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05000250/FIN-2017007-0930 September 2017 23:59:59Turkey PointNRC identifiedFailure to Update the UFSAR with the Latest Information DevelopedThe NRC identified a Severity Level-IV non-cited violation of Title 10 Code of Federal Regulations 71(e), Maintenance of Records, Making of Reports, for the failure to assure that the Updated Final Safety Analysis Report (UFSAR) contained the latest information developed, including all changes made in the facility or procedures as described in the UFSAR. The team determined that the licensee failed to update the UFSAR to include the latest information regarding several design features associated with turbine runback. For immediate corrective actions, the licensee entered this issue into their corrective action program as AR 2218695 to update the UFSAR. The NRC determined this violation was associated with a minor performance deficiency in accordance with the screening criteria in IMC 0612, Appendix E. Because the failure to update the UFSAR impacted the NRCs ability to perform its regulatory process, the team evaluated the violation using the traditional enforcement process. The team determined that this met the criteria for a SLIV violation because not accurately describing turbine runback design features in the UFSAR could have a material impact on licensed activities, and met the SLIV violation criteria in 6.1.d.3 of the NRC Enforcement Policy. The violation represented a failure to update the UFSAR as required by Title 10 Code of Federal Regulations Part 50.71(e), but the lack of up-to- date information has not resulted in any unacceptable change to the facility or procedures. Cross-cutting aspects are not assigned to traditional enforcement violations
05000251/FIN-2015001-0131 March 2015 23:59:59Turkey PointNRC identifiedUntimely 10 CFR 50.72 Notification of a ECC System Functional FailureThe NRC identified a SL IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, because unplanned inoperability of the Unit 4 emergency containment cooler (ECC) system was not reported to the NRC within eight hours of the time of discovery, as required by 10 CFR 50.72(b)(3)(v), Event or Condition that Could Have Prevented Fulfillment of a Safety Function. This issue was subsequently reported to the NRC in accordance with10 CFR 50.72(b)(3)(v), and entered into the corrective action program (CAP) as condition report AR 01990555. Because the issue impacted the regulatory process; in that, a safety system functional failure was not reported to the NRC within the required timeframe thereby delaying the NRCs opportunity to review the matter, the inspectors evaluated the issue in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, dated February 4, 2015, the inspectors determined that the violation was a SL IV (more than a minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation, because the licensee failed to make a report required by 10 CFR 50.72. In accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, dated January 24, 2013, traditional enforcement issues are not assigned cross-cutting aspects.
05000250/FIN-2014005-0531 December 2014 23:59:59Turkey PointLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.55a g (5) (ii), states, in part, that if a revised ISI program for a facility conflicts with the TS for the facility, the licensee shall apply to the Commission for amendment of the TSs to conform the TS to the revised program. Contrary to the above, from February 22, 2004, to October 03, 2014, the licensee failed to apply to the Commission for an amendment of the TSs when the revised ISI program for Turkey Point, Units 3 and 4, conflicted with the TS for the facility. Specifically, TS 3/4.7.6, Snubbers, conflicted with the revised ISI program for dynamic restraints (snubbers) because the TS did not reflect the latest American Society of Mechanical Engineers (ASME) Code of record for the current (Fourth) ISI interval (ASME Section XI, 1998 Edition with 2000 Addenda). This violation was dispositioned through the traditional enforcement process because the failure to submit a TS amendment impacted a regulatory process in that, the NRC was not able to perform its regulatory function in determining the adequacy of a licensed activity. This violation was determined to be of Severity Level IV because it is consistent with Example 6.1.d.3 in the NRC Enforcement Policy (revised July 9, 2013), Reactor Operations. As a result of a self-assessment, this violation was entered in the licensees CAP as AR 01984462.
05000250/FIN-2013002-0331 March 2013 23:59:59Turkey PointSelf-revealingWillful Violation of Radiological BarrierA self-revealing Severity Level (SL) IV non-cited violation (NCV) of Technical Specification (TS) 6.8, Procedures, was identified on June 6, 2012, when a worker willfully bypassed a radiological barrier and entered a posted high radiation area (HRA) without proper authorization. Specifically, the worker entered the HRA without receiving a HRA briefing and being issued a key as required by licensee procedure RP-SR-103-1002, High Radiation Area Controls and subsequently received a dose rate alarm. Upon identification, the licensee immediately restricted the workers access to the radiological controlled area (RCA) and placed this issue into the corrective action program (CAP) as action request (AR) 01773513. Due to the willful nature of the workers actions, the inspectors determined the performance deficiency was more than minor in accordance with the guidance contained in Chapter 2 of the Enforcement Manual, Revision 8. This willful finding involved an isolated act of a low-level nonsupervisory individual. It was addressed promptly by appropriate corrective actions, there was no actual safety significance and the underlying technical significance was low. Therefore, the inspectors concluded this finding was Severity Level IV, consistent with Section 2.2.2 of the Enforcement Policy, dated January 28, 2013. There was no cross-cutting aspect because this performance deficiency was dispositioned using traditional enforcement.
05000250/FIN-2011008-0530 September 2011 23:59:59Turkey PointNRC identifiedFailure to Update the UFSAR to Reflect Changes to the Unit 3 Fuel Oil Storage and Transfer SystemThe team identified a SL-IV NCV for the licensees failure to update the Updated Final Safety Analysis Report (FSAR) for a modification affecting the Unit 3 emergency diesel generator fuel oil storage tank. Specifically, a common-mode failure method was not described in the UFSAR that required proceduralized manual actions during design bases rain events. The licensee entered these issues into their corrective action program as AR 1679078. The failure to update the UFSAR as required by procedure ENG Q1-3.4 and 10 CFR 50.71(e) was a performance deficiency. This performance deficiency was considered as traditional enforcement because, not having an adequately updated UFSAR hinders the licensees ability to perform adequate 10 CFR 50.59 evaluations and can impact the NRCs ability to perform its regulatory function such as, license amendment reviews and inspections. In addition, the team determined that the performance deficiency was material to safety because the modification resulted in a common-mode failure method that required proceduralized manual actions for the Unit 3 EDGs to meet their mission time during design bases rain events. This violation was determined to be a SL-IV violation using Section 6.1 of the NRCs Enforcement Policy because the erroneous information was not used to make an unacceptable change to the facility or procedures. Cross-cutting aspects are not assigned for traditional enforcement violations.
05000250/FIN-2010009-0331 March 2010 23:59:59Turkey PointNRC identifiedFailure to maintain FSAR description of Unit 3 spent fuel pool activitiesThe inspectors identified an apparent violation of 10 CFR Part 50.71(e) requirements to periodically update the final safety analysis report so that the report contains effects of changes made to the facility such that the FSAR is complete and accurate. As of December 2009, changes made to manage the Unit 3 spent fuel pool since 2001, including neutron attenuation testing methods and results, use of computer programs such as RACKLIFE, and the use of alternate means of assuring that the spent fuel remains shutdown, such as rod control cluster assembly inserts and water holes, were not described in the FSAR. When identified to the licensee by the inspectors, the licensee documented the condition in condition report 2009-34470, and informed the NRC (in letter L-2009-295, dated December 31, 2009) of plans to make appropriate updates to the FSAR descriptions by March 15, 2010. The finding was more that minor because it impacted the regulatory process which depends on plant activities being properly documented. The inspectors evaluated this finding against NRC IMC 0609 Phase 1 Screening Worksheet for Initiating Events, Mitigation Systems, and Barriers Cornerstones. The inspectors determined that IMC 0609, Appendix M is required to determine the level of safety significance of this finding because the existing SDP guidance is not adequate to provide reasonable estimates of the finding significance within the established SDP timeliness goal of 90 days. NRC staff is currently reviewing this finding to determine the level of safety significance or enforcement aspect of the issue. (4OA2) (IR# 05000250, 251/2009005 dated January 28, 2010) A Non-cited Violation 05000250/201009-03 was identified for failure to update the FSAR in accordance with 10 CFR 50.71(e) so that the report accurately reflects significant changes made to the facility. (IR# 05000250/2010009 dated June 21, 2010).
05000250/FIN-2008005-0131 December 2008 23:59:59Turkey PointNRC identifiedFailure to Accomplish An Activity Affecting Quality in Accordance with ProceduresNRC issued a Severity Level (SL) IV violation to FPL on December 23, 2008, for failure to accomplish an activity affecting quality in accordance with procedures. Specifically, a supervisor failed to follow licensee procedure 0-OSP - 040.8, Reactivity Deviation from Design Calculation, when he reviewed and approved an incorrect (i.e., not current) boron sample that was collected several hours before the reactivity calculation was performed. This violation is being tracked in this inspection report as SL IV VIO 05000250, 251/2008-005-01: Failure To Accomplish An Activity Affecting Quality In Accordance With Procedures
05000250/FIN-2007004-0230 September 2007 23:59:59Turkey PointNRC identifiedInappropriate Blanket Overtime AuthorizationThe inspectors identified a non-cited, SL IV violation of TS 6.8.5 when inappropriate blanket overtime was authorized for thirty-eight electrical maintenance personnel for the entire Unit 3 fall 2007 refueling outage. This issue was promptly discussed with licensee management, the authorization was rescinded, and action was taken by the licensee to manage overtime in accordance with the technical specification requirements. The licensee entered this issue into their corrective action program for resolution. This finding was evaluated using traditional enforcement since it impacted the regulatory process in that the non-compliance with technical specifications was authorized at an executive level, which could become a more significant safety concern. This finding is of very low safety significance because there were no 3 Enclosure actual adverse plant or equipment conditions attributed to worker fatigue