ML20002A258

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Responds to NRC Re Development of RCS Instrumentation for Detection of Inadequate Core Cooling. Licensee Plans to Develop Alternative Instrumentation Sys & Test Schemes at Loft Facility
ML20002A258
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/31/1980
From: Baynard P
FLORIDA POWER CORP.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
NUDOCS 8011050458
Download: ML20002A258 (3)


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-m 7,7. g;.., fyEaviCE3 co October 31, 1980 a la File:

3-0-3-a-3 Mr. Darrell G. Eisenhut Di rector Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Instrumentation for Detection of Inadequate Core Cooling

Dear Mr. Eisenbat:

l F1 orida Power Corporation has reviewed your letter of September 24, 1980, and offers the following response regarding development of a RCS water level measurement system.

We are in agreement with the statements made in Mr. J. H. Taylor's let-ter of October 7,1980, to Mr. D. F. Ross, Jr.

Specifically, we support the B&W position sumarized below:

1 We utilire a fixed incore thermocouple system already having a highly redundant, reliable indication of inadequate core cool-ing.

The readouts are valid to temperatures in excess of 2000 F.

Reliance on these core exit thermocouples and previously pub-lished operator guidelines for interpreting the available in-formation -is.the best and most direct method of determining that the inadequate core cooling' condition has occurred.

The incore thermocouples provide an unambiguous indication of the approach. and existance of inadequate core cooling, and will not erroneously indicate inadequate core cooling.

l The recently installed Tsat meter provides a longer term indi-cation cf the approach 'to inadequate core cooling since satur-ation conditions must.be achieved prior to approaching inade-quate core cooling.

Each ' reactor vessel level measurement system concept that we have reviewed fails to provide any additional aid to the oper-l

. ator for ' detection of inadequate core cooling.

Core I

General Office o Tn rty ounn c

. P O Box 14042. st bu'g. Fionda 33733 e 813-866-5151

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Mr. Darrell G. Eisenhut Page Two October. 31, 1980 l

i c'ooling'.is directly indicC cd by temperature measurement, not level measurement. The measurement concept fails to meet most of the NRC establP 1 criteria.

i The potentially ambiguous infonnation provided by the above pr.oposed RC level indication instrument systems could lead to j

unsafe and incorrect actions if the operator acted on the j

level indication.

No new or additional detectors are requirci to cover the full range of plant ci nditions.

i Although we feel the existing incrat thennocouple systei::, in conjunction with the redundard. saturation 6eters, provide advance warning of and un-ambiguous. indication of inadequate core cooling, we are interested in programs to develop other types of instrumentation to accomplish this same function.

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Therefore, we will actively pursue the development of such an instrumen-tation system with.the following understanding.

Before any inadequate j

core cooling detection system is installed or placed in operation at Crystal River Unit. 3, we will :omplete the design and testing and re-ceive NRC approval of such an instrumentation system.

Also, testing of various schemes at the LOFT facility would ba prudent to ensure ambigu-ous information does not lead to unsafe ard incorrect actions by an operator.

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Until such an' instrumentation system is designed, tested, and installed j

at our facility, we will continue to rely on the highly reliable incore thermocouple system and the saturation meters, coupled with existing op-erator guidelines, to correct conditions of core cooling, should they occur.

Si ncerely, FLORIDA POWER CORPORATION i

1 9Me atsy Y. Baynard Manager Nuclear Support Services Mardis(/YBekcF01)D-8 1

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1 STATE OF FLORIDA COUNTY OF PINELLAS P. Y. Baynard states that she is the Manager, Nuclear Support Services Department of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the Nuclear Regulatory Com-mission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of her knowledge, information and belief.

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d (/P. Y. llaynard Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 31st day of October 1980.

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Notary Public 47 Notary Public, State of Flcrida at large, My Commission Expires: June 8,1984 PYB/MAHNotary(DN-98)

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