ML20054L177

Provides Addl Clarification in Response to NRC Re Status of NUREG-0737,Items II.B.2,II.B.3 & II.F.1.1-6. Analysis to Support Redesign of Refuel III Scheduled for Completion by 820930

ML20054L177
Person / Time
Site:	Crystal River
Issue date:	06/30/1982
From:	Mardis D FLORIDA POWER CORP.
To:	Stolz J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-TM 3F-0682-36, 3F-682-36, GL-82-05, GL-82-10, GL-82-5, TAC-49544, TAC-49573, NUDOCS 8207070233
Download: ML20054L177 (4)

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Mr. John F. Stolz, Chief Operating Reactors Branch #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 Status of NUREG-0737 Items II.B.2, II.B.3, and II.F.1.1-6

Dear Mr. Stolz:

On April 14, and June 18, 1982, Florida Power Corporation responded to an information request to justify the completion schedule of the subject items as requested by your letter

dated March 17, 1982. As a result of discussions with your staff during their site visit on June 24 and 25,1982, this letter provides additional clarification to our letter of June 18, 1982.

Item II.B.2 Design of Plant Shielding and Environmental Qualfication of Equipment for Spaces / Systems Which May Be Used in Post Accident Operations. This item was scheduled for completion during Refuel 111 (Fall 1981). The original design for modifying seven (7) valves evaluated to need modification was completed in May 1980. This design needed further refinement due to physical interferences. However, rework was not started until April,1981, because of the manpower drain caused by the February 26, 1980, incident at Crystal River Unit 3. Upon initiation of the rework, the need for two (2) additional design modifications to the valves was identified due to structural limitations on the valves. This redesign began in October,1981, and will be completed in August,1982.

The structural portion of the work package was originally issued to the site for procurement in September,1981. Material could not be received in time for installation during Refuel 111.

The redesign-work material was ordered in March,1982. Delivery is now expected in August 1982. Operator extension mechanisms were received in April, 1982 (delayed from November,1981); however, qualification paperwork will not be completed until July,1982.

8247070233 020630 DR ADOCK 05000302

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PDR U General Office 3201 inirty-fourin street sourn . P O Box 14042. St Peersburg. Florida 33733 813-866-5151 s-,

Mr. John F. Stolz June 30,1982 Page 2 An installation layout check has been performed, and the necessary wall cores have been bored. The remainder of the installation work can be completed by September 30, 1982, provided design work is completed, and equipment is received as expected.

Item II.B.3 Post Accident Sampling. This item was designed and issued for installation during Refuel III; however, due to design and material procurement problems, the installation was not completed. ALARA considerations caused a redesign of the proposed sump sample heat exchanger. Incomplete penetration modification design work also caused the incompletion of this project during Refuel Ill. Due to the complexity of this task, additional analysis was required to complete this design effort. The additional analysis could not be done in time to support completion during Refuel 11I or shortly thereaf ter.

Resolution of these problems and completion of the redesign effort is underway with completion scheduled by, September 30,1982.

Long-lead sample analysis equipment has been ordered and only the online chemical analysis equipment (i.e., boron and chloride analyzers) pose potential delivery problems.

Procurement of the sample conditioning equipment (e.g., heat exchanger, manual valves, and sample pump) has not been initiated because of incomplete designs. ' Orders (based upon redesigns) are scheduled for issuance in July,1982. Based on a preliminary review of equipment needs and associated lead times, delivery problems are not anticipated. The total project will be separated into discrete sections in order to maximize non-outage work prior to Refuel IV, (Spring,1983). The next available refueling outage (Refuel IV) may be required to complete this modification based upon expected delivery dates of to be ordered equipment.

Item II F.1.1 Noble Gas Effluent Radiological Monitor and Item II.F.1.2 Continuous Sampling of Plant Effluents. These items are scheduled to be completed during Refuel IV. The design of this modification had not advanced to the point where installation was possible during Refuel Ill. The analysis equipment to comply with II.F.1.1 and ll.F.1.2 has been on order since February,1982; however, because of development problems in the area of background shielding requirements and the resulting instrument sensitivities, the design of the additional shielding of this equipment will not be completed until July, 1982. The shielding modifications not only include the addition of shielding but also the changing of the placement of modules within the analysis equipment. This changing of module placement directly affects the plant modifications necessary to install the analysis equipment. The design of plant modifications necessary to install the above equipment was thus delayed.

Completion of this design effort is scheduled for September,1982, with equipment delivery in October,1982. The remaining equipment required for installation consists of electrical cable and sample tubing with attachments. The actual installation may be possible during plant operation but in any case, it will be completed during Refuel IV.

Item F.1.3 Containment High Range Radiation Monitor. This item is scheduled to be completed during Refuel IV. During Refuel Ill, the seismic supports for tv detectors were fabricated, coated, and installed in the containment. The detectors are on site and available for final installation. The conduit runs and the cabling pulling in the containment were completed but not terminated at the penetration. The triaxial termination connections were not available during Refuel Ill but are available now. The rest of this work and the installation of the readout modules and power supplies in the control room remains to be

Mr. John F. Stolz June 30,1982 Page 3 completed. This includes the fabrication and installation of a seismic support for the readout modules. The design work not available during Refuel III has been completed, and all material needed to complete this item is on site. Pre-outage installation of this item will be completed prior to RefuelIV with final work such as cable terminations in the Reactor Building and Control Room to be completed during Refuel IV.

Item II.F.1.4 Containment Pressure Monitor. This item is scheduled for completion during Refuel IV. The work package was originally issued in July,1981, but was separated into Refuel (11 work and Refuel IV work when the transmitters, relay racks, recorders, and other equipment could not be delivered in time to be installed during Refuel III. Work completed during Refuel 111 included the installation of conduit and pulling the cable. The transmitters were installed in the Spring,1982, and the redesigned relay racks from item II.F.1.6 are delaying other installation work. The recorders were not ordered until May,1982, because of potential 10 CFR 21 equipment evaluations. They are due to be delivered later this year.

The delivery of the new relay racks in July,1982, and the recorders later this year will permit advancement of additional pre-outage installation work. Total installation of this project is precluded by the power supplies which are now on-site, because of their placement in the Engineered Safeguards test cabinet. An outage of approximately two (2) weeks will be required to finish this installation af ter all pre-outage work is complete and all remaining equipment is received and ready to be installed.

Item II.F.1.5 Containment Water Level Monitor. This item is scheduled for completion during Refuel IV. The work package was originally issued in July 1981, but was separated into Refuel III work and Refuel IV work when the transmitters, relay racks, recorders, and other equipment could not be delivered in time to be installed during Refuel Ill. In containment work planned to be completed during RefuelIIIincluded in-sump welding of the mounting brackets for the sump and flood level transmitters. During this installation work in Refuel III, an engineering evaluation of the welding surface and further ALARA considerations determined that the brackets should be mounted outside the sump. This design change precluded completion of some of the planned Refuel III outage work. The cable and conduit portion of this modification was completed during Refuel III. The design changes identified during Refuel Ill have been completed and upon delivery of the relay racks and recorders additional pre-outage work can be advanced. Total installation of this item requires an outage of approximately two (2) weeks (due to the inside containment and control room work that is still remaining) after all pre-outage work is complete and all remaining equipment is received and ready to be installed.

item II.F.1.6 Containment Hydrogen Monitor. This item is scheduled during Refuel IV. The original system design for this project was completed and ready for issuance in April,1981; however, an evaluation of available H2 monitors indicated a change in manufacturer was warranted for regulatory and reliability reasons. The original hydrogen monitor was specified because it was the monitor on the commercial market at that time that came closest to meeting the NRC requirements. Also, its operation during reactor building spray operation was questionable. The new monitor does meet all regulatory requirements and will operate in a reactor building spray atmosphere. The evaluation showed that completing the installation during RefuelIll would not have resulted in a system which could be relied upon and, as it turned out, the containment penetration work could not have been completed to support such an installation. Thus, a design change was initiated which precluded installation during Refuel III and which is presently scheduled for completion by September 30,1982. All major equipment has been ordered and is on site and the only items

9 Mr. John F. Stolz June 30,1982 Page 4 remaining to be delivered are two relay racks which are scheduled for a July,1982, delivery. Another equipment problem is that of documentation associated with Target Rock solenoid valves which we are attempting to resolve by September,1982. This project is being broken into individual sections such that non-outage work can be initiated and completed before the outage in order to minimize the outage impact. The major outage work of this project is the modification of two spare containment penetrations, the connection of new sample lines to existing containment sample lines, and routing of inside containment sample lines.

All of these proposed design modifications have interim steps (modifications, procedures, operator training, etc.) in effect. These measures will remain in effect until the final upgrades (as previously described) are made. Based upon our good faith efforts to complete these modifications during or shortly after Refuel III, Florida Power Corporation contends these unanticipated problems should not preclude continued operation of Crystal River Unit 3.

Very truly yours,

. S mA David G. Mardis Acting Manager Nuclear Licensing DGM:mm cc: Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 3100 Atlanta, GA 30303

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