
a. Inspection Scope | |||
The inspectors reviewed the facility operating history and associated documents in | |||
preparation for this inspection. During the weeks of November 30, 2015 through | |||
December 21, 2015, the inspectors reviewed documentation associated with the | |||
licensees operator requalification program biennial written examinations. The activity | |||
performed by the inspectors was conducted to assess the licensees effectiveness 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 IP 71111.11, Licensed | |||
Operator Requalification Program. Documentation reviewed included two biennial | |||
written examinations. The records were inspected using the criteria listed in IP | |||
71111.11. Documents reviewed during the inspection are documented in the List of | |||
Documents Reviewed. | |||
The sample is now complete because the remainder of this sample was previously | |||
inspected and documented in the third quarter integrated inspection report | |||
(05000250&251/2015003). | |||
b. Findings | |||
No findings were identified. | |||
1R12 Maintenance Effectiveness (IP 71111.12) | |||
a. Inspection Scope | |||
The inspectors reviewed known equipment problems associated with the U3 steam | |||
generator steam flow module FM-3-474D affecting the maintenance rule program and | |||
equipment performance history trends associated with the equipment. Specifically, the | |||
inspectors reviewed AR 02081538. | |||
The inspectors reviewed the licensees activities to meet 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 licensees CAP. The inspectors used the licensee maintenance rule | |||
12 | |||
database, system health reports, maintenance rule unavailability status reports, and the | |||
CAP as sources of information on tracking and resolution of issues. This inspection | |||
constitutes one sample. | |||
* U3 FM-3-474D Flow Module Bias Potentiometer | |||
b. Findings | |||
No findings were identified. | |||
1R13 Maintenance Risk Assessments and Emergent Work Control (IP 71111.13) | |||
a. Inspection Scope | |||
The inspectors completed in-office reviews and control room inspections of the | |||
licensees risk assessment of five 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 0-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 is 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 OOS equipment was included in the OLRM calculation. The inspectors | |||
evaluated the following five risk assessment samples during the inspection period: | |||
* U3 3A 4kV Bus, U3 Startup Transformer (SUT), and 3A and 3B HHSI pumps OOS | |||
* U3 3A 4kV Bus, U3 SUT, and 3D Vital 480V Motor Control Cabinet (MCC) OOS | |||
* U3 3-312A Valve Inspection and Repair with Freeze Seal (WO 40411630) | |||
* U3 SUT OOS, U3 3A Sequencer OOS, and 3A and 3B EDGs Running | |||
* U3 Train 2 AFW, U4 Train 2 AFW, and U3 3B Emergency Containment Cooler OOS | |||
b. Findings | |||
No findings were identified. | |||
1R15 Operability Determinations and Functionality Assessments (IP 71111.15) | |||
a. Inspection Scope | |||
The inspectors evaluated the technical adequacy of the licensee evaluations to ensure | |||
that TS operability was properly justified and the subject component or system remained | |||
available such that no unrecognized increase in risk occurred for the five operability | |||
evaluations described in the ARs listed below. The inspectors reviewed applicable | |||
sections of the updated Final Safety Anaylsis Report (UFSAR) 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 | |||
13 | |||
the affected equipment remained capable of performing its intended design function. | |||
The inspectors also reviewed a sampling of CRs to verify that the licensee routinely | |||
identifed and corrected any deficiencies associated with operability evaluations. This | |||
inspection constitutes five samples. | |||
* AR 02083336, U3 RHR Gas Voids | |||
* AR 02082853, Pressurizer Steam Sample Line Containment Isolation Valve (CV-4- | |||
951) OOS | |||
* AR 02053124, 3B EDG Oil Leak | |||
* AR 02086176, 3A FT-3-414 Bent and Unsupported | |||
* AR 02093957, 4B EDG TS-4-6132 Broken | |||
b. Findings | |||
No findings were identified. | |||
1R18 Plant Modifications (IP 71111.18) | |||
Permanent Plant Modifications | |||
a. Inspection Scope | |||
The inspectors reviewed the following two permanent plant modifications. The | |||
inspectors reviewed the 10 CFR 50.59 screening and technical evaluation to verify that | |||
the modifications had not affected system operability or availability. The inspectors | |||
reviewed associated plant drawings, design analyses, and UFSAR documents impacted | |||
by these modifications and discussed the changes with licensee personnel to verify that | |||
the modifications were consistent with the WO and associated documents. The | |||
inspectors observed portions of the modifications and surrounding areas to determine if | |||
conditions resulted in any potential unsafe conditions not described in the engineering | |||
change documentation. Additionally, the inspectors reviewed and verified that any | |||
conditions associated with the modifications were being identified and entered into the | |||
CAP. This inspection constitutes two samples. | |||
* EC 280399, U3 Reactor Coolant Pump (RCP) Seal Replacmement Modification | |||
* EC 285012, FT-4-494 U4 Steam Generator C Steam Flow Detector Line | |||
Replacement | |||
b. Findings | |||
No findings were identified. | |||
1R19 Post Maintenance Testing (IP 71111.19) | |||
a. Inspection Scope | |||
For the five post maintenance tests and associated WOs 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 | |||
completed satisfactorily and demonstrated that the affected equipment was operable. | |||
14 | |||
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 five inspection samples: | |||
* WO 40281614, U3 Pressurizer Pressure Operated Relief Valve PCV-3-455C | |||
* WO 40419666, U4 Steam Generator C Steam Flow Detector FT-4-494 | |||
* WO 40371127, 3B Containment Spray Pump Check Valve Inspection | |||
* WO 40419961, Reactor Protection System 3-P7-1-B Relay Replacement | |||
* WO 40161059, 3B50 Load Center Relay Replacements | |||
b. Findings | |||
No findings were identified. | |||
1R20 Refueling and Other Outage Activities (IP 71111.20) | |||
.1 Unit 3 Refueling Outage PT3-28 (one sample) | |||
a. Inspection Scope | |||
Outage Planning, Control and Risk Assessment | |||
During daily outage planning activities by the licensee, the inspectors reviewed the risk | |||
reduction methodology employed by the licensee during RFO PT3-28 meetings including | |||
outage control center (OCC) morning meetings, operations daily team meetings, and | |||
schedule performance update meetings. The inspectors examined the licensee | |||
implementation of shutdown safety assessments during PT3-28 in accordance with | |||
administrative procedure ADM-051, Outage Risk Assessment and Control, to verify if a | |||
defense in depth concept was in place to ensure safe operations and avoid unnecessary | |||
risk. In addition, the inspectors regularly monitored outage planning and control | |||
activities in the OCC, and interviewed responsible OCC management personnel during | |||
the outage to ensure system, structure, and component configurations, and work scope | |||
were consistent with TS requirements, site procedures, and outage risk controls. | |||
Monitoring of Shutdown Activities | |||
The inspectors performed walk downs of important systems and components used for | |||
RHR from the reactor core and SFP during the shutdown period, including the intake | |||
cooling water system, component cooling water (CCW) system, and SFP cooling | |||
system. | |||
Outage Activities | |||
The inspectors examined outage activities to verify that they were conducted in | |||
accordance with TS, licensee procedures, and the licensees outage risk control plan. | |||
Some of the more significant inspection activities accomplished by the inspectors were | |||
as follows: | |||
15 | |||
* Walked down selected safety-related equipment clearance orders | |||
* Verified operability of RCS pressure, level, flow, and temperature instruments during | |||
various modes of operation | |||
* Verified electrical systems availability and alignment | |||
* Verified shutdown cooling system and SFP cooling system operation | |||
* Evaluated implementation of reactivity controls | |||
* Reviewed control of containment penetrations | |||
* Examined foreign material exclusion (FME) controls put in place inside containment | |||
(e.g., around the refueling cavity, near sensitive equipment and RCS breaches) and | |||
around the SFP | |||
* Observed fuel loading and unloading in the SFP and in containment | |||
Monitoring of Plant Heat up and Containment Closure Activities | |||
The inspectors examined the applicable TS, license conditions, and verified | |||
administrative prerequisites were being met prior to reactor plant mode changes. The | |||
inspectors reviewed measured RCS leak rates, and verified containment integrity was | |||
properly established. The inspectors performed a containment closeout inspection prior | |||
to the reactor plant startup to verify no evidence of leakage or debris were left in | |||
containment that could affect plant operations. | |||
Reactor Startup and Mode Changes | |||
On December 2, 2015, the inspectors observed the U3 reactor startup and turbine | |||
synchronization to the electrical grid and associated Mode changes. The inspectors | |||
reviewed the recorded reactor startup physics data in order to determine it was as- | |||
calculated by the licensee reactor engineering staff. The inspectors determined that | |||
startup and Mode changes were performed in accordance with licensee procedures 0- | |||
OSP-040.16, Initial Criticality After Refueling Outage and Nuclear Design Verification, | |||
and 3-GOP-301, Mode 3 to Power Operations. | |||
Corrective Action Program | |||
The inspectors reviewed ARs generated during PT3-28 to evaluate the licensees | |||
threshold for initiating ARs. The inspectors reviewed CRs to verify priorities, Mode | |||
holds, and significance levels were assigned as required. Resolution and | |||
implementation of corrective actions of several ARs were also reviewed for | |||
completeness. The inspectors routinely reviewed the results of site oversight of daily | |||
surveillances of outage activities. | |||
b. Findings | |||
Introduction: A Green self-revealing NCV of TS 6.8.1, Procedures and Programs, was | |||
identified for the licensees failure to correctly execute procedure 3-PMI-072.6, Steam | |||
Dump to Atmosphere Control Loop Calibration. The failure resulted in actuation of a 3B | |||
4160 V vital bus lockout circuit causing loss of power to the B train of U3 SFP cooling. | |||
Description: On November 4, 2015, at 2112 hours, Instrumentation and Controls | |||
technicians were performing procedure 3-PMI-072.6, Steam Dump to Atmosphere | |||
Control Loop Calibration, when a temporary electrical jumper was incorrectly installed in | |||
16 | |||
the control room reactor operator console 3C02 instead of 3C04, in contrast to step 6.3.2 | |||
of 3-PMI-072.6. At the time of the event, U3 was defueled with all of its fuel temporarily | |||
relocated to the SFP. The 3A 4160 V vital bus was de-energized for planned | |||
maintenance and all 480 V vital load centers were powered by the 3B 4160 V vital bus. | |||
Separate load centers provided power to two separate trains of U3 SFP cooling pumps, | |||
and the 3A train pump was powered from Unit 4 electrical switchgear. | |||
The incorrectly placed jumper actuated a 3B 4160 V vital bus lockout circuit causing all | |||
associated Unit 3 480 V vital load and motor control centers to de-energize. Numerous | |||
equipment was rendered OOS including the B SFP cooling pump and the 3B CCW | |||
pump. The 3B CCW pump provided cooling to both U3 SFP cooling heat exchangers. | |||
Upon loss of the 3B CCW pump, the standby 3C CCW pump started on low pressure as | |||
designed, providing cooling to the 3A SFP cooling train. Immediate corrective action | |||
was taken to remove the jumper and restore the B train of SFP cooling. However, the | |||
loss of one train of SFP cooling for approximately four hours caused the SFP | |||
temperature to rise from approximately 110 °F to 117 °F. The licensee restored U3 load | |||
and motor control centers at 0207 hours on November 5, 2015, and by 0300 hours the | |||
SFP temperature had returned to normal. | |||
The licensee entered the condition in its CAP as AR 02088911 and 02088914. | |||
Corrective actions included site-wide briefings of lessons learned from the event, quality | |||
reviews of procedure 3-PMI-072.6, and enhanced oversight of maintenance activities. | |||
Analysis: The inspectors determined that the failure to correctly implement maintenance | |||
procedure 3-PMI-072.6 was a performance deficiency. The performance deficiency was | |||
determined to be more than minor because it was associated with the human | |||
performance attribute of the barrier integrity cornerstone and adversely affected the | |||
cornerstone objective to provide reasonable assurance that physical design barriers (fuel | |||
cladding, RCS, and containment) protect the public from radionuclide releases. | |||
Specifically, the licensees failure to correctly execute step 6.3.2 of procedure | |||
3-PMI-072.6 rendered one of two SFP cooling trains OOS, causing the SFP temperature | |||
to rise from approximately 110 °F to 117 °F over a four-hour period. While the | |||
performance deficiency did not directly challenge the integrity of the fuel cladding, if left | |||
uncorrected, the SFP temperature would have continued to increase, potentially | |||
affecting SFP inventory. | |||
The finding was screened using IMC 0609, Significance Determination Process, | |||
Attachment 0609.04, Initial Characterization of Findings, Tables 2 and 3, dated July 1, | |||
2012, and Appendix G Attachment 1, Shutdown Operations Significance Determination | |||
Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 4 for Barrier | |||
Integrity, dated May 9, 2014. The inspectors determined the finding was of very low | |||
safety significance (Green) because it was not associated with low temperature over | |||
pressurization, freeze seals, steam generator nozzle dams, criticality, drain down or | |||
leakage paths, or the containment barrier. Furthermore, one train of SFP cooling | |||
remained in operation, the rate of SFP temperature rise was low (~2 °F/hour), and | |||
additional diverse compensatory methods remained available to limit SFP temperature | |||
rise. This finding was assigned a cross cutting aspect associated with the procedure | |||
adherence element of the human performance area because the licensee failed to | |||
correctly execute step 6.3.2 of procedure 3-PMI-072.6 (H.8). | |||
17 | |||
Enforcement: Technical Specification 6.8.1 requires that procedures required by the | |||
licensees Quality Assurance Topical Report (QATR) be established, implemented, and | |||
maintained. The QATR includes procedures listed in Appendix A of NRC Regulatory | |||
Guide 1.33, Revision 2, dated February 1978, including procedures for calibrations. The | |||
licensee implements TS 6.8.1 requirements, in part, using procedure 3-PMI-072.6, | |||
Steam Dump to Atmosphere Control Loop Calibration. Step 6.3.2 of procedure | |||
3-PMI-072.6, requires that a jumper be installed in reactor operator console 3C02. | |||
Contrary to this requirement, on November 4, 2015, at 2112 hours, a maintenance | |||
technician mistakenly installed a jumper in reactor operator console 3C04. This action | |||
resulted in actuation of a 3B 4160 V vital bus lockout circuit causing loss of power to the | |||
B train of U3 SFP cooling. The licensee took immediate corrective action to remove the | |||
jumper. This violation is being treated as an NCV, consistent with Section 2.3.2 of the | |||
Enforcement Policy, because it was of very low safety significance and was entered in | |||
the licensees CAP as AR 02088911 and 02088914. (NCV 05000250/2015004-01, | |||
Failure to correctly follow procedure 3-PMI-072.6, Steam Dump to Atmosphere Control | |||
Loop Calibration.) | |||
1R22 Surveillance Testing (IP 71111.22) | |||
a. Inspection Scope | |||
The inspectors either reviewed or observed the following five surveillance tests to verify | |||
that the tests met the TS requirements, the UFSAR description, the licensees | |||
procedural requirements, and demonstrated that 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 status required for the system to perform its | |||
safety function. The inspectors verified that any surveillance deficiencies were | |||
documented in the licensees CAP. This inspection constitutes two surveillance test | |||
samples, one inservice testing (IST) sample, and two containment isolation valve leak | |||
test samples. The inspectors reviewed the following tests: | |||
Surveillance Test: | |||
* 0-OSP-059.13, U4 Flux Map | |||
* 3-OSP-072.5, U3 Main Steam Safey Valve Setpoint Verification | |||
In-Service Tests: | |||
* 3-OSP-206.1, Component Cooling Water MOV-3-1418 Valve Test (IST) | |||
Containment Isolation Valve Test: | |||
* 3-OSP-051.5, U3 Local Leak Rate Test, Penetration 8 CV-3-951 | |||
* 3-OSP-051.5, U3 Local Leak Rate Test, Penetration 14 CV-3-204 | |||
b. Findings | |||
No findings were identified. | |||
18 | |||
Cornerstone: Emergency Preparedness | |||
1EP6 Drill Evaluation (IP 71114.06) | |||
.1 Emergency Preparedness Drill | |||
a. Inspection Scope | |||
On October 8, 2015, the inspectors observed an emergency preparedness drill and the | |||
performance of the licensees emergency response organization. The drill included a | |||
simulated fire in the U4 laydown area, a LOCA inside containment, followed by a RHR | |||
pump seal failure and radiological release to the environment. The fire, lasting greater | |||
than 15 minutes, required an unusual event emergency declaration and notification to | |||
state and local county officials and the NRC per licensee procedure 0-EPIP-20101, | |||
Duties of the Emergency Coordinator. The scenario progressed to a loss of two RCS | |||
barriers with the loss or potential loss of a third barrier requiring a general emergency | |||
declaration and an additional notification. The inspectors observed the crew in the plant | |||
simulator, including simulated implementation of emergency procedures. The inspectors | |||
observed the emergency response organization staff in the control room simulator and | |||
technical support center while they implemented the event classification guidelines and | |||
emergency response procedures. The inspectors determined that the emergency | |||
classification and notifications were made in accordance with the licensee emergency | |||
plan implementing procedure 0-EPIP-20101. The inspectors 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 licensees CAP. This inspection constitutes one sample. | |||
b. Findings | |||
No findings were identified. | |||
2. RADIATION SAFETY (RS) | |||
Cornerstones: Public Radiation Safety and Occupational Radiaition Safety | |||
2RS1 Radiological Hazard Assessment and Exposure Controls (IP 71124.01) | |||
a. Inspection Scope | |||
Hazard Assessment and Instructions to Workers. During facility tours, the inspectors | |||
directly observed labeling of radioactive material and postings for radiation areas, high | |||
radiation areas, and airborne radioactivity areas established within the radiologically | |||
controlled area (RCA) of the U3 containment building, auxiliary building, the Independent | |||
Spent Fuel Storage Installation (ISFSI), and radioactive waste processing and storage | |||
locations. The inspectors independently measured radiation dose rates or directly | |||
observed conduct of licensee radiation surveys for selected RCA areas. The inspectors | |||
reviewed survey records for several plant areas including surveys for alpha emitters, | |||
airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job | |||
surveys for upcoming tasks. The inspectors also discussed changes to plant operations | |||
that could contribute to changing radiological conditions since the last inspection. For | |||
selected outage jobs, the inspectors attended pre-job briefings and reviewed Radiation | |||
19 | |||
Work Permit (RWP) details to assess communication of radiological control | |||
requirements and current radiological conditions to workers. | |||
Hazard Control and Work Practices. The inspectors evaluated access barrier | |||
effectiveness for selected Locked High Radiation Area (LHRA) locations and discussed | |||
changes to procedural guidance for LHRA and Very High Radiation Area controls with | |||
Radiation Protection (RP) supervisors. The inspectors observed and evaluated controls | |||
for the storage of irradiated material within the SFP. Established radiological controls | |||
(including airborne controls) were evaluated for selected U3 RFO 28 (U3R28) tasks | |||
including RCP seal replacements, reactor cavity decontamination and reactor sump | |||
demobilization activities. In addition, the inspectors reviewed licensee controls for areas | |||
where dose rates could change significantly as a result of plant shutdown and refueling | |||
operations. | |||
Through direct observations and interviews with licensee staff, the inspectors evaluated | |||
occupational workers adherence to selected RWPs and RP technician proficiency in | |||
providing job coverage. Electronic dosimeter (ED) alarm set points and worker stay | |||
times were evaluated against area radiation survey results for selected U3 RFO jobs, | |||
including the reactor sump demobilization and reactor cavity decontamination. The | |||
inspectors discussed the use of personnel dosimetry (extremity dosimetry and | |||
multibadging in high dose rate gradients) with RP staff. The inspectors also evaluated | |||
worker response to dose and dose rate alarms during selected work activities. | |||
Control of Radioactive Material. The inspectors observed surveys of material and | |||
personnel being released from the RCA using small article monitor (SAM), personnel | |||
contamination monitor (PCM), and portal monitor instruments. As part of IP 71124.05, | |||
the inspectors reviewed the last two calibration records for selected release point survey | |||
instruments and discussed equipment sensitivity, alarm setpoints, and release program | |||
guidance with licensee staff. The inspectors reviewed records of leak tests on selected | |||
sealed sources and discussed nationally tracked source transactions with licensee staff. | |||
Problem Identification and Resolution. The inspectors reviewed CAP documents | |||
associated with radiological hazard assessment and exposure control. The inspectors | |||
evaluated the licensees ability to identify and resolve the issues in accordance with | |||
licensee procedures. The inspectors also reviewed recent self-assessment results. | |||
Radiation protection activities were evaluated against the requirements of the UFSAR | |||
Section 11; TS Sections 6.8 Procedures and Programs and 6.12 High Radiation Area; | |||
10 CFR Parts 19 and 20; Regulatory Guide 8.38, Control of Access to High and Very | |||
High Radiation Areas in Nuclear Power Plants; and approved licensee procedures. | |||
Licensee programs for monitoring materials and personnel released from the RCA were | |||
evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively | |||
Contaminated Material. Documents reviewed are listed in the Attachment. | |||
b. Findings | |||
No findings were identified. | |||
20 | |||
2RS2 Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls | |||
(IP 71124.02) | |||
a. Inspection Scope | |||
Work Planning and Exposure Tracking. The inspectors reviewed work activities and their | |||
collective exposure estimates for U3 RFO. The inspectors reviewed ALARA planning | |||
packages for the following high collective exposure tasks: SG cleaning (including bundle | |||
flushing, sludge lancing, and foreign object search and retrieval); refueling activities; | |||
RCP seal replacement; bottom mounted inspection, and; various valve work. For the | |||
selected tasks, the inspectors reviewed established dose goals and discussed | |||
assumptions regarding the bases for the current estimates with responsible ALARA | |||
planners. The inspectors evaluated the incorporation of exposure reduction initiatives | |||
and operating experience. Adjustments made to planned doses were also reviewed, | |||
along with the basis of those adjustments. Post-job reviews from both the current and | |||
previous RFO were assessed. Where applicable, the inspectors discussed changes to | |||
established estimates with ALARA planners and evaluated them against work scope | |||
changes or unanticipated elevated dose rates. | |||
Source Term Reduction and Control. The inspectors reviewed the collective exposure | |||
three-year rolling average from 2012-2014 and reviewed historical collective exposure | |||
trends. The inspectors evaluated historical dose rate trends and compared them to | |||
current data. | |||
Radiation Worker Performance. In conjunction with IP 71124.01, radiation worker | |||
performance was evaluated during several tasks both within containment and the | |||
auxiliary building. The inspectors specifically evaluated both the use of ALARA briefings | |||
and remote technologies, including teledosimetry and remote visual monitoring, to | |||
reduce dose. | |||
Problem Identification and Resolution. The inspectors reviewed and discussed selected | |||
CAP documents associated with ALARA program implementation. The inspectors | |||
evaluated the licensees ability to identify and resolve the issues in accordance with | |||
licensee procedures. The inspectors also reviewed recent self-assessment results. | |||
ALARA program activities were evaluated against the requirements of the UFSAR | |||
Section 11, applicable TS Sections 6.8 and 6.12, 10 CFR Part 20, and approved | |||
licensee procedure. Records reviewed are listed in the Attachment. | |||
b. Findings | |||
No findings were identified. | |||
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (IP 71124.03) | |||
a. Inspection Scope | |||
Engineering Controls: Licensee engineering controls used to control and mitigate | |||
airborne radioactivity were reviewed and discussed. The inspectors evaluated selected | |||
U3 engineering controls including temporary High Efficiency Particulate Air (HEPA) | |||
filtration systems for selected outage tasks with the potential for generating airborne | |||
21 | |||
activity conditions. The evaluations included procedural guidance, operability testing, | |||
and established configurations during specific outage tasks. In addition, plant guidance | |||
and its implementation for the monitoring of potential airborne beta-gamma and alpha- | |||
emitting radionuclides for outage tasks associated with refueling activities, head | |||
disassembly, and valve maintenance were reviewed and discussed with cognizant | |||
licensee representatives. | |||
Use of Respiratory Protection Devices: Program guidance for issuance and use of | |||
respiratory protection devices were reviewed and discussed with responsible licensee | |||
representatives. The inspectors reviewed Total Effective Dose Equivalent (TEDE) | |||
ALARA evaluations conducted for select U3 outage tasks. Use of respiratory protective | |||
equipment was evaluated for selected workers involved in U3 outage activities. The | |||
inspectors toured selected onsite compressors available for supplying breathing air for | |||
current outage activities and reviewed Grade D or greater air certification for permanent | |||
and temporary on-site compressors used for supplied-line breathing air and self- | |||
contained breathing apparatus (SCBA) bottle fill-station activities. Training, fit testing, | |||
and medical qualifications for selected RP, maintenance, and operations using | |||
respiratory protection for outage activities were reviewed and discussed with cognizant | |||
licensee representatives. | |||
Self-Contained Breathing Apparatus for Emergency Use: The inspectors reviewed | |||
current status, operability and availability of select respiratory and SCBA equipment | |||
maintained within the U3 and U4 control rooms, B5B lockers, and U3 and U4 reactor | |||
auxiliary building locations. Maintenance activities for selected respiratory protective | |||
equipment (e.g., compressed gas cylinders, regulators, valves, and hose couplings), by | |||
certified vendor technicians were reviewed for selected SCBA units. Training, fit testing, | |||
and medical qualifications for selected RP, maintenance, and operations staff assigned | |||
Emergency Response Organization duties were reviewed and discussed with cognizant | |||
licensee representatives. For selected U3 and U4 control room operators, the | |||
inspectors discussed and reviewed annual hands-on SCBA training activities, including | |||
donning, doffing, and functionally checking SCBA equipment, bottle change out, and | |||
also reviewed availability of corrective lens, as applicable, for on-shift personnel. | |||
Problem Identification and Resolution: The inspectors reviewed selected CAP | |||
documents within the area of radiological airborne controls and respiratory protection | |||
activities. The inspectors evaluated the licensees ability to identify and resolve the | |||
issues in accordance with licensee procedures PI-AA-104-1000, Corrective Action, Rev. | |||
6, and 0-ADM-533, Corrective Action Program Guidance, Rev. 14. The inspectors also | |||
evaluated the scope of the licensees internal audit program and reviewed recent | |||
assessment results. Specific licensee CAP documents reviewed for airborne | |||
radionuclide concentration monitoring and mitigation are listed in the Attachment. | |||
Radiation Protection program activities associated with airborne radioactivity monitoring | |||
and controls were evaluated against details and requirements documented in the | |||
UFSAR, TS Section 3/4.9.9, Containment Ventilation System, 3/4.9.13, Radiation | |||
Monitoring, and 6.8.1, Procedures and Programs; 10 CFR Part 20, and also approved | |||
licensee procedures. Documents reviewed are listed in the Attachment. | |||
The inspectors completed all specified line-items detailed in IP 71124.03. | |||
22 | |||
b. Findings | |||
No findings were identified. | |||
2RS4 Occupational Dose Assessment (IP 71124.04) | |||
a. Inspection Scope | |||
The inspector evaluated current RP program guidance and its implementation for | |||
monitoring and assessing occupational workers internal and external radiation | |||
exposure. The review included quality assurance activities, results, and responses to | |||
identified issues; and individual dose results for selected occupational workers. | |||
External Dosimetry: The inspector reviewed and discussed RP program guidance for | |||
monitoring external and internal radiation exposures of occupational workers. The | |||
inspector verified National Voluntary Laboratory Accreditation Program certification data | |||
and discussed program guidance for storage, processing and results for dosimeters | |||
currently in use. The inspector also reviewed and discussed the comparison between | |||
ED and thermoluminescent dosimeter data. | |||
Internal Dosimetry: Program guidance, instrument detection capabilities, and select | |||
results for assessing internally deposited radionuclides were reviewed and discussed in | |||
detail. The inspector evaluated licensee follow-up in vivo monitoring results and dose | |||
assignment for three workers involved in contamination events having the potential for | |||
internal deposition of radioactive material. In addition, the current licensee and contract | |||
vendor laboratory analysis capabilities for the collection and analysis of in vitro samples | |||
were reviewed and discussed in detail. | |||
Special Dosimetric Situations: The inspector reviewed monitoring conducted and results | |||
for two declared pregnant workers since the last inspection. The methodology and | |||
results of monitoring occupational workers within non-uniform external dose fields and | |||
assignment of effective dose equivalent results were discussed in detail. In addition, the | |||
adequacy of dosimetry program guidance and its implementation for shallow dose | |||
assessments and supporting calculations for an individual involved in a select | |||
contamination event were evaluated. Neutron monitoring guidance and implementation | |||
for select at power containment entries were reviewed and discussed. RP staff | |||
proficiency involved in conducting skin dose assessments, neutron monitoring, and | |||
whole body counter (WBC) operations were evaluated through review and discussions | |||
of completed records and supporting data. | |||
Problem Identification and Resolution: The inspectors reviewed and discussed selected | |||
CAP documents associated with occupational dose assessment. The reviewed items | |||
included ARs, self-assessments, and quality assurance audit documents. The | |||
inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve | |||
the identified issues in accordance with licensee procedures PI-AA-104-1000, Corrective | |||
Action, Rev. 6, and 0-ADM-533, Corrective Action Program Guidance, Rev. 14. | |||
Radiation protection program occupational dose assessment guidance and activities | |||
were evaluated against the requirements of the UFSAR Section 11; TS Sections 6.8.1, | |||
Procedures and Programs, and 6.12, High Radiation Area; 10 CFR Parts 19 and 20; and | |||
approved licensee procedures. Records reviewed are listed in the Attachment. | |||
23 | |||
The inspectors completed all specified line-items detailed in IP 71124.04. | |||
b. Findings | |||
No findings were identified. | |||
2RS5 Radiation Monitoring Instrumentation (IP 71124.05) | |||
a. Inspection Scope | |||
Radiation Monitoring Instrumentation: During tours of the auxiliary building, turbine | |||
building, SFP areas, and RCA exit point, the inspectors observed installed radiation | |||
detection equipment including the following instrument types: area radiation monitors | |||
(ARMs), airborne monitors, liquid and gaseous effluent monitors, PCMs, SAMs, and | |||
portal monitors. The inspectors observed the physical location of the components, and | |||
noted the material condition. | |||
In addition to equipment walkdowns, the inspectors observed source checks and alarm | |||
setpoint testing of various portable and fixed detection instruments, including ion | |||
chambers, telepoles, PCMs, SAMs, and portal monitors. For the portable instruments, | |||
the inspectors observed the use of a high-range check source and reviewed records of | |||
periodic output value testing for a calibration source. The inspectors reviewed recent | |||
calibration records and evaluated alarm setpoint values for selected ARMs, PCMs, portal | |||
monitors, SAMs, effluent monitors, and a WBC. This included a sampling of instruments | |||
used for post-accident monitoring such as containment high-range ARMs and effluent | |||
monitor high-range noble gas and iodine channels. Radioactive sources used to | |||
calibrate selected ARMs and effluent monitors were evaluated for traceability to national | |||
standards. Calibration stickers on portable survey instruments and air samplers were | |||
noted during inspection of storage areas for ready-to-use equipment. The inspectors | |||
also reviewed countroom quality assurance records for gamma ray spectrometry | |||
equipment and liquid scintillation detectors. | |||
Problem Identification and Resolution: Selected licensee CAP documents associated | |||
with instrumentation were reviewed and assessed. The inspectors evaluated the | |||
licensees ability to identify and resolve the identified issues in accordance with licensee | |||
procedures. The inspectors also reviewed recent self-assessment results. | |||
Operability and reliability of selected radiation detection instruments were reviewed | |||
against details documented in the following: 10 CFR Part 20; NUREG-0737, | |||
Clarification of Three Mile Island Action Plan Requirements; TS Section 3; UFSAR | |||
Chapters 11; and applicable licensee procedures. Documents reviewed during the | |||
inspection are listed in the Attachment. | |||
b. Findings | |||
No findings were identified. | |||
24 | |||
4OA1 Performance Indicator Verification (IP 71151) | |||
.1 Barrier Integrity Cornerstone | |||
a. Inspection Scope | |||
The inspectors reviewed licensee submittals for the U3 and U4 Performance Indicators | |||
(PI) listed below for the period October 1, 2014, through September 30, 2015, 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, CRs, 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 PI data collection, evaluation, | |||
and distribution. This inspection constitutes four samples. | |||
* U3 Mitigating Systems PIs | |||
* U4 Mitigating Systems PIs | |||
b. Findings | |||
No findings were identified. | |||
.2 Radiation Safety Cornerstones | |||
a. Inspection Scope | |||
Occupational Radiation Safety Cornerstone: The inspectors reviewed recent | |||
Occupational Exposure Control Effectiveness PI results for the occupational radiation | |||
safety cornerstone, and reviewed PI records generated from October 2014 through | |||
October 2015. For the assessment period, the inspectors reviewed ED alarm logs and | |||
selected CRs related to controls for exposure significant areas. Documents reviewed | |||
are listed in the Attachment. | |||
Public Radiation Safety Cornerstone: The inspectors reviewed recent radiological | |||
control effluent release occurrences PI results for the public radiation safety cornerstone, | |||
and reviewed PI records generated from October 2014 through October 2015. For the | |||
assessment period, the inspectors reviewed cumulative and projected doses to the | |||
public contained in liquid and gaseous release permits and CRs related to radiological | |||
effluent TS/Offsite Dose Calculation Manual issues. Documents reviewed are listed in | |||
the Attachment. | |||
b. Findings | |||
No findings were identified. | |||
25 | |||
4OA2 Problem Identification and Resolution (IP 71152) | |||
.1 Daily Review | |||
a. Inspection Scope | |||
As required by IP 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 CAP. 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: Missed Fire Watch Tours | |||
a. Inspection Scope | |||
The inspectors selected AR 02056905, Missed Fire Watch Tours for a more in-depth | |||
review of the circumstances and the corrective actions that followed. The AR report was | |||
reviewed to ensure that an appropriate evaluation was performed and corrective actions | |||
were specified and prioritized in accordance with the licensees program. Other | |||
attributes checked included disposition of operability and resolution of the problem, | |||
including cause determination, past operability determination, and corrective actions. | |||
The inspectors interviewed plant personnel and evaluated the CR in accordance with the | |||
requirements of the licensees corrective actions process as specified in licensees | |||
procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205, | |||
Condition Evaluation and Corrective Action. This inspection constitutes one sample. | |||
b. Findings and Observations | |||
No inspector findings were identified. A licensee-identified violation of very low safety | |||
significance (Green) is documented in Section 4OA7 of this report. The licensee | |||
identified that employees failed to perform hourly required fire watch roves. The | |||
inspectors noted that the licensees evaluation for the missed fire watch roves concluded | |||
that there was no violation of any TS requirement since TS do not require fire watches | |||
for degraded fire protection features. The licensee concluded that the missed roves | |||
represented a reduction in the effectiveness of the Fire Protection Program (FPP) and | |||
the loss of a defense-in-depth feature. | |||
The licensee determined the root cause of the event to be that operations management | |||
was not engaged with the fire watch program. The licensee also determined that a | |||
direct cause was that fire watch employees willfully chose non-compliance with fire | |||
protection requirements. Immediate corrective actions for this event included the | |||
immediate denial of site access for the individuals who failed to conduct the roves. The | |||
licensee also updated the fire protection procedure, 0-ADM-016.4, to include Operations | |||
26 | |||
Management Responsibilities and Oversight that requires observations, audits, and | |||
assessments to ensure regulatory requirements are met. The licensee also conducted | |||
an extent of condition and determined that no other missed tours were present in other | |||
departments based on data collected and security access logs. | |||
.3 Semi-Annual Trend | |||
a. Inspection Scope | |||
The inspectors performed a review of the licensees records including ARs, CAP health | |||
reports, apparent cause evaluation reports, and various corrective action review board | |||
reports to asses an adverse trend in the performance of reactor protection transmitters. | |||
The inspectors reviewed licensee AR 02088175, which identified an adverse trend in | |||
protection transmitter calibration check results. The inspectors evaluated the | |||
effectiveness of the licensees corrective actions and the significance of the problems, | |||
including attributes such as accurate documentation, reportability, evaluation, corrective | |||
actions, and problem resolution. This inspection constitutes one sample. | |||
b. Findings and Observations | |||
No inspector findings were identified. The licensee noted that the transmitters in | |||
question, Rosemount pressure transmitters, are expected to drift a slight amount. The | |||
licensee also noted that both the transmitter age and replacement of components tended | |||
to exacerbate the transmitter drift through the calibration cycle. The licensee concluded | |||
that even with the noted transmitter drift, the transmitters still performed satisfactorily | |||
and were within TS compliance. The inspectors did not identify any additional trends not | |||
observed by the licensees trending activities. | |||
4OA5 Other Activities | |||
.1 Independent Spent Fuel Storage Facility Walk down (IP 60855.1) | |||
a. Inspection Scope | |||
On December 17, 2015, the inspector conducted a walk down of the ISFSI protected | |||
area per IP 60855.1, Operation of an ISFSI at Operating Plants. The inspectors | |||
observed each cask building temperature indicator and passive ventilation system to be | |||
free of any obstruction, allowing natural draft convection decay heat removal through the | |||
air inlet and air outlet openings. The inspectors observed associated cask building | |||
structures to be structurally intact and radiation protection access and security controls | |||
to the ISFSI area to be satisfactory. | |||
b. Findings | |||
No findings were identified. | |||
27 | |||
4OA6 Meetings | |||
The resident inspectors presented the inspection results to Mr. Tom Summers and other | |||
members of licensee management on January 15, 2016. 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. | |||
4OA7 Licensee-identified Violation | |||
The following violation of very low safety significance (Green) was identified by the | |||
licensee and is a violation of NRC requirements which meets the criteria of the NRC | |||
Enforcement Policy for being dispositioned as an NCV. | |||
10 CFR 50.48 states that each operating nuclear power plant must have a fire protection | |||
plan that satisfies Criterion 3 of Appendix A of this part. Turkey Point Renewed | |||
Operating License condition D, for Units 3 and 4, states that the licensee shall | |||
implement and maintain in effect all provisions of the approved FPP as described in the | |||
UFSAR Appendix 9.6A. The approved FPP is implemented, in part, by 0-ADM-016, Fire | |||
Protection Program, as referenced in Section 7.2 of UFSAR Appendix 9.6A. Section 5.6 | |||
of 0-ADM-016 requires that, for non-functional post-fire safe shutdown components, | |||
engineering evaluations should identify appropriate compensatory actions, including | |||
hourly fire roves. Contrary to the above, between May 1st, 2014, and April 23rd, 2015, | |||
hourly fire watch patrols were not conducted on numerous occasions in fire zones that | |||
required regular hourly tours due to fire protection equipment impairment. The failure to | |||
perform the fire watch tours did not cause the inoperability of any equipment but resulted | |||
in the loss of a defense-in-depth feature for fire detection in fire zones affected by an | |||
impaired or non-functional fire safety component or feature. This violation was | |||
associated with the Mitigating Systems Cornerstone and affected the cornerstone | |||
objective of ensuring the availability, reliability and capability of the systems that respond | |||
to initiating events to prevent undesirable consequences. The inspectors determined the | |||
finding to be of very low safety significance (Green) after performing a detailed risk | |||
evaluation in accordance with Manual Chapter 0609, Appendix A, because the missed | |||
fire watch tours reflected a low degradation of the Fire Prevention and Administrative | |||
Controls FPP element in that other area fire protection defense-in-depth features such | |||
as automatic fire detection (smoke detectors), automatic fire suppression capability | |||
(sprinklers), manual suppression capability (fire brigade), and safe shutdown capability | |||
from the main control room were still available. The licensee entered this violation into | |||
their CAP as AR 02056905. | |||
ATTACHMENT: SUPPLEMENTARY INFORMATION | |||
SUPPLEMENTARY INFORMATION | |||
KEY POINTS OF CONTACT | |||
Licensee Personnel: | |||
F. Banks, Quality Manager | |||
C. Cashwell, Training Manager | |||
P. Czaya, Licensing | |||
C. Domingos, Plant General Manager | |||
T. Eck, Security Manager | |||
M. Guth, Licensing Manager | |||
O. Hanek, Licensing Engineer | |||
A. Katz, Projects Manager | |||
G. Melin, Operations Manager | |||
S. Mihalakea, Licensing | |||
K. Ohara, Emergency Preparedness Manager | |||
J. Pallin, Engineering Director | |||
D. Sluszka, Work Controls Manager | |||
B. Stamp, Operations Director | |||
T. Summers, Site Vice-President | |||
D. Barrow, Maintenance Director | |||
R. Hess, General Operations Training Supervisor | |||
M. Wilson, Operations Training Supervisor | |||
NRC Personnel: | |||
B. Bishop, Senior Project Engineer | |||
A. Beaston, Project Engineer | |||
A. Vargas, Project Engineer | |||
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED | |||
Opened and Closed | |||
05000251/2015004-01 NCV Failure to correctly follow procedure | |||
3-PMI-072.6, Steam Dump to | |||
Atmosphere Control Loop Calibration. | |||
(Section 1R20) | |||
Attachment | |||
LIST OF DOCUMENTS REVIEWED | |||
Section 1R01: Adverse Weather | |||
0-ONOP-103.3, Severe Weather Preparations | |||
Section 1R04: Equipment Alignment | |||
3-NOP-022, Emergency Diesel Generator Fuel Oil System | |||
3-NOP-023, Emergency Diesel Generator | |||
4-NOP-022, Emergency Diesel Generator Fuel Oil System | |||
4-NOP-023, Emergency Diesel Generator | |||
3-OP-201, Filling/Draining the Refueling Cavity and the SFP Transfer Canal | |||
4-OP-201, Filling/Draining the Refueling Cavity and the SFP Transfer Canal | |||
P&ID 5613-M-3022, Emergency Diesel Engine and Oil System | |||
P&ID 5613-M-3062, Safety Injection System | |||
P&ID 5614-M-3062, Safety Injection System | |||
Section 1R05: Fire Protection | |||
0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions | |||
Section 1R08: Inservice Inspection Activities | |||
Procedures: | |||
0-ADM-537, Boric Acid Corrosion Control Program, Rev. 11 | |||
3-OSP-045.1, ASME Section XI Quality Group A Bolting Examination, Rev. 2 | |||
MA-AA-1000, Plant Leak Management Procedure, Rev. 6 | |||
NDE 4.15, Visual Examination (VE) ASME Section XI Code Case N-722-1 and N-729-1, Rev. 4 | |||
NDE 4.2, Visual Examination VT-2 Conducted During System Pressure Tests, Rev. 10 | |||
NDE 4.3, Visual Examination VT-3, Rev. 12 | |||
NDE 5.16, Ultrasonic Examination Technique for the Detection of Cracking in Feedwater Piping, | |||
Rev. 10 | |||
NDE 5.18, Ultrasonic Thickness Measurement, Rev. 8 | |||
Calculations: | |||
EC 284178, Review of Degradation and Operational Assessments at End-of-Cycle 27 for | |||
Turkey Point Unit 3 | |||
Work Orders/Work Requests: | |||
WO 4029647301, Valve 3-298C Replace Valve | |||
WO 4030098001, Repair of PZR HTR Sleeve #11 | |||
CAP Documents: | |||
AR 1771920, Audit shows no self-assessments performed on the welding control program | |||
AR 1858601, BOP, ISI and FAC Quick Hit Self-Assessment for 2012 Outages (SL-1-24, SL-2- | |||
20, TP-3-26, TP-4-27) | |||
AR 2086224, Inconsistent gaps were identified between CRDM/RPI plates and the seismic plate | |||
bumper | |||
AR 2086933, Debris inside spring hanger | |||
Miscellaneous Documents: | |||
2012 Welding May 2012 Quality Assurance Assessment | |||
3 | |||
AES 13118520-2Q-3, Condition Monitoring and Operational Assessment for the Turkey Point | |||
Unit 3 Steam Generators Based on Eddy Current Examination End of Cycle 26, March 2014 | |||
Calibration Data Sheet for UT Instruments SN: 136P1106C031381, K07639 | |||
Calibration Data Sheet No.: 5.16-002 | |||
Certificate of Conformity NDE Probe SN: SE1110 | |||
Certificate of Personnel Qualification ID No.: D0360, C2231, C6756 | |||
ENG-CSI -2.3, Steam Generator Integrity Program Administration, Rev. 32 | |||
ENG-CSI-2.2, Planning and Reporting Results of Steam Generator Tubing Examinations, | |||
Rev. 44 | |||
ER-AP-116, Boric Acid Corrosion Control, Rev. 0 | |||
Focused Self-Assessment Report 1837244, Boric Acid Corrosion Control Program | |||
Krautkramer Transducer Certificate of Conformity SN: 012Y39 | |||
Personnel Certification Statement: T. Thomas, B. Thompson, M. Smith, and M. Johnson | |||
Quick Hit Assessment Report 1892958, Boric Acid Corrosion Control Leak Evaluations | |||
Ultrasonic Instrument Calibration Data Record and Certification SN: 01R6B7 | |||
Visual Examination Evaluation Sheet: 4.3.001 | |||
Visual Examination Record Data Sheets: #4.3-008 and #4.3-009 | |||
Section 1R11: Licensed Operator Requalification Process | |||
0-ADM-211, Emergency and Off-Normal Operating Procedure Usage | |||
TR-AA-230-1007, Conduct of Simulator Training and Evaluation | |||
TR-AA-220-1004, Licensed Operator Continuing Training Annual Operating and Biennial | |||
Written Exams, Revision 1 | |||
TR-AA-230-1004, SAT Implementation, Revision 5 | |||
PTN OPS LOC15 SRO EXM1, Administered 10/06/2015 | |||
PTN OPS LOC15 SRO EXM2, Administered 11/29/2015 | |||
Section 1R15: Operability Evaluations | |||
0-ADM-213, Technical Specification Related Equipment Out of Service Logbook | |||
0-ADM-226, Operability Screening and Condition Reports | |||
EN-AA-203-1001, Operability Determinations and Assessments | |||
Section 1R18: Plant Modifications | |||
5610-M-410-40, NX Seal Assembly | |||
SPEC-C-021, Turkey Point Units 3 & 4 Tubing and Tubing Supports | |||
WO 40419666 | |||
Section 1R19: Post Maintenance Testing | |||
0-ADM-737, Post Maintenance Testing | |||
MA-AA-203-1000, Maintenance Functional Testing | |||
Section 1R20: Refueling and Other Outage Activities | |||
0-ADM-009, Containment Closeout Inspection | |||
MA-AA-101-1000, Foreign Material Exclusion Procedure | |||
0-ADM-556, Fuel Assembly and Insert Shuffles | |||
Section 2RS1: Radiological Hazard Assessment and Exposure Controls | |||
Procedures, Guidance Documents, and Manuals | |||
0-HPA-001, Radiation Work Permit Initiation and Termination, Rev. 4 | |||
4 | |||
RP-AA-102-1000, Alpha Monitoring, Rev. 2 | |||
RP-AA-103-1006, Conduct of Radiological Diving Operations, Rev. 1 | |||
RP-AA-107, Radioactive Material Control Program, Rev. 0 | |||
RP-AA-107-1003, Unconditional and Conditional Release of Material, Rev. 1 | |||
RP-SR-103-1001, Posting Requirements for Radiological Hazards, Rev. 2 | |||
RP-SR-103-1002, High Radiation Area Controls, Rev. 3 | |||
RP-SR-103-1008, Remote Monitoring, Rev. 5 | |||
0-HPS-025.2, Posting and Survey Requirements for Fuel Movement, Rev. 4B | |||
0-HPS-027.1, Work Controls in Hot Particle Areas, Rev. 0 | |||
0-HPS-106, Survey & Posting Guidelines for Plant Evolutions, Rev. 5 | |||
Records and Data Reviewed | |||
2015 NSTS Annual Inventory Reconciliation, Dated 01/15/15 | |||
Radioactive Source Leak Test Results, Dated 10/15/2015 | |||
Air Calculation Sheet, (ACS) A/S Log Ref No. P1-15-1023, U3 RCB REACTOR Sump During | |||
Demob, Dated 11/17/2015 | |||
ACS, A/S Log Ref No. P0-15-1011, U3 RCB 30 6 Routine, Dated 11/17/2015 | |||
ACS, A/S Log Ref No. P0-15-1013, Vac Shack During Tool & Respirator Decon, Dated | |||
11/17/2015 | |||
ACS, A/S Log Ref No. P0-15-1021, U3 RCB 58 By REACTOR Head Stand, Dated 11/17/2015 | |||
ACS, A/S Log Ref No. P0-15-1025, U3 RCB Upper REACTOR Cavity, Dated 11/17/2015 | |||
PTN-M-20150604-3, U4 10 Foot Pipeway, Dated 06/04/2015 | |||
PTN-M-20150930-2, U4 10 Foot Pipeway, Dated 09/30/2015 | |||
PTN-M-20150914-1, U3 10 Foot Pipeway, Dated 09/14/2015 | |||
PTN-M-20150930-3, U3 10 Foot Pipeway, Dated 09/30/2015 | |||
PTN-M-20150711-25, U4 B RHR Pump Room, Dated 07/11/2015 | |||
PTN-M-20151010-2, U4 B RHR Pump Room, Dated 10/10/2015 | |||
PTN-M-20150918-5, U4 Charging Pump Room, Dated 09/18/2015 | |||
PTN-M-20151011-7, U4 Charging Pump Room, Dated 10/11/2015 | |||
PTN-M-20141120-6, Unit 4 B RHR Dose Alarm Follow-up, Dated 11/20/2014 | |||
PTN-M-20151020-6, Aux Bldg 3-240 Valve, Dated 10/20/2015 | |||
PTN-M-20151021-25, U3 Containment 14 ft elev Inside Biowall, Dated 10/21/2015 | |||
PTN-M-20151022-15, U3 Containment 14 ft elev Inside Biowall, Dated 10/22/2015 | |||
PTN-M-20151027-30, U3 Containment 14 ft elev Inside Biowall, Dated 10/27/2015 | |||
PTN-M-20150311-6, ISFSI Pad Semi-Annual, Dated 03/11/2015 | |||
PTN-M- 20150918-6, ISFSI Pad Semi-Annual, Dated 09/18/2015 | |||
RWP Number (No.) 15-3000 U3R28 Initial Containment Entry and when Containment is posted | |||
as a Locked High Radiation Area, Rev. 0 | |||
RWP No. 15-3008, Containment General Outage Maintenance (Bulk Work), Rev 0 | |||
RWP No. 15-3013, Regenerative Heat Exchanger Room Work (Bulk Work), Rev. 0 | |||
RWP No. 15-3014, Reactor Sump - Non Legacy Boric Acid Work, Rev. 0 | |||
RWP No. 15-3018, RCP Work (Bulk Work), Rev. 0 | |||
RWP No. 15-3205, Outage Locked High Radiation Area Work, Rev. 0 | |||
CAP Documents | |||
Nuclear Oversight Report # PTN-14-002, Radiation Protection and Radwaste, Dated | |||
08/18/2014 | |||
AR 01996578 | |||
AR 01997251 | |||
AR 01997991 | |||
5 | |||
AR 02006239 | |||
AR 02008430 | |||
AR 02009674 | |||
AR 02020231 | |||
AR 02024963 | |||
AR 02029276 | |||
AR 02033046 | |||
AR 02033644 | |||
AR 02044544 | |||
AR 02044742 | |||
AR 02049552 | |||
AR 02058970 | |||
Section 2RS2: ALARA | |||
Procedures and Guidance Documents | |||
0-HPA-001, Radiation Work Permit Initiation and Termination, Rev. 04 | |||
0-HPA-072, Installation, Control, and Removal of Permanent and Temporary Shielding, Rev. 03 | |||
RP-AA-104, ALARA Program, Rev. 04 | |||
RP-AA-104-100, ALARA Implementing Procedure, Rev. 06 | |||
RP-AA-104-2003, Five Year ALARA Plan Template, Rev. 01 | |||
Primary Strategic Water Chemistry Plan, FPL PTN Units 3 & 4, 08/15/2013 | |||
Records and Data Reviewed | |||
10 CFR Applicability Determination Form, TSR 15-03, Temporary Lead Shielding Installation on | |||
Containment 14 Cavity Drain Valves, 10/18/15 | |||
ALARA Review No. 2015-006, U3R28 Refueling Activities, Including Ultra-Sonic Fuel Cleaning, | |||
Rev. 0 | |||
ALARA Review No. 2015-007, Generator Bundle Flush, Sludge Lance, and FOSAR, Rev. 0 | |||
ALARA Review No. 2015-008, U3 A, B, C RCP Seal Replacement - Fukushima Upgrade - A | |||
Motor Replacement, and PMs. Rev. 0 | |||
ALARA Review No. 2015-010, U3 BMI (Bottom Mounted Inspection), Rev. 0 | |||
ALARA Review No. 2015-013, PCV-3-455A and PCV-3-455B, Rev. 0 | |||
Job-In-Progress Review No. 2015-007, S/G secondary sludge lancing and FOSAR, Rev. 0 | |||
Job-In-Progress Review No. 2015-008, U3 A,B,C RCP Seal Replacement, Rev. 0 | |||
Job-In-Progress Review No. 2015-010, U3 BMI, Rev. 0 | |||
PTN ALARA Review Board Meeting Minutes, 03/23/15, 06/29/15, 09/04/15 | |||
PTN Nuclear Oversight Report #PTN-14-002, Subject: Radiological Protection and Radwaste, | |||
05/09/14 | |||
PTN Quick Hit Assessment Report #1938751/1927754, Self Assessment of ALARA, 04/23/14 | |||
PTN-3-R28 Refueling Outage 0500 Turnover 11/03/15, 11/05/15 | |||
PTN-3-R28 Refueling Outage 1700 Turnover 11/12/15 | |||
PTN 5-Year ALARA Plan 2015-2020 | |||
RP Survey #PTN-M-20151029-34, Unit 3 Regenerative Heat Exchangers 14, 10/29/2015 | |||
RP Survey #PTN-M-20151029-27, Unit 3 Regenerative Heat Exchangers 14, 10/28/2015 | |||
RP Survey #PTN-M-20151028-36, U3 Containment 14 Inside Biowall, 10/28/2015 | |||
RP Survey #PTN-M-20151026-22, U3 Containment 14 Inside Biowall, 10/26/2015 | |||
RP Survey #PTN-M-20151020-19, U3 Containment 14 Inside Biowall, 10/20/2015 | |||
6 | |||
Temporary Shielding Request (TSR) No. 2015-03, U3 RCB, 14 Elevation, Cavity Drain Valves, | |||
07/20/2015 | |||
TSR No. 2015-17, U3 RCB, 14 Regen. Heat Exchanger Room, 07/22/2015 | |||
CAP Documents | |||
AR 01921887 | |||
AR 01997991 | |||
AR 01909707 | |||
AR 02072141 | |||
AR 01997680 | |||
AR 02043416 | |||
AR 02038064 | |||
Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation | |||
Procedures and Guidance Documents | |||
0-ADM-041, PTN Respiratory Protection Plan, Rev. 9 | |||
0-ADM-533, Corrective Action Program Guidance, Rev. 14 | |||
0-ADM-605, Control of Radioactive Material, Rev. 4 | |||
0-HPA-028, High Efficiency Particulate Air (HEPA) Filtration Ventilation Systems in the | |||
Radiation Controlled Area, Rev. 2A | |||
0-HPS-062.2, Use of the Self-Contained Breathing Apparatus, Rev.1 | |||
0-HPS-063.2, Maintenance and Accountability of Respiratory Protective Equipment, Rev. 7 | |||
0-HPS-063.4, Selection and Issuance of Respiratory Protection Equipment, Rev. 3 | |||
0-HPS-065.2, Operation and Maintenance of the Respirator Fit-Test System, Rev. 4 | |||
0-HPS-090, Inventory of Radiation Protection Emergency Equipment, Rev. 2 | |||
PI-AA-104-1000, Corrective Action, Rev. 6 | |||
RP-AA-102-1000, Alpha Monitoring, Rev. 2 | |||
RP-TP-102-1001, Radiological Air Sample Assay, Rev. 4 | |||
Records and Data Reviewed | |||
Air Sample Log, for the period 10/1 thru 11/5/2015 | |||
Air Calculation Sheet and Gamma Spectroscopy Analysis, Air Sample # P1-I1-15-0405, U-3 | |||
RCB Lower Reactor Cavity, 10/26/2015 | |||
Certificate of Testing, PortaCount Bench 2, S/N 8030111513, 07/08/2015; and S/N | |||
8030111601, 06/10/2015 | |||
HP-90, SCBA Inventory, Inspection, and Repair Records, September and October 2015 | |||
HP-93Respirator, Inventory, Inspection, and Repair Record, September and October 2015 | |||
HP-93.1, SCBA Air Bottle Inspection and Inventory Records, September and October 2015 | |||
HP-93.6, Air Quality Certificate, Bauer Air Compressor, Dated 08/05/2015, and 05/11/2015 | |||
List of SCBA Qualified Operations, Maintenance, and Health Physics Personnel, 10/01/2015 | |||
Scott Authorized Service Center Certificates for selected vendor employees, Dated 08/22/2014 | |||
Scott PosiChek3, Visual/Functional Test Results, Regulators: 89200090, Dated 09/22/2015; | |||
89200100, Dated 09/23/2015; 89200101, Dated 09/22/2015; 89200109, Dated | |||
09/22/2015; and 89200149, Dated 09/23/2015; | |||
Unitech Service Group, DOP Test Results, HEPA Unit Type, Portable, HEPA S/N 018, Dated | |||
06/23/2015; S/N 033, Dated 06/23/2015; and S/N 040, Dated 06/24/2015 | |||
Vendor Laboratory Compressed Air/Gas Quality Testing Report Results, Bauer Air Compressor, | |||
Dated 08/05/2015, and 07/31/2015 | |||
7 | |||
CAP Documents | |||
Quick Hit/Department Assessment Report, 2014 Respiratory Protection Program Annual | |||
Review (AR 2014222), 04/07/2015 | |||
AR 01911462 | |||
AR 01845706 | |||
AR 01877007 | |||
AR 01889000 | |||
AR 01900277 | |||
AR 01964422 | |||
AR 01997251 | |||
AR 01938504 | |||
AR 02057725 | |||
AR 02020932 | |||
Section 2RS4: Occupational Dose Assessment | |||
Procedures and Guidance Documents | |||
0-HPA-030, Personnel Monitoring of External Dose, Rev. 3 | |||
0-HPS-023, Environmental Radiation Monitoring, Rev. 1 | |||
0-HPS-026.2, Response Protocols for Whole Body Counting Entrance and Exit, Rev. 3 | |||
0-HPS-031.1, Whole Body Dosimetry Issue, Rev. 3A | |||
0-HPS-031.2, Multibadge Exposure Monitoring, Rev. 0B | |||
RP-AA-101-2004, Method for Monitoring and Assigning Effective Dose Equivalent (EDE) for | |||
High Dose Gradient Work, Rev. 3 | |||
RP-SR-101-1003, Personnel Contamination Monitoring and Decontamination, Rev. 3 | |||
RP-TP-101-1005, Internal Dose Assessment, Rev. 1 | |||
RP-TP-101-1000, Exposure Investigations, Rev. 0A | |||
RP-TP-102-1002, Hard to Detect Radionuclides and Contamination Controls, Rev. 1 | |||
RP-TP-105-3008, Operation of the Radiation Protection Apex-In Vivo Whole Body Counting | |||
Equipment, Rev. 2 | |||
Records and Data Reviewed | |||
ABACOS-2000 Nuclide Libraries, 11/05/2015 | |||
Alpha Smear Log, 01/08/2015 thru 11/05/2015 | |||
Dosimetry Task Matrix, Daily Fastscan QC Check, October 2015 | |||
Extended Fastscan QA File Control Charts, 10/06/2015 thru 11/04/2015 | |||
Extended Fastscan WBC System Calibration Report, System # 97-7040, 10/23/2013 and | |||
10/22/2014 | |||
EDE Multibadge Datasheets, Pack ID# 5010 and 5012, 11/04/2015 | |||
Fastscan 1 WBC System Calibration Report, System # 97-7040, 10/23/2013 and 10/22/2014 | |||
HP-55A, Turkey Point Plant Environmental Radiation Controlled Area Radiation Levels Results | |||
Log [including ISFSI], 06/24/14 thru 12/26/14 | |||
HP-55A, Turkey Point Plant Environmental Radiation Controlled Area Radiation Levels Results | |||
Log [including ISFSI], 12/26/14 thru 6/23/15 | |||
NVLAP Lab Code 100555-0, On-Site Assessment Report and Accreditation Certificate, | |||
06/11/2015 | |||
QA 1000 File, 2013 Alpha Smear Summary: Unit 4 R27 Refueling Outage, 06/13/2014 | |||
Sensitivity Study of Personnel Contamination Monitors used at Turkey Point Nuclear Station, | |||
02/10/2010 | |||
8 | |||
Technical Support Document No. 15-058, Rev 00, Neutron Dosimetry Evaluation at Turkey | |||
Point Nuclear Power Plant, 08/21/2015 | |||
Report, Turkey Point 2015 Site TEDE Dose, Top 25, 11/04/2015 | |||
Report, Turkey Point 2015 Annual (all sites) TEDE, Top 25, 11/04/2015 | |||
CAP Documents | |||
AR 01861722 | |||
AR 01940206 | |||
AR 01959134 | |||
AR 01979141 | |||
AR 02013453 | |||
AR 02024069 | |||
AR 02076960 | |||
2RS5: Radiation Monitoring Instrumentation | |||
Procedures | |||
0-HPT-072, Calibration and Operation of Canberra Personnel Monitors, Rev. 2 | |||
0-HPT-018, Calibration of Survey Instruments, Rev. 4 | |||
0-HPT-010, Radiation Protection Instrument Plan, Rev. 6 | |||
RP-TP-105-3007, Operation and Calibration of the GEM-5 Gamma Exit Monitor, Rev 4 | |||
Calibrations and Data | |||
Work Order 40033883, ARMS Cal Inside Containment (RD-1401-03), 02/2012 | |||
Work Order 40323168, ARMS Cal Inside Containment (RD-1401-03), 03/2014 | |||
Work Order 40170223, T.S R-4-19 S/G Liquid Sample PRMS Cal, 05/2013 | |||
Work Order 40280868, T.S R-4-19 S/G Liquid Sample PRMS Channel CAL, 12/2014 | |||
Work Order 40273313, T.S. Plt Vent SPING Rad-6304 PM Cal, 09/2014 | |||
Work Order 40113819, T.S. Plt Vent SPING Rad-6304 PM Cal, 12/2012 | |||
Work Order 40161233, T.S. RAD-6311 A/B Cont HI Range ARMS CAL Per 3-PMI-066.3, | |||
02/2013 | |||
Work Order 40219065, T.S. RAD-6311 A/B Cont HI Range ARMS CAL Per 3-PMI-066.3, | |||
03/2014 | |||
Work Order 40323168, T.S. RD-4-15 SJAE 18 Monthly PM CAL, 01/2015 | |||
Work Order 40247970, T.S. RD-4-15 SJAE Spiking cause alarms, 07/2013 | |||
Calibration of the FASTSCAN WBC System #97-7040, 10/2013 & 10/2014 | |||
HP-7:5.4 CRONOS Calibration Records for #1302-27, 09/24/14 & 03/19/14; #0912-039 , | |||
10/02/2014 & 10/11/2013; #1005-048 05/26/2015 & 06/09/2014; #1005-049 04/27/2015 & | |||
04/29/2014; #1006-037 06/15/2015 & 06/20/2014; #1302-029 07/22/2015 & 07/22/2014; | |||
#1302-028 01/13/12015 & 07/23/2014. | |||
GEM-5 Calibration Certificates: #1423, #1424, 07/2014 & 07/2013; #1425 07/2014 & 06/2015 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 03/2015 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 03/2014 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 01/2014 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-108, 07/2015 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-108, 01/2015 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #1107-185, 03/2015 | |||
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #1107-185, 02/2015 | |||
System Health Report 07/01/2015-09/30/2015 | |||
F & J Model LV-14M Calibration Record Serial #s 4029, 4030, 4031, 06/2015 | |||
9 | |||
Calibration of the Count Room MCA System, Detector Two, 06/2014 | |||
RADECO H809V/C Air Sampler Calibration Record, HPI# 1485E 02/2015 | |||
Controlled Settings- Eberline AMS 4, #1847, 10/2015; #2551, 10/2015; #1836 10/2015, #1283 | |||
8/2015, #1080 08/2015, #12872 05/2015, #1638 08/2015, #1079 08/2015 | |||
Radiation Detection Instrument Calibration and Maintenance Record, Telepole #6605-081, | |||
11/12/2015 & 05/07/2015; RO-20 #105 10/22/2015 | |||
HP-7-21, Shepard Model 89 Shielded Range Calibrator Certification Form, 02/2015 | |||
CAP Documents | |||
PTN-14-002, Radiological Protection and Radwaste Audit, 03/03/2014 | |||
AR 01895614 | |||
AR 02035780 | |||
AR 01945528 | |||
AR 02042545 | |||
AR 02009932 | |||
Section 4OA1: Performance Indicator Verification | |||
0-ADM-032, NRC Performance Indicators Turkey Point, Rev. 5 | |||
List of Dose and Dose Rate Alarms October 1, 2014 to September 30, 2015 | |||
Monthly Gaseous Dose Report, October 2015 | |||
Monthly Liquid Dose Report, October 2015 | |||
2014 Annual Radioactive Effluent Report | |||
AR 01909707 | |||
AR 02063559 | |||
AR 02083253 | |||
Section 4OA2: Problem Identification and Resolution | |||
AR 2046565, Engineering CAP Indicator for Quality of Cause Analysis | |||
AR 02038459, Safety Issue, No Safety Chain on Emergency Ladder | |||
AR 02039495, Unable To Complete 0-GME-005.03 for 4AD07 SBO Breaker | |||
AR 02039635, Station Blackout Tie Breaker Testing | |||
AR 02040240, RCS A HI Tave Alarmed Early Following Dilution | |||
AR 02040257, 4A Charging Pump Needs Oil | |||
AR 02040258, 3B Charging Pump Fluid Drive Needs Oil | |||
AR 02040265, 4B Turbo Oil Pump Minor Oil Seal Leak | |||
AR 02041403, Time Delay Actuation Outside Acceptable Band | |||
AR 02041408, Time Delay Actuation Outside Acceptable Band | |||
AR 02041612, 3P253A 3A 4KV Room Sump Pump Does Not Turn Off | |||
AR 02041798, Spalling Concrete in Unit 4 Spent Fuel Pool Room | |||
AR 02041864, 3A EDG Coolant Reservoir Stained With Coolant | |||
AR 02044844, 4KV Switchgear Sump High Level | |||
AR 02044936, Performed Level 3 Leak Rate Investigation on Unit 3 | |||
AR 02044977, Unit 3 Gamma Metric Channel Alarm Causing a Distraction | |||
AR 02045014, N-3-31 Detector Replacement | |||
AR 02045085, 3B RCP Motor Has Oil Leak and Needs Replacement | |||
AR 02046549, Active Boric Acid Leak at Bonnet of 4-873B | |||
AR 02046555, Maintenance Rule A(1) Status for NIS Source Range Detectors | |||
AR 02047770, Errors in Unit 4 Post Trip Review Restart Report | |||
AR 02047817, Coolant Leak From the 3B EDG | |||
AR 02049161, Excessive Ripple on the 22 Vdc Power Supply | |||
10 | |||
AR 02049180, Missing Bolt and Washer on 3B Belt Guard | |||
AR 02049269, 10 CFR 50.59 Screening for Rod Control System Monitoring | |||
AR 02049306, FME Found in 4P212A Pump Casing | |||
AR 20241958, U4 RHR Pump High Radiation Barrier Is Unsafe | |||
AR 02097053, Level 3 Mispositioning Event | |||
AR 02097144, RHR Pump Testing | |||
LIST OF ACRONYMS | |||
AFW Auxiliary Feedwater | |||
ALARA As Low As Reasonably Achievable | |||
AR Action Request | |||
ARM Area Radiation Monitor | |||
ASME American Society of Mechanical Engineers | |||
CAP Corrective Action Program | |||
CCW Component Cooling Water | |||
CFR Code of Federal Regulations | |||
CR Condition Report | |||
EAL Emergency Action Level | |||
ED Electronic Dosimeter | |||
EDG Emergency Diesel Generator | |||
FME Foreign Material Exclusion | |||
FPP Fire Protection Program | |||
GOP General Operating Procedure | |||
HEPA High Efficiency Particulate Air | |||
HHSI High Head Safety Injection | |||
ICW Intake Cooling Water | |||
IP Inspection Procedure | |||
ISFSI Independent Spent Fuel Storage Installation | |||
IST Inservice Testing | |||
LCO Limiting Condition of Operation | |||
LER Licensee Event Report | |||
LHRA Locked High Radiation Area | |||
LOCA Loss of Coolant Accident | |||
NAP Nuclear Administrative Procedure | |||
NCV Non-Cited Violation | |||
NDE Non-Destructive Examination | |||
NEI Nuclear Energy Institute | |||
NRC Nuclear Regulatory Commission | |||
OCC Outage Control Center | |||
OLRM On-Line Risk Monitor | |||
ONOP Off Normal Operating Procedure | |||
OOS Out of Service | |||
OSP Operations Surveillance Procedure | |||
P&ID Piping and Instrumentation Drawing | |||
PCM Personnel Contamination Monitor | |||
PI Performance Indicator | |||
PW Primary Water | |||
QATR Quality Assurance Topical Report | |||
RCA Radiologically Controlled Area | |||
RCE Root Cause Evaluation | |||
RCP Reactor Coolant Pump | |||
RCS Reactor Coolant System | |||
RFO Refueling Outage | |||
RHR Residual Heat Removal | |||
RP Radiation Protection | |||
12 | |||
RTP Rated Thermal Power | |||
RWP Radiation Work Permit | |||
SAM Small Article Monitor | |||
SCBA Self-Contained Breathing Apparatus | |||
SDP Significance Determination Process | |||
SFP Spent Fuel Pool | |||
SAM Small Article Monitor | |||
SCBA Self-Contained Breathing Apparatus | |||
SDP Significance Determination Process | |||
SG Steam Generator | |||
SFP Spent Fuel Pool | |||
SI Safety Injection | |||
SUT Startup Transformer | |||
TEDE Total Effective Dose Equivalent | |||
TS Technical Specifications | |||
U3 Unit 3 | |||
U4 Unit 4 | |||
UFSAR Updated Final Safety Analysis Report | |||
WBC Whole Body Counter | |||
WO Work Order | |||
}} |
Latest revision as of 19:44, 4 December 2019
ML16027A147 | |
Person / Time | |
---|---|
Site: | Turkey Point ![]() |
Issue date: | 01/27/2016 |
From: | Ladonna Suggs NRC/RGN-II/DRP/RPB3 |
To: | Nazar M Nextera Energy |
References | |
IR 2015004 | |
Download: ML16027A147 (43) | |
See also: IR 05000250/2015004
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
January 27, 2016
Mr. Mano Nazar
President and Chief Nuclear Officer
Nuclear Division
NextEra Energy
P.O. Box 14000
Juno Beach, FL 33408-0420
SUBJECT: TURKEY POINT NUCLEAR GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000250/2015004, 05000251/2015004
Dear Mr. Nazar:
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Turkey Point Nuclear Generating Station Units 3 and 4. On January 15,
2016, the NRC inspectors discussed the results of the inspection with Mr. Tom Summers and
other members of your staff. The inspectors documented the results of this inspection in the
enclosed inspection report.
NRC inspectors documented one self-revealing finding of very low safety significance (Green) in
this report. The finding involved a violation of NRC requirements. The NRC is treating this
violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement
Policy.
If you contest the violations or significance of these NCVs, 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, U.S. Nuclear
Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at
Turkey Point Nuclear Generating Station Units 3 and 4.
If you disagree with a cross-cutting aspect assignment, 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 Nuclear
Generating Station Units 3 and 4.
M. Nazar 2
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 Agency wide 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/
LaDonna B. Suggs, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Docket Nos.: 50-250, 50-251
Enclosure:
IR 05000250/2015004, 05000251/2015004
w/Attachment: Supplementary Information
cc Distribution via ListServ
ML16027A147 SUNSI REVIEW COMPLETE FORM 665 ATTACHED
OFFICE RII:DRP RII:DRP RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS
SIGNATURE TLH4 via email MXE2 via email MAB7 via email REW1 via email RXK3 /RA for/ RXK3 PGC1 via email
NAME THoeg MEndress MBates RWilliams BPursley RKellner PCapehart
DATE 1/26/2016 1/26/2016 1/25/2016 1/26/2016 1/26/2016 1/26/2016 1/25/2016
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
OFFICE RII:DRP RII:DRS RII:DRS
SIGNATURE LJB4 RXK3 /RA FOR/ CMD4 via email
NAME LSuggs JPanfel CDykes
DATE 1/26/2016 1/26/2016 1/26/2016
E-MAIL COPY? YES NO YES NO YES NO
M. Nazar 3
Letter to Mano Nazar from LaDonna B. Suggs January 27, 2016
SUBJECT: TURKEY POINT NUCLEAR GENERATING STATION - NRC INTEGRATED
INSPECTION REPORT 05000250/2015004, 05000251/2015004
DISTRIBUTION:
S. Price, RII
L. Gibson, RII
OE Mail
RIDSNRRDIRS
PUBLIC
RidsNrrPMTurkeyPoint Resource
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos: 50-250, 50-251
Report Nos: 05000250/2015004, 05000251/2015004
Licensee: Florida Power & Light Company (FP&L)
Facility: Turkey Point Nuclear Generating Station, Units 3 & 4
Location: 9760 S. W. 344th Street
Homestead, FL 33035
Dates: October 1 to December 31, 2015
Inspectors: T. Hoeg, Senior Resident Inspector
M. Endress, Resident Inspector
M. Bates, Senior Operations Engineer
R. Williams, Senior Reactor Inspector
B. Pursley, Health Physicist
C. Dykes, Health Physicist
J. Panfel, Health Physicist
B. Kellner, Senior Health Physicist
P. Capehart, Senior Operations Engineer
Approved by: LaDonna B. Suggs, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Enclosure
SUMMARY
IR 05000250/2015004, 05000251/2015004; 10/01/2015 - 12/31/2015; Turkey Point Nuclear
Generating Station, Units 3 and 4; Refueling Outage & Other Outage Activities.
The report covered a three-month period of inspection by the resident inspectors and specialist
inspectors from the Region II office. One Green non-cited violation (NCV) was identified. The
significance of inspection findings are indicated by their color (i.e., greater than Green, or
Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process, (SDP) dated April 29, 2015. The cross-cutting aspects
were determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December
4, 2014. All violations of NRC requirements were dispositioned in accordance with the NRCs
Enforcement Policy dated February 4, 2015. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 5.
NRC-Identified and Self-Revealing Findings
Cornerstone: Barrier Integrity
- Green: A self-revealing NCV of Technical Specification (TS) 6.8.1, Procedures and
Programs, was identified when the licensee failed to properly implement procedure
3-PMI-072.6, Steam Dump to Atmosphere Control Loop Calibration. Specifically, the
licensee incorrectly installed a temporary electrical jumper in reactor operator console
3C02 instead of 3C04, in contrast to Step 6.3.2 of 3-PMI-072.6. This action resulted in
actuation of a 3B 4160 volt (V) vital bus lockout circuit causing loss of power to the B
train of Unit 3 (U3) spent fuel pool (SFP) cooling. Immediate corrective actions were
taken to remove the jumper and restore the B train of SFP cooling. The licensee
entered the condition in its corrective action program (CAP) as action request (AR)
02088911 and 02088914.
The performance deficiency was determined to be more than minor because it was
associated with the human performance attribute of the barrier integrity cornerstone and
adversely affected the cornerstone objective to provide reasonable assurance that
physical design barriers (fuel cladding, reactor coolant system (RCS), and containment)
protect the public from radionuclide releases. In addition, the performance deficiency, if
left uncorrected, had the potential to lead to a more significant safety concern. The
finding was screened using IMC 0609, Significance Determination Process,
Attachment 0609.04, Initial Characterization of Findings, Tables 2 and 3, dated July 1,
2012, and Appendix G Attachment 1, Shutdown Operations Significance Determination
Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 4 for Barrier
Integrity, dated May 9, 2014. The inspectors determined the finding was of very low
safety significance (Green) because it was not associated with low temperature over
pressurization, freeze seals, steam generator nozzle dams, criticality, drain down or
leakage paths, or the containment barrier. Furthermore, one train of SFP cooling
remained in operation, the rate of SFP temperature rise was low (~ 2 °F/hour), and
additional methods remained available to limit SFP temperature rise. This finding was
assigned a cross cutting aspect associated with the procedure adherence element of the
human performance area because the licensee failed to correctly execute step 6.3.2 of
procedure 3-PMI-072.6 (H.8). (Section 1R20)
3
Licensee-Identified Violations
Violations of very low safety or security significance or Severity Level IV that were
identified by the licensee have been reviewed by the NRC. Corrective actions taken or
planned by the licensee have been entered into the licensees CAP. These violations
and corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Unit 3 began this inspection period at 100 percent of Rated Thermal Power (RTP) where it
remained until October 19, 2015, when it was shut down for a scheduled refueling outage
(RFO). Unit 3 was restarted November 29, 2015, and returned to 100 percent of RTP on
December 9, 2015, where it remained through the end of this inspection period.
Unit 4 (U4) began this inspection period at 100 percent of RTP where it remained through the
end of this inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection (IP 71111.01)
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
During the month of December, 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,
Attachment 7, Cold Weather Readiness Check List, and Attachment 14, Turkey Point
Site Specific Guidance. The inspectors reviewed system health reports and open CAP
ARs for the emergency diesel generators (EDGs) and auxiliary feedwater (AFW) 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:
- U3 and U4 EDGs
- AFW pumps
- U3 and U4 charging pumps
- U3 and U4 boric acid storage tanks
b. Findings
No findings were identified.
1R04 Equipment Alignment (IP 71111.04)
.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
5
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, by entering them in the CAP, equipment
alignment problems that could cause initiating events or impact the capability of
mitigating systems or barriers. Documents reviewed are listed in the Attachment. This
inspection constitutes three samples.
were OOS
b. Findings
No findings were identified.
1R05 Fire Protection (IP 71111.05)
.1 Fire Area Walk downs
a. Inspection Scope
The inspectors walked down the following five 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
inspectors routinely reviewed the licensees fire impairment lists and monitored the
associated corrective actions for completion. The inspectors reviewed the AR report
database to verify that fire protection problems were being identified and appropriately
resolved in the CAP. The inspectors tours of the selected areas verified the fire
protection equipment was installed as shown on the applicable fire plan drawings and
appeared functional and ready for usage. This inspection constitutes five samples. The
following areas were inspected:
- U4 Pipe and Valve Room, Fire Zone 030
- U3 Containment Building, Fire Zone 060
- U4 4B Vital Battery Room, Fire Zone 102
- U3 and U4 Mechanical Equipment Room, Fire Zone 097
- Auxiliary Building Electrical Equiptment Room, Fire Zone 025
b. Findings
No findings were identified.
6
.2 Fire Protection - Drill Observation
a. Inspection Scope
On December 9, 2015, the inspectors observed an unannounced fire drill that took place
within the station power block just outside the 3D31/4D31 non vital 125 VDC switchgear
room in the turbine building. The drill was observed to evaluate the readiness of the
plant fire brigade to fight fires and the control room to make the proper emergency action
level (EAL) classification. The inspectors verified that the licensee staff identified
deficiencies, openly discussed them in a self-critical manner at the drill debrief meeting,
and took appropriate corrective actions as required. Specific attributes evaluated were:
- Proper wearing of fire protective gear and self-contained breathing apparatus
- Proper use and layout of fire hoses
- Employment of appropriate fire-fighting techniques
- Sufficient fire-fighting equipment brought to the scene
- Effectiveness of command and control
- Search for victims and propagation of the fire into other plant areas
- Smoke removal operations
- Utilization of pre-planned strategies
- Adherence to the pre-planned drill scenario
- Drill objective
The inspectors also observed the placement and charging of the fire hoses used to
simulate extinguishing the fire.
b. Findings
No findings were identified.
1R08 Inservice Inspection Activities (IP 71111.08)
a. Inspection Scope
Non-Destructive Examination Activities and Welding Activities
From October 26-29, 2015, the inspectors conducted an onsite review of the
implementation of the licensees inservice inspection (ISI) program for monitoring
degradation of the RCS boundary, risk-significant piping and component boundaries,
and containment boundaries in U3.
The inspectors either directly observed or reviewed the following non-destructive
examinations (NDEs) mandated by the American Society of Mechanical Engineers
(ASME) Boiler and Pressure Vessel Code (Code of Record: 2007 Edition with 2008
Addenda) to evaluate compliance with the ASME Code,Section XI and Section V
requirements, and if any indications or defects were detected, to evaluate if they were
dispositioned in accordance with the ASME Code or an NRC-approved alternative
requirement. The inspectors also reviewed the qualifications of the NDE technicians
performing the examinations, to determine whether they were current and in compliance
with the ASME Code requirements.
7
- Ultrasonic Examination of Loop B 18-inch Feedwater Nozzle-to-Pipe weld,
Augmented Examination (observed)
Augmented Examination (observed)
- Visual Examination of the Reactor Pressure Vessel bottom-mounted instrumentation
penetrations (reviewed)
- Visual Examination (VT-3) of Spring Hanger 3-RCH-27, Class 1 Support (observed)
- VT-3 of Dual Spring Hanger VS-1G-12, Class 1 Support (observed)
The inspectors either directly observed or reviewed the following welding activities,
qualification records, and associated documents in order to evaluate compliance with
procedures and the ASME Code,Section XI and Section IX requirements. Specifically,
the inspectors reviewed the work order (WO), repair and replacement plan, weld data
sheets, welding procedures, procedure qualification records, welder performance
qualification records, and NDE reports.
- WO 4030098001, Repair of PZR HTR Sleeve #11, Class 1 (reviewed)
- WO 4029647301, Valve 3-298C Replace Valve, Class 2 (reviewed)
During non-destructive surface and volumetric examinations performed since the
previous RFO, the licensee did not identify any relevant indications that were analytically
evaluated and accepted for continued service; therefore, no NRC review was completed
for this inspection procedure (IP) attribute.
Pressurized Water Reactor Vessel Upper Head Penetration Inspection Activities
The inspectors verified that for the U3 vessel head, a bare metal visual examination and
a volumetric examination were not required during this outage, in accordance with the
requirements of ASME Code Case N-729-1 and 10 CFR 50.55a(g)(6)(ii)(D).
The licensee did not identify any relevant indications that were accepted for continued
service. Additionally, the licensee did not perform any welding repairs to the vessel
head penetrations since the beginning of the last U3 RFO; therefore, no NRC review
was completed for these IP attributes.
Boric Acid Corrosion Control Inspection Activities
The inspectors reviewed the licensees boric acid corrosion control program activities to
determine if the activities were implemented in accordance with the commitments made
in response to NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor
Pressure Boundary Components in PWR Plants, and applicable industry guidance
documents. Specifically, the inspectors performed an onsite records review of
procedures, and the results of the licensees containment walkdown inspections
performed during the current RFO. The inspectors also interviewed the Boric Acid
Corrosion Control (BACC) program owner, conducted an independent walkdown of
containment to evaluate compliance with licensees BACC program requirements, and
verified that degraded or non-conforming conditions, such as boric acid leaks, were
properly identified and corrected in accordance with the licensees BACC and CAP.
8
The inspectors reviewed the following engineering evaluations, completed for evidence
of boric acid leakage, to determine if the licensee properly applied applicable corrosion
rates to the affected components; and properly assessed the effects of corrosion
induced wastage on structural or pressure boundary integrity in accordance with the
licensee procedures.
- AR 02014343, Boric Acid Evaluation
- AR 02021132, Boric Acid Evaluation
- AR 02025309, Boric Acid Evaluation
- AR 02038045, Boric Acid Evaluation
The inspectors reviewed the following condition reports (CRs) and associated corrective
actions related to evidence of boric acid leakage, to evaluate if the corrective actions
completed were consistent with the requirements of the ASME Code and 10 CFR Part
50, Appendix B, Criterion XVI.
- AR 02086287, CV-3-2819 has corrosion on electrical connection
- AR 02086292, MOV-3-866B inactive minor dry white boric acid at packing
- AR 02086231, 3-309D inactive minor dry white boric acid at packing
- AR 02086226, 3-306B inactive minor dry white boric acid at packing
- AR 02086218, 3-120G inactive dry white boric acid at D/S pipe cap
- AR 02086240, 3-572 inactive dry white boric acid at packing
- AR 02086239, 3-542, inactive dry white boric acid at packing
Steam Generator Tube Inspection Activities
The inspectors verified that for the U3 steam generator tubes, no inspection activities
were required this RFO, in accordance with the requirements of the ASME Code, the
licensees TS, and Nuclear Energy Institute (NEI) 97-06, Steam Generator Program
Guidelines.
Identification and Resolution of Problems
The inspectors reviewed a sample of ISI-related issues entered into the CAP to
determine if the licensee had appropriately described the scope of the problem, and
had initiated corrective actions. The review also included the licensees consideration
and assessment of operating experience events applicable to the plant. The inspectors
performed this review to ensure compliance with 10 CFR Part 50, Appendix B, Criterion
XVI, Corrective Action, requirements.
b. Findings
No findings were identified.
9
1R11 Licensed Operator Requalification Program (IP 71111.11)
.1 Licensed Operator Requalification Exam
a. Inspection Scope
Annual Review of Licensee Requalification Examination Results: On December 30,
2015, 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 IP 71111.11, Licensed Operator Requalification Program. These results were
compared to the thresholds established in Section 3.02, Requalification Examination
Results, of IP 71111.11.
b. Findings
No findings were identified.
.2 Resident Inspector Quarterly Review
a. Inspection Scope
The inspectors performed the following inspection sample of a simulator observation and
assessed licensed operator performance while training. These observations included
procedural use and adherence, response to alarms, communications, command and
control, and coordination and control of the reactor plant operations.
On October 8, 2015, the inspectors assessed licensed operator performance in the
plant-specific simulator during a training evolution. The training scenario was started
with the unit in Mode 1 at 100 percent power and included a fire lasting greater than 15
minutes, a loss of reactor coolant accident (LOCA), a reactor trip, a safety injection, a
residual heat removal (RHR) pump seal failure, and a radiological release to the
environment.
During this simulator observation, the simulator board configurations were compared
with actual plant control board configurations reflecting recent plant changes or
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
10
b. Findings
No findings were identified.
.3 Control Room Observations
a. Inspection Scope
The inspectors performed daily assessments of licensed operators in the control room
during their performance of routine operations. These observations included daily
surveillance testing, log keeping, 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. The inspectors also
performed the following three focused control room observations during reactivity
manipulations and Mode changes:
On November 19, 2015, the inspectors performed a focused observation on U4
consisting of a RCS primary water dilution per 0-OP-046, Enclosure 6, Chemical
Volume Control System Boron Concentration Control. Specifically, the inspectors
observed the reactor operators performance of 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.
On December 1, 2015 and December 2, 2015, the inspectors performed a focused
observation in the U3 control room during low power physics testing in accordance with
procedure 0-OSP-040.19, Low Power Physics Testing. The inspectors observed the
pre-evolution operating crew brief, control rod movements, monitoring of subcritical
multiplication, and data collection.
On December 3, 2015, the inspectors performed a focused observation on U3 during a
reactor startup per procedure 3-GOP-301, Hot Standby to Power Operations. The
inspectors reviewed the expected critical boron concentration calculation and the control
rod pull sequence plan used during the observed reactor startup. The inspectors
reviewed the recorded reactor startup physics data to ensure it was as calculated by the
licensee reactor engineering staff.
This inspection constitutes three samples. 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
11
b. Findings
No findings were identified.
.4 Biennial Requalification
a. Inspection Scope
The inspectors reviewed the facility operating history and associated documents in
preparation for this inspection. During the weeks of November 30, 2015 through
December 21, 2015, the inspectors reviewed documentation associated with the
licensees operator requalification program biennial written examinations. The activity
performed by the inspectors was conducted to assess the licensees effectiveness 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 IP 71111.11, Licensed
Operator Requalification Program. Documentation reviewed included two biennial
written examinations. The records were inspected using the criteria listed in IP
71111.11. Documents reviewed during the inspection are documented in the List of
Documents Reviewed.
The sample is now complete because the remainder of this sample was previously
inspected and documented in the third quarter integrated inspection report
(05000250&251/2015003).
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (IP 71111.12)
a. Inspection Scope
The inspectors reviewed known equipment problems associated with the U3 steam
generator steam flow module FM-3-474D affecting the maintenance rule program and
equipment performance history trends associated with the equipment. Specifically, the
inspectors reviewed AR 02081538.
The inspectors reviewed the licensees activities to meet 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 licensees CAP. The inspectors used the licensee maintenance rule
12
database, system health reports, maintenance rule unavailability status reports, and the
CAP as sources of information on tracking and resolution of issues. This inspection
constitutes one sample.
- U3 FM-3-474D Flow Module Bias Potentiometer
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (IP 71111.13)
a. Inspection Scope
The inspectors completed in-office reviews and control room inspections of the
licensees risk assessment of five 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 0-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 is 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 OOS equipment was included in the OLRM calculation. The inspectors
evaluated the following five risk assessment samples during the inspection period:
- U3 3-312A Valve Inspection and Repair with Freeze Seal (WO 40411630)
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (IP 71111.15)
a. Inspection Scope
The inspectors evaluated the technical adequacy of the licensee evaluations to ensure
that TS operability was properly justified and the subject component or system remained
available such that no unrecognized increase in risk occurred for the five operability
evaluations described in the ARs listed below. The inspectors reviewed applicable
sections of the updated Final Safety Anaylsis Report (UFSAR) 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
13
the affected equipment remained capable of performing its intended design function.
The inspectors also reviewed a sampling of CRs to verify that the licensee routinely
identifed and corrected any deficiencies associated with operability evaluations. This
inspection constitutes five samples.
- AR 02083336, U3 RHR Gas Voids
- AR 02082853, Pressurizer Steam Sample Line Containment Isolation Valve (CV-4-
951) OOS
- AR 02053124, 3B EDG Oil Leak
- AR 02086176, 3A FT-3-414 Bent and Unsupported
- AR 02093957, 4B EDG TS-4-6132 Broken
b. Findings
No findings were identified.
1R18 Plant Modifications (IP 71111.18)
Permanent Plant Modifications
a. Inspection Scope
The inspectors reviewed the following two permanent plant modifications. The
inspectors reviewed the 10 CFR 50.59 screening and technical evaluation to verify that
the modifications had not affected system operability or availability. The inspectors
reviewed associated plant drawings, design analyses, and UFSAR documents impacted
by these modifications and discussed the changes with licensee personnel to verify that
the modifications were consistent with the WO and associated documents. The
inspectors observed portions of the modifications and surrounding areas to determine if
conditions resulted in any potential unsafe conditions not described in the engineering
change documentation. Additionally, the inspectors reviewed and verified that any
conditions associated with the modifications were being identified and entered into the
CAP. This inspection constitutes two samples.
- EC 280399, U3 Reactor Coolant Pump (RCP) Seal Replacmement Modification
- EC 285012, FT-4-494 U4 Steam Generator C Steam Flow Detector Line
Replacement
b. Findings
No findings were identified.
1R19 Post Maintenance Testing (IP 71111.19)
a. Inspection Scope
For the five post maintenance tests and associated WOs 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
completed satisfactorily and demonstrated that the affected equipment was operable.
14
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 five inspection samples:
- WO 40281614, U3 Pressurizer Pressure Operated Relief Valve PCV-3-455C
- WO 40419666, U4 Steam Generator C Steam Flow Detector FT-4-494
- WO 40371127, 3B Containment Spray Pump Check Valve Inspection
- WO 40419961, Reactor Protection System 3-P7-1-B Relay Replacement
- WO 40161059, 3B50 Load Center Relay Replacements
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities (IP 71111.20)
.1 Unit 3 Refueling Outage PT3-28 (one sample)
a. Inspection Scope
Outage Planning, Control and Risk Assessment
During daily outage planning activities by the licensee, the inspectors reviewed the risk
reduction methodology employed by the licensee during RFO PT3-28 meetings including
outage control center (OCC) morning meetings, operations daily team meetings, and
schedule performance update meetings. The inspectors examined the licensee
implementation of shutdown safety assessments during PT3-28 in accordance with
administrative procedure ADM-051, Outage Risk Assessment and Control, to verify if a
defense in depth concept was in place to ensure safe operations and avoid unnecessary
risk. In addition, the inspectors regularly monitored outage planning and control
activities in the OCC, and interviewed responsible OCC management personnel during
the outage to ensure system, structure, and component configurations, and work scope
were consistent with TS requirements, site procedures, and outage risk controls.
Monitoring of Shutdown Activities
The inspectors performed walk downs of important systems and components used for
RHR from the reactor core and SFP during the shutdown period, including the intake
cooling water system, component cooling water (CCW) system, and SFP cooling
system.
Outage Activities
The inspectors examined outage activities to verify that they were conducted in
accordance with TS, licensee procedures, and the licensees outage risk control plan.
Some of the more significant inspection activities accomplished by the inspectors were
as follows:
15
- Walked down selected safety-related equipment clearance orders
- Verified operability of RCS pressure, level, flow, and temperature instruments during
various modes of operation
- Verified electrical systems availability and alignment
- Verified shutdown cooling system and SFP cooling system operation
- Evaluated implementation of reactivity controls
- Reviewed control of containment penetrations
- Examined foreign material exclusion (FME) controls put in place inside containment
(e.g., around the refueling cavity, near sensitive equipment and RCS breaches) and
around the SFP
- Observed fuel loading and unloading in the SFP and in containment
Monitoring of Plant Heat up and Containment Closure Activities
The inspectors examined the applicable TS, license conditions, and verified
administrative prerequisites were being met prior to reactor plant mode changes. The
inspectors reviewed measured RCS leak rates, and verified containment integrity was
properly established. The inspectors performed a containment closeout inspection prior
to the reactor plant startup to verify no evidence of leakage or debris were left in
containment that could affect plant operations.
Reactor Startup and Mode Changes
On December 2, 2015, the inspectors observed the U3 reactor startup and turbine
synchronization to the electrical grid and associated Mode changes. The inspectors
reviewed the recorded reactor startup physics data in order to determine it was as-
calculated by the licensee reactor engineering staff. The inspectors determined that
startup and Mode changes were performed in accordance with licensee procedures 0-
OSP-040.16, Initial Criticality After Refueling Outage and Nuclear Design Verification,
and 3-GOP-301, Mode 3 to Power Operations.
Corrective Action Program
The inspectors reviewed ARs generated during PT3-28 to evaluate the licensees
threshold for initiating ARs. The inspectors reviewed CRs to verify priorities, Mode
holds, and significance levels were assigned as required. Resolution and
implementation of corrective actions of several ARs were also reviewed for
completeness. The inspectors routinely reviewed the results of site oversight of daily
surveillances of outage activities.
b. Findings
Introduction: A Green self-revealing NCV of TS 6.8.1, Procedures and Programs, was
identified for the licensees failure to correctly execute procedure 3-PMI-072.6, Steam
Dump to Atmosphere Control Loop Calibration. The failure resulted in actuation of a 3B
4160 V vital bus lockout circuit causing loss of power to the B train of U3 SFP cooling.
Description: On November 4, 2015, at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />, Instrumentation and Controls
technicians were performing procedure 3-PMI-072.6, Steam Dump to Atmosphere
Control Loop Calibration, when a temporary electrical jumper was incorrectly installed in
16
the control room reactor operator console 3C02 instead of 3C04, in contrast to step 6.3.2
of 3-PMI-072.6. At the time of the event, U3 was defueled with all of its fuel temporarily
relocated to the SFP. The 3A 4160 V vital bus was de-energized for planned
maintenance and all 480 V vital load centers were powered by the 3B 4160 V vital bus.
Separate load centers provided power to two separate trains of U3 SFP cooling pumps,
and the 3A train pump was powered from Unit 4 electrical switchgear.
The incorrectly placed jumper actuated a 3B 4160 V vital bus lockout circuit causing all
associated Unit 3 480 V vital load and motor control centers to de-energize. Numerous
equipment was rendered OOS including the B SFP cooling pump and the 3B CCW
pump. The 3B CCW pump provided cooling to both U3 SFP cooling heat exchangers.
Upon loss of the 3B CCW pump, the standby 3C CCW pump started on low pressure as
designed, providing cooling to the 3A SFP cooling train. Immediate corrective action
was taken to remove the jumper and restore the B train of SFP cooling. However, the
loss of one train of SFP cooling for approximately four hours caused the SFP
temperature to rise from approximately 110 °F to 117 °F. The licensee restored U3 load
and motor control centers at 0207 hours0.0024 days <br />0.0575 hours <br />3.422619e-4 weeks <br />7.87635e-5 months <br /> on November 5, 2015, and by 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> the
SFP temperature had returned to normal.
The licensee entered the condition in its CAP as AR 02088911 and 02088914.
Corrective actions included site-wide briefings of lessons learned from the event, quality
reviews of procedure 3-PMI-072.6, and enhanced oversight of maintenance activities.
Analysis: The inspectors determined that the failure to correctly implement maintenance
procedure 3-PMI-072.6 was a performance deficiency. The performance deficiency was
determined to be more than minor because it was associated with the human
performance attribute of the barrier integrity cornerstone and adversely affected the
cornerstone objective to provide reasonable assurance that physical design barriers (fuel
cladding, RCS, and containment) protect the public from radionuclide releases.
Specifically, the licensees failure to correctly execute step 6.3.2 of procedure
3-PMI-072.6 rendered one of two SFP cooling trains OOS, causing the SFP temperature
to rise from approximately 110 °F to 117 °F over a four-hour period. While the
performance deficiency did not directly challenge the integrity of the fuel cladding, if left
uncorrected, the SFP temperature would have continued to increase, potentially
affecting SFP inventory.
The finding was screened using IMC 0609, Significance Determination Process,
Attachment 0609.04, Initial Characterization of Findings, Tables 2 and 3, dated July 1,
2012, and Appendix G Attachment 1, Shutdown Operations Significance Determination
Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 4 for Barrier
Integrity, dated May 9, 2014. The inspectors determined the finding was of very low
safety significance (Green) because it was not associated with low temperature over
pressurization, freeze seals, steam generator nozzle dams, criticality, drain down or
leakage paths, or the containment barrier. Furthermore, one train of SFP cooling
remained in operation, the rate of SFP temperature rise was low (~2 °F/hour), and
additional diverse compensatory methods remained available to limit SFP temperature
rise. This finding was assigned a cross cutting aspect associated with the procedure
adherence element of the human performance area because the licensee failed to
correctly execute step 6.3.2 of procedure 3-PMI-072.6 (H.8).
17
Enforcement: Technical Specification 6.8.1 requires that procedures required by the
licensees Quality Assurance Topical Report (QATR) be established, implemented, and
maintained. The QATR includes procedures listed in Appendix A of NRC Regulatory
Guide 1.33, Revision 2, dated February 1978, including procedures for calibrations. The
licensee implements TS 6.8.1 requirements, in part, using procedure 3-PMI-072.6,
Steam Dump to Atmosphere Control Loop Calibration. Step 6.3.2 of procedure
3-PMI-072.6, requires that a jumper be installed in reactor operator console 3C02.
Contrary to this requirement, on November 4, 2015, at 2112 hours0.0244 days <br />0.587 hours <br />0.00349 weeks <br />8.03616e-4 months <br />, a maintenance
technician mistakenly installed a jumper in reactor operator console 3C04. This action
resulted in actuation of a 3B 4160 V vital bus lockout circuit causing loss of power to the
B train of U3 SFP cooling. The licensee took immediate corrective action to remove the
jumper. This violation is being treated as an NCV, consistent with Section 2.3.2 of the
Enforcement Policy, because it was of very low safety significance and was entered in
the licensees CAP as AR 02088911 and 02088914. (NCV 05000250/2015004-01,
Failure to correctly follow procedure 3-PMI-072.6, Steam Dump to Atmosphere Control
Loop Calibration.)
1R22 Surveillance Testing (IP 71111.22)
a. Inspection Scope
The inspectors either reviewed or observed the following five surveillance tests to verify
that the tests met the TS requirements, the UFSAR description, the licensees
procedural requirements, and demonstrated that 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 status required for the system to perform its
safety function. The inspectors verified that any surveillance deficiencies were
documented in the licensees CAP. This inspection constitutes two surveillance test
samples, one inservice testing (IST) sample, and two containment isolation valve leak
test samples. The inspectors reviewed the following tests:
Surveillance Test:
- 0-OSP-059.13, U4 Flux Map
- 3-OSP-072.5, U3 Main Steam Safey Valve Setpoint Verification
In-Service Tests:
- 3-OSP-206.1, Component Cooling Water MOV-3-1418 Valve Test (IST)
Containment Isolation Valve Test:
- 3-OSP-051.5, U3 Local Leak Rate Test, Penetration 8 CV-3-951
- 3-OSP-051.5, U3 Local Leak Rate Test, Penetration 14 CV-3-204
b. Findings
No findings were identified.
18
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (IP 71114.06)
.1 Emergency Preparedness Drill
a. Inspection Scope
On October 8, 2015, the inspectors observed an emergency preparedness drill and the
performance of the licensees emergency response organization. The drill included a
simulated fire in the U4 laydown area, a LOCA inside containment, followed by a RHR
pump seal failure and radiological release to the environment. The fire, lasting greater
than 15 minutes, required an unusual event emergency declaration and notification to
state and local county officials and the NRC per licensee procedure 0-EPIP-20101,
Duties of the Emergency Coordinator. The scenario progressed to a loss of two RCS
barriers with the loss or potential loss of a third barrier requiring a general emergency
declaration and an additional notification. The inspectors observed the crew in the plant
simulator, including simulated implementation of emergency procedures. The inspectors
observed the emergency response organization staff in the control room simulator and
technical support center while they implemented the event classification guidelines and
emergency response procedures. The inspectors determined that the emergency
classification and notifications were made in accordance with the licensee emergency
plan implementing procedure 0-EPIP-20101. The inspectors 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 licensees CAP. This inspection constitutes one sample.
b. Findings
No findings were identified.
2. RADIATION SAFETY (RS)
Cornerstones: Public Radiation Safety and Occupational Radiaition Safety
2RS1 Radiological Hazard Assessment and Exposure Controls (IP 71124.01)
a. Inspection Scope
Hazard Assessment and Instructions to Workers. During facility tours, the inspectors
directly observed labeling of radioactive material and postings for radiation areas, high
radiation areas, and airborne radioactivity areas established within the radiologically
controlled area (RCA) of the U3 containment building, auxiliary building, the Independent
Spent Fuel Storage Installation (ISFSI), and radioactive waste processing and storage
locations. The inspectors independently measured radiation dose rates or directly
observed conduct of licensee radiation surveys for selected RCA areas. The inspectors
reviewed survey records for several plant areas including surveys for alpha emitters,
airborne radioactivity, gamma surveys with a range of dose rate gradients, and pre-job
surveys for upcoming tasks. The inspectors also discussed changes to plant operations
that could contribute to changing radiological conditions since the last inspection. For
selected outage jobs, the inspectors attended pre-job briefings and reviewed Radiation
19
Work Permit (RWP) details to assess communication of radiological control
requirements and current radiological conditions to workers.
Hazard Control and Work Practices. The inspectors evaluated access barrier
effectiveness for selected Locked High Radiation Area (LHRA) locations and discussed
changes to procedural guidance for LHRA and Very High Radiation Area controls with
Radiation Protection (RP) supervisors. The inspectors observed and evaluated controls
for the storage of irradiated material within the SFP. Established radiological controls
(including airborne controls) were evaluated for selected U3 RFO 28 (U3R28) tasks
including RCP seal replacements, reactor cavity decontamination and reactor sump
demobilization activities. In addition, the inspectors reviewed licensee controls for areas
where dose rates could change significantly as a result of plant shutdown and refueling
operations.
Through direct observations and interviews with licensee staff, the inspectors evaluated
occupational workers adherence to selected RWPs and RP technician proficiency in
providing job coverage. Electronic dosimeter (ED) alarm set points and worker stay
times were evaluated against area radiation survey results for selected U3 RFO jobs,
including the reactor sump demobilization and reactor cavity decontamination. The
inspectors discussed the use of personnel dosimetry (extremity dosimetry and
multibadging in high dose rate gradients) with RP staff. The inspectors also evaluated
worker response to dose and dose rate alarms during selected work activities.
Control of Radioactive Material. The inspectors observed surveys of material and
personnel being released from the RCA using small article monitor (SAM), personnel
contamination monitor (PCM), and portal monitor instruments. As part of IP 71124.05,
the inspectors reviewed the last two calibration records for selected release point survey
instruments and discussed equipment sensitivity, alarm setpoints, and release program
guidance with licensee staff. The inspectors reviewed records of leak tests on selected
sealed sources and discussed nationally tracked source transactions with licensee staff.
Problem Identification and Resolution. The inspectors reviewed CAP documents
associated with radiological hazard assessment and exposure control. The inspectors
evaluated the licensees ability to identify and resolve the issues in accordance with
licensee procedures. The inspectors also reviewed recent self-assessment results.
Radiation protection activities were evaluated against the requirements of the UFSAR
Section 11; TS Sections 6.8 Procedures and Programs and 6.12 High Radiation Area;
10 CFR Parts 19 and 20; Regulatory Guide 8.38, Control of Access to High and Very
High Radiation Areas in Nuclear Power Plants; and approved licensee procedures.
Licensee programs for monitoring materials and personnel released from the RCA were
evaluated against 10 CFR Part 20 and IE Circular 81-07, Control of Radioactively
Contaminated Material. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
20
2RS2 Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
a. Inspection Scope
Work Planning and Exposure Tracking. The inspectors reviewed work activities and their
collective exposure estimates for U3 RFO. The inspectors reviewed ALARA planning
packages for the following high collective exposure tasks: SG cleaning (including bundle
flushing, sludge lancing, and foreign object search and retrieval); refueling activities;
RCP seal replacement; bottom mounted inspection, and; various valve work. For the
selected tasks, the inspectors reviewed established dose goals and discussed
assumptions regarding the bases for the current estimates with responsible ALARA
planners. The inspectors evaluated the incorporation of exposure reduction initiatives
and operating experience. Adjustments made to planned doses were also reviewed,
along with the basis of those adjustments. Post-job reviews from both the current and
previous RFO were assessed. Where applicable, the inspectors discussed changes to
established estimates with ALARA planners and evaluated them against work scope
changes or unanticipated elevated dose rates.
Source Term Reduction and Control. The inspectors reviewed the collective exposure
three-year rolling average from 2012-2014 and reviewed historical collective exposure
trends. The inspectors evaluated historical dose rate trends and compared them to
current data.
Radiation Worker Performance. In conjunction with IP 71124.01, radiation worker
performance was evaluated during several tasks both within containment and the
auxiliary building. The inspectors specifically evaluated both the use of ALARA briefings
and remote technologies, including teledosimetry and remote visual monitoring, to
reduce dose.
Problem Identification and Resolution. The inspectors reviewed and discussed selected
CAP documents associated with ALARA program implementation. The inspectors
evaluated the licensees ability to identify and resolve the issues in accordance with
licensee procedures. The inspectors also reviewed recent self-assessment results.
ALARA program activities were evaluated against the requirements of the UFSAR
Section 11, applicable TS Sections 6.8 and 6.12, 10 CFR Part 20, and approved
licensee procedure. Records reviewed are listed in the Attachment.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (IP 71124.03)
a. Inspection Scope
Engineering Controls: Licensee engineering controls used to control and mitigate
airborne radioactivity were reviewed and discussed. The inspectors evaluated selected
U3 engineering controls including temporary High Efficiency Particulate Air (HEPA)
filtration systems for selected outage tasks with the potential for generating airborne
21
activity conditions. The evaluations included procedural guidance, operability testing,
and established configurations during specific outage tasks. In addition, plant guidance
and its implementation for the monitoring of potential airborne beta-gamma and alpha-
emitting radionuclides for outage tasks associated with refueling activities, head
disassembly, and valve maintenance were reviewed and discussed with cognizant
licensee representatives.
Use of Respiratory Protection Devices: Program guidance for issuance and use of
respiratory protection devices were reviewed and discussed with responsible licensee
representatives. The inspectors reviewed Total Effective Dose Equivalent (TEDE)
ALARA evaluations conducted for select U3 outage tasks. Use of respiratory protective
equipment was evaluated for selected workers involved in U3 outage activities. The
inspectors toured selected onsite compressors available for supplying breathing air for
current outage activities and reviewed Grade D or greater air certification for permanent
and temporary on-site compressors used for supplied-line breathing air and self-
contained breathing apparatus (SCBA) bottle fill-station activities. Training, fit testing,
and medical qualifications for selected RP, maintenance, and operations using
respiratory protection for outage activities were reviewed and discussed with cognizant
licensee representatives.
Self-Contained Breathing Apparatus for Emergency Use: The inspectors reviewed
current status, operability and availability of select respiratory and SCBA equipment
maintained within the U3 and U4 control rooms, B5B lockers, and U3 and U4 reactor
auxiliary building locations. Maintenance activities for selected respiratory protective
equipment (e.g., compressed gas cylinders, regulators, valves, and hose couplings), by
certified vendor technicians were reviewed for selected SCBA units. Training, fit testing,
and medical qualifications for selected RP, maintenance, and operations staff assigned
Emergency Response Organization duties were reviewed and discussed with cognizant
licensee representatives. For selected U3 and U4 control room operators, the
inspectors discussed and reviewed annual hands-on SCBA training activities, including
donning, doffing, and functionally checking SCBA equipment, bottle change out, and
also reviewed availability of corrective lens, as applicable, for on-shift personnel.
Problem Identification and Resolution: The inspectors reviewed selected CAP
documents within the area of radiological airborne controls and respiratory protection
activities. The inspectors evaluated the licensees ability to identify and resolve the
issues in accordance with licensee procedures PI-AA-104-1000, Corrective Action, Rev.
6, and 0-ADM-533, Corrective Action Program Guidance, Rev. 14. The inspectors also
evaluated the scope of the licensees internal audit program and reviewed recent
assessment results. Specific licensee CAP documents reviewed for airborne
radionuclide concentration monitoring and mitigation are listed in the Attachment.
Radiation Protection program activities associated with airborne radioactivity monitoring
and controls were evaluated against details and requirements documented in the
UFSAR, TS Section 3/4.9.9, Containment Ventilation System, 3/4.9.13, Radiation
Monitoring, and 6.8.1, Procedures and Programs; 10 CFR Part 20, and also approved
licensee procedures. Documents reviewed are listed in the Attachment.
The inspectors completed all specified line-items detailed in IP 71124.03.
22
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment (IP 71124.04)
a. Inspection Scope
The inspector evaluated current RP program guidance and its implementation for
monitoring and assessing occupational workers internal and external radiation
exposure. The review included quality assurance activities, results, and responses to
identified issues; and individual dose results for selected occupational workers.
External Dosimetry: The inspector reviewed and discussed RP program guidance for
monitoring external and internal radiation exposures of occupational workers. The
inspector verified National Voluntary Laboratory Accreditation Program certification data
and discussed program guidance for storage, processing and results for dosimeters
currently in use. The inspector also reviewed and discussed the comparison between
ED and thermoluminescent dosimeter data.
Internal Dosimetry: Program guidance, instrument detection capabilities, and select
results for assessing internally deposited radionuclides were reviewed and discussed in
detail. The inspector evaluated licensee follow-up in vivo monitoring results and dose
assignment for three workers involved in contamination events having the potential for
internal deposition of radioactive material. In addition, the current licensee and contract
vendor laboratory analysis capabilities for the collection and analysis of in vitro samples
were reviewed and discussed in detail.
Special Dosimetric Situations: The inspector reviewed monitoring conducted and results
for two declared pregnant workers since the last inspection. The methodology and
results of monitoring occupational workers within non-uniform external dose fields and
assignment of effective dose equivalent results were discussed in detail. In addition, the
adequacy of dosimetry program guidance and its implementation for shallow dose
assessments and supporting calculations for an individual involved in a select
contamination event were evaluated. Neutron monitoring guidance and implementation
for select at power containment entries were reviewed and discussed. RP staff
proficiency involved in conducting skin dose assessments, neutron monitoring, and
whole body counter (WBC) operations were evaluated through review and discussions
of completed records and supporting data.
Problem Identification and Resolution: The inspectors reviewed and discussed selected
CAP documents associated with occupational dose assessment. The reviewed items
included ARs, self-assessments, and quality assurance audit documents. The
inspectors evaluated the licensees ability to identify, characterize, prioritize, and resolve
the identified issues in accordance with licensee procedures PI-AA-104-1000, Corrective
Action, Rev. 6, and 0-ADM-533, Corrective Action Program Guidance, Rev. 14.
Radiation protection program occupational dose assessment guidance and activities
were evaluated against the requirements of the UFSAR Section 11; TS Sections 6.8.1,
Procedures and Programs, and 6.12, High Radiation Area; 10 CFR Parts 19 and 20; and
approved licensee procedures. Records reviewed are listed in the Attachment.
23
The inspectors completed all specified line-items detailed in IP 71124.04.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation (IP 71124.05)
a. Inspection Scope
Radiation Monitoring Instrumentation: During tours of the auxiliary building, turbine
building, SFP areas, and RCA exit point, the inspectors observed installed radiation
detection equipment including the following instrument types: area radiation monitors
(ARMs), airborne monitors, liquid and gaseous effluent monitors, PCMs, SAMs, and
portal monitors. The inspectors observed the physical location of the components, and
noted the material condition.
In addition to equipment walkdowns, the inspectors observed source checks and alarm
setpoint testing of various portable and fixed detection instruments, including ion
chambers, telepoles, PCMs, SAMs, and portal monitors. For the portable instruments,
the inspectors observed the use of a high-range check source and reviewed records of
periodic output value testing for a calibration source. The inspectors reviewed recent
calibration records and evaluated alarm setpoint values for selected ARMs, PCMs, portal
monitors, SAMs, effluent monitors, and a WBC. This included a sampling of instruments
used for post-accident monitoring such as containment high-range ARMs and effluent
monitor high-range noble gas and iodine channels. Radioactive sources used to
calibrate selected ARMs and effluent monitors were evaluated for traceability to national
standards. Calibration stickers on portable survey instruments and air samplers were
noted during inspection of storage areas for ready-to-use equipment. The inspectors
also reviewed countroom quality assurance records for gamma ray spectrometry
equipment and liquid scintillation detectors.
Problem Identification and Resolution: Selected licensee CAP documents associated
with instrumentation were reviewed and assessed. The inspectors evaluated the
licensees ability to identify and resolve the identified issues in accordance with licensee
procedures. The inspectors also reviewed recent self-assessment results.
Operability and reliability of selected radiation detection instruments were reviewed
against details documented in the following: 10 CFR Part 20; NUREG-0737,
Clarification of Three Mile Island Action Plan Requirements; TS Section 3; UFSAR
Chapters 11; and applicable licensee procedures. Documents reviewed during the
inspection are listed in the Attachment.
b. Findings
No findings were identified.
24
4OA1 Performance Indicator Verification (IP 71151)
.1 Barrier Integrity Cornerstone
a. Inspection Scope
The inspectors reviewed licensee submittals for the U3 and U4 Performance Indicators
(PI) listed below for the period October 1, 2014, through September 30, 2015, 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, CRs, 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 PI data collection, evaluation,
and distribution. This inspection constitutes four samples.
b. Findings
No findings were identified.
.2 Radiation Safety Cornerstones
a. Inspection Scope
Occupational Radiation Safety Cornerstone: The inspectors reviewed recent
Occupational Exposure Control Effectiveness PI results for the occupational radiation
safety cornerstone, and reviewed PI records generated from October 2014 through
October 2015. For the assessment period, the inspectors reviewed ED alarm logs and
selected CRs related to controls for exposure significant areas. Documents reviewed
are listed in the Attachment.
Public Radiation Safety Cornerstone: The inspectors reviewed recent radiological
control effluent release occurrences PI results for the public radiation safety cornerstone,
and reviewed PI records generated from October 2014 through October 2015. For the
assessment period, the inspectors reviewed cumulative and projected doses to the
public contained in liquid and gaseous release permits and CRs related to radiological
effluent TS/Offsite Dose Calculation Manual issues. Documents reviewed are listed in
the Attachment.
b. Findings
No findings were identified.
25
4OA2 Problem Identification and Resolution (IP 71152)
.1 Daily Review
a. Inspection Scope
As required by IP 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 CAP. 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: Missed Fire Watch Tours
a. Inspection Scope
The inspectors selected AR 02056905, Missed Fire Watch Tours for a more in-depth
review of the circumstances and the corrective actions that followed. The AR report was
reviewed to ensure that an appropriate evaluation was performed and corrective actions
were specified and prioritized in accordance with the licensees program. Other
attributes checked included disposition of operability and resolution of the problem,
including cause determination, past operability determination, and corrective actions.
The inspectors interviewed plant personnel and evaluated the CR in accordance with the
requirements of the licensees corrective actions process as specified in licensees
procedures PI-AA-204, Condition Identification and Screening Process, and PI-AA-205,
Condition Evaluation and Corrective Action. This inspection constitutes one sample.
b. Findings and Observations
No inspector findings were identified. A licensee-identified violation of very low safety
significance (Green) is documented in Section 4OA7 of this report. The licensee
identified that employees failed to perform hourly required fire watch roves. The
inspectors noted that the licensees evaluation for the missed fire watch roves concluded
that there was no violation of any TS requirement since TS do not require fire watches
for degraded fire protection features. The licensee concluded that the missed roves
represented a reduction in the effectiveness of the Fire Protection Program (FPP) and
the loss of a defense-in-depth feature.
The licensee determined the root cause of the event to be that operations management
was not engaged with the fire watch program. The licensee also determined that a
direct cause was that fire watch employees willfully chose non-compliance with fire
protection requirements. Immediate corrective actions for this event included the
immediate denial of site access for the individuals who failed to conduct the roves. The
licensee also updated the fire protection procedure, 0-ADM-016.4, to include Operations
26
Management Responsibilities and Oversight that requires observations, audits, and
assessments to ensure regulatory requirements are met. The licensee also conducted
an extent of condition and determined that no other missed tours were present in other
departments based on data collected and security access logs.
.3 Semi-Annual Trend
a. Inspection Scope
The inspectors performed a review of the licensees records including ARs, CAP health
reports, apparent cause evaluation reports, and various corrective action review board
reports to asses an adverse trend in the performance of reactor protection transmitters.
The inspectors reviewed licensee AR 02088175, which identified an adverse trend in
protection transmitter calibration check results. The inspectors evaluated the
effectiveness of the licensees corrective actions and the significance of the problems,
including attributes such as accurate documentation, reportability, evaluation, corrective
actions, and problem resolution. This inspection constitutes one sample.
b. Findings and Observations
No inspector findings were identified. The licensee noted that the transmitters in
question, Rosemount pressure transmitters, are expected to drift a slight amount. The
licensee also noted that both the transmitter age and replacement of components tended
to exacerbate the transmitter drift through the calibration cycle. The licensee concluded
that even with the noted transmitter drift, the transmitters still performed satisfactorily
and were within TS compliance. The inspectors did not identify any additional trends not
observed by the licensees trending activities.
4OA5 Other Activities
.1 Independent Spent Fuel Storage Facility Walk down (IP 60855.1)
a. Inspection Scope
On December 17, 2015, the inspector conducted a walk down of the ISFSI protected
area per IP 60855.1, Operation of an ISFSI at Operating Plants. The inspectors
observed each cask building temperature indicator and passive ventilation system to be
free of any obstruction, allowing natural draft convection decay heat removal through the
air inlet and air outlet openings. The inspectors observed associated cask building
structures to be structurally intact and radiation protection access and security controls
to the ISFSI area to be satisfactory.
b. Findings
No findings were identified.
27
4OA6 Meetings
The resident inspectors presented the inspection results to Mr. Tom Summers and other
members of licensee management on January 15, 2016. 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.
4OA7 Licensee-identified Violation
The following violation of very low safety significance (Green) was identified by the
licensee and is a violation of NRC requirements which meets the criteria of the NRC
Enforcement Policy for being dispositioned as an NCV.
10 CFR 50.48 states that each operating nuclear power plant must have a fire protection
plan that satisfies Criterion 3 of Appendix A of this part. Turkey Point Renewed
Operating License condition D, for Units 3 and 4, states that the licensee shall
implement and maintain in effect all provisions of the approved FPP as described in the
UFSAR Appendix 9.6A. The approved FPP is implemented, in part, by 0-ADM-016, Fire
Protection Program, as referenced in Section 7.2 of UFSAR Appendix 9.6A. Section 5.6
of 0-ADM-016 requires that, for non-functional post-fire safe shutdown components,
engineering evaluations should identify appropriate compensatory actions, including
hourly fire roves. Contrary to the above, between May 1st, 2014, and April 23rd, 2015,
hourly fire watch patrols were not conducted on numerous occasions in fire zones that
required regular hourly tours due to fire protection equipment impairment. The failure to
perform the fire watch tours did not cause the inoperability of any equipment but resulted
in the loss of a defense-in-depth feature for fire detection in fire zones affected by an
impaired or non-functional fire safety component or feature. This violation was
associated with the Mitigating Systems Cornerstone and affected the cornerstone
objective of ensuring the availability, reliability and capability of the systems that respond
to initiating events to prevent undesirable consequences. The inspectors determined the
finding to be of very low safety significance (Green) after performing a detailed risk
evaluation in accordance with Manual Chapter 0609, Appendix A, because the missed
fire watch tours reflected a low degradation of the Fire Prevention and Administrative
Controls FPP element in that other area fire protection defense-in-depth features such
as automatic fire detection (smoke detectors), automatic fire suppression capability
(sprinklers), manual suppression capability (fire brigade), and safe shutdown capability
from the main control room were still available. The licensee entered this violation into
their CAP as AR 02056905.
ATTACHMENT: SUPPLEMENTARY INFORMATION
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel:
F. Banks, Quality Manager
C. Cashwell, Training Manager
P. Czaya, Licensing
C. Domingos, Plant General Manager
T. Eck, Security Manager
M. Guth, Licensing Manager
O. Hanek, Licensing Engineer
A. Katz, Projects Manager
G. Melin, Operations Manager
S. Mihalakea, Licensing
K. Ohara, Emergency Preparedness Manager
J. Pallin, Engineering Director
D. Sluszka, Work Controls Manager
B. Stamp, Operations Director
T. Summers, Site Vice-President
D. Barrow, Maintenance Director
R. Hess, General Operations Training Supervisor
M. Wilson, Operations Training Supervisor
NRC Personnel:
B. Bishop, Senior Project Engineer
A. Beaston, Project Engineer
A. Vargas, Project Engineer
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000251/2015004-01 NCV Failure to correctly follow procedure
3-PMI-072.6, Steam Dump to
Atmosphere Control Loop Calibration.
(Section 1R20)
Attachment
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather
0-ONOP-103.3, Severe Weather Preparations
Section 1R04: Equipment Alignment
3-NOP-022, Emergency Diesel Generator Fuel Oil System
3-NOP-023, Emergency Diesel Generator
4-NOP-022, Emergency Diesel Generator Fuel Oil System
4-NOP-023, Emergency Diesel Generator
3-OP-201, Filling/Draining the Refueling Cavity and the SFP Transfer Canal
4-OP-201, Filling/Draining the Refueling Cavity and the SFP Transfer Canal
P&ID 5613-M-3022, Emergency Diesel Engine and Oil System
P&ID 5613-M-3062, Safety Injection System
P&ID 5614-M-3062, Safety Injection System
Section 1R05: Fire Protection
0-ONOP-016.10, Pre-Fire Plan Guidelines and Safe Shutdown Manual Actions
Section 1R08: Inservice Inspection Activities
Procedures:
0-ADM-537, Boric Acid Corrosion Control Program, Rev. 11
3-OSP-045.1, ASME Section XI Quality Group A Bolting Examination, Rev. 2
MA-AA-1000, Plant Leak Management Procedure, Rev. 6
NDE 4.15, Visual Examination (VE) ASME Section XI Code Case N-722-1 and N-729-1, Rev. 4
NDE 4.2, Visual Examination VT-2 Conducted During System Pressure Tests, Rev. 10
NDE 4.3, Visual Examination VT-3, Rev. 12
NDE 5.16, Ultrasonic Examination Technique for the Detection of Cracking in Feedwater Piping,
Rev. 10
NDE 5.18, Ultrasonic Thickness Measurement, Rev. 8
Calculations:
EC 284178, Review of Degradation and Operational Assessments at End-of-Cycle 27 for
Turkey Point Unit 3
Work Orders/Work Requests:
WO 4029647301, Valve 3-298C Replace Valve
WO 4030098001, Repair of PZR HTR Sleeve #11
CAP Documents:
AR 1771920, Audit shows no self-assessments performed on the welding control program
AR 1858601, BOP, ISI and FAC Quick Hit Self-Assessment for 2012 Outages (SL-1-24, SL-2-
AR 2086224, Inconsistent gaps were identified between CRDM/RPI plates and the seismic plate
bumper
AR 2086933, Debris inside spring hanger
Miscellaneous Documents:
2012 Welding May 2012 Quality Assurance Assessment
3
AES 13118520-2Q-3, Condition Monitoring and Operational Assessment for the Turkey Point
Unit 3 Steam Generators Based on Eddy Current Examination End of Cycle 26, March 2014
Calibration Data Sheet for UT Instruments SN: 136P1106C031381, K07639
Calibration Data Sheet No.: 5.16-002
Certificate of Conformity NDE Probe SN: SE1110
Certificate of Personnel Qualification ID No.: D0360, C2231, C6756
ENG-CSI -2.3, Steam Generator Integrity Program Administration, Rev. 32
ENG-CSI-2.2, Planning and Reporting Results of Steam Generator Tubing Examinations,
Rev. 44
ER-AP-116, Boric Acid Corrosion Control, Rev. 0
Focused Self-Assessment Report 1837244, Boric Acid Corrosion Control Program
Krautkramer Transducer Certificate of Conformity SN: 012Y39
Personnel Certification Statement: T. Thomas, B. Thompson, M. Smith, and M. Johnson
Quick Hit Assessment Report 1892958, Boric Acid Corrosion Control Leak Evaluations
Ultrasonic Instrument Calibration Data Record and Certification SN: 01R6B7
Visual Examination Evaluation Sheet: 4.3.001
Visual Examination Record Data Sheets: #4.3-008 and #4.3-009
Section 1R11: Licensed Operator Requalification Process
0-ADM-211, Emergency and Off-Normal Operating Procedure Usage
TR-AA-230-1007, Conduct of Simulator Training and Evaluation
TR-AA-220-1004, Licensed Operator Continuing Training Annual Operating and Biennial
Written Exams, Revision 1
TR-AA-230-1004, SAT Implementation, Revision 5
PTN OPS LOC15 SRO EXM1, Administered 10/06/2015
PTN OPS LOC15 SRO EXM2, Administered 11/29/2015
Section 1R15: Operability Evaluations
0-ADM-213, Technical Specification Related Equipment Out of Service Logbook
0-ADM-226, Operability Screening and Condition Reports
EN-AA-203-1001, Operability Determinations and Assessments
Section 1R18: Plant Modifications
5610-M-410-40, NX Seal Assembly
SPEC-C-021, Turkey Point Units 3 & 4 Tubing and Tubing Supports
Section 1R19: Post Maintenance Testing
0-ADM-737, Post Maintenance Testing
MA-AA-203-1000, Maintenance Functional Testing
Section 1R20: Refueling and Other Outage Activities
0-ADM-009, Containment Closeout Inspection
MA-AA-101-1000, Foreign Material Exclusion Procedure
0-ADM-556, Fuel Assembly and Insert Shuffles
Section 2RS1: Radiological Hazard Assessment and Exposure Controls
Procedures, Guidance Documents, and Manuals
0-HPA-001, Radiation Work Permit Initiation and Termination, Rev. 4
4
RP-AA-102-1000, Alpha Monitoring, Rev. 2
RP-AA-103-1006, Conduct of Radiological Diving Operations, Rev. 1
RP-AA-107, Radioactive Material Control Program, Rev. 0
RP-AA-107-1003, Unconditional and Conditional Release of Material, Rev. 1
RP-SR-103-1001, Posting Requirements for Radiological Hazards, Rev. 2
RP-SR-103-1002, High Radiation Area Controls, Rev. 3
RP-SR-103-1008, Remote Monitoring, Rev. 5
0-HPS-025.2, Posting and Survey Requirements for Fuel Movement, Rev. 4B
0-HPS-027.1, Work Controls in Hot Particle Areas, Rev. 0
0-HPS-106, Survey & Posting Guidelines for Plant Evolutions, Rev. 5
Records and Data Reviewed
2015 NSTS Annual Inventory Reconciliation, Dated 01/15/15
Radioactive Source Leak Test Results, Dated 10/15/2015
Air Calculation Sheet, (ACS) A/S Log Ref No. P1-15-1023, U3 RCB REACTOR Sump During
Demob, Dated 11/17/2015
ACS, A/S Log Ref No. P0-15-1011, U3 RCB 30 6 Routine, Dated 11/17/2015
ACS, A/S Log Ref No. P0-15-1013, Vac Shack During Tool & Respirator Decon, Dated
11/17/2015
ACS, A/S Log Ref No. P0-15-1021, U3 RCB 58 By REACTOR Head Stand, Dated 11/17/2015
ACS, A/S Log Ref No. P0-15-1025, U3 RCB Upper REACTOR Cavity, Dated 11/17/2015
PTN-M-20150604-3, U4 10 Foot Pipeway, Dated 06/04/2015
PTN-M-20150930-2, U4 10 Foot Pipeway, Dated 09/30/2015
PTN-M-20150914-1, U3 10 Foot Pipeway, Dated 09/14/2015
PTN-M-20150930-3, U3 10 Foot Pipeway, Dated 09/30/2015
PTN-M-20150711-25, U4 B RHR Pump Room, Dated 07/11/2015
PTN-M-20151010-2, U4 B RHR Pump Room, Dated 10/10/2015
PTN-M-20150918-5, U4 Charging Pump Room, Dated 09/18/2015
PTN-M-20151011-7, U4 Charging Pump Room, Dated 10/11/2015
PTN-M-20141120-6, Unit 4 B RHR Dose Alarm Follow-up, Dated 11/20/2014
PTN-M-20151020-6, Aux Bldg 3-240 Valve, Dated 10/20/2015
PTN-M-20151021-25, U3 Containment 14 ft elev Inside Biowall, Dated 10/21/2015
PTN-M-20151022-15, U3 Containment 14 ft elev Inside Biowall, Dated 10/22/2015
PTN-M-20151027-30, U3 Containment 14 ft elev Inside Biowall, Dated 10/27/2015
PTN-M-20150311-6, ISFSI Pad Semi-Annual, Dated 03/11/2015
PTN-M- 20150918-6, ISFSI Pad Semi-Annual, Dated 09/18/2015
RWP Number (No.) 15-3000 U3R28 Initial Containment Entry and when Containment is posted
as a Locked High Radiation Area, Rev. 0
RWP No. 15-3008, Containment General Outage Maintenance (Bulk Work), Rev 0
RWP No. 15-3013, Regenerative Heat Exchanger Room Work (Bulk Work), Rev. 0
RWP No. 15-3014, Reactor Sump - Non Legacy Boric Acid Work, Rev. 0
RWP No. 15-3018, RCP Work (Bulk Work), Rev. 0
RWP No. 15-3205, Outage Locked High Radiation Area Work, Rev. 0
CAP Documents
Nuclear Oversight Report # PTN-14-002, Radiation Protection and Radwaste, Dated
08/18/2014
AR 01997251
5
AR 02008430
AR 02020231
AR 02029276
AR 02033644
AR 02044742
AR 02058970
Section 2RS2: ALARA
Procedures and Guidance Documents
0-HPA-001, Radiation Work Permit Initiation and Termination, Rev. 04
0-HPA-072, Installation, Control, and Removal of Permanent and Temporary Shielding, Rev. 03
RP-AA-104, ALARA Program, Rev. 04
RP-AA-104-100, ALARA Implementing Procedure, Rev. 06
RP-AA-104-2003, Five Year ALARA Plan Template, Rev. 01
Primary Strategic Water Chemistry Plan, FPL PTN Units 3 & 4, 08/15/2013
Records and Data Reviewed
10 CFR Applicability Determination Form, TSR 15-03, Temporary Lead Shielding Installation on
Containment 14 Cavity Drain Valves, 10/18/15
ALARA Review No. 2015-006, U3R28 Refueling Activities, Including Ultra-Sonic Fuel Cleaning,
Rev. 0
ALARA Review No. 2015-007, Generator Bundle Flush, Sludge Lance, and FOSAR, Rev. 0
ALARA Review No. 2015-008, U3 A, B, C RCP Seal Replacement - Fukushima Upgrade - A
Motor Replacement, and PMs. Rev. 0
ALARA Review No. 2015-010, U3 BMI (Bottom Mounted Inspection), Rev. 0
ALARA Review No. 2015-013, PCV-3-455A and PCV-3-455B, Rev. 0
Job-In-Progress Review No. 2015-007, S/G secondary sludge lancing and FOSAR, Rev. 0
Job-In-Progress Review No. 2015-008, U3 A,B,C RCP Seal Replacement, Rev. 0
Job-In-Progress Review No. 2015-010, U3 BMI, Rev. 0
PTN ALARA Review Board Meeting Minutes, 03/23/15, 06/29/15, 09/04/15
PTN Nuclear Oversight Report #PTN-14-002, Subject: Radiological Protection and Radwaste,
05/09/14
PTN Quick Hit Assessment Report #1938751/1927754, Self Assessment of ALARA, 04/23/14
PTN-3-R28 Refueling Outage 0500 Turnover 11/03/15, 11/05/15
PTN-3-R28 Refueling Outage 1700 Turnover 11/12/15
PTN 5-Year ALARA Plan 2015-2020
RP Survey #PTN-M-20151029-34, Unit 3 Regenerative Heat Exchangers 14, 10/29/2015
RP Survey #PTN-M-20151029-27, Unit 3 Regenerative Heat Exchangers 14, 10/28/2015
RP Survey #PTN-M-20151028-36, U3 Containment 14 Inside Biowall, 10/28/2015
RP Survey #PTN-M-20151026-22, U3 Containment 14 Inside Biowall, 10/26/2015
RP Survey #PTN-M-20151020-19, U3 Containment 14 Inside Biowall, 10/20/2015
6
Temporary Shielding Request (TSR) No. 2015-03, U3 RCB, 14 Elevation, Cavity Drain Valves,
07/20/2015
TSR No. 2015-17, U3 RCB, 14 Regen. Heat Exchanger Room, 07/22/2015
CAP Documents
AR 01997991
AR 02072141
AR 02043416
Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation
Procedures and Guidance Documents
0-ADM-041, PTN Respiratory Protection Plan, Rev. 9
0-ADM-533, Corrective Action Program Guidance, Rev. 14
0-ADM-605, Control of Radioactive Material, Rev. 4
0-HPA-028, High Efficiency Particulate Air (HEPA) Filtration Ventilation Systems in the
Radiation Controlled Area, Rev. 2A
0-HPS-062.2, Use of the Self-Contained Breathing Apparatus, Rev.1
0-HPS-063.2, Maintenance and Accountability of Respiratory Protective Equipment, Rev. 7
0-HPS-063.4, Selection and Issuance of Respiratory Protection Equipment, Rev. 3
0-HPS-065.2, Operation and Maintenance of the Respirator Fit-Test System, Rev. 4
0-HPS-090, Inventory of Radiation Protection Emergency Equipment, Rev. 2
PI-AA-104-1000, Corrective Action, Rev. 6
RP-AA-102-1000, Alpha Monitoring, Rev. 2
RP-TP-102-1001, Radiological Air Sample Assay, Rev. 4
Records and Data Reviewed
Air Sample Log, for the period 10/1 thru 11/5/2015
Air Calculation Sheet and Gamma Spectroscopy Analysis, Air Sample # P1-I1-15-0405, U-3
RCB Lower Reactor Cavity, 10/26/2015
Certificate of Testing, PortaCount Bench 2, S/N 8030111513, 07/08/2015; and S/N
8030111601, 06/10/2015
HP-90, SCBA Inventory, Inspection, and Repair Records, September and October 2015
HP-93Respirator, Inventory, Inspection, and Repair Record, September and October 2015
HP-93.1, SCBA Air Bottle Inspection and Inventory Records, September and October 2015
HP-93.6, Air Quality Certificate, Bauer Air Compressor, Dated 08/05/2015, and 05/11/2015
List of SCBA Qualified Operations, Maintenance, and Health Physics Personnel, 10/01/2015
Scott Authorized Service Center Certificates for selected vendor employees, Dated 08/22/2014
Scott PosiChek3, Visual/Functional Test Results, Regulators: 89200090, Dated 09/22/2015;
89200100, Dated 09/23/2015; 89200101, Dated 09/22/2015; 89200109, Dated
09/22/2015; and 89200149, Dated 09/23/2015;
Unitech Service Group, DOP Test Results, HEPA Unit Type, Portable, HEPA S/N 018, Dated
06/23/2015; S/N 033, Dated 06/23/2015; and S/N 040, Dated 06/24/2015
Vendor Laboratory Compressed Air/Gas Quality Testing Report Results, Bauer Air Compressor,
Dated 08/05/2015, and 07/31/2015
7
CAP Documents
Quick Hit/Department Assessment Report, 2014 Respiratory Protection Program Annual
Review (AR 2014222), 04/07/2015
AR 01845706
AR 01889000
AR 01964422
AR 01938504
AR 02020932
Section 2RS4: Occupational Dose Assessment
Procedures and Guidance Documents
0-HPA-030, Personnel Monitoring of External Dose, Rev. 3
0-HPS-023, Environmental Radiation Monitoring, Rev. 1
0-HPS-026.2, Response Protocols for Whole Body Counting Entrance and Exit, Rev. 3
0-HPS-031.1, Whole Body Dosimetry Issue, Rev. 3A
0-HPS-031.2, Multibadge Exposure Monitoring, Rev. 0B
RP-AA-101-2004, Method for Monitoring and Assigning Effective Dose Equivalent (EDE) for
High Dose Gradient Work, Rev. 3
RP-SR-101-1003, Personnel Contamination Monitoring and Decontamination, Rev. 3
RP-TP-101-1005, Internal Dose Assessment, Rev. 1
RP-TP-101-1000, Exposure Investigations, Rev. 0A
RP-TP-102-1002, Hard to Detect Radionuclides and Contamination Controls, Rev. 1
RP-TP-105-3008, Operation of the Radiation Protection Apex-In Vivo Whole Body Counting
Equipment, Rev. 2
Records and Data Reviewed
ABACOS-2000 Nuclide Libraries, 11/05/2015
Alpha Smear Log, 01/08/2015 thru 11/05/2015
Dosimetry Task Matrix, Daily Fastscan QC Check, October 2015
Extended Fastscan QA File Control Charts, 10/06/2015 thru 11/04/2015
Extended Fastscan WBC System Calibration Report, System # 97-7040, 10/23/2013 and
10/22/2014
EDE Multibadge Datasheets, Pack ID# 5010 and 5012, 11/04/2015
Fastscan 1 WBC System Calibration Report, System # 97-7040, 10/23/2013 and 10/22/2014
HP-55A, Turkey Point Plant Environmental Radiation Controlled Area Radiation Levels Results
Log [including ISFSI], 06/24/14 thru 12/26/14
HP-55A, Turkey Point Plant Environmental Radiation Controlled Area Radiation Levels Results
Log [including ISFSI], 12/26/14 thru 6/23/15
NVLAP Lab Code 100555-0, On-Site Assessment Report and Accreditation Certificate,
06/11/2015
QA 1000 File, 2013 Alpha Smear Summary: Unit 4 R27 Refueling Outage, 06/13/2014
Sensitivity Study of Personnel Contamination Monitors used at Turkey Point Nuclear Station,
02/10/2010
8
Technical Support Document No.15-058, Rev 00, Neutron Dosimetry Evaluation at Turkey
Point Nuclear Power Plant, 08/21/2015
Report, Turkey Point 2015 Site TEDE Dose, Top 25, 11/04/2015
Report, Turkey Point 2015 Annual (all sites) TEDE, Top 25, 11/04/2015
CAP Documents
AR 01940206
AR 01979141
AR 02024069
2RS5: Radiation Monitoring Instrumentation
Procedures
0-HPT-072, Calibration and Operation of Canberra Personnel Monitors, Rev. 2
0-HPT-018, Calibration of Survey Instruments, Rev. 4
0-HPT-010, Radiation Protection Instrument Plan, Rev. 6
RP-TP-105-3007, Operation and Calibration of the GEM-5 Gamma Exit Monitor, Rev 4
Calibrations and Data
Work Order 40033883, ARMS Cal Inside Containment (RD-1401-03), 02/2012
Work Order 40323168, ARMS Cal Inside Containment (RD-1401-03), 03/2014
Work Order 40170223, T.S R-4-19 S/G Liquid Sample PRMS Cal, 05/2013
Work Order 40280868, T.S R-4-19 S/G Liquid Sample PRMS Channel CAL, 12/2014
Work Order 40273313, T.S. Plt Vent SPING Rad-6304 PM Cal, 09/2014
Work Order 40113819, T.S. Plt Vent SPING Rad-6304 PM Cal, 12/2012
Work Order 40161233, T.S. RAD-6311 A/B Cont HI Range ARMS CAL Per 3-PMI-066.3,
02/2013
Work Order 40219065, T.S. RAD-6311 A/B Cont HI Range ARMS CAL Per 3-PMI-066.3,
03/2014
Work Order 40323168, T.S. RD-4-15 SJAE 18 Monthly PM CAL, 01/2015
Work Order 40247970, T.S. RD-4-15 SJAE Spiking cause alarms, 07/2013
Calibration of the FASTSCAN WBC System #97-7040, 10/2013 & 10/2014
HP-7:5.4 CRONOS Calibration Records for #1302-27, 09/24/14 & 03/19/14; #0912-039 ,
10/02/2014 & 10/11/2013; #1005-048 05/26/2015 & 06/09/2014; #1005-049 04/27/2015 &
04/29/2014; #1006-037 06/15/2015 & 06/20/2014; #1302-029 07/22/2015 & 07/22/2014;
- 1302-028 01/13/12015 & 07/23/2014.
GEM-5 Calibration Certificates: #1423, #1424, 07/2014 & 07/2013; #1425 07/2014 & 06/2015
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 03/2015
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 03/2014
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-107, 01/2014
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-108, 07/2015
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #0904-108, 01/2015
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #1107-185, 03/2015
Canberra Personnel Monitor Calibration Data Sheet Argos 5AB Serial #1107-185, 02/2015
System Health Report 07/01/2015-09/30/2015
F & J Model LV-14M Calibration Record Serial #s 4029, 4030, 4031, 06/2015
9
Calibration of the Count Room MCA System, Detector Two, 06/2014
RADECO H809V/C Air Sampler Calibration Record, HPI# 1485E 02/2015
Controlled Settings- Eberline AMS 4, #1847, 10/2015; #2551, 10/2015; #1836 10/2015, #1283
8/2015, #1080 08/2015, #12872 05/2015, #1638 08/2015, #1079 08/2015
Radiation Detection Instrument Calibration and Maintenance Record, Telepole #6605-081,
11/12/2015 & 05/07/2015; RO-20 #105 10/22/2015
HP-7-21, Shepard Model 89 Shielded Range Calibrator Certification Form, 02/2015
CAP Documents
PTN-14-002, Radiological Protection and Radwaste Audit, 03/03/2014
AR 02035780
AR 02042545
Section 4OA1: Performance Indicator Verification
0-ADM-032, NRC Performance Indicators Turkey Point, Rev. 5
List of Dose and Dose Rate Alarms October 1, 2014 to September 30, 2015
Monthly Gaseous Dose Report, October 2015
Monthly Liquid Dose Report, October 2015
2014 Annual Radioactive Effluent Report
AR 02063559
Section 4OA2: Problem Identification and Resolution
AR 2046565, Engineering CAP Indicator for Quality of Cause Analysis
AR 02038459, Safety Issue, No Safety Chain on Emergency Ladder
AR 02039495, Unable To Complete 0-GME-005.03 for 4AD07 SBO Breaker
AR 02039635, Station Blackout Tie Breaker Testing
AR 02040240, RCS A HI Tave Alarmed Early Following Dilution
AR 02040257, 4A Charging Pump Needs Oil
AR 02040258, 3B Charging Pump Fluid Drive Needs Oil
AR 02040265, 4B Turbo Oil Pump Minor Oil Seal Leak
AR 02041403, Time Delay Actuation Outside Acceptable Band
AR 02041408, Time Delay Actuation Outside Acceptable Band
AR 02041612, 3P253A 3A 4KV Room Sump Pump Does Not Turn Off
AR 02041798, Spalling Concrete in Unit 4 Spent Fuel Pool Room
AR 02041864, 3A EDG Coolant Reservoir Stained With Coolant
AR 02044844, 4KV Switchgear Sump High Level
AR 02044936, Performed Level 3 Leak Rate Investigation on Unit 3
AR 02044977, Unit 3 Gamma Metric Channel Alarm Causing a Distraction
AR 02045014, N-3-31 Detector Replacement
AR 02045085, 3B RCP Motor Has Oil Leak and Needs Replacement
AR 02046549, Active Boric Acid Leak at Bonnet of 4-873B
AR 02046555, Maintenance Rule A(1) Status for NIS Source Range Detectors
AR 02047770, Errors in Unit 4 Post Trip Review Restart Report
AR 02047817, Coolant Leak From the 3B EDG
AR 02049161, Excessive Ripple on the 22 Vdc Power Supply
10
AR 02049180, Missing Bolt and Washer on 3B Belt Guard
AR 02049269, 10 CFR 50.59 Screening for Rod Control System Monitoring
AR 02049306, FME Found in 4P212A Pump Casing
AR 20241958, U4 RHR Pump High Radiation Barrier Is Unsafe
AR 02097053, Level 3 Mispositioning Event
AR 02097144, RHR Pump Testing
LIST OF ACRONYMS
ALARA As Low As Reasonably Achievable
AR Action Request
ARM Area Radiation Monitor
ASME American Society of Mechanical Engineers
CAP Corrective Action Program
CCW Component Cooling Water
CFR Code of Federal Regulations
CR Condition Report
EAL Emergency Action Level
ED Electronic Dosimeter
EDG Emergency Diesel Generator
FME Foreign Material Exclusion
GOP General Operating Procedure
HEPA High Efficiency Particulate Air
HHSI High Head Safety Injection
ICW Intake Cooling Water
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
IST Inservice Testing
LCO Limiting Condition of Operation
LER Licensee Event Report
LHRA Locked High Radiation Area
LOCA Loss of Coolant Accident
NAP Nuclear Administrative Procedure
NCV Non-Cited Violation
NDE Non-Destructive Examination
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
OCC Outage Control Center
OLRM On-Line Risk Monitor
ONOP Off Normal Operating Procedure
OOS Out of Service
OSP Operations Surveillance Procedure
P&ID Piping and Instrumentation Drawing
PCM Personnel Contamination Monitor
PI Performance Indicator
PW Primary Water
QATR Quality Assurance Topical Report
RCA Radiologically Controlled Area
RCE Root Cause Evaluation
RCP Reactor Coolant Pump
RFO Refueling Outage
RP Radiation Protection
12
RTP Rated Thermal Power
RWP Radiation Work Permit
SAM Small Article Monitor
SCBA Self-Contained Breathing Apparatus
SDP Significance Determination Process
SFP Spent Fuel Pool
SAM Small Article Monitor
SCBA Self-Contained Breathing Apparatus
SDP Significance Determination Process
SFP Spent Fuel Pool
SI Safety Injection
SUT Startup Transformer
TEDE Total Effective Dose Equivalent
TS Technical Specifications
U3 Unit 3
U4 Unit 4
UFSAR Updated Final Safety Analysis Report
WBC Whole Body Counter
WO Work Order