3F0599-01, Rev 1 to LAR 241 for Amend to License DPR-72,revising Wording for SR 3.5.2.5 to Be More Consistent with NUREG-1430,rev 1 & Clarifying Process of Valve Position Verification
| ML20206M081 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/07/1999 |
| From: | Holden J FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20206M087 | List: |
| References | |
| RTR-NUREG-1430 3F0599-01, 3F599-1, TAC-MA3614, NUDOCS 9905140189 | |
| Download: ML20206M081 (5) | |
Text
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Flrrida Power "J ER^Lof
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May 7,1599 3F0599-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
License Amendment Request #241, Revision 1 High Pressure Injection System Modifications (TAC No, MA3614)
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Reference:
FPC to NRC letter, 3F1198-03, dated November 23,1998, " License Amendment Request #241, Revision 0, High Pressure Injection System Modifications" i
Dear Sir:
The purpose of this letter is to revise the proposed changes to the Improved Technical Specifications (ITS) requested in License Amendment Request (LAR) #241, Revision 0. LAR
- 241 proposed changes to the Crystal River Unit 3 (CR-3) ITS, including a revision to Surveillance Requirement (SR) 3.5.2.5 to accommodate plant modifications that are being implemented in the upcoming refueling outage. This submittal revises the wording for SR 3.5.2.5 to be more consistent with NUREG 1430, Revision 1, Standard Technical l
Specifications for Babcock and Wilcox Plants. The Bases for SR 3.5.2.5 are also revised to reflect this wording change and to clarify the process of valve position verification.
l The revision to LAR #241 does not affect the No Significant Hazards Consideration as L
provided in the referenced letter and as presented in the Federal Register Notice dated December 30,1998 (63 FR 71966-71968).
This letter establishes no new regulatory commitments. If you have any questions regarding this submittal, please contact Mr. Sid Powell, Manager, Nuclear Licensing at (352) 563-4883.
j S$ Sincerely, T
2.5 89 M
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. Holden Vice President and Site Director
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Regional Administrator, Region II u
NRR Project Manager 1
Senior Resident Inspector Attachments:
A. Description and Justification for Proposed Changes B. Proposed Revised Improved Technical Specifications and Bases Pages CRYSTAL RIVER ENERGY COMPLEX: 15760 W. Power Line Street + Crystal River, Florlde 34428-6708 + (352)795-6486 A Floride Progress Company t,i
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. U.S. Nuclear Regulatory Commission 3F0599-01 Page 2 of 2 1
STATE OF FLORIDA COUNTY OF CITRUS John J. Holden states that he is the Vice Presiderat and Site Director 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 and correct to the best of his knowledge, informatiori, and belief.
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John J. Holden Vice President and Site Director Sworn to and subscribed before me this N day of MA/
,1999,by John J. Holden.
'A j8, Notary Public,Stateof Florkin USA ANN MCBRIDE V '
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Signature of Notary Public
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State of Florida c
LLs A A/U N1 *8 / / 0 '
(Print, type, or stamp Commissioned Name of Notary Public)
Personally 1f Produced Known
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FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 ATTACHMENT A LICENSE AMENDMENT REQUEST #241, REVISION 1 HIGH PRESSURE INJECTION SYSTEM MODIFICATIONS Description and Justification for Proposed Changes
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', U.S. Nuclear Regulatory Commission Attachment A 3F0599-01 Page 1 of 2 1
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1 Attachment A Description and Justification for Proposed Changes Pursuant to discussions with the NRC staff, Florida Power Corporation (FPC) is proposing a revision to the wording of Improved Technical Specifications (ITS) Surveillance Requirement (SR) 3.5.2.5. The wording proposed in License Amendment Request (LAR) #241, Revision 0, identified the high pressure injection (FIPI) valves by function (throttled) rather than by valve tag number. The Standard Technical Specifications (STS) for Babcock and Wilcox Reactors (NUREG 1430, Revision 1) and the existing Crystal River Unit 3 (CR-3) ITS both list the IIPI valve tag numbers in this SR. The proposed revision to ITS SR 3.5.2.5 adds the IIPI valve tag j
numbers for all valves that may be throttled in the llPI flow path.
i The proposed revisions to the LAR #241 ITS changes are primarily administrative in nature.
Both the originally proposed wording in LAR #241 and the proposed revised wording will ensure that the IIPI stop check valves and throttle valves are in the correct position.
l The wording for SR 3.5.2.5 requested in LAR #241, Revision 0 was as follows:
8 "SR 3.5.2.5 Verify correct position for valves throttled in the llPI flow path that are locked, sealed or otherwise secured in position."
The term " throttled" was intended to include all valves not in the full open position. This would include the throttle valves and one or more of the stop check valves (one or two of the 1
stop check valves are expected to be full open). Any stop check valve that was in the full open l
position would not be verified under this surveillance. Ilowever, the same verification would be performed under the CR-3 locked / sealed valve program.
In order to ensure that all stop check and throttle valves are addressed under SR 3.5.2.5, the following wording is proposed:
"SR 3.5.2.5 Verify the following valves in the IIPI flow path are locked, sealed or otherwise secured in the correct position:
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- a. MUV-2;
- b. MUV-6;
- c. MUV-10;
- d. MUV-590; j
- e. MUV-591; i
- f. MUV-592: and
- g. MUV-593."
l This proposed rpvised wording is consistent with the STS and the current CR-3 ITS, which include a list of the stop check valves, MUV-2, MUV-6 and MUV-10. The revised list also includes the new throttle valves, which will provide the required functions as described in the I
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, U.S. Nuclear Regulatory Commission Attachment A q
3F0599-01 Page 2 of 2 i
i Bases. This change is considered administrative in nature because the previous proposed change and the locked / sealed valve program would ensure the same valves as those in the proposed list were in the correct position.
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Verification of the valves' positions will be accomplished by assuring the mechanism that locks, seals or secures the valves is intact. If the stop check valves or throttle valves are repositioned (for example, during maintenance or testing), the valves must be returned to their correct position and then secured. Verification of the valve position ensures that the "as-left" condition maintains the HPI flow assumptions in the accident analysis. There is no routine maintenance or testing that requires the throttle valves to ur.dergo a position change.
Therefore, the SR for the throttle valves will normally only require a visual inspection of the sealing mechanism.
The Bases for SR 3.5.2.5 are being revised to indicate that all the valves listed in the SR (stop check valves and HPI throttle valves) will be verified in the correct position, not just those that are throttled. The Bases are also being revised to def' e the valve position verification process m
as follows:
" Verification of correct valve podtion will be accomplished by assuring the mechanism that locks, seals or secures the valves is intact. If the stop check valves or throttle valves are repositioned, the valves must be returned to their correct position and then secured. This "as-left" position verification ensures the HPI flow assumptions in the accident analysis are maintained."
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