ML20211C291

Safety Evaluation Supporting Amend 185 to License DPR-72

ML20211C291
Person / Time
Site:	Crystal River
Issue date:	08/23/1999
From:	NRC (Affiliation Not Assigned)
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ML20211C280	List: ML20211C273 ML20211C291
References
NUDOCS 9908250201
Download: ML20211C291 (12)

Text

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a nu It UNITED STATES

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j NUCL. EAR REGULATORY COMMISSION

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t WASHINGTON D.C. 20555-0001 gu; SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.185 TO FACILITY OPERATING LICENSE NO. DPR-72 CONTROL ROOM EMERGENCY VENTILATION SYSTEM AND VENTILATION FILTER TESTING PROGRAM FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302 l

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1.0 INTRODUCTION

By letter dated July 30,1998, as supplemented April 8 and July 8,1999, the Florida Power Corporation submitted a license amendment request for Crystal River Unit 3 (CR-3) to revise Technical Specifications (TS) 3.7.12 anc B 3.7.12. " Control Room Emergency Ventilation System (CREVS)" and TS 5.6.2.12, " Ventilation Filter Testing Program (VFTP)." The April 8 and July 8,1999 supplements did not affect the original proposed no significant hazards j

determination, or expand the scope of the request as noticed in the Federal Reaister.

l in the July 8,1999, letter, the licensee, at the request of the Nuclear Regulatory Commission (NRC) staff, revised their submittal to proposo that TS 3.7.12, " Control Room Emergency

' Ventilation System (CREVS)," only be valid until the beginning of Cycle 13. The staff requested this change to allow resolution of generic issues associated with this change. The remainder of the July 30,1998, submittal remained unchanged.

l 2.0.

BACKGROUND l

l The CR-3 Operating License contains a requirement to maintain control room habitability as I

specified in item lli.D.3.4, " Control Room Habitability Requirements," of NUP.EG-0737,

" Clarifications of TMl Action Plan Requirements." The licensee identified, during system readiness review, that the value of unfiltered inleakage into the control complex habitability envelope (CCHE) was higher than the value utilized in its original control room habitability analysis. The licensee considered the following actions to maintain the design and licensing basis and address the unfiltered inleakage issue:

Modifications to reduce CCHE inteakage by improving the integrity of boundary elements; Design changes to the CREVS to provide attemate means of mechanical equipment room ventilation and to improve system reliability; and Programmatic changes to ensure that the assigned efficiency of the control a

complex charcoal filters is consistent with regulatory guidance and to ensure periodic leak testing of the CCHE boundary is performed.

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, The CREVS was modified by installing redundant bubble-tight dampers at all system connections that penetrate the boundary of the control complex and eliminating the system that cooled the ventilation equipment room with outside air. The modifications to the CCHE included an extensive sealing program and the addition of vestibules over all CCHE boundary

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doors.

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i The licensee also included a revised Control Room Habitabinty Report with the July 30,1998, i

submittal to present (1) the latest design of CREVS and the CCHE, (2) the inleakage j

measurement technique that is used and the means by which it is converted to an inteakage rate for calculations, (3) the methods, assumptions and results of the revised dose calculations and (4) the improvements made to toxic gas inventories and controls. This revised report is currently under staff review.

The CREVS consists of two independent safety-related air recirculation trains that, in addition to cooling capability, have the ability to divert 100 percent of the recirculation flow through an emergency filter unit (EFU). Each EFU contains, in the direction of flow, a roughing filter, a high efficiency particulate air (HEPA) filter, a 2-inch activated carbon filter bank, and a safety-related recirculation booster fan. The EFUs do not include means to lower the humidity of the air as it eniers the adsorber bank, such as electric heating coils. Heaters are not required since the system only operates.'n a recirculation mode. The emergency recirculation fans are powered by separate safety-related power sources. The CREVS processes and filters air from j

the top five lovels of the control complex.

Upon detection of either high reactor building pressure or high radistion in normal control room (CR) ventilation ductwork, as detected by RM-AS, the redundant, bubble-tight boundary j

isolation dampers are automatically closed. The operation of the emergency fans and filters is manually initiated by the operator. The calculations assume 30 minutes for manual initiation of the filters.

4 The redundant, bubble-tight boundary isolation dampers are also automatically closed as a result of a loss of offsite power (LOOP). The operation of the CREVS during a LOOP is manually initiated by the operators. Although the dieselloading would allow starting the 4

CREVS well before 30 minutes, the operation of the CREVS is not credited for 30 minutes.

The CREVS provides environmental control for personnel comfort, equipment operation and protection of control room personnel during radiological and toxic gas events. It provides habitability via zone isolation with filtered recirculation. The control complex is not pressurized to limit inleakage. Leak tightness and filtration capability provide the necessary level of protection for the control room operator to ensure that exposure limits associated with design-basis accidents and toxic gas events are not exceeded.

3.0 EVALUATION The staff has completed its review and evaluation of the licensee's submittals. The proposed changas to TS 3.7.12 (valid until the beginning of Cycle 13), the permartent change to TS 5.6.2.12 and the licensee's justifications for these changes, are described below:

. 3.1 TS 3.7.12 Control Room Emeraency Ventilation System (CREVS)

The licensee stated in their submittal that the current CREVS TS addresses the components of the ventilation system loop including fans, dampers, filters, and associated ductwork. However, the TS is silent on the components that make up the CCHE boundary including the walls, doors, roof, floors, and floor drains of the control complex. and does not explicitly address the isolation dampers. Including the CCHE in the scope of TS 3.7.12 would cover these components.

i The licensee's calculations indicate doses to control room operators in the 30-day period following a maximum hypothetical accident (MHA) due to radioactivity lesking into the habitability envelope conform to GDC-19 limits. Calculations have also been performed to determine how much additional leakage can be tolerated while assuring deses will not exceed the regulatory limit. The additionel leakage that can be tolerated is converted into an equivalent breach size that can be allowed in the habitability envelope to accommodate wear and tear on doors and maintenance / modification activities on habitability envelope boundary components. Based on the most recent leak test, 35.5 square inches of breaches are allowed in the habitability envelope boundary. This allowable breach size may increase or decrease when a leak test of the habitability t

envelope is performed and finds less or more leakage than the last test.

The licensee proposed to add the CCHE to the Limiting Condition for Operability (LCO) scope of

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TS 3.7.12. An associated ACTION CONDITION B was added to address CCHE inoperability due to a breach or breaches of the CCHE in excess of the limit (i.e.,35.5 square inches) and less than

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or equal to 1 square foot in excess of the limit (i.e.,179.5 square inches) for up to 7 days. This j

change was requested until the beginning of Cycle 13 only.

The proposed Condition B would be entered when breaches totaling greater than 35.5 square inches but less than 179.5 square inches exist, with an Allowed Outage Time (AOT) of up to 7 days. This allowance would permit additional breaches to facilitate maintenance / modification activities, or to accommodate door or seal failures that may occur. The proposed provision would permit the licensee to test, evaluate results, inspect / seal, and re-test the CCHE within the allowed 7-day period while operating.

Breaches would be authorized and tracked via a CR-3 administrative control procedure (Compliance Procedure, CP-147, " Control Complex Habitability Envelope (CCHE) Breaches") to assure the breach limit is not exceeded and operability is maintained in day-to-day operation. The process contained in CP-147 identifies the location and size of open breaches. In the event of an accident that poses a threat to control room habitability, breaches can be readily clo:;ed. The relatively small size of any single breach would facilitate closure using materials that are readily available.

Recent NRC-sponsored research on release of radioactive material from a damaged core, NUREG-1465, " Accident Source Terms for Ligl.t-Water Nuclear Power Plants," indicates much lower releases than are currently approved for use in dose calculations using Regulatory Guide (RG) 1.4, " Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Pressurized Water Reactors." Lower releases would translate directly into lower calculated doses and lower actual dos.es, thereby minimizing the threat from additional breaches or leakage into the habitability envelope.

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No threat to operators from toxic gas is created by the proposed breach allowance due to the reduction in the amount of toxic gas onsite, new analyses of the remaining toxic gas sources, and the insensitivity of toxic gas concentrations in the control room to breaches in the habi ability erivelope. Umiting toxic gas exposures come from " puff" releases that result in a highly concentrated cloud of gas entering the control complex through the normal ventilation intake. Since this type of release is quickly transported beyond the CCHE, the existence of breaches would not contribute significantly to toxic gas concentrations in the CCHE.

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Since the staff has not completed its review of the licensee's revised control room habitability report, the justification for continued operation (JCO) and associated compensatory measures, as described in FPC letter dated January 14,1998, remain in effect. The staff has previously determined, in a letter dated February 3,1998, that these measures provide reasonable assurance that CR-3 control room doses following design basis accidents will meet the requirements of 10 CFR Part 50, Appendix A. GDC-19 and the specifications of Standard Review Plan Chapter 6.4 during all operating modes. This determination is primarily based on the licensee's commitment for j

the timely administration of potassium iodide for thyroid prophylaxis. The staff's review of the proposed chmge relies in part on this previous determination and that the JCO and associated compensatory actions will remain in effect until the beginning of Cycle 13.

The staff also performed an independent habitability analysis for two toxic chemicals (sulfur dioxide and chlorine) that could be released from their containers and infiltrate into the CCHE. The staff analysis was based on the assumptions of the bounding control room volume (88,000 cubic ft), leak rate proportional to the size of break (179.5 square inches), and two cases: chemical container burst and chemical container developing a leak with a leakage rate of 100 kg/sec. The atmospheric conditions were selected to represent the most conservative values. Based on the amount of chlorine (64,000 lb) and sulfur dioxide (100,000 lb) in the containers and bounding distance from the chlorine and sulfur dioxide containers to the inlet to the CCHE (3400 ft), the concentration of chlorine or sulfur dioxide (container burst and container leak) in the CCHE would be below the lim!!s for the 2-minute criterion as specified in RG 1.78, " Assumptions for Evaluating the Habitab'lity of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release" and RG 1.95, " Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release," after either chemical was detected. Therefore, based upon the above, the toxic releases inside the CCHE due to the above chemicals are acceptable for the proposed temporary LCO Condition B to TS 3.7.12.

In addition to the potential for an increased dose contribution to the CR operators, a breach of the habitability envelope could allow smoke or toxic gasses built up in adjacent areas (e.g., the Turbine Building) to enter the CR, thus increasing the total plant risk. The licensee performed a risk assessment for the toxic gasses stored onsite and concluded that the risk increase, in terms of core damage frequency, is insignificant. The staff review found this assessment acceptable. The risk increase due to smoke entering the CR though the breach was not assessed by the licensee.

However, the licensee stated that there are administrative control procedures in place (CP-147) to ensure that breaches can be readily closed in case of an event, such as a fire in an adjacent area, that poses a threat to control room habitability. The staff performed a bounding assessment of the risk impact of smoke entering the CR through the breach following a fire in an adjacent area, such as the Turbine Building. It was concluded that, riue to the availability of CP-147, the average increase in yearly risk (assuming the proposed change will be valid until the beginning of Cycle 13) is expected to be insignificant based on guidance provided in RG 1.174,"An Approach for Using

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' 5 Probabilistic Risk ssessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis."' Furthermore, the risk increase during the AOT was assessed by the staff and

' iound acceptable based on guidelines provided in RG 1.177, "An Approach for Plant-Specific, e'

Risk-Informed Decision making: Technical Specifications." Therefore, the staff finds the proposed LCO Condson B to TS 3.7.12 acceptable.

The licensee also proposed changes to the remaining Conditions and Required Actions of '

.TS 3,7.12 to reflect the new Condition B. The staff finds that the additional changes to the Conditions and Required Actions of TS 3.7.12 are necessary to maintain consistency between the Requred Action steps and are acceptable.

.3.2'

Proposed Surveillance Reouirement (SR) 3.7.12.4 The licensee proposed a new SR to verify that CCHE boundary leakage does not exceed allowable limits as measured by performance of an integrated leakage test every 24 months. The proposed SR verifies the integrity of the CCHE and the assumed inleakage rates of potentially contaminated air. Dunng the emergency mode of operation, the CCHE is designed to be a closed environment having hmited air exchange with its surroundings. Performance of a periodic leak test verifies the contntang integrity of the CCHE. The frequency of 24 months is corisistent with the typical fuel cycle length.

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. The design of the CCHE precludes performance of the commonly applied leak test characterized by presstnizetion of the CCHE to a nominal value and measurement of the make-up air required to i

mantain pressurization.- The test for CR-3 is performed by operating CREVS in the emergency recirculation mode with the auxiliary building ventilation exhaust system (ABVES) operatng to maintan a differential pressure between the CCHE and the auxiliary building. The auxiliary building will be at least 1/8 inch water gauge negative pressure relative to the CCHE. Tracer gas will be i

used to determne the leakage rate. The acceptance c4iterion for the test is a leakage rate that would not result in control room personnel exceeding dose limits following the most limiting i

accident.

The proposed SR to perform a penodic leak test is similar to that included in Babcock & Wilcox Standard Technical Spoofications. It will determine the leakage across the hatxtability boundary,'

and allow licensee personnel to verify that the integrity of the CCHE is being maintained within the design basis. The licensee stated that tracer gas testing based on Amencan Society for Testing

'and Matenals (ASTM) Standard E741-93, " Standard Test Method for Determining Air Change Rate in a Sngle Zone by Means of a Tracer Gas Dilution," will be used to verify that the integrity of the -

CCHE is beng mantained within the design basis. The staff finds that the proposed SR 3.7.12.4, provides a new testing requrement that is more restrictive than the existing requirements for measunng unfiltered ir' leakage into the control complex hatxtability envelope and is, therefore, acceptable until the begonng of Cycle 13.

3.3

~ TS 5.6.212 Ventilation Filter Testina Prooram (VFTP)

The heenses proposed updating the labofeivry test standards to conform to current standards. The change in carbon adsost>er laboratory test standard will provide a more conservative test than that to which the hoensee is currently committed -.The new test conditions for the CCHE and auxiliary buildng ventilation exhaust system (ABVES) filters are more representative of the operating

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. conditions to which the carbon adsarber material will be exposed when in service. This change is conservative since testing at a higt.er temperature may overestimate adsorption capability at the expected filter media operating temperature.

The licensee has made major changes to improve control room habitability and CREVS performance. New control room radiological dose calculations have been performed. Lower, more conservative CREVS flow rates were used in the dose calculations. Flow rates were chosen which reflect the reduced flow associated with filter fouling. The values of allowed filter differential pressure and lower flow rate limit are being changed for the CREVS filter tests to be consistent with the calculations.

The staff finds that the licensee's proposed change whereby the VFTP for CREVS and the ABVES testing shall conform with RG 1.52, Revision 2,1978, " Design, Testing, and Maintenance Cnteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," and in accordance with American Society of Mechanical Engineers N510-1975, " Testing of Nuclear Air Treatment System" and ASTM D 3803-89, " Standard Test Method for Nuclear-Grade Activated Carbon " is acceptable because the proposed change reflects the use of acceptable and improved standards.

34 Inolace Testino and Pressure Drop for th3 CREVS filters The new lower limit on flow of 37,800 cfm for HEPA filters and charcoal adsorbers was chosen for inplace testing based on actual measured flow rates, and the calculated reduction in flow due to filter fouling and increased differential pressure across the filters. The staff finds that the licensee's proposed change whereby the VFTP for CREVS inplace testing for the HEPA filters and charcoal adsorbers conforms with RG 1.52, Revision 2,1978, Positions C.S.a, C.S.c, and C.S.d, and in i

accordance with ASME N510-1975, and is, therefore, acceptable. A corresponding change to the maximum allowed filter differential pressure from 6 inches to 4 inches is based on actual measured flow rates and is consistent with the flow and dose calculations, and is, therefore, acceptable to the staff.

3.5 Laboratory Testino for the CREVS Charcoal Adsorbers The licensee proposed revising TS 5.6.2.12.c to require a demonstration for each train of the CREVS that a laboratory test of a sample of the carbon adsorteer, when obtained as described in RG 1.52, Revision 2,1978, meets the laboratory testing criteria of ASTM D 3803-89 (Re-approved i

1995) at a temperature of 30 *C and relative humidity of 95 percent with methyl iodide penetration of less than 2.5 percent. The licensee provided the following discussion and justification for this change:

a.

The existing VFTP requires laboratory testing of carbon adsorber samples in accordance with RG 1.52, Revision 2,1978 and American National Standards Institute N509 -1976.

These documen:s ultimately require that the test be performed to US Atomic Energy Commission, Division of Reactor Development and Technology Standard RDT M16r 1T,

" Gas Phase Adsorbents for Trapping Radioactive lodine and lodine Components."

Performance of laboratory tests in accordance with ASTM D 3803-1989 eliminates technical problems that have been identified with the RDT 16-1T test method.

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• b.

The current test conditions specified in the VFTP are temperature of 80 *C and 70 percent relative humidity (RH). The proposed test conditions of 30 *C and 95 percent RH are more j

representative of the conditions to which the CR-3 carbon adsorber would be exposed following a radiological accident. NRC Information Notice 86-76, " Problems Noted in Control Room Emergency Ventilation Systems," indicated that laboratory testing of carbon at a i

temperature higher than that expected during the course of an accident could result in 4 significant over-prediction of the capability of the carbon to remove methyliodide. Therefore, the proposed test conditions will give a more accurate prediction of the performance of the carbon under post-accident conditions.

c.

ASTM D 3803-1989 is more stringent than RDT M16-1T, since it has closer tolerances on temperature, RH, and time. These tolerances result in better reproducibility of the test results. Testing in accordance with ASTM D 3803-1989 at 30 *C and 95 percent RH with a 2.5 percent penetration limit is more conservative than testing to RDT M161T at 80 *C and 70 percent RH with a penetration limit of 1 percent due to the more stringent tolerances on temperature and humidity in ASTM D3J03-1989. The combined effects of testing at more representative conditions and the use of the improved test standard compensates for the increased penetration limit.

The staff assessment for the proposed permanent change is as follows:

The current CR-3 TS 5.6.2.12.c requires that laboratory analyses of the carbon samples use the test procedures of Military Specification RDT M161T (date not indicated), but specifies that the test is to be conducted at 80 *C and 70 percent RH. The essential elements of this test are as follows:

e 70 percent RH, 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> pre-equilibration (pre-sweep) time, with air at 80 *C and 70 percent RH, e

2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> challenge, with gas at 80 *C and 70 percent RH, and e

2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> elution (post-sweep) time, with air at 80 *C and 70 percent RH.

e The licensee proposed TS 5.6.12.2.c requires that samples be obtained as described in RG 1.52, Revision 2, but specifies that the samples be tasted in accordance with ASTM D3803-1989 at 30*C and 95 percent RH. ASTM D3803-1989 is updated guidance based on an NRC verification and validation effort on ASTM D3803-1979, which is updated guidance based on RDT M16-1T. The essantial elements of the proposed TS changes for testing per ASTM D3803-1989 are:

e 95 percent RH l

o 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> minimum thermai stabiliz.ation, at 30 *C, l

e 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> pre-equilibration (pre-sweep) time, with air at 30 *C and 95 percent RH,

• 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> equilibration time, with air at 30 *C and 93 percent RH, e i hour challenge, with gas at 30 *C and 95 percent RH, and

. 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> elution (post-sweep) time, with air at 30 *C and 95 percent RH.

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The major differences between the current and proposed TS requirements for carbon testing are:

MAJOR DIFFERENCES Proposed TS Current TS Pre-Equilibration (Pre-Sweep) Temperature 30 *C 80*C i

Challenge Temperature 30 *C 80*C l

Y Elution (Post-Sweep) Temperature 30 *C 80 *C 1

Relative Humidity 95 percent 70 percent Total Pre-Test Equilibration 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 5 hours I

Tolerances of Test Parameters Smaller Larger The discussion below demonstrates that these differences make the proposed TS more conservative than the current TS requirements and, therefore, the proposed TS for CR-3 is j

acceptable.

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ASTM D3803-1989 challenges the representative charcoal samples at 30 *C rather than at 80 *C.

j in addition, ASTM D3803-1989 specifies a test temperature of 30 *C for both the pre-test and 1

post-test sweep rather than 80 *C. The quantity of water retained by charcoal is dependent on temperature, with less water being retained as the temperature rises. The water retained by the charcoal decreases its efficiency in adsorbing other contaminants. Because most charcoal is j

anticipated to be challenged at a temperature closer to 30 *C rather than 80 *C, the lower j

temperature test condition of AGTM D3803-1989 will yield more realistic results than a test performed at 80 *C.

ASTM D3803-1989 provides results which are reproducible compared to RDT M16-1T because it i

has smaller tolerances on various test parameters, and it requires that the charcoal sample be pre-equilibrated for a much longer period. The longer pre-equilibration timc is more conservative because it will completely saturate the representative charcoal sample which ensures reproducibility of the results by having every charcoal sample begin the test at the same initial conditions. Hence, 1

the proposed testing in accordance with ASTM D-3803-1989 standard would result in a more j

realistic prediction of the capability of the charcoal and is consistent with the intent of GL 99-02, j

• Laboratory Testing of Nudear Grade Activated Carbon," June 3,1999.

t in addition, proposed TS 12.5.6.2.c requires that the laboratory testing of charcoal samples show an acceptable methyl iodide penetration. In the licensee's dose analysis,2-inch charcoal beds are credited with a filter efficiency of 95 percent. The licensee's proposed acceptance criterion is a methyl iodide penetration of less than 2.5 percent for CR-3. The proposed acceptance criterion includes a safety factor of two which provides the staff with a degree of assurance that, at the end of the operating cycle, the charcoal will be capable of performing at least as well as assumed in the licensee's dose analysis. This factor of safety is acceptable based on the accuracy of test results obtained using the ASTM D3803-1989 standard.

9 3.6 Inplace Testino and Laboratory Testino for the ABVES Filters Control room habitability dose calculations include scenarios that postulate both a LOOP and no LOOP in combination with radiological release events. For scenarios where there is no LOOP, the ABVES and auxiliary building ventilation exhaust filters (ABVEFs) will remain functional and are credited in control room dose analyses. Therefore, the licensee proposed the addition of ABVEFs to

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the VFTP.

l The ABVEFs were included in the CR-3 Standard TS (STS), and were removed in the conversion to improved TS (ITS) in 1993. The basis for removal was that the filters were not credited as part of any accident analys;s. The analyses presented in the licensee's revised Control Room Habitability Report, included in the July 30,1998 submittal, takes credit for the ABVES at 75 percent iodine removal efficiency when the accident scenario does not include a LOOP. Therefore, the ABVES is being added to the ITS VFTP.

The licensee stated that the acceptanco criteria for high efficiency particulate air filter penetration and inplace carbon adsorber system bypass are consistent with the former STS requirements. The acceptance criterion for laboratory testing of carbon adsorber samples is being changed to 12.5 percent penetration to be consistent with the filter efficiency credited in control room dose calculations. In accordance with guidance provided in draft Generic Letter (GL) 99-02, a safety factor of two has been applied to the credited 75 percent removal efficiency to determine the laboratory sample acceptance criterion.

The licensee indicated that no LCO was being proposed for the auxiliary building (AB) exhaust fans.

These fans are normally operating 100 percent of the time to maintain environmental conditions within the auxiliary building, and to maintain a slight negative pressure in the auxiliary building to control the release of radioactivity to the environment. Normal operating and maintenance practices assure one train of auxiliary building exhaust fans are available and in operation. Dose analyses of the MHA and letdown line failure accident were performed for both LOOP and non-LOOP scenarios.

The effects of the unavailability of the auxiliary building exhaust fans, and therefore the filters, for the non-LOOP scenarios are bounded by the existing calculations. In general, unavailability of the AB fans results in lower leakage into the CCHE and results in lower calculated dose.

The staff's evaluation va inplacc testing for HEPA and carbon adsorber filters in TS 5.6.2.12.a and TS 5.6.12.2.b, and laboratory testing of a representative sample of the carbon adsorber in TS 5.6.12.2.c is also applicable to the above ABVES TS except that: (1) the flow rate through each filtration train is between 35,253 and 43,087 cfm; (2) inplace test penetration through the HEPA filter and bypass through the carbon adsorber is less than 1 percent; and (3) credited iodide removal efficiency through carbon adsorber is 75 percent. The staff also agrees with the licensee's above rationale. Therefore, the proposed TS for the ABVES is acceptable.

3.7 Technical Specification Bases The Bases associated with the changes to TS 3.7.12 and 5.6.2.12 were revised to reflect the proposed changec to these specifications and are acceptable.

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4.0 STATE CONSULTATION

Based upon a letter dated March 8,1991, from Mary E. Clark of the State of Florida, Department of Health and Rehabilitative Services, to Deborah A. Miller, Licensing Assistant, U.S. NRC, the State of Florida does not desire notification of issuance of license amendments.

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5.0 ENVIRONMENTAL CONSIDERATION

S The amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the

- types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding (63 FR 64115). Accordingly, the amendment meets the eligibility criteria for c&goricei exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connechon with the issuance of the amendment.

6.0 CONCLUSION

Based on its review of the licensee's proposal snd the guidance provided in RG 1.174, tne staff concludes that the average increase in yeariy risk (assuming tne proposed change will be valid to the beginn:ng of Cycle 13), is expected to be insignificant. Furthermore, the risk increase during the i

AOT was assessed by the staff to'be acceptable based on guidelines provided in RG 1.177. These findmgs support the proposed LCO Condition B to TS 3.7.12. Additionally, the staff performed an l

independent hatWtability ar.alysis for toxic chemicals (sulfur dioxide and chlorine) which could be

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released and infiltrate the CCHE and found that the concentration of these chemicals in the CCHE would be below the limits for the two-minute criterion as specified in RG 1.78 and 1.95. Therefore, l

based upon the above, the staff concludes that the proposed LCO Condition B to TS 3.7.12 is acceptable until the beginning of Cycle 13.

. The staff finds that the proposed changes to the L' CO Conditions C through F to TS 3.7.12 are admirustrative changes which reflect the addition of LCO Condition B conceming the CCHE moperability. Therefore, the changes to these LCO Conditions are acceptable.

Proposed SR 3.7.12.4 (valid until the beginnog of cycle 13) for verifying unfiltered inisakage inside

- CCHE is a new SR. The staff finds that the proposed SR 3.7.12.4, provides a new testing requrement which is more restrictive than the existing requirements for measuring Unfiltered inleakage into the control complex habitabihty envelope and is, therefore, acceptable until the begoneg of Cycle 13.

' The proposed change to TS 5.6.2.12, " Ventilation Filter Testing Program (VFTP)," is consistent with

- the ITS and results in k more restrictive requirement than previously specsfied and is, therefore, acceptable 'The proposed permanent change to test charcoal in iinsidance with the ASTM D-38031989 standard would result in a more realistic prediction of the capabihty of the charcoal and is f consistent with the' intent of GL 99-02, and is, therefore, acceptable.

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. The staff concludes that (1) there is reasonable assurance that the health and safety of th9 public will not be endangered by operation in the proposed manner, (2) such activities will be conducMd in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Raval, N. Saltos, K. Parczewski, J. Bongarra Date: August 23, 1999 t

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Mr. John Paul Cowan CRYSTAL RIVER UNIT NO. 3 Florida Power Corporation cc:

Mr. R. Alexander Glenn Chairman Corporate Counsel (MAC-BT15A)

Board of County Commissioners Florida Power Corporation Citrus County P.O. Box 14042 110 North Apopka Avenue i

St. Petersburg, Florida 33733-4042 invemess, Florida 34450-4245 j

Mr. Charles G. Pardee, Director Ms. Sherry L. Bemhoft, Director Nuclear Plant Operations (PA4A)

Nuclear Regulatory Affairs (NA2H)

Florida Power Corporation Florida Power Corporation

' Crystal River Energy Complex Crystal River Energy Complex 15760 W. Power Line Street 15760 W. Power Line Street Crystal River, Florida 34428-6708 Crystal River, Florida 34428-6708 Mr. Michael A. Schoppman Senior Resident inspector Framatome Technologies Inc.

Crystal River Unit 3 1700 Rockville Pike, Suite 525 U.S. Nuclear Regulatory Commission Rockville, Maryland 20852 6745 N. Tallahassee Road Crystal River, Florida 34428 Mr. William A. Passetti, Chief Department of Health Mr. Gregory H. Hainon Bureau of Radiation Control Director, Quality Programs (SA2C) 2020 Capital Circle, SE, Bin #C21 Florida Power Corporation Tallahassee, Florida 32399-1741 Crystal River Energy Complex 15760 W. Power Line Street Attomey General Crystal River, Florida 34428-6708 i

Department of Legal Affairs

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The Capitol Tallahassee, Florida 32304 Mr. Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100