ML11143A139
| ML11143A139 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/24/2011 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Franke J Florida Power & Light Co |
| saba f e | |
| References | |
| GL-08-001, TAC MD7816 | |
| Download: ML11143A139 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 24, 2011 Mr. Jon A. Franke, Vice President Crystal River Nuclear Plant (NA2C)
ATIN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 - CLOSURE LETTER FOR THE LICENSEE'S RESPONSE TO GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL AND CONTAINMENT SPRAY SYSTEMS" (TAC NO. MD7816)
Dear Mr. Franke:
On January 11, 2008, the U.S. 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 (ADAMS) Accession No. ML072910759). The stated purpose of GL 2008-01 was (a) to request addressees to submit information to demonstrate that 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; and, (b) to collect the requested information to determine if additional regulatory action is required.
GL 2008-01 requested that licensees provide the following information within 9 months of the date of the GL:
(a) A description of the results of evaluations that were performed pursuant to requested actions specified in the GL. This description should provide sufficient information to demonstrate that you are or will be in compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to Part 50 of Title 10 of the Code of Federal Regulations and the licensing basis and operating license as those requirements apply to the subject systems; (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
By letters dated October 13, 2008 and January 24, 2010, Florida Power Corporation (the licensee) for Crystal River Unit 3 Nuclear Generation (CR-3), provided responses to GL 2008-01. The responses to the NRC staff request for additional information (RAI) are provided in the licensee's letter dated January 24, 2010. The NRC staff has reviewed the licensee's responses and has determined that the licensee has acceptably addressed each
J. Franke
- 2 request. Below is a summary of the NRC staffs review of the licensee's responses and its closure:
RAI 1 discussed high to low pressure interfaces, the frequency with which parameters are monitored, and whether abnormal results would trigger inspections for voids. The licensee reported that the only system of potential concern was the decay heat (DH) removal system. This omits a potential interface path from the charging flow path into part of the high pressure safety injection system that may not be pressurized. NRR staff did not pursue this further because the path is unlikely and the licensee has identified the dominant issue. The licensee's response also indicated that parameters are monitored as part of operator logs and any abnormal indications would be investigated through the licensee's corrective actions program. NRR staff concludes that this acceptably addresses the question and the subject systems are currently operable with respect to the issues identified in RAI 1.
RAI 2 discussed the licensee's proposed void inspection interval of 92 days. This proposal is based on the licensee's previous operating experience and its activities to identify a condition that may cause gas accumulation to occur. The licensee stated that, over the past 15 years, there have been no recognized instances of inventory intrusion into the DH system from either the reactor coolant system or core flood tanks. Further, the licensee described other monitoring activities and systems to identify intrusion into the decay heat system. Based upon the current operating experience and the additional licensee described methods to detect a degraded condition, NRR staff finds that the licensee has demonstrated that the subject systems are currently operable with a void inspection interval of 92 days when monitoring and trending activities acceptably establish that potential sources of gas do not exist.
RAI 3 discussed licensee training of staff on activities associated with gas accumulation.
The licensee participates in the Nuclear Energy Institute's gas accumulation team that is coordinating with the Institute of Nuclear Power Operators to implement training modules. The licensee also uses plant procedure, PRO-NGGC-0204, "Procedure Review and Approval," to modify and establish needs. This approach is acceptable.
RAI 4 addressed the void acceptance criteria. The licensee's response referenced numerous industry documents and stated that evaluation of operability "is not based on NRC guidance." The licensee's response ended with "This industry guidance is being used by Progress Energy until such time that the NRC criteria can be formally issued and evaluated." The NRC has not approved much of the industry guidance and has stated that the older pump void criteria were not acceptable (ADAMS Accession No. ML091390637). However, following the June 2, 2010 NRC/industry meeting (ADAMS Accession No. ML101650201-meeting summary), the NRC provided revised criteria that industry accepted with minor additions that have been accepted by NRC (ADAMS Accession No. ML102080687). The NRC staff found the licensee's response acceptable, since the licensee stated that it would use the revised criteria.
The NRR staff has concluded that the licensee has acceptably demonstrated "that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified," as stated in GL 2008-01. The NRC is continuing to engage with stakeholders regarding the creation of
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- 3 durable guidance for gas management, which may require additional actions by the licensee beyond the scope of GL 2008-01.
The NRR staff has completed its review of the CR-3 systems that are evaluated under GL 2008-01 and has concluded that the subject systems are currently operable.
Notwithstanding, the NRC Region II inspectors may perform an inspection in accordance with temporary inspection (TI), "Managing Gas Accumulation in Emergency core Cooling, Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01)." TI2515/177 is confirmatory in nature in that it directs the NRC inspectors to selectively verify that the licensee has implemented or is in the process of acceptably implementation the commitments, modifications, and programmatically controlled actions describes in the licensee's responses to GL 2008-01 and the plant-specific information. The results of this inspection support the NRC's conclusion that the subject systems' operability is reasonable ensured.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-1447.
Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302 cc: Distribution via Listserv
J. Franke
- 3 durable guidance for gas management, which may require additional actions by the licensee beyond the scope of GL 2008-01.
The NRR staff has completed its review of the CR-3 systems that are evaluated under GL 2008-01 and has concluded that the subject systems are currently operable.
Notwithstanding, the NRC Region II inspectors may perform an inspection in accordance with temporary inspection (TI), "Managing Gas Accumulation in Emergency core Cooling. Decay Heat Removal, and Containment Spray Systems (NRC Generic Letter 2008-01)." TI2515/177 is confirmatory in nature in that it directs the NRC inspectors to selectively verify that the licensee has implemented or is in the process of acceptably implementation the commitments.
modifications, and programmatically controlled actions describes in the licensee's responses to GL 2008-01 and the plant-specific information. The results of this inspection support the NRC's conclusion that the subject systems' operability is reasonable ensured.
If you have any questions regarding this letter. please feel free to contact me at (301) 415-1447.
Sincerely.
IRA!
Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302 cc: Distribution via Listserv DISTRIBUTION:
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