ML19289F538
| ML19289F538 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/05/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| 3--3-A-3, 3-0-3-A-3, NUDOCS 7906110152 | |
| Download: ML19289F538 (7) | |
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cooce Florida Power C O R PO M A T eO N June 5, 1979 File:
3-0-3-a-3 Director of Nuclear Reactor Regulation U.S. Regulatory Commission Washington, D.C. 20555 Attention:
Mr. Robert W.
Reid, Chief Operating Reactors Branch #4
Subject:
Crystal River Unit #3 Docket No. 50-302 Operating License No. DPR-72 ECCS Small Breaks Analyses
Dear Sir:
In Florida Power Corporation's submittal of August 4, 1978, we requested that an exemption be granted to the provisions of 10 CFR 50.46 (a)(1) pursuant to 10 CFR 50.12 and that Crystal River Unit 3 be licensed to operate at full rated core thermal power of 2452 MWt.
On September 1,1978, as part of Amendment 16 to Operating License No. DPR-72, the Commission granted the exemption with an expiration date of May 1, 1979.
The operator action requirements and implementations submitted on June 14, 1978, justified startup and operation of Crystal River Unit #3 at full power until a permanent solution to the ECCS Small Breaks Analyses problem could be approved and put into effect.
The permanent solution was submitted for review on July 21, 1978 and approved on May 29, 1979.
On March 14, 1979, an exemption was requested to 10 CFR 50.46 (a)(1) so that Crystal River Unit 3 could start up after the April 1979 refueling outage based on a 31 week implementation schedule subsequent to NRC approval of the permanent solution.
The current implementation of that permanent solution is shown on the attached installation schedule. An outage of greater than fourteen (14) days in MODE 5 (Cold Shutdown) may be required to complete the installation and perform functional tests if the Plant is required to shut down upon the receirt of the final piece of equipment.
However, most of the installation can be performed while the plant is in operation. An outage of approximately three to four (3-4) days in MODE 5 will be required to complete the modification if all possible installation is completed prior to that shutdown.
2230 530 7906110 / f2
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General Office 3201 Tnirty-fourtn street soutn. P O Box 14042. St Petersburg. F!onda 33733 e 813-866 5151
Page 2 June 5,1979 The installation of this permanent modification is of the highest priority to Florida Power Corporation and all avenues of expediting the attached schedule are being employed including making premium payments for rush orders.
If the NRC required Florida Power to install this modification during the present outage, this will extend the outage from the present scheduled startup date of June 16, 1979 to July 20, 1979 (34 days) assuming that all equipment is delivered as scheduled. This would necessitate Florida Power buying electricity from other utilities to meet the demand of our system during one of the highest demand months.
Economically, this would cost our consumers $15,300,000 in replacement fuel costs and it would increase the probability that FPC will not be able to supply its firm load customers by a factor of 3 in June and 5 in July.
An outage of Crystal River Unit 3 decreases the system reserve by about 20% and this will result i.. raescive reserve margins during the last two weeks in June, 1979.
If the NRC required Florida Power to shut down the Plant upon receipt of the final piece of equipment, the modification could be implemented in a two week outage contingent on the receipt of the final piece of equipment (scheduled for July 6, 1979).
This would cost our consumers $6,300,000 in replacement fuel costs and would increase by a factor of 2 the probability that our firm load customers would not be supplied their power requirements.
If the NRC required Florida Power to shut down Crystal River Unit #3 solely to implement this modification, this would take a three-to-four-day outage subsequent to July 20, 1979 contingent on timely equipment delivery and the desire to plan the outage for a weekend to minim!ze the economic impact to our customers. This would allow for the maximum tustallation of equipment while the Plant was operating.
This would entail $1,800,000 in replacement fuel costs and a minimal increase in the probability of not being able to supply our firm load customers.
It is hereby requested that an exemption be granted to the provisions of 10 CFR 50.46 (a)(1), pursuant to 10 CFR 50.12, and that Crystal River Unit #3 be licensed to operate at the licensed rated core thermal power until August 6, 1979. The justification for startup and operation of Crystal River Unit #3 until August 6, 1979, is identified in our letter of June 14, 1978, and is applicable to this requested exemption.
This date is based on the proposed schedule with allowances for late equipment delivery and to allow the necessary flexibility in the operation of Crystal River Unit #3 to meet the required load demands that may exist at that time.
As this is a clarification of the exemption request forwarded to you on March 14, 1979, no licensing fee is applicable.
2230 331
Page 3 June 5, 1979 In our submittal of July 21, 1978 of the permanent solution to the ECCS Small Break Analysis problem, it was stated that "an operator must ensure sufficient HPI flow in 15 minutes following the Engineered Safeguards (ES) actuation." This was based on the May 1,1978 letter from B&W [J. H.
Taylor] to the NRC [R. L. Baer).
In Section 2.2 of that letter, operator action was assumed to begin at five (5) sinutes after an ES signal and be concluded fif teen (15) minutes af ter the signal.
This linear ramp of increasing IIPI flow was modeled in the CRAFT code as a step function at ten (10) minutes.
Because the proposed permanent solution will more nearly follow the step function rather than the linear ramp of HPI flow and the fact that it has not been shown that a step increase of HPI flow at greater than ten (10) minutes will mitigate the small break accident, the operation action in the control room to mitigate the small break accident using the proposed permanent solution must be completed within ten (10) minutes of receiving the ES signal.
If you have any questions, please contact this of fice.
Sincerely, FLORIDA POWER CORPORATION i LCA 2230 332 W.P. Stewart Manager, Nuclear Operations WPSemhF06 D14 Attachment
INSTALLATION STATUS OF ECCS PERMANENT SOLUTION AS OF 5/29/79 A.
MATERIAL DELIVERY 1) 4 MCC Buckets 6/8/79 (Allen Bradley) 2)
Lot Cable (Kerite) 6/8/79 3)
Lot Conduit 6/8/79 4) 4 Relays (GTE/Sylvania) 6/8/79 5) 4 Escutcheon Plates 6/22/79 4
Nameplates 4
Selector Switches 24 Indicating Lights 24 Lamps (Unit Electric Control) 6)
4 MCC Sections 7/6/79 (Gould/ Brown Boveri)
B.
ENGINEERING FPC has received construction work packagen from Gilbert Associates for conduit and cable installation. All construction work packages are due from Gilbert Associates by June 22, 1979.
2230 333 WPSemhF06 D14
STATE OF FLORIDA COUNTY OF PINELLAS W.
P. Stewart states that he is the Manager, Nuclear Operations, of 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 cntters set forth therein are true and correct to the best of his knowledge, information and belief.
1 6
DLO(A W.
F.~ Stewart Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 5th day of June, 1979.
Mb u
u4-Notary Public // ~
Notary Public, State of Florida at Large, 2230 334 My Commission Expires:
July 25, 1980 (CRPNotary 1 D12)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
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DOCKET No. 50-302 FLORIDA POWER CORPORATION
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CERTIFICATE OF SERVICE W.
P. Stewart deposes and says that the following has been served on the Chief Executive of Citrus County, Florida by deposit in the United States mail, addressed as follows:
Chairman, Board of County Commissioners of Citrus County Citrus County Courthouse Inverness, Florida 32650 An original copy requesting exemption to 10 CFR 50.46 (a)(1).
FLORIDA POWER CORPORATION
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0 EO h Sco, ach Y W. P. Stewart
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Manager, Nuclear Operations SWORN TO AND SUBSCRIBED BEFORE ME THIS 5th DAY OF JUNE, 1979.
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6 L Notary Public
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7 Notary Public State of Florida at Large My Commission expires: July 25, 1980 (NOTARIAL SEAL)
(Cert. Serv.D12)