3F1086-04, Forwards Addl Info Supporting 860814 Tech Spec Change Request 147,amending License DPR-72 to Address Surveillance Interval for HPI Pump & Valve Test,Per 860919 Telcon Request.Related Info Encl

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Forwards Addl Info Supporting 860814 Tech Spec Change Request 147,amending License DPR-72 to Address Surveillance Interval for HPI Pump & Valve Test,Per 860919 Telcon Request.Related Info Encl
ML20215E494
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/06/1986
From: Widell R
FLORIDA POWER CORP.
To:
Office of Nuclear Reactor Regulation
References
3F1086-04, 3F1086-4, NUDOCS 8610150336
Download: ML20215E494 (11)


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Power CORPORATION October 5, 1986 3F1086-04 Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Change Request Number 147: Additional Information

Dear Sir:

Florida Power Corporation (FPC) submitted on August 14, 1986, Technical Specification Change Request Number 147 requesting amendment to Appendix A of Operating License No. DPR-72. This submittal addressed both the reactor vessel internals vent valves ' surveillance interval and the surveillance interval for the high pressure injection pump and valve test. On September 19, 1986, representatives of the NRC staff and Florida Power Corporation held a telephone conference call to discuss the amendment request.

Addi tional information concerning the request is provided as an attachment to this letter.

Florida Power Corporation is currently planning on 24-month fuel cycles for Crystal River Unit 3 (CR-3) and would like to offer the following perspective on this Technical Specification Change Request and the issue of extended surveillance intervals in general .

During the recent reactor coolant pump outage at CR-3, surveillances with 18-menth intervals were performed that would be required prior to the end of the current fuel cycle. However, two surveillances that necessitated removal of the reactor vessel head were not performed at that time.

Technical Specification Change Request Number (TSCRN) 147 addressed both surveillances, the reactor vessel internal vent valve surveillance i nterval , and the surveillance interval for the high pressure injection (HPI) pump and valve test. Florida Power Corporation considered the handling of the surveillances at CR-3 for the current longer cycle to be consistent with the guidance provided in the Staff's June 20, 1983 letter 3 SCO 8610150336 361006._ U PDR ADOCK 05000302 1I p PDR GENERAL OFFICE: 3201 Thirty-fourth street south

  • P.O. Box 14042 + St. Petersburg, Florida 33733 + (813) 866-5151 A Florida Progress Company

October 6, 1986

3F1086-04

. Page 2 I

rejecting ,TSCRN 82, Attachment D. The Staff encouraged accomplishment of surveillances "9 the extent possible" with the balance to be resolved on a i case by case basis. Florida Power Corporation considered the request to be relatively straightforward since a similar change request for the RVVV's 4 had been issued on another docket, and the HPI test was for one-time relief from the 18-month interval, and the test had been successfully run except the test was not done in Mode 6 as required by the Technical Specifications.

, Florida Power Corporation submitted the RVVV's test interval extension request based upon successful testing experiences. FPC did not include RCS l chemistry or RVVV's material data because the large quantity of test data

indicating the high reliability of these valves was considered adequate to
justify confidence the valves are performing acceptably. FPC also noted L that the surveillance is imposed to assure closure during normal operations rather than opening during transient conditions. This requirement was 1 identified in the SER referenced in the TSCRN 147 submittal with an j interval of each refueling. Review of actions taken on the TMI-I and. ,

Oconee dockets, discussions with other owners and review of the Davis Besse

submittal reinforce FPC's perspective that attempts to predict corrosion '

rates will add very little to the technical basis supporting this request.

l Many Technical Specification quantitative requirements (principally allowed outage times (A0T's) and surveillance test intervals (STI's)) have as their major basis reasonable engineering . judgement. Very little and sometimes no detailed technical basis exists. Except where adverse experience exists and where retention of current requirements could cause substantial consequences (resource, transient, shutdown or other), it is reasonable to consider good engineering judgement an acceptable basis for changes. Where no technical basis exists, it is difficult to reconstruct what a particular reviewer may have been considering several years ago and show such j considerations are unaffected by a change request. Had the aforementioned SER mentioned corrosion rates as a consideration, we would have clearly

] been obligated to re-review it. FPC considers it appropriate to keep

. submittals on issues of this type within a "necessary and sufficient" scope ,

' based on good engineering judgement. >

j In addi tion , FPC is the " lead plant" for the B&W Owners on the reactor 2 vessel vent valve surveillance interval issue. Such designations have been requested by NRC/ Technical Specification Coordination Branch to allow as many issues as possible to be resolved on a generic basis. Additional i specific technical information that does not significantly contribute to

the technical basis of the change request can uanecessarily reduce the generic applicabili ty of these issues. The reactor vessel vent valve surveillance interval issue directly addresses the 18-month surveillance J

October 6,'1986 3F1086-04 '

. Page 3 issue that will have to be resolved for extended (24-month) fuel cycles.

The current industry thinking is that the 18-month surveillance intervals should be changed to refueling intervals to accommodate the extended fuel cycles.

FPC has been actively involved wi th the NRC's work on Technical Specification improvement and considers _the Staff's direction to be consistent with our understanding of the industry direction. However, the Staff has expressed concern that if the surveillance interval is changed to

" refueling" extended mid-cycle, outages could generate inordinately long intervals (e.g., several years). FPC has demonstrated good faith in this regard during our current cycle. Further, the NRC has sufficient means to prevent this from occurring without retaining the rigid values in the license itself. We believe this is consistent with current Staff actions such as the Policy Statement on TSIP currently being reviewed within the Staff. FPC currently perceives reluctance by the Staff to modi fy surveillance intervals and is concerned that this may be an indication that

- the Staff is not comfortable with longer cycle lengths.

FPC appreciates your consideration of our perspective and would welcome any comments or additional guidance on handling these issues in the future since FPC is planning on 24-month fuel cycles.

Sincerely, i

Rolf I Widell Manag , Nuclear Operations Licensing and Fuel Management a

RCW/feb Attachment xc: Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 i

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TSCRN 147 Supplemental Information

, Octot,er 6,1986 e

SCHEDULE The 18-month surveillance for the RVVV's was last performed on July 4, 1985. CR-3 Technical _ Specification 4.0.2 states the following:

, '"4.0.2 Each Surveillance Requirement shall be performed

, within the_ specified time interval with:

a. A maximum allowable extension not to exceed 25%_ of the surveillance interval, and i b. A total maximum combined interval time for l any three consecutive tests not to exceed
3.25 times the specified surveillance interval ." ,

As a result of the application of 4.0.2 b, the scheduled due date for the next surveillance of the RVVV's is prior to the end of the 18-month ,

interval. However, the next refueling outage when the reactor vessel head

, is removed and the RVVV's surveillance can be performed, is scheduled to begin on September 19, 1987. The interval from the last performed surveillance of the RvVV's .to the next refueling outage is 26.5 months.

t This interval is only four months greater than the maximum allowed surveillance ~ interval provided by Technical Specification 4.0.2 a.

RCS CHEMISTRY-

Tight reactor coolant chemistry controls are maintained to assure any l corrosion that may occur is insignificant. B&W plants either follow the

. specification provided in the "B&W Water Chemistry Manual for Duke Type j ' Plants" or other similar specifications.

~ Primary water chemistry at CR-3 is maintained in strict compliance with the

specifications listed in the "B&W Water Chemistry Manual for Duke Type Pl an ts" . CR-3 primary water chemistry specifications for chemical parameters known to affect general corrosion rates are shown in Table 1.

The bases for these specifications are to maintain a relatively benign

, primary environment such that corrosion and activation of primary-side components and equipment is minimized, and the life and reliability of these components is maximized. Primary-side pH and conductivity are maintained within the above referenced specifications. The concentration of corrosive species such as 30 4 , Cl , F1 , and 02 have been and are 3 consistently maintained at or below specified limits. Additionally, the hydrogen overpressure that is maintained on the primary environment tends

' to inhibit general corrosion by shifting the equilibrium of the oxidation reactions away from favoring metal oxide formation. Therefore, it is judged that the corrosion rate of RVVV's components is consistently maintained as low as practically achievable.

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MECHANICAL DESIGN / MATERIALS AND CLEARANCES All RVVV's for B&W 177 FA plants (including CR-3) were fabricated and supplied by Atwood and Morrill Company of Sal em , Massachusetts. The configuration of the RVVV's is depicted in the attached Figure 3-57 from the CR-3 FSAR. The RVVV's for the B&W 177 FA plants were made of the same materials. These materials were selected for the expected environment and service conditions. Materials utilized in the CR-3 RVVV's are listed in Table 2. These materials were chosen because of their compatibility with the reactor coolant.

Hinge interface clearances for the CR-3 RVVV's are provided in Table 3.

These clearances are provided for both cold and hot conditions. Clearances for the RVVV's for. the other B&W 177 FA plants are expected to be similar.

CONCLUSION As a result of the past testing history of the RVVV's,. the reactor coolant system chemistry controls and the RVVV's mechanical design, FPC considers the extension of the RVVV's surveillance interval is justified and that the existing reliability of the valves will be maintained.

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TABLE 1 CR-3 Water Chemistry Specifications for Parameters Affecting General Corrosion Rates pH at 770F 4.8 - 8.5 Conductivity at 770F 0.056 - 25.umho/cm Max. dissolved oxygen as 02 0.1 ppm Max, chlorides as Cl- 0.15 ppm Max. fluorides as F1- 0.15 ppm Max. total sulfur as S04 0.1 ppm Hydrogen as H2 15-40 std cc/kg H 2O

TABLE 2

., Reactor Vessel Internals Vent Valve Material at CR-3 Valve Part Material Specification Name and Form Valve Body 304 SS Casting ASTM A351-CF8 Valve Disc 304 SS Casting ASTM A351-CF8 Disc Shaft 431 SS Bar

. ASTM A276 Type 431 Cond-T Shaft Bushings Stellite No. 6 i

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h-TABLE 3 1- CR-3 Reactor Vessel Internals Vent-Valve Hinge Clearances (See Figure A for Locations)

A. Cold Clearance (at 70 F), in.

. Bushing ID 1.500 to 1.505 Shaft 00 1.490 to 1.485 0.010 to iT 076 Diametral clearance (gaps 1, 2,.7, and 8)

'+ Lug / Hub ID 2.000 to 2.005 Bushing OD 1.997 to 1.995 U.601 to 0.010 Diametral clearance i (gaps 3, 4, 5, and 6)

Bushing End Clearance i

Body Lugs 5.765 to 5.780 Disc Hub 4.750 to 4.740 1.015 to 1.040 Bushing s.992 to .980 Flange .023 to -.060 End clearance (gaps 9 and 10) f

.245x4=.980

.248x4=.992 B. . Hot Clearance (differential growth from 70 to 580 F) i Linear coefficient of thermal expansion of the materials for a temperature change from 70 to 580 F.

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Shaft -

A276-TP.431 6.7x10-6 in /in -F . .

Bushing -

Stellite No. 6 8.1x10-6 in./in.-F Bodies -

CF8 Stainless 9.5x10-6 in./in.-F i delta T = 580 - 70 = 510F 1

Shaft AD = DWAT = 1.5(6.7 x 10-6) 510 = 0.0351 Bushing ID AD = 1.5(8.1 x 10-6) 510 = 0.0062 0.0011 Typical diametral clearance increase Bushing OD.40 = 2(8.1 x 10-6) 510 = 0.0083 Lug / Hub ID.4D = 2(9.5 x 10-6) 510 = 0.0097 O.0014 Typical diametral clearance increase i

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TABLE 3 (Cont'd)

Bushing Endplay CF8 Lug / Hub AL = 1(9.5 x 10-6) 510 = 0.0048

.i Stellite No. 6 bushing A L = 1(8.1 x 10-6) 510 = 0.0041

0.0007 i Typical end clearance i

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