ML19318C327
| ML19318C327 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/26/1980 |
| From: | Richard Bright FLORIDA POWER CORP. |
| To: | |
| References | |
| 3--16-B, 3-0-16-B, TAC-04548, TAC-4548, NUDOCS 8007010355 | |
| Download: ML19318C327 (4) | |
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Florida Power CO M PO M A Y IO N June 26, 1980 File:
3-0-16-b Mr. Robert W. Reid Branch Chief Operating Reactors Branch #4 Division of Operating Reactors U.S. Nuclear Regulatory Comission Washington, DC 20555 Subj ect: Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Inservice Inspection Program
Dear Mr. Reid:
The current Inservice Inspection Program at Crystal River Unit 3 is based on ASME Section XI, 1974 Edition through Summer 1975 Addenda.
Florida Power Corporation filed on April 14, 1977, November 21, 1977, August 17, 1978, and March 28, 1979, written requests for relief from those portions of the ASME Section XI Code that we determined to be im-practical for Crystal River Unit 3.
As part of our waiver requests, FPC submitted alternative test and inspection methods to be utilized in lieu of the ASME Section XI Code requirements determined to be impractical.
We further stated that it may not be possible in all cases for Florida Power Corporation to determine that an ASME Code requirement is imprac-tical for our facility until all of the requirements have been implemen-ted during an actual inservice inspection.
We indicated at that time that we would advise you of any additional Code requirements that are determined not to be feasible for Crystal River Unit 3.
This letter is to advise you that Florida Power Corporation has deter-mined that a portion of the ASME Section XI Code, concerning " System Pressure Testing" of systems following modifications is not feasible for use at CR-3.
Specifically, Florida Power Corporation requests relief from Article IWC 5000, Subsection IWC 5220, of ASME Section XI,1974 Edition through Summer 1975 Addenda.
During the current CR-3 outage, modifications were accomplished to the Make-Up and Purification System. These involved the makeup pump suction piping.
Two hand-operated valves were replaced with two motor-operated valves.
Subsection IWC 5220 requires the system to be hydrostatically General Office 3201
-tourth street soutn. P O Box 14042, St Petersburg. Florida 33733 e 813-866-5151 8oo7o t0357
Mr. Robert W. Reid Page Two June 26, 1980 tested to 1.25 times the design pressure.
(The design is 450 psig at 300 F.)
However, there are three (3) 150 psig relief vaives located in this section of piping; one innediately prior to each makeup pump suc-tion.
Gagging these valves for the required hydrostatic test pressure would pose safety problems, and removing them could degrade system in-tegrity (more possibilities for leakage and no overpressure nrotec-tion).
Also, this equipment is contaminated and additional radiation exposure would be necessary to accomplish the hydrostatic test if the valves were to be removed.
The Winter Addenda to the 1977 Edition of ASME Section XI provides a more realistic approach to system hydrostatic test pressure require-ments.
IWC 5222(a) recognizes relief valves in the system and allows adjustments to the hydrostatic test pressure accordingly; thereby taking into account their provision for overpressure protection within the system.
This letter is to request that FPC be granted a waiver from the require-ments of Article IWC 5000, Subsection IWC 5220, of the 1974 Edition through Summer 1975 Addenda of ASME Section XI.
We wish to adopt Sub-section IWC 5220 of the Winter 1977 Addenda to ASME Section XI,1977 Edition.
Florida Power Corporation considers the more recent subsection to pro-vide a more realistic and practical guideline for defining system hydro-static tett pressure requirements without sacrificing system safety.
This waiver request is considered to be a Class III Amendment, per 10 CFR 170.22, as it involves a single safety issue.
No licensing fee is applicable for this request as it is being included in the Inservice Inspection Program presently under review by the NRC.
If you have any questions on this subject, please contact this office.
Very truly yours, FLORIDA POWER CORPORATION Ronald M. Brig t Acting Manager Nuclear Support Services i
RMBekcT02(DN-98)
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STATE OF FLORIDA COUNTY OF PINELLAS R.
M.
Bright states that he is the Acting Manager, Nuclear Support Services Department of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.
Lt/sLA
/R.F M/ Bright Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 26th day of June,1980.
Notary Public l
Notary Public, State of Florida at Large, My Commission Expires: August 24, 1983 RMB/SFCNotary(DN-98)
B UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
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DOCKET NO. 50-302 FLORIDA POWER CORPORATION CERTIFICATE OF SERVICE R. M. Bright deposes and says that the following has been served on the Chief. Executive of Citrus County, Florida, by deposit. in the United States mail, addressed as follows:
Chairman Board of County Commissioners of Citrus County Citrus County Courthouse Inverness, FL 32650 An original copy of Inservice Inspection Program Waiver Request.
FLORIDA POWER CORPORATION N
'R. F. Bright /
Acting Manager Nuclear Support Services SWORN TO AND SUBSCRIBED BEFORE ME THIS 26th DAY OF JUNE, 1980.
10tary Public Notary Public State of Florida at Large My Comission expires: August 24, 1983 (NOTARIALSEAL) 1 RMBekcT02(CertServ)DN-98 q