3F0904-05, Supplemental Information and Regulatory Commitments for License Amendment Request 281, Revision 0, Revised Improved Technical Specification (ITS) 3.7.5, Emergency Feedwater System

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Supplemental Information and Regulatory Commitments for License Amendment Request #281, Revision 0, Revised Improved Technical Specification (ITS) 3.7.5, Emergency Feedwater System
ML042720423
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 09/16/2004
From: Young D
Progress Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0904-05
Download: ML042720423 (19)
v • d • e


Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 50.90 September 16, 2004 3F0904-05 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Supplemental Information and Regulatory Commitments for License Amendment Request #281, Revision 0, Revised Improved Technical Specification (ITS) 3.7.5, Emergency Feedwater System

References:

PEF to NRC letter, dated December 9, 2003, Crystal River Unit 3 - License Amendment Request #281, Revision 0, Revised Improved Technical Specification (ITS) 3.7.5, Emergency Feedwater System

Dear Sir:

Florida Power Corporation, doing business as Progress Energy Florida, Inc. (PEF), hereby submits Supplemental Information and Regulatory Commitments for License Amendment Request (LAR) #281, Revision 0, referenced above. The supplemental information is included in Attachment A. This information includes risk insights for external events (internal fire and severe weather phenomena) related to performance of extended maintenance on the Emergency Feedwater System. (EFW) Information concerning fire detection, suppression and combustible loading are included in Attachment B. This information was requested verbally by NRC staff in a telephone conference on August 19, 2004.

A list of regulatory commitments is included in Attachment C. Crystal River Unit 3 (CR-3) will implement the provisions described in these commitments during extended EFW maintenance that will be performed during the one-time extended allowed outage time. The provisions of these commitments provide compensatory measures that will reduce or mitigate risk associated with having the EFW system out-of-service for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The compensatory measures are based on risk insights and consideration of external events such as fire and adverse weather conditions.

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428

U.S. Nuclear Regulatory Commission Page 2 of 3 3F0904-05 If you have any questions regarding this submittal, please contact Mr. Sid Powell, Supervisor, Licensing and Regulatory Programs at (352) 5634883.

Sincerely, 4 6 Dale E. Young V Vice President Crystal River Nuclear Plant DEY/pei Attachments:

A. Supplemental Information Regarding Insights for External Events B. Information Concerning Fire Detection and Suppression Capability and Combustible Loading C. List of Regulatory Commitments xc: NRR Project Manager Regional Administrator, Region II Senior Resident Inspector

U.S. Nuclear Regulatory Commission Page 3 of 3 3F0904-05 STATE OF FLORIDA COUNTY OF CITRUS Dale E. Young states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, currently doing business as Progress Energy Florida, Inc. (PEF); 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.

Dale E. Young ° Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this 'IlM day of 5epf-embcr 2004, by Dale E. Young.

nature o f Notarv Public.

State of Fl lJANREDSHRER f MYCOMMISSION W #D 12B063 Sto-at EXPIRES:Jm 20,20 dThru No"tPltk Wdewftes Bw~d (Print, type, or stamp Commissioned Name of Notary Public)

Personally Produced Known V7 -OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 ATTACHMENT A LICENSE AMENDMENT REQUEST #281, REVISION 0 Supplemental Information Regarding Insights for External Events

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 1 of 6 Supplemental Information The external events assessed for this activity include severe weather phenomena and internal fires. These events were evaluated as explained below and compensatory measures were determined to minimize risk during the planned Emergency Feedwater (EFW) maintenance.

Another consideration that helps minimize risk is the relative configuration of Emergency Feedwater Pump 3 (EFP-3) to the rest of the plant. Because EFP-3 is located in its own dedicated Category 1 structure located on the berm, activities associated with the work (welding, grinding, etc.) will not impact other systems or areas in the plant. This configuration reduces potential for cross-train errors or inadvertent impact on equipment relied upon for supplying feedwater or other mitigative functions.

In addition, using Probabilistic Risk Assessment (PSA) insights, the High Pressure Injection (HPI) system may be available to prevent core damage if all EFW and Auxiliary Feedwater (AFW) sources are unavailable. For many core damage scenarios involving loss of secondary side cooling, core cooling may be available for accident mitigation through "feed and bleed" using the flow path from the HPI system through the code safety relief valves or pilot operated relief valve. This alternative cooling method is included in plant Emergency Operating Procedures (EOPs).

Severe Weather Phenomena CR-3 utilizes Emergency Preparedness procedure EM-220 to address violent weather. This procedure provides guidance during the onset of a Flood Warning, Tornado Watch, Tornado Warning, Tropical Storm Watch, Tropical Storm Warning, Hurricane Watch, and Hurricane Warning; and implements activities to ensure plant safety by having the necessary equipment and supplies on hand. This procedure also provides guidance in recovering from the effects of a hurricane and implements Institute of Nuclear Plant Operations (INPO) Significant Operating Event Report (SOER) 02-01, Severe Weather. EM-220 defines conditions when operators must place the plant in a shutdown condition for violent weather conditions.

The Main Feedwater, EFW and AFW Systems are designed to provide secondary side cooling water needed to cool the plant down from operating conditions to shutdown conditions. Once shutdown conditions are achieved, secondary side cooling is no longer required. The EFW System and Technical Specification required water supply are designed to withstand design basis violent weather conditions.

CR-3 is designed to maintain safe shutdown capability in the event of a postulated hurricane. The following equipment is required to remain functional during the postulated hurricane to assure maintenance of the reactor in a safe condition:

a. Onsite emergency diesel generators, and their support equipment (fuel systems, cooling systems, switchgear)
b. Reactor decay heat removal equipment:
1. Nuclear Services Closed Cycle Cooling System (Service Water) (SW)
2. Decay Heat Removal System (DH)

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 2 of 6

3. Decay Heat Closed Cycle Cooling System (DC)
4. Nuclear Service and Decay Heat Seawater System (Raw Water) (RW)

Ability of this equipment to remain functional is assured by the facility design, as discussed in the following. Onsite power generation equipment is located within the auxiliary building, which is protected from flooding by water-tight doors at all openings lower than the predicted wave run-up height. Fuel storage tanks are located underground and are restrained against damage from their own buoyancy by hold-down straps and concrete anchor slabs. Tank vents are above postulated wave tops to prevent seawater entering the tanks via the vent lines. Diesel engine cooling is by a self-contained air radiator system within the structure. The SW System, DH System, and DC System are all located within the auxiliary building and are powered by onsite diesel generators. Additional component protective facilities required for local protection are discussed in CR-3 Final Safety Analysis Report Chapter 2.4.2, Flood Studies and Hurricane Effects.

Internal Fire The risk insights for fires are primarily based on a combination of portions of the Individual Plant Evaluation of External Events (IPEEE) and Appendix R studies for CR-3. Due to the vintage of the CR-3 IPEEE (1997), EFP-3, which was installed in 1999, is not included. EFP-3 was installed to replace the motor-driven EFW pump, EFP-1, to reduce loading on the "A" Train Emergency Diesel Generator (EGDG-1A). EFP-3 now serves as the Improved Technical Specifications (ITS) required EFW pump and provides the credited functionality previously provided by EFP-1. EFP-1 is retained for additional defense in depth functions.

The IPEEE also does not include the non-safety related diesel generator MTDG-1, which acts as an alternate AC power source for the motor-driven Feedwater Pump 7 (FWP-7). MTDG-1 may be able to supply FWP-7 during a fire but no formal analysis has been performed and no credit is taken for this power source for purposes of compliance with Appendix R.

Because the plant configuration has changed since the IPEEE was first developed, a quantitative fire risk assessment was not performed, and a more qualitative defense in depth approach was used. Evaluations of EFW/AFW equipment that would be available in the event of a fire are based on evaluations of equipment and circuit locations within fire areas using the deterministic criteria of Appendix R. Those evaluations postulate that if equipment and circuits are not separated or protected in accordance with Appendix R lII.G.2 criteria, then they will be made unavailable due to a fire in that area. The risk-informed portion of this evaluation, however, does consider the potential that equipment, which provides defense in depth but does not meet Appendix R criteria, may be available.

Based on Appendix R Fire Study data, several fire areas have been identified which contain cables supporting the various EFW equipment and /or support equipment. By postulating fires in these areas, and considering protection, separation, detection and suppression capabilities, fire areas have been identified that could potentially impact plant capabilities with EFP-3 out-of-service. An evaluation was performed for each fire area/zone. Six areas/zones were identified where EFP-3 would be the only pump demonstrated to be free from fire damage and addressed by fire response procedure OP-880A, Appendix "R" Post Fire Safe Shutdown Information (see Table 1). For three of these areas/zones, either EFP-1 or FWP-7 have been

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 3 of 6 demonstrated to remain free from fire damage and would be available to provide feedwater.

Because EFP-3 is the normally available EFW source, the use of these pumps is not proceduralized in OP-880A for these zones. However, if EFP-3 were unavailable, plant conditions of a loss of all feedwater would lead operators to EOPs that do include provisions and direction for use of EFP-1 and FWP-7.

Table 1 lists the six areas/zones of highest concern with EFP-3 out-of-service. For each zone, the availability of the four sources of emergency and auxiliary feedwater during a fire was assessed and is listed in Table 1. EFP-3 is normally available in all six areas/zones, but will be out-of-service for maintenance during the extended maintenance period. EFP-2 is unavailable for fires in all six of these areas/zones. Table 1 does not include area/zones where the fire itself makes EFP-3 inoperable because removing EFP-3 from service does not impact EFP-3 capability for that fire. Also, the risk evaluation determined that there was little or no increase in risk when EFP-2 was available for a fire in a particular area/zone. If EFP-2 remains available for a given fire, the EFW safety function continues to be met with EFP-3 out-of-service.

For area/zone CC-124-113, the fire does not impact the EDGs. With two EDGs available, adequate capacity exists to supply EFP-1 in addition to other equipment required for safe shutdown. For zones CC-95-101 and CC-124-115, offsite power is available to FWP-7.

Therefore, CR-3 has an alternate supply of feedwater for a fire in each of these areas/zones. For fires in the remaining three areas/zones (CC-108-105, CC-108-107, CC-124-116), no source of feedwater has been demonstrated to remain free from damage with EFP-3 out of service. This conclusion is based on the safe shutdown analysis done for Appendix R. The safe shutdown analysis does not take credit for MTDG-1, however, MTDG-1 may be available to power FWP-7 in some circumstances. The impact of fire on FWP-7 and MTDG-1 control and power circuitry was not analyzed for these areas/zones and, therefore, FWP-7 is not credited or addressed by OP-880A. However, FWP-7 would be used, if available, under direction of the EOPs should plant conditions require auxiliary feedwater.

Note that Table 1 replaces the table provided in the December 9, 2003 submittal (Attachment E, Page 6 of 7). There are several differences between Table 1 in this correspondence and the previously submitted table in the December 9, 2003 submittal. Table 1 below looks at EFW/AFW trains rather than breaking up the pumps and valves into separate items. This is simpler to read and understand because the evaluator does not have to determine which combinations of pumps and valves constitute availability. Also, two areas/zones were added (CC-95-101 and CC-124-113) to the table that were identified as affecting EFW in a post-fire safe shutdown strategy review. The safe shutdown strategy review also identified changes in the availability of EFW and AFW trains based on the availability of power sources to pumps and valves in the flowpaths. For example, EFP-1, previously listed in the December 9, 2003 submittal as available, is listed as not available in Table 1 for a fire in the "B" 4160 switchgear room. While EFP-1 itself is unaffected by this fire, it is considered unavailable because the fire makes the "B" EDG inoperable. The "A" EDG, which can power EFP-1, may not have the capacity to supply EFP-1 in all circumstances without the capability of shedding some loads (that have "B" train components running) from the "A" bus.

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 4 of 6 Table 1: Fire Zone Evaluation Train "B"l Train "A" Train "A" AFW Fire Area Description EFW EFW EFW A WP-7

__ __ __ _ __ __ _ EFP-2 EFP-3 EFP-1FW -

CC-95-101 Control Complex Elevation-95 U A U A*

CC-108-105 "B" Battery Charger Room U A U U*

CC-108-107 "B" ES 4160v Switchgear U A U U*

Room CC-124-113 "C" EFIC Room U A A* U*

CC-124-115 "B" EFIC Room U A U A*

CC-124-116 "B" ES 480v Switchgear Room U A U U*

A = available given fire in this zone A* = available but not proceduralized for use during a fire, directions for use in EOPs U = unavailable given fire in this zone U* = unavailable per Appendix R criteria but may be available under direction from EOPs and use of MTDG-1 In addition to the six areas/zones that have the highest increase in risk due to the planned EFP-3 extended maintenance, CR-3 evaluated which fire areas/zones have the highest risk of core damage under any circumstance. Two of the six areas/zones identified in Table 1 (CC-108-105 and CC-108-107) are among the highest Core Damage Frequency (CDF) fire areas/zones. There are four additional fire areas/zones that have comparable or higher CDF values. These areas/zones are listed in Table 2.

Table 2: High CDF Fire Areas/Zones Fire Area Description Core Damage Frequency/Year CC-108-106 "A" Battery Charger Room 1.49 E-05 CC-108-108 "A" ES 4160v Switchgear Room 7.31 E-06 CC-124-117 "A" ES 480v Switchgear Room 3.79 E-06 CC-108-102 Hallway and Remote Shutdown Room 2.66 E-06 Compensatorv Measures Based on risk insights, compensatory measures have been developed to lower the risk of removing EFP-3 from service for extended maintenance. Fire risk can be reduced in several ways. These include elimination of ignition sources, reduction of combustibles or increase in area/equipment defense in depth. In addition, other measures can be taken to provide additional assurance that redundant equipment and power sources are available. Risk can also be avoided by not performing the extended maintenance if adverse weather is anticipated. These compensatory measures will be taken for those areas listed in Table 1 to minimize the increase in risk due to the extended EFP-3 maintenance by providing greater assurance of the availability of redundant EFW and AFW trains. As an added compensatory measure, CR-3 will perform the same compensatory measures for the areas/zones in Table 2 as Table 1. Performing the

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 5 of 6 compensatory measures in these high risk areas/zones will offset the increased risk due to removing EFP-3 from service by lowering the potential for core damage due to fire.

The following measures will be implemented during the extended maintenance on the EFW system:

1. CR-3 will perform procedure CP-253, Power Operation Risk Assessment and Management, which requires both a deterministic and probabilistic evaluation of risk for the performance of all maintenance activities. This procedure uses the Level 1 PSA model to evaluate the impact of maintenance activities on core damage frequency. CR-3 will not plan any maintenance that results in "Higher' Risk" (10 Incremental Core Damage Probability) during extended Emergency Feedwater maintenance.
2. The following equipment and systems (including support equipment) will be designated administratively as "protected" (no planned maintenance or discretionary equipment manipulation): redundant Emergency Feedwater equipment, Auxiliary Feedwater (FWP-7 and MTDG-1), Control Complex Cooling, High and Low Pressure Injection, Emergency Diesel Generators, Service Water, Raw Water and the Appendix R chiller.
3. CR-3 will perform initial and daily walkdowns of the "B" train EFW system, EFP-1, the Auxiliary Feedwater System and associated power supply switchgear.
4. CR-3 will not schedule elective maintenance in the switchyard that would challenge the availability of offsite power.
5. CR-3 will not initiate an EFW extended preventive maintenance outage if adverse weather, as designated by Emergency Preparedness procedures, is anticipated.
6. Operator awareness will be increased on the need for and use of redundant EFW equipment, Emergency Feedwater Initiation and Control (EFIC), Auxiliary Feedwater System, and Appendix R chiller. This will be accomplished by on shift operating crew review of EOP-14 Enclosure 7, EFW Pump Management and OP-880A, Enclosure 38, Appendix R Chiller Start.
7. The following fire risk reduction actions will be taken for the areas listed in Tables 1 and 2: limit hot or spark producing work, initial walkdown of transient combustibles, and hourly fire watch will monitor for the presence of transient combustible material.
8. An hourly fire watch will be established in fire areas that are considered risk-significant (listed in Tables 1 and 2).

These proposed compensatory measures are consistent with those performed for other extended Allowed Outage Times (AOTs) for the Nuclear Services Seawater System (RW) and the Emergency Diesel Generators.

U.S. Nuclear Regulatory Commission Attachment A 3F0904-05 Page 6 of 6 Conclusion CR-3 has a robust EFW and AFW system. With EFP-3 out-of-service, EFP-2, EFP-1 and FWP-7 are available with diverse motive forces and flowpaths. CR-3 has evaluated the risks associated with an extended AOT for EFP-3 and identified the fire and adverse weather events as significant concerns. In order to reduce the risk from these events, CR-3 has proposed compensatory measures that maximize the availability of redundant equipment, minimize the potential for ignition and spread of fires, enhance availability of power sources, increase operator awareness and avoid risk due to violent weather through preparation and planning.

References

1. Amendment No. 207, dated June 13, 2003, Crystal River Unit 3 - Issuance of Amendment Regarding Technical Specification Change Request for Emergency Diesel Generator Allowed Outage Time Extension (TAC No. MIB5616)
2. Amendment No. 212, dated May 18, 2004, Crystal River Unit 3 - Issuance of Amendment Regarding the Nuclear Services Seawater System (TAC No. MC01 19)

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 ATTACHMENT B LICENSE AMENDMENT REQUEST #281, REVISION 0 Information Concerning Fire Detection and Suppression Capability and Combustible Loading

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 1 of 6 Fire Detection and Suppression for Selected Fire Areas/Zones CC-95-1O1A Fire Protection Suppression (type): PRE-ACTION SPRINKLER Hose Stations NONE (Note 1)

Portable Extinguishers: PROVIDED Detectors (type): THERMAL (Pyralarm zone 17)

Fire Resistance Rating:

Walls: N,SW WALLS - 3 HOUR: OTHERS - CONCRETE

_ Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A

  • _ CC-95-IOIB Fire Protection Suppression (type): PRE-ACTION SPRINKLER Hose Stations: NONE (Note 1)

Portable Extinguishers: NONE Detectors (type) THERMAL (Pyralarm zone 17)

Fire Resistance Rating: _

Walls: NW WALLS- 3 HOUR: OTHERS - CONCRETE Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A CC-95-1O1C Fire Protection Suppression (type): PRE-ACTION SPRINKLER Hose Stations: NONE (Note 1)

Portable Extinguishers: NONE Detectors (type): THERMAL (Pyralarm zone 17)

Fire Resistance Rating:

Walls: W,S,WALLS 3 HOUR: OTHERS - CONCRETE

_ Floor, Ceiling, Roof: 3 HOUR Penetrations SEALED EQUIVALENT TO FIRE AREA/ZONE FixedOpenings:RATING Fixed Openings: N/A

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 2 of 6 CC-108-102 Fire Protection Suppression (type): NONE Hose Stations: 1 Portable Extinguishers: PROVIDED Detectors (type) IONIZATION (Pyralarm zone 4)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: NONE CC-108-105 Fire Protection Suppression (type): NONE Hose Stations: NONE (Note 2)

Portable Extinguishers: PROVIDED Detectors (type): IONIZATION (Pyralarm zone 4)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A CC-108-106 Fire Protection l Suppression (type): NONE Hose Stations: NONE (Note 2)

Portable Extinguishers: NONE Detectors (type): IONIZATION (Pyralarm zone 4)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 3 of 6 CC-108-107 Fire Protection Suppression (type): NONE Hose Stations: NONE (Note 2)

Portable Extinguishers: PROVIDED Detectors (type): IONIZATION (Pyralarm zone 4)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: 3 HOUR Penetrations SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A CC-108-108 Fire Protection Suppression (type): NONE Hose Stations: NONE (Note 2)

Portable Extinguishers: PROVIDED Detectors (type): IONIZATION (Pyralarm zone 4)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: 3 HOUR Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: N/A CC-124-113 Fire Protection Suppression (type): NONE Hose Stations NONE (Note 3)

Portable Extinguishers: NONE Detectors (type): IONIZATION (Pyralarm zone 5)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: FLOOR- 3HOUR: CEILING- STEEL Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: NONE

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 4 of 6 CC-124-115 Fire Protection Suppression (type): NONE Hose Stations: NONE (Note 3)

Portable Extinguishers: NONE Detectors (type) IONIZATION (Pyralarm zone 5)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: FLOOR- 3 HOUR: CEILING - STEEL Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: NONE CC-124-116 Fire Protection Suppression (type): NONE Hose Stations: NONE (Note 3)

Portable Extinguishers: PROVIDED Detectors (type): IONIZATION (Pyralarm zone 5)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: FLOOR- 3 HOUR: CEILING - STEEL Penetrations: SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: NONE CC-124-117 Fire Protection Suppression (type): NONE Hose Stations: NONE Portable Extinguishers: PROVIDED Detectors (type) IONIZATION (Pyralarm zone 5)

Fire Resistance Rating:

Walls: 3 HOUR Floor, Ceiling, Roof: FLOOR- 3 HOUR: CEILING - STEEL Penetrations SEALED EQUIVALENT TO FIRE AREA/ZONE RATING Fixed Openings: NONE

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 5 of 6 Note 1:

Fire fighting strategies are directed by procedure Administrative Instruction AI-2205A, Pre Fire Plan -

Control Complex. Hose Stations are available for manual suppression as follows:

Primary:

Near the Turbine Building side of this area.

Secondary:

Turbine Building; Elev. 95' about 100' west of primary standpipe.

Note 2:

Fire fighting strategies are directed by procedure AI-2205A Hose Stations are available as follows:

Primary:

Outside of 3B Battery Room, near remote shutdown room. Manual pull station to actuate FSV-257 deluge valve, which will fill the standpipe.

Secondary:

Turbine Building; Elev. 95' outside the stair.

Note 3:

Fire fighting strategies are directed by procedure AI-2205A. Hose Stations are available as follows:

Primary:

119' elevation Turbine Building Secondary:

134' CC, foyer to Cable Spreading Room, Elev. 108'

U.S. Nuclear Regulatory Commission Attachment B 3F0904-05 Page 6 of 6 Combustible Loading For Fire Areas/Zones Zone Description MPFL* Transient In Situ Btu Total Btu Area Btu/sq. ft.

Btu Sq. ft.

101A HEALTH PHYSICS/CHEM AREA 55,000 13,107,360 126,141,952 139,249,312 3652 38,130 101B CHEMISTRY LAB 60,000 0 19,663,001 19,663,001 474 41,483 101C COUNT ROOM 75,000 0 9,392,400 9,392,400 168 55,907 102 HALLWAY AND REMOTE 140,000 120,000 45,380,434 45,500,434 411 110,707 SHUTDOWN 105 BATTERY CHARGER ROOM 3B 240,000 0 21,352,628 21,352,628 244 87,511 106 BATTERY CHARGER ROOM 3A 240,000 0 38,893,436 38,893,436 247 157,463 107 4160 ES SWITCHGEAR BUS ROOM 3B 240,000 465,600 77,085,280 77,550,880 852 91,022 108 4160V ES SWITCHGEAR BUS ROOM 240,000 0 73,379,654 73,379,654 815 90,036 3A.

113 EFIC ROOM "C" 38000 0 None 0 172 0 115 EFIC ROOM "B" 38,000 0 4,939,482 4,939,482 169 29,228 116 480V ES SWITCHGEAR BUS ROOM 3B 55,000 0 21,454,384 21,454,384 426 50,362 117 480V ES SWITCHGEAR BUS ROOM 3A 50,000 0 19,820,974 19,820,974 426 46,528

  • Maximum Permissible Fire Load (BTU/sq. ft)

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-3021LICENSE NUMBER DPR-72 ATTACHMENT C LICENSE AMENDMENT REQUEST #281, REVISION 0 List of Regulatory Commitments

U.S. Nuclear Regulatory Commission Attachment C 3F0904-05 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Progress Energy Florida (PEF) in this document. Any other actions discussed in the submittal represent intended or planned actions by PEF. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Supervisor, Licensing and Regulatory Programs of any questions regarding this document or any associated regulatory commitments.

Commitment Due Date CR-3 will perform procedure CP-253, Power Operation Risk During one-time Assessment and Management which requires both a deterministic and extended (greater probabilistic evaluation of risk for the performance of all maintenance than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) activities. This procedure uses the Level 1 PSA model to evaluate the Emergency impact of maintenance activities on core damage frequency. CR-3 will Feedwater not plan any maintenance that results in "Higher Risk" (10-6 System Incremental Core Damage Probability). maintenance The following equipment and systems (including support equipment) will be designated administratively as "protected" (no planned maintenance or discretionary equipment manipulation): redundant Emergency Feedwater equipment, Auxiliary Feedwater (FWP-7 and MTDG-1), Control Complex Cooling, High and Low Pressure Injection, Emergency Diesel Generators, Service Water, Raw Water and the Appendix R chiller.

CR-3 will perform initial and daily walkdowns of the "B" train EFW system, EFP-1, the Auxiliary Feedwater System and associated power supply switchgear.

CR-3 will not schedule elective maintenance in the switchyard that would challenge the availability of offsite power.

CR-3 will not initiate an EFW extended preventive maintenance outage if adverse weather, as designated by Emergency Preparedness procedures, is anticipated.

Operator awareness will be increased on the need for and use of redundant EFW equipment, Emergency Feedwater Initiation and Control (EFIC), Auxiliary Feedwater System, and Appendix R chiller.

This will be accomplished by on shift operating crew review of EOP-14 Enclosure 7, EFW Pump Management and OP-880A, Enclosure 38, Appendix R Chiller Start.

The following fire risk reduction actions will be taken for the areas listed in Tables 1 and 2: limit hot or spark producing work, initial walkdown of transient combustibles, and hourly fire watch will monitor for the presence of transient combustible material.

An hourly fire watch will be established in fire areas that are considered risk-significant (Tables 1 and 2.).

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