ML20012E989

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Grants Temporary Waiver of Compliance from Tech Spec 3.9.8.2 to Permit Normal or Emergency Power Source to Be Inoperable for Each DHR Loop in Mode 6 W/Less than 23-ft of Water Above Fuel
ML20012E989
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/26/1990
From: Lainas G
Office of Nuclear Reactor Regulation
To: Beard P
FLORIDA POWER CORP.
References
NUDOCS 9004090257
Download: ML20012E989 (4)


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UNITED $TAf t$

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NUCLE AR CECUL ATORY COMMIS$10N 3

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March 26,1990 i

Mr. Percy M. Beard, Jr.

i Senior Vice President, 1

Nuclear Operations j

Florida Power Corporation i

ATTN:

Manager, Nuclear Operations Licensing

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P.O. Box 219 NA-21 i

Crystal River, FL 32629

Dear Mr. Beard:

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SUBJECT:

CRYSTAL RIVER UNIT 3 TEMPORARY WAIVER OF COMPLIANCE FROM TECHNICAL SPECIFICATION 3.9.8.2 t

By letter dated June 11, 1980, licensees were requested to submit Technica) l Specifications (TS) to provide for redundancy in reactor decay heat removal (DHR) capability in all modes.

Model TS were enclosed with that letter, i

including TS 3.9.8.2.. Florida Power Corporation (FPC) submitted a TS change

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request intended to be consistent with the B&W model TS.

Amendment 117 covering thwse matters was subsequently issued by the NRC.

In your letter dated March 23, 1990, Request for Temporary Waiver of Compliance, you state that in the TS change request you inadvertently omitted a footnote, included in the model TS, in TS 3.9.8.2 which would have allowed for the normal or emergency power source to be inoperable for each DHR loop in Mode 6 with less than 23 feet of water above the fuel.

In your March 23, 1990 letter you state that:

(t]he new Specification, 3.9.8.2 (Amendment 117) is only applicable in Mode 6, and as such, will be utilized for the first time during Crystal River Unit 3's (CR-3) current refueling outage.

During planning activities for entry into Mode 6, it was discovered that the specification cannot be met since maintenance activities on a diesel generator are planned to occur simultaneously with the refueling water level less than 23 feet above the top of the fuel.

Based on the omission of the above mentioned power source footnote, CR-3 Specification 3.9.8.2 is unnecessarily restrictive in that (in conjunction with the definition of operable) it currently requires l

two independent power sources to be operable for each decay heat loop.

I Since one EDG will be out of service, in order to permit entry into Mode 6, you

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requested a Temporary Waiver of Compliance to allow for the use of the model B&W TS footnote regarding power sources in accordance with the marked-up TS i

3.9.8.2 enclosed with your request.

You also stated that you will expedite a TS change request to incorporate the footnote as a permanent change to the CR-3 TS.

In a telecon with a member of your staff on March 23, 1990 FPC committed to submit that request on March 26, 1990.

9004090257 900326 PDR ADOCK 05000302 P

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P. M. Beard, Jr. March 26, 1990 Your request for Temporary Waiver of Compliance discussed the requirements for which the waiver is requested,ficance and potential consequences, significant the need for prompt action, a preliminary evaluation of the safety signi hazards considerations, environmental consequences, and Plant Review Committee review.

You note that the temporary waiver would permit utilization of the previously-approved B&W standard TS provisions of TS 3.9.8.2, and therefore there is no reduction in safety or increase in potential consequences.

l We have reviewed your submittal and find it acceptable.

We also agree with l

the conclusions you have drawn.

Therefore, we herewith grant the recuested Temporary Waiver of Compliance.

The marked-up TS 3.9.8.2 is enciqsec, and may be used for the duration of this temporary waiver, as limited by TS 3.8.1.2.

This waiver shall be effective immediately and shall remain in effect until the license amendment is issued.

It is noted however, that the sub1ect matter of this waiver has been under discussionIntheTechnicalSpecificationImprovementProgram(TSIP).

This waiver and any resulting CR-3 TS change is intended to permit continued current operation by CR-3 on the same basis as other B&W plants, and does not necessarily represent an NRC position on this matter relative to the TSIP.

Sincerely,

/s/

Gus Lainas, Assistant Director for Region II Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

TS 3.9.8.2 y

cc w/ enclosure:

See next page

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3/M90 0FFICIAL RECORD COPY Document Name:

LETTER TO BEARD I

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Mr. Percy M. Beard, Jr.

Crysta) River Unit No. 3 Nuclear Florida Power Corporation Generating Plant I

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Mr. A. H. Stephens State Planning and Development i

l General Counsel Clearinghouse i

Florida Power Corporation Office of Planning and Budget MAC ASD Executive Office of the Governor P. O. Box 14042 The Capitol Building

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St. Petersburg, Florida 33733 Tallahassee, Florida 32301 Mr. P. F. McKee, Director Chairman Nuclear Plant Operations Board of County Commissioners Florida Power Corporation Citrus County P. O. Box 219-NA-2C 110 North Apopka Avenue Crystal River, Florida 32629 Inverness, Florida 32650 I

Mr. Robert B. Borsum Mr. Rolf C. Wide 11 Director i

Babcock & Wilcox Nuclear Operations Site Support Nuclear Power Generation Division Florida Power Corporation 1700 Rockville Pike, Suite 525 P.O. Box 219 NA-21 s

Rockville, Maryland 20852 Crystal River, Florida 32629 Senior Resident Inspector Mr. Gary L. Boldt f

Crystal River Unit 3 Vice President, Nuclear Production L

U.S. Nuclear Regulatory Commission Florida Power Corporation l

15760 West Powerline Street P. O. Box 219-SA-2C Crystal River, Florida 32629 Crystal River, Florida 32629 i

Regional Administrator, Region II l

U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 t

Atlanta, Georgia 30323 Mr. Jacob Daniel Nash Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

I Tallahassee, Florida 32399-0700 l

Administrator Departraent of Environmental Regulation Power Plant Siting Section State of Florida i

2600 Blair Stone Road i

Tallahassee, Florida 32301 Attorney General i

Department of Legal Affairs The Capitol Tallahassee, Florida 32304 e

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[NCLOSURE

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j REFUELINO CPER ATION$

LOT TATtR LIVEL 6

I LIMITING CONDlTION FOR OPERA 710N

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3.9.4.2 he secay host removal (DHR) loops shall be OptRABLE.'

A PPLIC At!LITY:

MODE ( when the water level &beve the top of the irret;4ted f.,el 666emblies seated witNn the reacter feessste vesselis less th6n 2) feet l

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ACTION With less th6n the two required DHR loops CPERABLE. iNtitte -(

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corrective action to retum the required loops to CPERABLE status, b.

The previ6 tens of Specification 3.0.3 are not applicable.

$URV11LL ANCE REQUIREMENTS r

i 6.9.4.2 No 6esational surveillance requirement 6 other than these required by

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Specificatien 6.0.3.

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CRYSTAL RIVER. UNIT )

3/49.la Speeent No. III

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