3F0518-03, Safety Analysis Report and 10 CFR 50.59 - 10 CFR 72.48 Report - May 2018
| ML18155A423 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/24/2018 |
| From: | Reising R Duke Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F0518-03 | |
| Download: ML18155A423 (11) | |
Text
Crystal River Nuclear Plant e.(-,DUKE 15760 W. Power Line Street
~ ENERGY Crystal River, FL 34428
- Docket 72-1035 Docket 50-302 Operating License No. DPR-72 10 CFR 50.71(e) 10 CFR 50.59( d)(2) 10 CFR 72.48( d)(2)
May 24, 2018 3F0518-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Safety Analysis Report and 10 CFR 50.59 - 10 CFR 72.48 Report - May 2018
Reference:
- 1. CR-3 to NRC Letter, "Crystal River Unit 3 - Final Safety Analysis Report, Revision 34, and 10 CFR 50.59 Report, dated May 25, 2016 (ADAMS Accession No. ML16172A182)
- 2. CR-3 to NRC Letter, "Crystal River Unit 3 - Final Safety Analysis Report -
August 2017, dated August 31, 2017 (ADAMS.Accession No. ML17251A161)
Dear Sir:
In accordance with 10 CFR 50. 71 (e ), Duke Energy Florida, LLC (DEF), hereby submits Revision 1 to the Crystal River Unit 3 (CR-3) Defueled Safety Analysis Report as Attachment 3 to this report. CD-ROMs are enclosed to the Document Control Desk, the Regional Administrator (Region I), and the CR-3 NRC Project Manager. This revision replaces the previous revision of the DSAR in its entirety. Revision O of the DSAR was submitted as part of Reference 2 above.
DSAR text changes are indicated by revision bars on the outside right border of each page.
The DSAR revision includes material which describes the organization, modifications, system abandonments and other changes to CR-3 that have been implemented subsequent to August .
31, 2017: As required by 10 CFR 50.71 (e), a summary of changes made in the DSAR, Revision 1, is provided in Attachment 1 (6 changes). Two (2) of these changes were made after a 50.54(a) review was completed to assure no Quality Assurance commitments would be reduced. No 10 CFR 50.54(a) review was required or performed for the remaining changes.
Additionally, as required by 10 CFR 50.59(d)(2) and 10 CFR 72.48(d)(2), in Attachment 2, DEF is providing a summary of evaluations completed under 10 CFR 50.59 and 10 CFR 72.48 for changes made to the plant and the Independent Spent Fuel Storage Installation (ISFSI).
Attachment 2 contains the 10 CFR 50.59 and 10 CFR 72.48 Report - May 2018, which includes a summary of all evaluations completed this reporting period (April 1, 2016 through April 1, 2018) with the exception of evaluations associated with changes, tests, or experiments that have not been fully implemented. In the event that multiple revisions were performed, the final 10 CFR 50.59 evaluation is being reported due to the cumulative nature of these changes. No 10 CFR 72.48 evaluations were completed by CR-3 for ISFSI related changes during this reporting period.
U. S. Nuclear Regulatory Commission Page 2 of 2 3F0518-03 No new regulatory commitments are made in this letter.
If you have any questions regarding this submittal, please contact Mr. Phil Rose, Nuclear Regulatory Affairs, at (352) 501-3172.
I declare under penalty of perjury that the forgoing is true and correct. Executed on May 24, 2018 Sincerely,
~~ &-
Ronald Reising, Senior Vice President Operations Support RR/par DSAR Revision 1 Change Summary Description 10 CFR 50.59 and 72.48 Report - May 2018 DSAR Revision 1 (CD) xc: Regional Administrator, Region I NMSS Project Manager
DUKE ENERGY FLORIDA, LLC CRYSTAL RIVER UNIT 3 LICENSE NUMBER DPR-72 DOCKET NUMBER 50-302 / 72-1035 ATTACHMENT 1 DSAR REVISION 1 CHANGE
SUMMARY
DESCRIPTION
U.S. Nuclear Regulatory Commission .Attachment 1 3F0518-03 Page 1 of 2 DSAR REVISION 1 CHANGE
SUMMARY
DESCRIPTION The Defueled Safety Analysis Report (DSAR) revision reflects plant modifications, system abandonment activities, and information and analyses that constitute changes to the DSAR since the publication of Revision 0. Applicable figures and tables were included in these changes but were not individually identified. Additionally, several material changes to the DSAR have been made as the result of License Amendments. As part of implementation of License Amendments No. 253 and 255, DSAR changes were made that did not reflect any plant change but were approved by the amendments.
This DSAR revision includes changes made to incorporate the following:
A. Changes to plant engineering, programs, and revisions to analyses:
- DSAR Change Package 2017-01: This change revised DSAR Chapter 1, Introduction and Summary; Chapter 3, Facility Design; and Chapter 5, Safety Analysis, to remove the Fuel Handling Accident from the DSAR and definitively state that all spent nuclear fuel is stored in the independent dry fuel storage facility (ISFSI) Due to having completed the
- 1 I
transfer of the fuel to the ISFSI, no safety related SSC remain in the plant, allowing for re-classification of SSC and removal of the last design basis accident. I I
- DSAR Change Package 2017-05: This change was to revise the description in Chapter I
6, Conduct of Operations, of the CR-3 Emergency Plan. The description was revised to reflect the implementation of License Amendment No. 253 for the ISFSI-Only Emergency Plan and to reference 10 CFR Part 72 as an applicable regulation.
- 8. Several editorial and clarification changes were made throughout the document. Each change was considered for 10 CFR 50.59 applicability using Crystal River Unit 3 and Duke Energy procedures: *
- DSAR Change Package 2018-03:
- This change clarified a commitment identified in License Amendment No. 247 related to the future inspection/surveillance of the neutron absorbing material in the spent fuel pool storage racks. Specifically, it stated that if the spent fuel will still be in the pools at the end of 2019, a LAR will have been submitted early enough to have a Permanently Defueled Technical Specification surveillance approved and implemented for the end of 2019. This commitment was revised to state that since all spent nuclear fuel was in dry storage by the middle of January 2018, this commitment was no longer required or valid. This change revised DSAR Chapter 3, Facility Design.
C. Quality Assurance Program changes that did not reduce commitments.
- DSAR Change Package 2018-02: This change revised Chapter 1, Introduction and Summary to incorporate into the Quality Assurance Program specific position requirements that were previously in the Permanently Defueled Technical Specifications (POTS). These included requirements for the Radiation Protection Manager, personnel who carry out Health Physics or Quality As.surance duties, and duties of the General Manager, Decommissioning. License Amendment No. 255 removed these requirements from the POTS and documented a commitment to include them into the Quality Assurance Section of the DSAR.
U. S. Nuclear Regulatory Commission Attachment 1 3F0518-03 Page 2 of 2
- DSAR Change Package 2018-04: This change removed the title and description of the Certified Fuel Handler as approved in Amendment No. 255. Chapter 1, Introduction and Summary, and Chapter 6, Conduct of Operations were affected.
D. Some changes are noteworthy because they involve removal of information from the DSAR.
These changes were evaluated per the guidance of Nuclear Energy Institute (NEI) 98-03, Revision 1, and determined to be appropriate:
DSAR Change Package 2018-05: This change removed significant information that is no longer necessary or valid based on the current configuration of the plant with all spent nuclear fuel stored within the ISFSI. In Chapter 1, Introduction and Summary, Fuel Design information was minimized and cycle specific information was removed. The Quality Assurance Prpgram in Chapter 1 was also revised to remove discussion about Duke Energy Fleet organizations that do not significantly interact with CR-3. Additional editorial changes were made to correct position titles.
In Chapter 2, Site and Environment, historical information associated with the local area was removed since no offsite dose concerns remain with all spent nuclear fuel stored within the ISFSI. A commitment for site flood protection measures was deleted and a clarification to the discussion on flood/hurricane effects was made to state that no Structures, Systems , or Components remain categorized as Class 1. The discussion in the site geology section of Chapter 2 also had information deleted as the amount of detail was not in accordance with the current configuration of the plant.
Chapter 3, Facility Design, had information deleted based *on the reclassification of plant SSC from Safety Related to Non-Safety and the amount of detailed design information presented for now Non-Safety SSC. The discussion on Spent Fuel Storage and Fuel Handling had information removed that was previously identified as historical or is no longer valid based on plant configuration. A reference to the fuel selection procedure used for the ISFSI loading campaign was added for completeness.
Chapter 4, Radioactive Waste and Radiation Protection, had some dilution flow information removed since other sources of adequate dilution flow are available.
DUKE ENERGY FLORIDA, LLC CRYSTAL RIVER UNIT 3 LICENSE NUMBER DPR-72 DOCKET NUMBER 50-302 / 72-1035 ATTACHMENT 2 10 CFR 50.59 AND 10 CFR 72.48 REPORT- MAY 2018
U. S. Nuclear Regulatory Commission Attachment 2 3F0518-03 Page 1 of 4 10 CFR 50.59 and 72.48 Evaluation Summaries Table of 10 CFR 50.59 Evaluations ID Number AR 1949206 Revising the FSAR for Spent Fuel Handling Activities AR 2103553 Manual Shutdown of Temporary Spent Fuel Area Air Conditioner AR 2145261 DSAR Revision O AR= Action Request No 10 CFR 72.48 evaluations were completed by CR-3 during this period.
U. S. Nuclear Regulatory Commission Attachment 2 3F0518-03 Page 2 of 4 ID Number: AR 1949206 Title Revising the FSAR for Spent Fuel Handling Activities Summary and Conclusions Spent fuel transfer cask handling will be conducted using a single failure proof lifting system, comprised of the new FHCR-5, along with lifting devices and interfacing lift points meeting the guidance in NUREG-0612. "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6.
With a new single failure proof crane, a load drop accident will be an extremely low probability event. Thus, the cask drop event described in the CR-3 Safety Evaluation Report, Section 9.1.2 (dated July 5, 1974 ), involving a dropped cask striking the edge of the pool deck and rolling or tumbling into the adjacent spent fuel pool causing damage to stored fuel is not considered credible. As such, NRC has approved Amendment 239 allowing movement of the cask with fuel in pool 'B' with no need for installation of the gate between the two spent fuel pools.
With the new single failure proof FHCR-5 crane being installed, mitigating actions required by NUREG 0612 section 5.1.2 no longer have to be addressed. This relieves the site from having to drain the Cask Loading Area (CLA) down to less than 6,000 gallons to protect safety related equipment located below. With CR-3 in decommissioning, and the equipment located on the floor below the pool (95') classified as abandoned or non-safety related; internal flooding is not of a concern. Therefore, deletion of the requirement to drain the CLA to 6000 gallons from FSAR Section 9.6.3.1 is considered.acceptable.
The Evaluation determined that no prior NRC approval is required to implement these activities.
U. S. Nuclear Regulatory Commission Attachment 2 3F0518-03 Page 3 of 4 ID Number: AR 2103553 Title Manual Shutdown of Temporary Spent Fuel Area Air Conditioner Summary and Conclusions This temporary modification package installs a rental air conditioning (AC) unit to spot cool various work areas in the Fuel Handling Building (FHB) during the ISFSI loading campaign. An emergency stop (ES) switch is being installed on the spent fuel floor to allow manual shutdown of temporary AC unit for radiological or fire emergencies.
With the operational requirement specified in the evaluation and the consequences of Fuel Handling Accident (FHA) and/or fire emergencies being insignificant and below the required limit, manual shut down of the temporary AC instead of automatic shut off will not impact the vacuum in the Auxiliary Building and will not result in leakage of fission product outside the FHB.
Installation of the temporary AC unit and manual shut down of the unit will not increase the consequence and frequency of occurrence of FHA previously evaluated in the FSAR, or malfunction of an SSC important to safety previously evaluated in the FSAR. With maintaining the required Aux building vacuum, the fission product barrier as described in the FSAR will be maintained.
It is concluded that a license amendment is not required for this change since the Air Handling system will be operated within its design limits, will not affect equipment used or the consequences of an accident, nor will it create a new accident.
U. S. Nuclear Regulatory Commission Attachment 2 3F0518-03 Page 4 of 4 ID Number: AR 2145261 Title DSAR Revision 0 Summary and Conclusions The development and issuance of the DSAR, which supersedes the FSAR in its entirety, involves no actual changes to any plant SSC, or significant changes to any maintenance, testing, operation, or surveillance program or procedure. Since no SSCs were impacted and the long period of shutdown with fuel removed from the reactor, there is no possibility for an accident or malfunction to occur, consequences to increase, fission product barriers to be challenged, or methods of evaluation to be changed. This DSAR revision is not required to be submitted to the NRC for prior approval.
DUKE ENERGY FLORIDA, LLC CRYSTAL RIVER UNIT 3 LICENSE NUMBER DPR-72 DOCKET NUMBER 50-302 / 72-1035 ATTACHMENT 3 DSAR REVISION 1 (CD)