ML19341D713

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Responds to 801120 Request for Proposed Change to Tech Specs Re safety-related Hydraulic & Mechanical Snubbers.Review Continues in Order That Util Can Adequately Address Listed Concerns.Tech Specs Change to Be Sent 810601
ML19341D713
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 04/03/1981
From: Baynard P
FLORIDA POWER CORP.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
3-041-07, 3-41-7, TAC-08881, TAC-8881, NUDOCS 8104080482
Download: ML19341D713 (2)


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1 Florida Power C O R FO R 4190 4 i

April 3, 1981

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A.r Darrell G. Eisenhut, Director e

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Office of Nuclear Reactor Regulation

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4s U. S. Nuclear Regulatory Comission Washington, D.C.

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Subject:

Crystal River Unit 3 Docket !b. 50-302 Facility Operating License !b. DPR-72 Snubber Surveillance Technical Specifications

Dear Mr. Eisenhut:

In your letter of Ibvember 20, 1980, (received December 4, 1980), you requested Florida Power to propose a change to the Crystal River Unit 3 Technical Spoeir!-

cations within 120 days (i.e. April 3, 1981).with regard to safety related hydraulic and mechanical snubbers.

Florida Power has been actively reviewing this change and its impact (s) on Crystal River Unit 3 (CR-3).

Our review to date has not identified a need to change current surveillance practices to the extent requested.

Ibwever, we intend to continue our review further until we can adequately address the concerns identified below.

. Among the points we wish to consider further are:

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-1) What is meant' by "...recent operating experience" and how does it affect the adr.quacy. of the current CR-3 Surveillance Program?

2) lbw does this portion of Revision 4 of the B & W Standard Technical Speci-fications (STS) compare with the STS's (Revision 1) utilized in developing the CR-3 Technical Specifications and ANSI /ASME CH-4 (Draft)?

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3) Should the Staff request piecemeal adoption of portions of Revision 4 of (STS) when we have been led to believe that pieccmeal adoption 'of portions is unacceptable, based on.the premise that each STS revision maintains a certain level of safety.
4) - Are certain aspects of the Revision 4 STS in this area going beyond typic;1-Technical Specification Scope (e.g.

required "second level" review in 4.7.9(f)) and is such warranted?

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'. General Oflice 3201 Tnirty-fourin street souin. P O Box 14042, St Petersburg i h.r t.' n13) e 813 -866 St">'

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i-Mr. Darrell G. Eise'nhut Page April 3, 1981 Additionally, FPC is currently pursuing several areas related to " Service Life" of which the Staff is aware (Versilube F-50 characteristics after long-term exposure, BUNA-N seals, etc).

It would appear imprudent to also change license abligations with regard to surveillance when so many "special studies" are 1

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and3rway.

We welcome Staff input on itens 1 through 4 abeve md propose to submit any

. Technical Specification Change Request resulting from our reviews by June 1,

1981. Your cooperation in this matter will be appreciated.

Very truly yours, FLORIDA-R CORPORCION

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<2y> w A Patsy Y. Baynard Manager Nuclear Support Services SNUBKW/ mig f

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