ML20062K202

Summary of 930805 Meeting W/Licensee in Rockville,Md Re Improved TS of Remote Shutdown Sys Surveillance Requirement SR 3.3.18.2 Dealing W/Verification of Transfer Switch Capability.Viewgraphs Encl

ML20062K202
Person / Time
Site:	Crystal River
Issue date:	12/15/1993
From:	Silver H Office of Nuclear Reactor Regulation
To:	NRC
References
NUDOCS 9312210209
Download: ML20062K202 (11)

Text

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4 December 15, 1993 Docket No. 50-302 LICENSEE: Florida Power Corporation (FPC) ,

1 FACILITY: Crystal River Unit 3 (CR-3)

SUMMARY

OF MEETING ON AUGUST 5, 1993 - REGARDING REMOTE SHUTDOWN l' SYSTEM SURVEILLANCES Representatives of the licensee met with members of the staff on August 5, 1993, in Rockville, Maryland, to discuss inclusion in the improved TS of the remote shutdown system surveillance requirement SR 3.3.18.2 dealing with verification of the transfer switch capability. The enclosure consists of the licensee's handouts during the meeting.

The licensee's position was that the Policy Statement criteria for inclusion in the TS are not satisfied. In addition, FPC considered that requiring verification of the' transfer switch capability in the TS, rather than only in a procedure, constituted a backfit. The staff's position was that TS control of the intended safety function was important. No decision was reached at the meeting.

Subsequent to the meeting, a decision was reached to leave the improved TS essentially unchanged from the existing TS.

(Original Signed by R. Croteau for)

Harley Silver, Senior Project Manager Project ~ Directorate 11-2 Division of Reactor Projects - I/II

Enclosure:

As stated cc w/ enclosure:

See.next page Distrittution Docket" File G. Lainas- ACRS-(10)

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_ 9312210209 931215 DR ADOCK 05000302 PDR . _ _ _ ~

. Crystal River Unit No.3

_ Florida Power Corporation Generating Plant .

l cC; Mr. Gerald A. Williams Mr. Joe Myers, Director Corporate Counsel Div. of Emergency Preparedness Florida Power Corporation Department of Community Affairs MAC-ASA 2740 Centerview Drive P. O. Box 14042 Tallahassee, Florida 32399-2100 St. Petersburg, Florida 33733 Mr. Bruce J. Hickle, Director Chairman Nuclear Plant Operations (NA2C) Board of County Commissioners I Florida Power Corporation Citrus County Crystal River Energy Complex 110 North Apopka Avenue 15760 W. Power Line Street Inverness, Florida 32650 ,

Crystal River, Florida 34428-6708 i Mr. Robert B. Borsum Mr. Rolf C. Widell, Director  ;

B&W Nuclear Technologies Nuclear Operations Site Support (NA21) 1700 Rockville Pike, Suite 525 Florida Power Corporation Rockville, Maryland 20852 Crystal River Energy Complex 15760 W Power Line Street Crystal River, Florida 34428-6708 Regional Administrator, Region II U. S. Nuclear Regulatory Commission Senior Resident Inspector 101 Marietta Street N.W., Suite 2900 Crystal River Unit 3 Atlanta, Georgia 30323 U.S. Nuclear Regulatory Commission Mr. Bill Passetti 6745 N. Tallahassee Road 1 Office of Radiation Control Crystal River, Florida 34428 i Department of Health and Rehabilitative Services Mr. Gary Boldt 1317 Winewood Blvd. Vice President - Nuclear Tallahassee, Florida 32399-0700 Production (SA2C)

Florida Power Corporation Attorney General Crystal River' Energy Complex Department of Legal Affairs 15760 W Power Line Street 1 The Capitol Crystal River, Florida 34428-6708 l Tallahaseee, Florida 32304 1 Mr. Percy M. Beard, Jr. )

Sr. Vice President Nuclear Operations Florida P'ower Corporation l ATTN: Manager, Nuclear Licensing (NA21) 1 Crystal ' River Energy Complex 15760 W Power Line Street Crystal River, Florida 34428-6708 1

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REMOTE SHUTDOWN INSTRUMENTATION TECHNICAL SPECIFICATION ,

FOR CRYSTAL RIVER UNIT 3  ;

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AUGUST 5,1993 NRC OFFICES, ROCKVILLE MD 1

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On February 6,1987, NRC published the interim policy statement on technical specification improvements for nuclear power reactors in the Federal Register for public comment (52 FR 3788).

The interim policy statement contained criteria for defining the scope of Technical Specifications. These criteria are provided below:

CRITERION 1: Installed instrumentation that is used to detect, and indicate in the Control Room, a significant abnormal degradation of the reactor coolant pressure boundary.

CRITERlON 2: A process variable that is an initial condition of a Design Basis Accident (DBA) or transient analysis that either assumes the failure or presents a challenge to the integrity of a fission product barrier.

CRITERION 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

In addition to those SSC captured by the above criteria,it was the Commission's policy that licensees retain in their Technical Specifications the following systems (as applicable) which operating experience and Probabilistic Risk Assessment have generally shown to be important to public health and safety:

Reactor Core Isolation Cooling (RCIC)/ Isolation Condenser Residual Heat Removal (RHR)

Standby Liquid Control (SBLC)

Recirculation Pump Trip (RPT)

-Page 2

By letter dated October 15,1987, B&W Owners Group submitted its assessment to the NRC,

Subject:

"B&W Owners Group Technical Specification Committee Application of Selection Criteria to the B&W Standard Technical Specifications."

B&WOG assessment of Remote Shutdown Instrumentation Technical Specification contained in NUREG-0103, Revision 4 indicates requirement may be relocated from Technical Specifications.

Letter dated May 9,1988, NRC issues " split report." This report documents the NRC Staff's conclusions as to which currer.t STS requirements were to be retained in the new STS.

Noteworthy to this issue:

. The Staff found that " Remote Shutdown instrumentation meets the policy statement criteria for inclusion in Technical Specification based upon risk" Note 4 To Appendix A, Table 1, Note 4 of the letter provided clarification on the basis for the Staff's conclusion that the Remote Shutdown Instrumentation Technical Specification should be retained in the new STS.

"Because fires (either inside or outside the Control Room) can be a significant contributor to the core melt frequency and because the uncertainties with fire initiation frequency can be significant, the Staff believes that this LCO should be retained in the STS at this time. The Staff will consider relocation of Remote Shutdown instrumentation on a plant-specific basis."

Staff provided further clarification that " Criteria 2 and 3 should not be interpreted to include purely generic design requirements applicable to all plants (e.g., the requirements of General Design Criteria 19 in Appendix A to 10 CFR S0 for Control Room Design)."

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By letter dated August 25,1989, FPC submitted the Technical Specification improvement License Amendment request for CR-3. FPC applied the screening criteria contained in the i Commission's interim policy statement to each CR-3 Technical Specification LCO. The Remote Shutdown Instrumentation LCO evaluation is provided below.

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1. Remote Shutdown instrumentation is not used to detect degradation of the RCS pressure boundary. CRl:ERlON 1 is not satisfied.

2. Although Remote Shutdown instrurnentation measures some process '

variables, this information is available in the main control room. Since DBA analyses do not assume that an accident starts while the Control Room is evacuated, the Remote Shutdown instrumentation does not support initial condition assumptions in the DBA. CRITERION 2 is not satisfied.

3. Remote Shutdown instrumentation is not a structure, system, or component that is nart of the primary success path and which functions or actuates; to mitigate a DBA. CRITERION 3 is not satisCed.

4 (Contiriued) k Page 4 ,

e

e (Continuation of FPC assessment )

DISCUSSION Although installation of Remote Shutdown instrumentation is required by GDC 19, DBA analyses do nat assume that an accident starts while the Control Room is evacuated. Therefore, the Control Room is assumed to be habitable for DBA management, and the instrumentation and controls in the remote location are not needed to provide abnormal transient information. The Control Room is designed for habitability; the event (s) leading to Control Room evacuation has never been clearly defined. Interpretations of the purpose of GDC 19 have often been rend 6 red, and the general purpose for remote shutdown control has been given simply as a uninhabitable Control Room without a specific cause (design basis), such as fire, having been designated.

PRA evaluations typically do not include risk requiring Control Room evacuation.

However, one PRA reviewed included a scoping evaluation of hazardous chemicals.

The results indicated risk was not significant. The same PRAindicated that 6% of the -

core melt frequency was due to fire; all fires were outside of the Control Room.

Thus it was concluded that Remote Shutdown is not a critical element for plant risk. 4 CONCLUSION This current Technical Specification may be relocated to Fire Protection Plan and will be controlled in the same manner outlined in Gener" Letter 88-12 (i.e., a license condition will be provided which precludes changes to the approved Fire Protection Plan without prior NRC approval if those changes would adversely affect the ability to achieve and maintain safe shutdown conditions on the event of a fire).

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l From 1989 through 1992, there were extensive discussions between the Industry and NRC on the scope of the Remote Shutdown Technical Spacification. Briefly;

. Staff concluded that the Standard Technical Specifications (STS) should include alternate / dedicated shutdown equipment provided for the design to comply with the requirements of Appendix R and Remote Shutdown capability of GDC 19. The industry maintained the scope of the LCO should be limited to GDC 19 alone.

. FPC deferred decision on Remote Shutdown Instrumentation relocation due to ongoing generic activities on the issue.

. Issue eventually culminated in an " appeal" on March 19, 1992. As part of the resolution of the appeal, NRC executives concluded the Staff had not consistently implemented the requirement to include the full complement of post-fire safe shutdown equipment in the Technical Specifications, and that it would ' be inappropriate to incorporate broader requirements into the new STS, beyond the Remote Shutdown capability. As part of the appeal, Industry committed to a Technical Specification Administrative Control Program to c:nsure safe shutdown capability.

. Curreat CR-3 Remote Shutdown Instrumentation Technical Specification does not address post-fire safe shutdown capability.

EFFECT OF THE APPEAL DECISION Appeal decision effectively eliminated risk due to fires outside the Control Room in the determination of risk significance of Remote Shutdown instrumentation.

Appeal decision casts serious doubts on consideration of risk due to Control Room /

Cable Spreading Room fire in the determination of risk significance of Remote Shutdown Instrumentation.

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SUBSEOUENT ACTIVITIES On May 25,1993, the Commission approved the final policy statement on Technical Specification improvements (SECY-93-067) subject to the following comment (among others):

" Prior to publication, the Staff should modify the policy statement to clarify how it intends to utilize the PSA as part of its review of Technical Specification change requests. The Staff should explain that if the results of the PSA indicate the Technical Specifications can be relaxed or removed, a deterministic review should be '

performed, and if the results of the deterministic review also support relaxing er removing the Technical Specifications, the Staff should not preclude relaxing or removing such Technical Specifications.

Final pe! icy statement codifies risk significance as a stand alone CRITERION 4.

Policy statement list of Technical Specification LCOs to be retained based upon this CRITERlON continues to .n_qLinclude Remote Shutdown instrumentation.

Previously discussed items basically unaffected by issuance of final policy statement. ,

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CONCt USION ,

FPC has re-evaluated the original CR-3-specific application of the screening criteria to the Remote Shutdown instrumentation Technical Specification. This was done in light of the ,

appeal-decision on the scope of the Technical Specification, issuance of the final policy >

statement, and additional PRA insights gained since 1989 (i.e., IPEEE). We conclude that the original assessment remains valid; Remote Shutdown Instrumentation does not satisfy any of the criteria in the Commission's final policy statement an'd should be relocated out of the CR-3 Improved Technical Specifications.

J f'

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STS Conversion Process  :

, Plant-Specific Review Process

~

onsider fo Proposed Plant-Specific STS Alternatives l I Differences A ,

Confirm Bases t Yes Additions & Changes .

EVALUATE  : STS Change? Consistent With '

Difference Justified by Licensing, Basis -

Unique Design gg

or 4 Different Plant Practice Voluntary No 1

. Licensee Concludes

' ' " Backfit?  ;

Backfit Unwarranted Explain l Appeal?l l'

in SER.

Yes No Explain

! NHR -#901  : -NRC Backfit? , .

in SER-

,  :#3 - 3/93.

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