3F0198-34, Forwards Summary of Evaluation of Dynamic Effects of Pressurizer Surge Line LOCA Other Systems & Components,In Response to NRC 971222 Rai.Commitments Made by Util,Encl
| ML20199A530 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/23/1998 |
| From: | Rencheck M FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F0198-34, 3F198-34, GL-87-11, GL-91-18, TAC-M96604, NUDOCS 9801280003 | |
| Download: ML20199A530 (5) | |
Text
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January 23, 1998 3F0198 34 U. S. Nuclear Regulatory Conunission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)
References:
1.
NRC to FPC Letter, 3N1297-18, dated December 22, 1997,
" Protection Against Dynamic Effects of LOCA - Request for Additional Information (TAC No. H96604)"
2.
FPC to NRC letter, 3F1297-05, dated December 13, 1997,
" Protection Against Dynamic Effects of LOCA - Request for Additional Information, Evaluation of Jet Impingement Effects ofPressurizerSurgeLine,inspectorFollowupItem(IFI)95-15 02" 3.
NRC to FPC letter, 3N0586-30, dated May 23, 1986, " License Amendment 689" 4.
FPC to NRC letter, 3F1297-33, dated December 8,
- 1997,
" Resolution Plans for USI A-46 and large Bore Piping and Piping Supports" 5.
FPC to NRC letter, 3F1297 36, dated December 18, 1997, "Large Bore Piping and Pipe Support Calculations - Response to NRC Request for Additional Information"
Dear Sir:
h$d Florida Power Corporation (FPC) is submitting this letter to respond to the Request for Additional Information (RAI) in Reference 1. The RAI stated that the December 13, 1997, FPC letter (Reference 2) " appears to address only Service Water (SW) piping and it is not clear whether FPC evaluated the dynamic effects I) i of a pressurizer surg line loss of coolant accident (LOCA) on any other systems and components in the area."
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'3F0198 34 Page 2 of 4 -
- (RB) performed a review of high energy line break (HELB) in the' Reactor Build
-, As part of this review, FPC performed - an impact evaluation of a-HELB originating (SSC) inside the RB.from the pressurizer' surge line on systems,. struc components In addition, the evaluation included postulated-breaks in the high energy-portions-of the Core Flood (CF) System lines, Decay 1
4 Heat (OH) System drop line, Makeu Auxiliary Pressurizer Spray -(APS)p and-Purification- (MU) System letdown line, line, and:the Pressurizer Spray -line.
The-Reactor Coolant-System main-loop piping.- i.e.. " hot-leg" and " cold-leg" piping, were not included in the scope of this evaluation because these lines qualify for-0 leakbeforebreakcriteria-asapprovedbyLicenseAmendment#89,datedMayl23, j
1986 (Reference 3),
i FPC identified SSCs that were potential targets of pipe whip or jet impingement o
from'a HELB for the lines identified above.
These interactions represented 1
potential deviations from the original: design criteria for protection from the i -
- dynamic effects of a LOCA.
2 3
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_The affected SSCs were dispositioned by one'or more of the following criteria:
1.-
The target is not required for LOCA mitigat an or the accident is-mitigated by other automatic functions consistent with the: CR-3 t
licensing basis.
i
~ 2.
The target has been modified in order to remove it from the path of
-the pipe whip and/or the jet impingement envelope.
c FPCappliedtheguidanceinGenericLetter(GL)9118, Revision 1.-
- 3.
t
- Information to Licensees Regarding NRC Inspection Manual Section on p
Resolution of Degraded and Nonconforming Conditions,"ito disposition i
Jnonconformances as follows:
1 a.
. The break location was eliminated using the methodology l
t of NRC GL 87-11,;" Relaxation in Arbitrary Intermediate Pipe Rupture Requirements,"
- b.
The target was eliminated by implementing NUREG/CR-2913, "Two Phase Jet Loads," methodology for redefinition of the jet impingement envelope.
i As p s t of item 3 above, fina1' corrective actions in accordance with GL 91-18,
. Revision.1 are required since 1.
GL 87-11 wa's applied to -longitudinal breaks on the surge line to eliminate them as part of an earlier effort to support Crystal River r
Unit.3:(CR-3) Restart issue D 58.
FPC performed a review of the stresses in both of the CF System lines, the DH Systei.; drop line, i
and' the MU System letdown line and concluded that intermediate F
. breaks can be eliminated using the criteria allowed by GL 87-11.
.However, the use of GL 87-11 on piping inside the RB for which the
' code of record is USAS B31.l.0 - 1967 is not part of the current licensing basis for CR-3.
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' NUREG/CR-2913 defines characteristics of the impingement jet.
It' l
= differs from the currently. licensed impingement-jet for a LOCA -
'inside the R8 as described in Final Safety-Analysis Report (FSAR)_
Section 14.2.2.5.11..
,1 FPC will submit a license amendment request providing justification for use of GL; 87-11 and NUREG/CR 2913 as the licensing -bases for; CR 3 and/or ' propose additional plant modifications that will be completed prior to restart from i
Refuel 11 in a separate-submittal by Nay 29, 1998.
.The nonconformances described ~ in this letter have been determined to' be
-reportable.and LER 98 001 00 will be submitted in accordance with 10 CFR 50.73.-
f The large Bore Piping Program discussed in References 4 and 5 will evaluate these
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pipe stresses to ensure the-application;of GL 8711 'for the elimination of intermediate breaks remains
- acceptable.
.The RAI noted that CR-3 is required to comply with the requirements of 10 CFR 50,
+
Appendix A, General Design Criteria (GDC) 4, Environmental and Dynamic Effects 4
Design Bases.- This is not consistent with the current CR 3' licensing and design
- basis.
CR 3 systems, structures, and components are designed to the criter'a described in FSAR Section 1.4, Principal-Architectural and Design Criterfs.
However, the Emergency Feedwater (EF) System is designed to the current GDC 4
. requirements because of NUREG 0737,
" Clarification of 7#1oAction Plan.
Requirements.* In 1989, the NRC granted a-schedular exemption to GDC-4 to allow l
h FPC timeLto complete modifications to CR 3 to resolve postulated _HELBs located l
l-outside the RB This schedular exemption did not change the design bases for CR-3 to the GOC in 10 CFR 50,' Appendix. A. : Subsequently, NRC issued NRC.SECY-92-223,
'Resolutton of Devfattons identiffed During the Systematic Evaluatton Program,"
t dated September-18, 1992, which established the NRC's position regarding the applicability of the current 10 CFR 50,' Appendix A General Design Criteria (GDC).
L The:NRC's position is that it will; not apply _ the-current Appendix A GDCs to plants with construction permits issued prior to May 21,1971 and exemptions from the current GDC are not necessary.
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' *3F0198-34 Page 4 of 4 The commitments in this letter are contained in the Attachment A.
Sincerely, M. W.- Rencheck, Director-NuclearEngineeringandProjects MWR/jwt Attachment xc:
Regional Administrator, Region !!
l Senior Resident Inspector NRR-Project Manager I
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ll~ 5. N9cleai Regulatory Commission Attachment A
- '3F0198 'M Page 1 of 1 i.ist of Regulatory Commitments The folinwing table idehtifies those actions committed to by Florida-Power Corporetton in this document.
Any other actions discussed in the submittal represents intended or planned actions by Florida Power Corporation.
They are described % the NRC for the NRC's inforsation and are not regulatory commitments.
Flene notify the Mar,ager, Nuclear Licensing of any questions regarding this decuran* nr any succiated regulatory commitma' '.
COMITEEWi ~
1Hli.ENENTATION Submit a
license amendment request providing May 29, 1998 p
justification for use of Generic letter 87-11 and NUREG/CR 2913 as the licensing bases for CR 3 and/or propose additional plant modifications that will be completed prior to restart from Refuel 11 in a separate subental.
The Large Bore Piping Program will evaluate these Program will take 4 6 pipe stresses to ensure the application of GL 87-11 years (2-3 fuel for the elimination of intermediate breaks remains cycles) to implement, acceptable.
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