ML20199F921

Informs That on 971215 FPC Submitted Jco Re Control Complex Habitabiltiy Envelope

ML20199F921
Person / Time
Site:	Crystal River
Issue date:	01/27/1998
From:	Chris Miller NRC (Affiliation Not Assigned)
To:	Hebdon F NRC (Affiliation Not Assigned)
References
TAC-M91823, NUDOCS 9802040167
Download: ML20199F921 (5)

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% January 27, 1098 di$)ORANDUM TO: Frederick J. Hebdon, Director Project Directorate 11-3 Division of Reacto: Projects - 1/ll Office of Nuclear Reactor R3gulation FROM: Charles L. Miller, Chief Emergency Preparedness and f , hI'-

Radiation Protection Eranch Division of Reactor Pmgram Management Office of Nuclear Reactor Regulation

SUBJECT:

CRYSTAL RIVER UNIT 3 CONTROL COMPLEX HABITABILITY ,

ENVELOPE JUSTIFICATION FOR CONTINUED OPERATION (FLOR POWER CORPORATION LETTER DATED ITECEMBER 5,1997)

(TAC NO. M91823) g By letter dated December 15,1997, Florida Power Corporation (FPC) submittec a Justification for Continued Operation (JCO) for Crystal River Uni - (CR-3) related to the Control Complex

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Habnability Envelope (CCHE). As part of its CCHE Action Plan, the licensea modified the Control Room Emergency Ventilation System (CREVS), performed a tracer gas study of CCHE infiltration, and re-analyzed CCHE accident doses. The meawred unfiltered inleakage exceeded the nriginal design basis value. In the event of a DBA accident, this increase in inteakage could result in CCHE doses exceeding the criteria of 10 CFR Part 50 Appendix A, GDC-19. The licensee re-calculated the CCHE doses using e revised analysis methodology and revised analysis assumptions. The licensee property identified this change in methodology as an unreviewed efety question (USQ) and prepared the subject JCO to demonstrate operability of the CCHE as provided in Generic Leiter 9018 Revision 1.

The Emergency Preparedness and Radiation Protection Branch (PERB) performed a review of the JCO. In its review, the PERB staff also considered information provided by the licensee in their letter of November 10,1997, and that presented during technical meetings cenducted on November 14 and 20. My memorandum of December 24,1997 identified five findings regardin the acceptability of the JCO. These findings were provided to the licenses in a request for additional information issued the same day. Personnel from NRR, Region it, the licensee, and I licensee contractors discussed this RAI in a teleconference on January 5,1998. By letter ddated January 7, and in a meeting on January 8, the licensee responded to the issues raised in the RAl. The status of these issues, sequenced as in my December 24 memo, is provided below-1.

Finding #1 regarding ti;e acceptability of the CCHE infiltration tracer test 2.

The licensee provided sufficient information to satisfy concems regarding the acceptability of its method of interpreting and applying the infiltration test results to the dose calculations. Finding #2 is considered to be closed.

CONTACT: Stephen F. LaVie, PERB/NRR 415-1081 NBC FRE CENTdt COPY 9802040167 980127 PDR ADOCK 05000302

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3. Finding #3 identified the concem that the licensee may not have analyzed the most limiting accident with regard to control room habitability. The finding cited the staff results for a letdown line failure event that exceed GDC-ig criteria. The JCO addresses a LOCA with a loss of offsite power (LOOP), a LOCA viithout LOOP, a steam generater tube.

rupture (SG FR), and a fuel handling accident (FHA). The licensee has taken the position that the letdown line failure is to be addressed under license amendment request 218 (TAC M99571). My staff identified a concem with the control dose consequences of this

' event in an RAI issued December 9,1997. The control room dose results of this event are appropristely a part of the larger CCHE issue addressed by the JCO since GDC-19 requires the control room to be habitable for all accidents.- The interim use of the thyroid prophylaxis potassium iodide (KI) proposed by the licensee as a compensatory measure (see below) provides reasonable rssurance that the control room doses resulting from a letdown line failure would be within GDO-19 criteria Based on this commitment and on the ongoing licenso amendment request 218 proceeding, my s'.aff considers finding #3 to

. be closed.

4. Finding #4 summarized that several of the licensee's assumptions represented deviations from the design basis and from current stati practice and regulatory guidance. The effect of the contested assumptions would be an increase in postulated CCHE doses. During the teleconference of January 5 and the meeting of January 8, the specific items of concem were identified and addressed.

a.

The licensee agreed that iodine plateout in their LOCA analyses had effectively been credited twice as a result of inconsistent analysis asumptions. The spray removal coefficient would change from 20.46 hr' to 20 hrd. The impact of this change is deemed to be negligible and the deficiency can be cormcted in a future revision.-

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b. My staff identified an apparent inconsistency between the assumed maximum lodine decor.tamination factor (DF) of 100 and the postulated sump pH. The licencec provided evidence that the NRC staff had accepted these assumptions in the license amendment (145) that changed the method of sump pH control.

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c. The licensee had taken credit for the operation of the auxiliary building ventilation -

system (ABVS) filters in th ? LOCA without LOOP analysis. The ABVS system is safety grade but does not have emergency power and was not considered in the LOCA w/ LOOP analysis for this reason. Within the confines of the LOCA without LOOP scenario, it would be appropriate b credit the operation of the filters, if there was reasonable assurance that the filters would be operable. While the 36rs are periodically tested under plant procedures, the operability and periodic testing of the filter are not addressed by technical spcifk4 ion. In order to be credited in an accident analysis, PERB requires that the filters be subject to technical specifications. The licensee has committed to propose appropriate technical specifications.

d. There were several concems associated with the SGTR analysis. The major concems involve: (1) the analysis does not address iodine spiking; (2) assumption of iodine mitiga tion via partitioning in the main condenser; and (3) a limiting single failure has not been assumed. PERB's position is that bdine spiking must be t

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addressed since technical specifiestions allow operation at RCS radioactivity-concentrations that are based, in part, on iodine spiking. These concentrationr. are greater in magnitude that those assumed in the licensee's analyses. Accide,t

- analysis credit is generally not given for iodine mitigation in PWR main condensers since the required equipment: (1) is not safety grad 6; (2) would be rendered inoperable by a loss of offsite power; and (3) would not meet single failure criteria. Design basis analyses are expected to model the most limiting credible scenarios which, for an SGTR, includes LOOP and iodine spiking. We note that Region 11 has raised issues regarding the suitability of licensee analysis assumptions regarding this event in TIA 97-028 (TAC MA0363).

These issues cannot be resolved in the time frame provided by the licensee's requested restart schedule. However, the licensee agreed to re-perform the SGTR analysis using assumptions compatible with the SRP and to submit the re-analysis results within six months from restart. The licensee may propose acceptable technicaljustifications for deviations from the SRP guidance.

R6ferences to the prior licensing basis, abi,ent a technicaljustification, will not be acceptable, if additional modifications are deemed to be necessary ir, order to she compliance with GDC-1g, the licensee will provide a schedule for these modifications. The licensee agreed that needed modifications would be completed prior to restart from refuelir;g outage 11.

The effect of assuming iodine spiking and eliminating cred;t for iodine m' !on in the mair; condenser would be to incrocse postuisted control room doses. .

the magnitude of the licensee's current armlysis results, the expected increases associated with the revi2ed assumptions, and the licensee's commitment for the o - timely administration of thyroid prophylaxis (KI), PERB finds reasonable assurance that the actual control room doses would be within GDC-ig criteria.

! 5. Finding #5 addressed the source term used in the zaalyses. The licensee confirmed that -

L analyses affected by the source term deficiency had been reviewed, and updated as necessary sind that the analyses upon which the JCO was based are current. This issue is closed.

My staff reviewed the FPC letter of January 14,19g8 that confirmed the discussions between FPC and the NRC staff. The regulatory commitments tabulated in the attachment to that letter are acceptable. On page 2 of the letter, the licensee stated their expectation that changes to dose analysis cmeria will include consideration of the revised source term and the application of TEDE concepts. Rulemaking efforts in t*.h regard are in progress. However, it is not likely that any segulatory relief afforded by this rulemaking will be available within the time frame of these commitments.

PERB expects to provide a safety evaluation of the USQ addressed by this JCO at the completion of its review of the final control room habitability report to be submitted by the licensee.

Conclusion My staff hus concluded, based on the .1bove, that reasonable assurance exists that CR-3 control room doses following design basis accidents will be within 10 CFR Part 50, Appendix A, GDC-19 criteria and SRP Chapter 6.4, during all operating modes.

Docket No. 50-302

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addressed since technicM specifications allow o ration at RCS radioactivity concentrations that are based in on iodine spiking These concentrations are greater in magni,ud t that those assumed in the licensee's analyses. Accident analysis credit is generally not given for iodine mitigation in PWR main condensors since the roouired equipmeat:

would be rendered inoperable by a loss of (1) ispower; offsite not safety and grade; (2)ld not traet single failure criteria wou Design b analyses are e to model the most limiting credible scenanos which, for an SGTP, i s LOOP and iodine spiking. We note that Region 11 has raised issues regarding the suitability of licensee analysis l assumptions regarding this event in TIA 97 028 (TAC MA0363).

These issues cannot be resolved in the time frame provided by the licensee's requested restart schedule. However, the licensee agreed to re-perform the SGTR analysis using assumptioni, compatible with ttie SRP and to submit the re-analysis results within six months from restart. The licensee may propose

acceptable technical justifications for deviations from the SRP ausdanco.

References to the prior licensing basis absent a technicaljustification will not be l acceptable. If additional modifications,are d63med to be necessary in, order to show compliance with GDC-19 the licensee will provide a schedule for these rnodifications. The licensee agr,eed that needed modifications would be completed l; prior to restart from refueling outage 11.

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The effect of assuming iodine spiking and eliminating credit for iodine mitigation in the main condenser would be to increase postulated control room doses. Given the magnitude of the licensee's current analysis results, the expected increases associated with the revised assumptions, and the licensee's commitment for the timely administration of thyroid prophylaxis that the actual cont"ol room doses wouldwi be(KI) thin GDC-19 criteria., PERB finds reasona

6. . Finding #5 addressed the source term used in the analyses. The licensee confirmed that analyses affected by the source term deficiency had been reviewed and updated as necessary and that the analyses upon which the JCO was based are current. This issue is closed.

. FPC My andstaffthe reviewed NRC staff. The the FPC letter regulatory commi of 1998 that confirmed January the discussions 14,tments between in the attachm tabulated are acceptable. On page 2 of the letter, the licensee stated their expectation that ch es to

- dose analysis criteria will include censideration of the revised source term and the tion of TEDE concepts. Rulemaki anyreculatoryrelief aff efforts in this regard are in progress. However, iiis not ely that by this rulemaking will be available within the time frame of these commitments.

PERB expects to provide a safety evaluation of the USQ address.d by this JCO at the completion licensee. of its review of the final control room habitability report to be submitted by the Conclusion My staff has concluded, based on the above, that reasonable assurance exists that CR-3 control room doses following design basis accidents will be within 10 CFR Part 50, Appendix A, GDC-19 criteria and SRP Chapter 5.4, during all operating modes.

Docket No. 50-302 Distribution:

Central File PERB R/F JRoe RAnderson LRaghaven PERB S/F Crystal River CCHE Habitability DOCUMENT To rarmiwa a NAME: G:/SFL/CCHEJCO2.WPD narw of this docurna M inwerata in the har "C" z f%ru win =N-

'_- rf "F" i: Copy w/SttaChmGnt. "N" = No copy 0FC D 3 ERB .

C SC:PERB BC:PERB 6 NAME StaVie h REmch CMillerr/m

-DATE' 1/P/98 1k/98 1//d98 m .

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addressed since technical specifications allow operation at RCS radioactivity cc ,contrations that are based, in part, on iodine spikina These concerications are greater in magnitude that those assumedin the licensee's analy ,es Accident analysis credit is generally not oiven for lodine mitigation in PWR main condensers since the require (equipment:

would be rendered inoperable by a loss of (1) is power, offsite not safety and grade; wou (2)ld not meet single failure criteria. Design basis analyses are to model the most limiting credible scenarios which, for an SGTR, udes LOOP and iodine spiking. We note that Region Il-has raised issues regarding the suitability of licensee analysis assumptions regarding this event in TIA 97-028 (TAC MA0363).

These issues cannot be resolved in the time frame provided by the licensee's requested restart schedule. However, the licensee agreed to re-perform the SGTR analysis using assumptions compatible with ttie SRP and to submit the re-analysis results within s'x months from restart. The licensee may propose acceptable technical)ustifications for deviations from the SRP guidance.

References to the prior licensing basis absent a technicaljustmcation will not be acceptable, if additional modifications,are deemed to be necessary in, order to show compliance with GDC-19, the licensee will provide a schedule for these modifications. The licensee agreed that needed modifications would be completed prior to restart from refueling outage 11.

The effect of assurr.'ng iodine spiking and eliminating credit for iodine mitigation in the main condenser would be to increase postulated control room doses. Given the magnitude of the licensee's current analysis results, the expected increases associated with the revised assumptions and the licensee's comrnitment for the

, PERB finds reasonable assurance timely that tne administration actual control roomofdoses thyroid wouldprophylaxis be wi (KI) thin GDC-19 criteria.

6. Finding #5 addressed the source term used in the analyses. The licensee confirmed that analyses affected by the source term deficiency had been reviewed and upuated as necessar is closed.y and that the analyses upon which the JCO was based are current. This issus 1998 that confirmed the discussions between My FPCstaff and the reviewed NRC staff.the TheFPC lettercommi regulatory of January 14,tments tabulated in the attachment to that letter arc acceptable. On page 2 of the letter the licensee stated their expectation that chan es to dose analysis criteria will include consideration of the revised source term and the a tion of TEDE concepts. Rulemaking efforts in this regard are in progress. However, it is ety that any recuistory relief afforded by this rulemaking will be available within the time frame of these commitments.

PERB expects to provide a safety evaluation of the USQ addressed by this JCO at the completion of its review of the final control room habitability report to be submitted by the licensee.

Conclusion M" staff has concluded, based on the above, that reasonable assurance exists that CR-3 control

- rotz a doses following desion basis accidents will be within 10 CFR Part 50, Appendix A, GDC-19 criteria and SRP Chapter 6.4, during all operating modes.

Docket No. 50-302 t PERB R/F JRoe PERB S/F Crystal River CCHE Habitability RAnderson LRaghaven DOCUMENT NAME: G:/SFi>CCHEJCO2.WPD g rarniva a mnv af this reaceama e andrata in the her "C'" a f?ar v w/n meemehmard "F" = Copy w/atta.hment,"N" = No copy 0FC PERB .

C SC:PERB BC:PERB b NAME' SlaVie = h REmch [ CMiller^/6 DATE. 1/M98 1k/98 1//d98

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