ML17207A556

Responds to NRC 790921 Ltr Re Violations Noted in IE Insp Rept 50-335/79-20.Corrective Actions:Testing of Shield Bldg Ventilation Sys Completed & Shipping Procedures Brought Into Compliance

ML17207A556
Person / Time
Site:	Saint Lucie
Issue date:	10/16/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17207A555	List: IR 05000335/1979020 ML17207A556
References
L-79-291, NUDOCS 7911130069
Download: ML17207A556 (9)

Text

.O. BOX 529100, MIAMI, FL 331S2

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j FLORIDA POWER II LIGHT COMPANY r

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October 16, 1979 L-79-291 Mr. James P. O'Reilly, Director, Region II Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: RI I: RWZ 50-335/79-20 Florida Power 8 Light Company has reviewed the subject inspection report and a response is attached.

There is no proprietary information in the report.

I Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/MAS/cph Attachment cc: Harold F. Reis, Esquire VQZX X SII 06 $

PEOPLE... SERVING PEOPLE

4 Jj 0 ATTACHfiE NT Re: RII:RWZ 50-'335/79-20

~Findi n A As required by Technical Specification 4.6.6.1.b, the Shield Building Ventilation System (SBVS) must be tested in accordance with ANSI N510-1975,

."Testing of Nuclear Air Cleaning Systems". Sections 8 and 9 of ANSI N510 are prerequisites to Section 10 and 12, and must be completed whenever the system is modified.

Contrary to the above, the SBVS was modified by the addition of two 30 kilowatt heaters in April through tune 1978. The prerequisite tests of Section 9 of ANSI N510 have not been performed although they are required.

Res onse A As a result of the findi ng, we have performed a complete test of the Shield Building Ventilation System (SBVS). In addition to the Surveillance Requirements of Technical Specification 4.6.6. 1, the test included the "prerequisite" cited in the finding. The testing was performed on August 27, 1979, and demonstrated that the plant is still in ccmpliance with the Specificat'ion. The additional testi ng was performed to eliminate any question regarding the operability of the SBVS, and does not constitute concurrence with the findi ng. All test data are available for review at the plant site.

Based on the following information, we request that the finding be re-classified as an open-item that has been resolved by additional testing:

(1) The finding does not represent a direct violation of a Technical Specification. Rather, it is written against a "prerequisite" to a test procedure in ANSI N510-1975, which is referenced in Specification 4.6.6. 1 as the method of performing various surveil lances. Thus, the finding is based on a "third-tier" preference that should not have the same weight as a Technical Specification.

(2) During the original post-modification surveillance, all Specification 4.6.6. 1 surveillance data had been properly acquired, compared against allowable limits, and found to be satisfactory.

(3) The "prerequisite" in question is intended to re-verify the adequacy of the injection and upstream sample points for the challenging agent (freon DOP) used for penetration testing. At the time of the original post-modification testing, we made a detemination, which was supported by our testing contractor, that such re-verification was not necessary because the nature of the modification (heater

installation) could not have adversely affected or invalidated previous penetration tests. The determination was based on the fact that a perforated metal diffuser plate is located immediately upstream of the new heater elements to ensure uniform flow across the elements. Since the filter assemblies are located downstream of the heaters, the diffuser plate also improves mixing and uniformity of flow into the filters. (A letter supporting our determination has been received from the testing contractor and is available for review at the plant site.)

(4) Additional testing after the I8E inspection showed that mixing had in fact been improved, thereby confi rmi ng that it was correct to have deleted such testing after the heater installation.

~Findin B As required by 10 CFR 71.12.b.l.ii, a person using a certified cask must comply with all the conditions of the license. Condition 6 of Certificate of Compliance number USA/9094/A requires that "shoring shall be placed between secondary containers...and the cask cavity to prevent movement during normal conditions of transport". Condition 6 of Certificate of Compliance number USA/9111/A requires that "shoring shall be provided in the shipping cask cavity sufficient to prevent significant movement of the packaging under normal conditions of transport".

Contrary to the above, on Narch 24, 1979 and April 14, 1979, shipment 79-1 and 79-4, using USA/9094/A and USA/9111/A, respectively, left the site with neither the need nor presence of shoring determined.

Res onse B We recognize the importance of this item and will ensur e compliance in the future. In addition, procedures and controls regarding shipping will be revised in connection with IE Bulletin 79-19. This action is expected to be completed by approximately December 31, 1979.

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~Findin C As required by 10 CFR 71.4.q, no more than 50 millicuries of group II material can be shipped in a Type A shipping cask.

Contrary to the above, on Hay 30, 1979, shipment 79-11 contained one container marked H.F.P. (defined in Appendix C to 10 CFR 71 as group II material) containing 209 millicuries of activity.

~RC The response to this item is identical to Response B.

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