ML17339A646
| ML17339A646 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/06/1980 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| L-80-75, NUDOCS 8003110563 | |
| Download: ML17339A646 (8) | |
Text
REGULATORY 4FORMATION DISTRIBUTION S EM (RIDS)
ACCESSION NBR ~ 8003 1 1 0563 DOC'y DATE ~ 80/03/06 NOTARIZED ~
NO DOCKE FACIL:50-250 Turkey Point Planti Unit 3i Florida Power and Light C
050 5
50~251 Turkey Point Planti Unit 0i Florida Power and Light C
05000251 AUTH BYNAME AUTHOR AFFIL'IATION UHRIGi R ~ E ~
Florida Power 8 Light Co.
RECIP ~ NAME RECIPIENT AFFILIATION SCHWENCERiA, Operating Reactors Branch 1
SUBJECT:
Forwards info re check valve cycl.ing in response to NRC 791130 ltr.Valve program meets ASME Section XI code requirements except for specific re'lief requested.
DISTRIBUTION CODE:
A001S COPIES RECEIVED:LTR ~ ENCL ~
SIZE:
TITLE: General Distribution for after Issuance of Operating Lic NOTES:~ MMMMM~WMMMWMWWMMMMMMMSFW RECIPIENT
.ID CODE/NAME'CTION:
05 BC CAJUN W/
INTERNAL:
1 REG F
17 ENGR BR 19 PLANT SYS BR 21 EFLT TRT SYS OELD COPIES LlTTR ENCI.
7 7
1 1
2 2
1 1
1 1
1 1
1 0
REC IP lENT COPIES ID CODE/NAME-LTTR ENCL 02 NRC PDR 15 CORE PERF BR 18 REAC SFTY BR 20 EEB EPB DOR STS GROUP LEADR EXTERNAL: 03 LPDR 23 ACRS 1
1 16 16 OcI NS I C 1
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 38 ENCL'7
41
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4 ro 41 K
.O. BOX 529100, MIAMI,FL 33152
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Wn eX FLORIOA POWER 5 LIGHTCOMPANY March 6, 1980 L-80-75 Office of Nuclear Reactor Regulation Attention:
Mr. A. Schwencer, Chief Operating Reactors Branch bl Division of Operating Reactors U ~
S. Nuclear Regulatory Commission Washington, D.
C.
20555
Dear Mr. Schwencer:
Re:
Turkey Point Units 3
& 4 Docket Nos.
50-250 8 50-251 Check Valve C clin The attached information is submitted in response to your letter of November 30, 1979.
The attachment presents Florida Power 8 Light Company's interpretation of ASME Code requirements for testing of check valves.
Very truly yours, Robert E. Ubrig Vice President Advanced Systems 8 Technology REU/MAS/GG/cph Attachment cc:
Mr. J.
P.
O'Rei lly, Region II Harold F. Reis, Esquire 8 0 G 9 y IIItI,+69 PEOPLE... SERVING PEOPLE
ATTACHMENT Re:
Turkey Point Units 3
8 4 Docket Nos.
50-250 8 50-251 Check Valve C cling This attachment addresses the NRC Staff's position that full stroke testing of check valves is a requirement of ASME Code Section XI, 1974 Edition, Article
-IWV-3520(b),
"CHECK VALVE TESTS, Exercising Procedure."
There are two basic aspects of the NRC position:
The NRC Staff has determined that flow is acceptable for demonstrating check valve disk position because the ASME Code recognizes flow rate (or lack thereof) as an established method for indi rect evidence of disk position.
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h ~if, df h
licensing basis Safet Anal sis, is required to pass through the valve, whereupon it may be assumed t at the valve moved to a position (full-stroking) to fulfill its function.
Florida Power 8 Light Company (FPL) recognizes f011 stroke testing as a Code requirement'.
FPL programs have always included full stroke testing and have further provided a definition of "full stroke."
Therefore, based on the acceptability of past FPL interpretations of the ASME Code, we do not apprehend the basis for the NRC Staff's position.
With specific regard to aspect I. of the NRC position, we agree that the Code provides for flow rate as an established method for indirect evidence of check valve disk position.
However, the Code also provides for changes in ~s stem hid hd+
I f
Idf Id check valve disk position.
As a consequence, the following should be recognized:
(A)
IWV-3410 (b) (2), Exercising Procedure for Category A and B Valves, provides acceptable methods for observi n the necessary di sk movement LIWV-3410 (b) (1), full-stroke 'exercise that reflects disk position, and which includes s stem ressure or tern erature in addition to flo~i rate;
- whereas, (B)
IWV-3520 (b), Exercise Procedure for Category C Valves (Check Valves),
omits reference to those methods for full-stroke exercising of valves, but does refer to methods of confirmation that the disk moves promptly on or off its seat by (1) visual observation, (2) by an electrical signal initiated by a position indicating device, (3) by observation of appropriate pressure indications in the system, or (4) by other positive means.
I' d
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'I U Il
With specific regard to aspect II.
NRC position, Code Article IWV-3520 (b),
"Ck 1,E used in the Safet Anal sis, as a requirement to satisfy the full-stroke exercise of the va ve.
The FPL valve program includes check valves with Category C and AC
-classifications.
IWV-2110, Category of Valves, requires combination of categories, such as Category AC, to meet all the requirements of each individual category, as applicable.
It is the FPL position that our valve program meets ASME Section XI Code requirements, except for specific relief requested in accordance with 10 CFR 50.
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