ML19289F321

Urges Repair of Steam Generator Tube Plugging.Alternate Methods of Repair to Be Considered Are Lower Section Replacement & Place Retubing.Nrc to Make Early Determinations of Repair Reviews by 781015

ML19289F321
Person / Time
Site:	Turkey Point
Issue date:	09/20/1977
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Stello V Office of Nuclear Reactor Regulation
Shared Package
ML19289F320	List: ML19289F319 ML19289F321
References
L-77-296, NUDOCS 7906070226
Download: ML19289F321 (2)

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U p' kmm FLORt0 A PCWER & LIGHT CD/PAJ4Y September 20, 1977 L-77-296 s

Office of Nuclear Reactor Regulation Attn: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stello:

Re: Turkey Point Units 3 & 4 Docket Nos. 50-250 and 50-251 Steam Generator Repair Report During the pas' two years, Florida Power & Light Company has on occasienn sht._ down Turkey Point Unit 4, and to a lesser extent Unit 3, for steam generatcr inspections and tube plugging.

If the total numer of steam generator tubes plugged continues to increase, it could become necessary to limit the output of the units. Accordingly, Florida Power & Light Company has deter-mined that a loss in the gent. rating capacity of the unito may make it desirable to undertake a maintenance program to repair the Turkey Point Unit 3 and 4 steam generators.

Two alternate methods of repair are being considered: lower section replacement and in place retubing. The lower section rep. scement is described in some detail in' the attached Steam 1

Generator Repair Report, which is being forwarded to you for your information. In place retubing is still undergoing review.

If retubing proves feasible and practical, we will supply a description of this alternative for your information.

The Turkey Point Plant Nuclear Safety Ccertittee (PNSC) and the Florida Power & Light Company Nuclear Review Soard (CNR3) have reviewed the steam generator repair described in the attached report. They have concluded that the repair of the steam genera-tor is most appropriately classified as a repair and not an alteration or a change to the f acility. However, since the repair involves minor modifications to steam generator internals to achieve state-of-the-art performance, eva.luation of t? e modifi-cations is required in acccrdance with 10 CFR 50.59. The PNSC and CNR3 have concluded that these modifications are not safety-related, and do not involve an unreviewed safety cuestion or a change in the facilities' Technical Specifications.

7906070224 Ph > , e SERVINC PECPLE

Office of Nuclear Reactor Regulation Attn: Mr. Victor Stello, Director Division of Operating Reactors Page Two The PNSC and CNRB have also reviewed this repair activity, in all aspects, and have concluded that it does not involve an unreviewed safety question and that a modification of the facilities' Technical Specifications is not required. The bases for this determination are provided in the attached report which evalu'ates all safety related aspects of the repair ef fort.

Thus, this repair, in accordance with the provisions of 10 CFR 50.59, does not require prior NRC approval.

It is the responsibility of Florida Power & Light Company, as the holder of operating licenses for Turkey Point Units 3 and 4, to perform those repairs which it deems necessary for. the con-tinued safe and reliable generation of electric power for its custcmers. Since this repair requires substantial advance plan-ning and involves a considerable cost, it is important that the NRC make early determinations with respect to any review it be-lieves is required in this matter. Therefore, Florida Power &

Light Company requests that the Nuclear Regulatory Commission Staff inform us what prior review, if any, they will require in this matter. This determination should be made by october 15, 1977, so as not to impact the earliest date we could commence the repair which is October 15, 1978.

Very truly yours, l4.At 7x ,

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Robert E. Uhrig Vice President 2233 085 .

REU/GDW:ltm Attachment cc: J. P. O'Reilly, Director, Region II Robert Lowenstein, Esq.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING SCARD In the Matter of: ) Dochet Nos. 50-250-SP

) 50-251-SP FLORIDA POWER & LIGHT CCMPA'FI )

)

(Turkey Point Nuclear Genera- )

ting Units Nos. 3 and 4) )

)

)

AFFIDAVIT OF G. D. NHITTIER STATE OF FLORIDA )

) SS:

COUNTY OF DADE )

BEFORE ME personally appeared G. D. Whittier, whc being first duly sworn, deposes and says:

1. I am employed by Florida Power & Light Company as Senior Licensing Engineer and the facts contained in this Affidavit are true and correct based upon my own personal knowledge. As part of my duties I am responsible for obtaining the licenses re-quired by the Nuclear Regulatory Commission for the proposed steam generator repairs at Turkey Point Units 3 and 4.

2. I have reviewed a copy of a letter dated February 9, 1979 from Mark P. Oncavage to the Nuclear Regulatory Commission which states that the Licensee's letter of September 20, 1977 was not available for inspection at the Local NRC Public Document Room at the Environmental and Urban Affairs Library at Florida Inter-national University, Miami, Florida, until January 22, 1979.

2233 086

3. On February 15, 1979, after I reviewed the letter, I personally visited the Local Public Document Rocm at the Environmental and Urban Affairs Library at Florida International University and personally spoke with the librarian there, Ms.

Rene Daily. She told me that no one had visited the library and asked to see the material on file referred to in the Federal Register notice until approximately a month or so before my visit.

At that time, in January 1979, she had been unable to locate a copy of the September 20, 1977 letter. She requested that a duplicate copy be sent frcm the NRC Public Document Room in Nashington, D. C.

In reponse to her request, a duplicate copy of the letter dated September 20, 1977 was received by the Local Public Document Room January 22, 1979.

4. On February 15, 1979, I located the original volume of the Steam Generator Repair Reporc which had been date stamped received by the Local Public Document Room October 4, 1977. This is the report which described the proposed repair program and which had been transmitted to the NRC by the letter of September 20, 1977.

5. On March 6, 1979, I visited the Local Public Document Room and located the letters of transmittal and revisions for each of the Amendments to the Steam Generator Repair Report submitted to the NRC by Florida Power & Light Company which had been date stamped received by the Local Public Document Room on the follow-ing dates:

2233 087

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Date of Receipt by Local Public Docu-

. ment Room of Letter Number of Transmittal of Transmittal &

Revision Letter Date Revision Revision 1 December 20, 1977 January 3, 1978 Revision 2 March 7, 1978 March 20, 1978 Revision 3 April 25, 1978 May 11, 1978 Revision 4 June 20, 1978 July 11, 1978 Revision 5 August 4, 1978 August 18, 1978 Revision 6 January 26, 1979 February 12, 1979

6. On March 7, 1979, I visited the Local Public Document Room and located the " Notice of Proposed Issuance of Amendments to Facility Operating Licenses" published December 13, 1977 by the NRC in the Federal Register which had been date stamped received by the Local Public Document Room on January 9, 1978.

7. If a person had been unable to locate the September 20, 1977 letter referred to in the notice at the Local Public Document Room prior to January 13, 1978, the librarian could have obtained a duplicate copy as she in fact did in January 1979.

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C. D. WiiITTIER SWORM TO and SUBSCRIBED before me this r rr day of March, 1979.

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Notary Puchc, State of Florida at Large N774 A13te; g Aft C? RCTOA et (apt?

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING SOARD In the Matter of: ) Docket Nos. 50-250-SP 50-251-SP FLORIDA PONER & LIGHT COMPANY )

(Turkey Point Nuclear Genera- )

ting Units Nos. 3 and 4 )

)

AFFIDAVIT OF H. D. MANTZ STATE OF FLORIDA )

) SS:

COUNTY OF DADE )

BEFORE ME personally appeared H. D. Mantz, who being first duly sworn, deposes and says:

1. I am employed by Florida Power & Light Company (FPL).

As part of my duties, I am Project General Manager for the Turkey Point Steam Generator Repair Project. The facts contained in this Affidavit are true and correct based upon my own personal knowledge and official records of Florida Power & Light Company.

2. In 1976, a project management team was assembled by FPL to study the problem of steam generator tube degradarion at Turkey Point and to make recommendations concerning alternatives for repairs.

3. In early 1977, the team was authorized by the Board of Directors of FPL to as quickly as possible develop the capability to perform the repairs.

4. In September 1977 FPL submitted a report to the No.C which described the proposed repair program. In December 1977 the 2233 089

2-NRC informed FPL that it intended to formally review the repair plans and issue a license amendment upon completion of the review.

Notice was published in the Federal Register on Ce: ember 13, 1977 In addition to announcing the Staff's intended acrion, the notice also provided an opportunity for any person whose interest might be affected to request a hearing. No such request was made within the period provided.

5. From January 1978 to the present, FPL has worked closely with the NRC Staff in its review of the proposed repairs.

At the present time, I understand that the NRC review is almosr complete, the Staff safety evaluation is expected to be issued within a few weeks, and issuance of the proposed license amend-ments should follow shortly.

6. Pursuant to a written contract entered into in April of 1977 with Westinghouse Electric Corporation, the fabrication of the replacement steam generator lower assemblies is nearing completion. Three of the lower assemblies are scheduled to be shipped by the vendor in May 1979; the remaining three assemblies are scheduled for shipment in December 1979.

7. Although it was not possible to predict exactly when the repairs would be economically justifiable, or otherwise desirable, all of the planning, design, engineering, procurement, fabrication and licensing schedules were developed and adopted by FPL to provide the flexibility to allow the proposed repairs to be performed at the earliest possible date. Consequently, the 2233 090

exact date of initiation of the repair program will depend upon FPL's analysis of the extent of degradation of the existing steam generators, maintenance schedules nd unplanned repair outages, refueling schedules, the availability of alternate oil fired gene. ration, and other f=ctors. Based upon this analysis, FPL will determine the most cost-effective schedule for the repairs consistent with the continued safe and reliable generation of electric power for its customers.

8. Commencement of a public hearing at this late date could result in delay which would be directly reflected in reduced flexibility, increased costs to Licensee, and the potential for decreased system reliability. The exact amount of such increased costs would depend upon the events existing at that time. However the likelihood is that they would reach many millic s of dollars.

Moreover, the granting of a public hearing at this late date would cause an unreasonable and unjustifiable hardship for FPL and its customers because the hearing process could deny FPL the flexibility it has prudently and diligently sought of being able to begin the proposed repairs at the earliest opportunity when economically justifiable or otherwise desirable.

2233 091 l

/l/ / /1l?axr-H . ID . LLNT Z f SWORN TO and SUBSCRIBED before me this ['I day of March, 1979.

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State NocarysPubla.c,darce of herida at ,

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