3F0311-02, Response to Request for Additional Information Regarding Part 26 Exemption Request
| ML110730510 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/03/2011 |
| From: | Holt J Progress Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F0311-02 | |
| Download: ML110730510 (7) | |
Text
., Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 26 March 3, 2011 3F0311-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Response to Request for Additional Information Regarding Part 26 Exemption Request
References:
(1) CR-3 to NRC letter, 3F0710-03, dated July 13, 2010, "Request for One-Time Exemption from the Requirements of 10 CFR 26.205(d)(3)"
(2) CR-3 to NRC letter, 3F0810-10, dated August 26, 2010, "Response to Request for Additional Information Regarding Part 26 Exemption Request" (3) CR-3 to NRC letter, 3F0910-06, dated September 23, 2010, "Response to Request for Additional Information Regarding Part 26 Exemption Request" (4) NRC to CR-3 email dated February 10, 2011, "Crystal River Part 26 exemption Request (ME4268)"
Dear Sir:
On July 13, 2010, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., requested a one-time exemption from portions of 1 CFR 26.205(d)(3) for Crystal River Unit 3 (CR-3). Subsequently, the Nuclear Regulatory Commission (NRC), by emails dated August 11, 2010, September 15, 2010, and February 10, 2011, forwarded requests for additional information (RAIs) concerning the exemption request. Attachment 1 to this letter provides a response to the February 10, 2011 RAI.
In addition, the CR-3 NRC Project Manager requested that FPC notify the NRC with a requested approval date for the exemption request. FPC hereby requests an exemption approval date of March 14, 2011, in order to support restart from the current extended outrage.
The regulatory commitment identified in this submittal is provided in Attachment 2.
If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Superintendent, Licensing and Regulatory Programs at (352 563-4796.
Sincerely, ames W. Holt Plant General Manager Crystal River Nuclear Plant Attachments: 1. Response to Request for Additional Information
- 2. List of Regulatory Commitments xc: NRR Project Manager Regional Administrator, Region II Senior Resident Inspector Progress Energy Florida, Inc.
Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428
FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 /LICENSE NUMBER DPR-72 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ATTACHMENT 1
U. S. Nuclear Regulatory Commission Attachment 1 3F0311-02 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION On July 13, 2010, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., requested a one-time exemption from portions of 10 CFR 26.205(d)(3) for Crystal River Unit 3 (CR-3). Subsequently, the Nuclear Regulatory Commission (NRC), by emails dated August 11, 2010, September 15, 2010, and February 10, 2011, forwarded requests for additional information (RAIs) concerning the exemption request. Below is the NRC RAI dated February 10, 2011, followed by the CR-3 response.
NRC RAI 1 In your letter dated July 13, 2010, you requested approval of this exemption by September 1, 2010 to support the restart of Crystal River Unit 3. Please provide the planned date for restart and the revised requested date for approval of this exemption.
CR-3 Response CR-3 is scheduled to close breakers on April 15, 2011. In order to support this schedule FPC requests an exemption approvaldate of March 14, 2011.
NRC RAI 2 Please update the requested exemption to explain how fatigue for the affected individuals is properly managed by the licensee up to the requested date.
CR-3 Response CR-3 has transitioned all covered workers to an online schedule that complies with 10 CFR 26.205(d)(3) requirements. As an example, operations,I&C maintenance, chemistry, and health physics personnel averaged 46, 43, 37, and 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> per week under 10 CFR 26.205(b),
respectively, during the shift cycle between January 10, 2011 and February20, 2011. CR-3 has maintained a similar schedule for over a year. As a result, CR-3 is confident that cumulative fatigue will not be an issue going into restart.
No waivers have been issued under 10 CFR 26.207 by CR-3 operations,maintenance, chemistry or healthphysics departments during the ongoing extended outage.
NRC RAI 3 In your letter dated August 26, 2010, you have stated that the current schedule indicated 58 days from the time the unit enters MODE 6 to reaching 100% power. Please revise this statement to reflect the current status and schedule for the restart. Also, please justify why a 60-day period is needed for restart.
U. S. Nuclear Regulatory Commission Attachment 1 3F0311-02 Page 2 of 3 CR-3 Response Currently, CR-3 is in MODE 5 and is scheduled to begin a Structural Integrity Test (SIT) the week of March 21, 2011. A precursor activity to performing the SIT is to depressurize and partially drain the Reactor Coolant System, which is scheduled to begin on March 14, 2011.
This is a complex evolution and will require additionaloperationspersonnel in excess of those required during normal, online operations. CR-3 is scheduled to close breakers on April 15, 2011, and will cease outage activities shortly thereafter.
Although startup activities are scheduled for 33 days, this has been a uniquely complex outage both in terms of the amount of time the plant has been offline and the extent of the modifications to both the primary and secondary systems and components. Industry operational experience suggests that 75% of delays in startup activities involved components that had been worked on earlier in the outage. This operationalexperience shows the main feedwater andreactor coolant systems, both of which have been modified during this outage, have been disproportionately involved in startup delays.
In the interest of nuclear safety, FPCfeels it is prudent to seek the full 60 days to ensure adequate staffing andflexibility to address equipment challenges as they arise during restart.
CR-3 will return to normal online work hour controls within 60 days or when the outage activities are completed, whichever is less.
NRC RAI 4 Please discuss the methods used for transition of the individuals, affected by this exemption, who are working at another plant (Progress Energy's plant or other nuclear power plants) outages onto the Crystal River. Specifically, please revise the RAI response dated September 23, 2010 to clearly discuss transition of the affected personnel as defined in 10 CFR 26.4(a)(1), (a)(2), and (a)(4) from another site to the Crystal River site. Please provide your commitment to support this transition in a regulatory commitment for tracking purposes.
CR-3 Response ProgressEnergy (PGN)is committed to ensuring that employees supporting other outages are not fatigued when they return to support the CR-3 restart. In the initial exemption request, dated July 13, 2010 (Reference 1), a commitment was made that, "Specifically, CR-3 will ensure covered personnel including those temporarily assigned to outages at other units, do not work greater than an average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> per week .for a minimum of eight weeks preceding implementation of the exemption. " Progress Energy implements the work hour restrictions of Part 26 through PGN fleet procedure ADM-NGGC-0206, "Managing Fatigue and Working Hour Limits, " which requires that.
U. S. Nuclear Regulatory Commission Attachment 1 3F0311-02 Page 3 of 3 If an outage worker begins work for PGN [CR-3] within 9 days of performing outage work at another nuclearplant., the worker must:
- a. Have had a 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break within the 9 days that precede the day on which the worker begins workfor PGN [CR-3].
- b. Not have exceeded or will not exceed the MWH1 rules.
This is consistent with the controls in Regulatory Guide 5. 73, "FatigueManagementfor Nuclear Power Plant Personnel," Regulatory Position 10. CR-3 will continue to implement Part 26 in this manner and commits to ensure all workers beginning restart work will have a minimum 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break within the 9 days thatprecede the day on which the worker begins work at CR-3, and will not exceed the Maximum Work Hour rules. In order to facilitate this, ProgressEnergy has a single fleet databasefor fatigue management that ensures compliance with Part26.
' MWH-Maximum Work Hours, as outlined in 10 CFR 26.205(d)
FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 /LICENSE NUMBER DPR-72 LIST OF REGULATORY COMMITMENTS ATTACHMENT 2
U. S. Nuclear Regulatory Commission Attachment 2 3F031 1-02 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies the commitment made by Florida Power Corporation (FPC) in this submittal relevant to the exemption request to 10 CFR 26.205(d)(3). Any other actions discussed in the submittal represent intended or planned actions by FPC. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Superintendant, Licensing and Regulatory Programs of any questions regarding this document or any associated regulatory commitments.
Commitment Due Date All workers beginning restart work will have a CR-3 will return to normal, online work hour minimum 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> break within the 9 days that controls within 60 days or when the outage precede the day on which the worker begins activities are completed, whichever is less.
work at CR-3, and will not exceed the Maximum Work Hour rules.