ML20071J706
| ML20071J706 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/07/1994 |
| From: | Boldt G FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20071J682 | List: |
| References | |
| NUDOCS 9407290052 | |
| Download: ML20071J706 (4) | |
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.9 ENCLOSURE Florida Power conecamON O2"O*
July 7, 1994 3F0794-07 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Request For Discretionary Enforcement
Dear Sir:
Florida power Corporation (FPC) is in the midst of an unanticipated replacement of the rotating element for the Motor Driven Emergency Feedwater Pump (EFP-1).
Crystal River Unit 3 (CR-3) entered the Action for Improved Technical Specification (ITS) 3.7.5.8 on Ju',y 6,1994 at 1145.
The duration of this i
activity is expected to exceed the 72-hour Allowed Outage Time (A0T) provided in the ITS.
FPC believes that, for the reasons provided in the attachment, enforcement discretion to allow up to an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is warranted. This will extend the A0T to 1145 on July 11, 1994.
Such discretion is hereby requested.
BACKGROUND The CR-3 feedwater and emergency feedwater systems designs include two turbine driven main-feedwater pumps, one 100% capacity motor driven emergency feedwater i
pump (EFP-1), one 100% capacity turbine driven emergency feedwater pump (EFP-2) and one motor driven non-safety-related auxiliary feedwater pump (FWP-7).
The l
emergency feedwater pumps are automatically initiated and controlled by a control system that has been shown to be highly reliable from a PSA perspective.
The main feedwater pumps are fully operational and in operation.
The turbine driven emergency feedwater pump is fully operational under current conditions.
If the unit were to be taken to Mode 3, greater reliance is placed on auxiliary steam from neighboring fossil units. One of these units is experiencing a tube j
icak that may require its removal from service in the immediate future.
The auxiliary feedwater pump has been recently modified to improve its performance from a vibration perspective.
A 48-hour run portion of the post modification testing is well-undemay and will be completed before noon tomorrow.
It is now fully functional.
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The EFP-1 rotating element is being replaced because of an anomaly in the shaft which prevents proper '**,-up with the outboard bearing. Alternatives considered included replacement or i.he bearing with one having a smaller ID or repair of the shaft using methods we have not previously utilized. The bearing would not be available in the time frame needed and the shaft repair was not considered the best alternative from a long-term safety perspective.
Replacement of the rotating element will take at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> longer than the remaining time in the A01. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time frame should provide for sufficient time to complete the repairs.
Should repairs not be completed within the allowed time, the situation will be reassessed next Monday.
Florida Power Corporation believes the granting of this request will provide a benefit to the over-all safe operation of the unit.
We have arranged for a teleconference to discuss this matter tomorrow morning.
Copics of relevant drawings and flow diagrams were provided through the NRC resident's via facsimile earlier this morning. Your prompt consideration will bc greatly appreciated.
Sincerely, G. L.
- ldt, Vice President Nuclear Production GLB/KRW:ff cc:
Regional Administrator, Region 11 NRR Project Manager Senior Resident Inspector I
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U. S. Nuclear Regulatory Ccmission 3F0794-07 Page 3 of 4 ATTACHMENT The following addresses each of the considerations required by 0 CFR Part granting enforcement discretion. NRC Inspection Manual. Part 9 2 Appendix C Enforcement Discretion"-
The requirement from which relief is being sought is the A0T for 8 of ITS 3.7.5.
The A0T limits the emergency feedwater train 1.
unavailability to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in Mode 3 thereafter.
result of routine condition was discovered as aDuring the performance 2.
The EFP-1 shaft The oil was replaced and the -
surveillance activities.
run. water droplets were noted in the oil.
l water jacket hydrostat1cally tested. No leak was identifiec
. Particulate The bearing matter was noted in the oil following a short duration run.
I was found to be easily removed off the shaft even thou fit should be present.No vibration particulate or other indicators had alerted u to this shaft condition.
Once discovered, neither FPC nor the was noted.
manufacturer felt a "use-as-is" disposition was appropriate even thou This the pump's performance had continued to be quite acceptable.
determination was made after a thorough consideration of a number alternatives and within a few hours of the discovery o condition.
immediately thereafter.
The safety function of emergency feedwater is to provide alte 3.
of supporting primary During normal operation the function is achieved by of normal feedwater.the two main feedwater pumps associated eculpment and their controls.
The MFW system for CR-3 has been highly reliable for a number of years.
The function of EFP-1 is to provide a diesel backed. motor driven pumpBecause of i
independent and diverse of the turbine-driven emergency Dump.
this AC dependency (and thus its unava11 ability during s':ation blackout),
the motor driven pump is slightly less significant than the turbine driven i
pump from either a deterministic or PSA perspective.
The two scenarios being considered in this request are whether the plant is safer in Mode 1 with main feedwater as well as the turbine driv emergency feedwater pump (EFP-2) and auxiliary feedwater pump (FWP-7) or. Mode 4 with just the turbine driven emergency feedwater available:
FPC oump (EFP-2) and the auxiliary feedwater pump (FWP-7) available.
additional equipment available makes Mode 1
miteves that the Further. most accident precursors tend to occur signtficantly safer.
during significant changes in operating mode not stead Finally.
worsened by causing a transient that can be reasonably avoided.
the limited duration of the request limits the exposure of the plant to other transients that may require emergency feedwater.
FPC will control activities that could adversely affect or challenge main The auxiliary pump 4.
or emergency feedwater while EFP-1 is out of service. service as soon as will be returned to full completed.
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U. S. Nuclear Regulatory Commission 3FG794-07 Pt,ge 4 of 4 ATTACHMENT l
allowing duration was chosen to minimize the extension w xtension is sufficient time for necessary activities.
The 5.
at least a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension will be needed. Thus a Nevertheless, requested to allow for any contingencies that may arise.
ill be exited as the activities are being expedited and the Condition w soon as possible.
d The BASES for the A0T confirms the duration to be based t
repair typical times as well as EFW redundancy a 6.
t of Repairs of this magnitude are not routinely plann frequency.
ITS A0T's.
it is not an ITS or safety-related back-up.
d reasonable and relied upon In other plant's technical specificati longer A0T's are thereby justified.
does not involve the consideration of a significant safety hazard The environment will not be adversely affected as a re 7.
substantial reliance on alternate energy supplies which generall extended A0T.
In fact, substantially higher environmental impacts.
The Plant Review Comittee reviewed this request and fully support t action as opposed to alternate repairs or plant shutdown.
8.
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