L-85-355, Responds to NRC Re Violations Noted in Insp Repts 50-250/85-23 & 50-251/85-23.Corrective Actions:Spent Fuel Pit Piping Surveillance Frequency Increased & Procedures Revised.Requests That NRC Mitigate Increased Civil Penalty
| ML20135H993 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/19/1985 |
| From: | Williams J FLORIDA POWER & LIGHT CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-85-080, EA-85-80, L-85-355, NUDOCS 8509250113 | |
| Download: ML20135H993 (8) | |
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FLORIDA POWER & LIGHT COMPANY EP1 91m L-85-355 l
Mr. James R. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Taylor:
Re: Turkey Point Units 3 & 4 Docket Nos. 50-250, 50-251 Notice of Violation and Proposed Imposition of Civil Penalty (EA 85-80)
Florida Power & Light has reviewed the NRC letter dated August 20, 1985 regarding the above subject and the accompanying Inspection Report 85-23. Our written statement of ernlanation, requested in that letter pursuant to 10CFR2.201, is attached.
FPL concurs with the specific finding but objects to the escalation to the base civil penalty. It is our position that the previous finding regarding the intake cooling water system (EA 84-121) should not, in and of itself, require penalty escalation. The extensive FPL programs formulated as a result of that finding are in place and working. The current finding regarding the spent fuel cooling system piping predates the intake cooling water issue, and was within the scope of our prior identified corrective action. That same corrective action could have prevented the continued existence of this condition.
FPL management is committed to safe operation of our nuclear plants. This committment has been demonstrated by the many voluntary programs implemented to upgrade an earlier generation plant such as Turkey Point. Our Performance Enhancement Program, and Program for Improved Operation are prime examples of our aggressive pursuit of excellence in operation of our nuclear plants.
Our programmatic corrective actions in the area of compliance with the requirements of 10CFR 50.59 are such that we are confident that we are achieving strict compliance with these important requirements.
It is our position that the considerable efforts expended in the Program for Enhanced Performance and the Program for Improved Operation have significantly improved our regulatory sensitivity and our capability to deal h
effectively with the letter and spirit of the applicable regulations.
These h
programs have, and will prevent similar occurrences from happening in the future.
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Page 2 Turkey Point Units 3 & 4 Docket Nos.30-250, 50-251 Notice of Violation and Proposal Imposition of Civil Penalty (EA 85-30)
The following information should be considered in a review of our request for mitigation:
The original error in classifying the spent fuel pool cooling system valve lineup change was clearly an oversight as opposed to a willful or intentional act to deviate from a FSAR requirement. We believe this type of error would not occur now or in the future as a result of the considerable efforts we have made to improve awareness of regulatory requirements.
The valve line.up change was made in response to dealing with a problem of vortexing at the upper suction connection. Corrective action for this condition had been identified and was in progress.
The long term corrective actions which were initiated in response to the previous finding (Reference EA 84-121) were still in progress. One of these actions was the System Operability Review Program (SORP). The concern regarding the lineup of the spent fuel cooling system could have been recognized and corrected by this long-term action item.
The FPL initiated corrective modifications to fix the vortexing problem which resulted in the realignment of the suction valves is being completed.
As noted in the body of the inspection report, the modification was completed on Unit 3 prior to the formal notification of the finding on May 17, 1985. The modification to the Unit 4 upper suction is scheduled to be completed by October 15,1985.
Considerable resources have been previously devoted to improving and upgrading physical features of the spent fuel storage areas, such as installation of a thicker liner plate, provision for cooling pump redundancy and continuous level indication in the control room.
A subsequent evaluation showed that there was reason to believe that the probability of uncovering the fuel in the spent fuel pool was not increased when consideration was given for operator intervention. This evaluation did not, however, recommend operation with the lower drain line opened.
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L Page 3 Turkey Point Units 3 & 4 Docket Nos. 50-250, 50-251 Notice of Violation & Proposal Imposition of Civil Penalty (EA 8540)
FPL..has addressed the other concerns identified in the NRC cover letter involving spent fuel pool operation. The corrective' actions for these items are designed to prevent similiar concerns in this area in the future. These corrective actions are detailed in the attachment to this letter.
The extensive corrective actions taken for the previous event, and those discussed in the attachment to this letter are designed to prevent similiar situations from occurring in the future. For those reasons we request that the NRC consider mitigating the increase to the base civil penalty. The spent fuel system will continue to receive. the management attention necessary for responsible operation of the facility.
Should you have any questions on this information, please contact us.
.s Sincerely, b
- 3. W. Williams, Jr.
Group Vice President
.., Nuclear Energy JWW: mis Attachments
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cc:
Dr. 3. Nelson Grace, USNRC, Region II Harold F. Reis, Esquire PNS-LI-85-315/1 -
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ATTACHMENT Re: Turkey Point Units 3 and 4 Docket No. 50-250,50-251 Proposed Civil Penalty EA 85-80.
Inspection Report 250-85-23 and 251-85-23 FINDING 1:
10 CFR 50.59(a) allows the holder of a license to make changes in the facility as described in the Final Safety Analysis Report (FSAR) without prior Commission approval unless it involves a change to the Technical Specifications or is an unreviewed safety question.
An unreviewed safety question is created if the consequences of an accident or the malfunction of equipment important to safety previously evaluated in the FSAR are increased.
10 CFR 50.59(b) requires in part that the licensee maintain records of changes in the facility to the extent that such changes constitute changes in the facility as described in the FSAR. These records shall include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Section 9.3 of the Turkey Point FSAR states that the possibility of siphon draining of the Spent Fuel Pit (SFP) by a break in the SFP drain piping is prevented by a normally closed valve located six feet above the fuel assemblies.
Contrary to the above, sometime prior to September 198te, and continuing through June 5,1985, the licensee had failed to meet the requirements of 10 CFR 50.59 in that a change was made to the facility described in the FSAR af ter license issuance without first conducting and documenting a review to determine that the change did not involve an unreviewed safety question. The chwige to the facility involved operating a valve on the drain piping portion of each unit's SFP cooling loop in an open position, although it was described in Section 9.3 of the FSAR as closed. This change involved an unreviewed safety question since a malfunction could have completely drained the SFP. The FSAR includes an evaluation of the possibility of a piping break upstream of this normally-closed valve, but did not evaluate a piping break or other malfunctions of eculpment downstream of the valve with the valve open.
Re: Inspection Report 250-85-23 and 251-85-23 i
Page 2 i
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RESPONSE
- 1) FPL concurs with the finding.
- 2) The reasons for the finding are as follows:
I During the period prior to September 1984, use of the lower spent fuel pit (SFP) line as a suction line was initiated without a safety evaluation that considered the criteria of 10 CFR 50.59. This safety _ concern remained unidentified by the plant until September,1984.
Although the immediate short term precautions identified below in item 4
3.a.were taken in response to the internal FPL letter, no long term and permanent solutions were implemented until May 1985 to resolve the.
potential for siphon draining the spent fuel pit. Af ter the internal FPL 1
correspondence was received by the plant in September 1984, operation of j
the spent fuel pit in a manner inconsistent with the FSAR was due to a technical concern over the vortexing problem associated with use of the' upper spent fuel pit suction line.
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- 3) a)
Immediate interim precautions were taken when the spent fuel pit concern was identified to the plant in September 1984. On September 28, 1984 an entry was made in the control room night order log which increased the frequency of the normal visual surveillances of the spent fuel pit (SFP) piping and equipment.
b). After completion of the installation of the Unit 3 SFP upper suction line vortex diffuser, the lower drain line was valved closed and the upper suction line was returned to use on May 2,1985. Later on May 30, 1985 the Unit 4 SFP lower drain valve was closed and the upper suction line was returned to use. Since these dates the SFP cooling has operated using the upper suction lines as described in section 9.3 of the FSAR.
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c)
The following actions are provided to address the additional items discussed in the NRC cover letter to EA 85-80.
1 (1)
The concern regarding higher than normal operating temperatures in the SFP systems, as a result of using a four inch instead of an eight inch line, has been resolved by switching over
. to use the upper eight inch suction lines for both units.
1 (2)
The concern regarding SFP level floats which were stuck in the.
normal level position has been resolved. PC/M 82-35 and PC/M 82-36 were developed to install new level indication / alarm i
systems on Units 3 and 4, respectively. Only testing remains to j-be performed on Unit 3 to complete these PC/Ms.
Re: Inspection Report 250-85-23 and 251-85-23 Page 3 (3) There was an additional concern regarding personnel shielding as a result of not maintaining design water level.
Item (2) above discusses corrective action to better control the water level. We have also investigated the cause of the higher than expected radiation levels and have determined the cause to be problems in the operation of the SFP demineralizer.
The situation was corrected by a thorough replacement of the demineralizer resin.
4)
It is our position that actions taken or initiated previously, as part of the t
Performance Enhancernent Program and Program For Improved Operation, are sufficient to prevent this type of finding in the future.
Our corrective action to prevent recurrence will, therefore, focus on the clarification of existing controls and requirements that have received detailed review during our investigation of the finding.
Corrective actions include the following items:
a)
The Program for Improved Operations provided for enhancement of plant management awareness and overview for issues potentially affecting plant safety. Part of the program enhanced the PNSC effectiveness, and increased awareness in order to ensure management is promptly notified of significant issues and concerns. To further enhance this effort, procedural guidance will be developed to ensure the Engineering Department notifies plant management of confirmed deviations from FSAR requirements.
These notifications will include presentations as appropriate and justifications for recommended corrective actions. In addition, the Engineering Department will provide the plant with a listing of required plant actions. This listing will identify the applicable correspondence and will be revised and issued on a periodic basis.
Engineering Department correspondence will be forwarded to the plant through the Technical Department Supervisor. The Technical Depsrtment will maintain files on these safety concerns to ensure proper document retention.
Engineering correspondence which include specific recommendations will be entered into a tracking system to ensure the assignment of responsible individuals, management visibility, and proper resolution of safety concerns.
b)
FPL will continue to implement the actions of the System Operability Review Program as discussed in our response to intake i
cooling water system violation, EA 84-121. It is our position that this long term corrective action would have assisted in identifying and. correcting the specific instance described in the finding and will be continued. This program will be instrumental in identifying and correcting other potential problems of this type.
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Re:
Inspection Report 250-85-23 and 251-85-23 Page 4 c)
The Procedures Update Program (PUP) Group is performing the required evaluations to determine whether a condition not consistent with the FSAR exists for new plant procedures.
These evaluations and the written safety evaluations per 10CFR 50.59, when required, will continue to be provided with the procedure change packages.
Administrative Procedures O-ADM-100, " Procedure Preparation, Review, and Approval", and 0109.3," On The Spot Changes to Procedures", will be revised to provide improved guidance to the individuals responsible for preparing procedure changes and on-the-spot changes (OTSCs) for FSAR and Technical Specification reviews. A Quality improvement Team has evaluated the preparation of OTSCs and has prepared guidelines, which follow INPO Good Practices, for the determination - of whether a' proposed OTSC constitutes a change of intent to a procedure. These guidelines have-been issued for trial implementation, and the final guidelines and associated administrative process selected by the QIP s
Team will be incorporated Jr.to appropriate plant procedures.. If the -
intent is not being changed, the OTSC will be processed as usual. Should the proposed OTSC involve a change in the intent, the revision will not be allowed and will require processing as a permanent procedure change.
These permanent procedure changes will receive the appropriate reviews for FSAR and Technical Specification applicability.
A line of communications is being established, by which PUP. will promptly ' otify plant management of potential concerns regarding n
procedure inconsistencies with the FSAR.
d). As required by 10CFR 50.59, written safety evaluations will be prepared i
for changes to procedures described in the FSAR. The evaluations and procedure changes which might result in revisions to the FSAR document l
will be provided on a timely basis to the engineering department as part of the procedure processing activities.
These evaluations will provide the engineering department access to the most current configurations of the plant systems for use in preparation and review of plant design changes.
5)
Full compliance for the pending actions identified in items 3.c.(2), 4.a, 4.c, i
and 4.d will be completed by December 1,1985, except those Performance Enhancement Program and Program for Improved Operations items which are covered under separate schedules.
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STATE OF FLORIDA
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COUNTY OF DADE
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J. W. Williams, Jr., being first duly sworn, deposes and says:
That he is Group Vice President of Florida Power & Light Company, the licensee herein; That he has executed the foregoing document; that the statements made in.this document are true and correct to the best of hi.s-knowledge, information, and belief, and that he is authorized to execute the document on behalf of said i
Licensee.
iniu6 J. W. Williams, Jr W i
Subscribed and sworn to before me this
/9 day of 8f 47[-n [er
, 1985 i
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NOTARY PUBLIC, in and for the County of Dade, State of Florida.
I nata 4Y PUBLIC STATE LF F'.Ck1LA uf C0wn!55104 ExP. CEC 27,1981 BC OED i m G W M N a N' My commission expires:
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