3F0797-10, TS Change Request Notice 213,rev 0 to License DPR-72, Establishing Requirements for Low Temperature Overpressure Protection Sys

TS Change Request Notice 213,rev 0 to License DPR-72, Establishing Requirements for Low Temperature Overpressure Protection Sys

ML20196H017
Person / Time
Site:	Crystal River
Issue date:	07/18/1997
From:	Richard Anderson FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196H022	List: 3F0797-10, TS Change Request Notice 213,rev 0 to License DPR-72, Establishing Requirements for Low Temperature Overpressure Protection Sys ML20196H028 ML20196H038
References
3F0797-10, 3F797-10, NUDOCS 9707230284
Download: ML20196H017 (14)

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Ng[Y Florida Power -

' CORPORATION C,yetal River Unit 3 Docent No. 50402 July 18,1997

. 3F0797-10 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Technical Specification Change Request Notice 213, Revision 0

References:

1. FPC to NRC letter, 3F0497-05, " Revised Low Temperature Overpressurization Protection Features and Request for Exemption to use ASME Code Case N-514,"

daict April 7,1997.

2. FPC to NRC letter,3F0697-23, "LTOPS Proposed Technical Specification Change Request," dated June 6,1997.

3. NRC to FPC letter, " Crystal River 3 - Exemption from Requirements of 10 CFR 50.60, Acceptance Criteria for Fracture Prevention for Lightwater Nuclear Power 9

Reactors for Normal Operation (TAC NO. M98380)," dated July 3,1997.

4. FPC to NRC letter, 3F0697-10, " Technical Specification Change Request Notice 210," dated June 14, 1997.

[l Ladies & Gentlemen:

Ib Florida Power Corporation (FPC) hereby submits Technical Specification Change Request Notice (TSCRN) 213, Revision 0, proposing an amendment to Operating License No. DPR-72 for Crystal River 3 (CR-3) to establi.sh requirements for a Low Temperature Overpressure Protection (LTOP) System as requir.d by 10CFR50.60. In References 1 and 2, FPC had E

committed to provide proposed Technical Specification changes to replace the administrative g

controls and lowered Power Operated Relief Valve (PORV) setpoint by which CR-3 is

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currently implementing required LTOP features. The proposed LTOP requirements are based E

on the CR-3 Pressure-Temperature (P/T) curves for 15 EFPY of operation whi;h are h

consistent with the requirements of 10CFR50, Appendix G. ASME Code Case N-514, " Low g*

Temperature Overpressure Protection Section XI, Division 1," has been applied in the

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preparation of the proposed LTOP requirements as approved by NRC in Reference 3.

. Attachment A provides the basis for, and a description of, the proposed TSCRN and an evaluation which concludes that the proposed Technical Specification changes do not involve a significant hazard.

Proposed Technical Specification and Bases page changes are also provided with this attachment..A set of changed pages with additions and deletions shown in strikeout or shaded font is also included.

220168CitYSTAL RIVER ENERGY COMPLEX 15760 W. Power Line Street Crystal River, Florida 34428-6708 - (352)795-6486 9707330284 970718 A Florida Progress Company PDR ADOCK 05000302 P

PDR

a U. S. Nuclear Regulatory Commission

' 3F0797-10 Page 2 of 3 Attachment B provides the FPC safety analysis for the proposed TSCRN. The analysis concludes that LTOP limits will protect the reactor vessel from overpressurization.

This LTOPS Technical Specification refers to CR-3 Technical Specification 3.5.3, "ECCS-Shutdown." As noted in TSCRN 210 (Reference 4), FPC is evaluating issues concerning decay heat removal in Mode 4 prior to restart. The evaluation includes modeling operation of HPI and LPI systems in LTOPS Mode 4 and may lead to revisions of Technical Specifications 3.4.5, 3.5.3, and 3.7.5. Any such revisions will' preserve all of the LTOP requirements of this TSCRN and will be forwarded promptly.

FPC has submitted other TSCRNs which are concurrently at the NRC for review (e.g.,

Reference 4). Although each TSCRN package has been structured to contain all necessary information for its approval, the possibility does exist for these TSCRN packages to be impacted by future Technical Specification change requests.

At this time, TSCRN 210 includes proposed changes to Technical Specification Bases Section B3.5.2, "ECCS-Operating," page B 3.5-15, as does the attached TSCRN 213.

However, the proposed changes to this bases page for LTOPS are additive to and do not affect those changes proposed with TSCRN 210. No other TSCRNs to date are affected.

As discussed with the NRC CR-3 Project Manager, FPC determined that the submittal of this TSCRN should be delayed to July 18, 1997, in order to resolve a technical issue. FPC requests that the NRC review and approve the proposed Technical Specification changes by September 18, 1997, and provide for a 30-day post-approval implementation period. This schedule will support the current restart schedule for CR-3. Under the current administrative controls for LTOP features, the reactor coolant pumps cannot be started until the proposed Technical Specification change is approved, and associated procedure changes are approved and issued.

Please call Mr. David Kunsemiller, Manager, Nuclear Licensing (352) 563-4566 regarding any questions concerning this proposed license amendment.

Sincerely,

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l A. Anderson Se for Vice President clear Operations AA/RSC/LVC Attachments:

A. Technical Specification Change Request Notice 213, Revision 0 B. FPC Calculation F97-0003, "CR-315 EFPY LTOP Limits" cc: Regional Administrator, Region II Senior Resident Inspector NRR Project Manager

i U. S. Nuclear Regulatory Commission 3F0797-10 Page 3 of 3 STATE OF FLORIDA COUNTY OF CITRUS Roy A.' Anderson states 'that he is' the Senior Vice President, Nuclear Operations for Floridc.

I Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Conunission the information attached hereto; arxl that all such statements-made and matters set forth therein are true and correct to the best of his knowledge, information, l

and belief.

j A

/

y A. Anderson

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nior Vice President I

uclear Operations Sworn to and subscribed before me this day of II/LY 1997, by Roy A. Anderson, who is personally known to me.

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Sigisture of Notary Public State of Florijla tisNE S.SWRm MY COAABBION f CC s14300 EXPNES: Decemter 18,1980 tended 71wu Natuy Punac theesmismo Stamp Commissioned Name of Notary Public

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FLORIDA POWER CORPORATION i

CRYSTAL RIVER UNIT 3 l

DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 TECHNICAL SPECIFICATION CHANGE REQUEST NOTICE 213, REVISION 0 i

ATTACHMENT A 4

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U. ' S. Nuclur Rtgulatory Commission 3F0797-10 Attachment A-Page 1 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 REQUEST NOTICE 213, REVISION O LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LICENSE DOCUMENT INVOLVED:

' Improved Technical-Specifications PORTIONS: 3.4.11[NEW]

- Low Temperature Overpressure Protection (LTOP) System 3.5.3

- ECCS-Shutdown 83.4.9

- Pressurizer Safety. Valves 83.4.11[NEW] - Low Temperature Overpressure Protection (LTOP) System B3.5.2

- ECCS-Operating B3.5.3

- ECCS-Shutdown

SUMMARY

OF CHANGES:

This proposed change to the Crystal River Unit 3 (CR-3) Improved Technical Specifications (ITS) incorporates a new Section 3.4.11 and a new Bases Section B3'.4.11 for the reactor vessel Low Temperature Overpressure Protection (LTOP)

System. These changes are being submitted in response to NRC letter to FPC dated February 4,1997, which requested that FPC submit a proposed LTOP Technical Specification to replace the administrative controls currently used to implement LTOP features. This proposed LTOP Technical Specification has been prepared applying ASME Code Case N-514 " Low Temperature Overpressure Protection Section XI, Division 1," and consistent with the recommendations-in NRC Generic Letter 88-11,' "NRC Pcsition on Radiation Embrittlement of Reactor Vessel Materials and Its Impact on Plant Operations." The balance of the proposed Technical Specification changes including, Section 3.5.3 and Bases Sections 83.4.9, B3.5.2,

.and B3.5.3, have been modified to provide reference to, and consistency with, the proposed new LTOPS Technical Specification.

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CHANGE TO SPECIFICATION 3.4.11 There is currently no LTOPS Technical Specification in the CR-3 ITS. There is an ITS Section 3.4.11 identified in the CR-3 ITS as "Not Used." This change adds a new' specification for the Reactor Coolant System for LTOP to the CR-3 Improved Technical Specifications as Section 3.4.11.

The change is modeled after the standard LTOP specification in NUREG-1430, Revision 1, Improved Technical Specifications for Gabcock and Wilcox (B&W) plants.

Description of Specification Change Since there is no current LTOPS Technical Specification in the CR-3 Improved Technical Specifications, this proposed change adds a new specification, 3.4.11 and associated ITS Bases, modeled after the standard technical specification for LTOPS published by the BWOG in NUREG-1430, Revision 1, Improved Technical Specifications for Babcock and Wilcox (B&W) plants.

The new Technical Specification establishes requirements for an LTOP System which I

shall be OPERABLE in MODE 4 when RCS temperature is s 253*F, MODE 5, and MODE 6

U. S. Nuclear R gulatory Commission 3F0797-10 Attachment A' Page 2

when the reactor vessel head is not completely detensioned. Operation of the RCS in LTOPS condition includes the following limitations; a maximum of one Makeup pump capable of injecting into the RCS, High Pressure Injection (HPI) deactivated, the Core Flood Tanks (CFT) isolated, limiting Pressurizer water level to s 160 inches, and an OPERABLE Power Operated Relief Valve (PORV) with a lift setpoint of s 464 psig. Action statements are provided for individual inoperable components or features, as well as for a condition in which the LTOPS safety function is lost (e.g., Pressurizer water level > 160 inches and the PORV is inoperable, oc; with the LTOPS inoperable for any reason other than for the listed conditions for which there are acceptable required action statements that can be met), in which case the RCS must be depressurized and a RCS vent 2 0.75 square inch established in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

None of the LTOP limits / values listed in the new LTOPS Technical Specification are adjusted for instrument uncertainty and will therefore not be used for plant operations. This fact has been noted by the statement, " uncorrected for instrument uncertainty" within this change request where applicable. The LTOP limits / values used for plant operations will be adjusted for instrument uncertainty and placed in the plant operating procedures.

Surveillance Requirements are specified with frequencies which have been shown by operating experience at other facilities and industry accepted practice to be sufficient to regularly assess conditions for potential degradation of components and to verify operation within the requirements discussed above.

The new LTOPS Technical Specification for CR-3 is consistent with the standard technical specification for LTOP referenced above, and includes changes for plant specific details which are not considered to be safety significant. These changes are discussed below.

With regard to RCS temperature measurement, CR-3 takes the measurement from a cold leg with Reactor Coolant Pumps (RCP) operating and from the decay heat outlet when no RCPs are operating. With the CR-3 reactor vessel head completely detensioned (i.e., the pre-stress relieved from all the studs, and the nuts free spinning), overpressurization is not possible. Therefore, LTOPS applicability l

includes Mode 6 without the reactor vessel head completely detensioned.

j LTOPS LCO 3.4.11, Condition F; inability to restore pressurizer level to s 160 inches, includes two additional required actions, F.1.1 and F.1.2, which are l

implemented to depressurize the RCS to s 214 psig and maintain the Pressurizer level to s 245 inches. Analysis shows that with a RCS pressure of 214 psig, the i

I pressurizer level can be increased to 245 inches and still prmfide 10 minutes for operator action during the limiting stuck full-open Makeup valve transient.

1 Surveillances are included to ensure LTOP System component operability whenever j

entering an RCS temperature condition requiring low temperature overpressure protection of the RCS. Two LTOPS surveillance frequency requirements have been revised, and a new surveillance has been added to verify PORV operability.

CR-3 RCS vents may be other than valves (e.g., a OTSG manway cover, or a handhole cover), and therefore, surveillance frequency requirements for RCS vents have been appropriately clarified to be for vent openings rather than for vent valves.

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To preclude operation with an inoperable PORV, the PORV channel functional test frequency is specified to be accomplished within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before or after j

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U. S. Nuclear Regulatory Commission 3F0797-10 Attachment A

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entering the LTOPS Technical Specification at RCS temperature of 253'F.

Pre-planning and implementing this PORV surveillance prior to entering LTOPS l

conditions verifies the PORV setpoint is proper for LTOP before being constrained

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to complete this task within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This is considered more conservative than the standard specification.

Finally, a new surveillance requirement is added to j

-verify that the-PORV is selected to the low range setpoint for LTOP. The CR-3 PORV has a mode selector switch for open, closed, high range and low range.

1 Description of Bases Chance The new Technical Specification BASES provides Background information to explain how the LTOP System protects the. RCS from overpressurization and the reactor vessel from brittle fracture. The purpose of the LTOP System is to ensure an adequate pressure relief capacity und a minimum coolant addition capability in applicable plant Modes. The Background information emphasizes the PORV and RCS Vent requirements to meet the purpose of the LTOPS design.

The BASES Applicable Safety Analyses section summarizes how the calculated results of the analyses demonstrate that the reactor vessel can be adequately protected from overpressurization transients during shutdown. The Safety

. Analyses section emphasizes results which show, for the most limiting transient, that with the LTOP limits established by the analyses and the performance of the PORV, Pressurizer level, and an established RCS vent, the RCS is protected from exceeding P/T limits.

Finally, this section states that any change to RCS j

operation or design must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits.

The balance of the BASES discussion provides clarification of the LTOPS Technical Specification regarding the LTOP LCO acceptance limits, the Applicability of the LCO (LTOP Modes), the anticipated Conditions and their acceptable corrective actions, and the performance of the specified Surveillance Requirements. Much of this detail is discussed in the Description of Specification Change above and the j

Evaluation of Request below for the LTOPS Technical Specification.

i Reason For Reauest This proposed change to the CR-3 ITS fulfills FPC commitments as stated in FPC letters 3F0497-05, dated April 7,1997, and 3F0697-23, dated June 6, 1997, to submit a Technical Specification Change Request for LTOP features applying ASME Code Case N-514, and consistent with the recommendations in NRC Generic Letter 88-11.

CR-3 is currently in MODE 5, with the reactor pressure vessel (RPV) head fully tensioned. CR-3 is currently implementing LTOP features through administrative controls and a reduced PORV setpoint until a Technical Specification change request for LTOP features is submitted and approved by the NRC.

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U. S. Nuclear Rtgulatory Commission 3F0797-10 Attachment A Page 4 FPC's current procedures contain the following limits and precautions related to LTOPS:

1. Pressurizer level is s 220 inches to maintain a compressible volume to accommodate a water level surge.

2. Both trains of High Pressure Injection (HPI) valves are closed and breakers secured in the lock / reset position to prevent inadvertent HPI into the RCS.

3. The PORV is operable with a low setpoint to maintain RCS pressure below the LTOP limit curves. A lower PORV setpoint of 454 psig based on the NRC approved 15 EFPY pressure-temperature (P/T) curves for Crystal River 3 with no reactor coolant pumps operating, and a RCS maximum pressure limit restriction of 100 psig have been implemented as confirmed by FPC letter 3F0697-23, dated June 6, 1997.

4. The Core Flood Tank (CFT) pressure is maintained within maximum allowable RCS pressure / temperature )imits when CFT isolation valves, CFV-5 and/or CFV-6, are open or these valves are required to be closed to prevent inadvertent CFT injection into the RCS.

FPC has committed to maintain these administrative controls in effect until a Technical Specification amendment with approved LTOP features that address the full range of RCS pressures is submitted, issued by NRC, and implemented at CR-3.

With the LTOP features listed above implemented, CR-3 cai not start reactor coolant pumps. This prevents a plant startup. Therefore, FPC is submitting this Technical Specification change request for LTOP features based on 15 EFPY P/T curves and use of ASME Code Case N-514 to comply with the NRC's request and to support CR-3's planned restart from the current outage in early December 1997.

Evaluation of Requ_ git This change will incorporate limits and actions into the CR-3 Improved Technical Specifications which will ensure that low temperature overpressure protection (LTOP) is provided for Crystal River Unit 3 for up to 15 EFPY of operation.

These limits are based on analyses performed in accordance with ASME Code Case N-514.

Use of this Code Case for Crystal River was requested by FPC letter 3F0497-05, dated April 7,1997, and was granted by the NRC (NRC letter to FPC dated July 3, 1997). The Code Case allows the use of 110% of the ASME Section XI, Appendix G limits on RCS pressure, when determining LTOP limits.

It also defines the LTOP enable temperature as the RTndt of the limiting material plus 50 degrees F.

The 15 EFPY pressure-temperature limits were calculated in accordance with ASME Section XI, Appendix G, as a part of the current Heatup and Cooldown P/T curve analysis for CR-3.

These curves were approved for use at CR-3 per NRC letter issuing Amendment No.133, dated February 7,1991, and were based on RTndt values calculated using RG 1.99, Rev. 2, as specified in NRC Generic Letter 88-11.

The steady state results from this analysis were used as the input for the current LTOP analyses and the 110% pressure adjustment was applied per ASME Code Case N-514.

The curve was further adjusted by applying plant characteristics due to the allowable operating pump combinations and resulting hydraulic eff ects.

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particular, since RCPs are typically started with RCS temperatures above 100 degrees F, the LTOP analysis assumed a temperature of 85 degrees F was used for

U. 5. Nuclear Rtgulatory Commission 3F0797-10 Attachment A Page 5

startup of the first and second RCP. The analysis also assumed that the third RCP would not be started prior to an RCS temperature of 2?S degrees F and the fourth pump after 253 degrees F.

The RCS temperatures assumed in the analysis are well within the actual starting temperatures allowed by procedures. The results of this analysis are discussed in Attachment B, FPC Calculation F97-0003, (See Reference 3 of the new LTOPS Technical Specification Bases B3.4.11).

Based on the LTOP analyses, the enable temperature for CR-3 is 253 degrees F (uncorrected for instrument uncertainty).

Below this temperature, the LTOP limits will be implemented. These limits are based on protecting the reactor vessel from overpressurization due to an RCS transient.

Several transients were evaluated for CR-3 (See LTOP ITS Bases B3.4.11, Reference 5, B&W (FTI) Document 51-1176431-01; Section 5.0).

This analysis report was earlier submitted to the NRC by FPC letter 3F1089-23, dated October 31, 1989, to support CR-3 Technical Specification Change Request No.174. The transient evaluations in Section 5.0 of this report are app'Nable to and support the bases for this change request.

If a condition is identified in which the RCS response to a transient would not allow at least 10 minutes for operator action, equipment is deactivated to preclude this transient from occurring. Of the remaining transients that could not be precluded by deactivations, the most limiting transient for CR-3 is a stuck full-open Makeup valve with one Makeup pump operating. The time available to mitigate this most limiting transient is determined by the makeup flow into the RCS and the initial RCS Pressurizer level.

Inadvertent HPI injection and Core Flood Tank discharge into the RCS are the transients which were evaluated as requiring deactivation of equipment to preclude RCS overpressurization. Actions have been included to ensure that, under required conditions, all but one HPI pump (i.e., one Makeup pump) is made inoperable, that flow through the HPI injection valves is blocked, and that the CFTs are isolated or operated below the LTOP limits. With these controls in place, adequate protection from these transients exists.

In the unlikely event a small break LOCA does occur subsequent to the High Pressure Injection (HPI) deactivation required for LTOPS, HPI can be restored by operator action. An engineering evaluation is being prepared by FPC in order to determine the decay heat removal requirements of the ECCS in Mode 4 (See TSCRN 210 submittal to the NRC by FPC letter 3F0697-10, dated June 14, 1997). This evaluation includes modeling operation of HPI and LPI systems in LTOPS Mode 4 and may lead to revisions of Technical Specification 3.5.3, "ECCS-Shutdown," or 3.7.5, " Emergency Feedwater (EFW) System." Any such revisions will preserve all of the LTOP requirements of this TSCRN.

The Pressurizer level upper limit for LTOP is determined by the requirement to provide 10 minutes for operator action during an RCS transient with the PORV inoperable. The limiting transient analyzed for CR-3 is a stuck full-open Makeup valve with one Makeup pump operating. The starting points for this transient are the maximum pressures and temperatures allowed by the PTLR or PORV operating limits. The ending point of the transient after 10 minutes must be below the LTOP limits as analyzed per Code Case N-514.

An initial Pressurizer water level of no greater than 160 inches (uncorrected for instrument uncertainty) ensures that the operators have at least 10 minutes to mitigate the transient before the LTOP limits are exceeded. Additional analyses have been performed for RCS pressures below the maximums allowed by the PTLR. At these lower RCS pressures,

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U. S. Nuclear Regulatory Commission 3F0797-10 Attachment A Page 6

the pressurizer level can be increased while maintaining the 10-minute window for operator action. The analyses show that at a RCS pressure of 214 psig, the pressurizer level can be as high as 245 inches and still provide 10 minutes for operator action with makeup flow through a stuck full-open makeup valve.

As an LTOP safety factor, Pressurizer water level has been analyzed and will be lowered based on the acceptable criteria discussed above to provide a compressible vapor space that can accommodate a coolant insurge and prevent a rapid pressure increase to the RCS due to uncontrolled mass addition. Although the lower water level reduces the operators abilities to maneuver during cooldown, heatup, or any anticipated operational occurrence through the LTOP modes, they have enough margin to accomplish the actions needed to control these occurrences without violating LCO 3.4.3, "RCS Pressure and Temperature (P/T)

Limits."

In addition to deactivating equipment and limiting the Pressurizer level, the PORV low pressure setpoint is set to open at or below the minimum RCS pressure determined by the LTOP analysis. The RCS pressure at this point is 464 psig (uncorrected for instrument uncertainty). The relief capacity of the PORV was also analyzed and determined to be greater at this pressure than the makeup flow resulting from the stuck open Makeup valve transient. Thus, the PORV can provide the required protection at low temperatures.

If the PORV is inoperable due to the PORV itself or due to the block valve, additional controls are implemented to limit the capability to overpressurize the RCS. Analysis has determined that a Makeup tank level of no greater than 88 inches (uncorrected for instrument uncertainty) limits the available water inventory below what is needed to exceed the LTOP limits.

In these cases, the Makeup tank which is the suction source for the Makeup pump will be controlled to maintain this limit.

If the PORV is inoperable when LTOP is applicable (due to the PORV block valve being closed and deenergized per the PORV ITS LCO 3.4.10), it can be made operable by reenergizing and opening the PORV block valve at this time.

Should the PORV block valve not open at this time of lower RCS temperature due to thermal binding, the PORV would remain inoperable for LTOP. The required actions for an inoperable PORV in LTOP are to reduce Makeup tank level and to deactivate the low low Makeup tank level interlock to the borated water storage tank, thereby minimizing coolant addition capability to preclude overpressuring the RCS. This is an acceptable limitation for LTOP.

Action statements for each LCO provide allowable times to implement the actions and controls described above. These times range from immediately to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The times are based on operational and industry experience and regulatory recommendations. The times are intended to balance the time necessary to accomplish the actions and the likelihood of experiencing a limiting transient during the action.

If for any reason, the LTOP controls described above cannot be implemented within the times specified after RCS temperature is reduced below 253'F, the RCS will be depressurized and a vent established such that overpressurization cannot occur.

When a vent is established under these conditions, controls will be implemented such as, locking or deactivating power to the component. A minimum vent size of 0.75 square inch has been specified. The relief capacity of this vent was also analyzed and determined to be greater at the limiting LTOP pressure than the

U. S. Nuclear Regulatory Commission 3F0797-10 Attachment A Page 7

makeup flow resulting from the stuck open Makeup valve transient. Thus the vent can provide the required protection at low temperatures.

Surveillance Requirements with frequencies which have been shown by operating experience and industry accepted practice to be sufficient to regularly assess conditions for potential degradation of components and to verify operation within the requirements discussed above, are specified in the LTOP Technical Specification to ensure that LTOP limits are set and that the equipment required to support LTOP safety factors is available.

Overall, these new requirements provide a level of protection greater than or equivalent to the existing administratively controlled LTOP features.

Based on the discussions provided above, FPC concludes that the new LTOP Technical Specifications being submitted provide assurance that controls are being implemented which are consistent with ASME Code Case N-514 and the recommendations of NRC Generic Letter 88-11, and provide for continued safe operation of CR-3.

2.

CHANGE TO SPECIFICATION 3.5.3 Description of Specification and Bases Chanael CR-3 ITS Section 3.5.3 [LCO 3.5.3] for ECCS operability in plant Shutdown includes a Note that High Pressure injection (HPI) may be deactivated in accordance with LTOP administrative controls. This editorial change references that LTOP administrative controls are now requirements of Technical Specification LCO 3.4.11," Low Temperature Overpressure Protection (LTOP) System."

CR-3 ITS Bases Section B3.5.3 for ECCS operability in plant Shutdown includes references to the Note with LCO 3.5.3 that states High Pressure Injection (HPI) may be deactivated in accordance with LTOP administrative controls. These editorial changes reference that LTOP administrative controls are now requirements of Technical Specification LCO 3.4.11, " Low Temperature Overpressure Protection (LTOP) System."

i Reason / Evaluation of Reauest I

A new Technical Specification Section 3.4.11. " Low Temperature Overpressure l

Protection (LTOP) System," is proposed to replace the provisions for overpressure protection which are currently implemented by LTOP administrative controls. This new specification includes the LCO to deactivate HPI. Therefore, LCO 3.4.11 1

should now be referenced as the provision for overpressure protection as it j

applies to HPI deactivation.

3 These editorial changes reference the new Technical Specification LCO 3.4.11 and deactivation of HPI for LTOPS.

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CHANGE TO SPECIFICATION BASES B3.4.9 Description of Bases Chance CR-3 ITS Bases Section B3.4.9 for Pressurizer Safety Valves includes references

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to LTOP administrative controls. These editorial changes reference that LTOP

U. S. Nuclear R:gulatory Commission 3F0797-10 Attachment A Page 8

administrative control.. are now requirements of Technical Specification LCO 3.4.11. " Low Temperature Overpressure Protection (LTOP) System."

Heason/ Evaluation of Reauest A new Technical Specification Section 3.4.11, " Low Temperature Overpressure i

Protection (LTOP) System," is proposed to replace the provisions for overpressure protection which are currently implemented by LTOP administrative controls.

Since LCO 3.4.11 includes the requirements for LTOP, this LCO is now proposed as the provision for overpressure protection.

These editorial changes reference the new LTOP Technical Specification LCO 3.4.11 regarding how overpressure protection is provided.

4.

CHANGE TO SPECIFICATION BASES B3.5.2 Description of Bases Chance CR-3 ITS Bases Section B3.5.2 for ECCS operability while the plant is Operating includes references to the currently implemented LTOP administrative controls.

These references to LTOP discuss operability of HPI in Modes 1, 2, and 3 uader conditions required by the current LTOP administrative controls. The changes to Bases Section B3.5.2 remove all reference to HPI deactivation required at RCS temperature s 2839: for the currently implemented LTOP administrative controls.

Although TSCRN 210 (FPC letter 3F0697-10, dated June 14, 1997) includes proposed changes to Bases Section B3.5.2, page B 3.5-15, as does this submittal, the proposed changes to this bases page for the LTOPS do not impact those changes proposed with TSCRN 210.

Reason / Evaluation of Reauest A new Technical Specification Section 3.4.11, " Low Temperature Overpressure Protection (LTOP) System," is proposed to replace the provisions for overpressure protection whica are currently implemented by LTOP administrative controls.

This new specification includes the LCO 3.4.11 requirements to deactivate HPI and to limit Makeup for LTOP during plant shutdown beginning in Mode 4 when RCS temperature is s 253'F.

ITS Section B3.5.2 discusses the bases for Technical Specification 3.5.2, "ECCS-Operating," and its limiting conditions of operation which are applicable in plant Modes 1, 2, and 3 only. The new proposed LTOP requirements are not applicable in Modes 1, 2, and 3.

The currently implemented LTOP administrative controls require HPI to be i

deactivated at RCS temperatures s 283'F.

Mode 4 plant operation (Hot Shutdown) is l

defined by the CR-3 ITS as beginning when the average RCS temperature is < 280"F.

Therefore, current LTOP administrative controls require HPI to be deactivated while the plant is in Hot Standby Mode 3 for a period of time while the RCS temperature is in the range of 283'F to 2809:. Thus, the reason for LTOP references presently in ITS Bases Section B3.5.2 is concluded. Since the proposed LTOPS Technical Specification 3.4.11 will require HPI deactivation in Mode 4 when RCS temperature is s 253'F, there is no time within Mode 3 when HPI is deactivated, and therefore, references to LTOP in Bases Section B3.5.2 may be removed.

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S.~ Nuclear Regulatory Commission 3F0797-10 Attachment A

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This proposed change to the Crystal River Unit 3 (CR-3) Improved Technical

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Specifications _ incorporates a new section 3.4.11 for reactor vessel Low Temperature Overpressure Protection (LTOP). An evaluation of the proposed change j

has been performed in accordance with 10CFR50.91(a)(1) regarding no significant hazards considerations using the standards in 10CFR50.92(c). A discussion of these standards as they-relate to this amendment request follows:

.i 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated -

This change does ng_t involve a significant increase in the probability or

- consequences of any accident previously evaluated.

i There are currently no LTOP requirements in the CR-3 Improved Technical j

Specifications. CR-3 currently implements LTOP features through administrative controls and a lowered PORV setpoint. The proposed change will establish new LTOP technical specification requirements necessary to preclude an LTOP event from occurring. The proposed LTOP requirements are based on safety analyses that i

apply ASME Code Case N-514.

These requirements will decrease the probability of i

a low temperature overpressure event by providing protection for all pressure and i

temperature combinations for which a low temperature overpressure event may be postulated.

The consequences of a low temperature overpressure accident are not affected by this change. There is no change to the 10CFR Part 100 dose calculation for a low temperature overpressure accident.

2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated This change does no.1 create the possibility of a new or different kind of accident from any previously evaluated.

The new LTOP Technical Specification does not require modification to the plant nor does it create a new mode of plant operation. The LTOP system adds no new accident initiators.

3 - Does Not Involve a Significant Reduction in the Margin of Safety The proposed change does no_t involve a significant reduction in the margin of safety and will provide added safety benefit gained through the requirements to preclude a low temperature overpressurization event to the RCS.

The margin of safety prior to having an LTOP system was limited due to the informal, administrative method of minimizing the impact of a low temperature overpressure accident.

By formalizing these requirements into a technical specification, at the least, margin of safety is retained and perhaps improved due to the elevated significance of required actions.

Therefore, based upon the reasoning presented above and the previous discussion of the amendment request, FPC has determined that the requested change does nnt involve a-significant hazard.

U. 5. Nuclear Regulatory Commission 3F0797-10 Attachment A Page 10 ENVIRONMENTAL IMPACT EVALUATION 10CFR51.22(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 I

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.

FPC has reviewed this license amendment and concludes that it meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9).

Pursuant to 10CFR51.22(c), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the proposed Technical Specification changes. The basis for this determination is as follows:

1. The proposed Technical Specification changes do not involve a significant hazard as described previously in the No Significant Hazards Evaluation.

2. The proposed Technical Specification changes do 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 Technical Specification changes do not introduce any new equipment nor do they require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The changes ensure that the consequences of previously evaluated accidents will not be increased.

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 these changes do not involve irreversible environmental consequences beyond those already associated with normal operation.

3. The proposed Technical Specification changes do not increase individual or cumulative radiation exposure beyond that already associated with normal operation.

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