ML20031C624
| ML20031C624 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/24/1981 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TASK-A-07, TASK-A-7, TASK-OR JPN-81-74, NUDOCS 8110070363 | |
| Download: ML20031C624 (5) | |
Text
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POWER AUTHORITY OF THE STATE OF NEW YORK 10 COLUMBUS CIRCLE NEW YORK. N. Y. too19 t212) 397.6200 GEORG,E7 sERRy TRUSTEES opsnatina carnte JOHN 9 DYSON JOHN W. SO9?ON y a.torm?
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- P'"'*""""C8 CEO8tGE 6 INGALLS voc s cmainnea" JOSE SC IEDER Pas othf e CMetr RICH ARD M. FLYNN R O B E R f 1. M b.LM E t LEROY W. SINCL A F R E D E RIC K st C L A N st a cw ar remancias
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s September 24, 1981 JPN-81-74
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Mr. Harold Denton, Director
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Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commissio'n g
OCT 61981% 4 Washington, D.C.
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Subject:
J.A.
FitzPatrick Nuclear Power Station 4'f' Docket No. 50-333 Mark I Containment Long Term Program
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g.g Referetice:
Letter from T.A.
Ippolito USNRC to G.T., Berry PASNY dated January 13, 1981
Dear Sir:
The purpose of this letter is to provide you with an update of the Mark I long term program at the J.A. FitzPatrick facility.
As you are aware, the Commission issued an order on January 13, 1981 which requires that all modifications necessary to restore the FitzPatrick containment to the original matgin of safety be completed by October 31, 1981 or, if the plant is shutdown on that date, before the resumption of power thereafter.
The'FitzPatrick facility is scheduled to begin its next refueling ou'tage on October 31, 1981.
Thus, this restriction is of concern to the Authority since there are certain modifications, as described below, which cannot be installed within the deadline specified in the Commissian's Order.
Accordingly, this letter provides descriptions of a) the modifications completed to date b) the modifications planned for completion during the 1981 refueling outage and c) the modifications which cannot be installed during the 1981 refueling outage and should be completed during the 1983 refueling outage.
Each modification except those associated with torus attached piping has been categorized as either major or minor, depending upon their contribution to restore the containment to the original margin of safety.
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Modifications Accomplished to Date A.
The modifications listed below were completed during the 1980 refueling outage.
o Mitered Joint Saddlr.s (Major)
This modification consisted of full saddle supports under the tor'.s, tie down plates and saddle anchor bolts.
o Downcomer Ties (Major) o Vent Header Deflector (Major) o New Monorail (Minor) o Reroute of SRV piping in the wetwell (Major) 8.
Modificatin's Planned for Completion During 1981 Refueling Outage Currently, the FitzPatrick facility is scheduled for a refueling outage to commence on October 11, 1981.
During this outage, the remainder of the modifications categorized as major will be installed along with other modifications
't isted below.
For each of these modifications, engineering, design and procurement has been completed or is being finalized.
Vendors' fabrication is on schedule to support the 1981 outage.
o "T Quencher" and supporcs (Major) o Vent Header /Downcomer Stiffening (Major) o Modify internal piping o
RHR return line elbow o
Wetwell vacuum breakers o
Torus temperature monitoring thermowells o
Additional SRV Discharge Line vacuum breakers (Minor) o Torque saddle anchor bolts to base mat (Minor)*
Completion of this effort is pending the finalization of appropriate base mat analyses.
It is estimated that these analyses would not be completed until the beginning of 1982.
Therefore, the bolta may not be torqued during the 1981 outage but shortly thereafter since this work can be performed while the plant is in operation.
o 3-In addition, a temporary access opening will be made to the torus shell in order to install the above modifications.
Upon completion of the work, the opening in the torus will be closed.
Inplant SRV bloudown tests will be performed upon resumption of power.
C.
Modifications to be Deferred t$ 1983 Refueling Outage Modifications listed below for which deferral is needed until the 1983 refueling outage include torus attached piping modifications and support modifications for SRV discharge lines inside the drywell and wetwell.
This need arises from difficulties experienced in completing the analyses for piping systems attached to the torus and from recent Lindications that mect -
i cal dynamic loads be included in fatigue
_ana yses for class 2 3 piping.
This latter item is currently l
under discussion between the NRC Staff and the Mark I owners.
The analysis for piping attached to the torus shell has been beset with difficulties from the beginning due to development problems in the computer model which accounts for piping / torus dynamic interaction.
Also, these analyses could not be started until the results of the torus structural analyses were available.
Consequently, meaningful results were not obtained from this effort until very late in the program.
Analyses for. these lines currently are only fifty percent complete.
Utilizing the available resources to the maximum extent possible, completion of the analyses, design of modifications and procurement of equipment and material cannot be completed to support the 1981 refueling outage and meet the deadline specified in the Commission's Order.
Recent discussions with your staff has indicated that mechanical dynamic loads shall be factored in the fatigue analyses for Class 2 and 3 piping.
Fatigue. analyses completed to date have been performed in accordance with ASME Class II rules.
Therefore, reanalyses for piping which fall under this criteria will be required.
In the case of FitzPatrick, the modifications which are affected by this i
requirement will be torus attached piping, SRV discharge lines inside the drywell and wetwell.
For torus attached piping as noted above, modifications cannot be completed during the 1981 outage, and significant reanalysis will be necessary.
Analysis for SRV discharge lines in the wetwell have been completed and the scope of the required modifications determined.
For these modifications'therefore, reanalysis and subsequent redesign work will be required.
There have 1
been indications that this issue may similarly impact the SRV discharge lines within the drywell.
The additional analyses and design effort for these modifications cannot be completed in order to support.the 1981 refueling outage.
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An additional complicating factor exists at FitzPatrick; plant-unique shall response data due to SRV blowdown does not exist.
The Data was extrapolated from tests conducted in other riant in order to support the required schedule.
Confirmatory post modification SRV testing is scheduled to be performed upon completion of the 1981 refueling outage.
Due to the uncertainties associated with this approach; i.e.,
final analysis cannot be completed or verified until inplant data has been obtained, additional margin needs to be factored into the design witn the risk that additional modifications may be required later.
The recently identified NRC staff position that mechanical dynamic load be included in fatigue analysis adds another uncertainty to these modifications, Therefore, faced with these two uncertainties, the Authority has decided to use good engineering judgement to determine actual loads by inplant testing and proceeed with the fatigue analyses as previously described prior to installation of these modifications.
Thi_ more prudent course of action requires that the Commissions order date of October 31, 1981 be extended to July, 1983 or completi.on of Reload 5, whichever is later.
There are other compelling reasons for postponing the con.pletion of these modifications until the 1983 refueling outage.
The modifications in question do not significantly contribute to the overall containment structural integrity.
Thus, the major objective of the Mark I program, i.e.,
to restore the original margin of safety co the containment system, wauld be accomplished by completion of the modifications planned for the 1981 refueling outage.
In order to complete the torus attached piping a3 required by the Commission's Order, the 1981 refueling outage would have to be extended significantly, thereby imposing a heavy economic penalty to the Authority and the New York State consumers.
However, uhould this be the case, these modifications may prove insufficient after factoring the inplant tests results and performing the mechanical dynamic fatigue analyses.
If additional modifications are identified upon i
completion of these analyses (which is very likely given the uncertainties of the original analyses), significant additional radiation exposure to workers would be experienced.
For reasons stated above, the following modifications will be installed during the 1983 refueling outage:
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SRV pipe support within wetwell (Minor) if necessary o
Torus attached piping Additional SRV Lines supports / reinforcement of existing o
supports in the drywell (Minor) o Catwalk modifications (Minor) if necessary i
The Authority has been participating with the Mark I Ownars Group in discussions with your staff to secure the necessary relief frora the Commissions Orders.
This letter is being forwarded to you to
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i re-emphasize our concern with this situation-and support any efforts by you and your staff to obtain the Commission's approval for-extending the deadline in their Order from Gctober 31, 1981 to July 1983 or completion of Reload 5 whichever is later.
We trust that the information provided herein serves to show the Authority's commitment to complete the Mark I program in a timely manner and demonatrates the adverse impact should relief not be granted.
Your efforta in resolving this matter are greatly appreciated.
Should you have any questions or require further information, please do not hesitate to contact me.
Very truly yours, r
J.
a%e Senior Vice President i
Duclear Generation LG/
i cc:
J.
Linville P.O.
Box 41 Lyncoming, NY 13093
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