View source for 3F0897-25, Application for LAR 216 Proposing Amend to License DPR-72, to Change Design Basis of EDG Air Handling Sys

{{Adams
| number = ML20217Q181
| issue date = 08/26/1997
| title = Application for LAR 216 Proposing Amend to License DPR-72, to Change Design Basis of EDG Air Handling Sys
| author name = Anderson R
| 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 = 3F0897-25, 3F897-25, NUDOCS 9709020016
| package number = ML20217Q183
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 9
| project = 
| stage = Request
}}

=Text=
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Florida Pswer CORPORATION D het o     2 August 26,1997 3F0897-25 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

==Subject:==
License Amendment Request 216, EDG Air Handling System

==Reference:==
FPC to NRC letter, 3F0697-10, " Technical Specification Change Request Notice (TSCRN) 210," dated June 14,1997

==Dear Sir:==

Florida Power Corporation (FPC) hereby submits License Amendment Request (LAR) 216                                     ,
proposing an amendment to Operating License No. DPR-72 for Crystal River Unit 3 (CR-3) to change the design basis of the Emergency Diesel Generator (EDG) Air Handling System.
This proposed design basis change incorporates the results of the revised cooling analysis for the EDG Air Han(lling System due to the EDG upgrade modification to increase the 200-hour and 2000-hour service ratings for each EDG.                         TSCRN 210, referenced above, addressed the Technical Specification changes resulting from 'his EDG upgrade.
The proposed Improved Technical Specifications tlTS) Bases changes of Sections B 3.8.1 and B 3.8.2 support the EDG operability requirements by maintaining proper ventilation of the EDG rooms. The EDG Air Handling System cooling fans are required to maintain the temperature of the EDG engine room and EDG control room within the diesel manufacturer's limits. Based on analysis, fan supply air temperature.        a single However, fan or thedual    fan results     operation of the              has revised analysis    beenoperation to support evaluated of > to be accep two cooling fans for each EDG to maintain the temperature of the EDG rooms within the manufacturer's limits, involves an unreviewed safety question (USQ) requiring NRC approval.                        t' i
The enclosure to this submittal provides the basis for, and a description of, the proposed LAR and an evaluation which concludes that the proposed changes do not involve a significant hazard. Proposed Technical Specification Bases page changes are provided with this enclosure.
                         . .'. u b en A D '' ci -                           l h h!!llflhlbllhlll a e . .
CRYSTAL RIVFR ENERGY COMPLEX 15760 W. Power Line Street Crystal River, Horida 34428-6708 (352)795-6486 9709020016 9~0826                                             '"'""""'""*""
PDR       ADOCK 0d000302 P                                          PDR    8

II. S. Nuclear Regulatory Commission -
3F0897-25       -
Page 2 of 3 A set of these changed pages with additions and deletions shown in redline and strikeout is also included. Attachment 1 of the enclosure provides the changes to the CR 3 Final Safety Analysis Report (FSAR) based on this license amendment request. FPC's procedure for license amendment implementation ensures that plant operating procedures and other documentation are revised to incorporate the requirements and operator guidance for single fan and dual fan operation.
FPC requests that the NRC review and approve the proposed changes concurrently with those requested in TSCRN 210 by November 1,1997, and provide for a 304ay post-approval implementation period. This schedule will support the current restart schedule for CR-3.
Please call Mr. David Kunsemiller, Manager, Nuclear Licensing, at (352) 563-4565 regarding any questions concerning this proposed license amendment.
Sincerely,
                                ^
    'Rc ' A. Anderson S nior Vice President
        'uclear Operations RAA/RSC/AEF

==Enclosure:==
License Amendment Request 216

==Attachment:==
FSAR Revision for LAR 216 cc: Regional Administrator, Region 11 Senior Resident inspector NRR Project Manager

            .                                                                                                                        0
: d. S. Nuclear Regulatory Commission 3F0897-25 Page 3 of 3 STATE OF FLORIDA COUNTY OF CITRUS Roy A. Anderson states that he is the Senior 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 infonnation attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, infonnation, and belief.
                                                                                             /Ec  A. Anderson
                                                                                                                        \
                                                                                           . nior Vice President uclear Operations Sworn to and subscribed before me this 86 day of                          Uj u.s /       ,1997, by Roy A.
Anderson, who is personally known to me.
USA ANN MCBRIDE                     ,
                                        -S Notary Public,Stateof Florida My Comm. Exp. 0ct. 25.1999            .
                                                                                                                        / t~
c mm N1 cc 50958 Signature or Notary Public State of Florida lis e         /$n n /71'8s < We Stamp Commissioned Name of Notary Public 1
l 1

        . S. Nuclear Regulatory Commission   '
3F0897'25                         -
Enclosure FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST 216 EMERGENCY DIESEL GENERATOR AIR HANDLING SYSTEM ENCLOSURE

            . S. Nuclear , Regulatory Commission 3F0897'25                               -
Enclosure FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-202/ LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST 216 EMERGENCY DIESEL GENERATOR AIR HANDLING SYSTEM LICENSE DOCUMENT INVOLVED:                                               Improved Technical Specification Bases-PORTIONS:                                       B 3.8.1 - AC Sources-Operating B 3.8.2 - AC Sources-Shutdown

==SUMMARY==
OF CHANGES TO SPECIFICATION BASES B 3.8.1 AND B 3.8.2:
Florida Pbwer Corpomtion (FPC) pruposes changes to tie Crystal River Unit 3 (CR-3) Improved Technical Specification (ITS) Bases to revise the LCO portions of Section B 3.8.1 and Section B 3.8.2 to state that EDG operability requires proper ventilation using EDG Air Handling System cooling fan (s) for each EDG in order to maintain the temperature of the EDG engine room and EDG control room (i.e., EDG rooms) within manufacturer's limits, Based on analysis, single fan or dual fan operation is acceptable dependent upon fan supply air temperature. The proposed change to operate two cooling fans for each EDG to maintain the EDG rooms within manufacturer's limits has been determined to involve an unreviewed safety question and requires a license amendment.
Reason For.hDEst This proposed change incorporates the results of the revised cooling analysis for the EDG Air Handling Sysicm due to the EDG upgrade modification to increase the 200-hour and 2000-hour                     i service ratings for each EDG. The results of the revised analysis to operate two cooling fans for each EDG to maintain the temperatu : of the EDG engine room and the EDG control room within the manufacturer's limits, involves an unreviewed safety question.
To address this EDG Air Handling System design basis change, Attachment 1 provides the
,          changes to the CR-3 FSAR based on this license amendment request. The information in Attachment 1 is based upon the most recent information available for the EDG modifications.
Finalized changes to the FSAR are being completed via the FSAR change program.

l U. S. Nuclear , Regulatory Commission-
                " 3F0897'-25
                - Enclosure Evaluation of Request EDG Modifications-The upgrade of the EDG 200-hour and 2000-hour service ratings _are to be accomplished by
                 . changes to the diesel engines and other plant _ systems. TSCRN.210 addressed the Technical
                 - Specification changes resulting from this upgrade.
                 .- EDG Cooling Fans Analysis '
                 ' The EDG Air Handling (AH-XL) System provides continuous ventilation, and dissipates internal i heat gains in the EDG engine room and EDG control room (i.e., EDG rooms) when the diesel is '
                  - operating. The system supplies _ sufficient air to maintain the tercperature of the EDG rooms no s-                - grester than _120*F, which is the manufacturer's limit. Each EDG is provided.with two axial f                 _ flow cooling fans'.
l Per the original system design requirements, two full capacity cooling fans were provided for each EDG, however, only one cooling fan was required to run at a time for each EDG FPC-to NRC letter, dated January 26,1979 (Response to Question #68), confirmed that each diesel" generator room has two 100% capacity fans that supply air to the rooms.'                               j
:In 1987,- FPC recognized that combustion air was being drawn directly from the EDG engine-room at unacceptably high temperatures. The temporary solution was to install additional duct work to discharge room cooling air from the fans in'close proximity to the turbocharger inlet.
         ,-         Since tk room cooling fans (AHF-22A, AHF-22B, AHF-22C and AHF-22D)-wen !!sa F.,
supply combustion air in addition to room cooling air, the total system flow increased above-ithe capacity of one fan, so_two fans were required to operate for each EDG engine room.' . The-temporary modification'was: implemented and tested. - Plant' documentations including 1thei         ;
FSAR, was updated to incorporate the change and to specify that two 50%. capacity fans are
              -   :: required to operate for each EDG engine room.                                                         q In 1990,            ermanent modification was installed to provide a dedicated combustion air flow.
cpath to the turbocharger of each EDG with a cooler air source from outside the EDG engine room. . This permanent solution restored'the EDG. air handling _ system cooling fans .to the original design margin requiring one of two fans to supply air to the EDG engine room. ^ Plant -
documentation was updated to reflect that only one ::ooling fan is required to operate _.per
                             ~
room. - However, the FSAR was inadvertently not updated, and currently remains unchanged,               i 1Therefore, the current FSAR Revision-23 (Reference 1) states that the.EDG. Air' Handling System design basis requires both fans, which is inconsistent with the present design basis that-
                   ~only one fan is required.
                    'Both EDG Air Handling System cooling fans automatically start when their associated diesel
                   ' starts. Subsequent to the EDG upgrade modification, single fan or dual fan operation is

   "           . S. Nuclear Regulatory Commission 3F0897;25 Enclosure I
acce; table dependent upon fan supply air temperature. Dual fan operation is required at fan supply air temperatures equal to or greater than 85'F (Reference 2). The heat load in the EDG rooms will increase due to operating the EDGs at higher power levels. The revised cooling analysis for the EDG Air Handling-System due to the EDG upgrade modiGcation (Reference 2) shows that the increased heat loads in the engine rooms, and the associated required ventilation system flow rates due to operation rd a higher power level, can be accommodated with the operation of both cooling - fans to maintain the maximum room.
l         temperature no greater than 120 F. FPC's procedure for license amendment implementation ensures that plant operating procedures and other documentation are revised to incorporate the requhements and operator guidance for single fan and dual fan operation.
4 The proposed change to operate both cooling fans for each EDG to provide adequate                   .
ventilation potentially increases the probability of malfunction of equipment important to safety. Reliance on two fans rather than one has reduced the redundancy of the EDG Air Handling System and increased the probability of malfunction of an EDO. However, a second EDG would remain fully operable. An EDG with one room cooling fan running will continue to operate for some period of time. If the fan supply air temperature is low enough (less than 85'F), the EDG will fulfill its mission with no impact on the life of electrical equipment. The loss of one fan results in increased room temperatures. Room temperatures above the design limit may affect the life of electrical equipment. Temperatures in the emergency diesel control room are monitored and alarmed. Shortening the life of this equipment is not expected to contribute significantly to the probability of EDG failure, i
7'his change is not different from the design basis of others in the industry. Operation of two 50% capacity fans to provide EDG room cooling is similar to the design basis of other licensed facilities within the industry, and there are licensed facilities-that operate with a
.         design basis of one 100% capacity cooling fan having no redundancy.
NO SIGNIFICANT HAZARDS CONSIDERATION An evaluation of the proposed license amendment request has been performed in accordance            <
with 10 CFR 50.91(a)(1) regarding no significant hazards considerations using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to this amendment request follows:
1 - Does not involve a significant increase in the probability or consequences of an
,                accident previously evaluated The proposed change does not involve a significant increase in the probability of an accident previously evaluated. The EDG room cooling fans support operation of the EDGs which are used to mitigate design basis accidents. Although EDG availability is a contributor to the risk of station blackout, the CR-3 licensing basis assumes a station blackout without regard to EDG
         - reliability. Therefore, the probability of previously evaluated accidents is not significantly increased.
              )
U . S. Nuclear Regulatory Commission 31 9897;25-
      -Erdosure ForEsign asis accidents, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated. The proposed change to operate both coolir g fans for each EDG to provide adequate ventilation potentially increases the probability
      . of r.alfunction of equipment important to safety. - However, the proposed changes do not Axt the independence of the EDGs or the independence of the EDG Air Handling Sys_ tem and, based on single failure criteria, one EDG will be fully operable and capable of meeting its mission:at all times) as required by the CR .' Technical Specifications. Therefore, - no significant increase in the consequences of an accident previously evaluated, including the offsite radiological dose exists.
Based on the above, the probability of. an accident previously evaluated has not been significantly_ increased, and this change does not involve a - significant increase in the consequences of an accident previously evaluated.
2 - Does not create the possibility of a new or different kind of accident from any accident
            - previously evaluated The proposed change does not create the possibility of a new or different kind of accident from
       --any accident previously evaluated, Neither the fans nor the EDGs are initiators of any new accidents.- The EDG room cooling fans support operation of the EDGs, which are used to -
mitigate design basis accidents . Reliance on two fans rather._ than 'one has reduced the redundancy of the EDG Air Handling System and increased the probability of a malfunction of an EDG. However, the proposed changes do not affect the independence of the EDGs or the independence of the EDG Air Handling System and, based on single failure criteria, one EDG will be fully operable and capable of meeting its mission at all times as required by_the CR-3 Technical Specifications. Results of analyses to evaluate the failure _of an:EDG to operate following a design basis accident are documented in the FSAR. Therefore, this change does.
not create the possibility of a new or different kind of accident.s 3 - Does not involve a significant reduction in the margin of safety _
The proposed change does not involve a significant reduction in the margin of safety. The        4 EDG room cooling fans support operation of the EDGs. Following this change, two fans will' be required to maintain the EDG engine room and EDG control room temperatures .within the .
design basis limit when the fan supply air temperature is greater than or equal to:85'F.
Reliance on two fans rather than one has reduced the redundancy of the _EDG Air Handling System and slightly increased the probability of malfunction of an EDG, but only after it has     1
        - run for some period of time. However, the proposed changes do not affect the independence of the EDGs or the independence of the EDG Air Handling System and, based on single
        -failure criteria, one EDG will be fully operable and capable of meeting its mission at all times as required by the CR-3 Technical Specifications. Therefore, this change does not result in a significant reduction to the margin safety.
_4_

      ',       S4 Nuclear Regulatory Commission
         ; 3F0897'25 -
Enclosure;
: ENVIRONMENTAL IMPACT EVALUATION
   .        10 CFR 51,22(c)(9) provides criteria fer, and identification _of, licensing and regulatory actions eligible for categorical exclusion from performing 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:-
(1) involve a sigraficant hazard consideration, (2) result in a significant change in the types or significant increase in the amount of any effluents that may be released offsite, or (3) result in -
an increase in individual or cumulative occupational radiation exposure. FPC has reviewed '
this= license amendment and concludes that it meets the eligibility criteria for categorical exclusion- set forth in 10CFR51.'22(c)(9).- Pursuant to;10CFR51.22(c), no environmental Limpact statement or environmental assessment needs to be prepared in connection with the issuance of the proposed Technical Specification changes. The basis for Qis dormination is~
as follows::                                                                                           -
:1. ~ The proposed- license amendment _ does not involve significe.( hazards as described-
               ' previously in the No Significant Hazards Consideration.                                         ,
: 2. This proposed license amendment does not result in a significant change in.the types or sigidficant increase in the amounts of any effluents that may be released offsite. The proposed license amendmerit does not introduce any new equipment nor does it require any;
: existing equipment or- systems to perform a different' type 'of function than they are presently designed to perform. The changes ensure that the. consequences of previously.
               . evaluated accidents will not be increased. FPC has concluded that there willlnot be a significant increase in the types or amounts of any effluents *. hat may be released offsiten and these changes do not involve irreversible environmental consequences beyond those already associated with normal operation.                                                       +
           - 3. The proposed license amendment does not increase individual or cumulative occupational 1 radiation exposure beyond that already associated with normal operation.
REFERENCES-4
                 '1. FPC to NRC letter,3F1196-01, " Final Safety Analysis Report , Revision 23," dated November 18,1996 i
: 2. FPC Calculation H93-0001, "EDG Minimum Ventilation Design Basis." Rev 1        -
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