ML17353A232
| ML17353A232 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/13/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17352B216 | List: |
| References | |
| NUDOCS 9506280371 | |
| Download: ML17353A232 (4) | |
Text
<P,R R50IJ Wp0 00 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION R LAT D TO THE THIRD TEN-YEAR INTERVA INS RVIC NSP CTIO MENDED RE VEST FOR RELIEF LORIDA POWER AND LIGH COMPAN TURKEY POINT UNIT 3 AND UNIT 4 DOCKET NOS.:
50-250 AND 50-251
- 1. 0 INTRODUCTION By letter dated September 9,
1993, Florida Power and Light Company (FPL), the licensee of Turkey Point Units 3 5 4, requested relief from the requirements of ASHE Code,Section XI, 1989 Edition for the Third Ten-Year Inservice Inspection (ISI) Program for snubbers.
As a result of questions raised by the staff during a
telephone conference with the licensee on April 4,
- 1995, concerning the above submittal, the licensee subsequently submitted its revised relief request for the snubber ISI program on Hay 8, 1995.
Currently, the Turkey Point ISI program for snubbers is required to comply with the ASME Code,Section XI, Article IWF-5000, in accordance with the first addenda to ASHE/ANSI OH-1987 Edition, Part 4, published in 1988 (OH Part 4).
The required VT-3 visual examination method is described in Article IWA-2213.
The licensee stated in the Hay 8, 1995, submittal, that complying with the Code requirements would result in extensive expenditure of resources and would adversely affect the refueling outage with no increase in the level of plant quality or safety.
The licensee also stated that the alternative use of the visual examinations and functional testing programs for Code Class 1, 2, and 3 snubbers, in accordance with Turkey Point Units 3 and 4 Technical Specifications (TS), would provide an acceptable 'level of plant quality and safety.
- 2. 0 EVALUATION The snubber visual examinations defined in the Turkey Point TS follow the recommendations of Generic Letter (GL) 90-09, "Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions," issued December ll, 1990.
Amendment Nos.
146 and 151 to the Turkey Point TS, issued February 7,
- 1992, incorporated the recommendations of GL 90-09 and removed the then restrictive visual examination requirements from the TS.
The snubber visual examination frequency specified by OH Part 4 is determined solely by the number of unacceptable snubbers found during the previous inspection, with a maximum interval of 18 months plus 25X.
Such visual examination frequency may result in more unanticipated shutdowns to meet the surveillance interval.
The Turkey Point TS schedule, on the other hand, is based on the number of unacceptable snubbers and the sizes of the various snubber populations or categories.
The inspection interval is based on a fuel cycle of up 950628037i 950hi3 PDR ADQCK 05000250i
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to 24 months and may be as long as two fuel cycles, or 48 months.
As is also stated in the Hay 8, 1995, submittal, the snubber visual examination will be performed by VT-3 certified examiners, and all snubbers will be handstroked during the examination.
This is acceptable to the staff.
For snubber functional testing, the initial sample size specified by "the 10X sample plan" in OH Part 4 is the same as that specified in the Turkey Point TS.
The sample expansion requirement specified in ON Part 4 is less restrictive than that of the Turkey Point TS and would result in fewer snubbers to be tested.
However, it would significantly increase the engineering manhours required to categorize the failure mode, identify the sample expansion required based on the failure mode, and identify the corrective action to be taken.
The Turkey Point TS simply require a
10X sample expansion based on its design type population, thus alleviating the extensive engineering manhours required by OH Part 4.
For Turkey Point the snubber functional testing is performed during the core offload portion of the refueling outage (approximately 7 to 9 days).
The requirements imposed by OH Part 4 would extend the time required to complete the snubber functional testing beyond the core offload window and adversely affect the refueling outage with no increase in the level of quality or safety.
As stated in the Hay 8, 1995, submittal, the 10X expansion sample of the Turkey Point TS will be based on snubber population and the following:
(1)
Snubbers of the same manufacturers or design types; (2)
Snubbers immediately adjacent to frozen snubbers; (3)
Snubber s from the same system; and (4)
Snubbers from other systems that have similar operating conditions, such as temperature, humidity, vibration and radiation.
It should be noted that the Turkey Point TS program scope encompasses all Code Class 1,
2 and 3 snubbers, since the majority of the saFety-related snubbers at Turkey Point are also Code Class.
The licensee, therefore, requested that visual examination and functional testing for the Code Class snubbers be performed'by the TS programs.
The staff has reviewed the licensee's submittal and considered that the TS requirements of snubber visual examination and functional testing as proposed by the licensee meet the intent of the Code-required OH Part 4.
The staff, therefore, concurs with the licensee that the TS provide an acceptable alternative for visual examination and functional testing of Code Class 1, 2, and 3 snubbers at Turkey Point Units 3 and 4.
~CQ CLUSION Based on the information provided, the staff has determined that the licensee has presented an adequate justification for its relief request from the requirements of ASME Code 1989 Edition,Section XI, Article IWF-5000 (which references OMa-
- 1988, Part 4), with regard to visual examination and functional testing of Code Class 1, 2, and 3 snubbers.
The staff has determined that the proposed alternative use of the Technical Specifications for the Code Class snubbers would provide an acceptable level of quality and safety.
Therefore, the altern'ative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
- Further, the staff has determined that the granting of this relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest.
Principal Contributor:
Arnold Lee Date:
June 13, 1995