ML20206G197

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Forwards Summary of 990412 & 14 Telcon with FPC Representatives Re NRC Questions Concerning Util 980729 & 1120 Ltrs Requesting Approval to Adopt NEI 97-03 Draft Final Rev 3, Methodology for Development of Eal
ML20206G197
Person / Time
Site: Crystal River Duke energy icon.png
Issue date: 05/04/1999
From: Wiens L
NRC (Affiliation Not Assigned)
To: Cowan J
FLORIDA POWER CORP.
References
TAC-MA1706, NUDOCS 9905070119
Download: ML20206G197 (10)


Text

'~

Mr. John Paul Cowan

~ Vice President, Nuclear Operations N'T 4> 1999 Florido Power Corporation ATTN: Manager, Nuclear Licensing (NA2C)

Crystal River Energy Complex 15760 WiPower Line Street

. Crystal River, Florida 34428 6708

SUBJECT:

SUMMARY

OF CONFERENCE CALL CONCERNING ADOPTION OF NEW EMERGENCY ACTION LEVEL METHODOLOGY (TAC NO. MA1706)

Dear Mr. Cowan:

By letter dated July 29,1998, and revised by letter dated November 20,1998, Florida Power Corporation (FPC) requested approval to adopt Nuclear Energy Institute 97-03 Draft Final Revision 3, " Methodology for Development of Emergency Action Levels," for Crystal River Unit

3. On April 12 and 14,1999, representativss of the U.S. Nuclear Regulatory Commission (NRC) staff held a teleconference with FPC representatives to discuss NRC staff questions concoming this request. The enclosure summarizes and documents this teleconference, including our understanding of actions FPC will take to resolve NRC concems. If the understanding of your staff concoming the agreed-to actions differ from ours, please have your staff contact me as soon as possible. The schedule for respond!ng to the action items included in this summary were discussed with John Stephenson of your staff, and it was agreed that a response would be provided within 60 days of receipt of this letter.

Please contact me at (301) 415-1495 if you have any questions regarding this matter.

Sincerely, .  ;

~

Original signed by:

Leonard A. Wiens, Senior Project Manager, Section 2 Project Directorate il LDivision of Licensing Project Management Office of Nuclear Reactor Regulation

~

Docket No. 50-302

Enclosure:

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Mr. John Paul Cowan Vice President, Nuclear Operations Florida Power Corporation ATTN: Manager, Nuclear Ucensing (NA2C)

Crystal River Energy Complex 15760 W. Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

SUMMARY

OF CONFERENCE CALL CONCERNING ADOPTION OF NEW EMERGENCY ACTION LEVEL METHODOLOGY (TAC NO. MA1706

Dear Mr. Cowan:

By letter dated July 29,1998, and revised by letter dated November 20,1998, Florida Power Corporation (FPC) requested approval to adopt Nuclear Energy Institute 97-03 Draft Final Revision 3," Methodology for Development of Emergency Action Levels," for Crystal River Unit 3. On April 12 and 14,1999, representatives of the U.S. Nuclear Regulatory Commiss (NRC) staff neld a teleconference with FFC representatives to discuss NRC staff questions concerning this request. The enclosure summarizes and documents this teleconference, including our understanding of actions FPC will take to resolve NRC concerns. If the understanding of your staff conceming the agreed-to actions differ from ours, please have your staff contact me as soon as possible. The schedule for responding to the action items included in this summary were discussed with John Stephenson of your staff, and it was agreed that a response would be provided within 60 days of receipt of this letter.

Please contact me at (301) 415-1495 if you have any questions regardir,g this matter.

Sincerely, Leonard A. Wiens, Senior Project Manager, Section 2 Project Directorate il Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/enci: See next page

r ISSUES ON CRYSTAL RIVER ENERGY ACTION LEVEL SUBMITTAL DISCUSSED DURING TELECONFERENCES HELD APRIL 12 AND 14,1999 The following issues were discussed during teleconferences held April 12 and 14,1999. The ,

licensee's emergency action level (EAL) is identified in bold typeface followed by a brief summary of the U. S. Nuclear Regulatory Commission's (NRC's) question or concern. The licensee's response is in italic typeface.

EAL 1.1-1 (NUMARC/NESP-007 AU1)

Please verify that all postulated gaseous releases will be monitored by RM-A1 and RWA 2.

Licensee verified that all anticipated gaseous releases will be monitored by RM-A 1 and RM-A2. If a steam generator tube rupture (SGTR) occurs and a secondary safety lifts however, there is no monitor for this type of release.

Please discuss how the thresholds for radioactive releases are set on the radioactive release permit. An example of a radioactive release permit will facilitate discussions.

The licensee stated that a new procedure will be developed to identify the Unusual Event (UE) and Alert thresholds on the radioactive release permits.

EAL 1.1-2 (NUMARC/NESP-007 AU1)

Please discuss why this EAL refers only to the noble gas instantaneous release limit.

The licensee stated that this is the only species which is monitored real-time. lodines and particulates are not monitored as a ;elease rate but rather are collected on a filter and evaluated in terms of the cumulative release.

EAL 1.3-1 (NUMARCINESP-007 AS1-1)

Please discuss the following issues:

Justification for deviation from NUMARC/NESP-007 guidance (i.e., accuracy, timeliness).

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potential numbering error in basis.

Does a shift dose assessment capability exist and if it does, why does the emergency response team need to provide input.

Why a note which provides for classifying on real time dose assessment (when available)instead of radiation monitor setpoints was not included.

What was the source term which was used in establishing the radiation monitor setpoints.

The licensee discussed these issues and will submit the requested justificationhnformation.

Enclosure

O

.c 2-EAL 1.4-2 (NUMARC/NESP-007 AG1)

Please discuss why indication of core damage is necessary to classify this event.

The licensee discussed these issues and will submit the requested justification /infonnation.

EAL 1.7-1,1.8-2 (NUMARC/NESP-007 AU2 3,AA3 2) l Please discuss why this EAL does not include all area radiation monitors. In particular, the  !

staff would like to discuss whether local radiation levels could limit access to safety equipment without causing the listed radiation monitors to exceed the specified setpoints.

The licensee discussed these issues and will consider modifying the EAL to add o- additional monitors to address the NRC concem. The licensee will submit the modified EAL and/orjustification formaintaining cunent EAL.

EAL 1.9 (also EAL 1.10.2)(NUMARC/NESP 007 AU2-1, AA2 2)

Please discuss why this EAL does not specify a water levelin the refueling cavity. l The licensee discussed these issues and will submit the requested justification /information EAL 1.101b (NUMARC/NESP-007 AA2-1)

Please discuss why this EAL refers to increasing trend instead of providing a setpoint. Further,

- the staff would like to discuss how this event would be classified if the increasing trend stabilized.

The licensee discussed theso issues and will consider modiff ing the EAL to address

~ the NRC concem. The liccusee willsubmit the modified EAL and/orjustification for maintaining cunent EAL.

EAL 2.1 (NUMARCINESP-007 HU1-1)

Please discuss why this EAL did not specify Ground motion sensed as a stand-alone condition.

In addition, please discuss the setpoint used (Revision 18 had the annunciated earthquake at the Alert level).

The licensee stated that sensing ground motion may not be a result of an earthquake but may be due to othercauses such as turbine vibration. Furthermore, the licensee stated that the seismic alarm is set et .01g which is below the operating basis  !

earthquake level and is consistent with the NUMARC/NESP-007 guidance. l EAL 2.6 (NUMARCINESP-007 HU1-2) l Please discuss why high winds were not included in this EAL. l The licensee stated that, as described in its deviation document, the primary sources of high winds are hum' canes or tomados. The NRC stated that it needs to further consider whether this deviation is appropriate.

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EAL 2.7 (NUMARC/NESP-007 HA1-2)

. Please discuss an apparent editorial mistake in this EAL.

The licensee stated that it will Rx the editorial mistake and resubmit the corrected EAL.

1 EAL 2.10 (NUMARCINESP-007 HU3-2) l Please discuss why " sheltering" was not included in this EAL.

The licensee stated that it will add sheltering to the EAL and resubmit it to the NRC. \

EAL 2.11 (NUMARC/NESP-007 AU1)

Please discuss why this EAL would not be applicable if personnel protective equipment was used. (The staff would like to discuss whether there are other EALs which include statements in its basis which limit their applicability.)  !

The licensee stated that it can saI61y operate equipment while using protective equipment and that this EAL is similar to one approved for Watts Bar. The NRC stated that there may be situations where operation of equipment needed for safe plant i operation with protective equipment (due to the presence of toxic gases) might represent a potential degradation in the level of safety of the plant warranting a UE

[ unusual event] classiRcation. The NRC stated that it needs to further consicer whether this deviation is appropriate.

EAL 2.15 (NUMARC/NESP-007 HA1-4)

Please discuss the statements limiting the applicability of this EAL contained in the basis for the EAL.

The licensee stated that it is considering ways of modifying the EAL to address the NRC's concems. A teleconference will be scheduled to discuss this issue further.

EAL 2.16 (NUMARCINESP-007 HAS-1)

Please discuss why it is not appropriate to declare this event as soon as possible.

The licensee stated that it is considering ways of modifying the basis for this EAL to address the NRC's concems. The licensee will submit the modified basis and/or Justification for maintaining cunent basis.

EAL 2.17 (NUMARC/NESP-007 HS2)

Please discuss the initiating condition for this EAL and its relationship to the NUMARCINESP-007 guidance. Please discuss the ease of classifying this event using the referenced procedure.

The licensee stated that its EAL does not deviate from the NUMARC/NESP-007 guidance. The NRC agreed. The licensee will evaluate the referenced procedure to ensure it provides sufficient guidance to support class lfying this type of event.

1 4

EAL 2.19, 20 (NUMARC/NESP-007 HA1, HS1)

Please discuss how this EAL corresponds to its NUMARC/NESP-007 counterpart and whether there are any other safeguards events which should be included.

The staff would like to discuss deviations from NUMARC/NESP-007 in the initiating conditions

- specified for the security event EALs. 1 The licensee stated that it would modify its EAL to meet the NUMARC/NESP-007 criteria as appropnate and willhave secunty representatives review the EAL to ensure it captures all safeguard ennis of concem.

EAL 2.21 (NUMARC/NESP-007 HG1)

Ple'ase discuss the justification for this deviation from the NUMARC/NESP-007 guidance.

The licensee stated that it will review the EAL and modify it to meet the NUMARC/NESP-007 guidance orjustify deviations as appropriate.

EAL 2.23 (no corresponding NUMARC/NESP-007 EAL)

Please discuss the statement in the basis regarding the applicability of the EAL.

The licensee stated thatitis considenng ways of modifying the EAL to address the  ;

NRC's concems. A teleconference willbe scheduled to discuss this issue further. l l

EAL 3.2 (NUMARC/NESP-007 SA4-1) i Please discuss why including the condition " reactor power 5% and decreasing" is not a I deviation from the NUMARC/NESP-007 guidance.

The licensee stated that it would modifyits EAL to utilize its EOP [ Emergency Operating Procedure] terminology for the failure to trip the reactor.

EAL 3.3 (NUMARC/NESP-007 SS2-1)

Please discuss whether reactor power less than 5% power corresponds to the power level for which the safety systems are designed.

I The licensee stated that it would modify its EAL to utilize its EOP terminology for the l failure to trip the reactor.

EAL 3.4 (NUMARC/NESP-007 SG2-1)

Please discuss how this EAL relates to the NUMARC/NESP-007 guidance for including indications that heat removalis extremely challenged.

The licensee stated that it was considenng modifying its EAL to include the ,

NUMARC/NESP-007 condition. The licensee stated it would modify the EAL or submit justification for the deviation. j EAL 3.6 (NUMARC/NESP-007 SU31) )

Please discuss the purpose of the annunciator printer. j I

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I

e The licensee described the annunciatorprinter function and will provide further information to the NRC on its use. '

EAL 3.15 (NUMARC/NESP-007 SA3-1)

Please discuss how this EAL relates to the guidance provided in NUMARC/NESP-007.

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The licensee stated that it would modifyits EAL to meet the NUMARC/NESP-007

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guidance. '

EAL 3.16 (NUMARC/NESP-007 SSS-1)

Please discuss how this EAL relates to the guidance provided in NUMARC/NESP-007.

l The licensee explained its use of site-specific indications in the EAL and will submit this !

justification to the NRC. The licensee stated that it would modify those parts ofits EAL b which deviated from the NUMARC/NESP-007 guidance. ,

EAL 4.4 (NUMARC/NESP-007 SG1-1) j Please discuss an apparent editorial error in this EAL.

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The licensee stated that it would correct the editorial error.

i EAL Fission Product Barrier (FPB)- Loss of Fuel Clad based on Radiation Monitor Reading  ;

Please discuss the basis for the setpoint used (e.g. RM-G29 > 100 R/hr).

l The licensee stated that it would re-evaluate the setpoint and submitjustification for the setpoint used.

EAL Fission Product Barrier (FPB)- Potential Loss of Fuel Clad based on CSFS Core l Cooling-Orange OR Heat Sink Red I 1

Please discuss whether there is any equivalent site-specific conditions which can be used to j develop an EAL which corresponds to this NUMARC/NESP-007 EAL.

The licensee stated that it would consider whether other conditions should be included in this EAL and will modify the EAL or submitjustification for this deviation.

EAL Fission Product Barrier (FPB)- Loss of Reactor Coolant System based on Steam l Generator Leak Please discuss:

-. How the loss of adequate subcooling margin is determined and how this setpoint relates to the NUMARC/NESP-007 and NEl EAL guidance.

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How the use of the setpoint "one or more injection valves" relates to the NUMARC/NESP 007 and NEl EAL guidance.

O The licensee described how its site speci6c indications meet the intent of the NUMARC/NESP-007 guidance and will submit thisjustification to the NRC.

4 EAL Fission Product Barrier (FPB)- Potential Loss of Reactor Coolant System based on CSFS RCS Integrity - Red OR Heat Sink-Red Please discuss whether there are any equivalent site-specific conditions which can be used to develop an EAL which corresponds to this NUMARC/NESP-007 EAL.

The licensee stated that it would consider whether other conditions should be included in this EAL and will modify the EAL or submitjustiMcation for this deviation.

EAL- Fission Product Barrier (FPB)- Loss of Containment based on Steam Generator Leak Please discuss how the CR EAL relates to the NUMARC/NESP-007 and NEl EAL guidance.

The licensee described how its site-specific indications meet the intent of the NUMARC/NESP-007 guidance and will submit thisjustification to the NRC.

EAL- Fission Product Barrier (FPB)- Loss of Containment based upon ICC curves Please discuss why the CR EAL did not include the 15-minute criteria provided in the NUMARC/NESP 007 and NEl EAL guidance. In addition the staff would like to discuss why a setpoint based upon reactor vessel level was not included.

The licensee described how its site-specific indications meet the intent of the NUMARC/NESP-007 guidance and wi!I submit this justification to the NRC.

EAL Fission Product Barrier (FPB)- Loss of Containment based upon area Radiation Levels Please discuss whether this EAL might misclassify an event due to shine from the containment in the event of a severe accident.

The licensee determined that misclassification may occur due to shine and decided to delete this EAL.

EAL Fission Product Barrier (FPB)-- Loss of Containment based upon Sump indications Please discuss why CR did not include an EAL equivalent to the NUMARC/NESP-007 EAL ,

" Containment pressure or sump level response not consistent with LOCA conditions."

The licensee stated that it was modifying its EAL scheme to include this EAL.

e NUMARC/NESP-007 EAL SU4 Please discuss whether there are any monitors which may be used in this EAL.

The licensee stated that there were no monitors which could be used. However, monitors in the letdown lines isolate letdown and prompt sample analysis can be used to classify the event.

NUMARC/NESP-007 EAL HUS Please discuss whether rapid depressurization of the secondary side should be included as an EAL. Revision 18 included this condition as an EAL, classified at the Unusual Event level.

The licensee stated that this type of event would be classified as an Unusual Event under EAL 2.12 for catastrophic failure ofpressurized equipment or as an Alert under EAL . The NRC stated that it needed to consider this issue further.

GENERAL The NRC representative stated that, although the licensee had developed its EAL scheme using guidance provided in NEl 97-03, it was reviewing the EAL scheme against the guidance provided in NUMARC/NESP-007 because the guidance in NEl 97-03 had not been approved by the NRC. However, the NRC was considering insights provided in NEl 97-03 in its review.

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O Mr. John Paul Cowan CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation cc:

Mr. R. Alexander Glenn Chairman I Corporate Counsel (MAC-BT15A) Board of County Commissioners Florida Power Corporation Citrus County i P.O. Box 14042 110 North Apopka Avenue l St. Petersburg, Florida 33733-4042 Inverness, Florida 34450-4245 Mr. Charles G. Pardee, Director Ms. Sherry L. Bemhoft, Director Nuclear Plant Operations (PA4A) Nuclear Regulatory Affairs (NA2H)

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 Mr. Michael A. Schoppman Senior Resident Inspector f' Framatome Technologies Inc. Crystal River Unit 3 1700 Rockville Pike, Suite 525 U.S. Nuclear Regulatory Commission Rockville, Maryland 20852 6745 N. Tallahassee Road Crystal River, Florida 34428 Mr. William A. Passetti, Chief Department of Health Mr. Gregory H. Halnon Bureau of Radiation Control Director, Quality Programs (SA2C) 2020 Capital Circle, SE, Bin #C21 Florida Power Corporation Tallahassee, Florida 32399-1741 Crystal River Energy Complex 15760 W. Power Line Street l Attorney General Crystal River, Florida 34428-6708 Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Ta!!ahassee, Florida 32399-2100