IR 05000250/2022003

Integrated Inspection Report 05000250/2022003 and 05000251/2022003

ML22300A104
Person / Time
Site:	Turkey Point
Issue date:	10/31/2022
From:	David Dumbacher NRC/RGN-II/DRP/RPB3
To:	Coffey B Florida Power & Light Co
References
IR 2022003
Download: ML22300A104 (11)

Text

October 27, 2022

SUBJECT:

TURKEY POINT UNITS 3 & 4 - INTEGRATED INSPECTION REPORT 05000250/2022003 AND 05000251/2022003

Dear Bob Coffey:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Turkey Point Units 3 & 4. On October 13, 2022, the NRC inspectors discussed the results of this inspection with Mr. Michael Pearce and other members of your staff. The results of this inspection are documented in the enclosed report.

No 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, Signed by Dumbacher, David on 10/27/22 David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000250 and 05000251 License Nos. DPR-31 and DPR-41

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000250 and 05000251 License Numbers: DPR-31 and DPR-41 Report Numbers: 05000250/2022003 and 05000251/2022003 Enterprise Identifier: I-2022-003-0022 Licensee: Florida Power & Light Company Facility: Turkey Point Units 3 & 4 Location: Homestead, FL Inspection Dates: July 01, 2022, to September 30, 2022 Inspectors: M. Endress, Senior Resident Inspector J. Hickman, Resident Inspector D. Orr, Senior Resident Inspector R. Reyes, Resident Inspector M. Schwieg, Senior Reactor Inspector Approved By: David E. Dumbacher, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

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

List of Findings and Violations

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

Additional Tracking Items

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

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

71111.01 - 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 from Hurricane Ian on September 26, 2022.

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

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on July 27, 2022, and on September 19, 2022.

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) 4A emergency diesel generator (EDG) and unit 3 and 4 high head safety injection (HHSI) Pumps with the 4B EDG unavailable due to 24-hour run, on August 2, 2022.

(2) Unit 4 startup transformer while the Unit 3 startup transformer was out of service (OOS) for maintenance, on August 19, 2022.

(3) 3B EDG while the left side air start system was inoperable, on September 13, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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 safety injection pump rooms, fire zones (FZs) 052 and 053, on July 8, 2022.

(2) Unit 3 "A" and "B" EDG Building, FZs 073 and 072 on July 15, 2022.

(3) Unit 3 and Unit 4 steam platforms, FZs 115 and 114 on August 1, 2022.

(4) Unit 3 and Unit 4 control room roof, FZs 106R on August 1, 2022.

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) Manholes 303, 304, and 306 during routine inspections.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 3C component cooling water (CCW) heat exchanger, on July 28, 2022.

71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)

The inspectors evaluated heat exchanger performance on the following:

(1) 3A and 4B CCW Heat Exchangers

Heat Exchanger (Closed Loop) (IP Section 03.03) (1 Sample)

The inspectors evaluated heat exchanger performance on the following:

(1) HHSI Pump Outboard Bearing Coolers

Ultimate Heat Sink (IP Section 03.04) (1 Sample)

The inspectors evaluated the ultimate heat sink performance on the following:

(1) Cooling Canals, Ultimate Heat Sink

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 a Unit 3 spent fuel pool primary water make-up, on August 7, 2022, and a Unit 3 3B emergency containment cooler (ECC) operability test, on September 6, 2022.

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

(1) The inspectors observed and evaluated training simulator scenario administered to an operating crew, on August 2, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Action Request (AR) 2427789, Maintenance Rule scoping issues on manual valves used in emergency operating procedures

(2) AR 2433053, Maintenance Rule evaluation for Unit 3 failed CCW heat exchanger

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

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

(1) Unit 3 and Unit 4 online risk monitoring (OLRM) while the 4C ECC, 4B HHSI pump, and 3CD diesel instrument air compressor were OOS, on July 5, 2022.

(2) Unit 3 and Unit 4 OLRM while the 4C ECC, 3CD instrument air compressor, E-16E DC equipment room HVAC air conditioning unit, and the 3Y01 3A static inverter 125-volt DC / 120 VAC were OOS, on July 07, 2022.

(3) Unit 4 4C ECC CCW outlet valve risk informed completion time entry and associated risk management activities, on July 22, 2022.

(4) Unit 3 and Unit 4 OLRM while the 4B intake cooling water (ICW) header, MOV-3-1404 auxiliary feed water (AFW) steam supply, and 3CD diesel instrument air compressor were OOS for maintenance and testing, on July 26, 2022.

(5) Unit 3 and Unit 4 OLRM while the Unit 3 startup transformer and the 3CD diesel driven instrument air compressor were OOS, on August 17, 2022.

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1) AR 02431259, Unit 4 ECC pump 4B tripped when CCW main control valve CV-4-2908 failed to open

(2) AR 02432341, control valve CV-4-2908 does not open the first time

(3) AR 2433012, missed Technical Specification surveillance requirements 4.8.3.1 and 4.8.3.2

(4) AR 2433053, 3C CCW heat exchanger inoperable

(5) AR 02433199, AFW pump C overspeed trip in the alert range

(6) AR 2434315, missed pressurizer pressure surveillance P-4-455/457

(7) AR 2436599, 3B EDG left side air start system became inoperable

(8) AR 2437151, 3C ICW pump seal leakoff accumulated behind plexiglass cover

71111.18 - Plant Modifications

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site SAMG were updated in accordance with the pressurized water reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

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

(1) 3C CCW heat exchanger following cleaning, on July 29, 2022.

(2) Functional testing for 3AB05 startup transformer breaker control and trip circuits after completing maintenance on the control cables, on August 19, 2022.

(3) CV-4-2908 repair following failure to open, on September 01, 2022.

(4) 4B EDG following 24-hour run failure, on September 02, 2022.

(5) 3-3476 vent valve replacement on 3B HHSI pump, on September 08, 2022.

71111.22 - Surveillance Testing

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

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) 3-OSP-023.1, 3B EDG operability test, on July 13, 2022.

(2) 3-OSP-055.1, 3A ECC operability test, on July 25, 2022.

(3) 0-OSP-003.1, 125V vital DC system breaker alignment verification, on July 28, 2022.

(4) 3-OSP-023.1 and 4-OSP-023.1, 3B and 4A EDG fast start for technical specification compliance, on August 03, 2022.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) 4-OSP-062.2B, Safety Injection Pump 4B Group B Pump Test, Revision 10, on July 8, 2022.

FLEX Testing (IP Section 03.02) (1 Sample)

(1) 0-OSP-083.32, Periodic Testing of PDG-2, FLEX 480V Portable Diesel Generator, on September 21, 2022.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) Emergency preparedness tabletop exercise in the technical support center, on August 04, 2022, and in the emergency operations facility, on September 16,

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) ===

(1) Unit 3 (July 01, 2021, through June 30, 2022)

(2) Unit 4 (July 01, 2021, through June 30, 2022)

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

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

(1) The inspectors reviewed AR 2426694, Failed Post-maintenance Test of 3-759A, isolation valve at 3A residual heat removal system heat exchanger. This AR and associated corrective actions and evaluations were reviewed to verify the licensee's corrective actions were appropriate to ensure cold leg recirculation capability was maintained in the piggyback configuration established by emergency operating procedures.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On October 13, 2022, the inspectors presented the integrated inspection results to Mr.

Michael Pearce, Site Vice President, and other members of the licensee staff.

On July 22, 2022, the inspectors presented the Heat Sink exit meeting inspection results to Mr. Pearce and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07T Corrective Action AR2432368 NC Identified 4C CCW HX Bolt Corrosion 1

Documents AR2432370 NC Identified #C CCW HX Valve Corrosion 1

Resulting from

Inspection

Drawings 5613-M-3030 Component Cooling Water System 28

Engineering EC282844 Turkey Point Cooling Canal System 2

Changes EC282972 FLEX Water Well & Cooling Canal System Salinity Reduction 7

Wells

Miscellaneous Heat Sink CCS Freshening 012020 - 062020 1

Heat Sink thermal Imaging pre modification 1

Heat Sink thermal Imaging post modification 1

Procedures 4-OSP-030.4 Unit 4 Component Cooling Water Heat Exchanger 11

Performance Test

Work Orders 40788152-01 Inspect, Clean 4C CCW HX 1

40798874-01 Inspect, Clean 3A CCW HX 1

40798875-01 Inspect, Clean 3B CCW HX 1

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