ML20211P928
| ML20211P928 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/09/1997 |
| From: | Raghavan L NRC (Affiliation Not Assigned) |
| To: | Richard Anderson FLORIDA POWER CORP. |
| References | |
| TAC-M96604, NUDOCS 9710220030 | |
| Download: ML20211P928 (4) | |
Text
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 30666 4001
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October 9, 1997 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 - PROTECTION AGAINST DYNAMIC EFFECTS OF LOCA - REQUEST FOR ADDITIONAL INFORMATION (TAC NO. M96604)
Dear Mr. Anderson:
By letter dated September 29, 1997. you submitted the results of your analysis of the potential dynamic effects of the pressurizer surge line following a loss-of-coolant-accident (LOCA) on the service water (SW) system piping.
On the basis of analysis, you have determined that there are no adverse interactions with the SW system piping.
Your letter indicates that the "... design documentation for the CR-3 [ Crystal River 3) pressurizer surge line is not of sufficient detail to judge the extent of the application of two of the current licensing bases to the surge line dynamic interactions --longitudinal breaks and jet fluid angle." Your present analysis did not include longitudinal pipe breaks in the pressurizer surge line following the guidelines in Generic Letter (GL) 8711. " Relaxation in Arbitrary Intermediate Pipe Rupture Requirements." and assumed a 20 cone angle (instead of the present licensing basis of 30 cone angle) as described in Standard Review Plan (SRP) 3.6.2. " Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of piaing." and ANSl/ANS Standard 58.2-1980. " Design Basis Protection of Lig1t Water Nuclear Power Plants." You plan to reflect the licensing basis changes (i.e..
eliminating the longitudinal ruptures, and use of 20' cone angle) in the Final Safety Analysis Report (FSAR) Revision 24. GL 87-11 permits licensees to not
)ostulate longitudinal ruptures without prior approval by the U.S. Nuclear Regulatory Coninission (NRC) and therefore is not discussed here.
The discussion below is related to the use of 20 cone angle.
Your September 29, 1997 letter states that "[J)et fluid is assumed to be conical with an included angle of 30 " and it is our understanding that this constitutes your current licensing basis relative to this issue.
Your letter states that you have determined that changing the jet impingement geometry from 3Y to 20 is not an Unreviewed Safety Question (US0) because the change implements " analytical techniques that are consistent with NRC guidelines and do not conflict with methodologies already reviewed and approved by the NRC for CR-3."
Your letter also states that the change in the jet impingement geometry from 30* to 20* is not an US0 because it is consistent with SRP 3.6.2 f
NRC's approval of your " Pipe Rupture Analysis Criteria Outside the Reactor (w I/
Building." dated December 18. 1989.
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1 Roy A. Anderson We do not agree with your US0 determination relating to jet impingement angle.
The SRPs are written "so as to cover a variety of site conditions and )lant designs" and inform licensees of the methodologies that may be accepta)le to the staff.
Therefore, using methodologies different from the current licensing basis without prior NRC review merely because a methodology is consistent with an SRP, is not an appropriate basis for the US0 determination per 10 CFR 50.59, particularly when the SRP was iseued after issuance of the operating license for the facility.
Further. your December 18. 1989 criteria, paragraph 1.2 states that "[T]he criteria for postuidting break locations and providing protection methods for Reactor Coolant System primary piping or other piping inside the containment structure are not within the scope of this report" and thus, is not applicable to the pressurizer surge line which is located inside the primary containment.
It is our opinion that you must assess the change in the jet impingement angle in accordance with the 10 CFR 50.59 criteria independent of the SRP.
If you determine that the change is an US0. the current SRP guidance may provide relevant safety analysis for a subsequent license amendment request. We consider your Restart Issue D-58. " Design Requirements for Dynamic LOCA Effects" to be open and the issue requires resolution prior to restart.
We are concerned at your performance in this area of 10 CFR 50.59 implementation.
The issue addressed in this letter, and other examples such as crediting the reactor coolant hot leg gap as a method for preventing boron precipitation based on a staff letter to the Babcock and Wilcox owners group.
demonstrate continued weakness in understanding and implementing the 10 CFR 50.59 requirements.
Please determine the extent of condition and inform us of your corrective action to improve your performance in this area.
We request your response within 30 days of receipt of this letter.
If you have any questions regarding this matter, please write or call me at (301) 415-1471.
Sincerely.
Original signed by:
L. Raghavan Project Manager Project Directorate H-3 Division of Reactor Projects - 1/11 Offie of Nuclear Reactor Regulation Docket No. 50-302 cc: See next page Distribution Docket File Public CR-3 Reading B. Boger J. Zwolinski OGC ACES R. Wessman K. Manoly J. Jauden Document Name: G:\\ CRYSTAL \\96604.LTR To receive a copy of this document, indicate in the box:
"C" - Copy without attachment / enclosure
"_E"_- Copy with attachment / enclosure "N" - No copy 0FFICE PDII-3/PM l
PDil-3/LA PDil-3/D,i lC l
NAME LRaghavan W BClayton M FHebdon 'N i
DALE 10/q /97 10/ 4 /97 10/(R /97 l
0FFIClAL RECORD COPY J
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a Roy A. Anderson i We do not agree with your US0 determination relating to jet impingement angle.
The SRPs are written "so as to cover a variety of site conditions and plant designs" and inform licensees of the methodologies that may be acceptable to the staff.
Therefore, using methoaologies different from the current licensing basis without prior NRC review merely because a methodology is consistent with an SRP. is not an appropriate basis for the US0 determination i
per 10 CFR 50.59. particularly when the SRP was issued after icsuance of the operating license for the facility.
Further, your December 18. 1989 criteria, paragraph 1.2 states that "[T]he criteria for postulating break locations and providing protection methods for Reactor Coolant System primary piping or other piping inside the containment structure are not witt' the scope of this i
report and thus. is not applicable to the pressurizer surge line which is located inside the primary containment, It is our opinion that you must assess the change in the jet impingement angle i
in accordance with the 10 CFR 50.59 criteria inctependent of the SRP.
If you determine that the change is an US0. the current SRP guidance may provide l
relevant safety analysis for a subsequent license amendment request.
We consider your Restart Issue D-58 " Design Requirements for Dynamic LOCA 4
Effects" to be open and the issue requires resolution prior to restart.
I We are concerned at your performance in this area of 10 CFR 50.59 implementation.
The issue addressed in this letter and other examples such as crediting the reactor coolant hot leg gap as a me,thod for preventing boron i_
precipitation based on a staff letter to the Babcock and Wilcox owners group, i
demonstrate continued weakness in understanding and implementing the 10 CFR j
50.59 requiremer.ts.
Please determine the extent of condition and inform us of your corrective action to improve your performance in this area.
We request 4
your response within 30 days of receipt of this letter.
l If you have any questions regarding this matter, please write or call me at j
_ (301) 415-1471.
1 l
Sincerely.
L.
ML L. Raghavan. Project Manager p
Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-302 c
i cc:
See next page 1
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Mr. Roy A. Anderson CRYSTAL RIVER UNIT N0. 3 Florida-Power Corporation CC:
Mr. R. Alexander Glenn Mr. Robert E. Grazio. Director l
Corporate Counsel Nuclear Regulatory Affairs (SA2A) i Florida Power Corporation Florida Power Corporation MAC ASA Crystal River Energy Complex P.O.-Box 14042 15760 W. Power Line Street St. Petersburg, Florida 33733-4042 Crystal River. Florida 34428-6708
)
Mr. Charles Pardee. Director Senior Resident Inspector Nuclear Plant Operations (NA2C)
Crystal River Unit 3 Florida Power Corporation U.S. Nuclear Regulatory Commission Crystal River Energy Complex 6745 N. Tallahassee Road 15760 W. Power Line Street Crystal River. Florida 34428 Crystal River. Florida 34428 6708 Mr. John P. Cowan Mr. Bruce J. Hickle. Director Vice President. Nuclear Production Director Restart (NA2C)
(NA2E) l 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 i
Mr. Robert B. Borsum Mr. James S. Baumstark B&W Nuclear Technologies Director. Quality Programs (SA2C) 1700 Rockville Pike Suite 525 Florida Power Corporation Rockville. Maryland 20852 Crystal River Energy Complex 15760 W. Power Line Street Mr.- Bill Passetti Crystal River. Florida 34428-6708 Office of Radiation Control De)artment of Health and cRegional Administrator. Region 11 Rehabilitativ? Services U.S. Nuclear Regulatory Commission 1317 Winewood Blvd.
61 Forsyth Street. SW.
Suite 23T85 Tallahassee. Florida 32399 0700 Atlanta, GA 30303 3415 Attorney General Mr. Kerry Landis Department of Legal Affairs U.S. Nuclear Regulatory Commission The Capitol 61 Forsyth Street. SW., Suite 23T85 Tallahassee. Florida 32304 Atlanta, GA 30303-3415 Mr. Joe Myers. Director Division-of Emergency Preparedness Department of Comunity Affairs 2740 Centerview Drive Tallahassee. Florida 32399-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue
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Iverness. Florida 34450 4245 L
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