ML20065B039

Clarifies Completion Schedule & Restates Compensatory Measures for NUREG-0737,Items II.B.2,II.B.3,II.E.1.2, II.F16.1-6.Item II.E.1.2 Completed During Refuel V.Other Items Completed During Refuel IV

ML20065B039
Person / Time
Site:	Crystal River
Issue date:	09/08/1982
From:	Hancock J 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.E.1.2, TASK-2.F.1, TASK-TM 3F-0982-07, 3F-982-7, GL-82-05, GL-82-10, GL-82-5, TAC-49544, TAC-49573, NUDOCS 8209140227
Download: ML20065B039 (6)

Text

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P M

Power ca..o....no September 8, 1982

1. 3F-0982-07 File: 3-0-26 Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 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, II.E.1.2, and II.F.1.1-6

Dear Mr. Stolz:

This letter documents recent discussions between Florida Power Corpora-tion and your staff which clarified the completion schedule and restated the compensatory measures for certain NUREG-0737 (" Clarification of TMI Action Plan") items. Specifically, we will address Items II.B.2, II.B.3, and II.F.1.1-6 as discussed in our letter dated June 30, 1982, and Item II.E.1.2 as discussed in our letter dated June 18, 1982.

Based on those previous discussions with your staff and the following confirmation of our continuing good faith efforts on these topics, we intend to complete the items addressed in this letter concurrent with the completion of Refuel IV (refueling outage scheduled to begin in March 1983) except Item II.E.1.2, Emergency Feedwater System Upgrade (reference our letter to you dated June 18,1982) which will be complet-ed during Refuel V (refueling outage estimated to begin in September 1984).

To provide assurances that efforts are supported by every facet of our organization, our senior management has established an oversight com-mittee comprised of mid-level managers. The committee has and will con- h f>

tinue to provide the nacessary guidance and direction to the engineer-ing, procurement, and installation activities to support completion of 8209140227 820908 PDR ADOCK 05000302 P PDR General Office 3201 Thin tounn c street soutn . P O Box 14o42. St Petersburg. Flonda 33733 813-866-5151

t Mr. John F. Stolz September 8, 1982 Page 2 the above Items by the end of Refuel IV. A computerized scheduling system is being utilized to aid in the identification and resolution of concerns. Senior management will be kept closely advised and will pro-vide resources in areas needing attention. The potential problem areas identified to date are due to material delivery and/or documentation to meet design requirements.

The present scope of pre-outage and outage activities includes 61 work packages of which 45 are related to NRC requirements and 23 of those are addressed by this letter. The estimates for craft labor which must be expended to complete the pre-outage and outage work are approximately 97,000 and 106,000 manhours, respectively. These manhour totals do not include supervision time which we expect to be significant. The magni-tude of this undertaking has essentially precluded any discretionary work for improving reliability of the plant during Refuel IV.

The present schedule for the pre-outage and outage work is very tight and contains thousands of activities in all areas of dasign, procure-ment, and installation that must occur on schedule in order for all of these projects to be completed during refuel IV. While we are committed to completing these projects and have high confidence that a significant portion if not all of these projects will be completed during Refuel IV, realism dictates that some problems beyond our control will probably occur that could preclude complete installation of all projects during Refuel IV.

Further, the large number of activities that must be accomplished prior to and during Refuel IV for these projects dictates that proper manage-ment controls be in place to ensure that these installations are not hurried to the point of reducing rather than enhancing the reliability and safety of Crystal River Unit 3 (CR-3).

i For these reasons, we respectfully request that you grant FPC until the completion of Refuel V for final closure of these NUREG-0737 Items. To show our strong commitment to meeting our goal by complating these NUREG-0737 Items during Refuel IV, we will provide you monthly schedule milestones and updates of problem areas including our action to resolve these problems. Additionally, we will meet with you and your staff prior to startup from Refuel IV to justify any deviations from our goal and provide our action plan for completion of any remaining NUREG-0737

. projects.

It would be difficult to overstate the extent of our desire and commit-ment to put these improvements in place in the nuclear plant during i

Refuel IV. Closure of these obligations will allow enhanced attention to other safety improvements as well as to improve plant reliability.

We sincerely believe that the above proposal is a prudent course of

Mr. John F. Stolz September 8,1982 Page 3 action regarding the NUREG-0737 issues when coupled with the compensa-tory measures inplace for these items. Additional clarification of each of the above NUREG-0737 Items is provided below on an item-by-item basis alo.rg with the compensatory measures in place at CR-3.

Item II.B.2. - Design of Plant Shielding and Environmental Qualification of Equipment for Spaces / Systems Which May Be Used in Post Accident Oper-ations. The schedule in our letter, dated June 30, 1982, called for this work to be completed by September 30, 1982, provided that the design work was completed and the equipment was received as expected.

However, in mid-August 1982, it was determined that the valve motor-operator starters would not be delivered in time for a September 30, 1982 installation. It was also determined that this installation should not be completed with CR-3 on-line. A six-day outage will be required to complete the final hookups to the Engineered Safeguards cabinets to alleviate the risk of tripping CR-3 unnecessarily. However, because cT the increased design and installation effort due to the electrical ccn-duit support concerns that were brought to light in early July 1982 and the valve motor-operator starter delivery problems, the modifications (except for the final hookup to the Engineered Safeguards cabinets) will now be completed by mid-January 1983. FPC will however, complete this modification during the first outage of sufficient duration subsequent to the completion of the design, the equipment delivery, and non-Engi-neered Safeguards cabinet work associated with this Item but no later than the completion of Refuel IV.

Item II.B.3 - Post Accident Sampling. Our schedule of June 30, 1982, called for this system to be installed during Refuel IV. That schedule remains valid. The work to be completed during Refuel IV includes a cold leg sample point in Reactor Coolant System loop A, sample return lines, installation of the Automated Isotopic Measurement System (AIMS) for liquid samples; and sample delive ry and return hookups to containment penetrations for gaseous samples from the AIMS. In the system description forwarded to you in our letter dated December 30, 1981, extra sample points were included to enhance accident monitoring above and beyond that required by this Item. To ensure completion of the requirements of this Item during Refuel IV, those additional sample points may possibly not be installed at that time. The compensatory measures, which were instituted until this system could be installed, were given in Attachment 6, Section 2.2 of our letter to you dated February 15, 1980. These are:

1. Plant procedures for the handling and analysis of post-accid'e nt samples have been developed and implemented.

These procedures address the sample locations, radiological pre-cautions (including use of shields), sample dilution requirements, means of handling the samples and necessary modifications to normal analytical procedures.

' Mr. John F. Stolz September 8, 1982 Page 4

2. In order to obtain RCS samples during the intervening period prior to implementation - of permanent modifications, temporary samples lines are being extended from the sample hood in the nuclear sample room through the common wall into the hood in the radiochemistry l aboratory. This sample line extension provides samp, ling capabili-ty of the Reactor Coolant letdown, and pressurizer water and steam space.

A single initial entry into the nuclear sample room will be re-quired to align valves for post-accident sampling. This activity can be conducted without exceeding the exposure criteria. Subse-quent sampling operations will be controlled using valves in the radiochemistry laboratory.

3. The post-accident containment atmosphere sample will be obtained utilizing the existing Station Air and Integrated Leak Rate Test penetrations through containment. These penetrations are located in Quadrant 1 of the containment and are adequately shielded and at sufficient distance from primary sources of radiation, that access for obtaining a post-accident sample can be accomplished within the dose limits of GDC-19.

A grab sample will be taken to allow hydrogen and radiological analysis (isotopic concentractions) of the containment atmosphere.

A gas powered (air and/or nitrogen) jet pump is permanently installed to draw the sample through the collection container. In the event that the survey meter located near the sampl e line indicates that high' concentrations of radioisotopes are present, a small shielded container will be utilized for collection and trans-port of the sample to the onsite counting and analyzing facili-ties. In addition, portable lead shielding is available for use as necessa ry.

Item II.E.1.2 - Auxiliary (Emergency) Feedwater System Automatic Initia-tion and Flow Indication. The schedule for installation of this Item, as stated in our letter dated June 18, 1982, is Refuel V. The equipment procurement concerns and the newly required fire protection interfaces (10 CFR 50, Appendix R) noted in that letter are being closely monitored so that any new problems can be readily addressed. As compensatory measures, FPC has installed and will continue to utilize a reliable, control-grade, redundant system which meets the single failure criteria to automatically initiate emergency feedwater and to indicate the emergency feedwater delivery system to each steam generator. The methods by which we have implemented the compensatory measures are discussed in our letters to you dated November 17, 1979, and January 11, 1980. This upgrade was completed in 1980.

1 1 '..-

Mr. John F. Stolz i

~i. ' .. .

September 8, 1982 Page 5 .

L

..r Item II.F.1.1 - Noble Gas Effluent Radiological Monitor and Item ml' V;-

II.F.1.2 - Continuous Sampling of Plant Effluent. The schedule for in- ..

e stallation of these Items, as stated in our letter dated June 30, 1982, m/. .

is during Refuel IV. The presently installed Radiation Monitoring 1 - ei System has a range of 10-6 to 10-2 Ci/cc (as Kr-85) while the Post- - . .

Accident Monitoring System will increase the range to 10 5 Ci/cc (as  ;]* , .-

Kr-C5) for the Reactor Building vent monitor and to 103 Ci/cc (as Kr-85) .

e for the Auxiliary and Fuel Handling Building vent monitor. Because of  :' . . . .

the range of the installed monitors and the unlikelihood of needing an -

' f. #

expanded range in the interim, no additional compensatory measures were 7...- ..

instituted for these Items. .

1, y. : ' .

Item II.F.1.3 - Containment High Radiation Monitor. The schedule for (.[ gU installation of this Item, as stated in our letter dated June 30, 1982, '"/

is during Refuel IV. The presently installed Containment Radiation f..

Monitor has a range of 5 to 5 X 10 5 Rad /hr while the Containment High lf'" ,

Radiation Monitor will have a range of 1 to 108 Rad /hr. Because of the .* :

range of the installed monitor and the unlikelihood of needing an 1 ~.; } 'y expanded range in the interim, no additional compensatory measures were '

5.? ~

instituted for this Item. -[* q Item II.F.1.4 - Containment Pressure Monitor. The schedule for instal- - - '

lation of this Item, as stated in our letter dated June 30, 1982, is c-during Refuel IV. The present installed Containment Pressure Monitor -

2 has a range of 0 to 70 psig while the new Containment Pressure Monitor

^

will have a range of 0 to 280 psig. Because of the range of the i installed monitor and the unlikelihood of needing an expanded range in f ,,

the interim, no additional compensatory measures were instituted for ,'-

this Item. .

. c.~  ;.

Item II.F.1.5 - Containment Water Level Monitor. The schedule for in-stallation of this Item, as stated in our letter dated June 30,1982, i s 15 J during Refuel IV. The present installed Containment Water Level Monitor ;7 has a range of 0 to 10 feet while the new Containment Water Level Moni- e.' ~

tor will have ranges of 0 to 10 feet and 10 to 20 feet. Because of the I i : i.'I range of the installed monitor and the unlikelihood of needing an  ; : ;.

expanded range in the interim, no additional compensatory measures were .

instituted for this Item. ' . J. f:/

J'.

..2 .

Item II.F.1.6 - Containment Hydrogen Monitor. The schedule for instal-  ; - 3 lation of this Item, as stated in our letter dated June 30, 1982, is e 7 v.-

during Refuel IV. As noted in the compensatory measures for Item II.B.3

~

/ ..? E referenced above, provisions have been implemented to allow for collec-

7. w .f tion of grab samples of the reactor containment atmosphere and subse- -

T-quent transportation and analysis at on-site facilities. . .

', , ' l.~. .:

w

[~.-

September 8, 1982

-Page 6 We look forward to meeting with you and your management on Friday, September 10, 1982 to discuss these issues in detail.

Very truly yours, D i ll ' n drmr -

John A. Hancock Vice President Nuclear Operations Attachments Bright (W01)D157-3 cc: Mr. J. P. O'Reilly Regional Administrator, Region II U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement 101 Marietta Street N.W. , Suite 3100 Atlanta, GA 30303 i