3F0303-02, Request for Exemption from Certain NRC Requirements of 10 CFR 55.59

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Request for Exemption from Certain NRC Requirements of 10 CFR 55.59
ML030760013
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/06/2003
From: Franke J
Progress Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0303-02
Download: ML030760013 (4)


Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 55.11 10 CFR 55.59 March 6, 2003 3F0303-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Request for Exemption from Certain Requirements of 10 CFR 55.59

Dear Sir:

Pursuant to 10 CFR 55.11, Progress Energy Florida, Inc. hereby requests an exemption to 10 CFR 55.59(c)(1) in that the current licensed operator requalification program period for Crystal River - Unit 3 (CR-3) be extended, on a one-time basis, from 24 to 26 months, ending February 28,2005.

The current annual operating test and comprehensive biennial written examination encompass the 24-month requalification cycle from January 1, 2003 through December 31, 2004. This request would allow the current 12-month operating test period to be extended to 14 months (ending February 28, 2004) and would extend the 24-month requalification period to 26 months (ending February 28, 2005). The second annual operating tests and the biennial written examinations would then be completed by February 28, 2005. The next requalification program period would begin on March 1, 2005 and continue for 24 months to February 28, 2007 with successive periods similarly adjusted.

This exemption is being requested at this time based on the successful completion of the recent two-year requalification cycle. A strong level of knowledge and skills in the recent end-of-cycle examinations was demonstrated by CR-3 licensed operators. This along with the successful INPO re-accreditation of the Operator Programs support this two month extension request.

This new examination period would have a reduced impact on CR-3 organizations. The overriding reasons to pursue this extension are based on scheduling difficulties associated with an end-of-the-year requalification program cycle.

CR-3 would like approval of this exemption request by May 31, 2003, so as to make orderly plans to adopt the one-time 14-month operating test and 26-month written examination schedules.

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428

U.S. Nuclear Regulatory Commission Page 2 of 2 3F0303-02 As explained in the Attachment to this letter, this exemption is authorized by law, will not endanger life or property, and is otherwise in the public interest.

This letter establishes no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Sid Powell, Supervisor, Licensing and Regulatory Programs at (352) 563-4883.

Sincerely, J. A. Franke Plant General Manager JAF/rmb

Attachment:

Description and Analysis of Request for Exemption from Certain Requirements of 10 CFR 55.59 xc: NRR Project Manager Regional Administrator, Region II Senior Resident Inspector

U.S. Nuclear Regulatory Commission Attachment 3F0303-02 Page 1 of 2 Description and Analysis of Request for Exemption from Certain Requirements of 10 CFR 55.59 A. Requested Exemption and Circumstances Leading to the Request In accordance with 10 CFR 55.11, "Specific exemptions," Progress Energy Florida, Inc. is requesting NRC approval of an exemption from the requirements of 10 CFR 55.59, "Requalification," paragraph (c)(1) for the requalification program schedule at Crystal River Unit 3 (CR-3). The requested exemption would allow for a one-time extension of:

the annual operating test required in paragraph (a)(2) from the 12-month interval to an interval of 14 months; and the comprehensive requalification written examinations required in paragraph (a)(2) from the 24-month interval to an interval of 26 months.

This exemption is being requested at this time based on the successful completion of the recent two-year requalification cycle. A strong level of knowledge and skills in the recent end-of-cycle examinations was demonstrated by CR-3 licensed operators. This along with the successful INPO re-accreditation of the Operator Programs support this two month extension request.

This new examination period would have the least impact on CR-3 organizations. The overriding reasons to pursue this extension are based on scheduling difficulties associated with an end-of-the-year requalification program cycle. Moving Operator annual and biennial exams from the November - December time frame to a January - February time frame would support the following benefits:

- Minimize the Fall refueling outage impact on exam development;

- Minimize the potential impact from any Fall refueling outage extensions;

- Minimize the scheduling and resource impact from both the Thanksgiving and Christmas holidays;

- Minimize the potential scheduling and resource impact of any exam remediation or retesting requirements during the holidays;

- Minimize the potential impact from future bargaining unit negotiations which occur periodically in the fourth calendar quarter.

CR-3 would like approval of this exemption request by May 31, 2003, so as to make orderly plans to adopt the one-time 14-month operating test and 26-month written examination schedules.

B. Basis for Exemption Request The criteria for granting specific exemptions from 10 CFR 55 regulations are stated in 10 CFR 55.11. In accordance with 10 CFR 55.11, the NRC is authorized to grant an exemption upon determining that the exemption is authorized by law and will not endanger life or property and is otherwise in the public interest.

U.S. Nuclear Regulatory Commission Attachment 3F0303-02 Page 2 of 2 As explained below, the requested exemption will not endanger life or property and is otherwise in the public interest.

All CR-3 licensed personnel are actively enrolled in the National Academy for Nuclear Training accredited training programs. The Requalification Operations Training programs all received accreditation renewals in August 2002. The Reactor Operator (RO), Senior Reactor Operator (SRO), and Shift Technical Advisor programs include both periodic written and operational exams throughout the 24-month training cycles. All of the CR-3 licensed ROs and SROs have completed both their annual operating tests and their biennial written examinations for the cycle ending December 31, 2002.

C. Environmental Assessment In accordance with 10 CFR 51.30, "Environmental assessment," and 10 CFR 51.32, "Finding of no significant impact," the following information is provided in support of an environmental assessment and finding of no significant impact for the proposed action.

The proposed action would grant an exemption from the requirements of 10 CFR 55.59(c)(1).

The requested exemption would allow for a one-time extension of the annual operating test required in paragraph (a)(2) from the 12-month interval to an interval of 14 months and the comprehensive requalification written examinations from the 24-month interval to an interval of 26 months.

The proposed action (i.e., granting the exemption) will not increase the probability or consequences of accidents, no changes are being made in the types or quantities of any radiological effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

The proposed action does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed action.

The environmental impacts of the proposed action and the alternative action are similar. Based on the assessment above, the proposed action will not have a significant effect on the environment.