ML20203C584
| ML20203C584 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/09/1997 |
| From: | Hebdon F NRC (Affiliation Not Assigned) |
| To: | Richard Anderson FLORIDA POWER CORP. |
| References | |
| GL-91-18, TAC-M99892, NUDOCS 9712150355 | |
| Download: ML20203C584 (4) | |
Text
_.
I
,y o t
UNITED STATES
.,j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 300tH001
\\.,,,*/
Deceumber 9,1997 Mr. Roy A. Anderson Senior Vice President Nuclear Operations Florida Power Corporation ATTN: Manager, Nuclear Licensing CrystalRiver Energy Complex (SA2A) 15760 W. Power Line Street Crystal River, Florida 34428-6708
SUBJECT:
CRYSTAL RIVER NUCLEAR GENERATING PLANT UNIT 3 - BORON PHECIPITATION PREVENTION - RESTART REQUIREMENTS (VAC NO.
M99892)
Dear Mr. Andsrson:
The purpose of this letter is to inform you of certain restart schedule discrepancies involving license amendment reauest (LAR) 220, relating to License Condition 2.C.(5) and LAR 223, relating to boron precipitation mitigation.
in a letter dated November 26,1997, you provided the status of Florida Power Corporation's (FPC's) restart issues in Attachment C of your letter, you indicated that both LAR 220 and LAR 223, are required prior to restart. We agree. We do not, however, agree with your determination that LAR 220 is required only prior to Mode 2. Further, the completion target date requested for LAR 223 in your December 4,1997, letter does not appear to be consistent with your restart plan. These issues are discussed below.
In LAR 220, dated October 31,1997, you proposed te revise License Condition 2.C.(5) to delete the requirement for installation and testing of flow indicators in the emergency core cooling system. By "3F1297-21, Forwards Response to NRC Questions & Comments Re Rev 1 to LAR 220,removing Portion of OL Condition 2.C.(5) Re Installation & Testing of Flow Indicators in ECCS to Provide Indication of 40 Gallons Per Min for [[Atomic Element" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Dilution|letter dated December 1,1997]], in a response to a request for additional information, it appears that your intent is to operate in Modes 4 and 3 without satisfying the license condition or receiving approval of LAR 220. The Nuclear Regulatory Commission (NRC) Generic Letter (GL) 91 18, Revision 1, 'information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions,' dated October 8,1997, states *[T]he licensee may make mode changes, restart from outages, etc.,
provided that necessary equipment is operable and the degraded condition is not in conflict with the TS [ technical specifications) or license." Further, GL 91 18 also states 'NRC review and action is required prior to the licensee taking actions that are contrary to compliance with the license condition or TS unless an emergency situation is present such that 10 CFR 50.54(x) t and (y)is applied.'
g Q;
Notwithstanding the guidance in GL 91 18, License Condition 2.C.(5) does not limit its applicability to any specific mode, and therefore, applies to all modes. Therefore, until you provide the flow indicator as required by the license condition or receive a license amendment to modify the requirement you are not in compliance with your license.
!f at%.Qhk
, m ioo2,,e m.000302 o,
PDR ADOCK 0 P
=
Mr. Anderson
-2 1
By letter dated December k,1997, you provided additional information regarding LAR 223 and indicated that you will document the results of certain calculations in support of the LAR by February 27,1998, and, accordingly, requested our approval af the LAR by March 31,1998.
This does not appear to be consistent with your November 26,1997 letter, which indicates that LAR 223 is required prior to Mode 2. Please reconcile this inconsistency and inform us of your target date for approval of LAR 223.
If you have any questions regarding this matter, please write or call me at (301) 4151471.
Sincerely, 08tIGINA14 SIGNED BY:
Frederick J. Hebdon, Director Project Directorate ll 3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-302 cc:
See next page DJatribution Docket File Public CR3 Reading B. Boger J. Zwolinski ACRS T. Collins W. Lyon J.Jaudon Document Name: G:\\ CRYSTAL \\99892.LTR To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
- E" o Copy with attachment / enclosure "N" = No copy
~
1 0FFICE PDil 3/PM,
[E_ PDil 3/LA lE PDII 3/D )
c' OGC e
l NAME LRaghavan 1 1, BClaytond e FHebdon #
.]re w 3 DATE 12/7/97 12/ / /97 12/ 9. /97 12/ 9 /97 /
OFFICIAL RECORD COPY' (cauxunu.
W s Oy C r-7mL.
i
l a
~.
Mr. Anderson
-2 i
r By letter dated December 4,1997, you provided additional information regarding 1.AR 223 and indicated that you will document the results of certain calculations in suppori of the (AR by J
February 27,1998, and, socordingh, requested our approval of the LAR by March 31,1998 This does not appear to be consistent with your November 26,1997 letter, which intilcates th.m init 223 is required prior to Mode 2. Please reconcile this inconsistency and inform as of your target i
date for approval of LAR 223.
If you have any questions regarding this matter, please write u. calline at (301) 4151471.
Sincerely, l
{
M' A<
rw Frederick J. Hebdon Director Project Directorate 113 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation Docket No,50 302 cc: See next page i
s i
.,-e.
-._..,,,J.-..,,--
,m..
y 7
o 4
\\
Mr. Rey A. Anderson CRYSTAL RIVER UNIT N0. 3 Florida Power Corporation CC1 Mr. R. Alexander Glenn Corporate Counsel Mr. Robert E._Grazio, Director Florida Pow 6r Corporation Nuclear Regulatory Affairs (SA2A)
MAC-ASA Florida Power Corporation P.O. Box 14042 Crystal River Energy Complex St. Petersburg, Florida 33733-4042 15760 W. Power Line Street Crystal River Florida 34428-6708 Mr. Charles G. Pardce, Director NuclearPlantDperations(NA2C)
Senior Resident Inspec'ior Florida Power Corporation Crystal River Unit 3 Crystal River Energy Complex U.S. Nuclear Regulatory Commission 15760 W. Power Line Street 6745 N. Tallahassee Road Crystal. River, Florida 34428-6708 Crystal River, Florida 34428 l
Mr. Bruce-J. Hickle, Director Mr. John P. Cowan-Director, Restart (NA20)
Vice President, Nuclear Production Florida Power Corporation Flo(NA2E)
Crystal River Energy Complex rida Power Corporation 15760 W. Power Line Street Crystal River Eners,y Complex Crystal River, Flor 4a 34428-6708 15760 W. Power Line Street l
Crystal River, Florida 34428-6708 Mr. Robert B. Borsum framatome Technologies Inc.
Mr. James S. Baumstark 1700 Rockville Pike, Suite 525 Director, Quality Programs (SA2C)
Rockville, Maryland 20852 Florida Power Corporation Crystal River Energy Complex Mr. Bill Passetti 15760 W. Power Line Street Office of Radiation Control Crystal River, Florida 34428-6708 i.
Department of Health and Rehabilitative Services Regional Administrator, Region 11 1317 Winewood Blvd.
U.S. Nuclear Regulatory Commission Tallahassee, Florida 32399-0700 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415 Attorney General Department of Legal Affairs Mr. Kerry Landis The Capitol U.S. Nuclear Pegulatory Commission Tallahassee, Florida 32304 61 Forsyth Street, SW., Suite 23T85 Mr.- Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Chairmaa Board of County Commissioners' Citrus County 110 North Apopka Avenue Iverness, Florida 34450-4245
--