3F0691-11, Responds to NRC 910506 Sser Re Station Blackout Rule Implementation at Facility.Station Blackout Battery Calculation Updated to Reflect Revised Coping Strategy to Be Implemented After Installation of non-1E Battery

Responds to NRC 910506 Sser Re Station Blackout Rule Implementation at Facility.Station Blackout Battery Calculation Updated to Reflect Revised Coping Strategy to Be Implemented After Installation of non-1E Battery

ML20081J031
Person / Time
Site:	Crystal River
Issue date:	06/13/1991
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0691-11, 3F691-11, NUDOCS 9106210006
Download: ML20081J031 (3)

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- Docket No. 50 302 June 13, 1991-3F0691-ll Nuclear. Regulatory Commission Attention: Document Control Desk Washington, D.C, 20555

Subject:

Station Blackout Rule Implementation

Reference:

A. NRC to FPC letter dated May 6, 1991 B. FPC to NRC letter dated April 17, 1989 C. FPC to NRC letter dated March 30, 1990 D. FPC to NRC letter dated October 22, 1990

Dear Sir:

This letter provides a response to the NRC staff's Supplemental Safety Evaluation (Reference A) regarding station blackout rule implementation for Crystal. River Unit- 3 (CR-3) as described in References B, C, and D. lnis letter provides -

additional information on three of five issues requiring further clarification.

EMERGENCY DIESEL GENERATOR (EDG) RELIABILITY PROGRAM NRC Recommendation: "[T]he licensee should state that this program will be in accordance with NUMARC 87-00, Appendix 0, as documented in the currently approved (November 1987) version (which is equivalent to RG 1.155, Section 1.2.), or with RG 1.155, Section 1.2."

FPC Resoonse: As part of the SB0 coping duration determination, FPC has committed to a target emergency diesel generator (EDG) reliability. In order to assure that reliability is maintained, FPC has implemented Performance Test, PT-354, "EDG Reliability and Unavailability Program," effective January 4,1991.- The program implements elements 1 through 4 of Regulatory Guide 1.155, Section 1.2.

Element 5, management oversight, although not addressed in PT-354, is addressed through management review of corrective action plans following any diesel generator start or load-run failure, n ., o s., v a . .L J

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9106210006 910614 {Dl -

P PDR ADOCK 05000302 PDR A Florida Progress Company k'u ll

4 U. S. Nuclear Regulatory Commission June 13, 1990 3F0690-Il Page 2 To date, the NRC has not issued Revision 3 to Regulatory Guide 1.9 or the proposed generic letter. Pending issuance by the Staff of these two documents, FPC will continue to use the aforementioned procedures to monitor EDG reliability. FPC will, upon issuance by the Staff, review the above mentioned documents and adjust our program, if appropriate.

Additionally, the Supplemental Safety Evaluation partially quoted the October 22, 1990 submittal (Reference D). The FPC submittal stated "The program will be based upon NUMARC 87-00, Appendix D and Regulatory Guide 1.9, as appropriate."

The underlined words were omitted from the quote in the Supplemental Safety Evaluation.

CLASS 1E BATTERY CAPACITl NRC Recommendation: "[T]he licensee should specifically state that the updated )

battery calculations (load profile) will equal or envelope the load profile i imposed by the normal battery-backed plant monitoring and electrical system )

controls in the control room during the SB0 event."

EPC Remqrts_el The station blackout battery calculation is being updated to reflect the revised coping strategy which FPC will implement following installation of the non-lE battery. This activity is required to demonstrate compliance with 10 CFR 50.63 and FPC's 10CFR50, Appendix B design control program. The updated battery calculation (load profile) will equal or envelope the load profile imposed by the normal battery-backed plant monitoring and electrical system controls in the control room needed for the SB0 event. Some unneeded loads may be manually stripped as allowed by NUMARC 87-00. This manual stripping (if any) will be reflected in the battery calculations.

L 1EVERTER OPERABILITY NRC Reauest: "The licensee must resolve this concern by, for example, providing appropriate cooling to the inverters, or demonstrating by test that the inverters will not fail at the expected temperature plus a reasonable margin,"

FPC Response: FPC understands the concerns of the NRC regarding the analysis to support inverter operability and is attempting to procure a more substantive test report to support' operability. FPC will provide a status update on our efforts to resolve this issue by July 31, 1991.

CONTROL ROOM HEATE NRC Reauest: "[T]he licensee must inform us specifically how temperature will be maintained at an acceptable level for operators and to assure SB0 equipment operability in the control room."

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U. S. Nuclear Regulatory Commission June 13, 1990 3F0690-11 Page 3 FPC Response: The temperature in the control room will be maintained at an acceptable level for the operators and to assure SB0 equipment operability by ,

opening the control room doors to allow fresh air from the turbine building to I enter and by removing a limited number of ceiling tiles, allowing greater air I circulation within the control room. The requirement for these actions will be incorporated into the station blackout procedure.

REACTOR COOLANT INVENTORY l

NRC Reauest: "[T]he licensee is requested to provide a copy of the analysis, or a summary of the assumptions used and results obtained, since this was not available during the staff's original audit."

FPC Response _1 A summary of the assumptions used and the results obtained in the i reactor coolant inventory analysis has been prepared and will be submitted pending release by the B&W Owners Group. This summary will be submitted by July 3, 1991.

Sincerely,

.M Beard, Jr.

Senior Vice President Nuclear Operations  ;

PMB:AEF xc: Regional Administrator, Region II NRR Project Manager Senior Resident Inspector