ML20199B442

Forwards Request for Addl Info Re License Amend Submittal & 970925 Re FPC Approach for Addressing Certain SBLOCA Scenarios

ML20199B442
Person / Time
Site:	Crystal River
Issue date:	11/05/1997
From:	Raghavan L NRC (Affiliation Not Assigned)
To:	Richard Anderson FLORIDA POWER CORP.
References
TAC-M98991, NUDOCS 9711180322
Download: ML20199B442 (7)

Text

- -- -- .. - . _ - _. _ _ ^ ~ ~ ~ ~

( November 5, 1997

. Mr. Roy A. Anderson

,, 3 Sdnior Vice President Nuclear vperatior.s ,

Florida Power Corpora tion y ATTN: Manager, Nuclear Licensing Crystal River Energy Complex (SA2A)

+

15760 W Power Line Street

, _ Cr)stal River, Fiorida 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION -

LICENSE AMENDMENT RELATED TO TECHNICAL SPECIFICATION CHANGE REQUEST NO. 210, SMALL BREAK LOSS OF COOLANT ACCIDENT (SBLOCA)

D'JBMllTAL (TAC NO. M98991)

Dear Mr. Anderson:

The purpose i f this letter is to request ad6lonal information (RAl) relating to your license amendment submittal dated June 14,1997, as supplemented by letter dated September 25, 1997, regarding Florida Power Corporation's (FPC's) approach for addressing certain SBLOCA scenarios. Speci0cally, the amendment requested a Technical Specification change to support operation with hardware changes involving the Emergency Feedwater System, the High Pressure injection System, and the Emergency Diesel Generators and review and approval of FPC's integrated design and operating, strategies to resolve unreviewed safety questions identified by the U.S Nuclear Regulatory Commission and FPC. The enclosure provides the details for the requested information.

We request your response as soon as possible so that we can schedule our review effort consistent with your restart plan. If you have any questions, please call me at (301) 415-1471.

Sincerely, ORIGINAL SIGNED DY:

L. Raghavan, Project Manager Project Directorate 113 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

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's.... Novenber 5, 1997 Mr. Roy A. Anderson Senior Vice President .

Nuclear Operations -

Florida Power Corporation ATTN: Manager, Nuclear Licensing -

Crystal River Energy Complex (SA2A) 15760 W Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 - REQUEST FOR ADDITIONAL INFORMATION -

LICENSE AMENDMENT RELATED TO TECHNICAL SPECIFICATION CHANGE REQUEST NO. 210, SMALL BREAK LOSS OF COOLANT ACCIDENT (SBLOCA)

SUBMITTAL (TAC NO. M98991)

Dear Mr. Anderson:

The purpose of this letter is to request additional information (RAl) relating to your license amendment submittal dated June 14,1997, as supplemented by letter dated September 25, 1997, regarding Florida Power Corporation's (FPC's) approach for addressing certain SBLOCA scenarios. Specifically, the amendment requested a Technical Specification change to support ,

operation with hardware changes involving the Emergency Feedwater System, the High ,

Pressu.e injection System, and the Emergency Diesel Generators and review and approval of FPC's integrated design and operating strategies to resolve unreviewed safety questions identified by the U.S Nuclear Regulatory Commission and FPC. The enclosure provides the details for the requested information.

We request your response as soon as possible so that we can schedule our review effort consistent with your restart plan. If you have any questions, please call me at (301) 415-1471.

Sincerely, 9

L. Raghavan, Project Manager s

Project Directorate ll-3 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-302 Enclosur3: RAI cc w/ enclosure: See next page 1

l

a Mr. Roy A. Anderson CRYSTAL RIVER UNIT N0. 3 Florida Power Corporation <

CC: ,

Mr. R. Alexander Glenn Corporate Counsel Mr. Robert E. Grazio, Director Florida Power Corporation Duclear Regulatory Affairs (SA2A)

MAC-ASA Florida Power Corporation P.O. Box 14042 Crystal River Energy Complex St. Petersburg, Florida 33733-4042 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Charles G. Pardee, Director Nuclear Plant Operations (NARC) Senior Resident Inspector Florida Power Corporation Crystal River Unit 3 Crystal River Energy Complex U.S. Nuclear Regulatory Commission 15760 W. Power Line Street 6745 N. Tallahassee Road Crystal River Florida 34428-6708 Crystal River, Florida 34428 Mr. Bruce J. Hickle, Director Mr. John P. Cowan Director, Restart (NA2C) Vice President, Nuclear Production Florida Power Corporation (NA2E)

Crystal River Energy Complex Florida Power Corporation 15760 W. Power Line Street Crystal River Energy Complex Crystal Rever, Florida 34428-6708 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. Robert B. Borsum Framatome Technologies Inc. Mr. James S. Baumstark 1700 Rockville Pike, Suite 525 Director, Quality Programs (SA20)

Rockville, Maryland 20852 Florida Power Corporatinn Crystal River Energy Complex Mr. Bill Passetti 15760 W. Power Line Street Office of Radiation Control Crystal River, Florida 34428-6708 Department of Health and Rehabilitative Services Regional Administrator, Region !!

1317 Winewood Blvd. U.S. Nuclear Regulatory Commission Tallahassee, Florida 32399-0700 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415 Attorney General De,)artment of Legal Affairs Mr. Kerry Landis The Capitol U.S. Nuclear Regulatory Commission Tallahassee, Florida 32304 61 Forsyth Street, SW., Suite 23T85 Atlanta, GA 30303-3415 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue Iverness, Florida 34450-4245

O REQUEST FOR ADDITIONAL INFORMATION - LICENSE AMENDMENT RELATED TO IECHNICAL SPECIFICATION CHANGE REQUEST NO. 210,EMALL BREAK LOSS OF COOLANT ACCIDENT (SBLOCA) SUBMITTAL Control Comolex Coolina l

1. The proposed 30-day allowed ot ' age time (AOT) for the chillers and associated pumps appears to be unacceptable and i.1 consistent with what the Nuclear Regulatory Commission (NRC) staff has accepted in the past. The chillers and chilled water pumps serve a number of different safety-related functions in addition to cooling the control room, A 30-day AOT for the loss of single failure protection is only allowed in the Standard Technical Specifications (TS) when it only affects control room cooling Plants that have TS for safety related chilled water systems (see CEOG-STS, NUREG 1432) that cool more than the control room, the accepted AOT has been 7 days. Therefore, it appears that the risk involved with one chiller or pump inoperable dees not support a 30-day AOT. However, for the control complex heat exchanger,30 days is acceptable because the system remains protected from single active failures.

Also, for Fuel Cycle 11, while in Modes 1,2, and 3, the NRC staff believes that the required AOT is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for a Train B chiller or chilled water pump. With CHHE-1B or CHP-1B inoperable, the emergency feedwater/ emergency core cooling system (EFW/ECCS) response to certain SBLOCAs is vulnerable to certain single failures because of the load management problems associated with emergency diesel generator (EDG)-1 A while a Train B chiller or pump is inoperable. As we understand your SBLOCA scenarios, the 1-hour verification of the emergency feedwater pump (EFP)-2 (CHHE 18 or CHP-18) only assures adequate SBLOCA mitigation capability (load management / decay heat removal)if no other single failures are assumed. The generally accepted 30-day AOT for control room chillers is based on the assumption that control room cooling is the only affected function that is vulnerable to a single failure while in the 30-day limiting condition 6f coeration (LCO) (this acceptance basis is consistent with NUREG 1430 and your proposed Bases). Because of your present EDG capacity limitations, safety functions (EFW/ECCS), other than control complex cooling, are potentially affected by the inoperability of the Train B chiller or chilled water pump.

As preposed, if a SBLOCA were to occur while in LCO 3.7.18, the associated risk may be significantly greater if a Train B chiller or pur.1p is inoperable (Condition A) compared to an inoperable Train A chiller or pump (Condition B). The reasoning behind this is that while in Condition B if a SBLOCA/EFP 2 failure were to occur, load management and the control complex cooling system (CCCS) are still available. While in Condition A, if a SBLOCA/EFP-2 failure were to occur, adequate load management will not be available without purposely disabling the entire CCCS (to manage loads) function, or prematurely securing EFP 1 A to restore the CCCS function further complicating the event. Thus, there appear to be more vulnerabilities (SBLOCA/EFP 2 failure is one, there may be more) while in Condition A than while in Condition B. Therefore, for Cycle 11, the AOT for the Train B chiller and chilled water pump should be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (while in Modes 1,2, l

2 and 3), the same as other SBLOCA mitigating equipment. Also, the AOT for the Train A chiller and pump should, as a maximum, be 7 days to minimize the risk from total loss of coc!ing that would affect a number of different safety-related arer.s in addition to control room ecoling. You should revise your proposed TS changes to address the above, or provide arktitional information and justification as to why such changes are mt necessary.

2. LCO 3.7.18 requires two heat exchangers for the CCCS to be Operable. The proposed Background section of the Bases states there are "two pairs of heat exchangers." It is further stated in the Background that "A single chiller and associated chilled water pump will provide the required temperature control for either heat exchanaers." The use of the singular "either" and the plural " heat exchangers" further confuses what is needed for adequate temperature control. Please provide additionalinformation and modify the proposed Bases and LCO as necessary to clarify exactly how many and which heat exchangers are necessary to maintain adequate control complex cooling and, therefore, required to be Operable. Also, for consistency and clarity LCO 3.7.18.b should specify two " Operable" heat exchangers in lieu of just two heat exchangers, the same as you have proposed in LCO 3.7.18.a for the two " Operable" chillers and associated pumps.

3. The proposed applicability for LCO 3.7.18 is Modes 1,2,3, and 4. To be consistent with NUREG-1430 and your corresponding TS 3.7.12 for the control room emergency ventilation system, the applicability should be expanded to include "During movement of irradiated fuel assemblies." However the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Train B AOT discussed above, would not be required during this mode (as it would not be required in Mode 4) and the AOT for this mode would be 30 days, the same as Train A components. Please make any necessary revisions to include this additional mode in your LCO or provide additional information to justify why such changes should not be required.

Hiah Pressure lniection

1. The submittal (pg.1) also indicates that certain aspects of the loss of EFP 2 were not analyzed. Please describe the potential for EFP-1 to be lost due to an automatic trip or as part of the load management strategy, given EFP-2 is lost.

2. Please verify that the isolation of the wrong high pressure injection (HPI) line, given a HPl line break, is not a more limiting single failure for your electrical system or from the standpoint of LOCA consequences. Additionally, please evaluate the HPl line isolation criteria of 50 gpm from an instrumentation standpoint and the expected flow splits in the four injection paths. With whct frequency do you expect the operators will isolate an intact injection path. What are operators instructed to do if one of the four injection line isolation valves fails to open on an engineered safeguards signal. A review of the emergency operating procedures indicate that the operators are instructed to isolate a second HPl flow path. Is this event bounded by the accident analysis?

3. The submittal (pg. 3) indicates that the loss-of-offsite power is assumed to occur coincident with the reactor trip. Please explain why this is assumed and discuss if it is consistent with the design basis (for LOCA and the other systems).

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4. The submittal (pg. 4) describes the methods for once through steam generator (OTSG) cooling and then desenbes " defense-in-depth" contingencies. The discussion includes the effect of depressurizing the steam generators using the turbine bypass valves or the atmospheric dump valves. Please verify that the cooling associated with the depressurization of OTSG cooling is considered a defense-in-depth mechanism rather than a being credited in the accident analysis because these are not fully qualifted components.

5. Please evaluate the increased risk associated with the proposed plant and procedure '

changes including the new load management strategy that is being proposed. For comparison, assume the onsite electrical, the EFW, and HPl systems and there i interconnections were adequately sized and no load management or reliance on EFW is necessary.

6. Please describe the current LOCA enalysis of record that was submitted in May of 1996.

Verify that the changes in the plant and procedures are correctly modeled in that analysis and that the modeling (CRAFT 2) is consistent with the code limitations and restrictions.

7. Pleaue clarify Action A of TS LCO 3.5.2 which requires that if one or more ECCS trains are inoperable and "at least 100% of the ECCS flow equivalent to a single operable ECCS train available." Because you run with the discharge of the HPl cross-connected and it appears that four of four injection paths are always needed. A def:nition of a

" train" of HPl would be helpful. Is a " train" one HPl pump and two, tiiree, or four injection lines or is it the equipment associated with a particular safety bus?

8. Is the inoperability of an injection line (i.e., an inoperable injection line isolation valve) considered the failure of one train or both trains? The TS bases (pg. B 3.5-13) state that " flow is required through a minimum of three injection legs in the event of a postulated break in the HPl injection piping." If this is the case, how is the failure of one of the injection line isolation valves bounded by accident analysis (for a HPl line break, when one of tb four injection lines is broken; are three of the remaining three required to meet the accident analysis)?

9. Are there any single failures that could cause two of the four injection lines (cr isolation valves) to be inoperable?

10. Operator Action #4 [lsolate reactor coolant pump (RCP) seal injection), in Table 3 A of Attachment D to the September 25,1997, submittal has not been approved by the NRC.

There is not sufficient information in the submittal to make a safety determination. A description of how RCP seal cooling will be maintained after injection is isolated and under what circumstances it would be lost should be provided. Additionally, the purnp vendor recommendations should also support isolation of the sealinjection and this should be described in detail.

11. It is not clear from reading the submittal that a post-SBLOCA situation is precluded in which the containment conditions cause an initiation of containment spray, which,

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combined with ECCS injection, could drain the borated water storage tank to the switch over point in about 45 minutes even with the loss of one diesel. With the need for chillers (at one hour?), the need for low pressure injection to provide HPl suction from the sump, the need for the motor-driven EFP (EFP-1) (for certain scenarios), and other loads (such as valve position changes), it would appear that the operating diesel could be overloaded. Please address the worst case postulated scenario in terms of tims.

dependent diescl loading, identifying which loading actions are automatic and which are operator actions. It seems that the timing may be important, reflect timing uncertainties in the assessment.

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