3F0889-10, Revised Response to Generic Ltr 88-11, NRC Position on Radiation Embrittlement of Reactor Vessel Matl & Impact on Plant Operations. Util Plans to Submit pressure-temp Curve & Low Temp Overpressure Protection Curve Together
| ML20245G920 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/14/1989 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F0889-10, 3F889-10, GL-88-11, NUDOCS 8908160255 | |
| Download: ML20245G920 (2) | |
Text
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e CORP OR AT 4 ON August 14, 1989 3F0889-10' U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.'C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Revised _ Generic-Letter 88-11 Response
Dear Sir:
The purpose of this letter is to revise Ficrida Power Corporation's (FPC) response
- to Generic Letter 88-11 "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant 0perations."
The Generic Letter requested utilities to submit the results of their tecNtical analyses regarding pressure-temperature limits and a proposed schedule for whatever actions they proposed to take.
In the response to the Letter, FPC committed to submit tpdated pressure-temperature curves for CR 3, utilizing the methodology of Regulatory Guide 1.99 Revision 2.
The proposed FPC schedule for submittal was given as-
. September 1989.
Based on the reasons discussed below, FPC is revising the scheduled submittal date to no later than October 31, 1989.
In the initial response to the NRC Staff, FPC planned to submit updated pressure-temperature curves for CR-3 based on 10CFR50 Appendix G and Regulatory Guide 1.99 Revision 2.
FPC did not anticipate the development of a non-Appendix G tow Temperature Overpressure Protection (LTOP) approach within the time frame of the
. initial submittal.
'However, during the Technical Specification Iraprovement Program (TSIP). effort, FPC identified the need to re-establish / confirm C&3's
' technical basis for LTOP.
Subsequent to. FPC's initial submittal, the Bab eck ard Wilce Owner's Group 4
(B&WOG) proposed the development of a non-Appendix C LTOP inpproach, based on the low probabilty of occurrence for this type of event. This approach was consistent i
with the NRC position in Generic letter 88-11 arc TSIP was viewed as an effectivt-r vehicle for accomplishing this. A meeting vith FPC, Bid, and the NRC on May 16, 1989 resulted its preliminary NRC concurrence with the B&W% LTOP approach.
fPC had anticipated completing the LTOP effort in time to support the September 1, 1989 TSIP submittal to the NRC, but it is now apprent that this will not occur.
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l Together,-the pressure-temperature-curves and the LTOP curve will comprise the CR-3 system for. providing reactor coolant pressure boundary (RCPB) protection l
against non-ductile failures.- The two curves provide overlapping protection of the RCPB during operation at lower temperatures'.
A complete review. of the pressure-temperature curves must include consideration of the LTOP curve as well.
For this reason,. FPC plans to submit both curves together.
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- As noted. in FPC's. initial Generic Letter 88-11 response, the most recent surveillance capsule results indicate that current 8 EFPY pressure-temperature limits (conserv tive until June 1990) will adequately protect the reactor coolant pressure boundary until the enhanced, combined submittal is made.
Sincerely, I
R. C. Widell-Director, Nuclear Operations Site support RCW/BPW xc:
Regional Aomaistrator, Region II
' Senior Resident Inspector l
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