3F0997-25, TS Change Request Notice 213,Suppl 1 to License DPR-72, Proposing New Improved TS 3.4.11 Re Low Temp Overpressure Protection Sys

TS Change Request Notice 213,Suppl 1 to License DPR-72, Proposing New Improved TS 3.4.11 Re Low Temp Overpressure Protection Sys

ML20210T972
Person / Time
Site:	Crystal River
Issue date:	09/12/1997
From:	Cowan J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210T975	List: 3F0997-25, TS Change Request Notice 213,Suppl 1 to License DPR-72, Proposing New Improved TS 3.4.11 Re Low Temp Overpressure Protection Sys ML20210T977
References
3F0997-25, 3F997-25, TAC-M99277, NUDOCS 9709160213
Download: ML20210T972 (3)

Text

.

4 Florida .

Power 7..a, ,[E.,

September 12,1997 3F0997 25 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Technical Specification Change Request Notice 213, Supplement 1 (TAC No, M99277)

References:

A. FPC to NRC letter, 3F079710, "TSCRN 213 (LTOPS), Revision 0,"

dated July 18,1997 B. FPC to NRC letter, 3F0997-II, " Response to Request for Additional l Information (RAI) Related to Proposed License Amendment for 1.ow-l Temperature Overpressure Protection Technical Specincation (TAC No.

l M99277)," dated September 5,1997 i

Dear Sir:

I Florida Power Corporation (FPC) submitted Technical Specification Change Request Notice I (TSCRN) 213 Revision 0, on July 18,1997 (Reference A). The submittal proposed a new l

Improved Technical Specification (ITS) 3.4.11 (Low Temperature Overpressure Protection System, LTOPS), new Bases B 3.4.11 (LTOPS), and revised ITS Bases B 3.5.3 (ECCS- '

Shutdown), Bases B 3.4.9 (Pressurizer Safety Valves), Bases B 3.5.2 (ECCS-Operating) and Bases B 3.5.3 (ECCS Shutdown) for Crystal River Unit 3 (CR-3). This letter is to supplement FPC's request with three revised Technical Specification pages 3.4 21B, B 3.4-52E and B 3.4-5211 of Reference A with replacement pages provided in Attachment I to this le Additionally, Pages 1 through 10 of Attachment A of Reference A provided the basis, a description, and an evaluation of the proposed TSCRN 213. Attachment 2 to this letter is providing replacement pages 2,5, and 6 to substitute those pages in Attachment A of TSCRN l l 213, Revision 0.

. Reason for ReplacinLPtoposed Panes 3.4-21Bu lL3.4-52E and B 3.4-5211 pg.

HE.

Actions F.1.1 and F.1.2 of proposed ITS Section 3.4.11, submitted to the NRC in TSCRN 213, Revision 0, were included to provide additional options for the plant in the event that the g-gg

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pressurizer level rises above 160 inches. This portion of TSCRN 213 is not required by the standcrd I. TOP specincation in NUREO-1430, Revision 1, Improved Technical Specifications g',

u_m for Babcock and Wilcox (B&W) plants. As discussed in Reference B, although FPC has analysis demonstrating that the proposed change was acceptable, it is not necessary and it is, therefore, g",

being withdrawn.! 9709160213 970912 PDR ADOCK 05000302 P PDR CRYSTAL PNER ENERGY CONPLEX

• 15760 W. Pomr une Stnet

• Crystal RJver a Florida 3442M708 * (352) 79%486 A Harfde Progress Conpany

4 U,S. Nuclear Regulatory Commission 3F0997 25 Page 2 of 3 Consc4ucnces 0LRemating Actions F.1.1 and.liL2 The basis for removing actions F.1.1 and F.1.2 is provided below:

Removal of actions F.1.1 and F.1.2 make TSCRN 213 consistent with the B&W Standard TechnicM Specifications, NUREG 1430. Revision 1 Removal of the actions does not affect proposed ITS limits Removal of actions F.1.1 and F.1.2 is appropriate since, at the low RCS pressures, the pressurizer level of 160 inches will still be maintained, which will provide additional pressure margin and allow more time for operator response to postulated LTOP events l -

The remaining actions F.1 and F.2 (formerly F.2.1 and F.2.2) will prevent l overpressurization of the RCS if the pressurizer level of 160 inches is exceeded l

l In summary, the original request was not based on regulatory or procedural requirements, and removal of proposed ITS actions F.1.1 and F.1.2 does not adversely impact any of the remaining TSCRN 213 requests. FPC also concludes that the proposed ITS Section 3.4.11 and Bases B3.4.11 provided in TSCRN 213, as supplemented by this letter, do not affect the previous conclusions or the basis for the conclusions in the No Signincant llazards Consideration evaluation provided in Reference A.

This submittal fulnlis FPC's commitment to revise TSCRN 213 as stated in Reference B. Other than TSCRN 213, Revision 0, this change does not affect any other proposed Technical Speci0 cation Change Request previously submitted by FPC for NRC review. FPC requests that the NRC review and approve the proposed LTOPS Technical Speci0 cation change, as supplemented, by October 20, 1997, and provide for a 304ay implementation period. This supersedes the previously requested schedule for N11C review and approval made in Reference A. This revised schedule will continue to support the current restart of CR-3.

Should you have any questions or require additional information, please contact Mr. David Kunsemiller, Manager, Nuclear Licensing at (352) 563-4566.

Sincerely, 2kb %

John Paul Cowan Vice President Nuclear Production JPC/RSC/LVC 1

xc: Regional Administrator, Region 11 Senior Resident inspector NRR Project Manager Attachments:

1. Replacement Technical Specincation pages 3.4-21B, B 3.4-52E and B 3.4-5211

2. Substitute Pages 2,5, and 6 for Attachment A of TSCRN 213, Revision 0

y.S. Nuclear Regulatory Commission 3F0997 35 Page 3 of 3 STATE OF FLORIDA COUNTY OF CITRUS John Paul Cowan s'.ates that he is the Vice President, Nuclear Production for Florida Power Corporation; that he is authorized on the part of said company to sign arxl 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.

MG -'

I John Paul Cowan l Vice President

! Nuclear Production l

Sworn to and subscribed before me this _ day of - YUYLA ,1997,by John Paul Cowan.

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