ML20071C252
| ML20071C252 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/03/1983 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20071C246 | List: |
| References | |
| L-83-53, NUDOCS 8303010604 | |
| Download: ML20071C252 (3) | |
Text
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P. O. BOX 14000, JUNO BE ACH, FL 33408 FLORIDA POWER & LIGHT COMPANY
- 3 rro 9
/4s,. 40 February 3,1983 L-83-53 Mr. James P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atl a nta, Georgi a 30303
Dear Mr. O'Reilly:
Re:
Turkey Point Units 3 & 4 Docket Nos. 50-250 and 50-251 IE Insoection Report 82-37 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary infomation in the report.
Very truly yours, N
2/e Robert E.
Vice President Advanced Systems & Technology REU/PLP/js Attachment cc:
Harold F. Reis, Esqui re PNS-LI-83-083-1 8303010604 830218 PDR ADOCK 05000250 G
PDR PEOPLE,. SERVING PEOPLE
o ATTACHMENT RE:
TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250, 50-251 IE INSPECTION REPORT 82-37 FI ND I NG:
10 CFR 50.59 requi res that for plant changes a written safety evaluation shall be prepared which provides the basis for the determination that the change does not involve an un revi ewed sa fety que stion.
Step 8.4.4.3 of Administrative Procedure 0190.15, " Plant Projects - Approval, Impleme ntation a nd Regul atory Requi reme nts", requi res a documented safety evaluation.for changes to safety-related systems demonstrating that the change neither introduces an un revi ewed safety question nor adversely affects any safety-related equipment.
Contrary to the above, a safety evaluation wa s not pe rf o rme d prior to ef fecti ng the foll owi ng two changes :
(1)
Removal of pressure transmi tter PT-934 f rom tne Unit 3 Boron Injection Tank di scharge header on April 8,
1982, and suosequent powe r operation of Unit 3 i n the absence of this transmitter.
(2)
Introduction on July 19, 1982, of a blank plate in tne place of fl ow o ri fice F.T.
943 on the safety i nj ection system (SIS) ano subsequent return of the SIS to unrestricted service for a ppr oxima tely 2-1/2 days.
RESPONSE
In response to the first ex am pl e ;
1.
FPL does not ag ree that 10 CFR 50.59 requi rec a written safety evaluation prior - to the removal of PT-934.
However, FPL concurs that an adequate review of subsequent power operation of Unit 3 in the a bsence of PT-934 was not pe r fo rmed.
2.
The reason fo r the findi ng wa s that, although our pr ocedures required the clearance order which authorized r emo vi ng PT-934 from s ervi ce De revi ewed fo r sa f ety considerations prior to starting up Unit 3, the procedures do not adequately prescrioe the deptn or t he detail s of the revi ew.
3.
As immediate corrective action, the operation of Unit 3 wi thout PT-934 was evaluated and found to not i nvol ve a ny unrevi ewea safety q ue s ti o n s.
4.
Corrective action to prevent f urther vi olations oy upgrading tne clearance review during startup is under review and will De s ubmi tted in a fo ll ow-u p respo nse oy Ma rch 19, 1983.
5.
Full compliance was achieved when the safety evaluation wa s p e rf o rme d which occu r red prior to Ja nua ry 25, 1983.
-E ATTACHMENT RE:l TURKEY POINT UNITS 3 AND 4
/
DOCKET NOS. 50-250, 50-251 IE INSPECTION REPORT 82-37 2.
In response to the second ex ampl e; (1)FPL concurs with the fi ndi ng.
(2)The reason fo r the findi ng wa s that it wa s erroneously determined that the proper control for the temporary i ns tal la tion of the pl ate woul d be by an equipment clearance order, whi ch did not require a written safety evaluation.
(3)As corrective action:
a.
An Engi neering evaluation wa s made of tne origi nal plate whi ch included a stress analysis at wn i ch time a recommendation wa s made to replace the plate due to concerns of permanent deformation even thougn tne pl ate wa s determi ned to be in the allowaDl0 range for failure due to breakage caused by nign pressures (1500 psi).
b.
The pl ate wa s removed and the system restored to.
n o rma l by re placi ng the fl ow ori fice (FT-4-943) prior to startup of Unit 4.
(4)
Corrective action to prevent f urther violations i s under revi ew and will be s ubmi tted in a follow-u p respo nse Dy March 19, 1983.
(5)
Full compliance wa s achieved when the system wa s restored to no rmal, which occurred prior to July 26, 1982.