ML20064D275
| ML20064D275 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/24/1978 |
| From: | Early P POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| JNRC-78-54, NUDOCS 7811010111 | |
| Download: ML20064D275 (3) | |
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POWER AUTHORITY OF THE STATE OF NEW YORK t o Cot.uMeus CIRCI.E NEW YORK. N. Y.10019 (212) 397 8200
- "*'JERA""? A.ER AND CM6EF ENetNEER FREDERICK R. CLARK LEWi.,R,.,.,gN,Eg,,,,,
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manAo ERMBE NERAb GEORGE L. INGALLS COUNSEL VICE CMAIRMAN WIL.UR L GRONBE ARCHARD M. FLYNN M AN AGE R.E M SIN E E RING ROBERY 8. MILLONZI
[R Cro or WILLIAM F. LUDDY October 24, 1978 yg o,, ",, ""'[,""
JNRC-78-54
=aamua Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. Thomas A.
Ippolito Operating Reactors Branch No. 3 Division of Operating Reactors
Subject:
JamesA.F[i trick Nuclear Power Plant Control Rod Drive \\ Scram Time Surveillance Docket No. 50-333)
Dear Sir:
The Power Authority is in receipt of your June 1,1978 letter j
which transmitted the results of the Commission's safety evaluation regarding the Authority's proposed reduction in frequency of control rod scram time surveillance requirements.
Based on a review of the Authority's submittal dated January 13, 1978, and subsequent generic discussions with General Electric Company on May 17, 1978,.the Commission concluded that interim operation of the control rod-drive system with the hydraulic return line valved off and isolated!from the reactor pressure vessel was acceptable for the remainder of cfcle 2r however, additional information would be required to support the proposed reduction in scram time testing.
r, Specifically, Attachment 1 of the June 1, 1978 letter, -" Suggested Topics for Discussion", outlined potential items for consideration associated with isolated operation of the hydraulic return line, including:
capability of system makeup, water flow to the vessel, effects of corrosion products from carbon steel system piping, and the status of recommendations set forth in General Electric Boiling Water Reactor Services Information Letter No. 200 and its Supple-ments (1 and 2).
Concurrent with the Commission's evaluation of such isolated operation of the control rod drive hydraulic control system, and under e\\
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4 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Page 2 the assumption that the system could be operated satisfactorily without drive performance deterioration with the line permanently j
eliminated, the Authority submitted to the Commission on June 20, 1978 their plans to cut and cap the return line at the refueling outage planned to commence in September, 1978.
However, the Com-mission transmitted a letter dated September 27, 1978 to the Authority indicating that the issue of the control rod drive return line modi-fication was "pending staff review" and further information from General Electric was required.
The Power Authority has under consideration several items i
associated with justifying such a reduction in scram time surveillance frequency.
Although installation of exhaust header filters is not currently thought to be feasible, neither is the replacement of carbon steel piping runs.
In fact, visual inspection has verified that there is very little carbon steel piping installed in the FitzPatrick drive control system.
Additionally, General Electric
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has provided the Commission with a copy of AID 45-77, " Control Rod Drive Hydraulic System Operation Without the Reactor Vessel Return Line", December 19, 1977, providing the results of initial tests on plants whose return line was isolated from the vessel, and indi-l cating that the control rod drive system could be operated satis-factorily without performance deterioration in this mode.
The Power Authority is also considering a statistical evaluation of FitzPatrick scram data in order to develop a revised scram time insertion curve and appropriate scram time limits.
Such an analysis would hopefully qualify the control rod drives for faster scram times.
The increased surveillance requirement of scram testing 15%
of the operable drives every eight (8) weeks, proposed as an interim measure by Amendment No. 30 to the FitzPatrick Technical Specifi-cations issued on September 16, 1977, was in effect during the i
i entire period of Cycle 2 operation.
Although the Commission's safety evaluation in support of Amendment No. 30 stated that such increased vs surveillance " compensates for an apparent reduced reliability of the drives" (due to increased likelihood of foreign material collecting in the drive mechanisms), it is the Authority's belief that such'a test frequency is restrictively high and impoces additional duty on the drives while contributing to a real reduction in reliability.
Such a high test frequency is also seen to be unacceptable from a point of view of unit capacity factor since such testing involves l
significant reductions in power.
While all of the above arguments are seen by the Authority as being sufficient to demonstrate that the omission of the exhaust j
header filters does not impair drive operation, a complete response l
to the Commission's concerns, as outlined in the June 1, 1978 letter, will not be possible until early 1979.
Thus, the Power Authority l
now plans to respond with additional justification by March 1, 1979.
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Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Page 3 In the meantime, the control rod drive hydraulic control system will continue to be operated in the isolated mode during Cycle 3 with the return line to the vessel valved out.
Very truly yours, f
PaulJ'.Earlyf Ass *stant Ch3 ef Engineer-Pr ects t
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