L-82-245, Forwards Response to NRC 820316 Preliminary Questions Re Inservice Insp Program

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Forwards Response to NRC 820316 Preliminary Questions Re Inservice Insp Program
ML17341B239
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 06/14/1982
From: Robert E. Uhrig
FLORIDA POWER & LIGHT CO.
To: Varga S
Office of Nuclear Reactor Regulation
References
L-82-245, NUDOCS 8206220219
Download: ML17341B239 (12)


Text

REGULATO INFORMATION DISTRIBUTION STEM (RIDS)

AOCESSION NBR:8206220219 DOC ~ DATE: 82/06/14 NOTARIZED: NO, DOCKET FACIL:.50-250 'Turkey Point

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'AUTH BYNAME AUTHOR AFFILIATION UHRIGi R ~ E ~

Florida 'Power,8 Light Co ~

>RBC IP ~ QAME RECIPIENT AFFILIATION, VARGAi'S ~ A ~

Operating lReac,tors Branch 1

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SUBJECT:

For. wards response

-to,NRC 820316 prel.iminary.questions ire inservice insp program.

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FLORIDA POWER & LIGHTCOMPANY June 14 1982 L-82-245 Office of Nuclear Reactor Regulation Attention:

Mr. Steven A. Varga, Chief Operating Reactors Branch gl Division of Licensing U.S.

Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Varga:

Re:

Turkey Point Units 3

8 4 Docket Nos. 50-250 and 50-251 Inservice Ins ection Pro ram Please find attached our response to your preliminary questions regarding the Inservice Inspection Program as requested in your letter dated March 16, 1982.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/JEM/mbd Attachment cc:

J.P. O'Reilly, Region II Harold F. Reis, Esquire

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TURKEY POINT 3 l.

Evaluation Criteria in Ultrasonic Examination of Piping Welds (Ref.;

Item 1, Ref.

4 and 5).

Query:

Is Reference 1 still a valid relief request to be used in the eval uati on criter ia?

Response

FPL evaluation criteria is being conducted to the first relief request (Ref.

1) alternative evaluation criteria which corresponds to the NRC Staff position (Ref. 4).

2.

Pressure Tests for Repair Examination (Ite~ 2, Ref.

4 and 5).

Query:

Response

Has FPL identified any circumstances where pressure tests were deemed impractical following repai r examinations?

No.

To date, FPL found it necessary to make some repairs (by grinding and/or weld deposition).

These repairs were re-examinedd by the same method of examination which detected the flaws.

Subsequently, pressure tests were conducted to the Code.

Therefore, there has oeen no reason for a relief request under these circumstances.

3.

Pr essure and Temperature Requirements of IAB-5000 ( Item 3, Ref.

4 and 5).

Query:

HZs FPL found it necessary for code relief resulting from the FPL Tech Specs vice IWB-5000?

4

Response

Exempting Query:

Response

No.

Lines based on Pipe Size (Iten 4, Ref.

4 and 5).

v) "J Does FPL intend to inspect all Class 1 branch lines under 6-inches diameter in accordance with Item B4.7 of Table IW8-2600?

Yes, except 1-inch diameter and below are subjected to visual examinations as provided by IM8-1220(c).

5.

Exempting Query:

ECCS Components (item 5, Rev.

4 and 4).

What examination program is proposed for ECCS, RHR and CHR components and what is the oasis'?

Response

FPL treats the

ECCS, RHR and CHR system components as non-exempt except for 1) containmen~

spray which is considered an Emergency Core Cooling System as provided by IWC-1220 (b) and

2) component connections,
piping, and associated
valves, and vessels (and their supports) tnat are 4-inch nominal pipe si.z and smaller as provided oy IWC-1220(d).

Accordingly, except for the above, the remainder of the components in these systems are subjected to the examination requirements of INC-2520.

The specific category for each of the multiple and/or single stream systems are reviewed and the required examinations are

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distr ibuted among the total number of components and streams by the allocation procedure provided by Il<C-2411(b) through (e),

inclusive.

6.

Visual Examination of Pump Casings (Relief Request iso. 6, Ref. 4)

,Quer y:

Respnse:

7.

Volumetric Query:

Response

A reply is requested which addresses industry and manufacturer's and recommendations experiences in permitting pump internal visual inspection to be performed only upon disassembly of the pump for maintenance which could exceed the inspection interval period.

Hhen FPl requested relief from the code requirement, the state of the art did not provide for a practical mechanism to conduct visual exami nations of the internals without subjecting personnel to high radiation 'exposure.

Recently, a

RCP inspection system was developed which provides for a mechanized examination of the pump internals.

This system was used successf'u) ly during the steam generator replacement outage.

Therefore, this relief request is withdrawn.

Examination of Pump Casing Helds (Relief Request iso 7, Ref. 3).

Similar to Query No.

6 above, additional information is requested to justify this relief request.

Same as Query No.

6 above; except tnat radiographic examination of the pump welds was conducted successfully using the Ninac RCP Inspection System device during the steam generator replacement outage.

Therefore, this relief request is wi thdr awn.

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II 1

TURKEY POINT UNIT 4 1.

Relationship of Turkey Point 3 and Turkey Point 4 Programs.

Query:

,Has FPL given consideration to combining the Turkey Point 3 and 4 programs?

Further, do the relief requests of Turkey Point 3 have applicability to Turkey Point 4?

Response

It is the intent of FPL to combine the Turkey Point 3 and 4

programs with respect to the ASIDE Section.

XI Code 1974 Edition thru Summer 1975 Addenda.

However, it is recognized that due to subtle differences in the plant's configurations there will be a separate Inspection Plan for each unit.

We are pr esently in the process of addressing the Turkey Point 4 program and Inspection Plan in preparation for the Steam Generator replacement outage which is scheduled for October 1982.

We are currently in the third period of the first interval and plan to perform*all, or most, of,our 40-month ISI during this outage.

To this end, we are planning to exercise the same relief requests as they apply to Turkey Point 4.

FPL intends to submit the Turkey Point 4 ISI program for the Third Period to HRC on July 16, 1982.

2.

Response

to previous RAI.

Query:

FPL submitted a partial resoonse to the NRC Staff (Ref. 3,77-372, dated 12/9/77) to NRC's request for additional information (Ref. 2, Lear to Uhrig, dated 9/7/77).

NRC raised the question whether this information was transmitted under a separate transmittal?

Response

Ho.

FPL's review of the unansw red questions submitted to the NRC Staff by Reference 3 are:

1.

II. Inservi ce Inspection - Class 1 components.

Question 7.

Provide all figures referenced in the Table for Class 1 examination.

Response.

We are continuing to pursue documentation used in support of ISI programs.thru the efforts of I.E. Bullet,in 79-14, on-going drawing up-dates and obtaining documents, from vendor 's that supplied the original plant components.

2.

II. Pressure Tests - Class 1 Components Question 1.

Provide all figures. listed for Class 1

components.

Response

Same response as Item 1 above.

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3.

III. Class 2 Components Question 1.

Provide levels of radiation in those cases where relief is requested.

Response.

FPL will provide the levels of radiation, in addi'tion to other necessary information, where it is considered necessary to request a relief from the Code.

Question 2.

Provide all figures listed as references for Class 2 pressure tests.

Response.

Same response as item l. above.

4.

III. Class 2 Components Question 1.

Provide levels of radiation in those cases where relief is requested.

Same response as item 3 above.

Question 2.

Provide all figures listed as references for Class 3 pressure tests.

Response.

Same response as item 1 above.

3.

Pr ogr am Inte"r'val Query:

When approved by the NRC Staff, FPL would be in the last 80 months of the First Inspection Interval.

Doel FPL intend to make any changes to the existing relief requests or propose other relief requests?

Response.

FPL would propose to request tne same relief from the Code as pi oposed in Turkey Point 3, except for the relief requests that have been withdrawn for aforementioned reasons.

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