L-77-130, 04/28/1977 Letter Proposed Amendment to Facility Operating Licenses DPR-31 & DPR-41 Proposed Valve Test, Pump Test, and Inservice Inspection Programs

04/28/1977 Letter Proposed Amendment to Facility Operating Licenses DPR-31 & DPR-41 Proposed Valve Test, Pump Test, and Inservice Inspection Programs

ML18227D844
Person / Time
Site:	Turkey Point
Issue date:	04/28/1977
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-77-130
Download: ML18227D844 (7)

Text

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(2 70 I 50- /251 FILE NUMBER NRC DISTRIBUTION For APT 50 DOCKET MATERIAL TO: FROM: DATE OF OOCUMENT

'lorida Power & Light Company 4/28/'77 Mr. Victor; Stello, Jr. Miami, Florida OATE AECEIVEO Robert HE Uhrig ~

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OESCRIPT ION ENCLOSU AE 1 ~

Ltr trans the I:ollowing: Concerns AmdLo to gL/change to tech specs

..notorized'4/28/77;.Concerns their inservice examination and testing program. ~ ~ ~

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.ygC April 28, 1977 r~ L- 7-130 r (g Director of Nuclear Reactor Regulation Attn: Victor Stello, Jr., Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stello:

Re: Turkey Point Units 3 and 4 //

Docket Nos. 50-250 and 50-251 Proposed Amendment to Facility 0 eratin 'i:censes DPR-31 'and DPR-41 On February 25, 1977, our letter L-77-58, Florida Power &

Light, Company submitted proposed Valve Test, Pump Test, and Inservice Inspection Programs for Turkey Point Unit 4 in response to a November 22, 1976 letter from Mr. George Lear of your office.

Before the program can be fully implemented after approval, numerous procedures will'ave to be written or modified.

Approximately 6 months will be needed to develop the re-

quired procedures and,implement our proposed program. Due to the magnitude of effort involved, to commence the modification and it will not be practical preparation of the required procedures until the proposed program, including Technical Specifications, has been accepted by your staff.

Power & Lignt Company respectfully requests, in "'lorida accordance with 10 CFR 50.12, an exemption from the require-ments of 10 CFR 50.55a(g)(4)(v), and from Technical Specifi-cations revised in accordance with 10 CFR 50.55a(g) (5) (ii) for a period ending six months subsequent to the .Nuclear Regulatory Commission's approval of the proposed inservice examination and testing program. Until that. time, we plan to comply w'th the existing Technical Specification sur-veillance requirements.

Our request for exemption has been reviewed by the Turkey Point Plant Nuclear Safety Committee (PNSC) and the Florida Power & Light Company Nuclear Review Board (CNRB) with the following conclusions:

1) The proposed inservice examination and, testing program provides some additional assurance over the already adequate requirements of the yacility Technical snecitications that cemapi)$ 7I4 PEOPLE .. ~ SERVING PEOPLE

To: Victor Stello, Jr., NRC Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 safety-related components are functioning properly.

2) Delay in implementing this proposed program will not endanger life or property or the common defense and security.

3) Ensuring the careful preparation, review, and approval of implementing procedures prior to imple-mentation of the proposed program is in the public inter'est ..')

The request. for exemption, as stated above, is necessary, and the time period of the exemption is appropriate.

As a result of this exemption request, we have modified one page of the proposed amendment that, was also submitted under the February 25th cover letter. In accordance with 10 CFR 50.30,,three (3) originals .and forty (40) copies of our modi-fied amendment request are enclosed. The proposed change is described below and shown on the accompanying, Technical Speci-fication page bearing the date of t'.his letter in the lower right hand corner.

4.

New page 4.2-1a is modified to conform with our request for exemption from the implementation requirements of 10 CFR 50.55a.

The PNSC and CNRB have also reviewed the prop'osed Technical Specification change and have concluded that volve an unreviewed safety 'question.

it does not in-Very truly yours,

~ r Robert E. Uhrig ~ e Vice President . ~ y+

REU/GDW/MAS/hlc Enclosure cc: Norman C. Moseley, Region II Robert Lowenstein, Esq.

UNIT 4 4.2 INSERVICE INSPECTION AND TESTING Applicability: Applies to inservice structural surveillance of ASME Code Class 1, Class 2, and Class 3 components.

Objective: To ensure the continued integrity of ASME Code Cl.ass 1, Class 2, and Class 3 components (and their supports) and boundaries.

Specification: 1. Inservice inspection of ASME Code Class 1, Class 2, Class 3 components shall be performed in accordance with the Turkey Point Unit 4 Inservice Inspection (ISI) Program. The ISI Program is developed and updated in accordance with Section XI of the ASME Boiler and.Pressure Vessel Code and applicable Addenda as required'y 10 CFR 50.55a(g}, except where specific written relief has been granted by the NRC, pursuant to 10 CFR 50. 55a(g)(6)(i).

2. Inservice testing of ASME Code Class 1, Class 2, and Class 3 pumps and valves shall be performed in accordance with the Turkey Point Unit 4 Pump and Valve Test Programs. The Programs are developed and updated in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR 50.55a(g)(6)(i).

3. In cases where, during the process of inspection and testing, certain requirements are found to be impractical due to unforseen circumstances, relief may be requested at that time and satisfaction of these requirements may be deferred pending NRC action on the request.

Unit 4 4.2-1a 4/28/77

STATE OF FLORIDA )

) ss COUNTY OF DADE )

Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Vice President of Florida Power 6 Light Company, the Licensee herein; That he has executed the foregoing document; that the state-ments made in this said document. are true and correct to the best of h's knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

Rober't E. Uhrig Subscribed and sworn to before me this 19 <7

'.fOTARY PUBLIC, in and for the County of Dade, State of Florida NOTARY f'UELlC ST>Qc u LGih> A Ny commission expires:  !'."...'."'".","".-'..'"". --'-"'-"