3F0285-02, Requests Exemption from Portion of 10CFR50,App A,Gdc 4, Per Provisions of 10CFR50.12.Meeting W/Nrc & B&W Requested to Clearly Define Staff Needs for Info to Support Approval of Request.Fee Paid

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Requests Exemption from Portion of 10CFR50,App A,Gdc 4, Per Provisions of 10CFR50.12.Meeting W/Nrc & B&W Requested to Clearly Define Staff Needs for Info to Support Approval of Request.Fee Paid
ML20101S104
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 02/01/1985
From: Westafer G
FLORIDA POWER CORP.
To: Harold Denton
NRC OFFICE OF ADMINISTRATION (ADM), Office of Nuclear Reactor Regulation
References
3F0285-02, 3F285-2, GL-84-04, GL-84-4, NUDOCS 8502050241
Download: ML20101S104 (4)


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M February 1,1985 3F0285-02 Mr. Harold R. Denton Office of Nuclear Reactor Regulation Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20535

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 REQUEST FOR EXEMPTION PROM A PORTION OF 10 CPR M, APPENDIX A, GENERAL DESIGN CRITERIA 4

Dear Mr. Denton:

Florida Power Corporation (FPC) hereby requests exemption from a portion of certain requirements of General Design Criteria 4 (10 CFR 50, Appendix A) pursuant to the provisions of 10 CFR 50.12(a). As indicated in Generic Letter 84-04, the staff has accepted the utilization of the leak-before-break concept on certain dockets as a means of obviating the need to Install certain piping / equipment support systems. The attached Exemption Request utilizes such methodology to support the exclusion of dynamic LOCA loads from the RCS piping, which will allow us to reduce the number of large bore hydraulic snubbers restraining the reactor coolant pumps. Attachment A summarizes this Exemption Request and Attachment B provides the scheduled milestones necessary to support snubber restraint arrangement modifications in Refuel VI. Pursuant to 10 CFR 170, a submittal fee of $150 is attached.

FPC hereby requests a meeting among NRC, Babcock & Wilcox, and FPC representatives to clearly define NRC staff needs for information to support your approval of this request. Mr.

Ken Wilson (904) 795 3802 (Extension 4549)is the FPC contact to arrange such a meeting.

Sincerely, G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management O

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f N G EN ERAL OFFICE 32011hirty fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

ATTACHMENT A EXEMPTION PROM A PORTION OP 10 CPR 50, APPENDIX A GENERAL DESIGN CRITERIA 4

' As required by Generic Letter 84-04, Florida Power Corporation (FPC) requests exemption,

' pursuant to 10 CPR 50.12(a), from a portion of General Design Criteria 4 (GDC-4) for

- Crystal River Unit 3. Specifically, FPC requests exemption from that portion of GDC-4 which requires protection of the reactor coolant system (RCS) from the dynamic effects (i.e., pipe whipping and discharging fluids) associated with a LOCA Involving double-ended

- rupture of RCS piping.

SCOPti OF REOUtiST:

Approval of this exemption will allow FPC to redesign the RCS pump restraint system in order to o- Remove several large bore hydraulle snubbers currently restraining the reactor coolant

. pumps (up to 20 out of a total of 32).

. o Replace other reactor coolant pump large bore snubbers with rigid restraints (4 restraints).

o Replace remaining reactor coolant pump large bore snubbers with smaller snubbers (8 smaller snubbers).

! FPC must remove all large bore snubbers for rebuilding and testing due.to service life considerations. Substantial Man Rem and dollar savings will be realized if these large bore ,

- snubbers do not have to be reinstalled or can be replaced with rigid restraints or smaller snubbers. These savings will be discussed in more detall in the safety balance value-impact statement that is being prepared 'for submittal consistent with the attached tentative schedule.

, Granting this exemption request would not affects o- ECCS design basis.

o Reactor building and compartment design basis.

o Equipment Qualification basis, o Engineered Safety Feature Systems response.

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o Cut.ently installed pipe whip restraints, jet Impingement shields and small bore RCS snubbers.

JUSTIFICATION FOR REOUEST:

On September 7,1984, PPC, as a member of the B&W Owners Group, submitted BAW-1847,

- " Leak-Before-Break Evaluation of Margins Against Full Break for RCS Primary Piping of B&W Designed NSS". This report provides the technical basis for determining that a double-ended guillotine break will not occur and that postulated flaws producing detectable leakage exhibit stable growth. The evaluation includes structural and fracture mechanics analyses using generic bounding data (loads and material properties) for all B&W Owners Group plants. The bounding loads and properties assumed are such that even with removal and/or replacement of the large bore snubbers, Crystal River Unit 3 is still bounded by the Generic Report. Additional justification will appear in the CR-3 plant-specific submittals shown in Attachment B.

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ATTACHMENT B TENTATIVE SCHEDULE

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Da'te of Action Action Item June 1,1985 Crystal River Unit 3 Leak-Before-Break Evaluation of RCS Piping Submittal to NRC June 1,1985 Crystal River Unit 3 Safety Balance Value-Impact Statement Submittal to NRC To Be Determined RCS Leakage Detection System Capability Evaluation Submittal to NRC October 1,1985 NRC Approval of Exemption

- July' 1986 Technical Specification Change Request Submittal to NRC j-October 1986 Refuel VI Begins

/ October 1986 NRC Approval of Technical Specification Amendment

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STATE OF FLORIDA COUNTY OF PINELLAS G. R. Westafer states that he is the Manager, Nuclear Operations Licensing and Fuel Management for 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.

n th G. R. Westafer g/

Manager, Nuclear Operations Licensing and Fuel Management Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 1st day of February,1985.

1 fM4 h Notary Putilic l Y

Notary Public, State of Florida at Large, My Commission Expires: November 19,1986

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