3F1297-33, Provides NRC W/Util Plans for Resolution of Unresolved Safety Issue (USI) A-46, Seismic Qualification of Equipment in Operating Plants & Large Bore Piping & Piping Supports

Provides NRC W/Util Plans for Resolution of Unresolved Safety Issue (USI) A-46, Seismic Qualification of Equipment in Operating Plants & Large Bore Piping & Piping Supports

ML20202H312
Person / Time
Site:	Crystal River
Issue date:	12/08/1997
From:	Rencheck M FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR 3F1297-33, NUDOCS 9712100242
Download: ML20202H312 (3)

Text

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Flrrida Power Ej.fmfdAf E*Mo*E.'.w.o%n December 8,1997 3F1297-33 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Plans for Resolution of US! A-46 and Large Bore Piping and Piping Supports ,

References:

1. FPC to NRC IGter,3F0897-01, dated August 1,1997, " Crystal River 3 - Request for Additional Infbrmation on the Resolution of Unresolved Safety Issue (USI) A-46 (Generic Letter 87-02)"

2. FPC to NRC letter, 3F0397-28, dated March 27,1997, " Verification of Seismic Adequacy of Equipment in Operating Ileactors Unresolved Safety issue (US!) A-46"

3. FPC tc NRC letter,3F1197-46, dated November 18,1997,"Large Bore Safety-Related i

Piping Calculations (TAC No. 99948)"

Dear Sir; The purpose of this letter is to provide the NC with Florida Power Corporation's (FPC) plans for resolution of Unresolved Safety Issue (USl) A-46, " Seismic Qualification of Equipment in Operating Plants," and Large Bore Piping and Piping Supports. The detailed plan, as discussed with the NRC on December 2,1997, is as follows:

Unresolved Safety issue A-46 FPC provided its schedule for overall resolution of USI A 46 indicating it will be improved from its earlier commitment of Refueling Outage 12. FPC is resohing the safety related outliers prior to restart from the current unit outage and will address the remaining non-safety related outliers by restart from Refueling Outage 11. This schedule and p!an is consistent with FPC's goal of resoMng USI A-46 in a systematic manner. Although the schedule for resolution of USI A-46 is an NRC commitment, the resolution of the safety related outliers for this outage is a self-identified commitment. FPC management has determined that the resolution of the identified safety related outliers prior to startup g;;'

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from the current outage is important to achieve the goal for a timely closure of USI A-46 for Crystal h'T' River Unit 3 (CR-3). The iemaining non-safety outliers will be addressed prior to startup from Refueling Outage 11.

g Eili, M.

FPC will make every effort to resolve the remaining non-safety related activities during our upcoming Bi!.

Cycle 1I operation. In the interim, FPC will perform an operability / safety assessment of the remaining non-safety related outliers to assure that the failure of any of the outstanding non-safety related outliers E.

will not affect the ability to achieve safe shutdown of the plant. This will be performed prior to restart ,

from the current outage. I

-bD d , i In addition, FPC plans to submit supplemental information to clarify FPC's response to the NRC's i Requests for AdditionalInformation (References I and 2). This submittal will also provide inforrnation

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9712100242 971200 4 Fl rfda Progress Comparty PDR ADOCK 05000302 i_ P PDR n

U.S. Nuclear Regulatory Commission 3F1297-33 Page 2 of 2 to support resolution of NRC USI A-46 sudit follow-up items that were identified to FPC in November 1997. FPC plans to submit the supplemental information by December 12,1997.

Large Bore Pipine and Pinine SuDDort For large bore piping and piping support, FPC discussed how the issue relates to incomplete and inadequate engineering documentation for large bore piping and piping supports. In mid-1996. FPC recognized a potential issue with the hck of adequate engineering calculations to support the qualification of safety related large bore piping and piping supports. To address the issue, FPC chartered an independent reviewer (Wais and Associate.2) to perform an assessment of the adequacy of existing documentation to support current licensing and design basis requirements. The assessment raised a concern with incomplete and inadequate engineering documentation. FPC initiated a corrective action document (Precursor Card 97-0048) to document the condition, assess the extent of condition and develop an action plan for the resolution. As part of the action plan, a second independent review (J.D. Stevenson Consulting Engineer) was performed to determine the cumulative effects. This review concluded that no safety concerns exist with respect to the as-designed and as-installed safety related large bore piping and supports. These assessment reports were submitted to the NRC on November 18,1997 (Reference 3). In adoition, due to the generic aspect of the issue, FPC issued a voluntary Licensee Event Report (LER 97-040-00) on December 4,1997.

In a meeting between the NRC and FPC on December 2,1997, FPC provided examples of calculations /cnalyses of large bore piping and pipmg supports. This information was requested to support the NRC s aff's ongoing inspection. The sample calculations mcluded Modification Approval Records @ tars) and operability calculations.

FPC plans to perform a comprehensive and rigorous inspection, revalidation and/or requalification of CR-3 safety related large bore piping and piping supports. A project scoping report is currently in development that will define the scope and duration of this effort. This effort will address the issue of a lack of adequate engineering documentation, as well as address the various technical issues identified.

FPC currently anticipates the program will take 4-6 years (2-3 fuel cycles) to implement. This actisity will be captured in FPC's long range planning. FPC is also developing a Justification for Continued Operation (JCO) fer documenting our conclusion of the assessments prior to the unit's restart.

Commitments made in this letter have been included in the attachment. If you have any questions regarding this letter, please contact Mr. David F. Kunsemiller, Manager, Nuclear Licensing at (352)563-4566.

Sincerely,

$ .A%c&

M.W. Rencheck, Dirbctor Nuclear Engineering and Projects MWR/gh Attachment xc: Regiona! Administrator, Region II Johns P. Jaudon, Director Division of Reactor Safety, NRC RII Senior Resident hspector >

NRR Project Manager

U.S. Nuclear Regulatory Commission Attachraent 3F1297-33 Page !of1 3

Attachment to 3F1297-33 ,

Lbt of Regulatory Commitments The following table idemifies those actions committed to by Florida Power Corporation in this documera. / ay mher actions discussed in the submittal represent intended or planned actions by Florids Power Corporation. They are described for the NRC's imormation and are not regulatory cortaitments. Please notify the Manager, Nuclear Licensing, of any questions regarding this document or any associated regulatory commitments.

f ID NUMBER COMMITMENT DUE DATE g 3F1297-33-1 For USI A-46: FPC is resolving the safety prior to restart frem related outliers. current outage 3FlH7-33 2 For USl A-46: The remaining non-safety related by restart frota outliers will be addressed. Refueling Outage 11

/

3F1297-33-3 For USI A-46: FPC will perform an operability / prior to restart from safety assessment of the remaining non-safety current outage related outliers to assure tlat the failure of any of the outstanding non-safety related outliers will not affect the ability to achieve safe shutdown of the plant.

3F1297-33-4 For Large Bore Piping and Piping Supports: the program will take Perform a comprehensive and rigorous 4-6 years (2-3 fuel inspection, revalidation and/or requalification of cycles) to implement CR-3 safety related large bore piping and piping suppons.

3F1297-33-5 For Large Bore Piping and Piping Supports: prior to restart from FPC is developing a JCO for documenting our current outage conclusion of the assessments, l

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