ML033090003

Request for Additional Information Related to Crystal River Unit 3 - Revised Appendix R Exemption Request - Fire Area CC-164-121 Submittal

ML033090003
Person / Time
Site:	Crystal River
Issue date:	11/05/2003
From:	Mozafari B NRC/NRR/DLPM/LPD2
To:	Young D Florida Power Corp
mozafari B, NRR/DLPM, 415-2020
References
TAC MB7987
Download: ML033090003 (5)

Text

November 5, 2003 Mr. Dale E. Young, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing and Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO CRYSTAL RIVER UNIT 3 - REVISED APPENDIX R EXEMPTION REQUEST - FIRE AREA CC-164-121 SUBMITTAL (TAC NO. MB7987)

Dear Mr. Young:

By letter dated February 4, 2003, Florida Power Corporation (FPC or the licensee) submitted a request for a revision to an Appendix R Exemption to allow removal of the automatic actuation feature for the Control Room Emergency Ventilation System (CREVS) charcoal filter fire protection deluge system for Crystal River Nuclear Plant, Unit 3 (CR-3). FPC proposed to revise its original exemption by demonstrating that the removal of the automatic actuation feature does not substantively alter the basis for the NRCs approval of the original exemption (ADAMS Legacy Library Accession Numbers 8508010796, 8508010808 and 8508010812, dated July 18, 1985).

For the NRC staff to complete its review on schedule, your response to the enclosed request for additional information is needed no later than November 30, 2003. This date was mutually agreed upon in a telephone conversation with Sid Powell on October 23, 2003. If you need to revise the target date, please call me at the earliest opportunity at 301-415-2020.

Sincerely,

/RA/

Brenda L. Mozafari, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/encl: See next page

Request for Additional Information for the Review of Crystal River 3 Revised Appendix R Exemption Request Regarding Fire Area CC-164-121

1. In your exemption request, you stated that the charcoal filter banks, which are the major combustible in the area of concern, will be protected by manually actuated fixed water spray systems with spray heads mounted inside the steel filter housings. You also state that a manually actuated water spray system for the CREVS charcoal filters is consistent with current industry practice and the guidance provided in ASME N509-1989 and Regulatory Guide (RG) 1.52. The NRC staffs position on this issue, as outlined in the relevant parts of RG 1.52 is that when a water-based fire suppression or prevention system is installed in the engineered safety feature atmosphere cleanup system housing, the fire system should be manually actuated unless there is a reasonable probability that the iodine desorption and adsorbent auto-ignition could occur in the housing, in which case the fire system should have both automatic and manual actuation.

Therefore, because you state that the charcoal is the major combustible in the area, we request that you demonstrate that there is not a reasonable probability that the iodine desorption and adsorbent auto-ignition could occur in the housing. One example of an acceptable way of demonstrating this is to provide the results of your calculations that demonstrate that the highest possible temperature that could occur in the vicinity of the charcoal (including the temperature rise associated with radioactivity-induced heat in the charcoal), as a result of a design-basis accident, is lower than the iodine desorption and adsorbent auto-ignition temperature of the adsorbent.

2. The local manual actuation is in the fire area containing the filter housings (Justification 2 of 10). Provide an analysis that fire conditions would be contained within the filter housing (i.e., capability to withstand a 1.7-hour ASTM E-119 fire). Describe where within the area the local manual actuation stations are located. State whether the fire brigade has been trained in the operation of these systems in the event that the fire area is filled with smoke.

3. The charcoal filters are normally isolated by ventilation dampers. State whether these dampers are fire rated. Describe the expected travel path of the smoke and hot gasses in case these ventilation dampers fail during a filter fire. State whether the smoke and hot gasses would interfere with control room ventilation, setting up the Appendix R chilled water system (ARCWS), or the actuation of the manual suppression system.

4. Appendix R Chilled Water System

a. The revised exemption states in Justification 10, Page 3 of 6, that the time to place the ARCWS in service is less than 90 minutes. Provide the technical basis for the acceptability of 90 minutes without cooling. Describe the temperatures expected in areas containing hot shutdown equipment and whether the hot shutdown equipment in these areas has been analyzed for these temperatures.

ENCLOSURE

b. Indicate whether the ARCWS has the capability of removing the heat from the affected areas due to the increased heat load from the loss of cooling for 90 minutes. Consider capability while assuming maximum expected ambient temperature conditions.

c. Describe the actions required to get the ARCWS in service. Also, describe the configuration of the ARCWS. For example, list the chillers, fans, ducting, and whether any tools are required. State whether the minimum operations staff is trained on setting up the ARCWS. Confirm that the minimum shift staff has the capability of setting up the ARCWS simultaneously with fire brigade operations and plant shutdown.

d. During 90 minutes while setting up the ARCWS, establish whether fans and elephant trunk can be used to keep the affected areas at ambient temperature.

If so, provide assurance that there are adequate fans to support ventilation of the main control room, cable spreading room, essential switchgear rooms, battery rooms, inverter rooms, and the emergency feedwater initiation and control system rooms, at the same time that fans are required to ventilate the fire-affected area.

e. Describe the elevated temperature in the main control room and establish how long the operators would be required to work in an area with elevated temperature.

f. Describe measures in place to protect operators during extended periods in areas of elevated temperatures.

5. The interior wall of rooms 121B and 121C have hash marks indicating some sort of opening. Provide a description of this opening.

November 5, 2003 Mr. Dale E. Young, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing and Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO CRYSTAL RIVER UNIT 3 - REVISED APPENDIX R EXEMPTION REQUEST - FIRE AREA CC-164-121 SUBMITTAL (TAC NO. MB7987)

Dear Mr. Young:

By letter dated February 4, 2003, Florida Power Corporation (FPC or the licensee) submitted a request for a revision to an Appendix R Exemption to allow removal of the automatic actuation feature for the Control Room Emergency Ventilation System (CREVS) charcoal filter fire protection deluge system for Crystal River Nuclear Plant, Unit 3 (CR-3). FPC proposed to revise its original exemption by demonstrating that the removal of the automatic actuation feature does not substantively alter the basis for the NRCs approval of the original exemption (ADAMS Legacy Library Accession Numbers 8508010796, 8508010808 and 8508010812, dated July 18, 1985).

For the NRC staff to complete its review on schedule, your response to the enclosed request for additional information is needed no later than November 30, 2003. This date was mutually agreed upon in a telephone conversation with Sid Powell on October 23, 2003. If you need to revise the target date, please call me at the earliest opportunity at 301-415-2020.

Sincerely,

/RA/

Brenda L. Mozafari, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC PDII-2 Reading D. Frumkin (email)

A. Howe (email) J. Munday (email) S. Weerakkody (email)

E. Dunnington (Hardcopy) B. Mozafari (Hardcopy) H. Walker (email)

S. Stewart (email) R. Dennig (email)

OGC ACRS ADAMS ACCESSION NO. ML033090003 OFFICE PDII-2/PM PDII-2/LA PDII-2/SC NAME BMozafari EDunnington KJabbour fro AHowe DATE 10/31/03 10/31/03 11/04/03 OFFICIAL RECORD COPY

Mr. Dale E. Young CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation cc:

Mr. R. Alexander Glenn Chairman Associate General Counsel (MAC-BT15A) Board of County Commissioners Florida Power Corporation Citrus County P.O. Box 14042 110 North Apopka Avenue St. Petersburg, Florida 33733-4042 Inverness, Florida 34450-4245 Mr. Jon A. Franke Ms. Sherry L. Bernhoft Plant General Manager Manager Regulatory Affairs Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant (NA2H) 15760 W. Power Line Street 15760 W. Power Line Street Crystal River, Florida 34428-6708 Crystal River, Florida 34428-6708 Mr. Michael A. Schoppman Mr. Daniel L. Roderick Framatome ANP Director Site Operations 1911 North Ft. Myer Drive, Suite 705 Crystal River Nuclear Plant (NA2C)

Rosslyn, Virginia 22209 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. William A. Passetti, Chief Department of Health Senior Resident Inspector Bureau of Radiation Control Crystal River Unit 3 2020 Capital Circle, SE, Bin #C21 U.S. Nuclear Regulatory Commission Tallahassee, Florida 32399-1741 6745 N. Tallahassee Road Crystal River, Florida 34428 Attorney General Department of Legal Affairs Mr. Richard L. Warden The Capitol Manager Nuclear Assessment Tallahassee, Florida 32304 Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Mr. Craig Fugate, Director Crystal River, Florida 34428-6708 Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100