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{{Adams
#REDIRECT [[3F0712-07, Response to Third Request for Additional Information to Support NRC Health Physics and Human Performance Branch (Ahpb) Technical Review of the CR-3 Extended Power Uprate LAR]]
| number = ML12216A355
| issue date = 07/31/2012
| title = Crystal River Unit 3 - Response to Third Request for Additional Information to Support NRC Health Physics and Human Performance Branch (Ahpb) Technical Review of the CR-3 Extended Power Uprate LAR (TAC ME6527)
| author name = Franke J A
| author affiliation = Progress Energy Carolinas, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000302
| license number =
| contact person =
| case reference number = 3F0712-07, TAC ME6527
| document type = Letter
| page count = 6
| project = TAC:ME6527
}}
 
=Text=
{{#Wiki_filter:Progress EnergyCrystal River Nuclear PlantDocket No. 50-302Operating License No. DPR-72July 31, 20123F0712-07U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001Subject: Crystal River Unit 3 -Response to Third Request for Additional Information to SupportNRC Health Physics and Human Performance Branch (AHPB) Technical Review of theCR-3 Extended Power Uprate LAR (TAC No. ME6527)References: 1. CR-3 to NRC letter dated June 15, 2011, "Crystal River Unit 3 -LicenseAmendment Request #309, Revision 0, Extended Power Uprate" (ADAMSAccession No. MLI 12070659)2. Email from S. Lingam (NRC) to D. Westcott (CR-3) dated May 14, 2012, "RE:Crystal River EPU LAR (ME6527) -Health Physics Draft RAI"3. NRC to CR-3 letter dated July 5, 2012, "Crystal River Unit 3 Nuclear GeneratingPlant -Request For Additional Information For Extended Power Uprate LicenseAmendment Request (TAC No. ME6527)" (ADAMS Accession No. ML12171A347)Dear Sir:By letter dated June 15, 2011, Florida Power Corporation (FPC) requested a license amendment toincrease the rated thermal power level of Crystal River Unit 3 (CR-3) from 2609 megawatts (MWt) to3014 MWt (Reference 1). On May 14, 2012, via electronic mail, the NRC provided a draft request foradditional information (RAI) related to radiation protection needed to support the AHPB technical reviewof the CR-3 Extended Power Uprate (EPU) License Amendment Request (LAR) (Reference 2) followinga teleconference on May 9, 2012 with FPC to confirm an understanding of the information provided in theCR-3 EPU LAR. On July 5, 2012, the NRC provided a formal RAI required to complete its evaluation ofthe CR-3 EPU LAR (Reference 3).The attachment, "Response to Third Request for Additional Information -Health Physics and HumanPerformance Branch Technical Review of the CR-3 EPU LAR," provides the CR-3 formal response to theRAI.*This correspondence contains no new regulatory commitments.If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Superintendent,Licensing and Regulatory Programs at (352) 563-4796.Jon .FrankeV* e President/(rystal River Nuclear PlantJAF/gweAttachment: Response to Third Request for Additional Information -Health Physics and HumanPerformance Branch Technical Review of the CR-3 EPU LARxc: NRR Project ManagerRegional Administrator, Region IISenior Resident InspectorState Contact 0oCrystal River Nuclear Plant AOO15760 W. Powerline Street mCrystal River, FL 34428 U.S. Nuclear Regulatory Commission3F0712-07Page 2 of 2STATE OF FLORIDACOUNTY OF CITRUSJon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for FloridaPower Corporation; that he is authorized on the part of said company to sign and file with theNuclear Regulatory Commission the information attached hereto; and that all such statementsmade and matters set forth therein are true and correct to the best of his knowledge, information,and belief.Jon .FrankeiVce President/ Crystal River Nuclear Plant/"The foregoing document was acknowledged before me this ,, day ofeC ha ,2012, by Jon A. Franke.Signature of Notary PublicCAROLYN E. PORTMANN ICommission # DD 937553NExpires March 1, 2014Boded Wm Trmy Fain Insm'an800.385.7019_ If(Print, type, or stamp CommissionedName of Notary Public)PersonallyKnown _____ProducedOR- Identification FLORIDA POWER CORPORATIONCRYSTAL RIVER UNIT 3DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72ATTACHMENTRESPONSE TO THIRD REQUEST FOR ADDITIONALINFORMATION -HEALTH PHYSICS AND HUMANPERFORMANCE BRANCH TECHNICAL REVIEW OF THECR-3 EPU LAR U.S. Nuclear Regulatory Commission Attachment3F0712-07 Page 1 of 3RESPONSE TO THIRD REQUEST FOR ADDITIONAL INFORMATION-HEALTH PHYSICS AND HUMAN PERFORMANCE BRANCHTECHNICAL REVIEW OF THE CR-3 EPU LARBy letter dated June 15, 2011, Florida Power Corporation (FPC) requested a license amendmentto increase the rated thermal power level of Crystal River Unit 3 (CR-3) from 2609 megawatts(MWt) to 3014 MWt (Reference 1). On May 14, 2012, via electronic mail, the NRC provided adraft request for additional information (RAI) related to radiation protection needed to supportthe AHPB technical review of the CR-3 Extended Power Uprate (EPU) License AmendmentRequest (LAR) following a teleconference on May 9, 2012 with FPC to confirm anunderstanding of the information provided in the CR-3 EPU LAR. On July 5, 2012, the NRCprovided a formal RAI required to complete its evaluation of the CR-3 EPU LAR. Thefollowing provides the CR-3 formal response to the RAI needed to support the AHPB technicalreview of the CR-3 EPU LAR. For tracking purposes, each item related to this RAI is uniquelyidentified as AHPB X-Y, with X indicating the RAI set and Y indicating the sequential itemnumber.AHPB RAIAHPB 3-1On page 2.10.1-2 of Attachment 5 to the original LAR dated June 15, 2011, the licensee statesthat the zone criteria established for the general accessible areas in the containment was < 25millirem per hour. It acknowledges that during the design of the plant, this was accomplished bydesigning the shields at an assumed power level of 2544 MWt to ensure dose rates at variouslocations were less than the specified zone criteria. The licensee evaluates the impact of the EPUby using actual operating data and providing the total person-rem for containment entries atpower as well as the maximum dose to any individual working at the plant. While it may be truethat the change in dose rates in accessible areas is not expected to increase significantly after theEPU and therefore, cumulative doses can be kept as low as reasonably achievable and individualdoses below Title 10 of the Code of Federal Regulations, Part 20 occupational dose limits, thedose information does not demonstrate that the original dose rates established in the originalshield design will not increase beyond their original design values. Provide justification thatdemonstrates that the dose rates are not expected to increase beyond the dose rates establishedunder the original shielding design analysis performed at an assumed power level of 2544 MWt.Response:The intent of the statement related to the zone criteria established for the general accessible areasin the containment on page 2.10.1-2 of the CR-3 EPU Technical Report (TR) (Reference 1,Attachments 5 and 7) was to acknowledge the historic basis for the plant shielding design asdescribed in Section 11.3, "Radiation Shielding," of the CR-3 Final Safety Analysis Report(FSAR). FSAR Section 11.3 provides a list of radiation occupancy zones; Zones 0 to IV. Asindicated in FSAR Section 11.3, the zones not designed as restricted access (i.e., > 100 mrem/hr)were originally intended to be < 25 mrem/hr. However, there are limited access areas within thereactor building (RB) (i.e., containment), outside the secondary shield, where radiation levelscurrently exceed the historical FSAR Section 11.3 value of 25 mrem/hr excluding considerationof the impact associated with operation at EPU conditions.
U.S. Nuclear Regulatory Commission Attachment3F0712-07 Page 2 of 3The current areas in Zone III that exceed 25 mrem/hr include: the area near a portion of theletdown line that bypasses the RB secondary shield; and the RB sump area. At existing fullpower conditions, the radiation levels in these areas at 30 cm may exceed 100 mrem/hr, but areless than 1000 mrem/hr. Therefore, access at power is restricted by maintaining the RB lockedexcept during periods when RB access is required. Access to both of these areas are controlledby the CR-3 Radiological Protection Program (RPP) in accordance with 10 CFR 20.1601(a) orCR-3 Improved Technical Specifications 5.8.1, "High Radiation Area." FPC has initiated anFSAR Change Request to revise the zone figures in Section 11.3 to identify these areas asrestricted access areas (i.e., Zone IV).The original CR-3 plant shielding design is considered conservative based upon a fission productsource term assumption of 1% failed fuel at full power operation conditions. This is consideredconservative for the following reasons:* 1% failed fuel is equivalent to a Dose Equivalent Iodine-131 (1-131) activity ofapproximately 4.5 [tCi/gm, which is 4.5 times the original operating Dose Equivalent 1-131activity limit of 1.0 &#xfd;tCi/gm; and* 1% failed fuel is 4 times greater than the fission product source criterion of 0.25% failed fuelfor plant shielding design provided in Regulatory Position 2.C of Regulatory Guide 8.8,"Information Relevant To Ensuring That Occupational Radiation Exposures At NuclearPower Stations Will Be As Low As Is Reasonably Achievable," (Reference 2).The Dose Equivalent 1-131 limit is being further reduced for EPU operation from 1.0 PCi/gm to0.25 &#xfd;XCi/gm resulting in limiting fission product sources to approximately 5.5% of that assumedfor the original plant shielding design.Thus, it is reasonable to conclude that, at EPU conditions, the existing plant shielding design cancontinue to limit radiation dose rates from fission product sources to within the rates establishedunder the original shielding design analysis. It is also reasonable to conclude, based on theconservative CR-3 plant shielding design and the Dose Equivalent 1-131 operational limitreduction from 1.0 &#xfd;tCi/gm to 0.25 pCi/gm, that operation at EPU conditions will not result inany accessible RB area radiation level exceeding 1000 mremi/hr; and therefore, will not result inany current accessible area in the CR-3 containment being restricted as a locked high radiationarea.Also, current radiation occupancy and routine personnel access is controlled by the CR-3 RPPand based on plant radiation surveys, which ensures compliance with 10 CFR 20 individual doserequirements and maintains cumulative dose as low as reasonably achievable irrespective of theradiation zones identified in FSAR Chapter 11.Finally, as indicated in Table 2.12.1-3, "Comparison of Proposed EPU Tests to FSAR Chapter13 Initial Startup Testing," of the CR-3 EPU TR, a biological shield survey will be conductedduring power ascension testing at various power levels, up to 100% of the EPU power level, toconfirm the adequacy of the plant radiation shielding.
U.S. Nuclear Regulatory Commission Attachment3F0712-07 Page 3 of 3References1. FPC to NRC letter dated June 15, 2011, "Crystal River Unit 3 -License AmendmentRequest #309, Revision 0, Extended Power Uprate." (ADAMS Accession No.ML1 12070659)2. NRC Regulatory Guide 8.8, "Information Relevant To Ensuring That OccupationalRadiation Exposures At Nuclear Power Stations Will Be As Low As Is ReasonablyAchievable," Revision 3, July 1978. (ADAMS Accession No. ML003739549)
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