3F1297-44, Forwards Addl Info Re LARs 220 & 223.Confirmation of Actions Discussed W/Nrc on 971218,to Be Taken to Support LAR 220, Response to Re Restart Requirements for Post LOCA Boron Precipitation Prevention & Rev to Commitments Encl

Forwards Addl Info Re LARs 220 & 223.Confirmation of Actions Discussed W/Nrc on 971218,to Be Taken to Support LAR 220, Response to Re Restart Requirements for Post LOCA Boron Precipitation Prevention & Rev to Commitments Encl

ML20197C600
Person / Time
Site:	Crystal River
Issue date:	12/20/1997
From:	Holden J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F1297-44, TAC-M99128, TAC-M99892, NUDOCS 9712240228
Download: ML20197C600 (6)

Text

_ _ _ _ . . - . ._ _ _ _ _ _ _ _

1 l l

Florida Power ELi^E."

. w::.::*-,,

December 20,1997 3P1297-44 U.S. Nuclear RegulatM smmission Attn: Document Control Desk Washington, DC 20555 0001

Subject:

AdditionalInformation Regarding License Amendment Requests #220 & #22?

(TAC Nos. M99128 & M99892)

References:

1. FPC to NRC letter, 3F1097 08, dated October 31, 1997, " License Amendraent Request #220, Revision 1 - Revision of Operating Licerse Condition 2.C.(5) (TAC No. 99128)"

2. FPC to NRC letter, 3F1197 53, dated November 26,1997, " Restart Readiness Progress and Status"

3. FPC to NRC letter, 3F129712, dated December 4,1997, " Additional Information Regarding the Post LOCA lbron Precipitation revention Plan for CR 3"

4. NRC to FPC letter, 3N1297-06, dated December Y,1997, " Crystal River Nuclear Generating Plant Unit 3 - Boron Precipitation Prwention - Restart Requirements (TAC No, M99892)"

5. FPC to NRC letter, 3F1297-43, dated December 13,1997, " Additional Information Regarding License Amendment Request #220 - Revision of Operating License Condition 2.C.(5) (TAC No M99128)"

Dear Sir:

This submitta! provides:

1) Confirmation of actions discussed with the NRC c.i December 18, 1997, that will be taken by Florida Power Corporation (FPC) to suppert License Anaendment Request (LAR) #220 for Crystal River Unit 3 (CR-3),

2) Response to Refuce 4 regarding restart requirements for post loss-of-coolant accident (LOCA) boron precipitation prevention, and

3) Revision to commitments provided in Reference 3.

hb g CRYST AL RIVER ENER0Y COMPLEX: 15700 W. Power the street e crystal tuver, riorksa 34428-e708 e (3521795 6486

d'***C'"'*"'

9712240220 971220 PDR ADOCK 05000302 P POR

l lM

.4 U. S. Nuclear ReFulatory Commission 3F1297-44 +

Page 2 of 6 Actions to Sunoort LAR #220 As discussed with the NRC on Decen.lc 18,1997, the following actions will be completed as indicated for CR 3 restart from the current outage to suppon LAR #220. These actions will also be entered into the CR-3 com'nitment tracking system as NRC commitments.

1. FPC will apply a 25% factor of safety to the Reactor Building (RB) Emergency Sump boron concentration difference curve developed by Framatome Technologies, Incorporated (FTI) when using it to determine the need to initiate an active boron dilution method (see FPC calculation M97-0146, Figure 12, " Core Boron Concentration Control Limits," included as an attachment to Reference 5). Tbk factor of safety will be required to be used except when either of the following conQions apply:

a. The time following the LOCA is less than the minimum time required to reach the corc boron solubility limit curve (see FPC calculation M97-0146, Figure 13,

" Minimum Boron Solubility and Mixing Limit Time Versus RCS Saturation Temperature," included as an attachment to Reference 5); or, I b. Adequate subcooling has been established for sufficient time following the LOCA to ensure that boton precipitation cannot occur.

This requirement will be incorporated in EM-225B, " Post-Accident Boron Concentration Management." EM-225B will be approved prior to entry into Mode 2.

2. Thermocouples will be installed on the Decay Heat Removal (DH) System drop line and auxiliary pressurizer spray (APS) line prior to entry into Mode 4. Remote readout of

, these thermocouples will be provideo in the main control room. These thermocouples will be required to be operable during Modes 1 through 4 whenever the decay heat generation rate is greater than 2 megawatts thermal. The thermocouples will be added to NOD-31, " Equipment Reliability Improvement Policy," to maintain this equipment commensurate with their recognized importance to safety.

Following NRC approval of LAR #220, FPC will implement a change to the CR-3 Final Safety Analysis Report (FSAR) to reflect the LAR and these specific actions.

Restart Requirements FPC understands the NRC position expressed in Reference 4 that Operating License Condition 2.C.(5) does not limit its applicability to any specific mode, and therefore, must be met. To do so as stated in Reference 3, FPC is installing thermocouples on the DH System drop line and the APS line. Remote readout of these thermocouples will be provided in the main control

i

?

U. S. Nuclear Regulatory Commission 3F1297 Page 3 of 6 room, thus allowing CR '.) operaW:s to confirm that boron dilution flow has comn enced in the affected line. FPC confina its rnor regest for approval of LAR #220, Revision 1 as sool as possible to support restart of CR-3.

FPC's letter of November 26,1997, (Reference 2), requested NRC approval of LAR #223,

" Boron Precipitation Mitigation," prior to Mode 2. Then in Reference 3, FPC requested NRC approval of LAR #223 by March 31,1998. This is the correct date for NRC approval. FPC has prepared a Deficiency Report (DR 97-0086) in accordance with CR-3's corrective action program and la preparing a justification for continued operation (JCO) consistent with the guidelines discussed in Generic Ixtter 91-18, Revision 1, "Information to Licensees Regarding

. NRC Inspection Manual Section on Resolutions of Degraded and Nonconforming Condition' ."

The JCO will document the conclusion that CR-3 can restart without LAR #223. There are no conflicts with the Operating License or Improved Technical Specifications.

Correction to Commitments The commitments provided in Reference 3 regarding the installation of thermocouples and implementation of a procedure to repower valves are revised by this submittal as follows:

Installation of Thennocouples Previous Conunttment - This step will be performed using thermocouples that are being installed on the DH System drop line and APS line. Remote readout of these thermocouples '

will be provided in the main control room. These thermocouples will be installed prior to entering Mode 2 from the current outage.

Revised Commitment - Thermocouples will be installed on the DH system drop line and APS line prior to entry into Mode 4. Remote readout of these thermocouples will be provided in the main control room. These thermocouples will be required to be operable during Modes 1 through 4 whenever the decay heat generation rate is greater than 2 megawatts thermal.

The thermocouples will be added to NOD-31, " Equipment Reliability Improvement Policy,"

to maintain this equipment commensurate with their recognin.d importance to safety. This change to NOD 31 will be approved prior to Mode 2.

Procedure for Repowering Valves Previous Commitment - A procedure will be developed to provide actions that will be taken- '

to repower affected valves on the drop line and auxiliary pressurizer ' spray flow paths upon the tailure of Engineered Safeguards (ES) Motor Control Center ( MCC) 3AB.

i , _

t i

k

.U. S. Nuclear Regulatory Commission '

E 3F1297-44>

• :Page 4 of 6 f _

Revised Commitment - A procedure will be developed prior to entry into Mode 2 to provide actions that will be taken to repower RCV-53 on the auxiliary pressurizer spray flow path ,

upon the failure of ES MCC 3AB.

Reasonfor Revision This procedure will be provided as a preplanned option to ensure that the RCV-53 can be opened in the event of this particular failure. Options to repower DHV-41 and DHV-91 would not be necessary in this case because these valves are located outside_ .

of containment and could be manually operated.-- If the drop line to RB Emergency Sump and APS methods ue not available, this procedure will be used to restore APS as soon-as-possible.

Also note that Reference-3 provided incorrect valve identification numbers in the text of the

" Single Failure" section. The correct valve identification numbers are DHV-41, DHV-91, and .

RCV-53.

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

Sincerely, r

jjy '

. . Holden, Director

. Site Nuclear Operations JJH:dah

- xc: Regional Administrator, Region 11 NRR Project Manager

' Senior Resident Inspector 1

l

=_ - , .___ _ . .- ._ _. . -.  :.

p ,-

U S. Nuclear Regulatory Commission 3P1297-44

• Page 5 of 6 List of Conunitments The following table identifies those actions committed to by Florida Power Corporation in this document. Any other actions discussed in the submittal represent intended or planned actions by Florida Power Corporation. They ere described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager, Nuclear Ucensing of any questions regarding this document or any associated regulatory commitmen'.s.

Commitment Due Date FPC will apply a 25% factor of safety to the Reactor Build!ng (RB) Prior to Mode 2 Emergency Sump boron concentmtion difference curve developed by FT! when using it to determine the need to initiate an active 'ooron dilution method (see FPC calculation M97-0146, Figure 12, " Core Boron Concentration Control Limits," included as an attachment to Reference 5). This factor of safety will be required to be used  ;

except when c"her of the following conditions apply:

a. The time following the LOCA is less than the minimum time required to reach the core boron solubility limit curve (see FPC calculation M97-0146, Figure 13, "Minimura Boron Solubility and Mixing Limit Time Versus RCS Saturation Temperature," included as e . attachment to Reference 5); or,

b. Adequate subcooling has been established for sufscient time following the LOCA to ensure that boron precipitation cannot occur.

This requirement will be incorporated in EM-225B, " Post-Accident Boron Concentration Management." EM-225B will be approved prior to entry into Mode 2.

Thermocouples will be installed on the DH system drop line and Prior to Mode 4 auxiliary pressurizer spray (APS) line prior to entry into Mode 4.

Remote readout of these thermocouples will be provided in the main control room. _

These thermocouples will be required to oe operale during Modes 1 Prior to Mode 2 through 4 whenever the decay heat generation rate is greater than 2 tr.cgawatts thermal. The thermocouples will be added to NOD-31,

" Equipment Reliability Improvement Policy," to maintain this equipmentpommensurate with their recognized importance to safety.

e=

ll U.' S. Nuclear Regulatory Commission -

~

3F1297-44 ' 1

' Page 6 of 6 g

~

Commitnwnt Due Date "

• FPC will implement a change to the CR-3 Final Safety Analysis Following Report (FSAR) to reflect the LAR and these specific actions. approval of LAR. l

1. 220' FI'C has prepared a Deficiency Report (DR 97-0086) in accordance Prior to Mode 4 -

with CR 3's corrective action program and is preparing a justification for continued operation (JCO) consistent with tie guidelines discussed in Generic 12tter 91-18,_ Revision 1, "Information to Licensees Regarding NRC Inspectio Manual Section on Resolutions of Degraded and Nonconforming Conditions." The JCO will document the conclusion that CR-3 can restart without LAR #223. .

. A procedure will be developed prior to entry into Mode 2 to provide Prior to Mode 2 -

actions that will be taken to repower RCV-53 on the auxiliary pressurizer spray flow path upon the failure of ES MCC-3AB. l t

e f

i l-l l

I L i