ML20023D329

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Submits Response to NRC Re Exemption from 10CFR50.44(c)(3)(iii), Reactor Vessel Head Heat. Interim Exemption Extending Implementation Deadline Requested Prior to Restart from Refueling Outage Scheduled for 830709
ML20023D329
Person / Time
Site: Crystal River 
Issue date: 04/29/1983
From: Westafer G
FLORIDA POWER CORP.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
3F-0483-26, 3F-483-26, TAC-44363, TAC-49060, NUDOCS 8305200378
Download: ML20023D329 (3)


Text

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Power C O n P o p a t s o se April 29,1983 3F-0483-26 Director of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Exemption to 10CFR50.44(c)(3)(iii)

Reactor Vessel Head Vent

Dear Sir:

Florida Power Corporation (FPC) has received and reviewed your letter dated February 22,1983, on the above subject. In our letter to you of March 9,1983, FPC committed to respond to your request for information by May 13, 1983. Those responses are given below.

Item I A commitment to perform the necessary integral system testing which demonstrates the efficacy of your proposed method of noncondensable gas removal from the reactor vessel head.

Response 1 FPC endorses the B&W Owners group letter dated January 13, 1983, and commits to perform the necessary integral system testing which demonstrates the efficacy of our proposed method of noncondensable gas removal from the reactor vessel head.

Item 2 A realistic scht.dule for the submittal of your evaluation of the test results which will verify analytical methods and operating procedures described herein.

Response 2 6

The latest schedule for submittal of the evaluation of the test results which will verify analytical methods and operating procedures is the First Quarter of 1987.

8305200378 830429 PDR ADOCK 05000302 P

PDR General Office 3201 Thirty-fourth Street Soum e P O. Box 14042. St. Petersburg, Florida 33733 e 813-866-5151

April 29,1983 3F-0483-26 Page 2 Item 3 A commitment that, prior to startup from the next scheduled refueling, the hot leg vents will have been installed and declared operable, procedures will be in place and operators will have beca trained for using the high point vents to vent noncondensable gas trapped in the reactor vessel.

Response 3 Prior to startup from the current refueling outage (Refuel IV), the hot leg vents will be installed and declared operable, procedures will be in place and operators will have been trained for using the high point vents to vent noncondensable gases trapped in the reactor vessel.

Item 4 Your Safety Analyris regarding the interim use of the above procedures for a period of time needed to conduct and evaluate the necessary integral testing program results, but not less than four years.

Response 4 FPC recognizes that the above procedures will be used for at least four (4) years since Response 2 references 1987 as the schedule for submitting our evaluation of the test results by which the NRC could grant a. full exemption request.

Florida Power Corporation justifies the continued operation of Crystal River Unit 3 in the interim for the following reasons:

1.

The sequence of events that could lead to the need to vent noncondensible gases from the reactor vessel head has a low probability of occurrence. In addition, FPC in conjunction with the B&W Owners Group, is evaluating the Reactor Coolant Pump (RCP) trip criteria and expects to change that criteria to safely allow the RCP's to operate to lower pressures than now allowed. This means that forced circulation will be available during more transients to aid the operators in bringing the plant to a stable condition.

f-2.

The procedures and high point vents referred to in Response 3 will be in place by the end of the current refueling outage and for the full interim period until the test results can be submitted in 1987.

3.

By December 31, 1983, the Emergency Operating Procedures required by Supplement I to NUREG-0737 will be in place, and the operators will have been trained on their use. These procedures address natural circulation (which is the only time _ when a head bubble would evolve) and give the operator system oriented recovery steps to bring the plant to a stable condition and then to cool down.

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April 29,1983 3F-0483-26 Page 3 FPC realizes that an interim exemption extending the implementation deadline of the reactor vessel head vent must be granted prior to restart from our current refueling outage which is currently scheduled for July 9,1983. In any case, your expeditious review of our request will be appreciated.

Sincer ly, o

G. R. Westafer Manager Nuclear Licensing and Fuel Management RMB:mm cc:

Mr. James P. O'Reilly Regional Administrator, Region II Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303 i

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