ML20006B878

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Responds to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Personnel Should Use Directives,Procedures & Training Lesson Plans to Manage Plant Svc Water Sys & Other Plant Sys
ML20006B878
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/30/1990
From: Beard P
FLORIDA POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0190-17, 3F190-17, GL-89-13, NUDOCS 9002060033
Download: ML20006B878 (7)


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. c oR Po R AT p DN January 30, 1990 3F0190-17 7 U. S. Nuclear Regulatory Commission L Attn: Document Control Desk Washington, D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Response to Generic Letter 89-13:

Service Water System Problems Affecting Safety-Related Equipment.

Dear Sir:

Florida Power Corporation (FPC) is submitting this response in L accordance with the 10CFR50. 54 (f) request in the subject letter.

l dated July 18,'1989, p

The letter classifies service water either as open-cycle or closed-

, cycle systems. Accordingly, the CR-3 Nuclear Service and Decay l

Heat ~ Seawater System (RW) -is an open-cycle system while the Nuclear Service closed Cycle cooling System (SW) and the Decay Heat Closed Cycle Cooling System (DC) are closed-cycle systems. The SW System l and' the ' DC System are physically separate and ' do not share l: ta components. All three systems are classified as safety-related.

l The RW System supplies seawater to the operating heat exchanger (s) l g in the SW and DC systems for all plant operating modes. The SW l ogo System is in service at all times, but the system heat loads vary crio$ depending upon the (.:quipment in operation. The DC System is used u - 58. during normal reactor cooldown, for heat removal during plant p g~ shutdown, and would be required for emergency cooling during a Loss of' Coolant Accident (LOCA). FSAR Figures 9-7, 9-8, and 9-10 show I' {$$ the flow diagrams for the RW System, SW System, and DC System, jg respectively.

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?8 . The generic letter requested each licensee to perform five (5)

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  1. aa actions to ensure that the systems which perform service water functions are in compliance and will be maintained in compliance f[

with the appropriate federal regulations. The majority of the referred actions were not developed in response to this letter, but .

GENERAL OFFICE: 3201 Thirty fourth Street South

  • P.o. Box 14042
  • St. Petersburg, Florida 33733 * (813) 866 5151 W

A Florida Progress Company

January 30, 1990 i 3F0190-17 Page 2 are ongoing activities which address the area of concern. FPC's response is numbered to agree with the generic letter.

I. The RW System is operated under a program of surveillance and  !

control techniques which have eliminated the incidence of flow 1 blockage problems. Preventative Maintenance Procedure PM-112, 1 "DC, SW, and SC Heat Exchanger Maintenance Inspection /

Cleaning / Shooting and Plugging," is performed on the operating cooler every 42 days or sooner if RW pump operating pressures indicate fouling is occurring. The PM program has been successful in preventing gross macrobiological fouling i of the RW System. Enclosure 1 to the generic letter suggests 4 that the service water system be continuously chlorinated l whenever macroscopic biological fouling species exist. The State of Florida Administrative Code imposes a water quality limit of Oe'l ppm per day which is near the limit of detection

for chlorine. In addition, the Environmental Protection L Agency's (EPA) Steam / Electric Effluent Guidelines in 40 CFR 423.12 limit the amount of chlorine discharged to no greater j than 0.2 ppm in a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. CR-3 cannot l operate with continuous chlorination of the RW System and meet  ;

i the federal and state water quality restrictions. The CR-3 i intake structure and raw water pits are inspected every l refueling outage to locate and remove foreign material L

including silt, marine growth, etc. that could reault in loss of the RW cooling path. FPC will maintain the use of PM-ll2 or an equivalent program as the flow ~ blockage preventative maintenance program.

l FPC is investigating chemical cleaning of the seawater side of the SWHE's and the DC System heat exchangers (DCHE) . While we do not expect state and federal water quality guidelines to become less stringent, FPC is continuing to investigate ,

water treatment methods which may be used in the RW system.

II. The generic letter requested that each licensee conduct a test l program to verify the heat transfer capability of all safety-related heat exchangers cooled by service water. FPC will use a combination of heat exchanger testing and frequent regular maintenance of heat exchangers in lieu of testing all safety-related heat exchangers as its program in response to  !

the generic letter. The performance of the closed-cycle 4 systems at CR-3 do not indicate the need for testing.

CR-3 has maintained a proactive chemical treatment of the I closed cycle systems since startup. Visual examination, via video, has shown the SW System side of the Service Water Heat j Exchangers (SWHE) to be free of corrosion and fouling. This .:

condition has been substantiated by physical examination of e -

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J January 30, 1990 l

.3F0190-17 i Page 3 i pulled tubes. Corrosion inhibition is not presently warranted based upon the examination of the removed tubes.

Some heat exchanger testing has already been performed at CR- l

3. In 1987, an NRC Operational Safety Team Inspection (OSTI) '

identified a discrepancy with the design. temperature for the ultimate heat sink (UHS). To confirm operability, the  :

manufacturers of all safety-related components (i.e., motor  ;

coolers, heat exchangers, etc.) provided documentation and/or analysis to permit operation with cooling water at temperatures slightly above that specified during original procurement. FPC also performed a thermal hydraulic analysis on the RW, SW, and DC Systems to confirm that the appropriate i UHS temperature would not cause other plant systems, components, and equipment to exceed established temperature limits. This evaluation has been previously submitted and accepted by the NRC. In addition to this analysis, FPC did ,

actual performance testing of the SWHE's in June ~1988. This i testing confirmed that the actual heat transfer coefficient exceeded the heat transfer coefficient assumed in all I analyses. The thermal hydraulic analysis performed on the ,

( SWHE's used the overall heat transfer coefficient associated with 20% fouling.

FPC has established, based on this analysis / testing progran, that FPC's preventative maintenance program will maintain cooling system compliance with NRC requirements. FPC continues to monitor the performance of its RW, SW, and DC Systems. We do recognize that improved periodic testing can provide valuable data for monitoring plant performance. FPC is evaluating the level of testing that will be necessary to maintain our conclusion that CR-3's respective service water systems will perform their safety functions. This evaluation is also covering any modifications necessary to support increased surveillance and testing of the SW system. This I periodic testing program is in the planning stage, and any 5 modifications or tests would be planned for completion by the

  • end of Refuel 8 which is scheduled to begin in the Spring of 1992. This schedule is compatible with the generic letter schedule. A summary of the program will be documented and all relevant documentation retained in plant records.

III. As FPC stated in Section I, CR-3 has an established preventative maintenance program for the RW heat exchangers as described in PM-112. CR-3 also has an ongoing program for RW piping under which personnel will inspect the internal condition of large bore lined piping during Refuel 7 scheduled to begin in March 1990. FPC will replace any RW pipe not meeting the acceptance criteria. The results of this program will be documented and maintained in plant records. Future

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January 30, 1990 3F0190-17 Page 4 activities and planning will depend upon the results of this inspection.

IV. As FPC stated in Section II, a confirmation of the RW, SW, and DC Systems design has been performed. The design confirmation program required an increase in the technical specification UHS temperature limit to 95'F. This technical specification change request was reviewed by the NRC and the NRC issued Technical Specifications Amendment No.109, dated February 14, 1989. In addition to this confirmation program, the following activities which were planned before the generic letter was issued, will be used by FPC to meet the intent of the requested action.

a. Single Failure Proof Design To support the development of an Equipment Qualification Master List (EQML) . FPC is developing Shutdown Logic Diagrams (SLD's) and Safety Function Diagrams (SFD's).

The SLD's depict all the systems required to mitigate the design basis accidents described in Chapter 14 of the CR-3 FSAR. The SFD's depict all components of a system required to achieve a particular safety function. In addition to supporting the EQML, the SFD's will also be used to confirm that the SW, RW, and DC Systems will perform their safety function with a single active failure.

b. As-Built Configuration The previous and ongoing efforts of several FPC nuclear departments including Systems Engineering, Quality Programs, and Configuration Management continue to demonstrate that the as-built system configuration is in accordance with the appropriate licensing basis documentation. The overlapping responsibilities, among these independent groups, particularly regarding system walkdowns, minimizes the opportunity for any anomaly going undetected.

FPC uses the System Engineer approach to designate the person accountable for maintaining an awareness of system performance. The current RW/SW systems engineer periodically walks his equipment down, reviews plant performance data to observe trends in system performance, observes the maintenance and repair of system components, and participates in the EPRI Service Water Assistance Program (SWAP).

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. i January 30, 1990 l 3F0190-17 Page 5  :

1 The Quality Programs Department (QPD) performs vertical audits on safety-related systems at CR-3. Such an audit -

reviews the various aspects of system fit and function.  !

A selection of Operating, Surveillance, and Abnormal #

procedures are reviewed in conjunction with applicable i electrical and flow diagrams. Various forms of design j basis information are reviewed for consistency. A random selection of design change packages are reviewed to >

ensure that all administrative, technical,and regulatory  :

concerns are adequately addressed. Complete system walkdowns focus on system function, instrument calibration, housekeeping, and general system condition.

Recommendations are brought to the attention of the responsible organization for review and corrective action, if necessary. QPD completed an audit of the RW and DC Systems in November 1989 with no major findings.  ;

While the . generic letter did not require the reconstitution of the design basis of the service water  ;

systems, such a program is ongoing at CR-3 with the Configuration Management Program. The existing Design '

Basis Documents are being replaced with Enhanced Design Basis Documents (EDBD) for each system. To support this '

effort,.all original design basis calculations are being assembled and reviewed. Key assumptions used in the ,

original analyses are being reverified. The effort will conclude with a comprehensive system walkdown. The current schedule for the EDBD's and the walkdowns of the RW, SW, and DC systems are consistent with the -

. recommendations of the generic letter. 1 V. Maintenance practices, operating and emergency procedures, and training at CR-3 involves a comprehensive -!

set of management directives, plant operating quality .

assurance manual procedures, training department procedures. FPC uses a 24-month review cycle for all Nuclear Operations Department directives and procedures.

Revisions to these documents can also occur whenever updated information is obtained from various sources.

For example, review of technical information is l

controlled by Administrative Procedure AI-404A, " Review of Technical Information" and AI-404B, " Review of Industry Operating Experience. These procedures cover T correspondence from sources external to FPC. Included in these sources are technical information from Babcock

& Wilcox (B&W), new vendor manuals / vendor manual revisions, B&W Transient Assessment Program (TAP)

Reports, INPO Significant Operating Experience Reports (SOER), INPO Significant Events Reports (SER), INPO Significant Event Notices (SEN), NRC Notices, selected

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January 30, 1990 ,

3F0190-17 '

Page 6  !

EPRI/NSAC Reports, etc. This process has been  ;

established to ensure that " lessons learned" can be i factored into plant maintenance, operations, training, and engineering.

FPC confirms that its personnel use the directives, procedures, training lesson plans, etc. to manage the CR- ,

3 service water systems, as well as, other plant systems, components, and equipment. Evaluations by FPC's QPD, as well as outside groups such as INPO, support our i confirmation. Corrective actions are identified and  ;

properly dispositioned. As stated earlier, CR-3's management practices are on-going. If the periodic surveillance programs or periodic testing indicate that modifications to the systems are necessary or that procedures should be revised, FPC will follow its established programs to ensure that its systems remain in compliance with regulations.

Sincerely, P. M. Beard, Jr.

Senior Vice President Nuclear Operations t 1

PMB/JWT l xc : - Regional-Administrator,-Region II Senior Resident Inspector L

STATE OF FLORIDA COUNTY OF PINELLAS P. M. Board, Jr. states that he is the Senior Vice President, Nuclear Operations for 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 matters set forth therein are true and correct to the best of his knowledge, information, and belief.

AA.<A P. M. Beard, Jr., Senior Vice President Nuclear Operations Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 30th day of January 1990.

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Notary Public d

No.tary Public, State of Florida at Large NOTARY PUBLIC ST ATE OF FL6RIDA My Commission Expires:_ Nb!fi0 gtyp 2 2,.

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