ML18096B504

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Condition of License J
ML18096B504
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 08/03/1976
From: Robert E. Uhrig
Florida Power & Light Co
To: Ziemann D
Office of Nuclear Reactor Regulation
References
L-76-281
Download: ML18096B504 (8)


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RT 50 DOCKET 01ATERIAL I'ILE NUMOEA I fO: Mr Zielhann QLETTEA I/IIOA IG IN AL QCOPV DESCAIPTION QNOTOAIZED NVNCLASSIFIED P AOP Florida Pwr &. Light Co Miami, Fla R E Uhrig.

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August 3, 1976 L-76-281 Office of Nuclear Reactor Regulation Attn:

Dennis L. Ziemann, Chief Operating Reactors Branch No.

2 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Ziemann:

Re:

St. Lucie Unit No.

1 Operating License DPR-67 Condition of License J

~ECRU AUG 9 1976~

LI,S, IRLCLSAR RLCVLAIOR'I COMMISS ION Moll Socllon Florida Power 6 Light Company (FPL) hereby requests that Section J of Enclosure 1 to the St. Lucie Unit No.

1 Operating License be deleted as a Condition of License.

As discussed

herein, FPL believes that this Condition has been satisfied and is 'no longer required.

The subject Condition of License reads as follows:

"J.

Control Element Drive Mechanism (CEDM) 44 shall be repaired or replaced at the next extended reactor shutdown expected to last at least two weeks."

This Condition was added by Amendment 4 to DPR-67, be-cause FPL was unable to complete the cold rod drop time testing required by a precEIding Condition of License.

The testing was required to preclude the reactor being made critical under conditions (i.e., cold) which had not first been tested for rod drop times, since it was conceivable that the plant would be in a cold critical condition at some time during its expected service lifetime.

This testing was not completed due to difficulty experienced in withdrawing the rod controlled by CEDM 44 in cold condition.

The test, procedure required that the two fastest rods be tested several times at various flow conditions.

It happened that the second fastest rod was that controlled by CEDM 44.

Al-though the rod could not be withdrawn successively in a cold condition in order to complete the required number of tests, it operated satisfactorily at hot operating conditions.

Accordingly, the license was conditioned to add Section J to Enclosure 1 of DPR-67 and to delete the authorization for low temperature criticality contained in Technical Specifica-tion 3.10.3.

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To Re:

Dennis L. Ziemann St. Lucie Unit No.

1 Operating License DPR-67 Condition of License J August 3, 1976 Page Since the issuance of Amendment 4 to DPR-67, the performance of the CEDM has improved considerably.

Although it initially required heating the RCS to approximately 360oF before the CEDM could be withdrawn consistently, it now reaches this level of operation at approximately 290oF.

The rod has been tested on several occasions since the initial cold rod drop time testing.

On June 12, 1976, during a maintenance

shutdown, and following cooldown to 260oF, the rod was withdrawn three times in succes-

- sion and dropped once.to verify its previous timing. It was then wit'hdrawn and dropped nine times in succession under various flow conditions in accordance with the test procedure.

During the heatup back to power on June 18, 1976, the rod was again tested and was withdrawn successfully at 260oF.

However, on July 10, 1976, during the shutdown to investigate an observed power distribution anomaly and following cooldown to 260 F, the rod was successfully withdrawn, on the first attempt, but could not be fully withdrawn on succeeding

'attempts.

Thus, although considerable improvement has been observed in its withdrawal at low temperature, the CEDM continues to show some inconsis-tency in its performance.

Despite this inconsistency successive withdrawal of the rod at the test temperature has occurred sufficiently to allow completion of the cold rod drop time testing.

These tests establish the rod controlled by CEDM 44 as the fastest rod during successive drops at low temperature under various flow conditions.

These data have been reviewed by the Facility Review Group and are available onsite for review by Region II I&E personnel.

Having satisfactorily completed the required testing, the repair of CEDM 44 loses any significance it may have had as a Condition of. License.

Difficulty. in withdrawal at low temperature now has only operational significance since a fully inserted rod is inherently safe.

Thus, the repair of CEDM 44 becomes more appropriately a routine maintenance item rather than a Condition of License.

Furthermore, the performance of the rod at low temperature does not even have operational significance since FPL has no intention of reinstating Technical Specificatioh 3.10.3 which would allow low temperature criticality.

Although FPL believes that Section J is no longer a necessary Condition of License, FPL does plan to undertake inspection of the mechanism during the present, outage.

Upon removal of the CEDM upper guide structure, the extension shaft of CEDM 44 will be visually inspected.

Following removal of'the reactor

head, the mechanism'ill be inspected internally using a

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To:

Re:

Dennis L. Ziemann St. Lucie Unit No.

1 Operating License DPR-67 Condition of License J August 3, 1976 Page boroscope to determine whether any material obstructions or configurational anomalies exist.

The CEDM coils will then be energized and the grippers will be exercised.

The horoscope will be used to observe their manner of operation.

Flushing will be undertaken as required.

Upon completion of this in-spection and during the subsequent

heatup, CEDM 44 will again be tested at 260 F.

The inspection efforts for CEDM 44 are expected to require one week.

Since replacement may not be necessary, and since replacement would require two weeks to complete-which would, thereby, interfere with the present reactor inspection and testing program (the reactor head will be off for only one week), replacement of CEDM 44 is not planned during this outage.

Should the efforts during this outage prove unsuccessful, the mechanism will be tested during the next scheduled refueling outage and replaced if necessary.

All indications are that CEDM 44, which's located in the northeast quadrant of the core, is not a factor in the power distribution anomaly which has been observed in'he northwest quadrant of the core.

On the basis of the foregoing, FPL believes that it has satis-fied the requirements leading to the incorporation of Section J

into the St. Lucie Unit, No.

1 Operating License and that future repair or replacement of CEDM 44 is a routine maintenance matter.

This repair is no different from that of any other CEDM which fails to operate properly during the service life of the reactor.

Repair or replacement of CEDM 44 will be undertaken in a manner which will not impact the present schedule for inspection and testing to resolve the observed power distribution anomaly.

Accordingly.,

FPL requests that Section J of Enclosure, 1 to, the St. Lucie Unit.No." 1 Operating License be deleted.

Id Yours very truly, Robert E. Uhrig Vice President REU/LLL/hlc cc:

Norman C. Moseley, Region XX Jack R.

Newman, Esq.

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