3F0198-26, Confirms 980108 Meeting Discussion Between FPC & NRC Re Complex Habitability Envelope Justification for Continued Operation Issues at Crystal River,Unit 3

Confirms 980108 Meeting Discussion Between FPC & NRC Re Complex Habitability Envelope Justification for Continued Operation Issues at Crystal River,Unit 3

ML20198L810
Person / Time
Site:	Crystal River
Issue date:	01/14/1998
From:	Rencheck M FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0198-26, 3F198-26, TAC-M91823, NUDOCS 9801160127
Download: ML20198L810 (4)

Text

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Florida Power-

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~ January 14,1998

- 3F0198-26 U.S. Nuclear Regulatory Commission Attn: DocumentControlDesk Washington, DC 20555-0001

Subject:

Control Complex Habitability Envelope Justification for Continued Operation (TAC M91823)

References:

1, NRC to FPC letter, 3N1297-19, dated December 24,1997, " Control Complex Habitability Envelope Justification for Continued Operation -

Interim Assessment Results"

2. FPC to NRC letter, 3F1297-19, dated December 5,1997, " License Amendment Request #222, Revision 0, Control Room Emergency Ventilation and Emergency Filters"

Dear Sir:

This letter confirms the discussions between Florida Power Corporation (FPC) and the NRC at our meeting of January 8,1998. The purpose of that meeting was to discuss the issues identified in Reference 1 regarding control room habitability for Crystal River Unit 3 (CR-3).

At the meeting:

1. NRC accepted FPC's methodology for the evaluation of control room doses for the maximum hypothetical accident, subject to completion of a detailed review.

~2. NRC accepted FPC's Justification for Continued Operation (JCO) for power operation of CR-3 for the current fuel cycle, subject to completion of a detailed review and to FPC implementing compensatory measures. The required compensatory measures will be to administer potassium iodide to control room operators in accordance with CR-3 Emergency Response Plan Implementing Procedures. Prior to Mode 2 operation, t

'these procedures will assure potassium iodide can be administered to control room 4

operators, if necessary, in the time period before the Technical Support Ccnter is 7

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• Crystat itiver, Florida 34428 6708 e (352) 795-6486 -

, - A Fbriele Prverwss Conomany

. U. S. Nuclear Regulatory Commission 3F0198-26 Page 2 of 4 FPC's JCO and compensatory measures will be maintained until the NRC Staff completes its review of a revised CR-3 Control Room Habitability Report and License Amendment Request (LAR) #222, and approves FPC's design and licensing basis for control room habitab.iity. FPC's submittals will be completed on a schedule consistent with NRC review and approval of LAR #222 prior to startup from Refueling Outage 11.

3. FPC agreed to perform an additional control room dose analysis for steam generator tube rupture (SGTR) events using methods and assumptions within Standard Review Plan (SRP) 15.6.3 as guidance.

FPC will address results of the revised SGTR analyses when the Control Room Habitability Report is submitted and will propose a schedule to resolve techn cal issues, and/or propose a technical justification for acceptance of the results within he current CR-3 design. The resolution of technical issues may include plant modifications and/or proposal of a license amendment to modify the CR-3 licensing basis or Technical Speci6eations.

The results of this analysis will be submi',ted to the NRC with the revised Control Room Habitability Report to demonstrate compliance with 10 CFR 50, Appendix A, General Design Criterion 19 within six months afler restr.rt from the current cutage.

This commitment changes the schedule for the revised Control Room Habitability Report to permit completion of the additional SGTR analysis, and supersedes the submittal date of April 1,1998, proposed in Reference 2.

4. FPC will revise License Amendment Request #222 to add the Auxiliary Building ventilation filte:s to the Ventilation Filter Test Program in the CR-3 Improved Technical Specifications.

5. Following receipt of NRC approval of FPC's Control Room Habitability Report and revised LAR #222, FPC will complete modifications to the plant and/or procedures that may be ; roposed by FPC to implement the approved design and licensing basis for CR-3 control room habitability.

Following the resciution of these issues, FPC will consider modifying its acceptance criteria for offsite dose to reflect a fraction of 10 CFR 100 limits. FPC anticipates that subsequent changes to dose analysis crit;ria will include consideration of the Revised Source Term and the application of Total Effective Dose Equivalent concepts to both control room and offsite doses.

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3F0198 26 <

Page 3 of 4; ' ,

The commitments mr.de in this correspondence are provided in the Attachment. Should you have .

. 'any. questions or require additional information concernir.g this response, please' contact Mr. David

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~ Kunsemiller, Manager, Nuclea: Licensing at (352) 563-4566.-

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.: Sincerely, M W.Rencheck, Director s

i Nuclear Engineering and Projects +

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xcf Regional Administrator, Region'II-NRR Project Manager Senior Resident Inspector. .

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. ._. 0. S. Nucliar Regulatory Commission 3F0198-26

Page 4 of4 i ATTACHMENT List of Regulatory Commitments The following table identifies those actions committed to by Florida Power Corporation in this document. Any other actions discussed in the submittal represent intended or planned actions by Florida Power Corparation.

They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager, Nuclear Licensing of any questions regarding this document or any associated regulatory commitments.

ID Number Commitment Commitment Date -

3F0198-26-01 FPC will maintain compensatory measures to administer potassium Prior to Mode ?

iodide to control room operators in accordance with CR-3 Emergency operation of CR-3 Response Plan Implementing Procedures until rcccipt of NRC approval of FPC's design and licensing basis for control room habitability.

3F0198-26-02 Prior to Mode 2 operation, Emergency Response Plan '.31cmenting Prior to Mode 2 i'rocedures will assure potassium iodide can be administered o operation of CR-3 control room operators in the time period before the Technical Support Center is operational.

3f0198-26-03 FPC will perform an additional control room dose analysis for steam Six months after restart generator tube rupture (SGTR) events using methods and assumptions from CR-3's current within Standard Resiew Plan (SRP) 15.6.3 as guidance. outage FPC will address results of the resised SGTR analyses when the Control Room Habitability Report is submitted and will propose a schedule to resolve technical issuca, and/er propose a technical justification for acceptance of the results within the current CR-3 design. The resolution of technical issues may include plant modifications and/or proposal of a license ame.ndment to modify the CR-3 licensing basis or Techmcal Specifications.

The results of this analysis will be submitted to the-NRC with the revised Control Room Habitability Repcrt to demonstrate c,mpliance with 10 CFR 50, Appendix A, General Design Criterion 19 within six months after restart from the current outage.

3F0198-26-04 FPC will revise License Amendment Request 'P22 to add the Six months after restart Auxiliary Building ventilation filters to the Ventilation Filter Test from CR-3's current Program in the CR-3 Improved Technical Specifications. outage 3F0198-26-05 Following receipt of NRC approval of FPC's Control Room Prior to startup from Habitability Report and LAR #222 FPC will complete modifications Refueling Outage iI to the plant and/or procedures that may be proposed by FPC to implement the anproved design and licensing basis for CR-3 control room habitability.

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