3F0198-34, Forwards Summary of Evaluation of Dynamic Effects of Pressurizer Surge Line LOCA Other Systems & Components,In Response to NRC 971222 Rai.Commitments Made by Util,Encl

Forwards Summary of Evaluation of Dynamic Effects of Pressurizer Surge Line LOCA Other Systems & Components,In Response to NRC 971222 Rai.Commitments Made by Util,Encl

ML20199A530
Person / Time
Site:	Crystal River
Issue date:	01/23/1998
From:	Rencheck M FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0198-34, 3F198-34, GL-87-11, GL-91-18, TAC-M96604, NUDOCS 9801280003
Download: ML20199A530 (5)

Text

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January 23, 1998 3F0198 34 U. S. Nuclear Regulatory Conunission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)

References:

1. NRC to FPC Letter, 3N1297-18, dated December 22, 1997,

" Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)"

2. FPC to NRC letter, 3F1297-05, dated December 13, 1997,

" Protection Against Dynamic Effects of LOCA - Request for Additional Information, Evaluation of Jet Impingement Effects ofPressurizerSurgeLine,inspectorFollowupItem(IFI)95-15 02"

3. NRC to FPC letter, 3N0586-30, dated May 23, 1986, " License Amendment 689"

4. FPC to NRC letter, 3F1297-33, dated December 8, 1997,

" Resolution Plans for USI A-46 and large Bore Piping and Piping Supports"

! 5. FPC to NRC letter, 3F1297 36, dated December 18, 1997, "Large Bore Piping and Pipe Support Calculations - Response to NRC Request for Additional Information"

Dear Sir:

Florida Power Corporation (FPC) is submitting this letter to respond to the h$d Request for Additional Information (RAI) in Reference 1. The RAI stated that the  ;

December 13, 1997, FPC letter (Reference 2) " appears to address only Service Water (SW) piping and it is not clear whether FPC evaluated the dynamic effects i of a pressurizer surg line loss of coolant accident (LOCA) on any other systems I) and components in the area."

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'3F0198 34  !

Page 2 of 4 -

FPC

(RB) - , performed

. As part of this a review review, FPC of high energy- an performed lineimpact break (HELB) of evaluation ina-the' HELB Reactor Build originating components (SSC) inside the RB.from In addition, thethepressurizer' evaluation surge included line on systems,. struc postulated-4 breaks in the high energy-portions-of the Core Flood (CF) System lines, Decay 1 Heat (OH) System drop line, Makeu  !

Auxiliary Pressurizer Spray -(APS)p line, and-and:thePurification-Pressurizer (MU)Spray System

-line. letdown The- line, Reactor Coolant- System main-loop piping.- i.e.. " hot-leg" and " cold-leg" piping, 0 were not included in the scope of this evaluation because these lines qualify for-  !

! leakbeforebreakcriteria-asapprovedbyLicenseAmendment#89,datedMayl23, j 1986 (Reference 3), i o FPC identified SSCs that were potential targets of pipe whip or jet impingement from'a HELB for the lines identified above. These interactions represented 1 i- potential deviations from the original: design criteria for protection from the '

dynamic effects of a LOCA.  !

2 3 i

_The affected SSCs were dispositioned by one'or more of the following criteria:

1.- The target is not required for LOCA mitigat. an or the accident is-t  : mitigated by other automatic functions consistent with the: CR-3 licensing basis.

i

~ 2. The target has been modified in order to remove it from the path of '

-the pipe whip and/or the jet impingement envelope.

c - -

FPCappliedtheguidanceinGenericLetter(GL)9118, Revision 1.-

- 3. t

- Information to Licensees Regarding NRC Inspection Manual Section on ,

p Resolution of Degraded and Nonconforming Conditions,"ito disposition i Jnonconformances as follows:

1

.: a. . The break location was eliminated using the methodology l t of NRC GL 87-11,;" Relaxation in Arbitrary Intermediate >

Pipe Rupture Requirements,"

- b. The target was eliminated by implementing NUREG/CR-2913, "Two Phase Jet Loads," methodology for redefinition of  ;

the jet impingement envelope.  ;

i' As p s t of item 3 above, fina1' corrective actions in accordance with GL 91-18,

. Revision.1 are required since

1. GL 87-11 wa's applied to -longitudinal breaks on the surge line to r eliminate them as part of an earlier effort to support Crystal River Unit.3:(CR-3) Restart issue D 58. FPC performed a review of the

stresses in both of the CF System lines, the DH Systei.; drop line, i and' the MU System letdown line and concluded that intermediate

• F . breaks can be eliminated using the criteria allowed by GL 87-11. '

.However, the use of GL 87-11 on piping inside the RB for which the

' code of record is USAS B31.l.0 - 1967 is not part of the current licensing basis for CR-3.

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12. ' NUREG/CR-2913 defines characteristics of the impingement jet. It' l

= differs from the currently. licensed impingement- jet for a LOCA -  !

'inside the R8 as described in Final Safety- Analysis Report (FSAR)_

Section 14.2.2.5.11.. ,

,1 FPC will submit a license amendment request providing justification for use of '

GL; 87-11 and NUREG/CR 2913 as the licensing -bases for; CR 3 and/or ' propose additional plant modifications that will be completed prior to restart from i Refuel 11 in a separate-submittal by Nay 29, 1998.

.The nonconformances described ~ in this letter have been determined to' be

-reportable.and LER 98 001 00 will be submitted in accordance with 10 CFR 50.73.- '

' The large Bore Piping Program discussed in References 4 and 5 will evaluate these [

pipe stresses to ensure the- application;of GL 8711 'for the elimination of  :

intermediate breaks remains

• acceptable.

+

.The RAI noted that CR-3 is required to comply with the requirements of 10 CFR 50,  !

. 4 Appendix A, General Design Criteria (GDC) 4, Environmental and Dynamic Effects  ;

Design Bases.- This is not consistent with the current CR 3' licensing and design '

- basis. CR 3 systems, structures, and components are designed to the criter'a  ;

described in FSAR Section 1.4, Principal- Architectural and Design Criterfs.

However, the Emergency Feedwater (EF) System is designed to the current GDC 4

. requirements because of NUREG 0737, " Clarification of 7#1oAction Plan. -!

Requirements.* In 1989, the NRC granted a-schedular exemption to GDC-4 to allow l h FPC timeLto complete modifications to CR 3 to resolve postulated _HELBs located l l- outside the RB This schedular exemption did not change the design bases for CR- <!

! 3 to the GOC in 10 CFR 50,' Appendix. A. : Subsequently, NRC issued NRC.SECY-92-223,  !

'Resolutton of Devfattons identiffed During the Systematic Evaluatton Program," t dated September-18, 1992, which established the NRC's position regarding the '

applicability of the current 10 CFR 50,' Appendix A General Design Criteria (GDC).

L The:NRC's position is that it will; not apply _ the- current Appendix A GDCs to >

plants with construction permits issued prior to May 21,1971 and exemptions from the current GDC are not necessary.

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• 3F0198-34 Page 4 of 4 The commitments in this letter are contained in the Attachment A.

Sincerely, M. W.- Rencheck, Director-NuclearEngineeringandProjects

!- MWR/jwt Attachment xc: Regional Administrator, Region !!

l Senior Resident Inspector NRR-Project Manager I

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ll~ 5. N9cleai Regulatory Commission Attachment A

• '3F0198 'M Page 1 of 1 i.ist of Regulatory Commitments The folinwing table idehtifies those actions committed to by Florida- Power Corporetton in this document. Any other actions discussed in the submittal represents intended or planned actions by Florida Power Corporation. They are described % the NRC for the NRC's inforsation and are not regulatory commitments. Flene notify the Mar,ager, Nuclear Licensing of any questions regarding this decuran* nr any succiated regulatory commitma' ' .

COMITEEWi ~ 1Hli.ENENTATION Submit a license amendment request providing May 29, 1998 '

p justification for use of Generic letter 87-11 and NUREG/CR 2913 as the licensing bases for CR 3 and/or propose additional plant modifications that will be completed prior to restart from Refuel 11 in a separate subental.

The Large Bore Piping Program will evaluate these Program will take 4 6 pipe stresses to ensure the application of GL 87-11 years (2-3 fuel for the elimination of intermediate breaks remains cycles) to implement, acceptable.

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