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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) ML17354B2061998-12-0909 December 1998 Informs That Request for Exemption Specified in Section II.B.3 Will Not Be Needed Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg ML17354B1981998-11-25025 November 1998 Forwards Scope & Objective for 1999 Plant Annual Emergency Preparedness Exercise.Objectives Developed in Conjunction with State & Local Govts.Exercise Scheduled for 990210 1999-09-09
[Table view] |
Text
PR.IC)R.j: EV 1 CCELERATED RIDS PROCESSING)~
REGULATOR~~ INFORMATION DISTRIBUTION~STEM (RIDS)
ACCESSION NBR:9408160213 DOC.DATE: 94/08/05 NOTARIZED: YES DOCKET g FACIL:50-,2501'urkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-'251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to 940218 ltr request to amend util TS 6 RAI to support technical review of proposed license amends.NRC questions encl.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 1 PD2-2 PD 1 1 CROTEAU,R 2 2 INTERNAL: NRR/DE/EELB NRR/DRCH/HICB 1
1 1
1 NRR/DORS/ONDD NRR/DRPW 1,
1 1
1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 0 OGC/HDS3 1 0 FIL 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 .1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACTTHE DOCUMENT CONTROL DESK, ROO!iI Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLIS'rS r'OR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 14
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L-94-119 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DE C. 20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos. '50-250 and 50-251 Request for Additional Information (RAI)
Proposed License Amendments Administrative Controls Audit Frequencies and Im lementation of Generic Letter 93-07 By letter L-94-017, dated February 18, 1994, Florida Power and Light Company (FPL) submitted a request to amend Turkey Point Units 3 and 4 Technical Specifications'n a conference call between the NRC and FPL, the staff requested additional information to support the technical review of the proposed license amendments. The response to these NRC questions is enclosed.
Should there be any questions, please contact us.
Very truly yours, T. F. Plunkett Vice President Turkey Point Plant Attachments TFP/RJT/rt CC: S. D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services
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STATE OF FLORIDA )
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COUNTY OF DADE )
T. F. Plunkett being first duly sworn, deposes and says:
That he is Vice President Turke Point Nuclear Plant, of Florida Power and 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 his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
T. F. Plunkett Subscribed and sworn to before me this
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day of 1994. jas:es LA'Ot8MSSQN g (g gyp~
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NOTARY PUBLIC, in and for the County of Dade, State of Florida My Commission expires ~ ~l<
Commission No. A~Ofo T ~ F. Plunkett is personally known to me.
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FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 RESPONSE TO NRC UESTIONS ON THE PROPOSED LICENSE AMENDMENTS:
ADMINISTRATIVE CONTROLS AUDIT FRE UENCIES AND IMPLEMENTATION OF GENERIC LETTER 93-07
L-94-119 Enclosure Page 1 of 6 RESPONSE TO NRC UESTIONS In a conference call between the NRC and FPL, the staff requested additional information to support the technical review of the proposed license amendments. The response to these NRC questions is enclosed.
uestion:
Confirm that the current Turkey Point Emergency and Security Plans, includes requirements of an annual audit and implementing procedures.
Res onse:
Florida Power and Light (FPL) Company acknowledges that the current Turkey Point Emergency and Security Plans, include the requirement of an annual audit, in accordance with Parts 50 and 73 of Title 10 of the Code of Federal Regulations. In addition the Emergency and Security Plans include provisions to maintain implementing procedures of these programs.
uestion:
A January 1994 Safety Evaluation approved removal of fire protection from the Turkey Point Technical Specifications (TS), in accordance with GL 88-12. GL 88-12 states that the existing administrative control requirements related to fire protection audits would be retained. However, the subject TS will change the existing administrative control requirements. Provide additional justification to support the proposed change.
Res onse:
In FPL's proposed license amendment submittal (L-94-017, dated February 28, 1994), FPL proposed deleting the frequencies specified in the Technical Specifications for the Company Nuclear Review Board (CNRB) Audits. The periodicity of these audits would be controlled as described in the FPL Topical Quality Assurance Report (FPLTQAR). The minimum audit frequency for any activity,would be established as biennial unless the audit is oth'erwise required to be performed more frequently in accordance with the Technical Specifications, Code of Federal Regulations or other licensing commitments.
In the area of fire protection, Turkey Point's Technical Specifications currently address three different audit intervals.
These intervals include: (a) an annual audit of the fire protection equipment and program implementation; (b) a biennial audit of the fire protection programmatic controls including implementing procedures; and (c) a triennial audit of the fire protection equipment and program implementation using an outside independent fire protection consultant. In FPL's proposed license amendment submittal, FPL proposed changing the audit interval from annually to a biennial frequency, maintaining the current biennial audit and performing the
L-94-119 Enclosure Page 2 of 6 triennial audit on a more frequent basis than currently required by the Technical Specifications.
FPL justified the proposed change by stating that the proposed change would allow the specific audit frequency to be adjusted based upon programmatic performance up to a maximum of two years. The fire protection program performance is, and will continue to be, assessed through self-assessments, management reviews, performance evaluations and audits in related areas, and other trend indicators. Increasing the audit interval frequency to biennially (2 years) will not impact compliance with provisions of the Technical Specifications, but will provide for more meaningful audits of those activities conducted less frequent and allow for additional focus on operational activities.
The resultant comprehensive audit of fire-protection equipment, programmatic controls including implementing procedures, and program implementation will be performed by a qual'ified audit team which will include at least a lead auditor from FPL's Nuclear Assurance department and an outside independent fire protection consultant (presently required only for a triennial audit). The minimum audit frequency will be biennial; however, more frequent audits may be conducted based on audit results. The proposed amendments do not alter the technical or Quality Assurance (QA) requirements which are required to be audited to verify compliance with Turkey Point's fire protection program. In fact, the effectiveness of the audit program will be enhanced by the increased utilization of outside expertise, and management flexibility for directing QA resources will be improved.
The administrative controls for the Fire Protection Program for Turkey Point Units 3 and 4 are defined in Section 6.0 of the Turkey Point Technical Specifications. The existing administzative controls for Turkey Point's Fire Protection Program continue to maintain requirements for the training program for the fire brigade, audits of the fire protection, and programmatic controls including the implementing procedures and program implementation utilizing outside independent fire protection consultants. FPL does not believe that the change from an annual to a biennial audit frequency changes the intent of the administrative control requirements, since all Fire Protection Program audit activities currently being conducted will continue.
Quality Assurance's oversight of the fire protection program is comprised of various layers of reviews (including Audits, Performance Monitoring (PMONs) Reports, surveillances, and procedure reviews) and consists of continuous rathez than discrete monitoring. Continuous monitoring of the fire protection program is ensured through the use of PMONs, surveillances and review of Condition Reports, as discussed below.
The top tier of QA oversight is the formally-scheduled audit. Quality Assurance views this type of auditing as "discrete" monitoring. The Quality Assurance philosophy is to shift away from discrete monitoring
L-94-119 Enclosure Page 3 of 6 (evaluation of activities that may occur during the scheduled audit),
and to shift to continuous monitoring (evaluation of activities when they occur) . The proposed change in the frequency of this discrete monitoring will be offset by the increase in continuous monitoring with no reduction in the effectiveness of QA oversight.
FPL's QA program would require increased oversight of the fire protection program based on the following requirement; o Topical Quality Assurance Report (FPLTQAR 1-76A), TQAR 18.0, "Audits", Section 18.2.2 states that "regularly scheduled audits shall be supplemented , as required to cover unforeseen events or changes in requirements."
The relocation of Fire Protection from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR) would constitute a change in requirements that 'would necessitate additional QA oversight. The March 1994 FPL Quality Assurance Audit reviewed the Fire Protection Program, following the relocation of the fire protection requirements from the TS, and found the program satisfactory.
Another level of zeview by Quality Assurance is ensured thxough the procedure review process. This review process is detailed in the following program documents:
o FPLTQAR 1-76a, TQAR 2.0, "Quality Assurance Program," Section 2.2.2, states "Quality Instructions shall be reviewed by the Quality Assurance Department at each revision."
o Plant Procedure, O-ADM-100, "Procedure Preparation, Review, and Approval", Section 3.1 7, states "Ensuring Quality Assurance (QA)
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receives a copy of the draft upgraded/new [Quality Instruction] QIs and Administzative Procedures for the following:
- 1. To review all draft upgraded/new QIs and Administrative Procedures prior to [Plant Nuclear Safety Committee] PNSC approval in accordance with the Quality Assurance Manual."
As the fire protection program requirements are defined in Administrative Procedures, Quality Assurance review of any proposed changes should identify any potential reductions in commitments relative to fire protection.
Continuous monitoring of fixe protection activities aze ensured through the use of PMON reports and surveillances, both of which are used as major inputs for the formally scheduled audit. The use of PMONs and surveillances ensures that critical evolutions are monitored and provides early warning of performance issues. A PMON is a limited scope audit based on the monitored activity. As an example, a PMON may be used to verify that the plant's procedures comply with UFSAR/Appendix R requirements, while a surveillance would be used to verify that the plant is properly implementing those procedures. A combination of PMONs and surveillances may be used during the two
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L-94-119 Enclosure Page 4 of 6 years leading up to the formally scheduled audit to cover such activities as fire brigade training, transient combustible controls, hot work permits, or fire detection.
Additionally, surveillances are scheduled through the Turkey Point Quality Department Quality Instruction (QI 10.1), "Inspections and Surveillances". Section 5.2.2 of QI 10.1, states that "surveillances shall be scheduled to cover the activities listed in Appendix A on a periodic basis." Appendix A of QI 10.1, item 1.1 identifies fire protection as an activity requiring periodic surveillances. The surveillance schedule presently requires fire pzotection to be reviewed on a quarterly basis.
This surveillance can be focused to look at the recent changes in fire protection as appropriate.
The last tool available for Quality Assurance is the review of Plant Condition Reports. Condition Reporting is the plant-wide process to report any deviation, procedure violation, etc. Approximately 1000 Condition Reports (CRs) were generated at Turkey Point in 1993.
Presently, CRs are reviewed on a daily basis by a plant oversight group for potential impact. Quality Assurance is part of this oversight group and applicable CRs may be funneled to the responsible QA auditor for follow-up.
Summary FPL's Nuclear Assurance department will continue to direct its resources during the two year interval leading up to and including the formal audit to ensure the following activities are covered:
Verification that necessary procedures exist and comply with baseline QA standards, Regulatory Guides, Technical Specifications, Updated Final Safety Analysis Report (UFSAR),
NUREGs, Generic Letters, etc.,
Analysis of all Licensee Event Reports (LER's), problem reports, in-house event reports, NRC Inspection Reports, etc., associated with the functional area for trends and input to the audit, Review of the effectiveness of self-assessment activities, Assessment of the effectiveness of corrective actions taken in response to Quality Assurance/Quality Control (QC) activities since the last audit, Review and utilization of QA/QC activity results since the last audit, Verification of implementation of requirements not verified in the interval leading up to the formal audit, Verification of the effectiveness of utilizing operating experience to include INPO Significant Operating Experience
L-94-119 Enclosure Page 5 of 6 Reports (SOERs) and INPO Significant Event Reports (SERs), and Overall review of the effectiveness of fire protection.
This approach will ensure that critical evolutions are monitored, provide early warning of performance issues, and provide more meaningful input to the outside fire protection consultant.
uestion:
With respect to the Fire Protection Program, FPL should provide more technical bases ox justification fox the amendment change. FPL stated that the audit frequency will be adjusted based upon programmatic perfonnance and will be assessed through pexformance evaluations and trend indicators. FPL should provide additional data and information that indicates that the audit frequency can be extended with its application. In addition, FPL wants to take credit for enhancements as justification for the proposed amendment. In fact, the enhancements, for example, increased utilization of outside expertise, are allowed by the existing TS. Therefore, they are not enhancements.
Res onse:
Turkey Point's plant performance has shown a continually improving Fire Protection Program that justifies modifying the audit frequency to biennially, A review of NRC Inspection Reports and FPL QA Audit Reports over the past 5 years (1989 present) supports this conclusion.
NRC Ins ection Re orts During this time period, there has been only one cited violation.
Beginning with a major NRC inspection of the 10 CFR 50 Appendix R requirements (Inspection Reports 50-250/89-37 and 50-251/89-37) which identified no violations; followed by a review of the Fire Protection Pxogram and restoration efforts after Hurricane Andrew (Inspection Repozts 50-250/92-23 and 50-251/92-23) that identified 4 strengths and 1 weakness; and culminating in the most recent SALP report (Inspection Reports 50-250/93-03 and 50-251/93-03) that stated:
"The results indicated that the fire protection program improved over the previous SALP period..",
and resulted in a SALP 1 rating; all justify fire protection as an area that would qualify for a longer audit interval.
L-94-119 Enclosure Page 6 of 6 FPL's A Audit Re orts Beginning in 1989 and proceeding through 1994, the six FPL QA audit reports of Turkey Point's Fire Protection Program did not identify any significant programmatic or implementation issues. The 1993 triennial audit which utilized an outside independent fire protection consultant identified several strengths, which included: timeliness of repairs to the fixe protection system following Hurricane Andrew, fire brigade response to an unannounced back-shift drill in a contaminated area, and the knowledge level of site and corporate personnel. The 1994 audit has not identified any new or repeat problems.
In addition, FPL's commitment to utilize an outside independent fire protection consultant every two years as opposed to every three years as currently required by Turkey Point's Technical Specifications, will also ensure proper oversight of fire protection activities.
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