ML19262C297
| ML19262C297 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/06/1980 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-578 3--3A-3, 3-0-3A-3, NUDOCS 8002080661 | |
| Download: ML19262C297 (4) | |
Text
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9 1f f
,9 Florida Powe, r February 6, 1980 File:
3-0-3-a-3 Mr. Harold R. Denton Director Office of 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 Short-term Lessons Learned Recommendations
Dear Mr. Denton:
This letter supplements Florida Power Corporation's letters of October 17, 1979, November 17, 1979, and January 11, 1980, concerning implementation of the NUREG-0578 Lessons Learned Recommendations and the Commission's January 2,1980, Show Cause Order.
Florida Power Corporation hereby requests an expansion of the exemption for implementation of NUREG-0578 Lessons Learned Recommendations, Item 2.1.3a, Power Operated Relief Valve and Safety Valve Direct Indica-tion, granted on February 1,1980, to iriclude Item 2.1.4, Diverse Contain-ment Isolation.
We stated in previous submittals that the modification would be implemented and tested during plant operation.
After reviewing the details of the final design package and installation /
test procedure, we have determined that the final installation / test por-tion of the modification has the potential for creating an unsafe operat-ing condition.
The details describing our safety concerns and course of action are identified in Attachment 1.
Florida Power Corporation will meet with you, at your convenience, to ex-peditiously resolve any of your concerns as well as to finalize Crystal River Unit 3's outage plans.
1944 333 8002080 b$/
General Of fice 3201 Ntvourtn sneet soum. P O Box 14042. St Petersburg Fienda 33733 e 813 866 5151
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Mr. ilarold R. Denton Page Two February 6,1980 Should any unforseen circumstances arise that preclude Florida Power Corp-oration's implementation of the Short-term Lessons Learned Reco:miendations as identified in this request and previous submittals, we will inform you within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the ci rcumstances involved and any changes in commitments.
Very truly yours, FLORIDA POWER CORPORATION ad 4"P d
Dr P. Y. Baynard Manager Nuclear Support Services PYBitureg0578(Ltr2/6/80)DN-94 Attachment i944 334
STATE OF FLORIDA COUf1TY OF PITELLAS Dr.
P.
Y.
Baynard states that she is the Manager, fluclear Support Services, of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the fluclear 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 her knowl-edge, information, and belief.
twN.
Wad
() Q/r. P. 'YT Baynard Subscribed and sworn to before me, a fiotary Public in and for the State and County above named, thi.s 6th day of February,1980.
b Luw f4m flotary Public flotary Public, State of Florida at Large, My Conmission Expires:
August 8, 1983 l'9 4 4 3 3 5 PYBitureg0578(fiotary)Dfl-94
ATTACHMENT 1 p-Recommendation 2.1.4 - Diverse Containment Isolation Based on power reliability considerations as identified in our submittal of January 14, 1980, Florida Power Corporation requests an extension through March 31, 1980, for the final installation / test cf the Diverse Containment Isolation Modification.
At that time, the modification could be tested, strongly considering both plant safety concerns and industrial safety Concerns, in conjunction with the scheduled refueling outage.
The prelimi na ry installation of cabling will still be completed by February 15, 1980.
The consequence of not obtaining this extension is that the plant will shut down on February 15, 1980, for approximately 10 to 12 days to perform the final installation / test. As stated above, an outage during this peri-od may jeopardize the reliability of the Florida Subregion System.
Florida Power Corporation stated on January 11, 1980, that this modifica-tion would be installed and tested on or before February 15, 1980.
This was based on tha issuance of the Construction Work Package (CWP) to the plant on January 11, 1980, the approximately 4 to 5 weeks' installation time required, and the testing with the unit on-line.
The installation / test procedure, which was not part of the CWP, was sub-mitted to the plant on January 28, 1980.
This procedure required revi-sion, a nd the CWP and the procedure were s ubmi tted for Plant Review Committee (PRC) recommendations and approval on January 31, 1480. The PRC determined the test method not to be as encompassing as that indicated in our discussions with Region 11 I&E Inspectors.
The installation / test pro-cedure was expanded and resubmitted to the PRC on February 4,1980.
The CWP and installation / test procedure were recommended for approval to the Nuclear Plant Manager, with the reservation that the final i nstallation/
test portion of this modification be perfonned in at least MODE 5.
The reservation identified is the result of safety considerations and li-cense considerations.
The possibility of inadvertent actuation of an iso-lation valve while on-line could, for example, result in the loss of cool-ing water to critical plant conponents, depressurize the Core Flood Tanks, or isolate the Reactor Coolant Pump seal returns.
This, therefore, has the potential for creating an unsafe operating condition.
In addition, performance of the final installation / test procedure while on-line would place the plant in a Technical Specification ACTION Statement.
This Statement could be exceeded if any problen is encountered with the final installation / test procedure.
Based on present estimates of working two 10-hour shifts daily for prelim-inary installation, and nine shif ts for final installation / testing, this modification could have been installed and tested by February 15, 1980.
PYBNureg0578(Atch1)DN-94 i944 3315