ML20024C181
| ML20024C181 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/06/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 3F-0783-07, 3F-783-7, TAC-42512, NUDOCS 8307120370 | |
| Download: ML20024C181 (9) | |
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M Power C O R P O R 4 ? a O ne July 6,1983 3F-0783-07 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 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 Environmental Qualification of Safety-Related Electrical Equipment
Dear Sir:
In a submittal to you dated May 20, 1983, Florida Power Corporation (FPC) provided detailed data for environmental qualification of electrical equipment in use at Crystal River Unit 3 (CR-3). That submittal indicated that the motors on four (4) motor operated valves (DHV-5, DHV-6, DHV-34, and DHV-35) would be replaced during the current refueling outage.
Efforts to procure qualified replacement motors for these valve operators were unsuccessful due to the fact that this older design of motor operator is no longer available with the type motor we require. FPC is now in the process of procuring complete new operators for these valves. Delivery time for these new operators is estimated to be 8 to 9 months, and it is anticipated that the installation can be done while the unit is in operation.
The attached Record Sheets and Justification for Continued Operation provides assurance that CR-3 can be safely operated until the new operators are received and installed; and provides new Pages 38, A-75, A-76, A-76-a, A-76-b, A-76-c, and A-78.
Also included is the required schedule for replacement.
Additionally, equipment required to be qualified by 10CFR50.49(b)(3) was not addressed in FPC's May 20,1983, submittal. FPC is participating with the Babcock and Wilcox (B&W)
Owners Group Task Force on Regulatory Guide 1.97. This Task Force is studying B&W plants and Reg. Guide 1.97 to determine where upgrades are required. FPC's schedule for these activities, submited April 15,1983, committed to submittal of a report documenting FPC's position on all items in Reg. Guide 1.97 in the 3rd Quarter of 1984. Installation of modifications required as a result of this work is scheduled for Refuel VI (beginning September 1986).
D 8307120370 830706 PDR ADOCK 05000302
/g P
PDR General Office 32o1 nurty-fourtn street soutn. P O. Box 14042, st. Petersburg, F orda 33733 813--866-5151
9 July 6,1983 3F-0733-07 Page 2 Thus, a position has not been developed at this time as to what equipment upgrades will be required in response te Reg. Guide 1.97. Therefore, for all equipment required to be qualified by 10CFR50.49(b)(3), FPC requests an exemption from the requirements of 10CFR50.49(g) until October 1,1984, for identification of equipment and scheduling of qualification or upgrade; and until December 10,1986, (the end of Refuel VI) for installation of upgraded equipment.
Sincerely, G. R. Westafer Manager Nuclear Licensing and Fuel Management Attachment AEF:mm cc:
Mr. James P. O'Reilly Regional Administrator, Region 11 Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303
.i 3.3 Compliance of Previous Submittals
- O l
By letter dated March 23, 1983, the NRC requested Florida Power Corporation to describe the level of compliance of previous submittals with 10 CFR 50.49.
All previous submittals comply with 10 CFR 50.49 except that those devices included in 10 CFR 50.49, paragraph (b) (2), were determined as requested by the original NRC SER (discussed in section 3.2).
This submittal is based on previous submittals and hence carries the same level of compliance.
3.4 Electrical Equipment Addressed by 10 CFR 50.49 (b) (3)
Post-accident monitoring equipment, as specified in Regulatory Guide 1.97, " Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Follow-ing an Accident," is not addressed in this submittal.
Due to the different time frames in schedules for compliance with 10 CFR 50.49 and Regulatory Guide 1.97, it is not possible to gather all the necessary data and firmly identify all equipment applicable in the time available for this submittal.
Regulatory Guide 1.97 devices which require environmental qualification are presently being identified in efforts underway at Florida Power Corporation and in B&W owners' groups.
Initial review of equipment indicates that approximately 30 items may have to be added to this submittal at a later date.
Florida Power Corporation will submit this material and schedule any equipment replacements commensurate with schedules applicable to Regulatory Guide 1.97.
O 38
i FLORIDA POWER CORPORATION 1
l QUALIFICATION STATUS
SUMMARY
SHEETS
( h.
U ID NUMBER:
DHV-5/6 RECORD NUMBER:
0044 SCEW PAGE NUMBER:
2-56 DESCRIPTION.
VALVE MOTOR LOCATION:
OPERATOR AUXILIARY BLDG.
ELEV. 95'-0" MANUFACTURER: LIMITORQUE TER EQUIPMENT NO.:
09 MODEL:
SMB-3-100 TER CATEGORY:
II.A SYSTEM:
DH ZONE LOCATION:
36 TER QUALIFICATION DEFICIENCIES NOTED:
- 1. DOCUMENTED EVIDENCE OF QUAL
- 2. EQUIP VS TEST SPECIMEN
- 3. AGING DEGRADATION EVAL
- 4. QUAL LIFE OR REPLACE SKED
- 10. RADIATION EXPOSURE (m
I QUALIFICATION STATUS:
NOT QUALIFIED.
t i
I CORRECTIVE ACTION:
REPLACE MOTOR.
g i
CORRECTIVE ACTION SCHEDULE:
APRIL 1984 MAR NUMBER:
82-05-24-08 JUSTIFICATION FOR CONTINUED OPERATION:
/~N
, ()
SEE ATTACHED.
A-75
Justification for Continued Operation N
DHV-5, DHV-6; DHV-34, DHV-35 Limitorque Motorized Valve Operators TER Item 9;2 References I
1)
FD-302-64, Revision 27, Decay Heat System Flow Diagram 2)
FD-302-651, Revision 25, Reactor Coolant Flow Diagram 3)
FD-302-702, Revision 12, Core Flooding System Flow Diagram i
4)
Environmental and Seismic Qualification Guide Specifications and
- Data, SP-5095, dated April 29, 1983; Section 4,
' Environmental Qualification Data' O'
Background
During the TER response activities, four (4) Decay Heat Valves (DNV-5, 6,
34 and 35) posed a potential problem.
Walkdown results indicated the motors on these actuators contained class H insulation which has not been tested to high radiation doses.
- Hence, the radiation resistance of those motors is undocu-mented.
(The calculated total integrated dose (TID) for 40 years plus a design base accidant for the installed location was obtained from reference 4 and included herein as Attachment I.)
l To eliminate any question of radiation resistance, Florida Power Corporation prudently decided to replace the motors with class B or RH insulated motors and remove the class H insulated motors due to inconclusive documentation.
(v A-76
Actions Florida Power Corporation initiated efforts to replace the motors on these actuators during the Spring 1983 outage, as well as pursue justifications for continued operation in the event replacement equipment could not be procured prior to the end of the outage.
JCO Efforts Review of References 1 through 3 revealed there were no redundant system arguments to provide a sound JCO.
Material breakdowns for class H insulation have not been made available hence, _ similarity in composition arguments are not feasible.
Since radiation exposure was the onl*/ item of concern, a justification for continued operation on the basis of operating experience of similar equipment in operating plants was pursued.
Such a JCO would be considered valid if:
.O 1.
The actuators in the operating plants contained motors with class H insulation, and 2.
The actuators and motors in the operating plants had received a TID which exceeds:
a.
the current TID of the motors installed at CR-3 olus b.
the TID the installed motors will receive during a design base accident olus c.
the TID that will be received between the present and the planned date of replacement.
First, calculate the dose we must exceed.
V A-76-a
(~
The equipment is located in zone 36. indicates a 40 8
6 year dose of 1X 10 R or a yearly dose of 2.5 X 10 R for this zone.
The scew sheets for this equipment indicate a required post accident operating time of 30 days. indicates 4
a dose of 8.9 X 10 R for the associated post accident operating time.
Crystal River maintenance records indicate these motors are the originals, therefore the current TID is 1.25 X 10 R.
The dose received for the accident is 8.9 X 10 R.
Assuming the motors remain in place until the next refueling outage the additional dose received will be 1.5 X
- 2. 5 X 10 R
=
3.75 x 10 R.
Therefore the total dose received by a class H insulated motor in other operating plants must exceed:
1.25 X 10 R
+
.009 X 10 R
+
.375 X 10 R Total 1.634 X 10 R Utilizing the EPRI Equipment Qualification Data Bank, plants that use the same type equipment were identified.
Plants in operation longer than CR-3 whose radiation scecification was equal to or i
greater than CR-3 for the equipment of concern were contacted.
It was learned that an operating BWR had similar equipment located in an environment which would receive a TID of 2 X 10 R l
In 40 years.
The current TID of the similar egoipment is 7 X 5 X 1
6 7
10 R = 3.5 X 10 R.
This exceeds the anticipated dose calculated for CR-3 and supports its continued operation.
GO A-76-b
Realizing that the larger dose rates occur during operation a comparison of the operating reports for both plants was made to validate implicit assumptions (e.g., yearly operation so that the yearly dose is indeed received).
The BWR's number of hours critical exceeded those of CR-3 by 10,725 (as of 12/1/82).
Cumulative unit availability factors were comparable.
Based on the above results the continued operation of CR-3 is justified on the basis of operating experience with similar equipment in harsher environments at other operating plants.
l l
i
. 'a A-76-c 1
f FLORIDA POWER CORPORATION QUALIFICATION STATUS
SUMMARY
SHEETS ID NUMBER:
DHV-34/35 RECORD NUMBER:
0046 SCEW PAGE NUMBER:
2-58 DESCRIPTION:
VALVE MOTOR LOCATION:
OPERATOR AUXILIARY BLDG.
ELEV. 75'-0"
- MANUFACTURER
- LIMITORQUE TER EQUIPMENT NO.:
l 02 1MODEL:
SMB-2-40 TER CATEGORY:
II.A SYSTEM:
DH ZONE LOCATION:
7 TER QUALIFICATION DEFICIENCIES NOTED:
- 1. DOCUMENTED EVIDENCE OF QUAL
- 2. EQUIP VS TEST SPECIMEN
- 3. AGING DEGRADATION EVAL
- 4. QUAL LIFE OR REPLACE SKED
- 10. RADIATION EXPOSURE
. QUALIFICATION STATUS:
NOT QUALIFIED.
i CORRECTIVE ACTION:
1 REPLACE MOTOR.
l l
CORRECTIVE ACTION SCHEDULE:
APRIL 1984 1
MAR NUMBER:
82-05-24-08 JUSTIFICATION FOR CONTINUED OPERATION:
(
SEE JCO FOR DHV-5/6; RECORD 44.
A-78
. -.