ML052380205
| ML052380205 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/31/2005 |
| From: | Mozafari B NRC/NRR/DLPM/LPD2 |
| To: | Young D Florida Power Corp |
| mozafari B, NRR/DLPM, 415-2020 | |
| References | |
| TAC MC5813 | |
| Download: ML052380205 (5) | |
Text
August 31, 2005 Mr. Dale E. Young, Vice President Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing and Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 REQUEST FOR ADDITIONAL INFORMATION (RAI) RE: PROPOSED LICENSE AMENDMENT REQUEST NO. 290, REVISION 1 (TAC NO. MC5813)
Dear Mr. Young:
By letter dated August 12, 2005, you submitted a revised amendment application to revise the Crystal River Unit 3 (CR-3) Improved Technical Specifications (ITS) to allow utilization of a probabilistic methodology to determine the contribution to Main Steam Line Break leakage rates for the Once-Through Steam Generator from the Tube End Crack Alternate Repair Criteria described in ITS 5.6.2.10.2.f.
For the NRC staff to complete its review on schedule, your response to the enclosed RAI is requested no later than September 15, 2005. This date was mutually agreed upon in a telephone conversation with Paul Infanger on August 24, 2005. If circumstances result in the 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
Enclosure REQUEST FOR ADDITIONAL INFORMATION CRYSTAL RIVER UNIT 3 LICENSE AMENDMENT REQUEST PROBABILISTIC METHODOLOGY FOR DETERMINING ACCIDENT LEAKAGE ASSOCIATED WITH TUBE END CRACKS IN STEAM GENERATOR TUBES 1.
On page 2 of Attachment F to your submittal dated August 12, 2005, please clarify what is meant by the described method satisfies the minimum requirements for calculating the projected TEC leakage contained in BAW-2346P Rev 0 as required by ITS 5.6.2.10.2.f. In addition, clarify what is meant that the leakage will be determined in conjunction with NRC approved LAR # 290 or existing leak rates to determined the required tube repairs. This latter sentence may not be consistent with the proposed technical specification change which states that main steam line break (MSLB) leakage rates shall be determined by the methodology in Addendum B to BAW-2346P, Rev 0.
2.
On page 2 of Attachment F to your submittal, Framatome calculation 32-5053981-00 is referenced. Please discuss what this reference is and provide a copy for NRC review and approval since it may be used in the calculation of tube end cracking (TEC) leakage. This may also be in conflict with the proposed technical specification which states that the contribution to MSLB leakage rates from TEC indications shall be determined utilizing the methodology in Addendum B dated August 10, 2005 to Topical Report BAW-2346P, Revision 0.
3.
Regarding item d on page 2 of Attachment F to your submittal, the NRC staff agrees that leakage is the parameter of concern from a safety perspective. However, the amount of leakage from the steam generator is a direct result of the number of TEC indications. In addition, your proposed methodology for determining the amount of leakage has inherent assumptions with respect to the number and distribution of indications. That is, although you are proposing to apply the probability of detection value directly to the as-found leakage (rather than to the number of indications), this approach is equivalent to determining the number of indications that were missed during the inspection and then assigning a leakage value to each of these indications. In addition, your approach for new leakage is inherently assuming that the distribution of new indications (i.e., as a function of tubesheet radius or radial zone) is identical between successive operating intervals. Given that these assumptions are critical to ensuring that any projections of accident induced leakage are conservative, please discuss your plans for modifying your proposed technical specifications to include reporting requirements related to implementation of this methodology. For example, include reporting requirements to provide the number of tubes with TEC indications and the number of TEC indications as a function of tubesheet radius and zone, and the as-found, the as-left, the POD, and the new TEC leakage for both the lower and upper tubesheet indications. In addition, include reporting requirements for assessing the adequacy of the predictive methodology including assessing the distribution of indications found in each steam generator to ensure that your inherent assumption regarding the similarity of the distribution of indications remains consistent from one cycle to the next and that the assumption of a linear increase in leak rate remains valid.
The reporting requirements should also include proposed corrective actions in the event that your assessment indicates that your assumptions can not be fully supported.
4.
Figure 2 of Attachment F to your submittal is intended to demonstrate that any increase in leakage can be modeled using a linear extrapolation. In this figure, the number of tubes with TECs is plotted as a function of time. Since the number of indications is the parameter used in the leakage calculation and each tube can have multiple indications, please provide a plot of the number of indications as a function of time. Please address how you will account for additional indications that may have initiated in tubes that were repaired (since tubes may be left in service longer under the proposed revision to the amount of leakage assigned to each indication resulting in more time for indications to initiate).
ML052380205 NRR-088 OFFICE PDII-2/PM PDII-2/LA PDII-2/ SC NAME BMozafari CHawes MMarshall DATE 8/ 29 /05 8/ 29 /05 8/ 31 /05
Mr. Dale E. Young Crystal River Nuclear Plant, Unit 3 Florida Power Corporation cc:
Mr. R. Alexander Glenn Associate General Counsel (MAC-BT15A)
Florida Power Corporation P.O. Box 14042 St. Petersburg, Florida 33733-4042 Mr. Jon A. Franke Plant General Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Jim Mallay Framatome ANP 1911 North Ft. Myer Drive, Suite 705 Rosslyn, Virginia 22209 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue Inverness, Florida 34450-4245 Mr. Michael J. Annacone Engineering Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Daniel L. Roderick Director Site Operations Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Senior Resident Inspector Crystal River Unit 3 U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River, Florida 34428 Mr. Terry D. Hobbs Manager, Nuclear Assessment Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 David T. Conley Associate General Counsel II - Legal Dept.
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