ML100670537

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Proficiency Watches During Extended Shutdown
ML100670537
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/08/2010
From: Widmann M
NRC/RGN-II/DRS/OLB
To: Franke J
Progress Energy Carolinas
References
Download: ML100670537 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 March 8, 2010 Mr. Jon A. Franke Vice President, Crystal River Nuclear Plant Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT - PROFICIENCY WATCHES DURING EXTENDED SHUTDOWN

Dear Mr. Franke:

The purpose of this letter is to document a review of licensed operator proficiency watch credit while the reactor is defueled and the unit is in an extended shutdown. On February 10, 2010, NRC was made aware that the original 90 day outage planned was changed to an extended shutdown for approximately eight months to repair the containment building. An earlier review of the acceptability of proficiency watches for four technical specification positions, Shift Manager, Control Room Supervisor, Reactor Operator and Balance of Plant Operator, was determined to meet the current regulatory standards.

Discussion:

The NRC staff reviewed watch-standing hours (i.e., proficiency watches) during no-mode (all fuel in the spent fuel pool) to determine if operators could be credited for meeting the requirements of 10 CFR 55.53(e). 10 CFR 55.53 (e) states in part:

If a licensee has not been actively performing the functions of an operator [RO] or senior operator [SRO], the licensee may not resume activities authorized by a license issued under this part except as permitted by paragraph (f) of this section [i.e., qualifications are current and valid; and that the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift function]. To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter.

As delineated in NUREG-1021, ES-605 C.2(b), and in accordance with 10 CFR 55.4, "actively performing the functions of an operator or senior operator" means that an individual has a position on a shift crew that requires an individual to be licensed as defined in the facility's technical specifications. Watch-standing proficiency credit may also be appropriate for certain licensed RO or SRO crew positions that are in excess of those required by a facility's technical specifications. However, in order to credit watch-standing proficiency for such excess positions, the facility licensee shall have in place the following procedural administrative controls:

(1) A list of all the licensed shift crew positions, including title, description of duties, and indication of which positions are required by technical specifications.

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(2) For shift crew positions in excess of those required by technical specifications, a description of how the position is meaningfully and fully engaged in the functions and duties of the analogous minimum licensed position(s) required by technical specifications If a facility cannot justify, as explained above, crediting watch-standing proficiency for shift crew positions in excess of technical specifications, or does not implement administrative controls as described above, then an individual who stands watch in an excess position shall not receive proficiency credit.

Crystal River Improved Technical Specification Paragraph 5.2.2.2.14 states that:

The following nuclear licensed positions are considered to be actively performing licensed duties and meet the requirement 10 CFR55.53 (e).

Shift Manager (SM)

Control Room Supervisor (CRS)

Chief Nuclear Operator (Control Room)

Nuclear Operator (Control Room)

Based on discussion with the Crystal River Technical Training Management, a basis was provided as to how the individuals serving in an excess crew position are meaningfully and fully engaged in the functions of a licensed RO/SRO. Your staff indicated that the positions manned by Crystal River Operations in all modes are the same as when at power. Whether or not fuel is in the reactor vessel or being cooled in the spent fuel pool the reactor operators and senior reactor operators are still responsible and performing license duties. The meaningfulness related to the additional reactor operator and senior reactor operator above what is required by Technical Specifications is to perform normal crew responsibilities while shutdown. The Shift Manager is still the senior licensed person with the same degree of responsibility as when on shift and will routinely relieve the Control Room Supervisors. The Balance of Plant Reactor Operator has the same degree of responsibility in No Mode as when at power, routinely relieving the Operator at the Controls and performing reactor operator duties.

Additional information was provided to the NRC staff regarding requalification and Just-In-Time (JIT) training. Requalification training will be ongoing throughout the duration of the extended shutdown. The JIT activities include: Placing decay heat removal in service; reactor physics testing; and generator air test using steam from Units 1 and 2. Other JIT training scheduled to be completed prior to restart of the unit include: Transition from decay heat removal cooling to Once-Through-Steam-Generators (OTSG) cooling in support of plant heat-up; reactor startup (including approach to criticality), critical data, reactor physics testing and ascension to the point of adding heat; plant startup including turbine synchronization; and raising unit load. The combination of requalification and JIT training will ensure that the operators are proficient before standing watch during the reactor startup and power ascension.

Summary:

The NRC has determined that the activities associated with the proficiency watches are consistent with guidance of NUREG-1021, ES-605 C.2(b) and meet the requirements of 10 CFR 55.53(e) for actively performing the functions of an operator or senior operator. Therefore, the NRC has determined that credit for the proficiency watches for the four positions (i.e., Shift

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Manager, Control Room Supervisor, Reactor Operator and Balance of Plant Operator) during the extended shutdown is acceptable.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Malcolm T. Widmann, Chief Operations Branch Division of Reactor Safety Docket No.: 50-302 License No.: DPR-72

Enclosure:

None.

cc w/encl.: (See page 4)

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Manager, Control Room Supervisor, Reactor Operator and Balance of Plant Operator) during the extended shutdown is acceptable.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Malcolm T. Widmann, Chief Operations Branch Division of Reactor Safety Docket No.: 50-302 License No.: DPR-72

Enclosure:

None.

cc w/encl.: (See page 5)

X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE X NON-SENSITIVE ADAMS: G Yes ACCESSION NUMBER:_________________________

X SUNSI REVIEW COMPLETE MTW OFFICE RII:DRS RII:DRP SIGNATURE MTW /RA/

MDS /RA/

NAME MWidmann MSykes DATE 03/08/2010 03/08/2010 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:

G:\\DRSII\\OBII\\SITES\\CRYSTAL RIVER\\GENERAL CORRESPONDENCE\\CR3 PROFICIENCY WATCHES EXTENDED OUTAGE 2010 REV1.DOC

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cc w/encl:

R. J. Duncan, II Vice President Nuclear Operations Carolina Power & Light Company Electronic Mail Distribution Brian C. McCabe Manager, Nuclear Regulatory Affairs Progress Energy Carolinas, Inc.

Electronic Mail Distribution James W. Holt Plant General Manager Crystal River Nuclear Plant (NA2C)

Electronic Mail Distribution Stephen J. Cahill Engineering Manager Crystal River Nuclear Plant (NA2C)

Electronic Mail Distribution R. Alexander Glenn Associate General Counsel (MAC - BT15A)

Florida Power Corporation Electronic Mail Distribution Christos Kamilaris Director Fleet Support Services Carolina Power & Light Company Electronic Mail Distribution William A. Passetti Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution Daniel R. Westcott Supervisor Licensing & Regulatory Programs Crystal River Nuclear Plant (NA1B)

Electronic Mail Distribution Phyllis Dixon, Training Manager Crystal River Nuclear Plant Electronic Mail Distribution Joseph W. Donahue Vice President Nuclear Oversight Carolina Power and Light Company Electronic Mail Distribution Jack E. Huegel Manager, Nuclear Oversight Crystal River Nuclear Plant Electronic Mail Distribution David T. Conley Associate General Counsel Legal Dept.

Progress Energy Service Company, LLC Electronic Mail Distribution Mark Rigsby Manager, Support Services - Nuclear Crystal River Nuclear Plant (NA2C)

Electronic Mail Distribution Attorney General Department of Legal Affairs The Capitol PL-01 Tallahassee, FL 32399-1050 Ruben D. Almaguer Director Division of Emergency Preparedness Department of Community Affairs Electronic Mail Distribution Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness, FL 36250

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Letter to Jon A. Franke from Malcolm T. Widmann dated March 8, 2010.

SUBJECT:

CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT - PROFICIENCY WATCHES DURING EXTENDED SHUTDOWN Distribution w/encl:

K. Kennedy, DRS L. Wert, DRP C. Christensen, DRS J. Munday, DRP M. Widmann, DRS M. Sykes, DRP T. Morrissey, DRP R. Aiello, DRS J. McHale, NRR/DIRS/IOLB F. Saba, NRR OEMAIL C. Evans, EICS RIDSNRRDIRS RidsNrrPMCrystal River Resource PUBLIC