3F0889-14, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 171,revising Tech Specs Re Listed Contents,Including Limiting Conditions for Operation, Upgraded Bases,Fsar Changes & Split Document

Application for Amend to License DPR-72,consisting of Tech Spec Change Request 171,revising Tech Specs Re Listed Contents,Including Limiting Conditions for Operation, Upgraded Bases,Fsar Changes & Split Document

ML20247B170
Person / Time
Site:	Crystal River
Issue date:	08/25/1989
From:	Wilgus W FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247B175	List: 3F0889-14, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 171,revising Tech Specs Re Listed Contents,Including Limiting Conditions for Operation, Upgraded Bases,Fsar Changes & Split Document
References
3F0889-14, 3F889-14, NUDOCS 8909120367
Download: ML20247B170 (10)

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C O R P O R ATIO N August 25,-1989 3F0889-14 U.S. Nuclear Regulatory Commission ATIN:- hv m ant Control Desk Washirgton, D.C. 20555

SUBJECT:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification 01ange Request No. 171 Technical Specification Improvement

REFERENCES:

1. L. 52FR3788,' NRC Interim Policy Statement on Technical Specification Inprovsiaiu:s for Nuclear Power Reactors, February 6, 1987.

2. NRC letter frun T.E. Marley (NRC) to W.S. Wilgus (EPC), NRC Staff Review of Nuclear Steam Supply System Verdor Owners Groups' Application of the & =n h ion's Interim Policy Statement criteria to Stardard Technical Specifications, May 9, 1988.

Dear Sir:

Florida Power Corporation (FIC) hereby subnits Technical Specification 01arge Request No. 171 requestirg siinmisit to' Appendix A of Operating License No.

DPR-72. As part of this request, the proposed replaoament pages for Appendix A are provided.

'Ihis' submittal: proposes to revise the Crystal River Unit 3 'Ibehnical Specifications using the guidance provided in References 1 and 2.

Additionally, guidance developed in the continuing dialogue between the NRC and NUMARC (to which FIC has been a principle contributor) has been utilized.

FPC's Crystal River . Unit 3 is the lead plant for Tedinical Specification Improvement for the NWk and Wilcox Owners Group.

'Ihe. Limitirg Canditions for Operations (ECOs) , Actions ard b W eillance i Requirements have been rewritten to be clear ard concise. For certain specifications, .FPC is pur=>ing to add requiu:uaius in order to achieve consistency with other specifications, safety analyses, ard plant harthrare.

FPC utilized the results of evaluations that have been reviewed and approved by 8909120367 890825 ,

FDR ADOCK 05000302 p PDC . ge_2--

POST OFFICE BOX 219

• CRYSTAL RIVER, FLORIDA 32629-0219 * (904) 795-6486 /l A Florida Progress Company g ggy,jgp g,gy-

p 3F0889-14 August 25, 1989 Page 2 1

the NRC ' in the development of these specifications. FPC also proposes technical changes that would relax requita=/w that are unduly restrictive and eliminate requita-is that are unrmw.ary or inappropriate.

The current Technical Specifications which do not meet the Selection Criteria in Reference 1 will be relocated. The principle control gocess for the ,

relocated specificaticas is an inproved implementation of 10 CFR 50.59. FPC awa+= to modify the appropriate administrative controls to address the improvements outlined in USAC-125 (Guidelines for 10 CFR 50.59 Safety Evaluations, June 1989) by mid-1990.

Technical Specification Bases have been upgraded in accordance with NRC guidance. Each IID, Required Action and Surveillance Requirement is addressed in the Bases. Additionally, each Bases has Background and Safety Analysis sections that provide general information about the system, ccmponent, or parameter addressed by the LCO, the relationship between the IID requirements and the appropriate safety analyses, and the explanation of which criterion requires it to be in the Technical Specifications.

The me.m were not developed principally frun the Crystal River Unit 3 Final Safety Analysis Report. Instead, FPC chose, as a direct parallel to the ongoirg Configuration Management Frugtam, to utilize calculations, analyses, pv -Mmes and other key developmental references to ascertain appropriate ham for the inproved Technical Specifications. As a result, this effort identified same inconsistencies between existing Technical Specification requita - is and analyses. These inconsistencies will be reported to the NRC under separate couuspurdence.

The contents of this submittal are as follows:

1. A plant-specific split docunent. This Mmont describes the application of the Selection Criteria from Reference 1 to the Crystal River Unit 3 Technical Specification. This document also summarizes the new location of existing Technical Specifications (either relocated to the Final Safety Analysis Report or retained in improved Technical Specifications). For retained Technical Specifications, a cross reference between the existire numbering and the revised numbering is provided.

2. A change request package for each individual chapter. The change request package reflects utilizing the existing license as a starting point for justifyirn revisions to the Technical Specifications. The Standard Technical Specifications were not utilized since a change request must address the charge to the license, not the departure frun a generic h= ant with no legal standing for the Crystal River Unit 3 license. The package includes:

(a) Revised IIDs, Actions arri Surveillance Requirements.

(b) Upgraded Bases.

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[ 3FC,889-14 August 25, 1989 Page 3, 1989 (c) A markup of the existing Crystal River Unit 3 Technical Specifications showing changes (including cross-reference identifiers to technical changes) .

(d) A detailed description of charges (including cross-reference identifiers to technical changes).

(e) An evaluation of technical charges. Each technical char'ge has been assigned a unique cross-reference identifier (e.g., Rx. 8, EOCS. 15, PS. 7, etc.) to help facilitate review.

(f) A pwpocsed significant hazards consideration evaluation for each technical charge (includirg cross-reference identifiers to technical changes).

3. A markup of BAW-2076 (mWk ard Wilcox Owners Group Revised Standard Technical Specifications (RSTS) showing remry plant specific changes to the generic RSTS. 'Ihis markup also provides discussions of the changes (includirg cross-reference identifiers to technical changes).

4. A copy of submitted FPC 'Ibchnical Specification Change Requests relied upon for the development of this document ard referenced in the evaluation of technical charges.

5. A summary and drafts of FSAR changes identified during the Technical Specification Improvement development process. 'Ihese charges are r - e ry to achieve consistency between the FSAR and analyses.

This submittal has been reviewed as a proposed change to Technical Specifications by the Plant Review Committee and the Nuclear General Review Committee in accordance with existing Technical Specifications sections 6.5.1. 6.c ard 6. 5.2.8.c. FPC is confident that this submittal and the efforts utilized in developirg it meet or exceed NRC needs ard expectations at this stage of the industry Technical Specification improvement process. As a result, this submittal is provided for IRC review ard acceptance.

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W.S. Wil Vice President Nuclearkper,ations I

WSW/DGG/wla Attachment xc: Regional Administrator, Region II Senior Resident Inspector

I. ; w * , 4 UNITED S'DFIS OF AMRICA NUCLEAR REGUIA'IORY OTMISSICH IN 'IHE 1% TIER )

) DOCKET NO. 50-302 FIORIDA IWER 00RFORATION )

Ut.KnnCATE OF SERVICE W.S. Wilgus deposes and says that the follcwirg has been served on the Designated State Representative and Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:

Chairman, khninistrator Board of County Camissioners Radiological Health Services of Citrus County Department of Health ard Citrus County ocurthouse Rehabilitative Services Inverness, FL 32650 1323 Winewood Blvd.

Tallahassee, FL 32301 A copy of Technical Specification Charge Request No.171 , requerting Alrealueit to Appendix A of Operatirg Licensirq No. DPR-72.

FIORIDA POWER CORPORATION f )

W W.S. Wil

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Vice President Nuclear tion SWORN 'IO AND SUBSCRIBED ist2un ME 'IHIS 25th DAY OF AUGUST 1989.

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dictary Public Notary Public, State of Florida at large My Ca:tanission Expires:

NOIARY PUBLIC, STATE OF FLORlDA AT LARGE MY COMMISSON EXP1RES DCT.19,1992 ccmoto sanovan *>toa acancy oc

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STATE OF FIDRIDA 00UlflY OF CITRUS W.S. Wilgus states that he is the Vice President, Nuclear Operations j for Florida Power Corporation; that he is authorized on the part of I said company to sigr. ard file with the Nuclear Regulatory Ocanission j l

the information attached hereto; ard that all such statements rade and matters set faith therein are true and cormct to the best of I his knowledge, information, ard belief.

W.Sf Wil ice President Nuclear ion  !

Subscribed ard sworn to befom me, a Notary Public in and for the State ard County abcree named, this 25th day of Atqust,1989.

/ Notary Public Notary Public, State of Florida at large My Commission Expires:

@TARY PUBUC. STATE OF FLORIDA AT LARCE MY CWWS;;0N lxP RES OCT.18.1992 ,

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eee Florida Power C ORPOR AT #0 N Pugust 25, 1989 3F0889-14 U.S. Nuclear Regulatory (W =innion ATIN: ,

ument Control Desk shirgton, D.C. 20555 SU3T. ECT: Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Omrge Request No.171

'Ibchnical Specification Improvement s M2LKtMCES: 1. 52FR3788, NRC Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors,

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') February 6, 1987.

2. NRC letter fran T.E. Marley (NRC) to W.S. Wilgus (FPC), IRC Staff Review of Nuclear Steam Supply System Vendor Owners Groups' Application of the ewuniecion's Interim Policy Statement criteria to Standard Technical Specifications, May 9, 1988.

Dear Sir:

Florida Power Corporation (FPC) hereby subnits Technical Specification Change Request No. 171 requesting alrr. rah.ad. to Apperrlix A of OpeLmting License No.

DPR-72. As part of this request, the proposed replacement pages for Apperriix A are provided.

'Ihis subnittal prcposes to re/ise the Crystal River Unit 3 Technical Specifications usirq the guidance provided in References 1 arri 2.

Additionally, guidance developed in the continuirq db1cque between the NRC arx3 NUMARC (to which FIC has been a principle contributor) has been utilized.

FPC's Crystal River Unit 3 is the lead plant for Technical Specification Improvement for the NWk and Wilcx:oc owners Group.

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'Ihe Limiting Conditions for Operations (IfDs), Actions and Surveillance Requirements have been rewritten to be clear arri concise. For certain specifications, FPC is proposirg to add requi m mads in order to achieve

%/,_} consistency with other specifications, safety analyses, and plant hardware. .

' V '- FIC utilized the results of evaluations that have been reviewed and approved by J POST OFFICE BOX 219 + CRYSTAL RIVER, FLORIDA 326294219 + (904) 7954486 A Florida Progrsss Company L__ _ . _ _ . _ _ _ _ __ ._-._

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. [.( . August 25, 1989 A} Page 2 the NRC in the development of these specifications. FEC also proposes technical charges that would relax requirements that are unduly restrictive and eliminate requita=(w that are unr-vry or inappropriate.

'Ibe current Technical Specifications which do not treet the Selection Criteria in Reference 1 will be relocated. h principle control sucmss for the relocated specifications is an inproved implementation of 10 CER 50.59. FPC expects to modify the appropriate administrative controls to address the improvements outlined in NSAC-125 (Guidelines for 10 CER 50.59 Safety Evaluations, June 1989) by mid-1990.

'Ibchnical Specificatico Bases have been upgraded in accordance with NRC guidance. Each IfD, Raquired Action and Surveillance 93guita-d. is addrh in the h . Additionally, each Bases has Backgrourd ard Safety Analysis sections that provide general information about the system, ocmponent, or parameter addressed by the IID, the relationship between the 100 requizamiw and the awivs-iate safety analyses, ard the explanation of which criterien requires it to be in the Technical Specifications.

'Ibe Bases were not develcped principally frcn the Crystal River Unit 3 Final Safety Analysis Report. Instead, FPC chose, as a direct parallel to the angoiry Configuration Management Fr@ tam, to utilize calculations, analyses, (5

y) procedures ard other key develupuiml references to ertain appropriate Bases for the improved 'Ibchnical Specifications. As a result, this effort 3 identified same inconsistencies between existing Technical Specification requinnents and analyses. 'Ibese incx)nsistencies will be reported to the NRC under P rate corruspendence.

h contents of this subnittal are as follows:

1. A plant-specific split hment. 'Ihis h=mit describes the application of the Selection Criteria fran Reference 1 to the Crystal River Unit 3

'Ibchnical Specification. 'Ihis dccument also sumarizes the new location of existirg Technical Specifications (either relocated to the Final Safety Analysis Report or retained in inproved 'Ibchnical Specifications). For retained 'Ibchnical Specifications, a cross refererxse between the existirg numberirn and the revised numbering is provided.

2. A change request package for each irriividual chapter. 'Ihe change request package reflects utilizirq the existirg license as a startirg point for justifyirq revisions to the 'Ibchnical Specifications. 'Ibe Standard

'Ibchnical Specifications were not utilind since a charge request nust address the change to the license, rot the departure from a generic h= ant with no legal standirg for the Crystal River Unit 3 license. 'Ihe package incitdes:

,7s (a) Revised IIDs, Actions ard Surveillance Requirements.

1 (b) Upgraded Bases.

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3F0889-14 (3 August 25, 1989

,) Page 3, 1989 (c) A markup of the existiry Crystal River Unit 3 Technical Specifications showiry changes (includiry ccms-reference identifiers to technical charges).

(d) A detailed description of charges (includiry crms-refemnae identifiers to technical charges).

(e) An evaluation of technical charges. Ead technical charge has been assigred a unique crms-reference identifier (e.g., Rx. 8, ECCS. 15, PS. 7, etc.) to help facilitate review.

(f) A prW_ significant hazards consideration evaluation for each technical change (includirg cross-reference identifiers to technical charges) .

3. A markup of BAW-2076 (RwWk and Wilcox Owners Group Revised Standard Technical Specifications (RSTS) shcwirg r-en plant specific changes to the generic RS'PS. This markup also provides Ma'= ions of the charges (includirg czms-refererce identifiers to takanical charges).

4. A copy of subnitted FPC 'Rx:hnical Specification Charge Requests relied upon for the develussit of this document and referenced in the evaluation of technical charges.

5. A summary and drafts of FSAR charges identifiai durity the Technical Specification Improvement development s ucess. These charges are remry to achieve consistency between the FEAR and analyses.

This subnittal has been reviewed as a pr-M charge to Technical Specifications by the Plant Review Cctraittee and the Nuclear General Review Ctr:mittee in accordance with existire Ib&nical Specifications sections 6.5.1.6.c and 6.5.2.8.c. FPC is confident that this subnittal and the efforts utilized in developirq it meet or exceed NRC rmM and expectations at this stage of the industry Technical Specification improvement process. As a result, this subnittal is provided for NRC review ard acceptance.

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W.S. Wil , Vice President Nuclear ' tions WSW/DGG/wla Attachment xc: Regional Administrator, Region II L Senior Resident Inspector

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_j IUCIEAR REGUIA'IUn' CIEMISSIQi

' IN 'iHE MATIER )

) DOCKET 10. 50-302 FLORIDA IUER CIXtPCPATIQi )

ut2nmCATE OF SERVICE W.S. Wilgus dye ard says that the following has been served on the Designated State Representative ard Chief Dcecutive of Citrus Ctunty, Florida, by deposit in the. United States raail, adiressed as follows:

Qiaiman, Administrator Board of County h i m ioners Radiological Health Services of Citrus County Department of Health and Citrus County Courthouse Rehabilitative Services Liverness, FL 32650 1323 Winewacd Blvd.

Tallahassee, FL 32301 A copy of Technical Specification Change Regaest No. 171 , requestirg Amendment to Appendix A of Operatirg Licensirg No. DPR-72.

FLORIDA 10WER CORIGATIOT r

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W.S. Wil Vice President Nuclear tion SWORN 'IO MID SUBSCRIBED BEFORE ME 'IHIS 25th DAY OF AUGUST 1989.

dictary Public

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My Canission State of Florida at Large NOIA9Y PUBLIC. STATE OF FLORIDA M LARGE MY COMM!SSON EXPIRES OCT 19.1992 -

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'r*h 1 STATE OF FIDRTIR

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CDUtTIY OF CI'IIUS W.S. Wilgus states that he is the Vice President, Nuclear Operations for Florida Power Corporation; that he is authorized on the part of said campany to sign and file with the Nuclear Regulatory Camrnission the information attached hereto; ard that all such statements made ard matters set forth therein are true and correct to the best of his knowledge, information, and belief.

W.Si Wil ' ice President IAlclear ion Subscribed and sworn to before me, a Notary Public in ard for the State ard County above named, this 25th day of August,1989.

/ Notary Public Notary Public, State of Florida at large My Cannission Expires:

WTARY PuBUC. STATE OF FLORicA AT LARGE MY COMUG.ON EXPIRES OCT.10.1988 ,

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