3F1097-27, Provides Response to NRC Request for Addl Info Re TS Change Request Notice 209,Rev 1 for Unit 3.Commitment Made in Submittal Identified in Attachment B

Provides Response to NRC Request for Addl Info Re TS Change Request Notice 209,Rev 1 for Unit 3.Commitment Made in Submittal Identified in Attachment B

ML20212D476
Person / Time
Site:	Crystal River
Issue date:	10/29/1997
From:	Holden J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F1097-27, TAC-M99308, NUDOCS 9710310110
Download: ML20212D476 (9)

Text

_

Florido Power ETRM W E2mmn October 29,1997 3F1097 27

- U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Technical Specific tion Change Request Notice 209, Revision 1 Response to Request for AdditionalInformation (TAC Number M99308)

References:

1.

FPC to NRC letter,3F0797 21, dated July 29,1997 2.

NRC to FPC letter,3N1097-08, dated October 7,1997 3.

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

Dear Sir:

s=

Thc purpose of this letter is to provide Florida Power Corporation's (FPC) response to NRC Request f

b for Additional Information regarding Technical Specification Change Request Notice (TSCRN) 209, Revision 1 for the Crystal River Unit 3 (CR 3) nuclear station.

By letter dated July 29, 1997 f

(Reference 1), FPC submitted TSCRN 209, Revision 1, which requested changes to the improved Technical Specifications (ITS) regarding Post Accident Monitoring instrumentation. By letter dated October 7,1997 (Reference 2), the NRC Staff requested additionalinformation. Attachment A to this submittal provides the response to that request.

The response to the NRC's request clarifies the design of the subcooling margin monitor: and the Safety Parameter Display System (SPDS) at CR 3 and provides additionalinformation regarding the backup method forcalculating subcooling margin. The submittal does not involve any revisions to the CR-3 ITS submitted by Reference 1. The Determination of No Significant Hazards Consideration submitted by Reference 1 was reviewed to determine if the conclusions were affected by the information provided in this response. That review concluded that the No Significant Hazards

determination submitted previously remains valid and that no changes to it are needed. The commitments made in this submittal are identified in Attachment B.

If you have any questions regarding this submittal, please contact Mr. David Kunsemiller, Manager, Nuclear Licensing, at (352) 563 4566.

Sincerely, h/4 hC l

'Jo J. Holden, Director 1 Site Nuclear Operations JJH/rer 9710310110 971029 "3 Attachments ;

DR ADOCK 050003g p

Regional Administrat6r,'R'egion 11 Qlll l{l(l{l xc:

Senior Resident inspector NRR Project Manager CRYSTAL RIVER ENERGY COWLEX: 15760 %. rawn una m,td e crymal hw. norm 34Us.670s e 05h 7954486 A 11erida Pretern Csmpany r;-

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U.S. Nuclear Regulatory Commission Attachment A 3F1097 27 Pcg) 1 of 7 ATTACHMENT A FPC RF.SPONSE TO NRC REQUEST FOR ADDITIONALINFORMATION

- TECHNICAL SPECIFICATION CHANGE REQUEST NOTICE 209, REVISION 1 1.

NRC Reaues!

In Attachment F (page 1, second paragraph) of the July 29,1997, submittal, Florida Power Corporation (FPC) states that 'allinputs used by the Safety Parameter Display System (SPDS) to calculate subcooling margin are environmentally qualified.'

However, I Attachment O (inarked up Technical Specifications page B 3.3138a, item 21) states that "the sore exit thermocouple inputs to the subcooling margin monitors are not

. environmentally qualified' The statements arpear contradictory, please clarify.

FPC Resco,=,se '

pag +

Attachment F to the July 29,1997, submittal, discusses the des!gn of the SPDS, whe eas Attachment D of the submittal, specifically ITS Bases page B 3.3138a, Item 21, discusses e

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the Bailey Tsar monitors. The SPDS and the Bailey systems are two separate and redundant systems that use different thermocouples to determine Degrees of Subcooling.

r The following discussion clarifies the discussion of these two systems.

Bailev Tyy Monitor:

As stated in Attachment D, on ITS Bases page B 3.3-138a:

' Two channels of subcooling snargin with sputs ham RCS hot leg temperature (TH), core

. exit temperature, and RCS pressure are provided. Multiple core exit temperatures are auctioneered with only the highest temporature being input to the monitor.....'

' This description statement refers to the two channels of the Bailey Ts y indication that are available to the operators on the PSA section of the Control Board. These two digital Ts,1 meters are designated RC-4-Tl4 and RC-4-Tl5 Attachment _1 to FPC letter 3F0796-03,

, dated July 8,1996 (Reference 3) depicts these two indicators and the instrument strings that provide the required input. Non-environmentally qualified core exit thermocouples (T/Cs) are used as inputs to these subcooling margin monitors. The following non-environmentally qualified T/Cs are used as input to calculate the subcooling margin displayed by RC-4-Tl4 and RC-4 Tl5:

Device RC-4 Tl4 Device RC 4 Tl5 3

IM-8H-TE IM-13F-TE IM-7E-TE IM-5D TE IM-8F-TE IM-9C-TE IM-5K-TE IM-3F-TE IM-9M-TE IM-120 TE IM 7M TE IM 50-TE I

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- U.S. Nuclear R:gul; tory Commission Attachment A g

3F1097 27 Pagn 2 of 7

(

ya The next section of item 21 states: *A note has been added to indicate that the two channels of subcooling margin ara backed up by either of two indications of subcooling r;targin based on similar inputs through the Safety Parameter Display system (SPDS). At least one SPDS channel must be available to provide this backup. With both SPDS channelsINOPERABLE, Condition Cisapplicable. Thisisconsiderednecessarybecause

= the core exit thermocouple inputs to the subcooling margin monitors are not

- environmentally qualified....."

c This statement indicates that SPDS provides a backup to the Bailey Tuy monitors. The Iast sentence in this excerpt from item 21 regaiding the non-environmentally qualified core m}/,

exit T/Cs, is referring to the Bailey Tur subcooling monitors, RC-4 Tl4 and RC-4-Tl5.

R

. Safety Parameter Disolav System (SPDSk

}

Attachment F of the July 29,-1997, submittal presents a discussion of the Safety Parameter Display System (SPDS). _ On page 1, second paragraph, it is stated that all of k

the ir, puts used by SPDS to calculate subcooling margin are environmentally qualified.

^

=The following sixteen environmentally q.ialified core exit T/Cs are used as input to the

. SPDS to calculate subcooling margin displayed by the A and B SPDS channels:

SPDS Channel A SPDS Channel B IM-2G-TE IM-9H-TE IM-7F-TE IM-6C-TE IM-SG-TE

. IM-10M-TE IM-6L-TE IM-60-TE IM-9E-TE.

IM-3L-TE IM-13G TE IM-100-TE l

lM-10C TE--

IM-4N-TE IM-11G-TE IM-13L TE 1

l NOTE: For this fuel cycle (Cycle 11) the sixteen environmentally qualified core exit thermocouples (CETs) are electrically routed in the plant as Channel "B", up to and including, the isolation device, as depicted in FPC's letter to the NRC dated July 8,1996 (Reference 3). As part of the subcooling margin monitor upgrade to be implemented

=

during Refuel Outage 11, these sixteen environmentally qualified CETs will be separated into an "A" channel and a "B'* channel.

In summary, the two Bailey channels of subcooling margin indication, addressed by Attachment D, Bases page B 3.3-138a, utilize a total of twelve non-environmentally qualified ' core exit T/Cs. The two channels of SPDS, as described in Attachment F, utilize sixteen environmentally qualified T/CE (eight T/Cs for each monitor). The Bailey monitors and the SPDS are separate and redundant systems (for monitoring SCM).

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n)ibr calculathe;T-satis a manuel calculation by operators using input fr In Attachment I(page 2) of the July 29,1997, submittal, FPC states that a backup method s:

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.y m: thermocouples and steam tables;i With regard to the manual calculation, the staff would g y q:Rehlb#owhg.-

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la. [A desception: of the conditionsIor actions:that initiates the operator to begin the -

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lbL %descr> tion ^ ol'he information needed by the operator to complete the manual t

Q m [is to the operetor?calculanon. In your response, please discuss how readily avai GF _x in m

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c.l i Anlea6matefof"the? timeinecessary forithe ^ operator to complete the manual Nsd ^

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? calculation.lHesse provide the basis for your answere en p g j* '

sig' ldi /A &$6n of the training provided to the operators to assure that they are able to

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complete the calculation accurately L 'd in the time period allotted.

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MA response to _each part of_ item' number 2 of the NRC's Request is presented below.

N' Before providing those responses, FPCzstresses_that the indication of the RCS hot leg-D' 1.1 temperature (TL) is safety relatodi environmentally qualified and is available whenever the -

MRCPslare: running, sAdditionally; the only portion of the Tm monitors that is not fully-h-

" _ 4" J i rw,444.g r; qualified are the incore Monitoring indications.1 The Emergency Operating -

7 Procedure (EOP) action for the operator to trip the Reactor Coolant Pumps (RCPs) within

. M " d{W iuse;of the Ts indication as the input to dCM monitors.p two minutes after lo R'

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$[jr Q' Lac iTho' operators would normally be prompted to manually determine Subcooling Margin s

r(SCM) by a loss of all SCM indication on the Main Control Board (MCB). A manual

. delerminationi of cSCM' might also be' performed in: the event of significant

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',, ; disagreement between the Bailey T monitLrs and the SPDS monitors.

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t There are two different indications of SCM located on tha front of the MCB. They are

%MW = (the two. Bailey SCM meters'and the two SPDG monitors.- The operators would u3e a

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manualLmethod to determinejSCM in the very unlikely event that both of these

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(indicetions wete unavailable or if significant disagreement between Bailey meters and

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-SPDS monitors was observed. The process that would most readily be used would A

be to manually plot Reactor Coolant System (RCS) pressure and temperature on a y

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figure of RCS pressure versus temperature and thereby verify that adequate SCM is s

, available; lThe figure used is provided as Figure 1. Points plotted to the left of the J'm.

curve labeled " Saturation Curve" are in the subcooled region, whereas points plotted yg n

to the right of this curve are in the superheated region. This figure is available in the 1

' EfW and in ' Administrative Instruction Al-505, " Conduct of Operations During

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gy n U.S. Nucle:r R:gul: tory Commission Attachmsnt A 3F1097-27 Page 4 of 7 . Abnormal and Emergency Events." Al 505 requires the Shift Technical Advisor (STA) to plot RCS temperature and pressure when SPDS is not available. Evaluating if adequate SCM is available in this way can be done quickly and provides the operators with enough information to take necessary EOP actions to address a condition of inadequate SCM (Emergency Operating Procedures require knowledge of whether adequate SCM is available to ensure proper transitions and step performance). The operators know when and how to manually determine SCM through the training they receive. b. The information the operators need to perform manual determination of SCM is RCS pressure and temperature. This is true whether plotting RCS pressure and temperature on Figure 1 (the preferred method) or determining a value of SCM using ASME steam tables. Displays of these parameters are located on the front of the MCB. At least one of each parameter is designated as Regulatory Guide (RG) 1.97, Category 1 (RCS temperature is determined from the safety related and fully qualified T, indication if Reactor Coolant Pumps (RCPs) are operating or the Coie Exit Thermocoup'es (CETs) if RCPs are not operating). Al 505 instructs operators to use RG 1.97 instruments to monitor and control plant parameters because these are i-expected to be the most reliable under harsh operating environments (i.e., radiation, temperature, moisture). [ The following RG 1.97 instrumentation is available on the front of the MCB: t l Three CET chart recorders each with three digital incore displays (0-2500 degrees F) i Two RCS Pressure Wide Range indicators (0 3000 psig) {1 . One RCS Pressure Wide Range recorder (0-3000 psig) .One T Temperature Wide Range indicator (120-920 degrees F) One T Temperature Wide Range recorder (120-920 degrees F) In addition to the above RG 1.97 instrumentation, RCS Pressure Low Range is currently indicated on the front of the MCB. However, these instrument strings are not safety related. A modification is being performed this outage to upgrade the RCS Pressure Low' Range instrument. Two new safety-related indicators are being installed on the MCB and the existing transmitters are being replaced with new ' Rosemount transmitters. After this upgrade, the instrument will be used as a Regulatory Guide 1.97 instrument. The range on the upgraded instrument will be 0-600 psig. A copy of the EOPs and Al-505 with the figuro used for plotting SCM are available in the main control room (MCR). The ASME steam tables are available in the MCR to support manual calculation of the SCM. The time to manually plot RCS pressure and temperature on the figure (the preferred c. method), and determine if adequate SCM is available, is estimated to be approximately one minute. The time to manually calculate the SCM using the steam tables is estimated to be approximately two minutes. ^

~'&,_. g NU 8f Nuclear Reguistory Cimm%sion? W .13F1097s270 Att: chm:nt A 1 Pcga 5 of 7 m y 1 ~ # ' ~ x .~ JK Y ;- Basia: ' The anticipated durations stated are based on the judgement of licensed and x Jk ' 3 1 experienced personnel in the CR 3 Operations department. ~ % f , ' id.i Licensed = personnellst.CR-3 receive classroom training on the determination of

1. 6 L subcooling margin by lesson plan ROT-2-34. _ Simulator training will be provided to all

?, licensed personnel'using a scenario in which all SCM oisplay is lost. This scenario-e Jwill reinforce the ability of the operating crew to handle this condition; Administrative- ~ ~ Fi,truction Al-505," Conduct of Operations During Abnormal and Emergency Events", c

pr. vides7 guidance. ton = conduct; of Operations personnelf during - abnormal and o

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events. ; A discussion of the actions to be taken to properly. handle a-

~ ^ condition in which all display of subcooling margin is lost will be added to Al 505. The LL - e ~ revision to Al-505 will be made and the simulator training on the loss of-SCM display y, scenario.will be given to all licensed personnel by December.4;- 1997. ~ Lesson ~ plan ROT-2-34, for classroom _ training, addresses _what SCM is, how it is - c njhn J expressed lwhy it is important, and indicates that conditions may exist when a manual A 7 calculation of SCM in the RCS is necessary. The lesson plan also addresses how yM,' the manual calculation of SCM is performed. Licensed personnel are tested on their s [s "' C @ ability to manually calculate SCM. r 1 W, ~ ( lC NRC Request ,l - 1 } , f..a$ ment F provides FPC's evaluation 'of tne SPDS against the design criteria of

• e ;

~ jf Regulatory; Guide (RG) 1_ g73 'Instrumentaticn for Light-Water-Cooled Nuclear Power Plants to As. ' Plant and Environs Conditions During and Following an Accident

• The l;~ f, des @n crketI in RG 1.g7 states that ' redundant ordiverse channels should be electrically independent and physicaMy separated kom each other and from equioment not classified Q$ 2 x

.knportantito sallety in:~accordance with RG;1.75,:' Physical Independence of Electrical Wy l }; Systems'." Please discuss howphysicalseparation forthe SPDScaNing willbe achieved. q ns v 3 ]f'* 'T p_pCER$pOh 2. ,&=_ ,g@jp 4 - ',EThe SPDS at CR-3 maintains separation of cables from the core exit thermecouples up l 1 to and including the isolation device.' The cabling from the isolation device to the displays 'is non-safety related and is not physically separated. The following information, presented %s, ? if lin the context of the information provided in'the July 29,1997, FPC letter to the NRC ~ dh 1"j@)l

(Refenence 1),9 provides the detailed response to this request. The following is an excerpt g

' ifrom?

Reference:

1,- Attachment F, page 5 'of_14,1The excerpt presents criterion 2 of Regulatory Guide 1.97pnd FPC's response to that criterion. 1 L"2.} Redundancyl ' 44 4. Ib _ G J+ qr! RG~ Recommendation ; !, y ;" x,'

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W e -? LNo single failure'within either the accident monitoring instrumentation, its w @a , auxiliary supporting features, or its power sources concurrent with the failures

that;are a condition or result'of 'a specific accident should prevent the J,

( foperators from,being presented the information necessary for them to s .~...........4.' _,,s ......_..m

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Attachmsnt A Paga 6 of 7 ,q+ g ~ ~ ' ^ determine the safety status of the plant and ti bring the plant to and maintain WA E'c fit in a safe condition following that accident. Ahere failure of one accident-(" 4 4 monitoring channel results' in information ambiguity (that is, the redundant L - f, displays disagree) _that could lead operators to defeat or fall to accomplish a required safety function,Ladditional_ information should be provided to allow 7the operators to deduceLthe actual conditions.in the plant. This may be ,, j i_ ^ t accomphshed by providing additional independent channels of information of- ^ =

the?same verlablei(addition of an-identical channel) or by providing _ an independent channel to: monitor-a different; variable that bears a known 4

4; ' relationship? toithec multiple; channels '(addition of' a diverse channel). 4 e;,J m a-t Redundant:or-diverse channels should be electrically independent and w' php6'.,Q separated from each other and from equipment not classified ( important to safety in accordance_with; Regulatory Guide 1.75, " Physical j + ~ y ? 4 1 Independence of Electric Systems,"_up to and including any isolation device. , Within each redundant division of a safety system, redundant monitoring - c 4~ channels are not needed except for steam generator level instrumentation in f two-loop' plants. f f " iDearea of Comohance JFulliSuhamonant to Modification) ~. 6 ,J _. ' lIn the~ final configuration, two independent channels of subcooling margin - = M(yf information are provided. The two channels will be electrically independent. b, < No_ single active component failure can result in the loss of both channels. 'T LinL theLevent-ofifailure Lof one of the channels' resulting:in ambiguous information, diverse.subcooling margin information is available from the use ~ f steam tables'using fully qualified and redundant pressure and temperature o indications."= e > eg y ~ [ 4 " hPC's Mito this recommendation of, Regulatory GuideJ1.97-'is:thatc-after the' te _ upgrade of SPDS is accomplished during Cycle 11 Refueling Outage, all of the instrument :

[ 7

+ loops,that feed into SPDS will. be environmentally qualified and meet the requirements of ~a*f a safety related instrument loop un to and includina the isolation devices This includes A physical _ separatior: of tho' cables. Downstream of the isolation device (i.e., from the N'

• isolation device to the displays) the signal cables will be routed to the SPDS Input / Output J(1/0) terminations! LThese-circuits-are non-safety related and are routed in non-safety related cable trays or conduitsi For this_ cabling, physical separation is not required and y,>,

> is not maintained. : The signal from the output of the isolators _to the displays is non-safety ..related..The proposedCN rade modification does not include upgrading these circuits to i Class 11E.1: However, the A Jnals are low voltage level (0 to 30 volts) thereby resulting in y7C (lowc potential for! electromagnetic : interference; between cables. Also, the cables are Pa considered passive devices up to the SPDS computers where the signals are designated _ ;e'i

asian ="A"fand;"B"ichannel and are maintained channelized up to the monitors

~ $(" channelized": indicates electrical separation but not physical separation). Failures of 4 ,,W passive devices (i.e;, cables) is not projected to occur. {Notei Negulatory Guide 1.75, " Physical Independence of Electrical Systems," is not part .- f of Crystal River's' Licensing Basis. In lieu of Reg. Guide 1.75, FPC employs the ipg., 7-A Electrical Design Criteria for Electrical Circuit Physical Separation and Cable Tray Loading; m ,u W/

U.S.: Nuclear Regulctiry Commissicn Attachment A 3F1097-27' Page 7 of 7 T RCS TEMPERATURE vs PRESSURE PLOT 2600 i e i l 'l .l' l l NORMAL POST l l-l l e TRIPWINDOW i e -a i

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i e ,i .i .i .i e i-i. i i i 2200 - - - - - - - -{ - - - - ;. - - - -l - - - l - - - l - - - - F - - ---; l l- ~l'NDT l. l l. l l l l. l CUFlVE l l l l l l l .2000 - - - - -l - - - - F - - - i. - - - - } _ -i- --!---i----l--- i---- -- i---- .i i e i. .ASCM i. i i i i. .i iCURV.E i i. i i i i 1800 .---j----p---q.---).----l ---p---q----y-y- -q-.-- .i i i i 1600 ---- ----*---*.----*.-- <----*---*----*---d-i i- .lvi.TtlRAL. -i i e e i e i [. 1400 - - - - - ' - - - - - L - 4GIRG ULATibN - ' -- --- r---4---- c r l

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l l CURVE l l l-i .i i i i - - - - i. - - - - l - - - i - - - - f - - - - l - - - } - - - 4. - - - F - - - -{ - - - - 1200 .i : i i i 1000 ----i----P.-- i-- ,'---i----t-- i.---- -- ,----t---i---- i i i .i e i. i. i 7 ano --..6.--a.. ..u-- a.---.---a.-- -i.. -a--- 6-- a.---- i i. i i-i i i _ e00

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. CURVE-.i e i i i i i i i i . - - - - - l. - - ;.. -. ' - - - 4. - - - ' -. -.. ' - - - 4. - - - l. - - - 4. - - - - 400= c r .i i i i e i i i - - - - i. - - - l-3. - - - - !- -3. - - l - - - i. - - - - F. - - - 4. - - - - ! - - - i. - - - - 200 i i i e i i e i - ~ i i 0 W 100 '200' 300 400 500 600 700 RCS TEMPERATURE B Acceptable region is:- Lo Below and._ to. the right of, the NOT curve lo? Above and-to the left of the adequate SCM curve o: Above and to the-left of the Nat Circ curve if RCPs are off and cooldown ' rate ;t 5'F/Khr

e.* -*-- ' U.S. Nuclear Regulatory Commusi:n _ Attachm:nt B 3F1097-27.. Page 1 of 1 i ATTACHMENT B COMMITMENTS - The following identifies those actions committed to by Florida Power Corporation (FPC) in this -document. Any other actions discussed represent intended or planned actions by FPC and are . described to the NRC Staff for their information and are not regulatory commitments. COMMITMENT ' COMMITMENT NUMBER DATE 3F1097-27-01 ' Provide simulator training to all licensed December 4,1997 personnel using a scenario in which all subcooling margin display is lost -3F1097-27-02 ' Revise Al-505 by adding a discussion of December 4,1997 specific actions to be taken to properly handle a condition in which all display of subcooling margin is lost i}}