ML102280010

Nuclear Generating Plant - Draft RAIs Regarding Crystal River Unit 3 Part 26 Exemption Request

ML102280010
Person / Time
Site:	Crystal River
Issue date:	08/11/2010
From:	Jason Paige Plant Licensing Branch II
To:	Westcott D Progress Energy Florida
paige, Jason, NRR/DORL,301-415-5888
References
Download: ML102280010 (2)

Text

From: Paige, Jason Sent: Wednesday, August 11, 2010 12:22 PM To: Westcott, Daniel

Subject:

Draft RAIs RE Crystal River, Unit 3 Part 26 Exemption Request By letter dated July 13, 2010 (Agencywide Document and Management System (ADAMS)

Accession No. ML102000019) and pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 26.9, Florida Power Corporation (FPC, the licensee) requested a one-time exemption to permit Crystal River, Unit 3 to not meet portions of 10 CFR 26.205(d)(3). Crystal River, Unit 3 has been in an extended outage. The proposed exemption would allow use of the less restrictive minimum day off (MDO) requirements of 10 CFR 26.205(d)(4) during the unit restart. Steam generators were replaced in the current outage. The exemption request indicates that the workload for covered personnel will undergo a temporary increase due to evolutions concerned with the steam generator replacements and other modifications that are in addition to normal unit startup activities.

The U.S. Nuclear Regulatory Commission performed a preliminary review of the exemption request. The licensees responses to the following request for additional information will allow the staff to complete its review in a timely manner.

1. The description of the proposed exemption in Sections 2.0 and 3.0 of the exemption request both mention that Crystal River will ensure that covered personnel 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. Describe how working, on average, a 54-hour week reflects fatigue management practices.

2. Section 5.0 of the exemption request states that no waivers have been issued to individuals who are part of this exemption request. Without discussing work hour controls, describe any other evidence of managing fatigue at CR-3 during the current unit outage.

3. The exemption requests a 60-day period of exemption from the normal minimum day off requirements in deference to the outage minimum day off requirements. Why is a 60-day period needed to start-up.

4. 10 CFR Part 26.205(d)(4) states that licensees need not meet the operating MDO requirements for individuals who are working on outage activities. The exemption request does not limit the request to individuals working on outage activities, explain the rational to broaden the scope of the MDO outage relaxation for this exemption request.

Review the above draft RAIs and determine if a call is needed to discuss. If a call is not needed, notify me and I will proceed with formally issuing the RAIs.

Thanks, Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888

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Subject:

Draft RAIs RE Crystal River, Unit 3 Part 26 Exemption Request Sent Date: 8/11/2010 12:12:23 PM Received Date: 8/11/2010 12:22:00 PM From: Paige, Jason Created By: Jason.Paige@nrc.gov Recipients:

Daniel.Westcott@pgnmail.com (Westcott, Daniel)

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Files Size Date & Time MESSAGE 10202 8/11/2010 Options Expiration Date:

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