ML20212B682
| ML20212B682 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/13/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20212B679 | List: |
| References | |
| NUDOCS 9909200199 | |
| Download: ML20212B682 (5) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.187TO FACILITY OPERATING LICENSE NO. DPR-72 EMERGENCY DIESEL GENERATOR LOSS OF POWER START INSTRUMENTATION FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302
1.0 INTRODUCTION
On May 17,1999, Florida Power Corporation (FPC), the licensee, submitted a proposed amendment to Section 3.3.8 of the Crystal River Unit 3 (CR-3) Technical Specifications (TSs).
1 The amendment would modify TS Section 3.3.8, " Emergency Diesel Generator (EDG) Loss of Power Start (LOPS)," Surveillance Requirement (SR) 3.3.8.1 and corresponding basis section.
The proposed change is to revise a note included with the surveillance and to delete a superseded note associated with the surveillance frequency. The surveillance note is revised to eliminate the option for a delayed entry into the applicable Conditions and Required Actions.
2.0 EVALUATION The staff's evaluation of the licensee's proposed changes to the TS is as follows:
2.1 Proposed Chanae to TS Section SR 3.3.8.1 l
The licensee proposed to change the CR-3 TS Section SR 3.3.8.1, which currently reads as follows:
SURVEILLANCE FREQUENCY
-NOTE-When EDG LOPS instrumentation is placed in an inoperable status solely 31 days for performance of this Surveillance, entry into associated Conditions and OB Required Actions may be delayed as follows: (a) up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for the
.. NOTE....
degraded voltage Function, and (b) up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for the loss of voltage Not effective after Function, provided the two channels monitoring the Function for the bus November 23,1997, are OPERABLE or tripped.
60 days Perform CHANNEL FUNCTIONAL TEST.
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PDR ADOCK 05000302 ENCLOSURE P
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2-The proposed amended TS Section would read:
1 SURVEILLANCE '
FREQUENCY NOTE
- When EDG LOPS instrumentation is placed in an -
inoperable status solely for performance of this i surveillance, entry into associated Conditions and Required Actions is not required provided the applicable Condition (s) -
- and Required Actions for the EDG made inoperable by EDG LOPS are antered.
Perform CHANNEL FUNCTIONAL TEST ays The licensee stated that the note, as currently written, is not consistent with the method for performing SR 3.3.8.1. The note currently states that, when EDG LOPS instrumentation is placed in an inoperable status solely for performance of this surveillance, entry into associated Conditions and Required Actions may be delayed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided the two channels monitoring the Function for the bus are OPERABLE or tripped. The CR-3 design and testing configuration do not permit application of the current note. Rather, the CR-3 design and testing configuration requires that the Conditions and Required Actions of Section 3.3.8 be entered when performance of the procedure for SR 3.3.8.1 is started. The proposed change will make the note consistent with the method of performing SR 3.3.8.1.
SR 3.3.8.1 is per' formed concurrently with SR 3.8.1.2 and 3.8.1.3. Each of these surveillances is required every 31 days. Performing these surveillances requires that the EDGs be declared inoperable. During SR 3.3.8.1, the EDGs are made inoperable to prevent an automatic start.
Performing 3.3.8.1 requires placing two channels of either the degraded voltage instrumentation or the loss of voltage channels in the trip blocked condition. In this condition the channels are not operable, nor are they tripped. Because the channels cannot be made operable and cannot be tripped as stated in the current note, the note as currently written cannot be applied. Because CR-3 cannot use the relief provided by the note in SR 3.3.8.1,
' Condition B of Section 3.3.8 is entered when performance of the surveillance is started. The required Action time for Condition B is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Because the average time period for performing the channel functional test of SR 3.3.8.1 is approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, Condition C is entered. The resulting condition is that two channels of degraded voltage or loss of voltage instrumentation are not operable. As a result, the associated EDG would have to be declared inoperable and the Conditions and Required Actions of TS Section 3.8.1 would have to be entered if the EDGs had not already been declared inoperable.
The proposed revised note would allow dir::t entry into TS section 3.8.1 Conditions and Required Actions. Such direct entry will eliminate the administrative burden related to tracking and logging multiple Required Action entries.
Additionally, the licensee proposed to delete the provision in SR 3.3.8.1 Frequency for a 60-day surveillance frequency, and the associated note that the 60-day frequency is not
. effective after November 23,1997. Deletion of the note is appropriate since the note is no longer applicable.
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. The staff evaluated the proposed changes and the licensee's justification for those changes as outlined above.- On the basis of its review, the staff finds that the proposed amendment would make the surveillance consistent with the method of testing and is more conservative than tqe exbting requirements and, therefore, is acceptable.
2.2 Proposed Chanaes to ' S BASES Section SR 3.3.8.1 T
The licensee proposed to change the CR-3 TS BASES section SR 3.3.8.1, which currently reads as follows:
A temporary extension of the Frequency has been made to indicaid "31 days or
' 60 days" as the Frequency. This temporary condition applies to a one-time performance of the surveillance on each diesel generator and will not be effective after November 23,1997. The need for this temporary extension of the frequency became evident during replacement of the radiator on the EDGs.
This activity had a minimum duration of 42 days, which was in excess of the 31-day frequency. Performance of the surveillance on one EDG with the other EDG inoperable because of the radiator replacement was considered as not the safest and most prudent course of action. A note has been added to the frequency to indicate that the 60-day frequency is not effective after November 23,1997.
A note has been added to allow performance of the SR without taking the ACTIONS for an inoperable instrumentation channel although during this time period the relay instrumentation cannot initiate a diesel start. This allowance is based on the assumption that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the average time required to perform channel Surveillance. The 4-hour testing allowance does not significantly reduce the availability of the EDG.
The proposed change to this Bases Section SR 3.3.8.1 is as follows:
A note has been added to allow performance of the SR without taking the ACTIONS for inoperable instrumentation channels although during this time period the relay instrumentation cannot initiate a diesel start. This allowance is based on the assumption that the EDG is maintained inoperable during this functional test and the appropriate actions for the inoperable EDG are entered.
The licensee modified the TS Bases to reflect the proposed change to SR 3.3.8.1. The staff finds that the change to the TS Bases Section is consistent with the requested change to revise the note for the surveillance and is acceptable.
3.0 -
STATE CONSULTATION Based upon a letter dated March 8,1991, from Mary E. Clark of the State of Florida, Department of Health and Rehabilitative Services, to Deborah A. Miller, Licensing Assistant, U.S. NRC, the State of Florida does not desire notification of issuance of license amendments, o
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4.0 ENVIRONMENTAL CONSIDERATION
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- The amendment changes requirements'with respect to installation or use of a facility
. component located within the restricted areas as defined in 10 CFR Part 20. The NRC staff
- has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is
- no significant increase in individual or cumulative occupational radiation exposure. The 1
Commission has previously issued a proposed finding that this amendment involves no
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significant hazards consideration, and there has been no public comment on such finding (64 FR 38026 ). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 52.22(b), no environmental i
impact statement or environmental assessment need be prepared in connection with the
. issuance of the amendment.
5.0 CONCLUSION
Based on the review of the licensee's submittal, the staff finds that the proposed TS change would make the surveillance consistent with the method of performing the testing, and is more conservative than the existing requirement. Therefore, the staff finds the proposed TS change acceptable, w
Principal Contributor: A. Pal Date: September 13, 1999 1
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Mr. John Paul Cowan CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation :
cc:
Mr. R. Alexander Glenn Chairman Corporate Counsel (MAC-BT15A)-
Board of County Commissioners Florida Power Corporation
. Citrus County P.O. Box 14042 110 North Apopka Avenue St. Petersburg, Florida 33733-4042 Invemess, Florida 34450-4245
. Mr. Charles G. Pardee, Director Ms. Sherry L. Bernhoft, 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 Framatome Technologies Inc.
Crystal River Unit 3 1700 Rockville Pike, Suite 525 U.S. Nuclear Regulatory Commission Rockville, Maryland 20852 6745 N. Tallahassee Road Mr. William A. Passetti, Chief __
Crystal River, Florida 34428
- Department of Health Mr. Gregory H. Hainon Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21.._
Director, Quality Programs (SA2C)
Florida Power Corporation Tallahassee, Florida 32399-1741 Crystal River Energy Complex 15760 W. Power Line Street Attomey 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 Communny Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 9
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