ML20041F710
| ML20041F710 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/04/1982 |
| From: | Mardis D FLORIDA POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 3F-0382-04, 3F-382-4, TAC-48020, NUDOCS 8203170322 | |
| Download: ML20041F710 (2) | |
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- 3F-0382-04 File: 3-0-3-c Mr. liarold R. Denton, Director g
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Of fice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission FS Washington, D. C. 20555
SUBJECT:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Reactor Coolant Pump Power Monitor Response Times
Dear Mr. Denton:
This letter is provided to document conversations during the evening of March 3,1982, among members of your staff, Florida Power Corporativn, and Babcock and Wilcox. Our conversations focused upon operation of Crystal River Unit 3 with the reactor coolant pump power monitor response times in excess of Technical Specification limits. The attached summary provides background information of the situation and justification for continued operation of Crystal River Unit 3 at reduced power levels, until justification for full power operation can be provided.
Florida Power considers the requested action to require a Class lit approval per 10 CFR 170.22 as it involves a single safety issue. Accordingly, the license fee in the amount of four thousand ($4,000) dollars is attached.
Very truly yours, Y0 m$
David G. Mardis Acting Manager Nuclear Licensing EFW/ mig Attachment 0\\
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8203170322 920304 PDR ADOCK 05000302 P
PDR General Office 3201 in rty fourin street souin. P O Box 14042 st Petersburg. Florda 33733 813-866 5151
JUSTIFICATION FOR CONTINUED OPERATION WITH THE REACTOR COOLANT PUMP POWER MONITOR (RCPPM)
RESPONSE TIMES IN EXCESS OF TECHNICAL SPECIFICATION LIMITS March 4,1982 BACKGROUND By Amendment 46 to the Crystal River Unit 3 Technical Specifications, the NRC approved operation of Crystal River Unit 3 at an increased power level for Cycle 4.
Table 3.3-2 (Reactor Protection System Instrumentation Response Times) included the response time for Nuclear Overpower based on RCPPM's as 0.47 seconds. This time delay was shorter than was approved by Amendment 41. The reason for this reduction was assumed to be the addition of conservative corrective factors for Reactor Protection System instrument inaccuracies. More recent review indicates the change was simply a change in philosophy associated with testing acceptance criteria. The 0.47 second delay represents expected time response of certain parts of the equipment, not the safety basis.
JUSTIFICATION All safety analyses in support of Cycle 4 operation were performed utilizing a time response of 620 milliseconds. In fact, License Amendment 41 included this as the technical specification value. No analytical reason for reducing the specification has been identified as mentioned above.
Operation without " OPERABLE" RCPPM's is considered justified at a reduced power level for the following reasons:
The only other Reactor Protection System related change supporting a.
the power level increase was a decrease in the conservatism for the flux / flow trip set points and response time taking credit for the anticipatory trip of the RCPPM's. The effect of these changes (1.08 vs.
1.044 and 1.79 vs.1.4 seconds) can be balanced by reducing power operations.
A reduction of 25% Full Power is considered quite conservative.
b.
Even though the RCPPM's are technically " INOPERABLE", per our Technical Specifications, they are in fact operable with a response time (including recently added time delays) of 6.560 seconds which is weil within safety analysis limits and relatively close to the Technical Specification limits.
Operation outside of Technical Specification Limits is not expected to c.
continue for any extended period of time.
CONCLUSION Operation at no more than 75% Full Power (Overpower trip set points of 79.92%)
will not constitute an unreviewed safety question. Ultimate resolutions, change to Technical Specifications will be accomplished in a timely fashion.