ML20216J910

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Forwards Request for Addl Info Re Submitting Emergency Operating Procedures W/Proposed Changes to Reflect TS Change Request Number 210 Relating to Mitigation of Small Break Loss of Coolant Accidents & Design Basis Changes
ML20216J910
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 09/10/1997
From: Raghavan L
NRC (Affiliation Not Assigned)
To: Richard Anderson
FLORIDA POWER CORP.
References
TAC-M98991, NUDOCS 9709180148
Download: ML20216J910 (5)


Text

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I September 10, 1997 e 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 UNIT 3 - RE0 VEST FOR ADDITIONAL INFORMATION RELATED TO EMERGENCY OPERATING PROCEDURES TECHNICAL SPECIFICATIONS CHANGE RE0lJEST NUMBER 210 (TAC N0. M98991)

Dear Mr. Anderson:

By-letter dated August 4. 1997. you submitted emergency operating procedures (EOPs) with proposed changes to reflect your technical specifications change request number 210 relating to mitigation of small break loss of coolant accidents and associated design basis changes. The purpose of this letter is to request additional information (RAI) relating to the proposed E0Ps.

Enclosed are the details of the RAI.

-We discussed the technical details in a telephone conversation with your staff on September 9, 1997. At your staff's request, we have tentatively scheduled a meeting with your staff at the Nuclear Regulatory Commission headquarters

. offices on Septcmber 18, 1997, to further discuss these issues. We will confirm the meeting date and agerida by a separate meeting notice. We request you to provide a written response.to our RAI before the meeting date.

If you have any questions, please write or call me at (301) 415-1471.

Sincerely.

Original signed by L. Raghavan Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-302 cc: See next page DistribJt'on e Docket Ei g '

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%, September 10, 1997 Mr. Roy A. Anderson Senior Vice President. Nuclear Operations Florida Power Corporation ATTN: Manager. Nuclear Licensing CrgstalRiverEnergyComplex(SA2A) 15,60 W Power Line Street Crystal R M r. F1orida 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 - RE0 VEST FOR ADDITIONAL INFORMATION RELATED TO EMERGENCY OPERATING PROCEDURES - TECHNICAL SPECIFICATIONS CHANGE RE0 VEST NUMBER 210 (TAC N0. M98991)

Dear Mr. Anderson:

By letter dated August 4, 1997. you submitted emergency operating procedures (E0Ps) with proposed changes to reflect your technical specifications change request number 210 relating to mitigatica of small break loss of coolant accidents and associated design basis changes. The purpose of this letter is to request additional informatioq (RAI) relating to the proposed E0Ps.

Enclosed are the details of the RAI.

We discussed the technical details in a telephone conversation with your staff on September 9. 1997. At your staff's request, we have tentatively scheduled a meeting with your staff at the Nuclear Regulatory Commission headquarters offices on September 18, 1997, to further discuss these issues. We will confirm the meeting date and agenda by a separate meeting notice. We request you to provide a written response to our RAI before the meeting date.

If you have any questions, please write or call me at (301) 415-1471.

Sincerely, a f -

L. Raghavan Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50 302 cc: See next page

\

Mr. Roy A. Anderson Florida Power Corporaticc, CR(STAL RIVER UNIT N0. 3 Cc:

Mr. R. Alexander Glenn Corporate Counsel Senior Resident Inspector Florida Power Corporation Crystal River Unit 3 MAC-ASA U.S. Nuclear Regulatory Commission P.O. Box 14042- 6745 N. Tallahassee Road St. Petersburg, Florida 33733-4042 Crystal River, Florida 34428 Mr. Bruce J. Hickle, Director Mr. John P. Cowan Nuclear Plant Operations (NA20) Vice President, Nuclear Production Florida Power Corporation (NA2E)

Crystal River Energy Complex Florida Power Corporation 15760 W. Power Line Street Crystal River Energy Complex Crystal River, Florida 34428-6708 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Pobert B. Borsum B&W Uuclear Technologies Mr. James S. Baumstark

'1700 Rockville Pike, Suite 525 Director, Quality Programs (SA20)

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 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 Regulatory Commission Tallahassee, Florida 32304 61 Forsyth Street, SW., Suite 23T85 Atlar.ta, GA 30303-3415 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32309-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue Iverness, Florida 34450-4245 Mr.- Robert E. Grazio, Director Nuclear Regulatory Affairs (SA2A)

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

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O REQUEST FOR ADDIT ONAL INFORMATION -

EM!RGENCY OPERA"ING PROC EDURES

1. Attachment F- Supporting Information, Crystal River 3 Safety Assessment.

Revision 2, 6/14/97 Please match the operator actions listed in Tables 3A and 3B with the corresponding steps that appear in Crystal River's emergency operating procedures (E0Ps)

2. How much total time (from initiation of each of the three small break-loss-of coolant accident (SBLOCA) events (i.e., loss of battery A (LOBA): loss of battery "B" (LOBB) and the emergency feedwater pump) is available to allow the operator, and the equipment, to complete actions needed before any design basis requirement / limit is exceeded? How were the total times determined (i.e., what were the criteria used to establish the times available to the operator to take the necessary steps)?
3. TSCRN 210. Table 3A Operator Actions Less Than 20 Minutes.

Operator Action 1 - Reference indicates that operator action to trip reactor coolant minutes of what? pumps (RCPs) is accident?

taken "withinInitiation 2 minutes":

within 2 Initiation of the of an alarm?

Please clarify.

4. E0P-3, Inadequate Subcooling Margin (ISM),

a, Entry Conditions How does an operator know that an ISM condition exists i.e., what is meant by "subcooling margin' monitor? What type of instrument is it (analog display, CRT screen, etc.)? Is an ISM easily read or is interpolation needed by the operator? How is the instrumentation qualified (i.e. , per RG 1.97)?

b. Imediate Actions Step 2.1--- How does the operator know whether 2 minutes have elapsed since losing SCM (knowledge of s3ecific time elapsed seems necessary to determine whether to trip all RC)s or have one RCP running in each loop)?

[ Rule 1. Loss of SCM]--- What does this refer to? If this information is important to understanding what the operator does in completing E0P steps, please provide a copy of the rule (as well as copies of all other

" rules' cited in the associated E0Ps).

Enclosure

,i

. 5. During the LOBA condition, how does the operator manually load the "B" Control Complex Chiller on EDG-1B, i.e., is the action carried out from the control room or is it done locally? In either case, what ste)s does the operator takrto accomplish this task and how long does it tate?

The operator has I hour to complete this task, How was this time determined? ' Will the performance of this step be verified / validated as part of the verification / validation (V/V) effort?

6, Under the LOBB condition, please describe the validation that was/will be done to demonstrate that the EFW can be cross-connected before an operational limit is reached.

7. TSCRN 210 Attachment 8, Page 8 14 Describe the process used to conduct the table-top evaluation and simulator V/V. Has the V/V been completed? Have all the crews been trained and tested (i.e., evaluation of the success / failure of the crews
  • performance) on the use of the new procedures? What were the results (i.e., successes vs. failures) of the V/V7 Were the operator acticns required performed with minimum shift staffing as well as normal crew staffing level? If there are any local manual actions required, how were they simulated / considered in the V/V process?
8. In general, when evaluating temporary or permanent changes to a facility that credit operator actions for system or component actuations that were previously automated, the staff has relied on guidance in Generic letter 91-18 and ANSI /ANS 58.8, " Time Response Criteria for Safety-Related Operator Actions." While ANSI-58.8 supplies guidance for determining minimum response times for operator actions, the standard does allow licensees to use time intervals derived from independent sources, provided that they are based on task arialyses to include, among other things, (a) specific operator actions required (b) potentially harsh or inhospitable environmental conditions ex)ected. (c) a general discussion of the ingress / egress paths taken by t1e operators to accomplish functions, (d) procedural guidance for the required actions.

(e) specific operator training necessary to carry out actions including any special qualifications required to perform the actions (f) description of information required by the control room staff to determine such operator actions are required, including uaiified instrumentation used to diagnose the situation and verif that the required action has been successfully taken, and (g) abi ity to recover from credible errors in performance of manual actions and the expected time required to make such a recovery.

Characterization of these items, through detailed analysis including the use of the )lant-specific simulator, 3rovides a means for the licensee to assess tie likelihood of accomplis 11ng the required actions and the consequences of delayed or missed opportunities to complete such actions.

Please discuss your application of the ANSI 58.8 standard for establishing or verifying operator action times. Also, please identify and reference applicable. procedures, and confirm your plan for completing operator training prior to implementing the E0P changes.