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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F9941999-10-15015 October 1999 Discusses FPC 970819 Request for Temporary Relief from ASME Code Section XI Requirements to Repair ASME Class 3 Nuclear Service & Decay Heat Sea Water System Piping.Forwards SE Containing Results of Staff Review ML20217J5171999-10-13013 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Plant,Unit 3 & Did Not Identify Any New Areas That Warranted More than Core Insp Program.Previously Planned Regional Initiative Insp of safety-related Mod Will Be Performed 3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999 Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed 3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999 Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made ML20212L0771999-10-0404 October 1999 Forwards SER Accepting Licensee Relief Requests 98-012 Through 98-018 Involving Containment Insps at Crystal River Unit 3 Pursuant to 10CFR50.55a(a)(3)(i) & 10CFR50.55a(a)(3)(ii) ML20217D6551999-10-0101 October 1999 Requests That Natl Communication Sys Arrange for Licensee Participation in Government Emergency Telecommunications Service,Per NRC Info Notice 99-025 ML20212J8481999-10-0101 October 1999 Forwards Safety Evaluation Re Second 10 Yr Interval ISI Program Requests for Relief 98-009-II.Reliefs Granted for 98-009-II,Parts B & C & 98-010-II & 98-011-II 3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999 Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment 3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999 Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331 ML20212F7251999-09-23023 September 1999 Discusses Staff Review of Util 980330 Response,As Suppl on 990514,to GL 97-06, Degradation of SG Internals. Staff Concludes That Licensee Responses to GL Provide Reasonable Assurance That Condition of SG Internals Acceptable ML20212F7331999-09-23023 September 1999 Discusses Util Licensing Action for GL 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants. NRC Ack Efforts Util Completed to Date in Preparing Crystal River,Unit 3 for Y2K Transition 3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999 Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46 ML20212E6741999-09-21021 September 1999 Forwards Safety Evaluation Accepting Proposed EAL Changes Submitted by ,As Supplemented by 981120,990713 & 0831 Ltrs,Incorporating Guidance in NUMARC/NESP-007,Rev 2, Methodology for Development of Eals 3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999 Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv) 3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999 Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief ML20212F3141999-09-13013 September 1999 Forwards Insp Rept 50-302/99-05 on 990704-0814.Violations Noted,But Being Treated as non-cited Violations ML20211L9081999-09-0303 September 1999 Informs of Completion of Licensing Action for GL 92-08, Thermo-Lag 330-1 Fire Barriers, Dtd 921217,for Crystal River Unit 3 ML20211Q7581999-09-0101 September 1999 Forwards Summary of 990812-13 Training Managers Conference in Atlanta,Georgia Re Recent Changes to Operator Licensing Program.List Conference Attendees,Copy of Presentation Slides & List of Participant Questions Encl 3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999 Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals ML20211G7111999-08-30030 August 1999 Modifies Approval of 980521 Request for Exception to 10CFR50.4(b)(6) & Grants Util Approval to Submit Copies of Future Updates to FSAR as Listed ML20211G7031999-08-30030 August 1999 Informs of Approval of Util 980521 Request for Exception to 10CFR50.4(b)(6),allowing Util to Submit Updates to Plant Ufsar.Ltr Modifies That Approval & Grants Util Approval 3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999 Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002 ML20212C1351999-08-27027 August 1999 Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input 3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999 Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71 3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999 Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3 3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999 Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05 3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999 Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal 3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999 Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2 3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999 Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value 05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999 Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented ML20210Q4511999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006 ML20210P0741999-08-0505 August 1999 Forwards SE Accepting Licensee 980416 & 1130 Ltrs Re Third 10-year Interval ISI Program Plan & Associated Requests for Relief for Plant,Unit 3 3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999 Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603 ML20210G8551999-07-27027 July 1999 Forwards Insp Rept 50-302/99-04 on 990523-0703.One Violation Identified & Being Treated as Noncited Violation 3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999 Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments ML20209H5211999-07-16016 July 1999 Forwards Request for Addl Info Re Licensee Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in CR-3 once-through Steam Generators in Order to Complete Review ML20209G3231999-07-15015 July 1999 Forwards Biological Opinion Issued by Natl Marine Fisheries (NMFS) of Dept of Commerce.Nmfs Concluded That Operation of Cw Intake Sys of Crystal River Not Likely to Jeopardize Existence of Species Listed in Biological Opinion ML20209G3481999-07-15015 July 1999 Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon 3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999 Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl 3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999 Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl 3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999 Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl 3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999 Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730 3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999 Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held 3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21 ML20196L1261999-07-0707 July 1999 Discusses Closeout of TAC MA0538 Re License Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Unit 3 3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999 Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3 ML20196J4991999-07-0101 July 1999 Advises That Info Contained in ,Which Included TR BAW-2346P,will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20209C0811999-06-25025 June 1999 Forwards Overdue Controlled Document Transmittals for Listed Documents 3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999 Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEAR3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999 Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed 3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999 Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made 3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999 Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment 3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999 Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331 3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999 Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46 3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999 Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv) 3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999 Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief 3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999 Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals ML20212C1351999-08-27027 August 1999 Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input 3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999 Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002 3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999 Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71 3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999 Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3 3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999 Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal 3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999 Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05 3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999 Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2 05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999 Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented 3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999 Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value 3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999 Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603 3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999 Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments ML20209G3481999-07-15015 July 1999 Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon 3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999 Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl 3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999 Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl 3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999 Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl 3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999 Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730 3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999 Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held 3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999 Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21 3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999 Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3 ML20209C0811999-06-25025 June 1999 Forwards Overdue Controlled Document Transmittals for Listed Documents 3F0699-12, Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested1999-06-23023 June 1999 Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested 3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999 Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl 3F0699-08, Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments1999-06-21021 June 1999 Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments 3F0699-09, Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl1999-06-0404 June 1999 Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl 3F0599-21, Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads1999-05-28028 May 1999 Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads 3F0599-10, Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl1999-05-26026 May 1999 Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl ML20207E4341999-05-25025 May 1999 Submits 30-day Written Rept on Significant PCT Changes in ECCS Analysis for ANO-1.CRAFT2 Limiting PCT for ANO-1 Was Bounded by 1859 F PCT Calculated at 2568 Mwt for Crystal River 3 Cold Leg Pump Discharge Break Size of 0.125 Ft 3F0599-22, Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs1999-05-21021 May 1999 Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs 3F0599-18, Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM1999-05-14014 May 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM 3F0599-17, Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments1999-05-14014 May 1999 Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments 3F0599-07, Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 19781999-05-14014 May 1999 Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 1978 3F0599-03, Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR1999-05-12012 May 1999 Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR 3F0599-05, Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl1999-05-12012 May 1999 Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl 3F0599-08, Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments1999-05-0303 May 1999 Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments 3F0599-09, Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 19981999-05-0101 May 1999 Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 1998 3F0499-24, Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent1999-04-30030 April 1999 Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent 3F0499-09, Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 9907301999-04-30030 April 1999 Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 990730 3F0499-23, Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements1999-04-23023 April 1999 Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements 3F0499-18, Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl1999-04-20020 April 1999 Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl 3F0499-05, Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin1999-04-16016 April 1999 Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin 3F0499-08, Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 19981999-04-16016 April 1999 Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 1998 1999-09-27
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Florida Pswer Mis i
April 7,1997 3F0497-05 l l
U.S. Nuclear Regulatory Commission !
Attn: Docurnent Control Desk Washington, D.C. 20555-0001 l
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Subject:
REVISED LOW TEMPERA,TURE OVERPRESSURIZATION !
PROTECTION FEATURES AND REQUEST FOR EXEMPTION TO USE I ASME CODE CASE N-514
References:
A) NRC to FPC letter, 3N0895-21, dated August 31,1995 j B) FPC to NRC letter, 3F0996-09, dated September 6,1996 i C) NRC to FPC letter, 3N0297-01, dated February 4,1997
Dear Sir:
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in Reference 'A', the NRC denied Florida Power Corporation's (FPC's) Technical '
Specification (TS) change request regarding Low Temperature Overpressure Protection (LTOP) features and requested that FPC submit a revised response to Generic Letter (GL) 88-11, "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its impact on Plant Operations."
In Reference 'B', FPC responded to Reference 'A' and described FPC's justification for continuing to implement its LTOP features at Crystal River Unit 3 (CR-3) using administrative controls and provided an October 1997 schedule for submitting a revised LTOP Technical Specification change request and response to GL 88-11. At the time Reference 'B' was submitted, CR-3 was shut down for what was expected to be a short term outage to repair a leaking turbine lube oil pipe. It was expected that the plant would return to power and operate until the revised LTOP Technical Specification could be submitted, reviewed, and approved by the NRC. Contrary to this expectation, CR-3 has remained shut down. As such, the plant is in a condition where LTOP features are required and are being implemented.
15 EA NR -
/00 3 CRYSTAL RIVER ENERGY COMPLEX:15760 W Power une St . Crystal River, Florida 844284700 * (352)7954488 A Florstra Progress Company
', U.S. Nuclear Regulatory Commission 3F0497-05 Page 2 in Reference 'C' the NRC informed FPC that the proposed LTOP features were unacceptable because the LTOP administrative controls and setpoints were not based on the current pressure / temperature curves and requested that FPC submit a revised LTOP Technical Specification within 60 days of receipt of the letter. FPC received Reference 'C' on February 11,1997.
This letter is in response to Reference 'C'. The proposed actions in this response have been discussed with the NRC Project Manager. FPC is providing, as Enclosure 1 to this letter, a Justification for Continued Operation (JCO) to continue implementing LTOP features through administrative controls until a TS change request for LTOP features is submitted and approved by the NRC. The features being implemented include: 1) a new Reactor Coolant System (RCS) maximum pressure limit of 100 psig and 2) a lower Pilot-Operated Relief Valve (PORV) setpoint 1 of 454 psig. These features are based on the approved 15 effective full power year (EFPY) pressure-temperature (P/T) curves for CR-3, which were developed using American Society of Mechanical Engineers (ASME) Code,Section XI, Appendix G methodology. They provide for safe operation in Mode 5 with the reactor pressure vessel head fully tensioned and the RCS fi!!ed and vented. The new PORV setpoint ;
will be implemented by May 23,1997. These controls will remain in effect until )
revised LTOP Technical Specification features, which address the full range of RCS pressures, are completed. The TS change request will be submitted by September !
18,1997.
With these proposed LTOP features implemented, CR-3 cannot start reactor coolant pumps. This prevents a normal plant startup. Therefore, FPC is developing additional analyses to define LTOP features for the Technical Specifications which will allow plant startup. These analyses use the methodology described in ASME Code Case N-514, " Low Temperature Overpressure Protection," which has not yet been endorsed by the NRC. Pursuant to 10 CFR 50.12, " Specific Exemptions", FPC requests an exemption from 10 CFR 50.60 to allow the use Code Case N-514. The exemption request is detailed in Enclosure 2 of this letter.
l Code Case N-514 was approved by ASME on February 12,1992, and incorporated into the 1993 Addenda to the ASME Boiler and Pressure Vessel Code,Section XI, Appendix G. Code Case N-514 provides alternate guidance on developing LTOP features, when LTOP features must be in effect, and the maximum RCS pressures allowable for LTOP features.
Regulatory Guide 1.84,1.85, and 1.147 list the ASME Code Cases that have been approved by the NRC. Code Case N-514 has not yet been added to those Regulatory Guides, although it has been approved for use at other facilities through
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, ; U.S. Nuclear Regulatory Commission 3F0497-05
- Page 3 the 10 CFR 50.12 exemption process. Code Case N-514 is also discussed in the
, attachment to SECY-94-267, Section 4.5.2, " Status of Low Temperature
_Overpressurization Protection Limits issue." That discussion concludes with the statement "The content of Code Case N-514 has been incorporated into Appendix .
4 G of Section XI of the ASME Code and published in the 1993 Addenda to Section XI. The NRC Staff is currently developing a revision to 10 CFR 50.55a that will !
{ endorse the 1993 Addenda and Appendix G of Section XI in the regulations." .
The enclosed exemption request is justified because it meets the requirements of 10 CFR 50.12 in that it is authorized by law, it will not present a risk to the public l health and safety, it is consistent with the common defense and security, and 1 special circumstances are present. Enclosure 2 describes specifically how these regulatory requirements are met. FPC requests approval of this exemption request '
a by July 15, 1997 to support development of the Technical Specification change request for LTOP features described above and restart from the current outage. If i questions arise during your review please contact the Manager of Nuclear Licensing, ;
at (352) 563-4566.
l Sincerely,
//~h J(YDwa.q John Paul Cowan Vice President Nuclear Production JPC/pmp Enclosures xc: Regional Administrator, Region ll Senior Resident inspector NRR Project Manager l
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. ; U.S. Nuclear Regulatory Commission 3F0497-05 Page 4 ENCLOSURE 1 JUSTIFICATION FOR CONTINUED OPERATION FOR LOW TEMPERATURE OVERPRESSURlZATION PROTECTION AT CRYSTAL RIVER UNIT 3 BACKGROUND The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 88-11, "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and Its Impact on Plant Operations," on July 12,1988. Florida Power Corporation (FPC) responded to the NRC in a letter dated November.23,1988, requesting the formal response to GL 88-11 be consolidated with a Technical Specification Change Request Notice (TSCRN) for 15 effective full power years (EFPY) pressure / temperature (P/T)
Curves.
On October 31,1989, FPC submitted to the NRC a TSCRN to change P/T limits for heat-up, cool-down and inservice leak and hydrostatic testing, based on the 15 EFPY and include Low Temperature Overpressurization Protection (LTOP) features for Crystal River Unit 3 (CR-3) in the Technical Specifications (TS). The TSCRN was FPC's formal response to GL 88-11. The NRC accepted the 15 EFPY P/T curves in a letter dated February 7,1991. At that time, the LTOP TSCRN was still under review.
Between October 31, 1989 and August 31, 1995, there were several meetings and discussions between the NRC, B&W/Framatome and FPC on the methodology to determine LTOP features. On August 31, 1995, the NRC issued a safety evaluation report (SER) denying the TSCRN for LTOP features. In response to that denial, on September 6,1996, FPC submitted a schedule to the NRC to revise the response to GL 88-11. The letter identified the interim LTOP administrative controls in place at CR-3 and proposed a date of October 15,1997 for the GL 88-11 revised response submittal. l On February 4,1997, the NRC rejected FPC's proposal for LTOP administrative ;
- controls and schedule for a response to GL 88-11, and requested FPC submit i proposed LTOP Technical Specifications within 60 days. FPC's does not have LTOP features currently in Technical Specifications. FPC has determined administrative controls would be equally effective as a TS change for the current outage.
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,' U.S. Nuclear Regulatory Commission 3F0497-05 Page 5 CURRENT CONDITIONS CR-3 is currently in MODE 5, with the reactor pressure vessel (RPV) head fully tensioned, and the reactor coolant system (RCS) filled and vented. CR-3 is susceptible to an LTOP occurrence while the plant is in this condition. CR-3 is currently implementing LTOP features by using operating procedures (OP's). Limite and precautions for LTOP features are included in OP-202, " Plant Heat-up," OP-209, " Plant Cool-down," OP-301, " Operation of the Reactor Coolant System," OP-305, " Operation of the Pressurizer," OP-401, " Core Flood System," OP-402,
" Makeup and Purification System," and OP-404, " Decay Heat Removal System."
FPC's current procedure limits and precautions related to LTOPS are:
- 1. Pressurizer level is .1220 inches to maintain a cornpressible volume to accommodate a water level surge.
- 2. Both trains of High Pressure Injection (HPI) injection valves are closed and breakers secured to prevent inadvertent HPI into the RCS.
- 3. The PORV is operable with a low setpoint to maintain RCS pressure below the P/T limit curves.
- 4. The Core Flood Tank (CFT) pressure is maintained within maximum allowable RCS pressure / temperature limits when CFT isolation valves, CFV-5 and/or CFV-6, are open, or these valves are closed to prevent inadvertent CFT injection into the RCS.
ASME SECTION XI RECOMMENDATIONS FOR LTOP The ASME Section XI Working Group on Operating Plant Criteria (WGOPC), which has the responsibility for Appendix G to Section XI, considered the burden and safety impact imposed by the regulatory requirements for LTOP, and developed Code guidelines for determining the LTOP setpoint pressure and the required LTOP enabling temperature. These guidelines state:
LTOP systems shall be effective at coolant temperatures less than 200 F or at coolant temperatures corresponding to a reactor vessel metal temperature less than reference temperature nil-ductility
l l U.S. Nuclear Regulatory Commission 3F0497-05 Page 6 (RTuoy) + 50 F, whichever is greater.*'
- LTOP systems shall limit the maximum pressure in the vessel to 110% of the pressure determined to satisfy Appendix G of Section XI, Article G-2215.
These ASME Code guidelines relieve some cperational constraints and provide adequate margins against failure for the reactor pressure vessel. Further, by relieving the operational restrictions, these guidelines result in a reduced potential )
for activation of pressure relieving devices, thereby improving plant safety.
PROPOSED CHANGES FPC will limit RCS pressure to 100 psig and set the PORV low setpoint to 454 l psig. These values are based on the 15 EFPY P/T curves, using the methodology described in ASME,Section XI, Appendix G, with no reactor coolant pumps running. The PORV setpoint will be lowered to 454 psig by May 23, 1997.
Procedure changes to control RCS pressure to less than or equal to 100 psig will be completed by June 27.-1997. These administrative controls will remain in effect until revised LTOP Technical Specification features, which address the full range of RCS pressures, are completed.
JU6TIFICATION FOR CONTINUED OPERATION '
CR-3 is currently in MODE 5 with the RPV head fully tensioned and the RCS filled l and vented. FPC will remain in the current plant configuration based on the ;
administrative controls and PORV setpoint change described above.
The proposed LTOP features are based on the approved (15 EFPY) P/T curve r analyses for CR-3, and on the accepted methodologies for this type of analysis.
Specifically, the values are based on ASME,Section XI, Appendix G, as referenced by 10 CFR 50, Appendix G.
The PORV low setpoint will be adjusted to 454 psig. This value is based on the analysis for the approved 15 EFPY P/T curves for CR-3, using ASME,Section XI, Appendix G. The proposed LTOP setpoint for the PORV of 454 psig will protect the current steady state P/T curves at 100% of the Appendix G limits, provided that no RC pumps are operating.
1 The coolant temperature is the reactor coolant inlet temperature.
2 The vessel metal temperature is the temperature at a distance one fourth of the vessel section thickness from the inside wetted surface in the vessel beltline region. RT,cr is the highest adjusted reference temperature (for weld or base metal in i the beltline region) at a distance one forth of the vessels section thickness from the wetted inner surface ss determined by Regulatory Guide 1.99, Revision 2.
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. ,' U.S. Nuclear Regulatory Commission 3F0497-05 Page 7 Based on the analysis using ASME Code Case N-514, LTOP protection is provided when pressurizer level is 1220 inches if the RCS pressure is limited to < 200 psig.
Until ASME Code Case N-514 is approved for use at CR-3 through the approval of the enclosed exemption request, the RCS pressure will be limited to 1100 psig for the current outage (MODE 5), and the allowable pressurizer water level will remain 1220 inches, in accordance with the administrative controls described earlier.
FPC selected 100 psig as the administrative limit for the RCS pressure to provide margin to the analytical limit.
l In addition to the revised PORV setpoint and RCS pressure limits, the existing limits and precautions established for LTOP will remain in effect to control inadvertent addition of mass to the RCS.
FPC is also requesting an exemption from 10 CFR 50.60 to use ASME Code Case
! N-514 to establish the LTOP features for CR-3. FPC determined that the revised 4 LTOP features, without the use of the ASME Code Case N-514, resulted in reactor coolant pump operational prohibitions, based on pressurizer level and the window between the P/T curves and reactor coolant pump net positive suction head curve.
l Therefore, use of ASME Code Case N-514 is necessary to develop the LTOP features for CR-3.
CR-3 is in a safe condition for current plant operating mode. Reducing the PORV low set point to 454 psig will protect the P/T curve from being exceeded, therefore, assuring RPV integrity is maintained. The administrative controls provide a defense in-depth to prevent an LTOP occurrence due to an inadvertent introduction of water into the RCS. The inherent conservatisms in the ASME Code,Section XI, Appendix G analysis methodology, provide further assurance the RPV integrity will not be jeopardized.
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i U.S. Nuclear Regulatory Commission 3F0497-05 Page 8 ENCLOSURE 2 l
EXEMPTION REQUEST TO USE ASME CODE CASE N-514 l
l EXEMPTION REQUEST l l t 10- CFR 50.60, " Acceptance Criteria for Fracture Prevention Measures for l Lightwater Nuclear Power Reactors For Normal Operation," states "Except as l provided in paragraph '(b) of this section, all lightwater nuclear power reactors l must meet the fracture toughness and material surveillance program requirements !
for the reactor coolant pressure boundary set fourth in Appendices G and H to this l part." Part 50, Appendix G, Paragraph IV(A)(2)(b), requires that "
... pressure-temperature limits...be at least as conservative as limits obtained by following the methods of analysis and the margins of safety of Appendix G of Section XI of the I
ASME Code." 10 CFR 50.60, Paragraph (b) allows alternatives to Appendices G and H when the Commission grants an exemption to the Rule under 10 CFR j 50.12. !
l Pursuant to 10 CFR 50.12, FPC hereby requests an exemption from 10 CFR 50.60 l and approval to use ASME Code Case N-514, " Low Temperature Overpressure l- Protection Section XI, Division 1" in lieu of ASME Code,Section XI, Appendix G.
l Code Case N-514 will be used to establish the LTOP setpoints for CR-3.
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10 CFR 50.12 states the Commission may grant exemptions from the
! requirements contained in 10 CFR 50 which are:
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- 1) Authorized by law No law exists which precludes the activities covered by this exemption l request. 10 CFR 50.60(b) allows the use of alternatives to 10 CFR 50, l
Appendices G and H when an exemption is granted by the Commission l under 10 CFR 50.12.
- 2) Will not present an undue risk to the public health and safety
. This exemption does not present an undue risk to public health and safety for the following reasons. The LTOP setpoint will utilize 110% of the pressure determined to satisfy ASME Section XI, Appendix G, Paragraph G-r 2215, as a design limit. PORV setpoints and enabling temperatures will be j developed based on the appropriate P/T curves. The enable temperature is
- . , U.S. Nuclear Regulatory Commission 4 3F0497-05 Page 9 to provide a bounding low coolant temperature for reactor vessel integrity protection during an LTOP design-basis transient. The approach is justified because the resulting pit curve provides adequate margin to protect the i reactor vessel against brittle fracture.
1 Restrictions on allowable operational conditions and equipment operability !
requirements have been established to ensure that operating conditions are consistent with the assumptions of the accident analysis. Specifically, RCS :
3 pressure and temperature must be maintained within the heat-up and cool- '
5 down rate dependent pressure / temperature limits specified in TS 3.4.3, "RCS Pressure and Temperature Limits."
- 3) Consistent with the common defense and security This exemption request applies to the operation of the CR-3 RCS at low temperatures and pressures. It does not effect the common defense and security.
10 CFR 50.12(a)(2) states "The Commission will not grant an exemption unless special circumstances are present." FPC's request meets the special circumstances as described below:
a) 10 CFR 50.12(a)(2)(li), Application of the regulation in the particular ,
circumstances would not serve the underlying purpose of the rule...;
ASME Code Case N-514 recognizes the conservatism of the ASME Appendix G curves and allows setting LTOP setpoints such that the ASME Section XI, Appendix G limits are not exceeded by more than 10E The Code Case permits use of an LTOP enable temperature equal to the reference temperature, nil-ductility (RTuor) plus 50 F for the limiting material, or 200 F, whichever is greater. This allows the implementation of LTOP features which preserve an acceptable margin of safety while at low temperatures and pressures. The LTOP features established in accordance with ASME Code Case N-514 will also reduce the risk of unnecessary actuations of the protection system pressure relieving device (the PORV).
Therefore, establishing the LTOP features in accordance with ASME Code Case N-514 criteria satisfies the underlying purpose of the ASME Code and the NRC regulations to ensure an acceptable level of safety.
b) 10 CFR 50.12(a)(2)(iii), compliance would result in undue hardship or other costs that are significant if the regulation is enforced;
I- . U.S. Nuclear Regulatory Commission 3F0497-05 Page 10 The reactor coolant system pressure / temperature operating window at low temperatures is defined by the LTOP features. Implementation of LTOP features without the additional margin allowed by ASME Code Case N-514 would restrict the pressure / temperature operating window and would potentially result in undesired actuation of the PORV. This constitutes an undue hardship that can be alleviated by the application of ASME Code Case N-514. Implementation of LTOP features in accordance with ASME Code Case N-514 provides assurance that the reactor vessel is protected at low temperatures.
10 CFR 50.12(a)(2)(v), the exemption will provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulations.
The exemption provides only temporary relief from the regulation and FPC has made a good faith effort to comply with the regulations. FPC will
, implement LTOP features in accordance with the regulations as described in Enclosure 1. However, FPC determined that implementation of the LTOP features, without the use of the ASME Code Case N-514, results in operational prohibitions for reactor coolant pumps and, therefore, prohibits plant heat-up and cool-down. FPC requests that the exemption be granted until such time as the NRC endorses Code Case N-514 for use by the industry. However, to obtain sufficient pressure / temperature operating margin for normal reactor startup, FPC requires the exemption to use ASME Code Case N-514.
CONCLUSION FOR EXEMPTION TO USE ASME CODE CASE N-514 l As discussed above, this exemption request will not present undue risk to the i
health and safety to the public. Compliance with the requirements of 10 CFR 50.60 would result in undue hardship without a compensating increase in the level l of quality and safety. ASME Code Case N-514 allows setting the PORV setpoint and enable temperature such that the ASME,Section XI, Appendix G limits are not exceeded by more than 10%. The Code Case recognizes the conservatism of the Appendix G curves and allows establishing a PORV setpoint that retains an acceptable margin of safety while maintaining operational margins for reactor coolant pump operation at low temperatures and pressures. The Code Case provides an acceptable margin of safety against reactor vessel failure and reduces the potential for an undesired PORV actuation. Therefore the application of ASME Code Case N-514 at CR-3 will ensure an acceptable level of safety.
Code Case N-514 was approved by ASME on February 12, 1992, and incorporated into the 1993 Addenda to ASME Boiler and Pressure Vessel Code,
t- , U.S. Nuclear Regulatory Commission 3F0497-05 i Page 11 Section XI, Appendix G. Code Case N-514 provides guidance on when LTOP features shall be implemented and the maximum RCS pressures allowable for LTOP.
Regulatory Guides 1.84,1.85, and 1.147 list the ASME Code Cases that have
- been approved by the NRC. Code Case N-514 has not yet been added to those Regulatory Guides, although it has been approved for use at other facilities. Code Case N-514 is also discussed in the attachment to SECY-94-267, Section 4.5.2, i
" Status of Low Temperature Overpressurization Protection Limits issue." That ,
discussion concludes with the statement "The content of Code Case N-514 has :
been incorporated into Appendix G of Section XI of the ASME Code and published in the 1993 Addenda to Section XI. The NRC Staff is currently developing a i revision to 10 CFR 50.55a that will endorse the 1993 Addenda and Appendix G of -
Section XI in the regulations."
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