ML17342B199
| ML17342B199 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/26/1988 |
| From: | Conway W FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0452, RTR-NUREG-452 L-88-94, NUDOCS 8803010118 | |
| Download: ML17342B199 (7) | |
Text
ACCEKERATED DIS IBUTJON DEMONSYR ON SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
L ACCE(SION NBR:8803010118 DOC.DATE: 88/02/26 NOTARIZED: NO FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Advises that util will revise current Tech Specs using STS for guidance rather than submit amends to procedures.
DISTRIBUTION CODE:
A001D COPIES RECEIVED:LTR ENCL i SIZE:D TITLE: OR Submittal:
General Distribution NOTES:
DOCKET 05000250 05000251 RECIPIENT ID CODE/NAME PD2-2 LA EDISON,G INTERNAL: ARM/DAF/LFMB NRR/DEST/CEB8H7 NRR/DEST/RSB 8E PP~
B12 ILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME PD2-2 PD NRR/DEST/ADS7E4 NRR/DEST/MTB 9H NRR/DOEA/TSB11F OGC 15-B-18 RES/DE/EIB NRC PDR COPIES LTTR ENCL 5
5 1
1 1
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1 1
0 1
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A TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 17
P. O.
14000, JUNO BEACH, FL 33408-0420
+Miff/
FXBRIRt, 2 6 1988 L-88-94 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Gentlemen:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Technical S ecification Revision On January 28,
- 1988, FPL met with members of the NRC Staff to discuss concerns as outlined in an NRC letter dated January 15, 1988 regarding the use by Turkey Point Plant operators of the "Interim Technical Specifications (ITS)."
The ITS were issued internally by FPL to reflect the more conservative of the requirements in the current approved Technical Specifications (CTS) and the proposed Revised Technical Specifications (RTS) submitted to the NRC by FPL on September 29, 1986 and November 28, 1986.
As part of the Turkey Point Performance Enhancement Program (PEP),
FPL committed in April 1984 to review, and implement where appropriate, the philosophy and guidance of the Standard Technical Specifications (STS),
NUREG-0452, in the development of new procedures, and to incorporate (within certain limitations) the requirements of the STS in future proposed amendments to the CTS.
FPL subsequently decided to completely revise the CTS using the STS for guidance, rather than submit individual amendments.
The ITS were developed as part of Phase II of PEP Project 10, the Technical Specification Upgrade Project for trial implementation of the RTS requirements, within the limitations of the CTS, until the RTS were issued.
The ITS were placed in the control room to allow the operators to:
TCG.008;TSR
,8803010118 880226 PDR ADOCK 05000250
,P
1I V
a e
Nuclear Regulatory Commission L-88-94 Page Two 0
become accustomed to the change of format (i.e. limiting conditions for operation (LCO),
applicability, action statements, and surveillance requirements),
o become familiar with the surveillance requirements that were being added to the plant procedures, o
compare the CTS LCO action statements with the proposed RTS action statements as shown in the ITS (and follow the most restrictive),
and o
to identify changes that would need to be made prior to approval of the RTS by the NRC.
Explicit guidance in the form of a training brief was provided to the operators regarding use of the ITS.
That guidance specifically stated that the CTS governed operation of the plant.
When an LCO could not be met, the operators were to compare the CTS and ITS, and adhere to the ITS action statement if it was as restrictive or more restrictive than the CTS requirement.
If the ITS action requirement was so restrictive that it jeopardized the unit s operation (i.e. required an immediate unit shutdown vs.
a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shutdown),
the operators were to contact the Operations Supervisor or the Operations Superintendent for direction. If an ITS requirement was found to be less restrictive than a
CTS requirement, it was not to be
- followed, and the Operations Supervisor or Operations Superintendent were to be informed.
Since the ITS were developed to reflect as restrictive or more restrictive requirements than the
'concerns regarding their use as a
guidance document in implementing the requirements of the revised plant operating procedures.
To remove any potential for confusion on the part of the operators regarding the use of the ITS vs.
CTS in making interpretations and judgments regarding compliance, a
formal plant procedure is being developed incorporating the ITS as an attachment and providing guidance on its use.
This procedure is scheduled to be issued by April 1, 1988.
TCG.008.TSR
Nuclear Regulatory Commission L-88-94 Page Three In the interest of minimizing the time to issuance of the
- RTS, FPL will continue to support any meetings with your staff necessary to complete the RTS review.
If you have any further questions regarding this matter, please call us.
Very truly yours, W. F.
Con ay Senior Vice President Nuclear WFC/TCG/dh CC Steven A.
- Varga, Director, Division of Reactor Projects I/II, NRR Dr.
J.
Nelson
- Grace, Regional Administrator, Region II, USNRC D.
R.
- Brewer, NRC Senior Resident Inspector, Turkey Point Plant TCG.008.TSR