ML17212B444

Responds to NRC 820108 Ltr Re Violations Noted in IE Insp Rept 50-335/81-30.Does Not Concur W/Violation,However Surveillance Procedure for Local Leak Rate Testing of Containment Isolation Valves Will Be Revised

ML17212B444
Person / Time
Site:	Saint Lucie
Issue date:	02/12/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17212B442	List: IR 05000335/1981030 ML17212B444
References
L-82-52, NUDOCS 8203170332
Download: ML17212B444 (6)

Text

FLORIDA POWER II LIGHT COMPANY

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February 12, 1982 L-82-52 Mr. James P. O'Reilly Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: St. Lucie Unit 1 Docket No. 50-335 IE Ins ecti.on Re ort 81-30 Florida Power 8 Light Company has reviewed the subject inspection report and a response is attached.

There is no proprietary information in the report.

Very truly yours, Robe t E. Uhrig President Advanced Systems & Technology REU/PLP/mbd Attachment cc: Harold F. Reis, Esquire

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I ATTACHMENT Re. St. Lucie Unit I Docket No. 50-335 IE Ins~ection Re or t 81-30

~Findin Technical Specification 6.8.l.c requires that written procedures shall oe established. implemented and maintained covering sur veillance and test activities of safety-related equipment.

Contrary to the above, the surveillance procedure for local leak rate testing of containment isolation valves was inadequate in that the procedure did not always provide an atmospheric vent path downstream of the valve under test, did not provide for demonstration that other pressure sources which could affect the test were in fact isolated and not leaking into the test area, and did not address alI valves requiring alignment in order to conduct a valid test.

Response

FPL does not concur with this finding for the following reasons:

By plant desi gn, there are no available vent paths in the indicated cases. In these cases there is, however, a large (admittedly unvented) volume which would have to be filled by the leak tester to give false results. The filling process would itself give unacceptaole leakage indication.

If this same volume (which is vented to 0 psig before testing) were being pressurized by outside leakage, large leak rates would make venting impossible, small leak rates would have no effect and the probabi'lity of a leak rate just the size to give false results is very low. Valve alignments to isolate test boundaries are in fact covered by the plant tagout procedure which requires full isolation for personnel and equipment protection.

Finally when some of the disputed systems were retested with piping physically opened or outside sources verified isolated the results generally did not change at all. In one case the slight increase observed was within the accur acy of the test method.

We have always followed the practice of doing this testing under the direct supervision of a trained engineer. We do not use maintenance personnel or even technicians for the express reason of ensuring proper, valid testing. This valid testing is best demonstrated by the fact that results of both the initial and fi rst periodic Integrated Leak Rate Test at St. Luci e were a factor of 10 below the allowable limit.

Again, we do not feel the procedure, done by trained engineers in conjunction with other procedures (such as the tagout procedure) is inadequate.

To preclude future problems in this area, we do agree to revise the procedure, before the next performance, to more clearly address the disputed areas.

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STATE OF FLORIDA )

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J. E. Vessely being first duly sworn, deposes and says:

That he is Director, Nuclear Affairs ~

of Florida Power Light Company, the herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his'knowledge, information, and belief, and that he is authorized to execute tne document on behalf of said J. E. Vessely Subscribed and sworn to before me this I ~,"'ay of NOTARY PUBLIC in and for the County of Dade, State. of Flora.da flotary Pub!ic, State of Florida at Large

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~ My CommMon Exp!roe October 30, 1983

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