ML17354B059

Responds to Violations Noted in Insp Repts 50-250/98-05 & 50-251/98-05.Corrective Actions:Section 9.3 & App 14D of Tps UFSAR Were Extensively Revised as Part of Rev 13 Update & FPL Implemented Design Basis Reconstitution Program

ML17354B059
Person / Time
Site:	Turkey Point
Issue date:	07/27/1998
From:	Plunkett T FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-250-98-05, 50-250-98-5, 50-251-98-05, 50-251-98-5, L-98-185, NUDOCS 9808050047
Download: ML17354B059 (8)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9808050047 DOC.DATE: 98/07/

8 07/27 NOTARIZED: NO DOCKET CXL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 050002 UTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F. Florida Power 6 Light Co.

RECXP.NAME RECIPIENT AFFILIATION Records Management Bxanch (Document Contxol Desk)

SUBJECT:

Responds to violations noted 3.n 3.nsp re p ts 50-250/98-05 &

- . o 50-2 51/98-05.Corrective actions:section 9.3 & App 14D of TPS UFSAR were extensively revised as part of rev 13 u p date & A FPL implemented design basis reconstitution pxogram. \

T DISTRIBUTION TITLE: General CODE o IEO 1D COPIES RECEXVED o LTR (50 Dkt)-Xnsp Rept/Notice of Vino ENCL ation ~ SIZE:

Response

NOTES:

RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 PD 1 1 JABBOUR,K 1 1 INTERNAL: AEOD/SPD/RAB 1 DEDRO 1 . 1 E NRR/DRCH/HOHB 1 1 NRR/DRPM/PECB NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT OE DXR 1 1 OGC/HDS3 RGN2 FILE 01 1 1 EXTERNAL: LXTCO BRYCE, J H NOAC 1 1 NRC PDR NUDOCS FULLTEXT 1 1 ORGANIZATION REMOVED FROM DISTRIBUTION LIST PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR 0 OR REDUCE THE NUM ION C NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTRO

'DESK (DCD) ON EXTENSION 415-2083 TOTAL,NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 17

Jui27l998 L-98-185 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: Turkey Point Units 3 A, 4 Docket Nos. 50-250/25]

~Re 1 to a Notice of Violation 98-05-01 I

Florida Power 8. Light Company has reviewed the subject notice of violation and, pursuant to 10 CFR 2.201, the required response is attached.

Ifthere are an/ questions, please contact us.

Very truly yours, T. F. Plunkett President Nuclear Division CLM Attachment cc: Regional Administrator, Region II, USNRC Senior Resident inspector, USNRC, Turkey Point Plant P8080M047 F807277 PDR ADQCK 05000250 PDR'n FPL Group company

t Attachment to L-98-185 Page 1 of 3 REPLY TO A NOTICE OF VIOLATION RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 NRC Inspection Report 98-05 Notice of Violation 98-05-01 "During an NRC inspection conducted on February 11, to March 23, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50.71{e) requires that licensees update the Final Safety Analysis Report (UFSAR) periodically, on a frequency of annually or six months aAer each refueling outage provided the interval between successive updates does not exceed 24 months. The revision must reflect all changes up to a maximum of six months prior to the date of filing. The revision submittal shall contain all the changes necessary to reflect information and analyses submitted to the NRC or prepared by the licensee per NRC requirements.

Contrary to the above, as of March 23, 1996, an important design basis parameter of the spen t fuel e pool p system as revised by License Amendment Nos. 111 and 105, issued on November 21, 1984, was not incorporated into the UFSAR as follows: the UFSAR does oes not reflect the calculated decay heat load associated with a full core off-load. This value was calculated as 35 million BTU/hour in the licensee's October 5, 1984, letter which was submitted to support issuance of Amendment Nos. 111 and 105.

This is a Severity I.evel IV violation (Supplement I)."

RESPONSE TO FINDING

1. FPL concurs with the violation.

l, Attachment to L-98-185 Page 2 of 3 I

2. Reason for the violation f 'I d 'ude the maximum calculated decay heat and calculated maximum spent fuel pool temperature parameters for the fuH core ofF-load case in the Tur ey and 4 UFSAR when revising the UFSAR for replacement of the spent fuel storage racks.

Th ese parame ter s were calculated and provid'ed, in response to NRC requests for additional information, by FPL Letters L-84-165 (dated July 2, 19 ), an (dated October 5, 1984), as supplements to the proposed license amendment safety analysis and no significant hazards consideration for the rerack project.

FPL submitted the proposed license amendment for the spent fuel storage facility (rerack amendment) by Letter L-84-71, dated March 14, 1984. This submittal included the f iy alysis which followed the guidance of the NRC position paper entitled, "OT Position for Review and Acceptance of Spent Fuel Storage and Han andlin ing ted A ril 14 1978. Upon NRC approval of Amendment Nos. 111/105 to increase the orage ccapacity of the Turkey Point spent fuel pools, FPL prepare t e sstorage re ared thee UFSAR update for the plant modification. The safety analysis submi tted e b y letter L-84-71 was used exclusively to prepare the update. The supplemental information provided in letters L-84-165 and L-84-264 regarding the full core off-load was overlooked and not integrated into the UFSAR update.

The oversight is considered to be a personnel error caused by the engineering organization contractedtoup d atet h e UFSAR, following implementation of the r'evised spent fuel rack design in 1986.

3. Corrective steps which have been taken and the results achieved:

a) Section 9.3 and Appendix 14D of the Turkey Point UFSAR were extensively f

revise d as pa rt o th e Revision 13 update. The discrepancies identified in Inspection R epo rt 96-02 w corrected. Revision 13 of the Turkey Point UF SAR

- were was submitted to the NRC by FPL letter L-96-248, dated October 7, 1996.

Startin in 1985 and continuing until 1989, FPL implemented a design basis reconstitution program for selected safety related and non-safe y re y Turkey Point. The output of this process was the issuance of the Turkey Point Design asis'ocuments D ocumen s (DBDs) in 1989. The DBDs have since been periodically d d a roximately the same frequency as the UFSAR. Since 1 has made improvements to the overall UFSAR updating process to enhance e a its accuracy. As part of these improvements, each engineering design change or stand-alone safety evaluation is required to address the impact on the UFSAR as f

part of the h engmeeringg cchangeprocess an and includeproposed changes tot e

Attachment to L-98-185 Pag~e3 of3 UFSAR with the issuance of each design change package, as applicable. These changes have provided a comprehensive mechanism for inserting change information into the UFSAR.

c) In 1997, a review was conducted to assess the adequacy of the programmatic controls in use to maintain the plant licensing basis. The review was performed using the approach outlined in NEI 96-05, "Guidelines for Assessing Programs for Monitoring the Licensing Basis." No programmatic weaknesses were identified as a result of this review.

d) As described in PPL letter L-97-143, PPL has undertaken a multi-discipline review of the UFSAR to identify and correct remaining discrepancies. This review is expected to be complete by October 18, 1998.

e) In accordance with the UFSAR updating process, correspondence between FPL and the NRC is reviewed to ensure that changes in plant design bases, design criteria, restrictions, and other licensing commitments as documented in NRC related correspondence are captured in the UPSAR updates.

a) Items 3b), 3c), 3d), and 3e) above describe the corrective actions that have been taken, and are being taken, to prevent recurrence of the condition identified in this notice of violation.

b)

'o address the potential generic implications of a failure to capture amended design information into the UFSAR, a sample population of PPL submittals made in response to NRC Request for 'Additional Information (RAIs) will be reviewed.

The review will focus on those RAIs submitted prior to 1985, when the programmatic changes described in item 3b) were started.

The date when full compliance was or will be achieved:

Full compliance was achieved on October 7, 1996, when PL letter L-96-248 transmitted Revision 13 of the Turkey Point UFSAR to the NRC in accordance with 10 CFR 50.71(e). That revision included all of the supplemental information generated by the 1984 rerack license amendment. It also resolved the various discrepancies identified in Inspection Report 96-02. As 'of Revision 13, the'UPSAR includes all the information and parameters that support the 1984 rerack license amendment (including full core ofF-load) as discussed in the notice of violation and in this reply.