View source for 3F0498-02, Application for Amend to License DPR-72,clarifying Improved Tech Specs 5.7.2, Special Repts, to State That Complete Results of OTSG Tube Inservice Insp Shall Be Submitted to NRC 90 Days After Startup (Breaker Closure)

{{Adams
| number = ML20217G004
| issue date = 04/23/1998
| title = Application for Amend to License DPR-72,clarifying Improved Tech Specs 5.7.2, Special Repts, to State That Complete Results of OTSG Tube Inservice Insp Shall Be Submitted to NRC 90 Days After Startup (Breaker Closure)
| author name = Cowan J
| 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 = 3F0498-02, 3F498-2, NUDOCS 9804290009
| package number = ML20217G010
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 7
| project = 
| stage = Request
}}

=Text=
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    .           Flrrida Power CORPORATION Dock N 60- 2 Operaung Uconne No. OPR-72 April 23,1998 3F0498-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==Subject:==
License Amendment Request #221, Revision 1 "B" Once Through Steam Generator Tube Surveillance Program and Special Reports

==Reference:==
NRC to FPC {{letter dated|date=October 28, 1997|text=letter dated October 28,1997}}, " Crystal River Unit 3 - Staff Evaluation and Issuance of Amendment RE: Steam Generator Tube Intergranular Attack Degradation (TAC No. M98262)" [3N1097-40]

==Dear Sir:==

The purpose of this submittal is to provide License Amendment Request (LAR) #221, Revision 1 for NRC review and approval. This request proposes a clarification to Improved Technical Specifications (ITS) 5.7.2, "Special Reports," to state that the complete results of the Once Through Steam Generator tube inservice inspection shall be submitted to the NRC 90 days after startup (breaker closure). In addition, ITS pages 5.0-17 and 5.0-29A are being submitted to reflect changes         I made by License Amendment No.158, issued by the NRC in the above referenced letter. Florida                 )
Power Corporation (FPC) has reviewed the Crystal River Unit 3 (CR-3) licensing basis regarding this report and found the proposed changes attached herewith are administrative in nature. The previous conclusion of No Significant Ilazards Consideration is not affected and is being provided          )
for completeness.
There are no new commitments established by this letter or its attachments. If you have any questions regarding this information, please contact Ms. Sherry Bernhoft, Manager, Nuclear Licensing at (352) 563-4566.
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Sincerely,
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John Paul Cowan                      9804290009 9eo423 Vice President                       PDR  ADOCK 05000302 P
Nuclear Operations                 -
PDR                                              j
                                  .vvvv2 j     JPC/LVC                                                                                                 i   !
xc:    Regional Administrator, Region II                                                              N\
Senior Resident Inspector                                                                          \
NRR Project Manager Attachments:
A.
god License Amendment Request and No Significant Hazards Evaluation B.      Set of Changed Pages with New or Revised Information Shown in Strikeout / Shadowed Font C.      Set of Changed Pages with Revision Bars              ,
CRYSTAL RIVER ENERGY COMPLEX: 15760 W. Power Line Street Crystal River. FL 34428-6708 - (352) 7954486     1 A Florida Progrwss Company

            .S. Nuclear Regulatory Conunission i   . 3F0498-02 Page 2 of 2 STATE OF FLORIDA COUNTY OF CITRUS John Paul Cowan states that he is the Vice President, Nuclear Operations for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are tme and correct to the best of his knowledge, information, and belief.
                                                          $ b C-                    ~
John Paul Cowan Vice President Nuclear Operations Sworn to and subscribed before me this A3         day of b10hd                  ,1998,by John Paul Cowan.
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                                                        ~ Signature of Notary Public      l State of Florida
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Personally                   Produced Known                 -OR Identification

1 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 ATTACIIMENT A LICENSE AMENDMENT REQUEST #221, REVISION 1 "B" ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM AND SPECIAL REPORTS License Amendment Request and No Significant Hazards Evaluation i
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U.S. Nuclear Regulatory Commission                                                   Attachment A 3F0498-02                                                                              Page 1 of 4 CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 LICENSE AMENDMENT REQUEST #221, REVISION 1 "B" ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM AND SPECIAL REPORTS LICENSE DOCUMENT INVOLVED: Improved Technical Specifications PORTIONS:          Specification 5.6.2.10, "OTSG Tube Surveillance Program" Specification 5.7.2, "Special Reports"

==SUMMARY==
OF CHANGES:
l Florida Power Corporation (FPC) is proposing a clarification to Improved Technical Specifications (ITS) 5.7.2, "Special Reports," (ITS page 5.0-29) to state that the complete results of the Once Through Steam Generator (OTSG) tube inservice inspection shall be submitted 90 days after startup (breaker closure). ITS pages 5.0-17 and 5.0-29A are being submitted to reflect changes which resulted from the usuance of License Amendment No.158.
Reason for Reauest These changes are being proposed to reflect the impact from the issuance of License Amendment       i No.158 and to provide clarification to the time for submitting the complete results of the OTSG     l tube inservice inspection to assure timely submittal of this report. The changes to the submitted   l pages are administrative in nature (format only).
Lustification for Reauest                                                                           l License Amendment No.158 was issued after License Amendment Request (LAR) #221,                     !
Revision 0, had been submitted to the NRC. With respect to ITS pages 5.0-17 and 5.0-29A,            ,
G .equest simply provides updated ITS pages to reflect the changes made to these pages as a         !
result of the issuance of License Amendment No.158. This submittal is consistent with the FPC commitment provided in LAR #221, Revision 0, to provide updated pages after issuance of             i License Amendment No.158.
FPC is proposing a clarification to the time for submitting the complete results of the OTSG tube inservice inspection. Historically, for reporting and scheduling purposes, Crystal River Unit 3 (CR-3) has considered the completion of the OTSG tube inservice inspection to coincide with breaker closure. This position is typical at other nuclear plants as well. Although this practice has been applied consistently through previous outages, its basis had never been investigated or documented. To confirm that such a position is consistent with the CR-3 licensing bases, a search was performed which included correspondence related to License Amendment Numbers 154 and 158 along with a Confirmatory Action letter (Reference 6). The 90-day reporting requirement was first implemented by License Amendment No.154. The only specific instance related to when the clock starts for the 90-day report is addressed in the Safety Evaluation Report (SER) for License Amendment No.158 which reads as follows:

U.S. Nuclear Regulatory Commission                                                   Attachment A 3F0498-02                                                                              Page 2 of 4
         " Staff guidance for the implementation of a voltage-based SG tube repair criteria for Westinghouse model SGs in Generic letter (GL) 95-05 recommends establishing inspection reporting requirements to the NRC. Specifically, licensees are required to notify the NRC prior to returning the SGs to service of conditions that could warrant a staff assessment of the tube inspection results. . In addition, licensees are required to submit a more comprehensive operational and condition monitoring assessment within 90-days after startup."
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           ...the staff believes that the long range progress of the dispositioning tubes with pit-like IGA degradation as defective or degraded based on bobbin coil eddy current data should be monitored through reporting requirements in a manner consistent with alternate SG repair criteria approved by the NRC (e.g., GL 95-05). Therefore, the staff has concluded that the licensee's proposal to modify TS 5.7.2, Special Repo,ts, is appropriate and acceptable."

== Conclusion:==

From the review of References 1 through 6, and based on the above information, submitting the 90-day OTSG Report within 90 days of startup (breaker closure) is consistent with NRC expectations. FPC considers that the analysis provided in LAR #221, Revision 0 remains valid.
The previous conclusion of No Significant Hazards Consideration is not affected. However, it is being provided herewith for completeness.
REFERENCES
: 1.       Generic 12tter 95-05, " Voltage-Based Repair Criteria for Westinghouse Steam Generator Tubes Affected by Outside Diameter Stress Corrosion Cracking," Section 6b, "Information To Be Provided Following Each Restart"
: 2.         FPC to NRC {{letter dated|date=March 21, 1996|text=letter dated March 21,1996}}, 3F0396-19, " Technical Specification Change Request No. 203, Revision 2"
: 3.        NRC to FPC {{letter dated|date=April 30, 1996|text=letter dated April 30,1996}}, 3N04%-25. " Crystal River Nuclear Generating Plant Unit 3 - Issuance of Amendment RE: Alternate Repair Criteria for Steam Generator Tubing (TAC No. M92548)"
: 4.         FPC to NRC {{letter dated|date=August 20, 1997|text=letter dated August 20,1997}}, 3F0897-10, " Technical Specification Change      ;
Request Notice No. 211, Revision 1"                                                      j
: 5.        NRC to FPC {{letter dated|date=October 28, 1997|text=letter dated October 28,1997}}, 3N1097-40, " Crystal River Unit 3 - Staff       !
Evaluation and Issuance of Amendment RE: Steam Generator Tube Intergranular Attack Degradation (TAC No. M98262)"
: 6.        NRC to FPC {{letter dated|date=April 26, 1994|text=letter dated April 26,1994}}, 3N0494-21, " Crystal River Nuclear Generating Plant Unit 3 - Confirmatory Action I2tter (CAL) - Regarding _Once-Through Steam
                 ' Generator (OTSG) Tube Inspection During Refuel 9"                                        l l

U.S. Nuclear Regulatory Commission                                                   Attachment A
  . 3F0498-02                                                                              Page 3 of 4 NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION An evaluation of the proposed License Amendment Request (LAR) has been performed in accordance with 10 CFR 50.91(a)(1) regarding significant hazards considerations, using the standards in 10 CFR 50.92(c)." A discussion of these standards as they relate to this LAR follows:
Criterion 1 Does Not involve a Sigmpcant increase in the Probability or Consequences of an Accident Previously Evaluated The purpose of an OTSG tube inservice inspection is to identify tubes that have a higher potential for inservice failure due to degradation that results in a reduced ability to withstand normal and upset operating conditions. The formal incorporation of specific indication growth monitoring and repair criteria is consistent with this purpose. Therefore, the probability of an accident previously evaluated has not been increased.
Chapter 14 of the CR-3 Final Safety Analysis Report (FSAR) provides an analysis to assess the consequences of a steam generator tube rupture event, including the complete. severance of a steam generator tube. This analysis concluded that CR-3 was sufficiently designed to ensure that in the event of a steam generator tube mpture, the radiological doses would not exceed the allowable limits prescribed by 10 CFR 100. This would not result in additional tube failures or further degradation of the integrity of the reactor coolant pressure boundary. The proposed changes do not alter this analysis in any fashion. Therefore, the consequences of an accident have not been increased.-
Criterion 2 Does not Create the Possibility of a New or Diferent Kind of Accident from any Accident Previously Evaluated This change does not alter the design or operation of the OTSGs. The incorporation of the proposed requirements is more conservative than the existing ITS requirements. Neither the type of inspection of OTSG tubes nor the process for performing inspections will be changed by this amendment. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3 Does Not Involve a Sigmpcant Reduction in the Margin of Safety as depned in the Basesfor any Technical Specipcations The previously performed analysis on the effects of OTSG tube failures, as reported in the CR-3 FSAR, has demonstrated that onsite and offsite consequences are within allowable limits. The proposed change incorporates more conservative growth monitoring and operational assessment criteria for the "B" OTSG first-span pit-like intergranular attack (IGA) indications. This change does not result in a significant reduction in the margin of safety as defined in the Bases for any Technical Specifications.

U.S. Nuclear Regulatory Commission                                                       Attachment A 3F0498-02
    .                                                                                                Page 4 of 4 ENVIRONMENTAL IMPACT EVALUATION l
10 CFR 51.22(c)(9) provides criteria for identification of licensing and regulatory actions eligible for categoric exclusion from perfonning an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not:
l (i)     involve a significant hazards consideration, (ii)    result in a significant change in the types or significant increase in the amounts of  .
any effluents that may be released offsite, and (iii) result in a significant increase in individual or cumulative occupational radiation exposure.
l FPC has reviewed this license amendment and concludes it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(c), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the proposed license amendment for changing the "B" OTSG tube inspection and reporting requirements.
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