Responds to NRC Generic Ltr 90-06, Resolution of Generic Issue 70, 'Power-Operated Relief Valve & Block Valve Reliability,' & Generic Issue 94, 'Addl LTOP for Lwr,' Per 10CFR50.54(f)| ML20065T228 |
| Person / Time |
|---|
| Site: |
Crystal River  |
|---|
| Issue date: |
12/20/1990 |
|---|
| From: |
Beard P
FLORIDA POWER CORP. |
|---|
| To: |
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
|---|
| References |
|---|
| REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI, TASK-070, TASK-094, TASK-OR 3F1290-07, GL-90-06, NUDOCS 9012270369 |
| Download: ML20065T228 (9) |
|
|
|---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217F9941999-10-15015 October 1999
Discusses FPC 970819 Request for Temporary Relief from ASME Code Section XI Requirements to Repair ASME Class 3 Nuclear Service & Decay Heat Sea Water System Piping.Forwards SE Containing Results of Staff Review
ML20217J5171999-10-13013 October 1999
Informs That on 990930,NRC Staff Completed mid-cycle PPR of Plant,Unit 3 & Did Not Identify Any New Areas That Warranted More than Core Insp Program.Previously Planned Regional Initiative Insp of safety-related Mod Will Be Performed
3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999
Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed
3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999
Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made
ML20212L0771999-10-0404 October 1999
Forwards SER Accepting Licensee Relief Requests 98-012 Through 98-018 Involving Containment Insps at Crystal River Unit 3 Pursuant to 10CFR50.55a(a)(3)(i) & 10CFR50.55a(a)(3)(ii)
ML20217D6551999-10-0101 October 1999
Requests That Natl Communication Sys Arrange for Licensee Participation in Government Emergency Telecommunications Service,Per NRC Info Notice 99-025
ML20212J8481999-10-0101 October 1999
Forwards Safety Evaluation Re Second 10 Yr Interval ISI Program Requests for Relief 98-009-II.Reliefs Granted for 98-009-II,Parts B & C & 98-010-II & 98-011-II
3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999
Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment
3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999
Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331
ML20212F7251999-09-23023 September 1999
Discusses Staff Review of Util 980330 Response,As Suppl on 990514,to GL 97-06, Degradation of SG Internals. Staff Concludes That Licensee Responses to GL Provide Reasonable Assurance That Condition of SG Internals Acceptable
ML20212F7331999-09-23023 September 1999
Discusses Util Licensing Action for GL 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants. NRC Ack Efforts Util Completed to Date in Preparing Crystal River,Unit 3 for Y2K Transition
3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999
Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46
ML20212E6741999-09-21021 September 1999
Forwards Safety Evaluation Accepting Proposed EAL Changes Submitted by ,As Supplemented by 981120,990713 & 0831 Ltrs,Incorporating Guidance in NUMARC/NESP-007,Rev 2, Methodology for Development of Eals
3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999
Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)
3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999
Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief
ML20212F3141999-09-13013 September 1999
Forwards Insp Rept 50-302/99-05 on 990704-0814.Violations Noted,But Being Treated as non-cited Violations
ML20211L9081999-09-0303 September 1999
Informs of Completion of Licensing Action for GL 92-08, Thermo-Lag 330-1 Fire Barriers, Dtd 921217,for Crystal River Unit 3
ML20211Q7581999-09-0101 September 1999
Forwards Summary of 990812-13 Training Managers Conference in Atlanta,Georgia Re Recent Changes to Operator Licensing Program.List Conference Attendees,Copy of Presentation Slides & List of Participant Questions Encl
3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999
Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals
ML20211G7111999-08-30030 August 1999
Modifies Approval of 980521 Request for Exception to 10CFR50.4(b)(6) & Grants Util Approval to Submit Copies of Future Updates to FSAR as Listed
ML20211G7031999-08-30030 August 1999
Informs of Approval of Util 980521 Request for Exception to 10CFR50.4(b)(6),allowing Util to Submit Updates to Plant Ufsar.Ltr Modifies That Approval & Grants Util Approval
3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999
Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002
ML20212C1351999-08-27027 August 1999
Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input
3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999
Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71
3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999
Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3
3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999
Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05
3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999
Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal
3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999
Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2
3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999
Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value
05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999
Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented
ML20210Q4511999-08-0505 August 1999
Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006
ML20210P0741999-08-0505 August 1999
Forwards SE Accepting Licensee 980416 & 1130 Ltrs Re Third 10-year Interval ISI Program Plan & Associated Requests for Relief for Plant,Unit 3
3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999
Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603
ML20210G8551999-07-27027 July 1999
Forwards Insp Rept 50-302/99-04 on 990523-0703.One Violation Identified & Being Treated as Noncited Violation
3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999
Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments
ML20209H5211999-07-16016 July 1999
Forwards Request for Addl Info Re Licensee Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in CR-3 once-through Steam Generators in Order to Complete Review
ML20209G3231999-07-15015 July 1999
Forwards Biological Opinion Issued by Natl Marine Fisheries (NMFS) of Dept of Commerce.Nmfs Concluded That Operation of Cw Intake Sys of Crystal River Not Likely to Jeopardize Existence of Species Listed in Biological Opinion
ML20209G3481999-07-15015 July 1999
Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon
3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999
Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl
3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999
Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl
3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999
Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl
3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999
Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730
3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999
Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held
3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999
Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21
3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999
Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21
ML20196L1261999-07-0707 July 1999
Discusses Closeout of TAC MA0538 Re License Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity, Issued on 950519 to Plant,Unit 3
3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999
Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3
ML20196J4991999-07-0101 July 1999
Advises That Info Contained in ,Which Included TR BAW-2346P,will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5)
ML20209C0811999-06-25025 June 1999
Forwards Overdue Controlled Document Transmittals for Listed Documents
3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999
Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl
1999-09-03
[Table view]
Category:INCOMING CORRESPONDENCE
MONTHYEAR3F1099-14, Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed1999-10-13013 October 1999
Requests Copy of NRC Radtrad Code & Copy of User Instructions.Conditions for Receiving Code Listed
3F1099-11, Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made1999-10-0404 October 1999
Provides Info on Requested Minor Permit Mod of Encl NPDES Permit.No New Regulatory Commitments Are Made
3F0999-03, Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment1999-09-27027 September 1999
Notifies of Approved Change to NPDES Permit Applicable to Crystal River Unit 3 IAW Section 3.2.3 of Epp.Proposed Change Was Approved on 990914 by State of Fl & Provided in Attachment
3F0999-18, Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 0003311999-09-27027 September 1999
Notifies NRC That Due Date for Commitment Common to Ltrs 980115 & 980209 Will Be Extended.Revised Completion Date for Cable Ampacity Project Is 000331
3F0999-20, Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-461999-09-21021 September 1999
Forwards Summary Re Justification to Defer USI A-46 Commitment,Per Work Needed to Resolve GL 87-03, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Usi A-46
3F0999-01, Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)1999-09-17017 September 1999
Forwards FPC Crystal River Unit 3 Plant Reference Simulator Four-Year Simulator Certification Rept Sept 1995-Sept 1999, Per 10CFR55.45(b)(5)(ii) & 10CFR55.45(b)(5)(iv)
3F0999-19, Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief1999-09-15015 September 1999
Provides Clarification of Minor Inconsistency Identified During Review of NRC SE for Plant Third 10-year Interval Inservice Insp Program Plan & Associated Requests for Relief
3F0899-23, Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals1999-08-31031 August 1999
Provides Addl Info in Response to Several NRC Staff Questions Needed to Complete Review of Request to Adopt NEI 97-03,Draft Final Rev 3, Methodology for Development of Eals
ML20212C1351999-08-27027 August 1999
Requests Withholding of Proprietary Version of Enhanced Spent Fuel Storage Project Engineering Input
3F0899-07, Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 20021999-08-27027 August 1999
Provides Formal Notification to NRC of FPC Plans Relative to Renewal of Crystal River Unit 3,FOL DPR-72.FPC Plans to Submit Application for License Renewal by End of 2002
3F0899-20, Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.711999-08-26026 August 1999
Forwards six-month fitness-for-duty Program Performance Data for Period 990101-990630,IAW 10CFR26.71
3F0899-05, Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 31999-08-20020 August 1999
Forwards Response to NRC 990716 RAI Re Proposed Alternate Repair Criteria for Axial Tube End crack-like Indications in Crystal River Unit 3
3F0899-16, Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal1999-08-19019 August 1999
Informs That Licensee Is Requesting State of Fl Dept of Environ Protection to Make Changes in Plant NPDES Permit to Modify Conditions on Use of Biocide in Instrument Air Compressor Sys.No New Commitments Are Made in Submittal
3F0899-17, Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-051999-08-19019 August 1999
Submits Relief Request 99-0001-RR,seeking NRC Approval for Evaluation Performed by Util on through-wall Flaw in Nuclear Svc & Decay Heat Sea Water (RW) Sys,Per Guidance of GL 90-05
3F0899-02, Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 21999-08-16016 August 1999
Forwards Rev 2 to Cycle 11 COLR IAW Plant TS Section 5.6.2.18.Rev 1 of Cycle 11 COLR Was Not Submitted Due to Administrative Error.Changes Made in Rev 1 Listed & Incorporated in Encl Rev 2
05000302/LER-1997-038, Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented1999-08-13013 August 1999
Forwards LER 97-038-01,IAW 10CFR50.73(c).Submittal Also Provides Notification That Commitment Common to LER 97-038-00 & Reply to NOV 50-302/97-16 Has Been Revised & Revised Commitment Has Been Implemented
3F0899-06, Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value1999-08-13013 August 1999
Forwards Monthly Operating Rept for July 1999 for Crystal River,Unit 3,per ITS 5.7.1.2.Revised Repts for Apr,May & June 1999,also Encl.Data on Line Item 6 Updated to Agree with More Accurate Computer Point That Measures Value
3F0799-30, Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 9906031999-07-29029 July 1999
Forwards List of Licensing Actions Currently Estimated for Fys 2000 & 2001,in Response to Administrative Ltr 99-02,dtd 990603
3F0799-09, Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments1999-07-19019 July 1999
Provides Response to NRC 990625 Telcon RAI Re Util Use of Relief Request 98-009-II for Plant ASME Section XI, Inservice Insp Second Interval.Ltr Established No New Regulatory Commitments
ML20209G3481999-07-15015 July 1999
Transmits Natl Marine Fisheries Svc (NMFS) Biological Opinion Based on Review of Continued Use of Cw Intake Sys at Crystal River Energy Complex.Concludes That Continued Use of Cw Intake Sys Not Likely to Adversely Affect Gulf Sturgeon
3F0799-25, Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl1999-07-14014 July 1999
Forwards License Renewal Applications for Four Individuals, IAW 10CFR55.57.Without Encl
3F0799-21, Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl1999-07-14014 July 1999
Forwards Copy of Revised NPDES Permit IAW Section 3.2.3 of Unit 3 Environ Protection Plan,Per 990430 Request to Allow Use of Biocide in Station Air Compressor Cooling Sys. Wastewater Permit FL0000159 Issued 990630 Also Encl
3F0799-05, Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl1999-07-14014 July 1999
Requests Exemption from 10CFR70.51, Matl Balance,Inventory & Records Requirements, as It Relates to 10CFR70.51(d) Re Physical Inventory of SNM for Crystal River Unit 3.Detailed Justification for Request,Encl
3F0799-26, Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 9907301999-07-14014 July 1999
Provides Notice of Change in Status for Senior Operator,Iaw 10CFR50.74(a).RD Demontfort,License Number SOP 20528-2,has Been Reassigned & No Longer Requires License Effective 990730
3F0799-22, Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held1999-07-13013 July 1999
Provides Update & Rev to Submittal Made by Util Ltr with Regard to EAL Classification Methodology for Unit 3.Reponses to NRC Staff Questions Provided as Attachment D to Ltr & Reflects Discussions Held
3F0799-02, Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999
Submits Rev 7-3 to Physical Security Plan,Replacing Current Rev to CR-3 Physical Security Plan,Rev 7-2,in Entirety.Rev Withheld,Per 10CFR73.21
3F0799-03, Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.211999-07-0808 July 1999
Forwards Rev 5-0 to Safeguards Contingency Plan,Replacing Current Rev to Safeguards Contingency Plan,Rev 4,in Entirety.Rev Withheld,Per 10CFR73.21
3F0799-10, Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 31999-07-0707 July 1999
Submits Copy of Historical NPDES Permit Rev That Was Made in 1997 Re Use of Biocide at Crystal River Unit 3
ML20209C0811999-06-25025 June 1999
Forwards Overdue Controlled Document Transmittals for Listed Documents
3F0699-12, Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested1999-06-23023 June 1999
Provides Suppl Info for LAR 240,rev 0 & Pump Curve for EFP-3 to Facilitate Review,As Requested
3F0699-06, Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl1999-06-23023 June 1999
Submits Final Response to GL 98-01,Suppl 1 Re Year 2000 Readiness of Nuclear Power Plants.Year 2000 Readiness Disclosure for Crystal River,Unit 3,encl
3F0699-08, Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments1999-06-21021 June 1999
Provides Updated Info to Licensee Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions. Ltr Establishes No New Regulatory Commitments
3F0699-09, Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl1999-06-0404 June 1999
Forwards FPC 1998 Annual Financial Repts for Two Participating co-owners of Crystal River Unit 3.Financial Statements & Independent Auditors Repts for City of Alachua,Fl,Encl
3F0599-21, Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads1999-05-28028 May 1999
Submits Addendum to B&W Owners Group Topical Rept BAW-2346P, Rev 0.Addendum Includes Leak Rate Values Based on CR-3 Plant Specific Main Steam Line Break Tube Loads
3F0599-10, Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl1999-05-26026 May 1999
Submits Changes Made to Crystal River,Unit 3 Its,As Required by ITS 5.6.2.17.Encl Provides Revs to Plant ITS Bases That Will Update NRC Copies of Its.Instructions for Updating ITS, Encl
ML20207E4341999-05-25025 May 1999
Submits 30-day Written Rept on Significant PCT Changes in ECCS Analysis for ANO-1.CRAFT2 Limiting PCT for ANO-1 Was Bounded by 1859 F PCT Calculated at 2568 Mwt for Crystal River 3 Cold Leg Pump Discharge Break Size of 0.125 Ft
3F0599-22, Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs1999-05-21021 May 1999
Forwards non-proprietary Version of B&Wog Topical Rept BAW-2346NP, Alternate Repair Criteria for Tube End Cracking in Tube-to-Tubesheet Roll Joint of Once-Through Sgs
3F0599-18, Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM1999-05-14014 May 1999
Forwards 1998 Annual Radiological Environ Operating Rept for Crystal River,Unit 3. Rept Is Submitted in Accordance with CR-3 ITS 5.7.1.1(b) & Section 6.6 of ODCM
3F0599-17, Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments1999-05-14014 May 1999
Submits Update Response to GL 97-06, Degradation of SG Internals. Ltr Establishes No New Regulatory Commitments
3F0599-07, Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 19781999-05-14014 May 1999
Submits Guarantee of Payment of Deferred Premiums for CR-3 in Accordance with 10CFR140.21.Internal Cash Flow Projection Was Prepared in Accordance with Suggested Format Outlined in Reg Guide 9.4 Dtd Sept 1978
3F0599-03, Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR1999-05-12012 May 1999
Provides Update Curves for Facility Pressure/Temp Limits Rept,Rev 2 & Updated Rev Bar ITS Pages Associated with LAR, in Response to NRC RAI Re Subject LAR
3F0599-05, Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl1999-05-12012 May 1999
Responds to 990402 RAI Re Third 10-year Interval ISI Program Plan Requests for Relief.Util Revised Relief Requests 98-010-II,98-003-PT,98-005-PT & 98-001-SS Based on Responses to Rai.Revised Relief Requests Encl
3F0599-08, Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments1999-05-0303 May 1999
Forwards Licensee Clarification of Info Provided in Amend 171 Re post-LOCA Boron Dilution Precipitation Prevention.Ltr Establishes No New Regulatory Commitments
3F0599-09, Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 19981999-05-0101 May 1999
Forwards Crystal River Unit 3 Radioactive Effluent Release Rept - 1998 & Revised Crystal River Unit 3 Radioactive Effluent Release Rept - 1997. Licensee Informs That ODCM & PCP Were Not Revised During 1998
3F0499-24, Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent1999-04-30030 April 1999
Forwards Summary of Proposed Changes to Crystal River,Unit 3 NPDES Permit,That Are Being Submitted to Florida Dept of Environ Protection.Proposed Change Will Allow Use of Scale Inhibitor,Biocides & Foam Control Agent
3F0499-09, Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 9907301999-04-30030 April 1999
Forwards FPC Annual Financial Rept & Annual Financial Repts for Eight of Ten Participating co-owners of Crystal River Unit 3 Nuclear Station.Outstanding Annual Financial Rept Will Be Submitted by 990730
3F0499-23, Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements1999-04-23023 April 1999
Submits Repts Required by App B,Environ Protection Plan,Of Crystal River,Unit 3 Operating License.Fl Dept of Environ Protection Has Provided Clarification Re Ph Monitoring Requirements
3F0499-18, Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl1999-04-20020 April 1999
Informs of Recent Senior Management Change at Fpc,Which Will Not Affect Std Recipients of Incoming NRC Correspondence. Updated Util Mailing List,Encl
3F0499-05, Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin1999-04-16016 April 1999
Forwards Rev 19 to Radiological Emergency Response Plan. Changes to Plan Marked with Vertical Bars in Left Margin
3F0499-08, Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 19981999-04-16016 April 1999
Forwards FPC Annual ITS Dose Rept for Period Jan-Dec 1998. Rept Provides person-rem Radiation Exposures,According to Work & Job Function,At CR-3 for Period Jan-Dec 1998
1999-09-27
[Table view] |
Text
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,e Florida Power
' Do ket No. 50 302 Crystal River Unit 3 December 20, 1990 3F1290-07 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Response to NRC Generic Letter 90-06, _ Resolution of Generic Issue 70; " Power-0perated Relief Valve and Block Valve Reliability," and Generic Issue ~ 94, " Additional low-Temperature Overpressure 4
Protection for Light-Water Reactors," Pursuant to 10 CFR 50.54(f).
Dear Sir:
Florida Power Corporation (FPC) submits the attached response to Enclosure A of Generic letter 90-06 as requested in your June 25, 1990 letter. (Enclosure 8 recommendations of- 90-06 are not applicable to_ B&W-designed plants such as Crystal River Unit 3 (CR-3) and are not addressed in this response). Enclosure A makes specific recommendations intended to result in improved reliability of the ' Power-0perated Relief Valve (PORV) and its associated block valve. FPC concurs with the majority of the recommendations, but two recommendations are
' considered inappropriate for CR-3. These are discussed below and detailed in the attachment to'this letter.-
o .The recommendation for stroke-testing of the PORV in all cases prior to establishing: conditions. where it is used for low-temperature overpressure protection'(LTOP) is unnecessary and results in adverse
" side" effects. :. These effects include the increased potential for
- PORV -leakage and additional thennal cycles applied to the pressurizer surge line.- (These effects -have been previously addressed by FPC's response to other NRC initiatives). Thus, this testing requirement is not being added.
o The - . recommendation for - a technical specification shutdown requirement in response to PORV or block valye inoperability is not warranted.- .The requirement would likely result in a substantial financial burden. with little resultant risk reduction. Forced shutdowns of. the unit should be limited to situations for which continued : operation cannot be permitted in order to ensure the health and. safety of the public.
9012270369 901220
{DR ADOCK 05000302 O PDR l POST OFFICE BOX 219
- CRYSTAL RIVEH, FLORIDA 326290219 + (904) 563 2943
'O{P1Q']
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A Florida Progress Cornpany ll
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- NRC Document ' Control Desk December 20,-1990 ~
Page 2 This !s- not the case for an-inoperable PORV or block valve.
In fact,- forcing the unit to shutdown creates the potential for additional transients. Probabilistic assessments (which consider risk:due to plant operation in the LTOP region with an inoperable PORV) would likely demonstrate an increase in risk (decrease in a safety) due to the proposed shutdown requirements. Therefore, FPC does not intend to include additional shutdown requirements for the !,
PORV and block valve'in the CR-3 Technical Specifications. ,
FPC is concerned that Generic Letter 90-06 contains new NRC Staff positions which '
are: inconsistent with FPC's. understanding of existing NRC policy. The ;
application of the NRC Interim Policy on Technical Specification Improvement is one example. Generic Letter 90-06 recognizes the' PORV may not-be the crimary means of mitigating any design basis accident, but still applies Criterion 3 of the Interim Policy as justification of the recommendations. This application is contrary to .the stated purpose of technical specification improvcment and .
-NRC/ industry efforts _to develop a consistent criteria for the content.-- of-technical' specifications. The attachment to this letter further discusses this issue.
Sincerely,
\
.M.[ Beard,Jr.
Senior Vice. President ~
Nuclear Operations-
-PMB:BPW'-
. Attachment-k =xc: Regional Administrator, Region II Senior Resident Inspector
'NRR-Project Manager-L i.
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t
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a *
. STATE OF FLORIDA-COUNTY OF CITRUS
.P. M. Beard, Jr. states that he is the Senior Vice President, Nuclear Operations for Florida Power Corporation; that he-is authorized on the part of said company to. sign j 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.
l 's P. M. Beard, Jr.
Scnicr Vice President Nuclear Operations Subscribid andL sworn .to. me,- a Notary Public in and for -the State and County above named,.this 20th day.of' December, 1990, c- A Notary Public NOT ARY PUStic, STATE OF FLORIDA AT LARM ~
< W :'4 RIBS 60N EXPIRES OCL 10, Ni:2 Notary Public, State of Florida at Large MyfCommission_ Expires: b /1, / 9 4 v
-i l
ss Attachment to letter 3F1290 07
- December 20, 1990
- page 1
Introduction:
Generic Letter 90-06, dated June 25, 1990 contained the NRC Staff. positions which resulted in the resolution of Generic Issue 70 " Power-0perated Relief Valve and ~ Block Valve Reliabili ty. " The generic letter concluded that improvements in the reliability of the PORV and block valve could have a significant impact on plant safety. This conclusion was based upon the current agency understanding of the PORV's role in accident mitigation. Generic Letter 90-06 also made several recommendations. intended to result in improvements in valve reliability. The Florida Power Corporation (FPC) response to the specific recommendations of NRC Generic letter 90-06 is as follows: t Recommendation 1:
. Include PORV and block valve within the scope of an operational quality assurance program that is in compliance with 10 CFR Part 50, Appendix B. This
. program should include- the following elements:
- a. The addition of PORV and block valve to the plant operational Quality
- Assurance List.
- b. Implementation of a maintenance / refurbishment program for the PORV and block valve that is' based on manufacturer's recommendations or guidelines and is implemented by trained plant maintenance personnel,
- c. When replacement ^ parts and spares, as well as complete components,. are required for existing non-safety-grade PORVs .r.d block valves (and
' associated control systems), it is the intent of this gueric letter that these items may be procured in'accordance with the origin d construction-
- l. codes and standards.
I FPC Resoonse:
h a. The power-operated relief valve (PORV) and its associated block: valve are classified as safety-related components in the CR-3 Configuration l Management Information ' System (CMIS). The - CMIS serves as the plant
! .-operational quality assurance list for CR-3. Electrical portions of the CR-3 PORV and block valve- (power and controls) -were - not- originally designed as safety-related. As a: result,-control circuitry for-the PORV is non-1E and -the' motor operator for the block-. valve is non-safety rel ated. The motor operator for the block . valve has subsequently been envi_ronmentally qualified (EQ) -Appropriate levels of the CR-3 quality
-ussurance program are applied to these portions of the valves.
- b. Safety-related valves are only -sent to approved vendors.=for repairs or refurbishment. The manufacturers of the PORV (Dresser Industries Inc.)
and the block valve (Velan Engineering) are on the list of FPC-approved vendors for performing these activities. FPC-approved nuclear vendors
-have approved 10 CFR 50 Appendix B programs and undergo periodic FPC o
. . , . -,-y e , v. - _ -, - , . , - . e._- ___m, - _ - _ - - . _
Attachment to letter 3F1290-07 December 20, 1990 page 2 audits of their programs. FPC also periodically performs an additional step of sending inspectors to the vendor installation to verify critical manufacturing steps are assured in the course of work on these valves.
Maintenance activities conducted by FPC personnel on-site are based on the manufacturer's recommendations and guidelines and are implemented through controlled procedures by trained plant personnel.
- c. Replacement parts and spares for the PORV and block valve will be procured in accordance with the original construction codes and design standards.
Recommendation 2:
Include the PORV and block valve within the scope of a program covered by Subsection IWV, " Inservice Testing of Valves in Nuclear Power Plants" of Section XI of the ASME Boiler and Pressure Vessel Code,
- a. Stroke testing of the PORV should only be performed during Mode 3 (HOT STANDBY) or Mode 4 (HOT SHUTDOWN) and in all cases prior to establishing conditions where the PORV is used for low-temperature overpressure protection. Stroke testing of the PORV should not be performed during power operation,
- b. The PORV block valve should be included in the licensees expanded MOV test program discussed in Generic Letter 89-10 " Safety Related Motor L Operated Valve Testing and Surveillance," dated June 28, 1989.
FPC Resoonse:
The PORV and block valve are included in the FPC Inservice Inspection - Pump I and Valve Program for CR-3. This program has been developed to implement the requirements of.10 CFR 50.55a(g) and Section XI of the ASME Boiler and Pressure-l- Vessel Code (hereafter referred to as "the Code").
- a. Recommendation 2.a above is an exception to Section XI, Subsection l
IWV-3411 of the Code. This subsection requires all Category A and B valves be exercised at least once every three months, except as provided by IWV-3412(a), etc. IWV-3412(a) states that valves that cannot be exercised during plant operation shall be full-stroke exercised during cold shutdowns. FPC satisfies the intent of the Code (and the generic letter) by performing a procedurally-required stroke test of the PORV during each plant heatup from cold shutdown. This is performed with the plant in MODE 3 (HOT STANDBY). The recommendation to stroke test the PORV in all cases prior to entering the low-temperature overpressure protection (LTOP) mode is an LTOP-driven recommendation directly related to the need to have the PORV available for LTOP. Applying this recommendation to B&W-designed plants such as CR-3 is somewhat inconsistent with the balance of Generic Letter 90-06. Generic Letter 90-06 specifically states LTOP recommendations of the letter - i.e. the resolution of Generic Issue 94 - are not applicable to B&W-designed
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c Attachment to' letter 3F1290-07
-December 20,-1990
=page~3 plants. FPC has submitted a CR-3 LTOP Features technical specification
.to the NRC.as part of Technical Specification Change Request 174, dated October 31, 1989. The proposed technical specification contains operability requirements for the PORV-while the plant is operated in the LTOP region,'and includes appropriate surveillances to verify operability of -the valve. ,
Apart from the applicability issue of this recommendation, FPC has ,
4 additional concerns with unnecessarily cycling the PORV. Operating history has shown a. limited number of PORY cycles are available before valve. seat leakage begins--to develop. Thus, the proposed increased exercising may actually result in a decrease in PORV availability, .since dependent- upon the amount of the leakage, - valve isolation or refurbishment becomes necessary. Further, cycling the valve is inconsistent with NRC Bulletin 88-11 " Pressurizer Surge Line Thermal Stratification." Each time the PORV is opened, there is an insurge of reactor coolant .into tho' pressurizer. The more frequently the valve is cycled, the greater the number of. thermal cycles applied to the surge
.line. Based upon the reasons given, FPC will not add the requirement for stroke testing the PORV in all cases prior to establishing conditions for
~
LTOP.
b.. The .-block valve has been included in the motor-operated valve test program developed in response to Generic-Letter 89-10. Actual testing of the= block- valve will be performed -in accordance with the schedule contained-in'FPC's Generic > Letter 89-10-response..
Recommendation'3:-
for operating-PWR plants, modify the limiting conditions of operation of the .
PORV' and block? valve in the technical specifications for MODES 1,2, and 3 to .
-incorporate the position ~ adopted by-the staff- in-recent licensing actions.-
FPC ReSDonse:'
Recommendation number 3 proposes several- significant changes to the content of the CR-3 Technical! Specification for the PORV and block valv'e. These changes:
Lwould require:
a' .. a revision to' the required action end-state (the plant conditions the '
-operator is directed- to- in the event of a technical specification-required = shutdown),
l b. faddition of a surveillance requirement to exercise the PORV through one L ? complete- cycle every 18 months,
- c. maintenance of power to the block valve when it is used to isolate an inoperable PORV, and
- d~. additional shutdown requirements for the PORV and block valve.
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a Attachment to letter 3F1290-07 L December 20, 1990 page 4 Current CR-3-Technical Specifications contain limiting conditions of operation (LCOs) for the PORV and its associated block valve. -The CR-3 specification is identical to the corresponding B&W Standard Technical Specification (STS) as it _ appears in NUREG 0103 Revision 4, with the exception of a surveillance requirement.which is not applicable to the CR-3 design. The CR-3 specification is also 'very similar to the B&W Revised STS version being developed for the Technical Specification Improvement Program (TSIP). The specification, which contains no shutdown requirements for an inoperable PORV or block valve, has been reviewed by the NRC Staff as part of TSIP, with no discrepancies or open items yet_ identified.
Proposed, changes a through c above are considered to be general improvements to the specification and will be incorporated into the CR-3 specification as part of TSIP.- CR-3 -is tt.e lead plant for the B&W Owner's Group technical specification improvement effort with implementation tentatively scheduled for the Cycle 8 refueling cutage (October 1992). This schedule is consistent with the requested schedule for . implementing changes to the technical specifications as a result of the generic letter.
- Proposed change ."d" regarding additional si,utdown requirements for the PORV and block valve has been' reviewed and is considered inappropriate for CR 3, This conclusion is based upon the following
o The proposed shutdown requirements may result in a decrease in the level
- of reactor safetyi The proposed requirements mandate the plant be placed
~
in. MODE 4 Triot: Shutdown) due to an inoperable PORV or block valve. This action is in response to safety concerns due to a Steam Generator Tube Rupture (SGTR)-or an event requiring feed-and-bleed cooling but creates the potential for another transient. - In this region of plant operation,
.the PORV_.is relied: upon to provide low temperature overpressure protection -(LTOP)- for the reactor: coolant system. -Industry experience has'shown the probability of an LTOP event is greater than that of a SGTR or an- event requiring feed-and-bleed cooling. Thus, a p1 ant in this degraded condition (inoperable PORV or block valve) is placed in a region where the_ probability of a - safety-related- challenge to the -PORV is increased.
-o Applying the NRC_ Interim Policy Statement on Technical Specification Improvement (hereaf ter referred to as:"the Policy") on a -plant-specific
-basis' does not- support the proposed snutdown requirements. Two - PORV -
accident mitigation " functions" were considered: the secondary role of-the -PORV in SGTR mitigation and the use of the PORV as part of High
' Pressure Injection / PORV cooling capability- (feed-and-bleed). Our assessment. focusses primarily on feed-and-bleed cooling. This is due to the -importance the NRC placed -on this capability to justify the recommendations of the generic letter. NUREG 1316 (page xi) acknowledged
-that without consideration of this capability, the recommendations of Generic Letter 90-06 were not justified by regulatory analysis.
l
. l Attachment to letter 3F1290 07 December 20, 1990 page.5 The Policy gives specific criteria to be used in determining the content of technical specifications. The two criteria which relate indirectly to PORV accident function are Criterion 3 (primary success path for accident mitigation) and the risk-significant provision.
The stated intent of Criterion 3 is to capture into technical specifications, those structures, systems, and components that are part
- of the primary success path of a safety ;equence analysis. PORV operation is not r,ssumed as part of the primary success path for any CR-3 design basis accident. Neither the CR-3 FSAR or the NRC Operating License-stage Safety Evaluation Report (SER) address the need for PORV operation to mitigate a SGTR or for feed-and-bleed cooling.
The risk-significant provision of the Policy requires that structures, systems, and components which cperating experience and PRA have shown to be significant contributors to the plant's overall core melt probability and risk be included in technical specifications. The CR-3 Probabilistic Risk Assessment (PRA) demonstrates that the expected. improvements in PORV reliability do not have a significant impact on core damage frequency at CR-3. The-reduction in risk due to the estimated improvements in PORV and block valve reliability is minimal. The CR-3 PRA indicates, assuming the an optimistic resulting decrease75% increase in core in PORV damage frequency and block valve is approximately 4.5x10' reliability, th year. This is equiva per year to 1.455x10'}ent to a and per year, 3% decrease - from is due to the role approximately of the PORV in 1.5x10' depressurization during a steam generator tube rupture event.
Enhancement of feed-and-bleed cooling has no effect on core damage frequency for CR-3.
Since use of the PORV in SGTR mitigation and feed-and-bleed cooling fails to satisfy either Policy selection criteria for CR-3, changes to the current technical specification based upon these capabilities would be inconsistent with TSIP.
o The use of feed-and-bleed cooling to justify regulatory requirements is inconsistent with other NRC Staff licensing actions. The generic letter recognizes that feed-and-bleed cooling is beyond design basis and is not, strictly speaking, within the scope of this issue. However, this L capability has been largely used to justify the recommendations of the generic letter and the resolution of GI-70. An example of other uses of feed-and-bleed cooling in licensing actions is the NRC SER written on the Resolution of GI-124. Auxiliary Feedwater System Reliability for CR-3.
The SER stated that " uncertainties about the operator's decisional,
, procedural, and performance abilities under stress, do not permit
! crediting feed-and-bleed as a reliable compensatory decay heat removal I feature for resolution of GI-124. These uncertainties and concerns L regarding intentional release of reactor coolant into the containment, l cannot justify this method of removing decay heat as a suitable compensatory feature." This is contradictory to the use of feed-and-bleed capability in the regulatory analysis for Generic letter 90-06.
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4 j
Attachment to letter 3F1290-07 December 20, 1990 page 6 o There is a _high potential for substantial costs in replacement power due -
to outages.resulting from the proposed shutdown requirements. There have been three failures of the- PORV and two failures of the block valve at CR-3 during the period from September 1978 to January 1988. _W hile none .
of -these failures occurred during power operation,. had they occurred under the ' proposed -technical specifications, CR-3 would have had - to i shutdowri, In order to restore the valves _to operability,- the unit would likely have to .be placed in cold shutdown-(MODE 5) due to the environmental conditions in the general area of the valves. Such an outage would be expected to typically last a minimum of 10 days (costing-7-10 million dollars in terms of- replacement power costs). -This information has been omitted from the NUREG 1316 cost / benefit analysis performed to , justify the proposed recommendations.
Conclusion:
- .l Im'plementation- of Recommendations 1, 2, and 3 a-c, are considered sufficient to -result in the reduction in risk potential sought by the NRC in Generic Letter 90-06. . Based _upon the actions taken and the.-concerns discussed above,
-shutdown requirements for the PORV and block valve will not be added to the CR-3 Technical Specifications.-
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