ML20062K879
| ML20062K879 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/13/1982 |
| From: | Mardis D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.17, TASK-TM 3F-0882-09, 3F-882-9, NUDOCS 8208180046 | |
| Download: ML20062K879 (2) | |
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.P.o...w..e...r August 13, 1982
- 3F-0882-09 File:
3-0-26 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 NUREG-0737, Item II.K.3.17 Report on Outages of Emergency Core Cooling Systems
Dear Mr. Stolz:
In your request for additional information on the subject item (dated July 8,1932) you requested Florida Power Corporation (FPC) to provide supplemental information to our March 31, 1981 submittel on this item.
Your requests and our responses follow.
Item 1:
A complete summary of outages for surveillance testing in the ECC and diesel generator systems for the period coin-ciding with the initial report (i.e., December 3,1976, to March 17,1981).
Response 1: While surveillance testing of the ECC and diesel generator systems took place as required during the period of the initial report, the duration of these outages is unrecord-ed.
Therefore, no summary of outages is forwarded as it would be meaningless without specific duration information.
(See Response 3 below).
Item 2:
Clarification of the basis of the table of non-reportable occurrences and inclusion of outage durations.
Response 2: As stated in our March 31, 1981 letter, the basis for the jON table of non-reportable occurrences is "those remaining
[ equipment] outage incidents (e.g., due to testing or main-tenance during shutdown) where the system or component was not required to be operable per the CR-3 Standard Technical Specifications".
The example in parentheses is only one example.
If equipment was not required during power opera-tion, it could be taken out of service and not reported.
8208180046 820813 PDR ADOCK 05000302 P
PDR General Office 3201 in.rty fourth sireet soutn. P O Box 14o42. St Petersburg. Florida 33733 813-866-5151
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Mr. J. F. Stolz August 13, 1982 Page 2 The key is whether or not the equipment was required to be operable by the Crystal River Unit 3 (CR-3) Technical Spec-ifications in the mode of operation at the time of the equipment outage.
For example, taking a high pressure in-jection pump out of service for testing during power opera-tion is not reportable if the other two pumps are opera-tional as required by the CR-3 Technical Specifications.
Item 3:
Wherever outage durations are not available for an outage event, an estimate of the outage duration should be supplied.
Response 3:
FPC cannot with good engineering judgement, estimate a duration for an equipment outage when such duration is not docunented.
To estimate a longer than actual outage dura-tion would indicate that the ECC systems were unavailable more than they actually were.
This would lead to a false conclusion that additional requirements are needed to limit this outage time. To estimate a shorter than actual outage duration would indicate that the ECC systems were more available than they actually were.
This would lead to a non-conservative conclusion that the ECC systems were more available than they actually were.
Based upon our evaluation of CR-3 ECCS outages, the total outage time the ECCS has been inooerable has been minimal when compared to the total time the systems were required to be operable by the CR-3 Technical Specifications.
Therefore, a cumulative outage limitation for the Emergency Core Cooling System is not warranted.
Very truly yours, M
David G. Mardis Acting Manager Nuclear Licensing Attachments j
Bright (T01)Cl-3 cc: Mr. J. P. O'Reilly Regional Administrator Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street, NW Ste. 3100 Atlanta, GA 30303 L