3F0797-21, TS Change Request 209,Rev 1 for License DPR-72,adding EDG Kilowatt Indication to post-accident Monitoring Instrumentation to Support CR-3 Restart Issue of EDG Load Mgt

TS Change Request 209,Rev 1 for License DPR-72,adding EDG Kilowatt Indication to post-accident Monitoring Instrumentation to Support CR-3 Restart Issue of EDG Load Mgt

ML20196J135
Person / Time
Site:	Crystal River
Issue date:	07/29/1997
From:	Andersen R FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196J141	List: 3F0797-21, TS Change Request 209,Rev 1 for License DPR-72,adding EDG Kilowatt Indication to post-accident Monitoring Instrumentation to Support CR-3 Restart Issue of EDG Load Mgt ML20196J143
References
3F0797-21, 3F797-21, NUDOCS 9708040009
Download: ML20196J135 (9)

Text

Florida Power COMPORATION (tyetal Rhrer Urdt 3 Docket No. 50 302 July 29,1997 3F0797-21 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 I

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Subject:

Technical Specification Change Request No. 209, Revision 1 Post-Accident Monitoring Instrumentation k

Reference:

1.

FPC to NRC letter,3F0996-05, dated September 27,1996 2.

FPC to NRC letter,3F0796-03, dated July 8,1996

Dear Sir:

By Reference 1, Florida Power Corporation (FPC) submitted Technical Specification Change Request No. (TSCRN) 209, Revision O. This was done in response to Reference 2, in which FPC committed to submit, by October 1,1996: (a) the conclusions of an evaluation of alternatives to permanently modify the Crystal River Unit 3 (CR-3) subcooling margin monitors, and (b) a technical specification change request to add subcooling margin and decay heat removal (Iow pressure injection) flow to the post-accident monitoring (PAM) instrumentation technical specification. In addition, two other changes were proposed to correct the nomenclature in the PAM technical specification. To properly implement emergency diesel generator load management, proposed in FPC submittal TSCRN 210 dated 6/14/97, FPC proposes to add emergency diesel generator kilowatt indication to the PAM instrumentation. These changes are submitted at this time because they are needed to support the CR-3 restart issue of emergency diesel generator load management.

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FPC hereby submits TSCRN 209, Revision 1, requesting an amendment to Operating Esii License No. DPR-72 for revisions to CR-3 technical specifications. The proposed I,,

technical specification revisions in strikeout and highlight font are provided as E!B.

Attachment D, and in final revision bar format in Attachment E.

This Revision 1 E!!E.

supersedes Revision 0 in its entirety. FPC considers these changes to be plant-specific hII rather than generic changes applicable to all Babcock and Wilcox-designed Nuclear Steam Supply plants. Revision 1 proposes the following changes to the CR-3 post-accident monitoring instrumentation technical specification LCO 3.3.17, Table 3.3.17-1:

YSTAL NER E COMPLEX

• 15760 W. Power une Street

• Cryetal River

• Floride 34428-6708 * (352)795-6486 hDR D

0500 02 P

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i U.S. Nucl:ar R:gul: tory Commission 3F0797-21 Page 2 of 4 (Note: Items A through D were submitted by TSCRN 209, Revision O. Item E is a new change submitted by this Revision 1).

A.

A revision to the descriptor for the narrow range containment pressure function.

The descriptor change will eliminate confusion with the instruments used to monitor containment pressure during normal operation which have a range narrower than the instruments controlled by this specification.

B.

A revision to the required channels for the core exit temperature function. The revised requirement presents a more logical relationship to the installed configuration than the existing requirement.

C.

The addition of low pressure injection (LPI) flow to the LCO. This variable has been reclassified as Type A per Regulatory Guide (RG) 1.97, requiring it to be added to the PAM LCO in accordance with our commitment to improved technical i

specifications. Reference 2 describes our commitment to upgrade the recording capability of the low pressure injection flow instrumentation no later than Refuel 11, currently scheduled for the fall of 1999. This modification work will be performed during the current outage, ahead cf FPC's original commitment.

D.

The addition of degrees of subcooling to the LCO. This variable has also been reclassified as Type A per RG 1.97, requiring it to be added to the PAM LCO. As discussed in the referenced letter, the current design of the instrumentation used to measure degrees of subcooling (subcooling margin) does not meet all of the recommended criteria of RG 1.97 for Category 1 instrumentation. FPC commits to enhance this design to meet most, but still not all RG 1.97, Category 1 criteria during Refuel 11. A description of the design attributes of this instrumentation and a comparison of these attributes against the RG 1.97 recommendations is provided for NRC review and approval as Attachment F to this submittal. This attachment also includes justification for those areas where the recommendations of RG 1.97 are not fully met for this instrumentation.

E.

The addition of Emergency Diesel Generator kW Indication to the LCO. This variable has been recently reclassified as Type A per RG 1.97, requiring it to be added to the PAM LCO. These kW meters are used by operators to monitor load and perform load management on the EDGs during post-LOCA conditions.

Revised BASES pages are also included.

To assist NRC review, FPC is providing in this submittal an evaluation of compliance with Regulatory Guide 1.97 for the instrumentation being added to Table 3.3.17-1.

These evaluations are provided as Attachment F for the subcooling margin monitors, Attachment G for the LPI flow instruments, and Attachment H for the EDG kW meters.

The NRC review of TSCRN 209, Revision 0, had resulted in a request for information which was discussed by telephone conference on December 10,1996. The FPC response to that request is provided as Attachment I to this submittal.

l U.S. Nuclear Regulatory Commission 3F0797-21 Page 3 of 4 l

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FPC requests NRC approval of this request for license amendment by October 22, l

1997, with a 30-day implementation period.

l A review of emergency operating procedures (EOPs) to ensure that operating l

parameters are properly classified in accordance with Regulatory Guide 1.97 is ongoing i

at CR-3 as a separate activity. Potential changes to the technical specifications related to post-accident monitoring instrumentation may be required when the EOPs are finalized in the October,1997 timeframe. Changes to the instrumentation list may require the addition of instrumentation surveillance requirements to the Technical Specifications which are currently managed as part of CR-3 Surveillance Procedures.

These changes are not required to support CR-3 start up and will be dealt with on a I

routine basis during operation.

if you have any questions regarding this submittal or the schedule, please contact Dave i

l Kunsemiller at (352) 563-4566.

l Sincerely, 1

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R A. Anderson nior Vice President uclear Operations i

RAA:rer xc: Regional Administrator, Region ll Seriior Resident inspector NRR Project Manager

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Attachments:

A.

List of Commitments B.

Description of Changes, Reason for Request, and Evaluation of Request C.

Determination of No Significant Hazards Consideration Pursuant to 10 CFR 50.92 D.

Proposed Technical Specifications and Bases Changes: Strikeout / Highlight l

E.

Proposed Technical Specifications and Bases Changes: Revision Bars F.

Evaluation of Safety Parameter Display System Against Design Criteria of Regulatory Guide 1.97 For Subcooling Margin Monitor G.

Evaluation of Low Pressure injection Flow Instrumentation Against Design Criteria of Regulatory Guide 1.97 H.

Evaluation of Emergency Diesel Generator kilowatt Meters Against Design Criteria of 1

Regulatory Guide 1.97 l

1.

Response to NRC Request for information FPC - NRC Telephone Conference of December 10,1996

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U.S. Nucl::r R:gulatory Commi sion 3F0797-21 l

Page 4 of 4 l

STATE OF FLORIDA COUNTY OF CITRUS Roy A. Anderson states that he is the Senior Vice President, Nuclear Operations 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, information, and belief.

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Rgt A. Anderson S6nior Vice President huclear Operations Sworn to and subscribed before me this o?Uday of Jak

.1997, l

V by Roy A. Anderson.

[/5t&f/6nt /SYkst Signature of Notary Public State of Florida

• ""s?4J'Ja"ac^

' "a:CY"

• BONDEDTHRtI AsA1888 NOTARY 1 (Print, type, or stamp Commissioned Name of Notary Public) i Personally /

-OR-Produced Known identification l

l U.S. Nuclear Regulatory Commission Attachment A 3F0797-21 Page 1 of 1 ATTACHMENT A LIST OF REGULATORY COMMITMENTS The following list identifies those actions committed to by Florida Power Corporation in this document. Any other actions discussed in the submittal represents intended or planned actions by Florida Power Corporation. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager, Nuclear Licensing of any questions r Jarding this document or any associated regulatory commitments.

l Item nos.1 and 2 are new commitments made in this document. Item nos. 3 through 8 were l

previously committed to in FPC letters 3F0796-03 and 3F0996-05 (TSCRN 210, Revision 0).

Item no. 3 was previously identified to be done no later than cycle 11 refuel outage but will be done during the current outage. Item nos. 5,6, and 7 are the enhancements to the SPDS related to subcooling margin monitors.

1.

FPC will install a modification to add inputs from Emergency Diesel Generator kilowatt indication to the Recall /SPDS computer to provide the recording function. This will be done before restart from the current outage.

2.

Both of the indicators used for EDG load indication which are credited as C3tegory 1 will be labeled on the main control board so the operator can easily discem ti.at they are Regulatory Guide 1.97 qualified instruments. This will be done before restart from current outage.

3.

FPC will install a modification to add inputs to the Recall /SPDS computer to provide the recording function required for compliance with Regulatory Guide 1.97, Revision 3, Criterion 6, " Display and Recording", for Low Pressure injection flow. This will be done before restart from the current outage.

4.

The SPDS displays will be labeled as Regulatory Guide 1.97 instruments on the main control board. This will be done during the cycle 11 refuel outage.

5.

Modify the power supply for the SPDS to separate it into a train "A" and train "B" redundant system, powered from safety related inverters which are backed up by the station standby power sources, i.e. diesel generators. This will be done during cycle 11 refuel outage.

6.

A redundant "B" side narrow range pressure signal will be provided to both trains of the subcooling margin monitor. This will be done during cycle 11 refuel outage.

7.

The major componenit necessary for the operation of SPDS will be physically restrained to prevent motion and minimize the probability of damage during a seismic event. This will be done during cycle 1*. refuel outage.

8.

Operators will be trained to use the SPDS displays as the primary means of determining l

subcooling margin. This will be done during cycle 11 refuel outage.

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l U.S. Nuclear Regulatory Commission Attachment B 3F0797-21 Page 1 of 2 ATTACHMENT B DESCRIPTION OF CHANGES, REASON FOR REQUEST, AND EVALUATION OF REQUEST LICENSEE DOCUMENT INVOLVED: Technical Specifications PORTIONS: Limiting Condition for Operation 3.3.17, Post-Accident Monitoring Instrumentation DESCRIPTION OF CHANGES:

A.

Table 3.3.17-1, Function 8: The descriptor is changed from " Containment Pressure (Narrow Range)" to " Containment Presstsa (Expected Post-Accident Range)."

8.

Table 3.3.17-1, Function 18: The required channels for Core Exit Temperature (Backup) is changed from "2 sets of 5" to "3 per core quadrant."

C.

Table 3.3.17-1: A new Function 20 is added and designated as " Low Pressure injection Flow", with 2 required channels, and Condition E.

D.

Table 3.3.17-1: A new Function 21 is added and designated as " Degrees of Subcooling",

with 2 required channels, and Condition E.

E.

Table 3.3.17-1: A new Function 22 is added and designated as " Emergency Diesel Generator kW Indication", with 2 required channels, and Condition E. A note clarifying the number of required channels is added:"(c): one indicator per EDG".

REASON FOR REQUEST:

A.

The change in the containment pressure descriptor is to eliminate confusion between the -

10 to +70 psig instrument used for this LCO and the -5 to +5 psig instrument used to verify compliance with LCO 3.6.4, Containment Pressure.

B.

The required channels for the core exit temperature function are being changed to provide j

a more logical minimum subset of detectors.

C/D/E.

The low pressure injection flow, degrees of subcooling, and EDG kW indication functions are being added because they have been identified as being used at Crystal River 3 (CR-

3) in a manner that requires they be considered " Type A" per the criteria of Regulatory j

Guide 1.97. All Regulatory Guide 1.97 Type A functions are category 1 instruments and all category 1 instruments are included in Table 3.3.17-1.

EVALUATION OF REQUEST:

A.

CR-3 has three ranges of containment preseure monitoring instrumentation. The narrowest range instrument (-5 to +5 psig) is usa.: to verify compliance with LCO 3.6 4, but is not used for post-accident monitoring. It k., therefore, not considered a Regulator y Guide 1.97 instrument and is not included in T, ole 3.3.17-1. The mid-range instrumen's (-10 to 70

U.S. Nuclear Regulatory Commission Attachment B 3F0797-21 Page 2 of 2 psig) cover the expected post-accident containment pressure range for design basis accidents. These instruments are covered by Table 3.3.17-1, Function 8, and are currently designated as " narrow range," although they are not the narrowest range instruments available to the operators. The wide range instruments (0 to 200 psig) cover the range of containment pressure that might be expected following an accident more severe than that required to be postulated by the CR-3 design basis. These instruments are covered by Table 3.3.17-1, Function 9. None of the installed plant instrumentation for containment pressure included in Table 3.3.17-1 is being changed as a result of this descriptor change.

The change simply allows the use of the term " narrow range" to be applied solely to the narrowest range of containment pressure instrumentation.

B.

The recorders that provide the indication of core exit temperature for Table 3.3.17-1 receive 16 thermocouple inputs, four from each quadrant of the reactor core. Adding the requirement that three instruments in each quadrant be OPERABLE provides better assurance that a representative distribution of temperatures across the core will be available to the operator for monitoring post-accident conditions.

C/D/E.

Low pressure injection flow, degrees of subcooling and Emergency Diesel Generator kilowatt (kW) indication are being added to Table 3.3.17-1 because these functions have been determined to be Type A per Regulatory Guide 1.97. Low pressure injection flow must be manually throttled prior to switching from the borated water storage tank to the containment sump in order to prevent loss of net positive suction head (NPSH). Degrees of subcooling is used as a criterion for manual initiation of high pressure injection, tripping of reactor coolant pumps and selection of the steam generator high level setpoint on the Emergency Feedwater Initiation and Control System during loss of coolant accidents (LOCA's). Indication of kWload on the Emergency Diesel Generators (EDG) is used for load management as part of post-accident rr.itigation, i.e. to determine whether it is permissible to add loads to the EDG or ifloads need to be removed before adding others.

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U.S. Nuclear Regulatory Commission Attachment C 3F0797-21 Page 1 of 2 l

ATTACHMENT C DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION l

l PURSUANT TO 10 CFR 50.92 Florida Power Corporation (FPC) has reviewed the requirements of 10 CFR 50.92(c) as they I

relate to the proposed revisions to Technical Specification 3.3.17 (Post-Accident Monitoring Instrumentation), Table 3.3.17-1 and considers the proposed changes do not involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1.

The proposed changes will not significantly increase the probability or consequences of an accident previously evaluated because-I l

A/B. The changes in containment pressure and core exit thermocouple nomenclature do

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not reflect any physical changes to the facility. This would have no impact on accident probability or consequences.

C/D/E.

The addition of low pressure injection flow, degrees of subcooling, and EDG kW l

indication to the Post-Accident Monitoring Instrumentation LCO is being done to comply with a commitment made during the technical specification improvement l

program to include in the technical specifications that instrumentation which monitors variables classified as Type A in accordance with Regulatory Guide 1.97. These three variables have been reclassified as Type A. The associated instruments are used in post-accident conditions to prompt the operators to take certain mitigative actions. Therefore, the probability of an accident occurring is unaffected. As part of the re-classification of these variables to Type A and inclusion in technical specifications, the associated monitoring instrumentation will be under more strict surveillance and control, which provides additional assurance that the prescribed manual operator actions will be implemented when necessary. This, in turn, assures the previously evaluated accident consequences remain valid.

2.

The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated because:

A/B. The changes in containment pressure and core exit thermocouple nomenclature do not reflect any physical changes to the facility. The changes provide clarification for the instruments which are required to comply with the LCO. This would not create possibility of a new or different kind of accident.

C/D/E.

The addition of low pressure injection flow, degrees of subcooling, and EDG kW indication to the Post-Accident Monitoring instrumentation LCO is being done to comply with a commitment made during the technical specification improvement program to include in the technical specifications that instrumentation which monitors variables classified as Type A in accordance with Regulatory Guide 1.97. These l

three variables have recently been reclassified as Type A.

The associated 4

l instruments are used after an accident occurs to prompt the operators to take certain mitigative actions. Since the instrumentation is used only post-accident, these changes do not create the possibility of a new or different kind of accident.

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3.

The proposed change will not involve a significant reduction to the margin of safety because:

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U.S. Nuclear Regulatory Commission Attachment C 3F0797-21 Page 2 of 2 l

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A/8. The changes in containment pressure and core exit thermocouple nomenclature have no affect on the margin of safety. The changes provide clarification of the technical specifications. This reduces the potential for confusion regarding this J

instrumentation.

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C/D/E.

The addition of low pressure injection flow, degrees of subcooling, and EDG kW l

indication to the post-accident ~ monitoring instrumentation table in technical specifications results in added controls on the OPERABILITY of this post-accident monitoring instrumentation and provides greater assurance that it will be available J

should an accident occur.

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