ML19329D748
| ML19329D748 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/24/1976 |
| From: | Rodgers J FLORIDA POWER CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003170689 | |
| Download: ML19329D748 (3) | |
Text
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3RhrORu 195 U.S. NUCLE AR GEGULATORY r MISSION DOCKET NUMIE R iras) 50-302 NRC DISTRIBUTION roR PART 50 DOCKET MATERI AL tTO:
FROM:
DATE OF DOCUMENT l
i Florida.Powe,r Corp.
6/24/76 Mr. John Stolz St. Petersburg, Florida o,7,,g e,,y g o J. T. Rodgers 6/28/76
% ETT$R O NOTO R 12 E Q PROP INPUT FORM NUMBER OF COPIES RECEIVED MOR KelN AL hWNC LASSIFIE D one signed OCOPy DEICRIPTION ENCLOSU RE Ltr. re our 5/24/76 revision......concerning the massive revision to the STS package and the imposition of such revisions.
N:te Distribution as per Mr. Leon Engle-(2-P)
PLANT NAME:
Crystal River #3 SAFETY FOR ACTION /INFORMATION ENVTnn 6/29/76 RJL Y ASSIGNED AD:
DeYoune ASSIGNED ADr M BRANCH CHIEF:
S tolz ~
BRANCH CHTEF*
X PROJECT MANAGER:
L. Enstle PROJECT MANAGER!
X LIC ASST.:
Hylton LIC. ASST.!
INTERNAL DISTRIBUTION XEREG FTTFJ SYSTEMS SAFETY PLANT RYSTEMg SITE SAFETY &
M NRC PDR X IEINEMAN TEnEsco ENVIRO ANALYSIS X I&E M
SCHROEDER BENAROYA DENTON & MULT ER OELD LAINAS GOSSICK & STAFF ENGINEERING IPPOLITO ENVIRO TECH -
MIPC MACCARRY KIRKWOOD ERNST CASE M
KNIGHT (27 BALLARD HANAUER SIIMEIL OPERATING REACTORS SPANCLER HARLESS X PAWLICKI
(.3 )
STELLO 9TTE TFEM PROJECT MANAGEMENT REACTOR SAFETY OPERATING TECH.
CAMMTLL
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BOYD ROSS X EISENHUT STEPP P. COLLINS NOVAK V
SRA0 HULMAN HOUSTON ROSZTOCZY BAER PETERSON CHECK BUTLER SITE ANALYSIS MELTZ GRIFES VOLLMUR k HELTEMES AT & I BUNCH M SKOVHOLT
/3)
SALTZMAN J. COLLTNS RUTBERG KnEcEn EXTERN AL DISTRIBUTION CONTROL NUMBE R X LPDR5 Crystal River.F] a.
NAT LAB:
BROOKHAVEN NAT LAB
' TIC:
REG. VIE ULRIKSON(ORNL)
NSTc.
LA PDR g
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CONSULTANTS R ACRS / CYS HOMMMG/SENT:/,/kg.mA/
QnAg17 g L.
NRCFORM 195(2 76)
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bnw a. x Florida Power June 24, 1976 Mr. John Stol:
Branch Chief p
'" [.7 Light Water Reactors Branch I Q
g Division of Project Management 1:j hR23.gg76, U.S. Nuclear Regulatory Commission O;> t y.
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Washington, D. C.
20555
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Subject:
Crystal River Unit #3 6
/
Standardize Technical T
s, Specifications.
~...s*,
Dear Mr. Stol:
On May 24, 1976, we again received (informally) a massive re-vision to the STS package we virtually finalized late last year.
One major concern is the continuing imposition of such massive revisions upon us during the most critical time of plant start-up and operator licensing.
Another is the inclusion of Crystal River 3 as a non-operating plant requiring immediate compliance with the new 10 CFR 50.55(a),
while operating plants appear to have been granted approximately 40 months maximum time for compliance.
A third concern is that our STS included surveillance criteria and frequency for equipment testing you deemed essential.
By referring to ASME Section XI, you incorporated a completely new set of surveillance criteria upon us.
Also in so doing, you incorporated the ASME use of "in service" as being synonymous with your term " surveillance".
We were prepared to accommodate the previous requirements for surveillance in STS.
Our procedures, hardware, and operator training were so accomplished.
A review of the new requirements requires us to complete immediately the following:
~5d ( (
General Office 3201 ininy-tourin street soutn. P.O Box 14042. St Petersburg. Fionca 33733 813-866-5151
Mr. John'Stol: June 24, 1976
' I '.
Perform an intensive review of ASME Section XI to determine specific requirements for inservice
' inspection lif all Class 1, 2, and 3 components and surveillance requirements for all pumps and valves.
2.
Relate requirements to specific pi'eces of. equipment to determine if surveillance testing or inservice 4
inspection can be-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 being developed from our STS, 67 or 50%
will require extensive rewriting.
i To perform these tasks, purchase additional testing equipment, establish a comprehensive vibration monitoring system for pumps and-implement these requirements while our operator personnel
.are running hot fuctional and other required testing is im-possible to do immediately.
[
We request that we be granted a waiver for compliance sufficient to allow us time to accomplish the above work effort on an
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acceptable schedule.
In fact, the operating plant' schedule of up to 40 months is in our case not an unrealistic maximum.
If you. desire, we welcome the opportunity to discuss this situation with you.
Very truly yours,
-l
.. l J. T. Rodgers+
Asst. Vice President JTR/iw 1
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