ML17346B133

Forwards Insp Repts 50-250/85-23 & 50-251/85-23 on 850515-0605 & Notice of Violation & Proposed Imposition of Civil Penalty Based on Failure to Review Mod of Spent Fuel Pit Piping as Unreviewed Safety Question.W/O Notice

ML17346B133
Person / Time
Site:	Turkey Point
Issue date:	08/20/1985
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Williams J FLORIDA POWER & LIGHT CO.
Shared Package
ML17346B134	List: IR 05000250/1985023 ML17346B133
References
EA-85-080, EA-85-80, NUDOCS 8509040306
Download: ML17346B133 (8)

See also: IR 05000250/1985023

Text

AUG 20 1986

Docket Nos.

50-250

and 50-251

License

Nos.

DPR-31

and

DPR-41

EA 85-80

lorida Power and Light Company

~

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~

~

~

~

.ATTN:

Mr. J.

W. Williams, Jr.

Group Vice President

Nuclear Energy Department

P. 0.

Box 14000

Juno

Beach,

FL

33408

Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED

IMP

ON OF CIVIL PENALTY

(NRC INSPECTION

REPORT

NOS. 50-250/ 5-23

ND 50-251/85-23)

This refers to the inspection

conducted

by this office during the period

May 15-

June 5, 1985, of activities authorized

by

NRC Operating License

Nos.

DPR-31

and

DPR-41 for the Turkey Point Units 3 and

4 located

near

Homestead,

Florida.

During

this inspection,

a violation of an

NRC requirement

was identified by the

NRC

~

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resident inspector.

The finding was discussed

with those

members of your staff

identified in the enclosed

inspection report and at an Enforcement

Conference

held in the

NRC Region II Office on June 4, 1985.

The violation described

in the enclosed

Notice of Violation and Proposed

Imposition

of Civil Penalty involves the failure of your staff to determine whether

a

modification to the spent fuel pits'SFP)

piping created

an unreviewed safety

question.

This failure resulted in the operation of SFP

systems for several

years in a different manner

than that described

in the Final Safety Analysis

Report

(FSAR).

We have concluded that operating

the

SFP system in this improper

and unanalyzed configuration created

an unreviewed safety question.

It is of concern to us that you failed to recognize for an extended

period of

time that operation of the

SFP systems

in this manner violated the design parameters

for normal

SFP systems

operation.

Modified safety analysis reports

submitted to

the

NRC in 1976 and

1984 to support Turkey Point Technical Specification

changes

did not identify the modification to SFP

systems

operation.

Several

design

changes

were completed

on these

systems

that also failed to identify that

SFP systems

operation

was outside of the normal operating

parameters.

Although an internal

Florida Power and Light letter to the Plant Manager identified this problem in

September

1984, it was not until you were informed by NRC Region II management

on May 29,

1985, of our concerns

on this matter that you initiated corrective

actions.t

Other problems involving SFP

systems

operation

were also noted during this

inspection.

By aligning the

SFP cooling

pump suction via the four-inch diameter

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SFP drain path instead of the required eight-inch diameter

SFP upper suction

path,

SFP cooling

pump flow was greatly reduced,

resulting in higher than normal

operating

temperatures

in the

SFP systems.

The higher operating

temperatures

frequently resulted in control

room temperature

monitors continually alarming

and,

as

a result providing no meaningful indication.

Level floats were also

found to have stuck in the normal level position, causing

the level alarm in the

control

room to be inoperable.

In addition, since the

SFP design water level

has not been maintained,

personnel

shielding

has not been provided

as required

by the analysis

described

in the

FSAR.

This is important when considering that

the radiation detectors

in the

SFP area

were usually not reliable

and have

required extensive

maintenance.

To emphasize

the importance of determining whether

changes

in design or normal

operating practices

create

unreviewed safety questions,

I have

been authorized,

after consultation with the Director, Office of Inspection

and Enforcement,

to

issue

the enclosed

Notice of Violation and Proposed

Imposition of Civil Penalty

in the amount of One Hundred Thousand Dollars ($100,000) for the violation

described

in the enclosed

Notice.

In accordance

with the "General

Statement

of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C

(1985), the violation described

in the enclosed

Notice has

been characterized

as

a Severity Level III violation.

The base civil penalty .for this type of

violation is

$50,000.

However, the base civil penalty in this case

has

been

increased

by 100 percent.

This action was taken

because

the duration of the

violation provided opportunities to identify and correct the problem and because

of prior poor performance

in the area of operation in accordance with'esign

requirements

(Reference

EA 84-121; Operation of the Intake Cooling Mater Structure

in violation of Technical Specification requirements).

You are required to respond to this letter and you should follow the instructions

specified in the enclosed

Notice when preparing your response.

In your response,

you should

document the specific actions

taken

and any additional actions

you

plan to prevent recurrence.

After reviewing your response

to this notice,

including your proposed

corrective actions,

the

NRC will determine whether

further

NRC enforcement

action is necessary

to ensure

compliance with NRC

regulatory requirements.

In accordance

with Section

2.790 of the NRC's "Rules of Practice,"

Part 2,

Title 10,

Code of Federal

Regulations,

a copy of this letter and its enclosures

will be placed in the

NRC Public Document

Room.

The responses

directed

by this letter and the enclosed

Notice are not subject to

the clearance

procedures

of the Office of Management

and Budget issued

under the

Paperwork

Reduction Act of 1980,

PL 96-511.

Sincerely,

Encls:

(See

page 3)

J. Nelson Grace

Regional Administrator

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Enclosures:

1.

Notice of Violation and Proposed

Imposition of Civil Penalty

2.

Inspection Report Nos. 50-250/85-23

and 50-251/85-23

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w/encls:

. M. Wethy, Vice President

Turkey Point Nuclear Plant

vC'. J. Baker, Plant Manager

Turkey Point Nuclear Plant

vK. J. Acosta, Plant

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Superintendent

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