View source for 3F0198-34, Forwards Summary of Evaluation of Dynamic Effects of Pressurizer Surge Line LOCA Other Systems & Components,In Response to NRC 971222 Rai.Commitments Made by Util,Encl

{{Adams
| number = ML20199A530
| issue date = 01/23/1998
| title = Forwards Summary of Evaluation of Dynamic Effects of Pressurizer Surge Line LOCA Other Systems & Components,In Response to NRC 971222 Rai.Commitments Made by Util,Encl
| author name = Rencheck M
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0198-34, 3F198-34, GL-87-11, GL-91-18, TAC-M96604, NUDOCS 9801280003
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
| project = TAC:M96604
| stage = Other
}}

=Text=
{{#Wiki_filter:,_                                                 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - -
Slorida 2939Y
:=.?a:
January 23, 1998 3F0198 34 U. S. Nuclear Regulatory Conunission Attn: Document Control Desk Washington, DC 20555-0001

==Subject:==
Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)

==References:==
: 1.                                     NRC to FPC Letter, 3N1297-18, dated December 22, 1997,
                                                           " Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)"
: 2.           FPC to NRC letter, 3F1297-05, dated December 13, 1997,
                                                            " Protection Against Dynamic Effects of LOCA - Request for Additional Information, Evaluation of Jet Impingement Effects ofPressurizerSurgeLine,inspectorFollowupItem(IFI)95-15 02"
: 3.          NRC to FPC letter, 3N0586-30, dated May 23, 1986, " License Amendment 689"
: 4.           FPC to NRC letter, 3F1297-33, dated December 8, 1997,
                                                             " Resolution Plans for USI A-46 and large Bore Piping and Piping Supports"
!                                              5.            FPC to NRC letter, 3F1297 36, dated December 18, 1997, "Large Bore Piping and Pipe Support Calculations - Response to NRC Request for Additional Information"

==Dear Sir:==

Florida Power Corporation (FPC) is submitting this letter to respond to the                                                                                            h$d Request for Additional Information (RAI) in Reference 1. The RAI stated that the                                                                                       ;
December 13, 1997, FPC letter (Reference 2) " appears to address only Service Water (SW) piping and it is not clear whether FPC evaluated the dynamic effects                                                                                      i of a pressurizer surg line loss of coolant accident (LOCA) on any other systems                                                                                          I) and components in the area."
900120o003 98o123 l{,l[]lllltnl l
DR    ADOCK 0500                                            2                                                                                 ll g CRYSTAL RIVER ENERGY COMPLEX 16760 W. Power Line Street
* Crystal River, Florida 34428-6708 e (362) 795 6480 A horlds hopess Corrveny

7         y- .              ..-                                . - - - - . - - - .                                                                   -
l
;                         U. 5. Nuclear Regulatory Commission                                                                                                                                                               l
                       '3F0198 34                                                                                                                                                                                          !
Page 2 of 4 -
FPC
:(RB)    - , performed
                                 .         As part of this                     a review review, FPC        of high                 energy- an performed            lineimpact break              (HELB) of evaluation              ina-the' HELB  Reactor Build originating components                   (SSC) inside the RB.from                                    In addition,       thethepressurizer' evaluation surge       included    line  on systems,. struc postulated-4 breaks in the high energy-portions-of the Core Flood (CF) System lines, Decay                                                                                                                 1 Heat (OH) System drop line, Makeu                                                                                                                                                                 !
Auxiliary Pressurizer Spray -(APS)p                                                                line, and-and:thePurification-Pressurizer            (MU)Spray   System
                                                                                                                                                                                        -line. letdown The-           line, Reactor Coolant- System main-loop piping.- i.e.. " hot-leg" and " cold-leg" piping, 0                         were not included in the scope of this evaluation because these lines qualify for-                                                                                                                !
!                         leakbeforebreakcriteria-asapprovedbyLicenseAmendment#89,datedMayl23,                                                                                                                              j 1986 (Reference 3),                                                                                                                                                                               i o                         FPC identified SSCs that were potential targets of pipe whip or jet impingement from'a HELB for the lines identified above. These interactions represented                                                                                                                     1 i-                        potential deviations from the original: design criteria for protection from the                                                                                                                 '
: dynamic effects of a LOCA.                                                                                                                                                                      !
2                                                                                                                                                                                                                       3 i
:                      _The affected SSCs were dispositioned by one'or more of the following criteria:
1.-           The target is not required for LOCA mitigat. an or the accident is-t                                                   : mitigated by other automatic functions consistent with the: CR-3 licensing basis.
i
                                      ~ 2.             The target has been modified in order to remove it from the path of                                                                                                '
                                                     -the pipe whip and/or the jet impingement envelope.
c                                          -                       -
FPCappliedtheguidanceinGenericLetter(GL)9118,                                                                                 Revision 1.-
                                      - 3.                                                                                                                                                                                t
                                                      - Information to Licensees Regarding NRC Inspection Manual Section on                                                                                               ,
p                                                      Resolution of Degraded and Nonconforming Conditions,"ito disposition                                                                                              i Jnonconformances as follows:
1
                                 .:                                           a.              . The break location was eliminated using the methodology                                                                  l t                                                                                               of NRC GL 87-11,;" Relaxation in Arbitrary Intermediate                                                                  >
Pipe Rupture Requirements,"
                                                                           - b.                 The target was eliminated by implementing NUREG/CR-2913, "Two Phase Jet Loads," methodology for redefinition of                                                                  ;
the jet impingement envelope.                                                                                            ;
i' As p s t of item 3 above, fina1' corrective actions in accordance with GL 91-18,
                         . Revision.1 are required since
: 1.            GL 87-11 wa's applied to -longitudinal breaks on the surge line to r                                                    eliminate them as part of an earlier effort to support Crystal River Unit.3:(CR-3) Restart issue D 58. FPC performed a review of the
:                                                     stresses in both of the CF System lines, the DH Systei.; drop line, i                                                    and' the MU System letdown line and concluded that intermediate
* F                                                . breaks can be eliminated using the criteria allowed by GL 87-11.                                                                                                  '
                                                    .However, the use of GL 87-11 on piping inside the RB for which the
                                                     ' code of record is USAS B31.l.0 - 1967 is not part of the current licensing basis for CR-3.
e p+   ---             C-  r  -=   i-r   M-i.v-     ,siewm-v-+p---,                -w--4e we +      a *-*-se-Tw-e*---g-*               w Pw+-      r+-g--      eig
* w       +-              --
Wr-'v-='r

        ~
l
    .                                                                                                                                -1 is                                                                                                                                   j l
;                                 U.LS. Nuclear: Regulatory Commission                                                                  I
                            ,t 3F0194 34' Page 3 ,of_ 4
: e.                                                                                                                                     :
I'
: 12.        ' NUREG/CR-2913 defines characteristics of the impingement jet.          It'       l
                                                    = differs from the currently. licensed impingement- jet for a LOCA -                !
                                                     'inside the R8 as described in Final Safety- Analysis Report (FSAR)_
Section 14.2.2.5.11..                                                          ,
                                                                                                                                 ,1 FPC will submit a license amendment request providing justification for use of                      '
GL; 87-11 and NUREG/CR 2913 as the licensing -bases for; CR 3 and/or ' propose additional plant modifications that will be completed prior to restart from                         i Refuel 11 in a separate-submittal by Nay 29, 1998.
                                  .The nonconformances described ~ in this letter have been determined to' be
                               -reportable.and LER 98 001 00 will be submitted in accordance with 10 CFR 50.73.-                       '
'                                 The large Bore Piping Program discussed in References 4 and 5 will evaluate these                   [
pipe stresses to ensure the- application;of GL 8711 'for the elimination of                          :
intermediate breaks remains
* acceptable.
+
                               .The RAI noted that CR-3 is required to comply with the requirements of 10 CFR 50,                     !
.                            4 Appendix A, General Design Criteria (GDC) 4, Environmental and Dynamic Effects                      ;
Design Bases.- This is not consistent with the current CR 3' licensing and design                     '
                               - basis. CR 3 systems, structures, and components are designed to the criter'a                         ;
described in FSAR Section 1.4, Principal- Architectural and Design Criterfs.
However, the Emergency Feedwater (EF) System is designed to the current GDC 4
:                              . requirements            because of NUREG 0737, " Clarification of 7#1oAction Plan.               -!
Requirements.* In 1989, the NRC granted a-schedular exemption to GDC-4 to allow                     l h                                 FPC timeLto complete modifications to CR 3 to resolve postulated _HELBs located                     l l-                                outside the RB This schedular exemption did not change the design bases for CR-                 <!
!                                 3 to the GOC in 10 CFR 50,' Appendix. A. : Subsequently, NRC issued NRC.SECY-92-223,                !
:                                 'Resolutton of Devfattons identiffed During the Systematic Evaluatton Program,"                     t dated September-18, 1992, which established the NRC's position regarding the                        '
applicability of the current 10 CFR 50,' Appendix A General Design Criteria (GDC).
L                                 The:NRC's position is that it will; not apply _ the- current Appendix A GDCs to                     >
plants with construction permits issued prior to May 21,1971 and exemptions from the current GDC are not necessary.
j.
f                                                                                                                                     ;
r                                                                                                                                     l Ft
      .                                                                                                                               6
~
if        ' i 1
                          )
    ,.          ..-,.-~.a----~~.-,             - . - - -
                                                            ._--._.-,-.~,..,_--._,,-.~..--,--~,.-~r~,.w.=,,.

o U. S. Nuclear Regulatory Commission
                   *3F0198-34 Page 4 of 4 The commitments in this letter are contained in the Attachment A.
Sincerely, M. W.- Rencheck, Director-NuclearEngineeringandProjects
!-                  MWR/jwt Attachment xc:    Regional Administrator, Region !!
l Senior Resident Inspector NRR-Project Manager I
s
        =. ~ m             m    =
b

ll~ 5. N9cleai Regulatory Commission                                                Attachment A
            * '3F0198 'M Page 1 of 1 i.ist of Regulatory Commitments The folinwing table idehtifies those actions committed to by Florida- Power Corporetton in this document. Any other actions discussed in the submittal represents intended or planned actions by Florida Power Corporation.                            They are described % the NRC for the NRC's inforsation and are not regulatory commitments.       Flene notify the Mar,ager, Nuclear Licensing of any questions regarding this decuran* nr any succiated regulatory commitma' ' .
COMITEEWi ~                                      1Hli.ENENTATION Submit   a   license   amendment           request       providing May 29, 1998                        '
p                  justification for use of Generic letter 87-11 and NUREG/CR 2913 as the licensing bases for CR 3 and/or propose additional plant modifications that will be completed prior to restart from Refuel 11 in a separate subental.
The Large Bore Piping Program will evaluate these Program will take 4 6 pipe stresses to ensure the application of GL 87-11 years                     (2-3             fuel for the elimination of intermediate breaks remains                 cycles)  to implement, acceptable.
      -        .                                 - _     _ - _ .      . . _ ,  ,-..                    _ _ _ .      _    .}}