IR 05000250/2020003

Integrated Inspection Report 05000250/2020003 and 05000251/2020003

ML20309A873
Person / Time
Site:	Turkey Point
Issue date:	11/04/2020
From:	Randy Musser NRC/RGN-II/DRP/RPB3
To:	Moul D Florida Power & Light Co
References
IR 2020003
Download: ML20309A873 (12)

Text

November 4, 2020 Mr. Don Moul Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.

Juno Beach, FL 33408 SUBJECT: TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2020003 AND 05000251/2020003

Dear Mr. Moul:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On October 23, 2020, the NRC inspectors discussed the results of this inspection with Mr. Michael Pearce, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000250 and 05000251 License Numbers: DPR-31 and DPR-41 Report Numbers: 05000250/2020003 and 05000251/2020003 Enterprise Identifier: I-2020-003-0046 Licensee: Florida Power & Light Company Facility: Turkey Point Units 3 & 4 Location: Homestead, FL 33035 Inspection Dates: July 01, 2020 to September 30, 2020 Inspectors: D. Bacon, Senior Operations Engineer N. Lacy, Operations Engineer D. Lanyi, Senior Operations Engineer D. Orr, Senior Resident Inspector R. Reyes, Resident Inspector Approved By: Randall A. Musser, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

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

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000251/2020-001-00 LER 2020-001-00 for Turkey 71153 Closed Point, Unit 4, Automatic Reactor Trip caused by Main Generator Lockout due to Exciter Fault

PLANT STATUS Unit 3 began the inspection period at rated thermal power (RTP). On August 17, 2020, Unit 3 was manually tripped in response to high steam generator levels following inadvertent opening of the low-pressure feedwater heater bypass valve. On August 19, 2020, an automatic reactor trip occurred in response to high source range neutron flux during the startup. Unit 3 was returned to power operation on August 20, however, during power ascension, Unit 3 was manually tripped in response to an automatic trip of the single operating steam generator feedwater pump. Unit 3 was returned to RTP on August 25, 2020, and remained at or near RTP for the remainder of the inspection period.

Unit 4 began the inspection period at RTP. On July 5, 2020, an automatic reactor trip occurred in response to an automatic turbine trip. The automatic turbine trip was due to a main generator lockout. Unit 4 was returned to RTP on July 21, 2020, and remained at or near RTP for the remainder of the inspection period.

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

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY 71111.01 - Adverse Weather Protection Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather due to Tropical Storm Isaias on July 29 - 31, 2020

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment were consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on July 23 - 24, 2020 71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Unit 3 and Unit 4 auxiliary feedwater (AFW) system normal standby alignment with A and C AFW pumps aligned to train 1 and B AFW pump aligned to train 2, after testing and realignment due to the Unit 4 forced outage on July 7, 2020 (2) 3B emergency diesel generator (EDG) after testing and realignment on July 28, 2020 (3) Unit 3 and Unit 4 AFW system abnormal standby alignment with the C AFW pump on train 1 and the B AFW pump on train 2, while the A AFW pump was isolated and out of service (OOS) for troubleshooting and repair on September 18, 2020 71111.05 - Fire Protection Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

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

(1) Units 3 and 4 pipe and valve rooms, (fire zones (FZs) 030 and 040);

Unit 3 electrical penetration south room, (FZ 020);

Unit 4 electrical penetration north room, (FZ 026); and, Unit 4 electrical penetration west room, (FZ 027), on August 04, 2020 (2) Units 3 and 4 control room, (FZ 106); and, 3A and 3B EDG engine rooms, (FZs 073 and 072), on August 4, 2020 (3) Units 3 and 4 spent fuel pool rooms, (FZs 042 and 029), on September 10, 2020 (4) Units 3 and 4 main steam platforms, (FZs 115 and 114), on September 16, 2020 (5) Units 3 and 4 steam generator feedwater pump rooms, (FZs 069 and 066); and, Unit 3 hydrogen purity blower area, (FZ 081), on September 22, 2020 (6) Units 3 and 4 condensate pump pits, (FZs 092 and 091); and, Units 3 and 4 turbine lube oil reservoirs area, (FZs 081 and 076),

on September 30, 2020 Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on August 11, 2020

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Units 3 and 4 component cooling water (CCW) rooms on August 13 - 14, 2020 71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during:

• Unit 3 reactor startup and trip on source range high neutron flux on August 19, 2020

• Unit 3 reactor startup on August 20, 2020

• Source range nuclear instrumentation, (3-N-32), post maintenance test and Unit 3 reactor startup on August 24, 2020

• Establishing Unit 3 main feedwater regulating valves in automatic during reactor startup on August 24, 2020 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed senior reactor operator and reactor operator annual operating exam in the control room simulator on September 1, 2020 71111.12 - Maintenance Effectiveness Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Action requests (ARs) 2312791 and 2354210, manhole (430),

maintenance rule (a)(1) action plan on August 10 - 13, 2020 (2) ARs 2359195 and 2364188, 4D, 4-kilovolt (kV) switchgear room supply fan, (4V65B), motor starter maintenance rule evaluation on August 26, 2020 71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

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

(1) Units 3 and 4 on-line risk monitor (OLRM) with 4E239B 1B load center and switchgear chiller unit, E234 electrical equipment room water chiller unit, train 1 AFW, 3CD instrument air diesel compressor, and 4B emergency containment cooler (ECC),

OOS on July 21, 2020 (2) Units 3 and 4 OLRM with 3C charging pump, 3B2 battery charger, E234 electrical equipment room chiller, 4C CCW heat exchanger, and 4A intake cooling water (ICW)

header OOS on September 10, 2020 (3) Units 3 and 4 OLRM with the A AFW pump, 4C motor-driven instrument air compressor, water chiller unit for electrical equipment room AHU-V78, and the 3A EDG, OOS on September 16, 2020 71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) AR 2363732, Small nitrogen leak downstream of PCV-3-1702, train 2 backup nitrogen pressure control valve to AFW flow control valves on July 27, 2020 (2) AR 2358251, 3B safety injection system degraded voltage on July 27 - 28, 2020 (3) AR 2362722, RV-4-1425, 4A ECC, CCW relief valve not reseating on July 31, 2020 (4) AR 2364217, 4A steam generator blowdown piping active through-wall leak on August 7, 2020 (5) AR 2367468, A AFW pump lube oil reservoir level trending up on September 24, 2020 71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering change (EC) 293937, Installation of an air conditioning unit for 3B motor control center room on August 13, 2020 (2) EC 294356, Flood protection improvements for north and south perimeter flood walls on August 13 - 14, 2020 71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) 0-PMI-074.11, Feedwater Pump Pressure Switch Calibration / Replacement, after replacement of pressure switch PS-3-2011 and PS-3-2014 per work order (WO)

40737414 on August 26, 2020

(2) 0-GME-102.11, Accelerated motor operated valve (MOV) Inspection, Overhaul and Equipment Qualification (EQ) Inspection, after replacement of MOV-3-1433, main steam to reheater 3C valve torque switch per WO 40737489 on August 27, 2020 (3) 3-SMI-059.03, Source Range Nuclear Instrumentation N32 Calibration, after modifying the instrument electrical operational parameters per WO 40738044 on September 15, 2020 (4) MA-AA-100-1011, Equipment Troubleshooting, after repairing position indication on MOV-3-1432 B main steam to reheater 3B valve per WO 40737415 and WO 40737489 on September 18, 2020 (5) Post-maintenance testing performed within WO 40641564, 3S75, 3D 4-kV Control Power direct current (DC) Transfer Switch Inspection and Cleaning, on September 23, 2020 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (3 Samples)

(1) 3-OSP-050.2A, Residual Heat Removal Train A Test - Standby Alignment on July 20, 2020 (2) 4-OSP-075.2, Auxiliary Feedwater Train 2 Operability Verification, (Sections 7.1 and 7.2), on July 30, 2020 (3) 0-OSP-059.15, Nuclear Instrumentation Channel Check and Calibration, (Sections 4.1, 4.2, and 4.3 for Units 3 and 4) on July 31, 2020 71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Emergency classifications and notifications to Florida, local counties, and NRC emergency operations centers during a licensed senior reactor operator and reactor operator annual examination in the control room simulator on September 1, 2020 OTHER ACTIVITIES - BASELINE 71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (2 Samples)

(1) Unit 3 July 2019 through June 2020 (2) Unit 4 July 2019 through June 2020

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) AR 2353977, evaluate surveillance frequency for degraded voltage relays. This issue was selected for follow-up to verify the licensee's corrective actions were appropriate to address technical specification surveillance requirements to calibrate the under voltage and degraded voltage relays associated with the 480 Volt alternating current (VAC) safety-related load centers that were not performed in the Spring 2020 Unit 3 refuel outage. Observations related to this inspection are included in the results section of this inspection report titled, "Inappropriate Consideration to Apply Technical Specification 4.0.3 to a Surveillance Performed Within Its Specified Frequency."

71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01) (4 Samples)

(1) On July 5, 2020, the inspectors evaluated the licensee's response to a Unit 4 automatic reactor trip which was due to an automatic turbine trip as a result of a main generator lockout.

(2) On August 17, 2020, the inspectors evaluated the licensee's response to a Unit 3 manual reactor trip in response to high steam generator level following inadvertent opening of the low-pressure feedwater heater bypass valve. This event was the first of three reactor trips on Unit 3 during the week of August 17, 2020. These events were subsequently the focus of a special inspection. The results of the special inspection will be documented in Inspection Report 2020050.

(3) On August 19, 2020, the inspectors evaluated the licensee's response to a Unit 3 automatic reactor trip in response to high source range neutron flux during a startup.

This event was the second of three reactor trips on Unit 3 during the week of August 17, 2020. These events were subsequently the focus of a special inspection.

The results of the special inspection will be documented in Inspection Report 2020050.

(4) On August 20, 2020, the inspectors evaluated the licensee's response to a Unit 3 manual reactor trip caused by the 3B steam generator feedwater pump automatic trip.

This event was the third of three reactor trips on Unit 3 during the week of August 17, 2020. These events were subsequently the focus of a special inspection.

The results of the special inspection will be documented in Inspection Report 2020050.

Event Report (IP Section 03.02)

The inspectors evaluated the licensee event report (LER) 05000251/2020-001-00, Automatic Reactor Trip caused by Main Generator Lockout due to Exciter Fault, (ADAMS Accession No. ML20242A001). The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foresee and correct and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. This LER is closed.

INSPECTION RESULTS Observation: Inappropriate Consideration to Apply Technical Specification 4.0.3 71152 to a Surveillance Performed Within Its Specified Frequency On April 22, 2020, a senior reactor operator (SRO) reviewed a list of work orders that were not completed in the spring 2020 Unit 3 refuel outage (PT3-31) in preparation for ascending the unit from operational mode 3, hot standby, to operational mode 2, startup. The SRO identified that degraded voltage and under voltage relay calibrations that were normally performed in mode 5, cold shutdown, or below mode 5, were not performed. The calibrations are required by technical specification (TS) surveillance requirement (TSSR) 4.3.2.1 as specified in Table 4.3-2. Table 4.3-2 required the calibrations at a frequency determined by the surveillance frequency control program (SFCP). The SFCP required the relay calibrations occur at a refuel outage interval or eighteen months. The calibrations were normally performed while the plant is, at a minimum, offline in mode 5, cold shutdown, or below.

This is due to the operational risk of an inadvertent partial loss of offsite power occurring during the relay calibration activities. The surveillances were not performed during PT3-31 because they were inadvertently coded as a common Unit 3 and Unit 4 activity but should have been specifically assigned to Unit 3. The administrative error occurred when the responsible department to perform the relay calibrations was transferred from the site area operations department to the electrical maintenance department.

The SRO generated AR 2353977, to evaluate the surveillance frequency for degraded and under voltage, voltage relays, on April 22, 2020. AR 2353977 stated the end of life (EOL)

date to complete the surveillance was September 29, 2020. The EOL date included application of TSSR 4.0.2 which allowed an extension to not exceed 25 percent of the surveillance interval, or for this instance, 22.5 months since the calibrations were last performed. AR 2353977 stated that if the work was not performed by EOL it would constitute a missed surveillance until next outage.

The inspectors determined that the condition as described in AR 2353977 did not constitute a missed surveillance but rather a surveillance that will not be performed due to current plant conditions. The condition was discovered in mode 3, and the outage control center determined that proceeding to mode 1, power operations, was acceptable and at a later date would evaluate if the relay calibrations could be performed online or if the surveillance test interval could be extended by the SFCP.

As of September 28, 2020, the licensee was considering application of TS 4.0.3 as appropriate for the circumstances. TS 4.0.3 is appropriate for surveillances discovered not performed within its specified frequency after the specified frequency has passed.

TS 4.0.3 allowed a one-time delay for performing the surveillance up to the limit of the specified frequency. On September 28, 2020, the inspectors communicated to the licensee that not performing the relay calibrations for current conditions was a misapplication of TS 4.0.3. On September 29, 2020, the licensee agreed that their earlier interpretation of TS 4.0.3 was incorrect, and this circumstance was therefore not a missed surveillance but a surveillance that will not be performed due to current plant conditions. For several weeks the licensee was also evaluating through the SFCP process to extend the test interval for the relay calibrations. On September 29, 2020, the SFCP process approved extending the test interval to 24 months. The 24-month interval was limited by an associated vendor manual that recommended maintenance be performed on the relays every 24 months. The licensee continued to evaluate the basis of the 24-month limitation in the vendor manual and may be able to further extend the test interval to 36 months. Regardless of the SFCP outcome to

extend the test interval to 36 months, the licensee agreed that TS 4.0.3 was not appropriate for these circumstances. Additionally, the Technical Specifications Task Force (TSTF),

documented a Regulatory Position Paper, TSTF-RPP-14-01, (ADAMS Accession No.

ML20308A398) dated October 6, 2014. The TSTF is an industry owners group tasked with interacting with the NRC on issues related to TS. Inspectors noted that the regulatory position paper also provided further evidence that the licensee was misinterpreting TS 4.0.3.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

• On October 23, 2020, the inspectors presented the integrated inspection results to Mr. Michael Pearce, Site Vice President, and other members of the licensee staff.

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