ML20210V622
| ML20210V622 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/12/1987 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-87-66, NUDOCS 8702190070 | |
| Download: ML20210V622 (3) | |
Text
_ _ _ _
P. o. Bon 14CDO, Juf40 BEACH, FL 33408-0420 qiil! /
FEBRUARY 12 1987 L-87-66 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inspection Report 86-44 Florida Power & Light Company has reviewed the subject inspection report and a response is attached.
There is no proprietary information in the report.
Very truly yours, Werl C. O. Woo Group Vi President Nuclear Energy Department COW /RG/gp Attachment cc:
J. Nelson Grace, Regional Administrator, Region 11, USNRC Senior Resident inspector, USNRC, Turkey Point Plant
$ o @g an FPL Graup company
C ATTACHNENT RE: TURKEY POINT UNITS 3 AND 4 DOCKET NO. 50-250, 50-251 IE INSPECTION REPORT 250-86-44 & 251-86-44 FINDING A Title 10, Code of Federal Regulations Part 50.59 ( 10 CFR 50.59 ) requires that changes to a facility be evaluated to determine whether those changes involve unreviewed safety questions, that records of those evaluations be kept, and that a report be made to the NRC at least annually, containing a description of those changes including a summary of the safety evaluation.
Contrary to the above, changes to the Turkey Point facility were not evaluated for unreviewed safety questions in that valve 4-872 was throttled in March 1978 and subsquently unthrottled in April 1984 and those changes were not evaluated to determine whether they involved unreviewed safety questions.
RESPONSE
As per the NRC letter dated January 13, 1987, no response is required for finding A.
FINDING B:
Technical Specification (TS) 6.8.1 requires that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the requirements and recommendations of section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Cuide 1.33.
FP&L Procedure, Maintenance Procedure 0734, dated February 26, 1986, " Safety-Related Supports / Restraints Removal and Replacement" requires safety-related pipe supports be removed and replaced in accordance with safety-related Plant Work Order (PWO).
Contrary to the above, pipe support 622A H-2 was removed without the authorization of a PWO.
RESPONSE
1)
FPL concurs with the finding.
2)
The investigation of the circumstances of the support removal was inconclusive as to the root cause or most probable root cause. However, the investigation recognized that the procedure on safety-related supports / restraints removal and replacement did not provide adequate guidance for the removal of safety-related supports / restraints.
I 1
f I
,r 3)
The subject support was immediately restored. A non-conformance report (NCR)86-315 was issued to evaluate what impact the inoperable support would have had on the piping. The results of the evaluation show the system to be operable with the support disconnected, therefore, no safety issue was involved.
4)
The following corrective actions are being taken to prevent recurrence:
A) The procedure for removal and replacement of safety-related supports and restraints will be revised to provide additional guidance.
B) Collateral procedures will be reviewed to determine the need to add references and or make procedure changes.
C) Upon completion of the procedure changes, these changes will be incorporated into the maintenance training program to ensure that personnel understand the procedural requirements and prerequisite steps necessary for working on safety-related supports.
5)
A) Full compliance for item 3 above was achieved by August 18, 1986.
B) Full compliance for item 4.a and 4.b above will be achieved by October 1, 1987.
C) Full compliance for item 4.c above will be achieved by December 1, 1987.
1 2
j