3F0114-02, Request for Exemptions from 10 CFR 73, Appendix B, General Criteria for Security Personnel

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Request for Exemptions from 10 CFR 73, Appendix B, General Criteria for Security Personnel
ML14023A662
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/15/2014
From: Elnitsky J
Duke Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0114-02
Download: ML14023A662 (7)
v • d • e


Text

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Docket 50-302 Operating License No. DPR-72 SAFEGUARDS INFORMATION

Subject:

Crystal River Unit 3 - Request for Exemptions from 10 CFR 73, Appendix B, General Criteria for Security Personnel

References:

1. CR-3 to NRC letter dated February 20, 2013, "Crystal River Unit 3 -

Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor," (Accession No. ML13056A005)

2. NRC to CR-3 letter dated March 13, 2013, "Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel

Dear Sir:

In accordance with 10 CFR 73.5, "Specific exemptions," Duke Energy Florida, Inc. (DEF) is hereby requesting exemptions from 10 CFR 73, Appendix B, related to annual force-on-force exercises. These exemption requests are provided in Attachment 1 and the associated environmental consideration is provided in Attachment 2. Attachment 1 contains Safeguards Information, as defined by 10 CFR 73.21, and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended. DEF requests approval of the exemption requests by mid-December 2014, which is when preparation for the March 2015 annual force-on-force exercise would need to begin.

By letter dated February 20, 2013, DEF informed the U. S. Nuclear Regulatory Commission (NRC) that Crystal River Unit 3 (CR-3) had permanently ceased operations and that the fuel had been permanently removed from the reactor vessel (Reference 1). By letter dated March 13, 2013, the NRC acknowledged the CR-3 certificate of permanent cessation of power operation and permanent removal of fuel from the reactor vessel (Reference 2). Therefore, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

No new regulatory commitments are contained in this submittal.

NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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, .o1llllllll SAFEGUARDS INFORMATION If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Regulatory Affairs Manager, at (352) 563-4796.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 15, 2014.

J n Elnitsky, Vice President reject Management and Construction JE/dwh xc: Regional Administrator, Region I NRR Project Manager Attachments: 1. Exemption Requests (Safeguards Information)

2. Environmental Consideration NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACHMENT 1 EXEMPTION REQUESTS NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACHMENT 2 ENVIRONMENTAL CONSIDERATION NOTE:. ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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SAFEGUARDS INFORMATION Crystal River Unit 3 Docket No. 50-302/ License No. DPR-72 Environmental Consideration The proposed exemptions meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25), because the proposed exemptions involve: (i) no significant hazards consideration; (ii) no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (iii) no significant increase in individual or cumulative occupational radiation exposure; (iv) no significant construction impact; (v) no significant increase in the potential for consequences from radiological accidents; and (vi) the requirements from which the exemptions are sought involve safeguards plans and other requirements of an administrative, managerial or organizational nature. Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed exemptions.

(i) No significance hazards consideration Duke Energy Florida, Inc., (DEF) has evaluated the proposed exemptions to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92 as discussed below:

1. Do the proposed exemptions involve a significant increase in the probability or consequences of an accident previously evaluated?
  • The proposed exemptions have no effect on plant structures, systems and components (SSCs) and no effect on the capability of any plant SSC to perform its design function.

The proposed exemptions would not increase the likelihood of a malfunction of any plant sse. The proposed exemptions would have no effect on any of the previously evaluated accidents in the CR-3 Final Safety Analysis Report. The exemptions will not affect the probability of occurrence of any previously analyzed accident.

Therefore, the proposed exemptions do not involve a significant increase in the probability or consequences of an accident previously evaluated.

NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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2. Do the proposed exemptions create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed exemptions do not involve a physical alteration of the plant. No new or different type of equipment will be installed and there are no physical modifications to existing equipment associated with the proposed exemptions. Similarly, the proposed e>Eemptions would not physically change any SSCs involved in the mitigation of any accidents. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed exemptions do not create the possibility of a new accident as a result of new failure modes associated with any equipment or personnel failures. No changes are being made to parameters within which the plant is normally operated, or in the setpoints which initiate protective or mitigative actions, and no new failure modes are being introduced.

Therefore, the proposed exemptions do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed exemptions involve a significant reduction in a margin of safety?

The proposed exemptions do not alter the design basis or any safety limits for the plant. The proposed exemptions do not impact station operation or any plant SSC that is relied upon for accident mitigation.

Therefore, the proposed exemptions do not involve a significant reduction in a margin of safety .

. Based on the above, DEF concludes that the proposed exemptions present no significant hazards consideration, and, accordingly, a finding of "no significant hazards consideration" is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

There are no expected changes in the types, characteristics, or quantities of effluents discharged to the environment associated with the proposed exemptions. There are no materials or chemicals introduced into the plant that could affect the characteristics or types of effluents released offsite. In addition, the method of operation of waste processing systems will not be affected by the exemptions. The proposed exemptions will not result in changes to the design basis requirements of SSCs that function to limit or monitor the release of effluents. All the SSCs associated with limiting the release of effluents will continue to be able to perform their functions. Therefore, the proposed exemptions will result in no significant change to the types or significant increase in the amounts of any effluents that may be released offsite.

NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1,

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SAFEGUARDS INFORMATION (iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The exemptions would result in no expected increases in individual or cumulative occupational radiation exposure on either the workforce or the public. There are no expected changes in normal occupational doses. Likewise, design basis accident dose is not impacted by the proposed exemptions.

(iv) There is no significant construction impact.

No construction activities are associated with the proposed exemptions.

(v) There is no significant increase in the potential for consequences from radiological accidents.

See the no significant hazards considerations discus~ion in Item (i) above.

(vi)The requirements from which exemptions are sought involve safeguard plans and other requirements of an administrative, managerial or organizational nature.

DEF is requesting exemptions from 10 CFR 73, Appendix B, related to annual FOF exercises.

NOTE: ATTACHMENT 1 TO THIS LETTER CONTAINS SAFEGUARDS INFORMATION AND MUST BE PROTECTED ACCORDINGLY. ON SEPARATION OF ATTACHMENT 1, THIS LETTER IS "DECONTROLLED."

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