3F1295-23, Outlines Results of 951215 Meeting Re TS Change Request 203, Rev 0 Re Small Vol Eddy Current Indication Disposition

Outlines Results of 951215 Meeting Re TS Change Request 203, Rev 0 Re Small Vol Eddy Current Indication Disposition

ML20095J400
Person / Time
Site:	Crystal River
Issue date:	12/20/1995
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F1295-23, NUDOCS 9512270086
Download: ML20095J400 (3)

Text

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Florida Power CORPORATION nrw noaxe December 20, 1995 3F1295-23 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Technical Specification Change Request No. 203, Revision 0 Small Volume Eddy Current Indication Disposition

Reference:

A. FPC to NRC letter, 3F0595-05, dated May 31, 1995 B. NRC to FPC letter, 3N0494-21, dated April 26, 1994 C. NRC to FPC letter, 3N1095-21, dated October 24, 1995 D. FPC to NRC letter, 3F1295-03, dated December 5, 1995 E. FPC/NRC Meeting December 15, 1995

Dear Sir:

The purpose of this brief correspondence is to outline the results of our December 15, 1995 meeting (Reference E) on the subject request. We felt the meeting was successful in focussing our future efforts. The following are the actions we agreed to and are taking:

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1) Florida Power Corporation (FPC) will correct the data used in Figure 3-4 of Reference A to separate the data from multiple indications into separate data points for each indication.

2) FPC will also separate the data from tube support plates (TSP) inoications from free-span indications in Figure 3-4. FPC will review the separate correlations with the NRC staff to ascertain whether it remains appropriate to conservatively apply the same criteria to small-volume indications at the TSPs (most likely wear) and in the free-span (most likely IGA). If it isn't; we will split the proposal into two criteria.

3) FPC agrees that it is likely that further review of the statistical correlations may lead to the adjustment of one or more of the quantitative acceptance criteria in our proposal. We noted our willingness to make such changes in the cover letter transmitting the RAI responses. We may also bN C 76 CHYSTAL RNER ENERGY COMPEX: 15760 W Power uno St . Crystal River, Florida 344284708 . (3'a 7956486

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propose use of the criteria relied upon in the previous Confirmatory Action Letter (Reference B) in order to strengthen the validity of relying on our subsequent operating period as a demonstration period.

4) FPC will consider the addition of requirements to record additional eddy current data in our analyst guidelines, if it is determined that such data may be helpful in future analysis.

5) FPC is evaluating the possibility of planning and scheduling in-situ pressure testing to supplement the statistical evaluations.

6) FPC will review the historical data on tubes with free-span indications above the first span. While we have no destructive examinations of CR-3 free-span indications above the first span, industry data from pulled tube examinations performed by other OTSG facilities document the presence of acidic IGA, similar to that found in the CR-3 first span, in the upper region.of other OTSGs.

These actions will require that we formally supplement the subject change request. We will plan to review the proposed changes with the NRC staff before we submit the formal change through the required administrative processes. We understand that the NRC staff's review is continuing and that addition RAI's may be forthcoming. It is anticipated that our actions (including proposed changes to our criteria) and your review of the responses to the initial RAI (Reference C) will be completed in a time-frame to support a mid-January meeting that we will finalize later.

We would anticipate that the mid-January meeting may involve multiple days where l our staffs can work out the technical details followed by a meeting with I appropriate management. Such a forum was very useful during TSIP development and for other complex issues. As was noted at the meeting our outage continues to be scheduled to begin in late February with the OTSG manway removals currently scheduled for March 7. We hope to have reached a point of agreement.in mid-January with the formal submittals and approvals occurring in late January and February respectively. Reaching closure in mid-January is necessary to support completion of the associated plant-specific analyst guidelines.

FPC initiated this effort to address limitations in existing eddy current )

technology which inhibits accurate sizing of low volume indications. '

Furthermore, the application of the existing percent through wall based technical specification plugging limit to small volume indications is inappropriately l conservative.

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'U. S. Nuclear Regulatory Commission 3F1295-23 Page 3 '

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We strongly believe that the efforts we are both going through in this review will strengthen the working relationship between industry and the staff at the

! rulemaking proceeds and as we deal with life extension and other challenges in this area. We appreciate your continued attention to this key licensing action.

1 Sincerely,

! P. M. Beard, Jr.

Senior Vice President Nuclear Operations KRW/PMB:1f i xc: Regional Administrator, Region II NRR Project Manager 3

Senior Resident Inspector l

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