L-2020-129, Commitment Revision Summary Report for MOV-3-751
| ML20211L804 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/29/2020 |
| From: | Hess R Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2020-129 | |
| Download: ML20211L804 (2) | |
Text
Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Turkey Point Units 3 Docket Nos. 50-250 Commitment Revision Summary Report for MOV-3-751
References:
- 1. NRC Safety Evaluation of Licensee Response to Generic Letter 96-05, Turkey Point Plant, Unit Nos 3 and 4, dated June 29, 2000.
- 2. NEI Guidance 99-04, NEI 99-04, Guidelines for Managing NRC Commitments
- 3. Turkey Point Condition Report (AR) 02352000 In response to Generic Letter (GL) 96-05, Turkey Point committed to implement the Joint Owners Group (JOG) periodic verification plans (Reference 1).
The purpose of this letter is to summarize a Turkey Point Unit 3 commitment revision related to one of the motor operated valves (MOVs) that is in the scope of the GL 96-05 program. Specifically, MOV 751, Residual Heat Removal (RHR) inlet isolation valve, is tested at assigned intervals to periodically verify design-basis capability with regards to valve operating requirements. This ensures that age related degradation has not caused a significant decrease in motor-operator capability or increase in operating requirements that could jeopardize the MOVs ability to perform its safety function and is a requirement of the MOV Program. MOV-3-751 is a JOG Class B valve. For Class B valves, the JOG program specifies that the static diagnostic test matrix be followed based on functional margin and risk categorization of the specific MOV. Accordingly, for MOV-3-751, the current Turkey Point commitment following the JOG verification plans, is to perform the maximum Periodic Verification Test (PVT) at an interval of 10 years.
The last static test of MOV-3-751 was performed on October 13, 2010. The proposed commitment change is a one-time deferral of the static periodic verification test for MOV-3-751 by one year or until the end of the next Unit 3 refueling outage, which is currently scheduled for October 2021.
The test deferral of MOV-3-751 was due to Turkey Point Unit 3 Cycle 31 refueling outage scope changes for the extenuating circumstances associated the COVID-19.
The commitment revision review was performed in accordance with guidance provided in NEI 99-04, Guidelines for Managing NRC Commitments (Reference 2). The commitment revision evaluation is documented in the Turkey Point Corrective Action Program (Reference 3). The justification for changing the commitment is based on the presence of acceptable positive margin, the completion of scheduled stem lubrication and operator inspection PMs, the acceptable Inservice test results, and the lack of any indication that the MOVs performance has degraded. As such, it was concluded that deferring the MOV-3-751 static PVT until the next Turkey Point Unit 3 refueling outage for Cycle 32, does not adversely affect the ability of the MOV to perform any of its safety functions.
July 29, 2020 L-2020-129
L-2020-129 Page 2 Additionally, the MOV-3-751 Inservice stroke time test results provides reasonable assurance that MOV-3-751 remains capable of.performing its safety functions until the MOV static verification test can be performed during the next Turkey Point Unit 3, cycle 32 Refueling outage, currently scheduled for October 2021.
If you have any questions or require additional information, please contact Mr. Robert Hess, Licensing Manager, at (305) 246-4112.
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Robert J. ~ess Licensing Manager Turkey Point Nuclear Plant cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant