ML19327B754

Submits Responds to Generic Ltr 88-20 Re Performance of Individual Plant Exam.Util Goal for Upgrading Level 1 PRA Is Have Useful Tool Used by Personnel to Generate Risk Profile of CR-3 & Identify risk-significant Sys & Components

ML19327B754
Person / Time
Site:	Crystal River
Issue date:	11/03/1989
From:	Widell R FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-1150, RTR-NUREG-1335, RTR-NUREG-CR-5245 3F1189-11, GL-88-20, NUDOCS 8911130067
Download: ML19327B754 (4)

Text

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November 3, 1989  !

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U.S. Nuclear Regulatory Commission l g' Attn Document Control Desk l

. Washington,'D.C. 20555 ,

Subject:

Crystal River. Unit 3 u , .' c Docket No. 50-302 3 1'~~ Operating License No. DPR-72 1, .

Generic Letter 88 ,

Plan and.ScheduleLfor Performance of an  :

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Individual Plant Examination (IPE) [

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Dear Sir:

' Florida Power Corporation-(FPC) submitted a Level 1 PRA'for Crystal .) '

Lt-'  ! River Unit 3' (CR-3) in our November 2, 1987 letter. The NRC t

subsequently'. contracted Argonne National Laboratory- to review the

<PRA~and:the results of this review were reported in'NUREG/CR-5245.

, The NRC later:. issued a September 18, 1989 letter summarizing the j

.' review and giving ' qualified approval to use of the CR-3 ' PRA in 1 support of engineering and licensing activities. ,

The' 'CR-3 PRA was originally developed by Science Applications [

International Corporation (SAIC) with full-time participation by FPC ';

engineers. The' study took three years to complete. Since that time,  !

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, .the FPC PRA staff has redone _and/or updated most of the CR-3 PRA.

E ~a FPC . has recently completed the second data base update and L requantification since the original publication. The current input, '

% results, and supporting documentation reside on computer files. The p ,

CR-3 PRA recort has not been updated.

lU The CR-3 PRA is a Level 1 PRA addressing internal events and loss of offsite power. In consideration of the guidance set forth NUREG-L 1335, FPC has planned six steps to achieve the IPE:

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1 8911130067 891103 00N

. PDR ADOCK 05000302 '

t P PNU q g POST OFFICE box 219. CRYSTAL RIVER, FLORIDA 326294219 * (904) 795 6486

' A Florida Progress Company

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1. Respond to the comments and exceptions noted in NUREG/CR-5245. Resolution of most of the NUREG/CR-5245 comments is '

i- not expected to be a time-consuming task. However, if the L comments . require additional modeling, it will demand significant resources and possibly contractor support.

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2. Update the existing Level 1 documentation. This process ,

'is expected to take several man-months and will be done L . entirely.in-house.

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L 3. Conduct the independent review of the updated CR-3 PRA.

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This review will consist of having each system model reviewed.by the cognizant FPC system engineer, and having

• 4 x the event sequence and recovery analyses reviewed by an FPC operations representative.

4. Perform an internal flooding analysis.

, 5.. Perform a Level 2 (containment) analysis. The method by which the CR-3 containment analysis will be performed has not been decided. FPC will likely use an existing analysis (e.g. NUREG-1150) and modify it to represent CR-3, or use the Source Term Code Package (STCP) for an original t containment analysis. There is presently much work being done by EPRI, owners groups, contractors, and ' industry to put together containment analysis approaches which comply with the NUREG-1335 guidelines. Before FPC commits to one l of these methods, the results of this work will be evaluated.

6. Submit the IPE package for review.

Tasks'4 and 5 will require contractor support. FPC agrees with the L NRC's expressed interest in promoting maximum utility involvement in

- the IPE analysis,' and plans to have the contractor assume a technical

'< advisory role in these tasks with the PRA staff performing the bulk of the analyses.

FPC's goal in upgrading the Level 1 PRA is not simply to comply with the IPE generic letter, but to have a useful tool which can be used  ;

. by utility personnel to generate a risk profile of CR-3, identify

'n risk-significant systems and components, evaluate systems' reliabilities and their most important components, and calculate

cost / benefit ratios for real and proposed modifications. FPC has considered the following items to establish this goal and the IPE b schedule

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1. FPC's experience with performing a Level 1 PRA; h

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l November 3, 1989 l 3Fll89-ll l Page 3 -j

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2. FPC's demands on our PRA staff regarding the use of the PRA l in support of licensing, engineering, and operations i activities; and )

3. the industry's uncertainty surrounding the IPE containment ,

analysis methodology. '

For these reasons, FPC plans to submit the IPE as soon as reasonably practicable; but expects this may not be appreciably earlier than

. September 1, 1992.

o ' The IPE requested by the generic letter is being conducted for events which are beyond the design basis of CR-3. The use of the IPE results to develop a severe accident management program has great  !

potential to obscure the distinction between " design basis accidents"

.(where substantial core damage is assumed to be prevented)- and

" severe accidents" -(where such damage is assumed to occur, up to and including a major meltdown of the core). FPC will use the IPE

results to identify outliers which would increase the core damage frequency or decrease containment performance. These outliers will be evaluated against the design basis accident requirements. If the potential. improvements, whether design or procedural, warrant implementation, FPC will take appropriate action to correct such vulnerabilities.- These modifications would be implemented voluntarily by FPC to address accidents beyond the design basis.

Sincerely, j

R.C. idell, Director Nuclear 3perations Site Support l

RCW/JWT/sdr xc: Regional Administrator, Region II Senior Resident Inspector NUMARC - Mr. David Modeen l'

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STATE OF, FLORIDA

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.3 COUNTY OF. CITRUS Rolf C. Widell states that he is the Director, Nuclear Operations Site Support for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory '

l Commission the information attached hereto; and that all- such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

b 3 Rolf C.} Widell,\ Director Nuclear Operations Site Support subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 3rd day of November 1989.

'/d.f 4' C Notary Public Notary Public, State of Florida at Large, ucur ru i:: w u nr rtenin My Commission Expires: 'NDs"~ !"" """"" 33'f,% j i.

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