3F1297-19, Application for Amend to License DPR-72,proposing Changes to Improved TSs for CREVS & to Vftp.List of Commitments,Summary of Changes,Reason & Justification for Request,Control Room post-accident Dose Calculations & Analysis Also Encl

Application for Amend to License DPR-72,proposing Changes to Improved TSs for CREVS & to Vftp.List of Commitments,Summary of Changes,Reason & Justification for Request,Control Room post-accident Dose Calculations & Analysis Also Encl

ML20202G826
Person / Time
Site:	Crystal River
Issue date:	12/05/1997
From:	Richard Anderson FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202G831	List: 3F1297-19, Application for Amend to License DPR-72,proposing Changes to Improved TSs for CREVS & to Vftp.List of Commitments,Summary of Changes,Reason & Justification for Request,Control Room post-accident Dose Calculations & Analysis Also Encl ML20202G851
References
3F1297-19, NUDOCS 9712100117
Download: ML20202G826 (12)

Text

, y . ...

Florida Power I,U%2".TI v

owe am December 5,1997

.W1297419 U S Nuclear Regulatory Commission Attu: Docurnent Control Desk Washington, DC 20555 0001

Subject:

License Amendment Request #222, Revision 0 Coittroi Room Emergency Ventilation and Emergency Filters Refe ences: 1. FPC to NRC letter,3F1197 09, dated November 10,199'/

2. FPC to NRC letter,3F0687 16, dated June 30,1987 l

. 3. FPC to NRC letter,3F0588 10, dated May 23,1988

4. NRC to FPC letter,3N0589 25, dated May 25,1989 3

4 Dear Sir; l

The purpose of this letter is to submit Florida Power Corporation's (FPC's) License Amendment Request (LAR) #222, Revision 0, regarding proposed amendments to Operating License No.

DPR-72 for Crystal River Unit 3 (CR.3) The attached LAR proposes changes to the Improved Technical Specifications (ITS) for the Control Room Emergency Ventilation System (CREVS) and to the Ventilation Filter Test Program (VFTP). The LAR also submits for NRC review and approval the methodology used to determine control room doses to address the unreviewed safety question related to the changes to the determination ofinleakage for control room habitability.

. This liicludes information that was identified in Reference 1 as under development regaiding Control Complex liabitabihty Envelope (CCilE) seconda y leakage etrects, nd analysis inputs )

changed from those provided in References 2 and 3. ,

l I

-The LAR proposes to: 7t

1. establish a new ITS Surveillance Requirement in ITS 3.7.12 for the performance of a periodic integrated leak test of the CCllE boundary,

2. revise ITS 13ases 3.7.12 to define operability of the CCHE and describe the proposed i Th% Q 1 new surveillance requirement, and 9712100117 971205 p

M MOCK osoooao:a lh: , lIgllI1N-lI5llk-I

• • undary including the walls, doors, roof, floors, and flou drains of the CC, and does not explicitly address the isolation vapers. The Bases change will redse the system con 81guration and operating description, and establish a c' ear connection between CCilE integtity and CREVS operability. The proposed leak test will determine the leakage across de habitamiity boundary, and will allow FPC personnel to verify that the integrity of the CCllE is being minmined within the design basis These changes establish char requirements for CCllE integrity, and establish a measurement ofintegritv wuere these have not existed praiously in TS.

The CREVS rern fr. is being adde.d to the LCO section of the Bases for establishing CREVS operabihty requircrucats.

Specification 5.6.2.12, Ventilation Filter Test Program (VITP)

The change in embon adsorber laboratory test standard will provide a more conservative test than that to which FPC is curiently cornmided The new test condition; are more representative of the operitinh conditions to which the carbon adsorber material will be exposed following a radiological accident. This change is conseivative since testing at a higher temperature may

. overestimate adsorption capability at the expected filter media operating temperature.

- FPC has made major modiacations to improve control roorn habitability perfbrmance. This has included new control room radiological dose calculations. Lower and more conservative CREVS flow rates weie used in the do3e calculations Flow rates were chosen which reflect the reduced flow associated with filter fouling, The values of allowed filter differential pressure and lower flow rate limit are being changed in this TS to be consistent with the calculations.

b.S Nuclear Regulatory Connaission Attachment 11 3F129719 Page 3 JUSTIFICATION FOR ltEQUEST:

Specifications 3.7.12 and 11L7.12. Control Room Einergency Ventilatioa System (CREYS) hiindicicAlOLSttticdhtnge This Surveillance Requirement is similar to that included in the Standard Babcock & Wilcox improved Technical Specifications (ITS), however, a change to the standard requirement is necessary. The standard surveillance test acceptance criteria is expressed as a specific amount of leakage (or makeup air) when the control room is peessurized at a nominal 1/8 inch wg. The CR-3 CREVS is not designed to pressurize the CCllE, therefore an alternate test is required.

The CCllE up3rade accomplished during the curreat design improvement outage included a leak test of the CCllE. The test reschs have been evsluated in relation to control room habitability and found to be acceptable. The addition of a requirement to perform a periodic leak test is conservative. The adoption of this serveillance requirement will assure the integrity of the CCllE boundary.

IlucLChangc3 The Standard liabcock & Wilcox ITS Bases include a statement in the Lirniting Condition for Operation (l CO) section that requires the integrity of the control room habitability boundaty be mair.tained within the assumptions of the design analysis. FPC is proposing to include the same requirement in the CR-3 ITS liases I.CO section Additional discussion on the treatment of CCllE breaches within the limits of the approved design calculations is provided for clarification and to assure consistent interpretation of this TS. The addition of a return fan to the list of CRiiV5 equipment necessary for operability corrects an error in ITS. Other Ba.;es changes are provided to update the CREVS functional description, describing improvements in the .;ystem design.

These changes are justified since they provide better information to the users or the ITS on the basis for CREVS operability.

Spedfication 5.6.2.12, Ventilation Filter Test Program (VFTP)

The existing VFTP requires laboratory testing of carbon adsorber samples in accordance with Regulatory Guide (RG) 1.52, Revision 2,1978 and ash 1E M509-1976 These documents ultimately requite that the test be performed to USAEC Division of Reactor Development and Technology Standard RDT hi-16 lT. Performance oflaboratory tests in accordance with ASTM D 3803-1989 eliminates technical problems that have been identified with the RDT hi-16-IT test method The RDr ht-16-lT test standard reqmres the carbon to be equilibrated by sweeping air at 25"C and 70% Ril through the test carbon. The methyl iodide test medium is then instantaneously introduced at 30'C and 70% Ril. Testing caibon with such the mal step changes is technically

b S Nucle:r Regulatory Commission Attachment D 3F1297-19 Page 4 inconect because it causes condensation on the samples Condensation on the carbon makes the test invalid To correct this problem ASTM D 3803 1989 includes a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> pre test thermal etabilitation at 30'C and r,pecifies a tempcrature of 30*C for all phases of the test. Therefore, ASTM D 38031989 is a better test because it solves the problem of the formation of condensation on the carbon sample.

The cunent test conditions t,pecified in the VFTP are temperature of 80*C and 70% Ril. The proposed test conditions of 30"C and 95% Rif are more representative of the conditions to which the CR-3 caibon adsorber would be exposed following a ndiological accident. Ir. formation Notice 86 76,' Problems Noted in Control Room Emergency Ventilation Systems," indicated that laboiatory testing of cmbon at a temperature higher than that expected during the course of an accident could result in a significant over prediction of the capability of the carbon to remove methyliodide. Therefore, the proposed test conditions will give a more accurate prediction of the performance of the carbon under post-accident conditions The ASTM D 38031989 si.andard is more stiingent than the RDT M-16-lT standard since it has closer talerances on temperature, relative humidity, and time. These result in better reproducibility of the test results. Testing in acconlance with ASTM D 38031989 at 30*C and 95% Ril with a 2 5% penetration limit is more conservative than testing to RDT M 16-lT at 80*C and 70% Ril with a penetration limit of 1% due to the more stringent tolerances on temperature ar,J humidity in ASTM D 3803 1989. The combined etrects of testing at more representative conditions and the use of the impicved test standard compensates for the increased penetration limit.

The existing limita on ventilation finw rates are 43,500 cfm i 10%. The proposed revision to the VFTP will not change tFe upper flow rate (43,500 + 4,350 == 47,850 cfm). Calculations have verified that tilter performance will be maintained at this flow rate. The lower limit on flow ma ches the assumptions in the control room dose calculations The assumption oflower flow rates results in increasing the dose calculated for a given accident scenario. The new lower limit on flow of 37,<100 cfm was chosen based on actual measured now rates, and the calculated reduction in flow due to filter fouling and increased ditTerential pressure across the filters A 4 corresponding change to the maximum allowed filter differential pressure from 6 inches to 4 inches is consistent with the flow and dose calculations.

l l b S Nuclear Regulatory Commission Attachment B 3F129719 Page5 NO SIGNIFICANT li AZARDS CONSIDERATION:

An evaluation of the proposed license amendment has been performed in accordance with 10 CFR 50 91(a)(1) regarding significant hazards consideration, using the standards in 10 CFR 50 02(c)

1. Does not anvh e a signspcant increase m the probabahty or consequences of an accident previonsty emluated.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated The Control Room Emergency Ventilation System (CREVS) and the Control Complex liabitability Envelope (CCIIE) are designed to limit the radiation dose to the control room operating staff following an accident involving massive reactor core damage and breach of the reactor containment building. Since these systems aic only etrective in limiting dose following an accident, the performance of periodic leak tests, and changes to the Ventilation Filter Test Program (VFTP) would not increase the probability of occurrence of any evaluated event. The features of the CREVS and the Control Complex emergency filters, or the CCllE have no direct function in mitigating the offsite consequences of any evaluated accident.

The changes to the ITS Ilases improve intbrmation on the operation and function of CREVS, and establish that CREVS operability is dependent on maintaining CCllE integrity. The inclusion of this information reinforcer the importance of maintaining the CCilE boundary, and will help to ensure the CREVS is capable of perfonning its intended safety function Based on the above, the proposed amendment do:s not significantly increase the probab:lity or consequence of an accident previously evaluated

2. Does not create the pombshty of a new or different kmd of accidentfrom any accident previously eminated.

Wither performance of periodic CCllE leak tests nor changes to the existing VFTP can create the possibility of a new or different kind of accident. Since CREVS and the emergency filtration units function to provide protection following a radiological accident the changes proposed to improve their performance cannot create a new or different kind cf accioent. Changes to the Bases to provide better information on determining CREVS and CCllF operability cannot create the possibility of a new or different kind of accident.

I

i b S Nuclear Regulatory Commission Attachment il 3F129%19 Page 6

3. Does not irnvhv a sigmficant reduction in a margin >f.rafety.

The proposed amendment does not involve a significant reduction in a margin of safety.

Neither performance of periodic CCllE leak tests nor changes to the existing VFTP can create a reduction in the margin of safety. The changes to both of these programs will provide assurance that the CREVS and CCllE will perform as expected. Changes to the liases of the CREVS Technical Specification which clarify the conditions necessary for operability will improve understanding of the requirements for maintaining control room habitability, and will not create a reduction in the margin of safety.

ENVIRONMENTAL IMPACT EVALUATION:

RadinkgicaLErahiMien While 10 CFR 51 requires an environmental assessment (EA) or environmental impact statement (EIS) for any " major Federal action significantly affecting the quality of the human environment,"

it does allow the NRC discretion in evaluating the extent to which EAs or EISs are necessary.

HA.s or EISs are not required for any action included in the list of" categorical exclusions" set forth in 10 CFR 5122(c). Specifically,10 CFR St.22(c)(9), provides that an EA is not required for the issuance of an amendment provided that:

(i) the amendment involves no significant hazards consideration, (ii) there it no significant change in the types or significant increase in the arnounis of any elliuents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

FPC considers that the provisions of 10 CFR 51.22(c)(9) are applicable to this request for these changes to the improved Technical Specifications for the CREVS and CCllE, and for the Ventilation Filter Test Program. For the reasons described in this submittal, FPC believes that the three criteria of 10 CFR S t.22(c)(9) are satisfied Therefore, this Licenu Amendment should be considered under the " categorical exclusions" provisions of 10 CFR SI.22(c)(9) There will be no environmental impact from ocrforming periodic leak tests of the CCilE or from changes to the VFTP. For the reasons given m this submittal that there will be no change in ofTsite consequences due to this action, its impact is bounded by the impacts assumed in the existing Final Enviromnental Statement (FES) for CR-3. Even if the NRC chooses to perform an EA, information provided in the FES, together with this submittal, should assist the NRC in making a linding of no significant impact" in accordance with 10 CFR 51.32.

t

_-___