ML19343A379

Application to Amend App a to Ol,Changing Aspects of NUREG-0578 Including Model License Conditions & Emergency Feedwater Initiation & Flow Monitoring.Affidavit & Certificate of Svc Encl

ML19343A379
Person / Time
Site:	Crystal River
Issue date:	09/15/1980
From:	Baynard P FLORIDA POWER CORP.
To:
Shared Package
ML19343A381	List: ML19343A379 ML19343A382
References
3--3-E, 3-0-3-E, TAC-45333, NUDOCS 8009170288
Download: ML19343A379 (4)

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Flor'ida Power CO R PO R A T s0N September 15, 1980 File: 3-0 e Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Change Request No. 64, Revision 1

Dear Sir:

Enclosed are three (3) originals and forty (40) copies of Technical Spe-cification Change Request No. 64, Revision 1, requesting an amendment to Appendix A of Operating License No. DPR-72. As part of this request, proposed replacement pages for Appendix A are enclosed. (Revision 0 of Technical Specification Change Request No. 64 was an internally devel-oped draft which was completed immediately prior to receipt of your let.

ter, but which had _not yet been transmitted to your office.)

This is provided in response to Mr. Darrell Eisenhut's letter of July 2, 1980. The proposed changes address those aspects of NUREG-0578, Cate-gory A, that Florida Power Corporation considers appropriate for techni-cal specifications. Florida Power Corporation diverged from your recom-raendations in the following areas:

(a) Model License Conditions - Florida Power Corporation does not consider the items provided appropriate for license conditions and, more specifically, does not consider them appropriate as specific license condi-tions for Crystal River Unit 3. We Faye committed to appropriate programs and they have been reviewed and approved by the Staff. If the Staff continues to support such a position, the changes should be pursued via o rulemaking including them as generic license conditions in 10 CR 50.54. To include such items as specific license conditions will serve no purpose and will complicate what should be a straightforward document. Specific license condi-tions should be limited to specific restrictions on

- plant operations, should -have a finite duration, and should not be used to simply document programatic commitments.

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General Office 3201 inirty-fourin street soutn . e o Box 14042. St Petersburg. Florida 33733 e 813-866-5151 8 0 09.170 'A$5 - __ _

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Office of Nuclear Reactor Regulation September 15, 1980 (b) . Emergency Feedwater Initiation and Flow Monitoring -

! .Since-the installed system is only established as an

-interim measure until .a safety-grade system is in-

- stalled, technical specifications would be of dubi-ous value. Florida Power Corporation will submit, at the staff's request, technical specifications when the upgraded system is installed. However, Florida Power Corporation opposes the inclusion of the Emergency Feedwater System las an ES actuation system, since it is- not an ES designed system.

(c) Diverse Containment Isolation - Florida Power's in-stalled Reactor : Building Isolation system remains unchanged in the sense that no new valves are iso-lated. It would be unnecessarily cumbersome to in-clude a notation of those receiving the " Diverse"

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signal in technical specifications.

(d) ~ Emergency Power Supply to Pressurizer Heaters - Re-view of this specification, and surveillance associ-ated therewith, is continuing. Florida Power Cor-poration will supplement Technical Specification Change Request No. 64, Revision 1, when this review is completed. It is anticipated that this will be completed within 30 days.

An index, cross-referencing proposed specifications with the applicable NUREG-0578 item, is provided for your convenience.

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Florida Power Corporation considers Technical Specification Change Re-quest No. ~64, . Revision 1, to be a Class IV Amendment, per 10 CFR 170.22. However, no license fees are provided since the Commis-sion has determined that such an amendment is in the public interest and is exempt from fees pursuant to Footnote 2 to 10 CFR 170.22. A signed copy of the Certiiricate of Service for Technical Specification Change Request No. -64,- Rr vision 1, . to the Chief Executive Officer of Citrus County, Florida,1s. attached.

Very- truly yours, FLORIDA POWER CORPORATION'

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Patsy" YvBaynand Manager .  ;

Nuclear Support Services  !

TSCRN-64Rev1(TSCRNDisk#1-3). ,

Attachments  !

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STATE OF FLORIDA COUNTY OF PINELLAS Patsy Y. Baynard states that she is the Manager, Nuclear Support Servi-ces Department of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attacned hereto; and that all such statements made and matters set forth therein are true and correct to the best of her knowledge, information, and belief.

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1. (/PatVy W. Baynard Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 15th day of September,1980.

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Notary Public, State of Florida at Large, My Commission Expires: May 29,1984 TSCRN-64Rev1(TSCRNDisk#1-3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

) DOCKET N0. 50-302 FLORIDA DOWER CORPORATION )

CERTIFICATE OF SERVICE Dr. P. Y. Baynard depo es and says that the following has been served on the Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:

Chairman Board of County Commissioners of Citrus County Citrus County Courthouse Inverness, FL 32650 An original copy of Technical Specification Change R.'. quest No. 64, Re-vision 1, which requested Amendment to Appendix A of Operating License No. DPR-72.

FLORIDA POWER CORPORATION h 1 MW

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anager Nuclear Support Services SWORN TO AND SUBSCRIBED BEFORE ME THIS 15th DAY OF SEPTEMBER,1980.

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Notary Public

. 9 61 EM Notary Public State of. Florida at Large My Commission expires: May 29, 1984 (NOTARIAL SEAL)

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