ML20205K611
| ML20205K611 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/02/1999 |
| From: | Wiens L NRC (Affiliation Not Assigned) |
| To: | Cowan J FLORIDA POWER CORP. |
| References | |
| TAC-MA1642, NUDOCS 9904130296 | |
| Download: ML20205K611 (6) | |
Text
F Mr. John Pcui Cowan
. Apri1 - 2, 1999 Vica Presid:nt, Nucle:r Oper;tions
' Floridt Power Corporation
' ATTN: Manager, Nuclear Licensing (SA2A)
Crystal River Energy Complex 15760 W. Power Line Street Crystal River, Florida 34428 4708
SUBJECT:
CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION -
THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF (TAC NO. MA1642)
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Dear Mr. Cowan:
i in a submittal dated April 16,1998, and revised November 30,1998, Florida Power j
Corporation submitted the third 10-year Inservice inspection Program for Crystal River Unit 3.
j included in the submittal were requests for relief from the requirements of American Society of Mechanical Eng!neers Boiler and Pressure Vessel Code. In order to complete our review of
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these relief requests, we require add;tionalinformation as specified in the enclosure to this letter. Please provide the requested information within 30 days of receipt of this letter. This Request for Additional information and requested submittal date were discussed with Mr. Sidney Powell of yeus staff.
i Sincerely,-
original signed by:
Leonard A. Wiens, Senior Project Manager, Section 2 i
Project Directorate !!
Division of Licensing Project Management Office of Nuclear Reactor Regulation
. Docket No. 50-302 l
Enclosure:
Request for Additional Information P.],
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NUCLEAR REGULATORY COMMISSION l
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April Z. 1999 Mr. John Paul Cowan Vice President, Nuclear Operations j
Florida Power Corporation l
ATTN: Manager, Nuclear Licensing (SA2A)
Crystal River Energy Complex-i 15760 W. Power Line Street l
Crystal River, Florida 34428 6708
SUBJECT:
CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION -
THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN REQUESTS FOR RELIEF (TAC NO. MA1842) i
Dear Mr. Cowan:
In a submittal dated April 16,1998, and revised November 30,1998, Florida Power Corporation submitted the third 10-year Inservice inspection Program for Crystal River Unit 3.
Included in the submittal were requests for relief from the requirements of American Society of j
Mechanical Engineers Boiler and Pressure Vessel Code. In order to complete our review of these relief requests, we require additionalinformation as specified in the enclosure to this letter. Please provide the requested information within 30 days of receipt of this letter. This Request for Additional Information and requested submittal date were discussed with Mr. Sidney Powell of your staff.
Sincerely, Leonard A. Wiens, Senior Project Manager, Section 2 Project Directorate ll Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
Request for AdditionalInformation cc w/ encl: See next page
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Mr. John Paul Cowan CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation ec:
Mr. R. Alexander Glenn Ms. Sherry L Bemhoft, Director Corporate Counsel Nuclear Regulatory Affairs (SA2A) l Florida Power Corporation Florida Power Corporation MAC-A5A Crystal River Energy Complex P.O. Box 14042 15760 W. Power Line Street St. Pete sburg, Florida 33733-4042 Crystal River, Florida 34428-6708 Mr. Charles G. Pardee, Director Senior Resident inspector Nuclear Plant Operations (NA2C)
Crystal River Unit 3 i
Florida Power Corporation U.S. Nuclear Regulatory Commission Crystal River Energy Complex 6745 N. Tallahassee Road 15760 W. Power Line Street Crystal River, Florida 34428 Crystal River, Florida 34428-6708 Mr. Gregory H. Halnon Mr. Michael A. Schoppman Director, Quality Programs (SA2C)
Framatome Technologies Inc.
Florida Power Corporation 1700 Rockville Pike, Suite 525 Crystal River Energy Complex Rockville, Maryland 20852 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circiel, SE, Bin #C21 Tallehassee, Florida 32399-1741 Attomey General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Chairman Board of County Commissioners Citrus County i
110 North Apopka Avenue invemess, Florida 34450-4245 j
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REQUEST FOR ADDITIONAL INFORMATION, EQR INSERVICE INSPECTION PROGRAM REQUESTS FOR RELIEF 1.
Recuest for Relief 98-007-II. Code Case N-521 states that examination of reactor pressure vessel nozzles, IR sections, and nozzle-to-safe end welds may be deferred provided (a) no inservice repairs or replacements by welding have ever been performed on any of the subject areas, (b) none of the subject areas contain identified flaws or relevant conditions that currently require successive inspections in accordance with IWB-2420(b),' and (c) the unit is not in the first intental.
Please verify that all the conditions in Code Case N-521 will have been met. An additional requirement imposed by the U.S. Nuclear Regulatory Commission (NRC) is that all subject areas be scheduled for examination such that the new sequence of examinations will not exceed 10 (Ccda) years between examinations, it appears that the scheduled sequence of examinations will exceed 10 years for two of the inner-radius examinations. Please justify why exceeding ten Code years between inspections provides quality and safety.
2.
Reauest for Relief 98-002-PT. Florida Power Corporation (FPC) has committed to i
comply with the requirements found in Code Case N-416-1. However, FPC has not committed to perform a surface examination on the root pass layer of Class 3 butt and socket welds when a surface examination on the completed weld is required in accordance with Section lil requirements. In order for the staff to find the use of Code Case N-416-1 acceptable, FPC needs to incorporate into its proposed attemative a surface examination on the root pass layer of Class 3 butt and socket welds when a surface examination on the completed weld is required in accordance with Section 111 requirements.
3.
Reauest for Relief 98-003-PT. Appendix J contains two options for examination requirements. Option A, Prescriptive Requirements, requires that three Type A tests be l
performed at approximately equal intervals during the 10 year inservice inspection (ISI) l interval, with the third test being done during shutdown for the 10-year plant ISI. Option A also requires Type B and C tests during each refueling outage, but in no case at l
intervals greater than 2 years. This is more frequent than the periodic pressure tests j
required by ASME Section XI. Appendix J, Option B, Performance Based i
Requirements, allows a licensee to perform Type A, B, and C tests at frequencies related to the safety significance and historical performance of the system's isolation l
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capabilities. This could, in effect, allow only one test to be performed during the 10-year ISI interval. The staff's position, as stated in Regulatory Guide 1.163, i
Performance-based Containment Leak-Test Program, is that the licensee is to establish test intervals of no greater than 60 months for Type C tests because of uncertainties (particular1y unquantified leakage rates for test failures, repetitive / common mode I
failures, and aging effects) in historical Type C component performance data. While this Enclosure
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. 5-year limit results in an increased time betwesa testing over that required by Section XI (40 months), it is believed that Appendix J tests are more appropriate and provide reasonable assurance of the continued operability of containment penetrations.
Please provida information concoming the Option B inspection frequency at Crystal River Unit 3 (CR-3) for the subject examinations and clarification as to whether the proposed test frequencies will exceed the 60-month interval for a Type C test as stated in Regulatory Guide 1.163.
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4.
Reauest for Relief 98-005-PT Code Case N-533 does not provide details of the l
examination parameters for the system pressure test or VT-2 visual examination with i
insulation in place. The staff determined that the system pressure test and corresponding VT-2 visual examination with the insulation in place is to be performed L
with a minimum 4-hour hold time after attaining a test pressure of not less than the nominal operating pressure associated with 100% rated reactor power. The 4-hour hold allows time for leakage to penetrate the insulation, providing a means of detecting any significant leakage with the insulation in place. Please provide specific details concoming the hold times associated with this proposed altamative.
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5.
Reauest for Relief 98-01011. Code Case N-508-1 proposes an attemative to the current l
Section XI, Paragrapn IWA-7000 requirements in regard to generating a replacement plan when removing snubbers or pressure relief valves for testing. The following l
additionalinformation is required to complete our evaluation of the request to implement this Code Case at CR-3.
a.
Provide a detailed description of the snubber and pressure relief valve replacement plans utilizing the Code Case.
b.
Provide a clarification of FPC's intention to comply with "same design and construction," as indicated in item (a) of the code case.
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c.
Provide a clarification of what would be considered repair or replacement of both j
removed mechanical and hydraulic snubbers, as far as the use of an NIS-2 form is concemed.
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Provide a discussion of the potentialimpact on the required plant snubber service life monitoring program due to the use of the Code Case.
e.
Provide a discussion of the traceability of removed snubbers from their supported systems, as a result of using the code case, and its impact on the ability to trace a potential affected system, which has previously contained such l
a removed snubber that eventually fails a functional test.
6.
Relief Reauest 98-001-SS. This relief request is to extend the schedule for visual examination and functional testing of safety-related snubbers from 18 months to 24 months to match the refueling interval schedule for CR-3. The following additional information is required to complete our evaluation of this request.
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The FPC request states that Subsection ISTD of the 1997 Addenda to ASME OM-1995 will be used in the CR-3 program. The staff has not approved this Addenda at this time, and inclusion in the CR-3 ISI program would be premature at this time. FPC is requested to provide justification for the extension of the inspection and testing of the safety-related snubbers without reliance on this Addenda.
b.
FPC is requested to provide the performance history for the safety-related snubbers covered by this request.
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