ML20203A046

Provides Comments on Jco for Crystal River Unit 3 Related to Control Complex Habitability Envelope.Concludes That Reasonable Assurance Exists That CR-3 Control Room Doses Following Design Basis Accidents Will Meet Requirements

ML20203A046
Person / Time
Site:	Crystal River
Issue date:	02/03/1998
From:	Raghavan L NRC (Affiliation Not Assigned)
To:	Richard Anderson FLORIDA POWER CORP.
References
TAC-M91823, NUDOCS 9802230255
Download: ML20203A046 (6)

Text

-.

.4 February 3, 1998 A

Mr. Roy A. Anderson Senior Vice President, Nuclear Operations Florida Power Corporation ATTN: Manager, Nuclear Licensing Crystal River Energy Complex (SA2A) 15760 W. Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

CRYSTAL RIVER NUCLEAR GENERATING PLANT UNIT 3 - CONTROL COMPLEX HABITABILITY ENVELOPE JUSTIFICATION FOR CONTINUED OPERATION - INTERIM ASSESSMENT RESULTS (TAC NO.M91823)

Dear Mr. Anderson:

The purpose of this letter is to provide our comments on your Justification for Continued Operat%n (JCO) for Crystal River Unit 3 (CR-3) related to the Control Complex Habitability Envelope (CCHE). Based on the information you provided and the commitments described in your letter of January 14,1998, the staff has concluded that reasonable assurance exists that CR-3 control room doses following design basis accidents will meet the requirements of Title 10 of the Code of FederalRegulations, Part 50, Appendix A, General Design Criterion (GDC)-19 and Ctandard Review Plan Chapter 6.4, during all operating modes. The enclosure provides our basis for the conclusion.

Sincerely, )

Origiml signed by: /

L. Raghavan, Senior Project Manager 3

Project Directorate ll-3 [%;

, , , , 1 ,. f* Division of Reactor Projects l/II /

Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

Interim Assessment Results cc: See next page l[

ll llll !l]- llg

. Distribution Docket File: ..Public CR3 Reading J. Zwolinski ACRS OGC C. Miller ~ J.Jaudon S. LaVie Document Name: G:\ CRYSTAL \91823.SER To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFC PDil-3/PM E PDil-3/LA ,. E PDil-3/D ,1 E' NAME LRaghavan Q BClayton /7 FHebdon 4d DATE 02/JJ98 02/3/98 02/ W98 01/28/98

_ OFFICIAL RECORD COPY

" ." - - " "OI )h D Oh0$02 ' '

P PDR "

1yn u:g**t UNITED STATES

• /) "

NUCLEAR REGULATORY COMMISSION If WASHINGTON, D.C. m

% / February 3,1998 i

Mr. Roy A. Anderson Senior Vice President, Nuclear Operations Florida Power Corporation 1

ATTN: Mane,. t, Nuclear Licensing Crystal River E!nergy Complex (SA2A) 15760 W. Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

CRYSTAL RIVER NUCLEAR GENERATING PLANT UNIT 3 - CONTROL COMPLEX HABITABILITY ENVELOPE JUSTIFICATION FOR CONTINUED OPERATION -INTERIM ASSESSMENT RESULTS (TAC NO. M91823)

Dear Mr. Anderson:

The purpose of this letter is to provide our comments on your Justification for Continued Operation (JCO) for Crystal River Unit 3 (CR 3) related to the Control Complex Habitability Envelope (CCHE). Based on the information you provided and the commitments described in your letter.of January 14,1998, the staff has concluded that reasonable assurance exists that 4

CR-3 control room doses following design basis accidents will meet the requirements of Title 10 of the Code of FederalRegulations, Part 50, Appendix A, General Design Criterion (GDC)- 19 and Standard Review Plan Chapter 6.4, during all operating modes. The enclosure provides our basis for the conclusion.

l Since 'ely, 1 e L. Raghavan, cSenlor Project Manager Project Directorate li-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

Interim Assessment Results cc: See next page

-I Mr. Roy A. Anderson CRYSTAL RNER UNIT No. 3 Florida Power Corporation cc:

Mr. R. Alexander Glenn Chairman Corporate Counsel Board of County Commissioners Florida Power Corporation Citrus County MAC A5A 110 North Apopka Avenue P.O. Box 14042 .

Ivemess, Florida 34450-4245 St. Petersburg, Florida 33733-4042 Mr. Robert E. Grazio, Director Mr. Charles G. Pardee, Director Nuclear Regulatory Affairs (SA2A)

Nuclear Plant Operations (NA2C) Florida Power Corporation Florida Power Corporation Crystal River Energy Complex Crystal River Energy Complex 15760 W. Power Line Street 15760 W. Power Line Street Crystal River, Florida 34428-6708 Crystal River, Florida 34428-6708 Senior Resident Inspector Mr. Bruce J. Hickle, Director Crystal River Unit 3 Director, Restart (NA2C) U.S. Nuclear Regulatory Commission Florida Power Corporation 6745 N. Tallahassee Road Crystal River Energy Complex Crystal River, Florida 34428 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. John P. Cowan Vice President, Nuclear Production Mr. Robert B. Borsum (NA2E)

Framatome Technologies Inc. Florida Power Corporation 1700 Rockville Pike, Suite 525 Crystal River Energy Complex Rockville, Maryland 20852 15760 W. Power Line Street Crystal River, Florida 34428 6708 Mr. Bill Passetti

Office of Radiation Control Mr. James S. Baumstark

! Department of Health and Director, Quality Programs (SA2C)

Rehabilitative Services Florida Power Corporation 1317 Winewood Blvd. Crystal River Energy Complex

t. . Tallahassee, Florida 32399 0700 15760 W. Power Line Street Crystal River, Florida 34428-6708 Attomey General

Department of Legal Affairs Regional Administrator, Region 11 The Capitol - U.S. Nuclear Regulatory Commission Tallahassee, Florida 32304 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303 3415

Mr. Joe Myers, Director Division of Emergency Preparedness Mr. Kerry Landis

- Department of Community Affairs U.S. Nuclear Regulatory Commission l 2740 Centerview Drive 61 Forsyth Street, SW., Suite 23T85 Tallahassee, Florida 32399-2100 Atlanta, GA 30303-3415 i-v 1

. l

[. '

i= l

n CRYSTAL RIVER NUCI FAR GENERATING PLANT UNIT 3

~

CONTROL COMPI FX HABITABILITY ENVELOPE JUSTIFICATION 1

EQB CONTINUED OPERATION -INTERIM ASSESSMENT RESULTS

, As part of Control Complex Habitability Envelope (CCHE) Action Plan, Florida Power i Corporation (FPC or the licensee) modified the Control Room Emergency Ventilation System j (CREVS), performed a tracer gas study of CCHE infiltration, and re-analyzed CCHE accident

! doses.' The measured unfiltered inleakage exceeded the original design basis value. In the -

event of a DBA accident, this increase in inleakage could result in CCHE doses exceeding the

criteria of Title 10 of the Code of FederalRegulativns, Part 50, Appendix A, General Design j- Criterion (GDC)-19. FPC re-calculated the CCHE doses using a revised analysis methodology

. and revised analysis assumptions. FPC also identified this change in methodology as an ,

unreviewed safety question (USQ) and by letter dated December 15,1997, provided the subject Justification for Continued Operation (JCO) to demonstrate operabil;ty of the CCHE as  ;

provided in Generic Letter (GL) 91-18, Revision 1. The licensee provided additional

! information by letters dated November 10,1997 and January 7, and 15,1998 and in meeting l discussions with the staff on November 14, and 20,1997, and January 8, and 14,1998. -

' By letter dated December 24,1997, the staff identified five findings regarding the acceptability [

}- of the JCO and requested additionalinformation. The staff also discussed its request for i additional information (RAI) in a teleconference on January 5,1998. By letters dated *

] January 7, and 15,1998, and in a meeting on January 8,- FPC provided responses to the RAl.

, The staff has reviewed the licensee's response and its determination of these issues, as sequenced as in the staffs RAI of December 24,1997, is provided below:

l 1. Issue 1 regarding the acceptability of the CCHE infiltration tracer test is closed.

1

! 2. The information provided in the licensee's submittals are sufficient to satisfy concems i~ regarding the acceptability of its method of interpreting and applying the infiltration test j results to the dose calculations. Issue 2 is considered to be closed.

3. Issue 3 identified the concem that the licensee's analysis may not be the most limiting j accident with regard to control room habitability. The staff cited results for a letdown line

! failure event that exceed GDC-19. The JCO addresses a LOCA with a loss of offsite l power (LOOP), a LOCA without LOOP, a steam generator tube rupture (SGTR), and a

fuel handling accident (FHA). FPC's position is that the letdown line failure is to be

addressed under the license amendment request 218 (TAC No, M99571) The staff

. identified a concem with the control dose consequences of this event in an RAI issued

, December 9,1997. The control room dose results of this event are appropriately a part

[ of the larger CCHE issue addressed by the JCO since GDC-19 requires the control

. room to be habitable for all accidents. The interim use of the thyroid prophylaxis

, potassium iodide (KI) proposed by you as a compensatory measure (see below)

L provides reasonable assurance that the control room doses resulting from a letdown line l' failure would be within GDC-19. Based on this commitment and on the ongoing license L amendment request 218 proceeding, the staff considers issue 3 to be closed.

I F Enclosure j:

i'- -. . _ - . , .u.____.._...._. _ . . . _ _ _ . _ - _ _ _ _ m. -- __ , , - , .- -

.v-2

4. lasua 4 summarized that several of FPC's assumptions represented deviations from the design basis and from current staff practice and regulatory guidance. The effect of the contested asi amptions would be an increase in postulated CCHE doses. During the teleconference of January 5,1998, and the meeting of January 8, the specific items of concem were identified and addressed.

a. The licensee agreed that iodine plateout in their LOCA analyses had effectively been credited Mice as a result of inconsistent analysis assumptions. The spray .

removal coefficient would change from 20.46 hr' to 20 hr'. The impact of this change is deemed to be negligible and the deficiency can be corrected in a future revision,

b. The staff identified an apparent inconsistency between the assumed maximum iodine decontamination factor (DF) of 100 and the postulated sump pH. The licensee provided evidence that the NRC staff had accepted these assumptions l in previous license amendment No.145, that changed the method of sump pH t

control,

c. The licensee had taken credit for the operation of the auxiliary building ventilation system (ABVS) filters in the LOCA without LOOP analysis. The ABVS system is safety grade but does not have emergency power and was not considered in the LOCA w/ LOOP analysis for this reason. Within the confines of the LOCA without LOOP scenario, it would be appropriate to credit the operation of the filters, if there was reasonable assurance that the filters would be operable.

While the filters are periodically tested under plant procedures, the operability and periodic testing of the filter are not addressed by technical specification, in order to be credited in an accident analysis, the staff requires that the filters be subject to technical specificationt The licensee has committed to propose appropriate technical specifications.

d. There were several concems associated with the SGTR analysis. The major concems involve: (1) the analysis does not address lodine spiking; (2) assumption of iodine mitigation via partitioning in the main condenser, and (3) a limiting single failure has not been assumed. PERB's position is that iodine spiking must be addressed since technical specifications allow operation at RCS radioactivity concentrations that are based, in part, on iodine spiking. These concentrations are greater in magnitude that those assumed in the licensee's analyses. Accident analysis credit is generally not given for iodine mitigation in a pressurized water reactor-main condensers, since the required equipment: (1) is not safety grade; (2) would be rendered inoperable by a loss of offsho power, and (3) would not meet single failure criteria. Design basis analyses are expected to model the most limiting credible scenarios which, for a steam generator tube rupture (SGTR), includes LOOP and iodine spiking.

However, the licensee agreed to re-perform the SGTR analysis using assumptions compatible with the applicable Standard Review Plan (SRP) and to U

t 3

submit the re-analysis results within six months from restart. The licensee may g propose acceptable technical justifications for deviations from the SRP guidance.

References to the prior licensing basis, absent a technical justification, will not be acceptable. If additional modifications are deemed to be necessary in order to show compliance with GDC 19, the licensee will provide a schedule for these modifications. The licensee agreed that needed modifications would be completed prior to restart from refueling outage 11.

The effect of assuming lodine spiking and eliminating credit for iodine mitigation in the main condenser would be to increase postulated control room doses.

Given the magnitude of the licensee's current analysis results, the e::pected increases associated with the revised assumptions, and the licensee's commitment for the timely adminintration of thyroid prophylaxis (KI), the staff

] finds reasonable assurance that the actual control room doses would be within GDC-19.

5. Issue 5 addressed the source term used in the analyses. FPC has confirmed that analyses affected by the source term deficiency had been reviewed and updated as g necessary and that the analyses upon which the JCO v,as based are current. This issue is closed.

The staff reviewed the FPC letter of January 14,1998 that confirmed the discussions between FPC and the elRC staff. The regulatory commitments tabulated in the attachment to that letter are acceptable. On page 2 of the letter, the licensee stated their expectation that changes to dose analysis criteria willinclude consideration of the revi!ed source term and the application of total effective dose equivalent concepts. Rulemaking efforts in this regard are in progress.

However, it is not likely that any regulatory relief afforded by this rulemaking will be available within the time frame of these commitments.

P 5, . . . . - -

--