L-2024-191, Units 3 and 4, Reply to a Notice of Violation: NOV 05000250/2024003 and 05000251/2024003
| ML24327A256 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/22/2024 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2024-191, IR 2024003 | |
| Download: ML24327A256 (1) | |
Text
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555-0001 Re:
Florida Power and Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed License Nos. DPR-31 and DPR-41 November 22, 2024 L-2024-191 10 CFR 2.201 Reference:
Turkey Point Units 3 and 4 - Integrated Inspection Report 05000250/2024003 and 05000251/2024003 and Notice of Violation, Dated November 13, 2024 Reply to a Notice of Violation: NOV 05000250,05000251/2024003-01 Attached is Florida Power & Light Company's (FPL) response to the Notice of Violation contained in the referenced Inspection Report for Turkey Point Units 3 and 4.
Should you have any questions regarding this response, please contact Maribel Valdez, Fleet Licensing Manager, at (561) 904-5164.
Sincerely, Director, Licensing and Regulatory Compliance Florida Power & Light Company
Attachment:
Response to Notice of Violation cc:
Regional Administrator, Region II, USNRC Project Manager, Turkey Point Nuclear Generating Station, USNRC Resident Inspector, Turkey Point Nuclear Generating Station, USNRC Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
Response to Notice of Violation NRC Inspection Report 05000250/2024003 and 05000251/2024003-01 L-2024-191 Attachment Page 1 of 2 Notice of Violation (NOV) 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that "measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected."
Contrary to the above, from February 2, 2022, to May 17, 2024, the licensee failed to promptly correct a condition adverse to quality associated with the control of unsecured debris material in Unit 3. Specifically, the licensee failed to promptly remove waste bags, dated August 21, 2021, from the Unit 3 RHR heat exchanger room, a condition adverse to quality, which challenged the function of the flood mitigation features in the room. This condition was dispositioned previously as non-cited violation (NCV) 05000250/05000251/2021004-01 on February 2, 2022. However, on May 17, 2024, the NRC identified that the licensee failed to completely remove the waste bags involved in the NCV, resulting in failure to restore compliance with the applicable requirements within a reasonable time after the first violation was identified.
Response
- 1. The reason for the violation Previous corrective actions put in place to maintain the U3/U4 RHR heat exchanger rooms clear of material that could affect sump pump functionality have not been sustainable. Recent NRC walkdowns of the specified areas have identified material (insulation in these cases) that could potentially, in a flooding event, affect functionality and proper operation of the RHR room sump pumps.
An investigation into the continued housekeeping issues in the RHR heat exchanger rooms determined the cause to be ineffective corrective actions. Specifically, the actions previously taken were vague with undefined guidance for material storage in the RHR heat exchanger rooms.
- 2. The corrective steps that have been taken and the results achieved The Notice of Violation (NOV) was entered into the Turkey Point corrective action program under CR 2501650. In addition, an Issue Investigation was conducted to determine the driver of the continued housekeeping issues in the RHR heat exchanger rooms and to identify actions to close any identified gaps. The following is a summary of actions taken.
Immediate actions Site and departmental communications were completed regarding the expectation that no material is to be left in the RHR heat exchanger rooms.
L-2024-191 Attachment Page 2 of 2 Walk-downs of all safety-related sump pump areas were completed to verify no materials had been improperly stored.
Actions taken to address the cause of the violation include:
The access keys to the RHR heat exchanger rooms were replaced with unique keys with placards that contain guidance that a briefing is to be conducted before the key(s) can be issued. In addition, similar signage has been placed on the entrance doors to the rooms. The required briefing is intended to make it clear that no material is to be left in the room(s) after work activities.
Maintenance Procedure, MA-AA-100-1008, was revised to provide clear guidance that no equipment, tools, or materials are permitted to be left or staged in any area that has a sump pump (such as RHR, HHSI, Condensate, and Auxiliary Building) without an engineering evaluation.
Operator daily log sheets were revised to require operators to conduct daily checks of the RHR heat exchanger rooms to ensure that no loose items, such as tools, debris, equipment, or materials are left in the room. If items are identified, they are to be removed immediately. In addition, the operator will brief the Control Room Supervisor regarding any identified deficiencies and enter them into the corrective action program in accordance with OP-AA-100-1000, Conduct of Operations.
- 3. The corrective steps that will be taken All corrective actions to address the cause for the NOV have been completed.
- 4. The date when full compliance will be achieved Full compliance was achieved on 11/19/2024 with the completion of the above discussed corrective actions.