L-84-329, Responds to NRC Re Violations Noted in Insp Repts 50-250/84-27 & 50-251/84-28.Corrective Actions:Procedure Revised to Include 45-day Tech Spec Time Limit for Sample Analysis & New Decontamination Procedure Generated

Responds to NRC Re Violations Noted in Insp Repts 50-250/84-27 & 50-251/84-28.Corrective Actions:Procedure Revised to Include 45-day Tech Spec Time Limit for Sample Analysis & New Decontamination Procedure Generated

ML20101G291
Person / Time
Site:	Turkey Point
Issue date:	11/13/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101G272	List: L-84-329, Responds to NRC Re Violations Noted in Insp Repts 50-250/84-27 & 50-251/84-28.Corrective Actions:Procedure Revised to Include 45-day Tech Spec Time Limit for Sample Analysis & New Decontamination Procedure Generated
References
L-84-329, NUDOCS 8412270464
Download: ML20101G291 (3)

Text

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USNRC RE 510N :I ^

• ATL ANTA. GEORGIA

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84 Nov 16 A10 : 5 6 November 13, 1984 L-84-329 Mr. James P. O'Reilly Regionel Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 250-84-27 and 251-84-28 Florida Power and Light Company has reviewed the subject inspection report and a response is attached.

Per discussions with your Mr. C. M. Hosey, a proposed Technical Specification change to allow the breaching of containment integrity of a unit at power or refueling by opening certain valves under administrative controls will be submitted by January 15, 1985. This exception is required to allow for certain surveillance and testing requirements.

There is no proprietary information in the report.

Very truly yours, j

J '

b Gr.oupW. Vice Williams, Jr.

President I Nuclear Energy Department l l

JWW/JA/ms l Attachment cc: Harold F. Reis, Esquire K15 l

l 8412270464 841203 PDR ADOCK 05000250 0 PDR PEOPLE. . SERVING PEOPLE

ATTACIMENT Re: Turkey Point Units 3 and 4 Docket No. 50-250, 50-251 IE Inspection Report 250-84-27 and 251-84-28 FINDING 1:

Technical Specification 4.7.1 requires that a carbon analysis for each emergency containment filter plenum be performed at least every 18 months or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and that the analysis verify greater than 99.9% removal efficiency for elemental iodine within 45 days after removal of the sample, j Contrary to the above, carbon samples removed on July 20, 1982 and March 24, 1984, were not analyzed within 45 days of removal.

RESPONSE

1) FPL concurs with the finding.

2) The reason for the finding was an oversight by plant personnel in that the Technical Specification (TS) requirement was not identified on the Delivery and Work Authorization (DWA) sheet, transmitting the sample to an outside company for analysis.

3) Operating Procedure (0P) 4704.2, " Emergency Containment Charcoal Filters Surveillance Specimen Evaluations", has been revised to include specific references to the TS time limit for sample analysis of 45 days. Included in this revision is a note to include on the DWA for the sample analysis, that the test must be completed and results sent back to Turkey Point within two weeks of receipt of the sample in order to comply with TS.

4) No further corrective actions are deemed necessary.

5) Full compliance was achieved on September 5, 1984 FINDING 2:

Technical Specification 6.8 requires that written procedures and administra-tive policies be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33 Regulatory Guide 1.33 recommends that the licensee have a radiation work permit procedure. Plant Procedure HP-1, Radiation Work Permit, April 2,1984, Paragraph 4.1.1 requires the licensee to have a specific radiation work permit for areas posted "RWP required for entry".

Contrary to the above, between August 6 -

22, 1984, bags of radioactive material were opened, material sorted, and tools and equipment decontaminated i n

• he dry storage warehouse without an approved specific radiation work perm t to perform these tasks.

IE Inspection R~ port 250-84-27 and 251-84-28 l

.. Re:

Page 2

RESPONSE

1) FPLconcurshiththefinding.

2) The reason for the finding was that due to an anticipated change in work scope, the Radiation Work Permit (RWP) covering the decontamina-tion operations was terminated. Another RWP was expeditiously authorized to include the change of work scope, however, the requirements for the decontamination operations were omitted due to an oversight.

3) A decontamination operation RWP 84-1968, " Dry Storage Ruilding, Sort, Segregate and Decontaminate Tools and Equipment", was generated on August 23, 1984 This event has been reviewed with all Health Physics Supervisors to make them cognizant of the importance of including all operations to be performed in a RWP and the significance of failing to do so.

4) No further corrective actions are deemed necessary.

5) Full compliance was achieved on August 23, 1984 o

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