3F0897-35, Requests Withdrawal of Requested Changes to Tss.Util Determined That Proposed Changes to Improved TSs SR 3.8.1.3 & Associated Bases,Not Needed.Change Is Required to Permit special,one-time Outage on Each EDG to Perform Mod & Maint

Requests Withdrawal of Requested Changes to Tss.Util Determined That Proposed Changes to Improved TSs SR 3.8.1.3 & Associated Bases,Not Needed.Change Is Required to Permit special,one-time Outage on Each EDG to Perform Mod & Maint

ML20210K887
Person / Time
Site:	Crystal River
Issue date:	08/16/1997
From:	Cowan J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210K890	List: 3F0897-35, Requests Withdrawal of Requested Changes to Tss.Util Determined That Proposed Changes to Improved TSs SR 3.8.1.3 & Associated Bases,Not Needed.Change Is Required to Permit special,one-time Outage on Each EDG to Perform Mod & Maint ML20210K892
References
3F0897-35, 3F897-35, NUDOCS 9708200149
Download: ML20210K887 (4)

Text

_ _ _ _

I '

e

lorida 39Xer n==l August 16,1997 3F0897-35 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Request for Withdrawal of Requested Changes to Technical Specifications

Reference:

FPC Letter No. 3F0897-22 dated August 4,1997

Dear Sir:

The referenced letter submitted Technical Specification Change Request Notice No. 215 (TSCRN 215) requesting temporary changes to the Crystal River Unit 3 (CR-3) Improved Technical Specifications (ITS). TSCRN 215 was an exigent request for changes to the ITS that would allow a one-time extension of the frequency of Emergency Diesel Generator (EDG) surveillance requirements. That change is required to permit a special, one-time outage on each EDG to perform necessary modifications and maintenance. !n discussions with the Nuclear Regulatory Commission (NRC) Staff and additional reviews by Florida Power Corporation (FPC) personnel, it was determined that one of the proposed changes to ITS Surveillance Requirement (SR) 3.8.1.3 and to associated Bases section SR 3.8.1.3 is not needed, BACKGROUND: =,

O FPC is performing modifications and maintenance on the Emergency Diesel Generators E.

!Eli-(EDGs) during the current outage at CR-3. This work, which results in the EDGs being declared inoperable, is being performed on one EDG at a time. Because the outage on an ---

EDG is projected to be in excess of the 31-day surveillance interval, performance of ITS C;;-

surveillances on the other, operabit, diesel would be required during the time the EDG is E-inoperable for performance of the work. The procedures for surveillance of the EDG require E!E-that it be declared inoperable during performance of the SR.

By the referenced letter, FPC submitted TSCRN 215 which requested changes to ITS sections Surveillance Requirements SR 3.3.8.1 and SR 3.8.1.3 and associated Bases. The 1c;.'.iG7-av. .. - (N g CRYSTAL RIVER ENERGY COMPLEX

• 15760 W. Pcwer Line Street

• Crystal River, Florida 34428-6708 = (352) 795-6486 970820M49 97081b A Florida Progrsss Company PDR ADOCK 05000302 P PDR , ___ __ ____ _ ___ _ _ _

i L.,

- U.S. Nucliar Rrgulatory Commission 3F0897 Page 2, of 3 requested changes were to allow a one time extension of the surveillance interval for each EDG from 31 days to 60 days, with these revisions expiring on November 23,1997.

Through discussion of TSCRN 215 with the NRC Staff, FPC has determined that one of the proposed changes to ITS SR 3.8.1.3 is not needed. This proposed change is not needed because the NOTE in SR 3.8.2.1, with additional clarification in the Bases, states that surveillance of SR 3.8.1.3 is not required to be performed.

REQUESTED ACTION:

FPC requests withdrawal from consideration of the requested change to ITS Surveillance Requirement 3.8.1.3 and associated Bases submitted by the referenced letter. Additionally, FPC concluded that a change to the Bases for SR 3.8.2, clarifying when performance of the surveillances is not required,is needed for a full understanding of the NOTE in 3.8.2.1. The change to the Bases is being made pursuant to 10 CFR 50.59 and is being provided to the NRC Staff as part of this request.

A description of changes and reason for changes is provided as Attachment A. The revised Bases page in strikeout and highlight font is provided as Attachment B, and in revision bar

-font as Attachment C.

The requested changes to SR 3.3.8.1 and associated Bases submitted by the referenced letter are still needed. If you have any questions concerning this request, please contact David Kunsemiller, Manager, Nuclear Licensing at (352) 563-4566.

Sincerely, hh" John Paul Cowan Vice President-Nuclear Production JPC/rer xc: Regional Administrator, Region 11 NRR Project Manager

- Senior Resident inspector Attachments:

A. Description of Changes and Reason for Changes B. Revised Bases Page (Strikeout and Highlight Font)

C. Revised Bases Page (Revision Bar Font)

TU.S. NuclMr Rsgulatory Commission.

' 3F0897 -

c- Page 3 of 3 p ,.

' STATE OF ' FLORIDA COUNTY OF CITRUS l

John Paul Cowan states that he is the Vice President, Nuclear Production for Florida -

Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief, jg&f a John Paul Cowan Vice President Nuclear Production

-Sworn to and subscribed before me this &A day of Atgusf .-1997, by:

John Paul Cowan. '

f/)at/ cat /lliY/et Signature of Notary Public State of Florida 4

"

• TEr#^J'u%"

c *

• 1%2 mom:,2  %

-(Print, type, or stamp Commissioned -

Name of Notary Public)

Personally / Produced Known Identificati'on

___a

' U.S. Nucizr Regul: tory Commission Attichm3nt A 3F0897-35 -Page 1 of 1 ATTACHMENT A DESCRIPTION OF CHANGES AND REASON FOR CHANGES LICENSEE DOCUMENT INVOLVED: Technical Specifications PORTIONS: Bases for Surveillance Requirement 3.

8.2 DESCRIPTION

OF CHANGES:

The Bases for Surveillance Requirement (SR) 3.8.2 is being revised to clarify which surveillances

-of Section 3.8.1, related to the Emergency Diesel Generators (EDGs), are required to be

- performed as part of SR 3.8.2.1. The NOTE in SR 3.8.2.1 is reiterated in the Bases as i clarification. This NOTE explains that SRs 3.8.1.3, 3.8.1.8, and 3.8.1.11 are not required to be performed.

The Bases are further clarified by indicating which SRs are addressed by performance of portions of SP-354 when one EDG is inoperable due to maintenance or modification.

REASON FOR CHANGES:

Under certain conditions one EDG might be inoperable for maintenance or modifications to the

- EDG, - With this condition of limited AC sources available it is not desirable to perform surveillances which load the operable EDG by being paralleled to the offsite power network. If surveillances were performed under such conditions there is a potential for a grid disturbance to

. cause loss of the EDG being surveilled. ' is not advisable to jeopardize the only operable EDG by performing surveillances. This condition is clarified in the Bases.

Additionally, performance of certain SRs requires that the EDG be declared inoperable. For these SRs a problem is created if performance of SP-354A / B is attempted. Declaring the EDG inoperable results in both EDGs being inoperable, and action must be initiated immediately to restore one EDG to operable status per Action B.3. To restore the EDG to operable will require that performance of the SP be terminated. Thus, the surveillance by performing the SP could never be achieved.

BASIS FOR CHANGES:

Florida Power Corporation (FPC) has evaluated the proposed change pursuant to 10 CFR 50.59 Land has concluded that the change to the Bases does not involve an unreviewed safety question.

Accordingly this change is being made to the Bases pursuant to 10 CFR 50.59.

,