ML19308D751

Submits Util Planned Surveillance & Inservice Insp Program & Requests First Year Relief from STS 4.0.5 Requirements

ML19308D751
Person / Time
Site:	Crystal River
Issue date:	12/15/1976
From:	Rodgers J FLORIDA POWER CORP.
To:	Stolz J Office of Nuclear Reactor Regulation
References
TAC-04548, TAC-4548, NUDOCS 8003130685
Download: ML19308D751 (4)

Text

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N;C t o:M 195 u.s. NUCLEAQ REGULATo3Y CoMf' - SEN ooCKET NUM!ER u 83 . 50-302

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FROM: oATE oF ooCUMENT Florida Power Corp. 12/15/76 Mr. John Stolz St. Petersburg, Fla. oATE RECEivEo Mr. J. T. Ridgers 12/27/76 E ETTER ONoToRIZEo PROP INPUT FORM NUMBER oF COPIES RsCEIVEo KoRIGIN AL E'yNc LAggg p lg O One *g[gned CCon .

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DE2CEIPTICN ENCLOSURE

• g Ltr. re their 9/22/76 ltr....trans the following:- Surveillan~ce and Inservice InspcCtion Program - Florida Power Corporation -

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PLANT NAME: (3-P) (75-P) 4.  :-

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Mr. John Stolz .

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Light Water Reactors Branch I Division of Project Management U.S. Nuclear Regulatory Commission .

Wishington, D.C. 20555

Subject:

Crystal River Unit #3 Operating License DPR-72 Docket No. 50-302

Dear Mr. Stolz:

On Septe."ber 22, 1976, Florida Power Corporation filed with the Commission a request that FPC be granted written relief from the requirements of Section 4.0.5 of the Crystal River

1. 3 Technical Specifications, pursuar.t to 10 CFR, Section 5 0. 5 5a (g) (6) (i) , for the initial period of operation of CR#3.

As basis for our request, we filed with the NRC the planned Surveillance and Inservice Inspection Program for CR#3, which would be implemented in lieu of the requirements of Section 4.0.5 of the CR#3 Technical Specifications. l It was emphasized in our September 22, 1976 letter that ,

Florida Power Corporation (FPC) was prepared-to accommodate 4 the previous requirements for surveillance and inservice in-spection contained in STC " Proof 6 Review Copy" received March 30, 1976, and that our procedures, hardware, and operator training were so accomplished. We further stated that a re'-

view of the new requirements of 4.0.5 requires us to complete the following:

1. Perform an intensive review of ASME Section XI to .

determine specific requirements for inservice : -

spection of all Class 1, 2, and 3 components and --

surveillance requirements for all pumps and valves.

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General Office 3201 ininy.tounn street south . P.O. Box 14042. St Petersburg. Fionda 33733 813-866-5151 )

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. Mr. John Stolz December 15, 1976

2. Relate requirements to specific pieces of equipment to determine if surveillance testing or inservice inspection can he performed. If it cannot, an ex-clusion needs to be requested.

3. Rewrite Surveillance Procedures to reflect new requirements. Out of the 134 Surveillance Procedures currently developed from our STS, 67, or 50%, will require extensive rewriting.

Compliance with 50.55(a) provisions to the extent practical is still our intdnt and we are presently assessing how to carry out the code interpretations.

Since our Septembet 22, 1976 filing, we met with you and members of your staff to discuss our request for relief from the require-ments of Section 4.0.5. As a result of this meeting, you re-quested FPC to resubmit our filing with the corrections made that were discussed at our meeting, in an attempt to better define the program that will be performed during our assess-ment of the code requirements.

We are hereby submitting for your staff's review forty (40) copies of Florida Power Corporation's planned Surveillance and Inservice Inspection Program. This program consists of the attached requirements (which were included in the March 30, 1976 Proof and Review Copy of the CR#3 STS), plus the require-ments of the CR#3 Technical Specifications contained in Appendix A to Operating License DPR-72, dated December 3, 1976, with the exception of Section 4.0.5 and all references to that section, either stated or implied. It is hoped that this re-submittal will better define for your staff our interim Sur-veillance and Inservice Inspection Program for CR#3.

Based on this submittal, we request that the Commission grant FPC written relief from the requirements of Section 4.0.5 of the.CR#3 STS, for the first year of operation, in order that we may conduct an orderly assessment and implementation, to the extent practical, of the requirements of Section 4.0.5.

We feel that this request is justified, as the program identi-fled.herein was developed on what was thought to be final and l approved Technical Specification requirements from the NRC, and does provide adequate surveillance of plant systems to insure the safe operation of CR#3 during the interim period while we complete our assessment of the 4.0.5 requirements.  !

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.Mr. John Stolz December 15, 1976 Should' additional discussion be required, please do not hesitate to call us.

Very truly yours,

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J. T. Rodgers 7gM Asst. Vice President J.TR/iw 6

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