View source for 3F0484-11, Requests Change to Inservice Testing Requirements Allowing Pump Operational Tests to Be Performed Quarterly as Specified in ASME Code,Section IWP-3400 1980 Edition

{{Adams
| number = ML20083L225
| issue date = 04/12/1984
| title = Requests Change to Inservice Testing Requirements Allowing Pump Operational Tests to Be Performed Quarterly as Specified in ASME Code,Section IWP-3400 1980 Edition
| author name = Westafer G
| author affiliation = FLORIDA POWER CORP.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF ADMINISTRATION (ADM), NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0484-11, 3F484-11, NUDOCS 8404170184
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 1
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:a o
r* enc     *a OO.5 a fy &f0*,                                                                                                              .
ShO -' 00%
so o Y% 9         y
     '*Ye a e Florida Po...w. .e. ._r m
April 12,1984 3F0484-il Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation Attention: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Inservice Testing Program

==Dear Mr. Denton:==

In accordance with 10CFR 50.55a (g)(4) and (g)(5) Florida Power Corporation (FPC) hereby requests a change to the Inservice Testing (IST) program requirements for Crystal River, Unit 3 (CR-3). The current IST program is conducted in accordance with Section XI of the ASME Boiler and Pressure Vessel Code 1974 edition and addenda through summer of 1975.
10CFR 50.55a (b) (2) adopts Section XI editions through the 1980 edition and addenda through winter 1981. Section IWP-3400 of the code edition in effect at CR-3 requires monthly operational testing of pumps. FPC requests that approval be granted to perform pump operational tests at the frequency specified in section IWP-3400 of the 1980 edition, which is quarterly. Based on our review of Section XI requirements associated with IWP-3400 it is FPC's position that there are no related requirements which must be implemented upon approval of this change.
In NUREG-1024, " Technical Specifications - Enhancing the Safety Impact," the NRC Staff Task Force on Technical Specifications addresses the subject of periodic testing frequency. The report states, "In addition, frequot periodic testing of systems, with no compensating reduction in risk to the public, resi . in unnecessary diversion of operators and other plant personnel, economic costs, and, in some cases, excessive exposure to plant personnel which may be adverse to safety." Since the 1980 edition of the code and addenda have been endorsed by the NRC, and based on conversations with your staff and responsible NRC/OIE personnel, we have concluded that monthly versus quarterly pump testing provides no demonstrable or expected reduction in risk to the public.
                                                                                                                 /jo47 8404170184 840412 DRADOCK05000g GEN ERAL OFFICE 3201 Thirty fourth Street South e P.O. Box 14042, St. Petersburg, Florida 337336 813-866-5151

E s
4 April 12,1984 3F0484-11 Page 2     '
l s
L It is FPC's position that quarterly testing of pumps offers the advantages of reducing wear on equipment, reducing opportunities for personnel errors, and reducing radiation exposure while reliably demonstrating pump operability. Quarterly versus monthly testing at CR-3 would not result in increased risk to the public, but should in fact be an improvement in overall plant safety and reliability. The absence of this relief is costing FPC several           i thousands of dollars for contract support of the IST program. Therefore, your prompt attention will be appreciated.
Sincerely,                                                                                      l o
G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management
          . SCP/nsw cc:        Mr. 3. P. O'Reilly Regional A' dministrator, Region II.
                    . Office of Inspection & Enforcement -
U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900                                               l Atlanta,'GA -30303 1
4 t
i e
e.
                    ,}}