3F0316-03, License Amendment Request No. 318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Scheme, Revision 1, for the ISFSI, Response to Request for Additional Information

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License Amendment Request No. 318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Scheme, Revision 1, for the ISFSI, Response to Request for Additional Information
ML16063A240
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/02/2016
From: Reising R
Duke Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0316-03, TAC L53072
Download: ML16063A240 (8)
v • d • e


Text

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.90 March 2, 2016 3F0316-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - License Amendment Request #318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Scheme, Revision 1, for the Independent Spent Fuel Storage Installation Response to Request for Additional Information

References:

1. NRC to CR-3 letter dated February 04, 2016, Crystal River Unit 3 Nuclear Generating Plant - Request for Additional Information License Amendment Request for Emergency Plan Changes (TAC NO. L53072) (Adams Accession No ML16032A177)
2. CR-3 to NRC letter dated August 27, 2015, Crystal River Unit 3 - License Amendment Request #318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Bases Manual, Revision 1, for the Independent Spent Fuel Storage Installation (ADAMS Accession No. ML15246A231)

Dear Sir:

In accordance with the provisions of 10 CFR 50.90, Duke Energy Florida, LLC, previously known as Duke Energy Florida, Inc., hereby submits the response to the Nuclear Regulatory Commission (NRC) request for additional information (RAI). This RAI (Reference 1) was provided to Crystal River Unit 3 (CR-3) from the NRC Project Manager on February 4, 2016, regarding the CR-3 submittal, Permanently Defueled Emergency Plan and Emergency Action Level Bases Manual, for the Independent Spent Fuel Storage Installation (Reference 2). to this letter provides the RAI response. to this letter provides a corrected PDEP Summary of Changes.

This correspondence contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Phil Rose, Nuclear Regulatory Affairs, at (352) 563-4883.

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 2, 2016.

Sincerely, Ronald R. Reising, Senior Vice President Operations Support RRR/par

Enclosures:

1. Response to Request for Additional Information
2. Corrected PDEP Summary of Changes xc: NMSS Project Manager Regional Administrator, Region 1

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

U. S. Nuclear Regulatory Commission Page 1 of 2 3F0316-03 Enclosure 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated August 27, 2015 (Reference 1), Duke Energy Florida, LLC., previously known as Duke Energy Florida, Inc., (DEF) requested that the Nuclear Regulatory Commission (NRC) review and approve License Amendment Request (LAR) #318, Revision 0, Permanently Defueled Emergency Plan (PDEP), Revision 2, and Emergency Action Level Bases Manual, Revision 1. In a letter dated February 4, 2016, the NRC provided a request for additional information (RAI) regarding LAR #318, Revision 0 (Reference 2).

The RAI questions and the Crystal River Unit 3 (CR-3) responses are provided below. These responses clarify the revision number process used by DEF and the removal of the reference to the Emergency Management Network (EMNET) tool from the Permanently Defueled Emergency Plan (PDEP).

CR-3-RAI-01 In a letter dated May 23, 2014 (ADAMS Accession No. ML14154A408), DEF submitted Revision 1 to the PDEP and Revision 1 to the Permanently Defueled EAL Bases Manual. In a letter dated October 6, 2014 (ADAMS Accession No. ML14288A122), DEF submitted Revision 2 to the PDEP. Finally, in the August 27, 2015, letter cited above, DEF submitted Revision 2 to the PDEP and Revision 1 to the Permanently Defueled EAL Bases Manual (duplicate numbers, in both cases, to previous submittals). Please explain the revision numbering process for both documents.

RAI-01 Response When the PDEP and Permanently Defueled EAL Bases Manual were submitted on September 26, 2013 for staff review, a decision had not been made as to how any additional changes made to these documents during the staff review and approval process would be tracked. Subsequently, an internal convention, which used the same revision numbering (i.e.

Rev. 1, Rev. 2) system for these documents that is used for controlled documents at the station after they are issued, was adopted to differentiate versions of the PDEP and EAL Bases Manual created as responses to Requests for Additional Information (RAI) were submitted. In hindsight, a unique numbering system should have been used to track these draft revisions while initial approval of these documents was still in progress. This condition has been entered into the CR3 corrective action program.

Following receipt of NRC approval on March 31, 2015, both the PDEP and the Permanently Defueled EAL Bases Manual were formally issued at the station as Revision 0.

A subsequent revision to the PDEP was made under 10 CFR 50.54 (q) to clarify requirements for Self Contained Breathing Apparatus (SCBA) training for emergency response personnel. This resulted in the formal issue of Revision 1.

During preparation of LAR #318, the same internal numbering convention was carried forward, resulting in confusion between the current draft submittals under review as the PDEP, Revision 2, and Permanently Defueled EAL Bases Manual, Revision 1, and the previous draft submittals made under LAR #315. Although the revision numbering of the documents submitted appears to be a duplication, the documents submitted under LAR #318 correctly reflect the planned changes for which staff approval is requested.

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 Enclosure 1 CR-3-RAI-02 In the May 23, 2014, DEF letter cited above, containing Revision 1 to the PDEP, it is noted in the Summary of Changes that references were deleted from the Emergency Management Network (EMnet) as the back-up communications system to the State Watch Office. The August 27, 2015, DEF letter containing Revision 2 to the PDEP, also states Deleted EMnet.

Please explain the revision process regarding the elimination of EMnet, since based on DEFs May 23, 2014 correspondence, it is understood that commercial telephones (landlines) or cellular telephones are viewed as the back-up means of communications (to the State Hot Ringdown) with off-site emergency response organizations. Also, please confirm that the State of Florida is in agreement with the means of communication between CR-3 and the State.

RAI-02 Response The August 27, 2015 License Amendment Request contained an administrative error that was not identified, where the summary of changes contained in the PDEP referenced the Emergency Management Network (EMnet) in error. The CR-3 PDEP was issued to the plant on April 1, 2015 as Revision 0 and did not contain any reference to the use or testing of EMnet.

None of the subsequent revisions to the PDEP contained any reference to EMnet. EMnet is no longer used at CR-3 and is not part of the PDEP. A corrected Summary of Changes is included as Enclosure 2 to this letter.

CR-3 confirms that the State of Florida Division of Emergency Management, Radiological Emergency Preparedness Program is in agreement with the current methods of communication, including commercial telephones (landlines) and cellular phones used as back-up communications.

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ENCLOSURE 2 CORRECTED PDEP

SUMMARY

OF CHANGES

U. S. Nuclear Regulatory Commission Page 1 of 2 3F0316-03 Enclosure 2 Summary of Changes DRR 752017 REASON &

PAGE / SECTION CHANGE REFERENCES Cover Sheet Changed Emergency Planning Coordinator Name Update Staffing change to current EPC Throughout Updated Decommissioning Director to new title, SAFSTOR organization General Manager, Decommissioning title change Throughout DTO or Decommissioning Transition Organization DTO is now called the has been replaced with the title SAFSTOR SAFSTOR organization organization Throughout Replaced Plant Manager with Operations and SAFSTOR organization Maintenance Manager title change Throughout Changed Emergency Preparedness Coordinator Correct erroneous title to Emergency Planning Coordinator Table of Contents Updated Section Title and page numbers Format update Table of Contents, Deleted reference to [R3] NOCS 100477, the Commitment page v RERP and EALs Updated to Reflect Information Corresponding to NUMARC/NESP-007, Guidance in NRC Bulletin 2005-02, Attachment 2, Pages 6-7 Page 2-1, Section Changed wording from as applicable to CR3 in its Editorial. Reflects 2.1 permanently shutdown and defueled status to current PDEP with approved exemptions that reflect CR3 in its permanently shutdown and defueled status Page 2-2 Added to the facility description the ISFSI ISFSI added to PDEP facility description Page 4-5, Section Changed DEF acronym from Duke Energy Editorial 4.2 Florida, Inc. to Duke Energy Florida Page 4-3 Added ISFSI definition ISFSI added to PDEP Page 4-5 Removed DTO and added ISFSI DTO transitioned into SAFSTOR. ISFSI is a new facility Page 5-5, step Retitled Citrus County Dispatch Center to be 911 Update title 5.5.4.1 dispatch center Page 6-1, step 6.1 Added management of the ISFSI activities to the ISFSI facility added.

SS/CFH (LAR 318)

Page 6-7, section6.4 Corrected title of Dhiaa Jamil to Executive Vice Update title per Org.

President & President Regulated Generation and Chart Transmission Page 6-4 step Removed communicator position ERO position reduction 6.2.3.1 and re- (LAR 318) numbered

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 Enclosure 2 Summary of Changes REASON &

PAGE / SECTION CHANGE REFERENCES Page 6-6 step 6.2.5 Re-titled Fire Brigade to Industrial Incipient Fire Update titles Brigade Page 6-7 and Re-titled Vice President to present title of Senior Update titles throughout Vice President of Operations Support Page 6-8, Table 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 6-9, Figure 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 8-1, step 8.1 Added NEI 99-01 Reference for ISFSI EAL ISFSI EAL addition (LAR 318)

Page 8-2, step 8.2 Added ISFSI EAL category ISFSI EAL addition (LAR 318)

Page 9-3, Section Added notification and removed emergency Time of notification is 9.3 incident on the first paragraph, last sentence appropriate in lieu of time of emergency incident Page 10-1, step Replaced Communicator with Emergency Deleted Communicator 10.1 Coordinator as being responsible for ERO position (LAR 318) communications Page 12-3, step Added Portable radiation monitoring instruments Added instrumentation 12.2.1 are maintained to support ISFSI operations available to support including transfer operations of the Dry Shielded ISFSI operations Canister (DSC) to the Horizontal Storage Module (HSM) and for monitoring of the spent fuel while in storage in the HSM Page 15-4, step Removed words is affected Editorial wording 15.3.3 correction Page 18-5, step Replaced EP Supervisor with Emergency SAFSTOR organization 18.4 and throughout Planning Coordinator does not have a EP Supervisor Page 19-1, Section Removed words communications personnel MCR Communicator 19.0 being eliminated (LAR 318)

Page 19-3, step Deleted training reference for MCR Communicator ERO position reduction 19.1.7 (LAR 318)

Page 19-4, Table Deleted training reference for MCR Communicator ERO position reduction 19.1 (LAR 318)

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.90 March 2, 2016 3F0316-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - License Amendment Request #318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Scheme, Revision 1, for the Independent Spent Fuel Storage Installation Response to Request for Additional Information

References:

1. NRC to CR-3 letter dated February 04, 2016, Crystal River Unit 3 Nuclear Generating Plant - Request for Additional Information License Amendment Request for Emergency Plan Changes (TAC NO. L53072) (Adams Accession No ML16032A177)
2. CR-3 to NRC letter dated August 27, 2015, Crystal River Unit 3 - License Amendment Request #318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Emergency Action Level Bases Manual, Revision 1, for the Independent Spent Fuel Storage Installation (ADAMS Accession No. ML15246A231)

Dear Sir:

In accordance with the provisions of 10 CFR 50.90, Duke Energy Florida, LLC, previously known as Duke Energy Florida, Inc., hereby submits the response to the Nuclear Regulatory Commission (NRC) request for additional information (RAI). This RAI (Reference 1) was provided to Crystal River Unit 3 (CR-3) from the NRC Project Manager on February 4, 2016, regarding the CR-3 submittal, Permanently Defueled Emergency Plan and Emergency Action Level Bases Manual, for the Independent Spent Fuel Storage Installation (Reference 2). to this letter provides the RAI response. to this letter provides a corrected PDEP Summary of Changes.

This correspondence contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Phil Rose, Nuclear Regulatory Affairs, at (352) 563-4883.

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 2, 2016.

Sincerely, Ronald R. Reising, Senior Vice President Operations Support RRR/par

Enclosures:

1. Response to Request for Additional Information
2. Corrected PDEP Summary of Changes xc: NMSS Project Manager Regional Administrator, Region 1

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

U. S. Nuclear Regulatory Commission Page 1 of 2 3F0316-03 Enclosure 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated August 27, 2015 (Reference 1), Duke Energy Florida, LLC., previously known as Duke Energy Florida, Inc., (DEF) requested that the Nuclear Regulatory Commission (NRC) review and approve License Amendment Request (LAR) #318, Revision 0, Permanently Defueled Emergency Plan (PDEP), Revision 2, and Emergency Action Level Bases Manual, Revision 1. In a letter dated February 4, 2016, the NRC provided a request for additional information (RAI) regarding LAR #318, Revision 0 (Reference 2).

The RAI questions and the Crystal River Unit 3 (CR-3) responses are provided below. These responses clarify the revision number process used by DEF and the removal of the reference to the Emergency Management Network (EMNET) tool from the Permanently Defueled Emergency Plan (PDEP).

CR-3-RAI-01 In a letter dated May 23, 2014 (ADAMS Accession No. ML14154A408), DEF submitted Revision 1 to the PDEP and Revision 1 to the Permanently Defueled EAL Bases Manual. In a letter dated October 6, 2014 (ADAMS Accession No. ML14288A122), DEF submitted Revision 2 to the PDEP. Finally, in the August 27, 2015, letter cited above, DEF submitted Revision 2 to the PDEP and Revision 1 to the Permanently Defueled EAL Bases Manual (duplicate numbers, in both cases, to previous submittals). Please explain the revision numbering process for both documents.

RAI-01 Response When the PDEP and Permanently Defueled EAL Bases Manual were submitted on September 26, 2013 for staff review, a decision had not been made as to how any additional changes made to these documents during the staff review and approval process would be tracked. Subsequently, an internal convention, which used the same revision numbering (i.e.

Rev. 1, Rev. 2) system for these documents that is used for controlled documents at the station after they are issued, was adopted to differentiate versions of the PDEP and EAL Bases Manual created as responses to Requests for Additional Information (RAI) were submitted. In hindsight, a unique numbering system should have been used to track these draft revisions while initial approval of these documents was still in progress. This condition has been entered into the CR3 corrective action program.

Following receipt of NRC approval on March 31, 2015, both the PDEP and the Permanently Defueled EAL Bases Manual were formally issued at the station as Revision 0.

A subsequent revision to the PDEP was made under 10 CFR 50.54 (q) to clarify requirements for Self Contained Breathing Apparatus (SCBA) training for emergency response personnel. This resulted in the formal issue of Revision 1.

During preparation of LAR #318, the same internal numbering convention was carried forward, resulting in confusion between the current draft submittals under review as the PDEP, Revision 2, and Permanently Defueled EAL Bases Manual, Revision 1, and the previous draft submittals made under LAR #315. Although the revision numbering of the documents submitted appears to be a duplication, the documents submitted under LAR #318 correctly reflect the planned changes for which staff approval is requested.

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 Enclosure 1 CR-3-RAI-02 In the May 23, 2014, DEF letter cited above, containing Revision 1 to the PDEP, it is noted in the Summary of Changes that references were deleted from the Emergency Management Network (EMnet) as the back-up communications system to the State Watch Office. The August 27, 2015, DEF letter containing Revision 2 to the PDEP, also states Deleted EMnet.

Please explain the revision process regarding the elimination of EMnet, since based on DEFs May 23, 2014 correspondence, it is understood that commercial telephones (landlines) or cellular telephones are viewed as the back-up means of communications (to the State Hot Ringdown) with off-site emergency response organizations. Also, please confirm that the State of Florida is in agreement with the means of communication between CR-3 and the State.

RAI-02 Response The August 27, 2015 License Amendment Request contained an administrative error that was not identified, where the summary of changes contained in the PDEP referenced the Emergency Management Network (EMnet) in error. The CR-3 PDEP was issued to the plant on April 1, 2015 as Revision 0 and did not contain any reference to the use or testing of EMnet.

None of the subsequent revisions to the PDEP contained any reference to EMnet. EMnet is no longer used at CR-3 and is not part of the PDEP. A corrected Summary of Changes is included as Enclosure 2 to this letter.

CR-3 confirms that the State of Florida Division of Emergency Management, Radiological Emergency Preparedness Program is in agreement with the current methods of communication, including commercial telephones (landlines) and cellular phones used as back-up communications.

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ENCLOSURE 2 CORRECTED PDEP

SUMMARY

OF CHANGES

U. S. Nuclear Regulatory Commission Page 1 of 2 3F0316-03 Enclosure 2 Summary of Changes DRR 752017 REASON &

PAGE / SECTION CHANGE REFERENCES Cover Sheet Changed Emergency Planning Coordinator Name Update Staffing change to current EPC Throughout Updated Decommissioning Director to new title, SAFSTOR organization General Manager, Decommissioning title change Throughout DTO or Decommissioning Transition Organization DTO is now called the has been replaced with the title SAFSTOR SAFSTOR organization organization Throughout Replaced Plant Manager with Operations and SAFSTOR organization Maintenance Manager title change Throughout Changed Emergency Preparedness Coordinator Correct erroneous title to Emergency Planning Coordinator Table of Contents Updated Section Title and page numbers Format update Table of Contents, Deleted reference to [R3] NOCS 100477, the Commitment page v RERP and EALs Updated to Reflect Information Corresponding to NUMARC/NESP-007, Guidance in NRC Bulletin 2005-02, Attachment 2, Pages 6-7 Page 2-1, Section Changed wording from as applicable to CR3 in its Editorial. Reflects 2.1 permanently shutdown and defueled status to current PDEP with approved exemptions that reflect CR3 in its permanently shutdown and defueled status Page 2-2 Added to the facility description the ISFSI ISFSI added to PDEP facility description Page 4-5, Section Changed DEF acronym from Duke Energy Editorial 4.2 Florida, Inc. to Duke Energy Florida Page 4-3 Added ISFSI definition ISFSI added to PDEP Page 4-5 Removed DTO and added ISFSI DTO transitioned into SAFSTOR. ISFSI is a new facility Page 5-5, step Retitled Citrus County Dispatch Center to be 911 Update title 5.5.4.1 dispatch center Page 6-1, step 6.1 Added management of the ISFSI activities to the ISFSI facility added.

SS/CFH (LAR 318)

Page 6-7, section6.4 Corrected title of Dhiaa Jamil to Executive Vice Update title per Org.

President & President Regulated Generation and Chart Transmission Page 6-4 step Removed communicator position ERO position reduction 6.2.3.1 and re- (LAR 318) numbered

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0316-03 Enclosure 2 Summary of Changes REASON &

PAGE / SECTION CHANGE REFERENCES Page 6-6 step 6.2.5 Re-titled Fire Brigade to Industrial Incipient Fire Update titles Brigade Page 6-7 and Re-titled Vice President to present title of Senior Update titles throughout Vice President of Operations Support Page 6-8, Table 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 6-9, Figure 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 8-1, step 8.1 Added NEI 99-01 Reference for ISFSI EAL ISFSI EAL addition (LAR 318)

Page 8-2, step 8.2 Added ISFSI EAL category ISFSI EAL addition (LAR 318)

Page 9-3, Section Added notification and removed emergency Time of notification is 9.3 incident on the first paragraph, last sentence appropriate in lieu of time of emergency incident Page 10-1, step Replaced Communicator with Emergency Deleted Communicator 10.1 Coordinator as being responsible for ERO position (LAR 318) communications Page 12-3, step Added Portable radiation monitoring instruments Added instrumentation 12.2.1 are maintained to support ISFSI operations available to support including transfer operations of the Dry Shielded ISFSI operations Canister (DSC) to the Horizontal Storage Module (HSM) and for monitoring of the spent fuel while in storage in the HSM Page 15-4, step Removed words is affected Editorial wording 15.3.3 correction Page 18-5, step Replaced EP Supervisor with Emergency SAFSTOR organization 18.4 and throughout Planning Coordinator does not have a EP Supervisor Page 19-1, Section Removed words communications personnel MCR Communicator 19.0 being eliminated (LAR 318)

Page 19-3, step Deleted training reference for MCR Communicator ERO position reduction 19.1.7 (LAR 318)

Page 19-4, Table Deleted training reference for MCR Communicator ERO position reduction 19.1 (LAR 318)

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