3F0297-09, TS Change Request 212 to License DPR-72,adopting 10CFR50,App J, Primary Reactor Containment Leakage Testing for Water- Cooled Reactors, Option B
| ML20134L813 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/17/1997 |
| From: | Beard P FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20134L816 | List: |
| References | |
| 3F0297-09, 3F297-9, NUDOCS 9702190298 | |
| Download: ML20134L813 (10) | |
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Florida Power CORPORATION UE*
February 17, 1997 3F0297-09 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001
Subject:
Technical Specification Change Request No. 212, Revision 0
Reference:
A. FPC to NRC letter, 3F0595-02, dated May 19, 1995 B. NRC to FPC letter, 3N0995-12, dated September 29, 1995
Dear Sir:
Pursuant to 10 CFR 50.90, Florida Power Corporation (FPC) hereby submits Technical Specification Change Request Number (TSCRN) 212, Revision 0 requesting amendment to Operating License No. DPR-72.
The TSCRN and the proposed new Technical Specification pages are provided.
The proposed changes to the Crystal River Unit 3 Technical Specifications (TS) are to adopt 10 CFR 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Reactors," Option B.
This option gives the licensee the opportunitv to voliintarily change from prescriptive testing requirements to performance-based testing requirements based on the leakage rate testing history of the containment and components.
The change to the Technical Specifications sections are:
3.6.1,
" Containment"; 3.6.2,
" Containment Air Locks";
3.6.3,
" Containment Isolation Valves"; and the addition of " Containment Leakage Rate Testing Program" to Section 5.0, " Administrative Controls."
The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using 10 CFR 50.92(c). FPC believes that this TS amendment involves no significant hazard considerations. The basis for this determination is included in the attachment.
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U.S. Nuclear Regulatory Commission 3F0297-09 Page 2 of 10
- FPC requested schedular exemption of the requirements from Appendix J (Reference A). In the exemption request justification, the results of the previous leakage rate tests were forwarded to the NRC. The NRC granted the exemption (Reference B) based on the acceptable results of the previous integrated leak rate tests and local leak rate tests.
FPC requests the effective implementation date for this Technical Specification 1
amendment to be 90 days from the date of approval. Your review and approval is requested by March 31, 1997.
If questions arise during your review please contact Brian Gutherman, Manager, Nuclear Licensing at (352) 563-4566.
Sincerely,
. M.
eard, Jr.
Senior Vice President Nuclear Operations PMB/PMP Attachment xc:
Regional Administrator, Region II Senior Resident Inspector NRR Project Manager
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U.S. Nuclear Regulatory Commission 3F0297-09 Page 3 of 10 i
STATE OF FLORIDA COUNTY OF CITRUS I
P. M. Beard, Jr. states that he is the Senior Vice President, Nuclear Operations for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true i
and correct to the best of his knowledge, information, and belief.
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L P. M. Beard, Jr.
Senior Vice President i
Nuclear Operations i
Sworn to and subscribed before me this N day of February,1997, by P. M.
Beard, Jr., who is personally known to me.
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Signature of Notary Public State of Florida LYNNE S. SMITH MY COMMW840N f CC 514300 EXPIfES December 18,1900 3
Stam Commissioned Name of Notary Public
U.S. Nuclear RGgulatory Commission 3F0297-09 Page 4 of 10 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER
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DOCKET NO. 50-302 FLORIDA POWER CORPORATION
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CERTIFICATE OF SERVICE P. M. Beard, Jr. deposes and says that the following has been served on the Designated State Representative and Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:
- Chairman, Administrator, Board of County Commissioners Radiological Health Services of Citrus County Department of Health and Citrus County Courthouse Rehabilitative Services Inverness, FL 34450 1323 Winewood Blvd.
Tallahassee, FL 32301 A copy of Technical Specification Change Request No. 212, Revision 0.
FLORIDA POWER CORPORATION
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P.M. Beard, Jr.
Senior Vice President i
Nuclear Operations Sworn to and subscribed before me this ay of February, 1997, by P. M.
Beard, Jr., who is personally known to me.
Signature of Notary Public State of _ Florida _ __ _ _
i LYNNE S. SMITH i
MY ColdhMSSION f CC 614300 I
DGTIES: Osawnbar 18,Igge 9endedThru Netwy Planc tmdenuttus i
Stamp Commissioned Name of Notary Public
U.S. Nuclear Regulatory Commission 3F0297-09 Page 5 of 10 1
FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 REQUEST NO. 212, REVISION O CONTAINMENT LEAKAGE RATE PROGRAM 10 CFR 50, APPENDIX J, OPTION B LICENSE DOCUMENT INVOLVED:
Technical Specifications PORTIONS:*
Technical Specification 3.6.1 Technical Specification 3.6.2 Technical Specification 3.6.3 Technical Specification Section 5.0 Technical Specification BASES B3.6.1 Technical Specification BASES B3.6.2 Technical Specification BASES B3.6.3
- See
SUMMARY
OF CHANGES for specific Technical Specification changes DESCRIPTION OF REQUEST:
The proposed changes to the Crystal River Unit 3 (CR-3) Technical Specifications (TS) are to adopt 10 CFR 50, Appendix J, Option B.
This option gives the licensee the opportunity to voluntarily change from prescriptive testing requirements to performance-based testing based on the leakage rate testing history of the containment and components.
REASON FOR REQUEST:
l The Nuclear Regulatory Commission (NRC) amended 10 CFR 50, Appendix J to include
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Option B, " Performance-Based Requirements."Section V.B.2 of Option B requires licensees who wish to voluntarily replace the prescriptive testing requirements (Option A) with performance-based testing requirements (0ption B), submit to the NRC a request for revision to the Technical Specifications.
EVALUATION OF REQUEST:
The proposed changes to the CR-3 TS are to adopt 10 CFR 50, Appendix J, Option B.
Compliance with 10 CFR 50, Appendix J, provides assurance that the primary containment, and those systems and components which penetrate the primary containment, do not exceed the allowable leakage rate values specified in the Containment Leakage Rate Testing Program.
The allowable leakage rate is determined so that the leakage assumed in the safety analyses for a design basis accident is not exceeded.
As described in 10 CFR 50, Appendix J, Option B, deviations to the testing requirements, detailed in Appendix J, must be justified. FPC does not intend to deviate from the requirements in 10 CFR 50, Appendix J, Option B.
The current exemption, approved by the NRC (References A and B), was a schedular exemption i
and, upon approval of this proposed TS amendment, this exemption will no longer be necessary.
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U.S. Nuclear Regulatory Commission i
l 3F0297-09 i
Page 6 of 10 This TS amendment is not intended to change the testing frequency for the 48 inch containment purge valves with resilient seals.
The TS commitments for surveillance and testing of these valves is separate from Appendix J required tests. The current surveillance requirements in the TS will remain valid for the l
48 inch containment purge valves.
l BASES FOR THE TECHNICAL SPECIFICATION CHANGE REQUEST:
CR-3 has historically demonstrated satisfactory Type A, B, and C leakage rate tests on the containment and components.
These results demonstrate leak-tightness and provide a high degree of confidence that the containment will not significantly degrade due to extended test intervals.
Experience demonstrates that essentially all containment leakage can be detected by local leakage rate tests (LLRTs) Type B and C.
As noted in NUREG-1493,
" Performance Based Leak Rate Testing Program," of 180 ILRTs reported, which covered 110 individual reactors and approximately 770 years of cumulative operating history, only 5 integrated leakage rate test (ILRT) failures were found that LLRTs could not detect.
i This TS amendment does not affect the methodology of performing Type A, B and C testing at CR-3 and would not contribute to the degradation of containment integrity.
The leakage rates observed at CR-3 during Type B and C tests have been consistently below the allowable leakage rates as described in Appendix J. The combined "as-found" leakage in each test (from 1990 to 1996) was less than the allowable combined Type B and C leakage rate of 0.6 La (266,431 SCCM) at the calculated maximum peak containment pressure.
l The "as-left" leakage rates were also significantly below the allowable limits.
Since 1987 testing, the "as-left" leakage rate has trended downward.
This downward trend highlights FPC's commitment to repair and maintain components that may affect the overall containment integrity.
FPC has already invoked administrative limits on valve leakage rates based on valve opening size. If valves fail to meet those administrative limits, then the valves are repaired or replaced and re-tested. Repairs and replacement are in accordance with Appendix J and CR-3's Inservice Testing and Repair and Replacement Program, as described in the American Society of Mechanical Engineers (ASMI) Code,Section XI.
STRUCTURAL CAPABILITY OF THE CONTAINMENT:
The CR-3 containment is a reinforced concrete structure with a cylindrical wall, a flat foundation mat, and a shallow dome roof.
The cylinder wall is pre-stressed, with a post-tensioning system in the vertical and horizontal directions.
The dome roof is pre-stressed using a three way post-tensioning system.
The inside surface of the containment is a carbon steel liner.
The liner plate nominal thickness is 3/8 inch for the cylinder and dome and 1/4 inch for the base. The liner plate is anchored to the concrete. Piping penetrations have been designed to ensure that the liner will not be breached due to the i
rupture of the piping. During Refuel 10, a visual inspection of the containment and containment liner was performed by FPC. There were no findings of deterioration that could affect the leak tightness or structural integrity of containment, l
U.S. Nuclear Regulatory Commission 3F0297-09 Page 7 of 10 RISK IMPACT ASSESSMENT:
The purpose of containment leakage rate testing is to detect an unacceptable trend in containment leakage before a design basis accident occurs. Containment leakage, caused by the degradation of sealing material within containment penetrations and containment isolation components, will continue to be effectively measured by the Type B and C testing performed in accordance with Option B.
The only potential failure not covered by Type B and C testing, is a failure of the containment due to structural deterioration caused by pressure or temperature excursions between tests.
Under normal conditions there are no i
significant environmental or operational stresses which could contribute to the degradation of the containment structure.
Additionally, visual inspections performed in accordance with Appendix J, Option B, provide the opportunity to detect structural deterioration that may be present.
The results of a sensitivity study exploring the risk impact of several alternate leak rate testing schedules are found in NUREG-1493. The NUREG concludes that the impact on risk due to decreasing Type A, B and C testing frequency is very low and that a decrease of ILRT frequency to once per ten years would not i
significantly increase the risk of containment failure.
This TS amendment submittal is bounded by the analyses in NUREG-1493.
Based on the historical data, the risk increase due to the adoption of Appendix J, Option B, at CR-3, is negligible.
BENEFITS:
ALABA The estimated radiation exposure for performing each ILRT is 4 ManREM.
The estimated dose savings by not performing the additional ILRTs is 16 ManREM, over the life of the plant.
The estimated dose for performing each set of LLRTs is 2 ManREM.
The dose savings for the reduction of LLRTs is 20 ManREM, over the life of the plant.
Cost The anticipated cost savings for implementing Appendix J, Option B, is attributed to reducing the number of remaining ILRTs from six to two and LLRTs from twenty 4
to ten. The cost to perform one LLRT is approximately $60,000. The savings over the life of the plant is expected to be $600,000.
The approximate cost to perform one ILRT is $2 million, which over the life of the plant, would be a savings of $8 million.
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U.S. Nuclear Regulatory Commission 3F0297-09 Page 8 of 10 DETERNINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION (SHOLLY):
An evaluation of the proposed TS amendment has been performed in accordance with 10 CFR 50.91(a)(1) regarding significant hazards considerations, using the standards in 10 CFR 50.92(c).
Criterion 1 Does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The TS amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the TS are to implement Option B of 10 CFR 50, Appendix J, at CR-3.
The proposed changes will result in increased intervals between containment leakage tests based on the leakage rate testing history.
The proposed changes do not involve a change to the plant design or operation and does not change the testing methodology.
NUREG-1493, " Performance-Based Containment Leak-Test Program," provides the technical basis of 10 CFR 50, Appendix J, Option B.
NUREG-1493 contains a i
detailed evaluation of the expected leakage from containment and the associated consequences.
The increased risk due to increasing the intervals between containment leakage tests was also evaluated.
The NUREG used a statistical approach to determine that the increase in the expected dose to the public due to decreasing the testing frequency is extremely low. NUREG-1493 also concluded that a small increase is justifiable in comparison to the benefits from decreasing the testing frequency.
The primary benefit is in the reduction in occupational radiation exposure.
Criterion 2 Does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The TS amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
l The proposed TS amendment incorporates the performance-based testing approach authorized by 10 CFR 50 Appendix, J, Option B.
Decreasing the testing frequency allowed by this change does not involve a change to plant design or operation.
Safety related equipment and safety functions are not altered as a result of this change. Decreasing the testing frequency does not affect testing methodology.
As a result, the proposed change does not affect any of the parameters or conditions that could contribute to the initiation of any accidents.
Criterion 3 Does not involve a significant reduction in the margin of safety.
This TS amendment does not involve a significant reduction in the margin of safety.
The proposed TS amendment does not change the methodology of the containment leakage rate testing program or program acceptance criteria.
The proposed TS
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1 U.S. Nuclear Regulatory Commission 3F0297-09 l
Page 9 of 10 change does affect the frequency of containment leakage rate testing. With an increased interval between tests, a small possibility exists that an increase in leakage could go undetected for a longer period of time.
Based on the l
operational experience at CR-3, it has been demonstrated that the leak-tightness l
of the containment building has consistently been significantly below the allowable leakage limit. Adequate controls are in place to ensure that required maintenance and modifications are performed.
I ENVIRONMENTAL IMPACT EVALUATION:
10 CFR 51.22 (c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.
A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not; (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational radiation exposure.
Florida Power Corporation (FPC) has reviewed this TS amendment and believes it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c)(9).
Pursuant to 10 CFR 51.22 (c), no environmental impact statement or environmental assessment needs to be prepared l
in connection with the issuance of the proposed TS amendment. The basis for this determination is as follows:
1.
The proposed TS amendment does not involve a significant hazards consideration as described previously in the significant hazards consideration evaluation.
2.
The proposed TS amendment does not result in a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite. The proposed TS amendment does not introduce any new equipment nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform.
The proposed TS amendment does not alter the testing methods or testing i
acceptance criteria associated with primary containment testing.
The primary containment ILRTs and LLRTs being performed will continue to ensure that the consequences of any previously evaluated accident does not increase. FPC has concluded that there will not be a significant increase in the types or amounts of any effluents that may be released offsite and does not involve irreversible environmental consequences beyond those already associated with normal operation.
3.
The proposed TS amendment does not change the duration, methods or acceptance criteria for the performance of ILRTs and LLRTs.
Since the number of ILRTs and LLRTs will be decreased, the amendment does not i
increase the individual or cumulative occupational radiation exposure.
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U.S. Nuclear Regulatory Commission 3F0297-09 Page 10 of 10
SUMMARY
OF CHANGES:
PAGE NUMBER SECTION CHANGE 3.6-2 SR 3.6.1.1 Change the reference from 10 CFR 50, Appendix J to the Containment Leakage Rate Testing Program, i
3.6-7 SR 3.6.2.1 Change the reference from 10 CFR 50, Appendix J to the Containment Leakage Rate Testing Program.
3.6-13 SR 3.6.3.6 Change the reference from 10 CFR 50, Appendix J to the Containment Leakage Rate Testing Program.
5.0-26A 5.6.2.20 New addition of the Containment Leakage i
Rate Testing Program requirements.
B 3.6-1
Background
Addition of 10 CFR 50, Appendix J, Option B reference.
B 3.6-4 SR 3.6.1.1 Addition of 10 CFR 50, Appendix J, Option B reference.
B 3.6-5 References Correct FSAR references.
B 3.6-6
Background
Addition of 10 CFR 50, Appenoix J, Option B reference.
B 3.6-13 Actions Addition of test frequency and Code reference ANSI /ANS-56.8-1994 to match NEI-94-01.
i SR 3.6.2.1 Addition of 10 CFR 50, Appendix J, Option B reference.
B 3.6-14A References Correct FSAR referencesans include ANSI /ANS 56.8-1994.
B 3.6-28 References Correct FSAR references.
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