ML081690718
| ML081690718 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/25/2008 |
| From: | Farideh Saba NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Young D Progress Energy Florida |
| Saba F 301-465-1447 | |
| References | |
| GL-08-001, TAC MD7816 | |
| Download: ML081690718 (7) | |
Text
September 25, 2008 Mr. Dale E. Young, Vice President Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 - GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7816)
Dear Mr. Young:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month submittal date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By "3F0508-07, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated May 8, 2008]], Florida Power Corporation (the licensee) provided a 3-month submittal to GL 2008-01 for Crystal River Nuclear Plant, Unit 3. The NRC staffs assessment of the responses for Crystal River Nuclear Plant, Unit 3 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for Crystal River Nuclear Plant, Unit 3, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided implementation is consistent with the clarifications and associated requests discussed in the enclosure.
D. E. Young If you have any questions regarding this letter, please feel free to contact me at (301) 415-1447.
Sincerely,
/RA/
Farideh Saba, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302 cc: See next page
D. E. Young If you have any questions regarding this letter, please feel free to contact me at (301) 415-1447.
Sincerely,
/RA/
Farideh Saba, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302 Distribution:
PUBLIC LPL2-2 Rdg RidsNrrDorlLpl2-2 RidsNrrPMFSaba RidsNrrLACSola (Hard Copy)
RidsOgcRp RidsAcrsAcnw_MailCTR RidsRgn2MailCenter (P. Fredrickson)
RidsNrrDss RidsNrrDorlDpr RidsNrrDprPgcb ADAMS Accession Number: ML081690718
- See previous concurrence NRR-106 OFFICE LPL2-2/PM LPL2-2/LA PGCB/BC DSS/DD LPL2-2/BC NAME FSaba CSola MMurphy*
JWermeil*
TBoyce DATE 9/25/08 9/25/08 09/22/08 09/19/08 9/25/08 OFFICIAL RECORD COPY
Florida Power Corporation Crystal River Nuclear Plant, Unit 3 cc:
Mr. R. Alexander Glenn Associate General Counsel (MAC-BT15A)
Florida Power Corporation P.O. Box 14042 St. Petersburg, Florida 33733-4042 Mr. Michael J. Annacone 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. Stephen J. Cahill Engineering Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Jon A. Franke 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 Ms. Phyllis Dixon 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.
Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. Daniel L. Roderick Vice President, Nuclear Projects &
Construction Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. David Varner Manager, Support Services - Nuclear Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708 Robert J. Duncan II Vice President, Nuclear Operations Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551 Brian C. McCabe Manager, Nuclear Regulatory Affairs Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551
Enclosure U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 CRYSTAL RIVER NUCLEAR PLANT, UNIT NO. 3 DOCKET NO. 50-302
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month submittal date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By "3F0508-07, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated May 8, 2008]], Florida Power Corporation (the licensee) provided a 3-month submittal to GL 2008-01 for Crystal River Nuclear Plant, Unit 3. The licensee stated they cannot meet the requested 9-month submittal schedule because walkdowns and ultrasonic examinations of piping for the subject systems cannot be completed for the following reasons:
(1) the piping is in an area where dose rates are substantially higher during normal operation as compared to those during plant shutdown conditions; (2) the piping is in the containment building; (3) insulation removal is needed to fully characterize relevant geometry and insulation removal in not practical; and, (4) scaffolding is needed to access the piping to fully characterize relevant geometry and installation of scaffolding could jeopardize operability of adjacent equipment.
The licensee also stated that evaluation of licensing basis, design, testing, and corrective actions will be completed within the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns and ultrasonic testing examinations of inaccessible piping during the next refueling outage scheduled for September 2009. The licensees "3F0508-07, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated May 8, 2008]], listed the following commitments:
- 1. Complete the detailed walkdowns and ultrasonic examinations of inaccessible piping at locations potentially susceptible to gas accumulation for systems within the scope of the GL before December 19, 2009, prior to startup from the next refueling outage scheduled for September 2009.
- 2. Submit supplemental response to the NRC within 90 days following completion of refueling outage (R16), which will describe any changes to 9-month submittal resulting from walkdowns and ultrasonic examination of inaccessible piping.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. The majority of-inaccessible piping is on the pump discharge where potential impact of gas accumulation is generally less than for pump suction piping.
- 2. Based on reviews completed to date, no historical examples of events related to gas accumulation have been identified for the inaccessible piping.
- 3. Successful performance of surveillance requirements (such as periodic venting and pump testing).
Based on the above considerations, the licensee stated that Crystal River Nuclear Plant, Unit 3 has confidence that the subject systems can fulfill their required design functions. As such, the licensee concluded that completing walkdowns and ultrasonic testing examinations of inaccessible piping outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, procedures, and corrective actions associated with managing gas accumulation at Crystal River Nuclear Plant, Unit 3.
The NRC staff notes examples where the licensees 3-month submittal dated May 8, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, although the submittal states that the 9-month submittal will include evaluations of non-accessible piping based on the existing plant as-built design drawings, as well as system operating experience and any previously performed walkdown information, it does not explicitly state that this response will also include information on its walkdowns and evaluations of accessible piping within the GL scope.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - Provide to the NRC by October 11, 2008, all GL-requested information for the portions of the subject systems that are accessible prior to the Crystal River Nuclear Plant, Unit 3, refueling outage R16.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL-requested information for the subject systems to the NRC within 90 days following completion of refueling outage R16 currently scheduled to begin in September 2009 at Crystal River Nuclear Plant, Unit 3.
For each of these submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated May 8, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.