ML16027A147

NRC Integrated Inspection Report 05000250/2015004, 05000251/2015004, October 1, 2015 to December 31, 2015

ML16027A147
Person / Time
Site:	Turkey Point
Issue date:	01/27/2016
From:	Suggs L B 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 NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the

NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agency wide Documents Access and M

anagement 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 emailRXK3 /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

Enclosure

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

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 NRC's

Enforcement Policy dated February 4, 2015. The NRC's 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 licensee's 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 (E

DGs) 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 licensee's procedure 0-ADM-016, "Fire Protection Plan" and 10 CFR Part 50, Appendix R. The

inspectors routinely reviewed the licensee's 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 Acti

vities and Welding Activities

From October 26-29, 2015, the inspectors conducted an onsite review of the

implementation of the licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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

licensee's 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 licensee's 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

• Evaluator's 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

licensee's operator requalification program biennial written examinations. The activity

performed by the inspectors was conducted to assess the licensee's 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 licensee's 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 licensee's 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

licensee's risk assessment of five emergent or planned maintenance activities. The

inspectors verified the licensee's 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 licensee's 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 requirem

ents 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 t

he 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 licensee's 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 licensee's

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 licensee's 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 licensee's 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 licensee's Quality Assurance Topical Repor

t (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 licensee's 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 licensee's

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 licensee's 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 licensee's 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 licensee's

post drill critique, reviewed the licensee's critique items, and discussed inspector

observations with the licensee to verify that drill issues were identified and captured in the licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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

licensee's 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 licensee's CAP. This review was accomplished by reviewing daily printed summaries of ARs and by reviewing

the licensee's 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 licensee's 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 licensee's corrective actions process as specified in licensee's 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 licensee's 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 licensee's 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 licensee's 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 licensee's 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

Attachment 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)

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 bet

ween 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;

1. 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