L-2012-437, Standardization of Senior Reactor Operator Fuel Handling Duties

Standardization of Senior Reactor Operator Fuel Handling Duties

ML13004A097
Person / Time
Site:	Saint Lucie
Issue date:	12/27/2012
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-437
Download: ML13004A097 (13)

Text

S FPL.

December 27, 2012 L-2012-437 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 St. Lucie Units 1 and 2 Docket Nos 50-335 and 50-389 RE:

License Amendment Request Standardization of Senior Reactor Operator Fuel Handling Duties Pursuant to 10 CFR 50.90, Florida Power & Light (FPL) hereby requests to amend Renewed Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2. These proposed license amendment requests (LARs) align St. Lucie Technical Specifications with Combustion Engineering Owners Group (CEOG) Standard Technical Specification language describing required licensed Senior Reactor Operator (SRO) duties during fuel handling.

Please process this LAR within one (1) year of receipt, and once approved, the amendments will be implemented within 90 days. There are no regulatory commitments being made in this submittal.

These changes have been reviewed by the St. Lucie Plant Onsite Review Group. A copy of this submittal is also being sent to our appointed state official pursuant to 10 CFR 50.91.

If you have any questions or require additional information, please contact Eric Katzman, Licensing Manager, at (772) 467-7734.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on\\December 21'"

, 2012 St. Lucie Plant Enclosure cc:

Ms. Cynthia Becker, Chief-Florida Bureau of Radiation Control Florida Power & Light Company MM kilL 6501 S. Ocean Drive, Jensen Beach, FL 34957

St. Lucie Units 1 and 2 L-2012-437 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 1 of 12 Enclosure Evaluation of the Proposed Changes

Subject:

Standardization of Senior Reactor Operator Fuel Handling Duties

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination 4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. TS (and/or Operating License) Page Markups

2. Retyped TS (and/or Operating License) Pages

St. Lucie Units 1 and 2 L-2012-437 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 2 of 12 1

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Florida Power and Light Company (FPL) requests to amend Renewed Facility Operating License DPR-67 for St. Lucie Unit 1 and NPF-16 for St. Lucie Unit 2. These proposed license amendment requests (LARs) align St. Lucie Technical Specifications with Standard Technical Specification language describing required licensed Senior Reactor Operator (SRO) duties during fuel handling.

The proposed amendments will remove TS 6.2.2.d which specifies licensed SRO duties during fuel handling. TS 6.3.2 will remain as currently written, as it reflects Combustion Engineering Owners Group (CEOG) Standard Technical Specifications verbiage which directly references the requirements in regulation 10 CFR 50.54(m), whereas TS 6.2.2.d uses custom language that is not consistent with the regulation.

2 DETAILED DESCRIPTION The proposed amendments will remove TS 6.2.2.d which uses custom language to enforce the requirements of 10 CFR 50.54(m)(2)(iv). This Technical Specification is redundant to existing TS 6.3.2. TS 6.3.2 expressly cites 10 CFR 50.54(m), which encompasses licensed SRO duties during core alteration including fuel loading and transfer, and reflects CEOG Standard Technical Specifications verbiage. Removal of TS 6.2.2.d will negate duplication and any potential conflict with existing TS 6.3.2, and may preclude the need for future amendment in the event 10 CFR 50.54(m)(2)(iv) is revised. Further, TS 6.2.2.d is not consistent with the regulation in that it mandates licensed SRO oversight of discrete fuel handling operations. The regulation is inclusive of fuel loading and transfer; however, the requirements apply only when these fuel handling operations are ancillary to core alterations.

10 CFR 50.54(m)(2)(iv) describes required licensed SRO duties during core alteration fuel handling operation:

"Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person."

The custom language in TS 6.2.2.d will be removed and replaced by "DELETED":

TS 6.2.2.d "Either-a lieensed SRO eff -icene-ised-SRO limited to -fu-el h-an-dling W-ho has n c.n.u..ent responsibilities dur.ing this ;peration shall be present during fuel handling and shall dir-tl1 y supe-vise all GORE ALTERATIONS."DELETED TS 6.3.2 addresses licensed SRO duties and encompasses fuel handling operations using standard language, and will remain:

W St. Lucie Units 1 and 2 L-2012-437 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 3 of 12 TS 6.3.2 "For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m)."

Amendments No. 210 (Unit 1) and No. 159 (Unit 2) implemented TS 6.3.2. The potential conflict with TS 6.2.2.d was not recognized at that time. It is proposed to delete TS 6.2.2.d, as it is consistent with neither the intent of 10 CFR 50.54(m)(2)(iv) nor Standard Technical Specifications language. TS 6.3.2 will remain as currently written which draws a direct reference to the governing regulation and replicates CEOG Standard Technical Specifications language.

3 TECHNICAL EVALUATION The proposed license changes are administrative in nature. Deletion of TS 6.2.2.d and retention of TS 6.3.2 has no technical implications with respect to the previous evaluation of safety related to core alterations. Regulation 10 CFR 50.54(m)(2)(iv) requires the direct involvement of a licensed SRO only during core alterations and TS 6.3.2 ensures enforcement. The methods for conducting core alterations and other fuel handling operations will remain the same.

Consequently, nuclear safety is maintained.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Common to St. Lucie Units 1 and 2 10 CFR 50.54 10 CFR 50.54, Conditions of Licenses, is applicable to St. Lucie Units 1 and 2, and establishes the staffing requirements for and duties of licensed operators. 10 CFR 50.54(m)(2)(iv) specifically addresses the direct involvement of a person holding a senior reactor license or license limited to fuel handling during core alteration.

The proposed changes to the TSs are not contrary to the cited regulatory criterion; rather, the requirements are enforced by drawing a direct reference to the regulation within the Technical Specification's language. Further, the Technical Specification that will remain reflects the language of the CEOG Standard Technical Specifications, which has previously been approved by the Nuclear Regulatory Commission. As such, the ability to comply with the regulatory criterion is enhanced by the changes.

St. Lucie Units 1 and 2 L-2012-437 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 4 of 12 4.2 No Significant Hazards Consideration Determination FPL is requesting approval of changes to St. Lucie Unit 1 and Unit 2 Technical Specifications relating to licensed SRO staffing during the core alteration fuel handling operation. The standards used to arrive at a determination that a request for amendment involves a no significant hazards consideration are included in the Commission's regulation, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the amendment would not result in either of the following consequences:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated (3)

Involve a significant reduction in a margin of safety As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below.

(1)

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed changes will not result in any significant increase in the probability or consequences of an accident previously evaluated, as the proposed TS changes are consistent with Standard Technical Specifications. Further, not requiring licensed SRO oversight of fuel handling operations other than core alterations does not introduce additional risk or a greater potential for consequences of an accident that has not previously been evaluated.

(2)

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

No. The proposed changes are administrative in nature and do not involve a physical modification of the plant. No new or different type of equipment will be installed. The methods for conducting core alterations and other fuel handling operations will remain the same. The proposed changes will not introduce new failure modes/effects that could lead to an accident for which consequences exceed that of accidents previously analyzed.

Therefore, the proposed changes do not create the possibility of a.new or different kind of accident from any accident previously evaluated.

(3)

Does the proposed change involve a significant reduction in a margin of safety?

No. The proposed changes will not involve a significant reduction in a margin of safety in that the changes are administrative in nature. No plant equipment or accident analyses will be affected. Additionally, the proposed changes will not relax any criteria used to establish safety limits, safety system settings, or the bases for any limiting conditions for

St. Lucie Units 1 and 2 L-2012-437 Docket Nos. 50-335 and 50-389 Enclosure License Amendment Request Page 5 of 12 operation. Safety analysis acceptance criteria are not affected. Plant operation will continue within the design basis. The proposed changes do not adversely affect systems that respond to safely shutdown the plant and maintain the plant in a safe shutdown condition. Consequently, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, it is concluded that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

5 ENVIRONMENTAL CONSIDERATION The proposed amendments concern administrative changes relating to the required oversight for fuel handling operations and have been evaluated as not involving a significant hazards consideration. Consequently, the proposed amendments satisfy categorical exclusion criterion 10 CFR 51.22(c)(10)(ii): changes to recordkeeping, reporting, or administrative procedures or requirements. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

6 REFERENCES

1. St. Lucie Unit 1 Technical Specifications

2. St. Lucie Unit 2 Technical Specifications

3. NUREG-1432 (Standard Technical Specifications for Combustion Engineering Plants), Volume 1, Revision 4.0

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 6 of 12 TS Markups Unit 1 Page 6-2 Unit 2 Page 6-2

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 7 of 12 The attached markups reflect the current revision of the Facility Operating Licenses. At the time of submittal, the Facility Operating Licenses were revised through Amendment No. 199 for Unit 1 and Amendment No. i 56 for Unit 2.

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 8 of 12 6.0 ADMINISTRATIVE CONTROLS 6.2 ORGANIZATION (continued)

UNIT STAFF 6.2.2 The unit organization shall be subject to the following:

a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b.

Deleted.

c.

A health physics technician# shall be on site when fuel is in the reactor.

d.

Eihr a Qiconsod SRO or lic-sedR.O0 limitd to fu Al ha,,i....-W 1426 kRA cpibltocdrigtiA.orto Ah-l 6k; preSont duigfuel handlin. and shall d.........

• ,,:ic:

all CORE A^TERATIONS.

e.

Deleted.

1. The health physics technician may be less than the minimum requirement for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

ST. LUCIE - UNIT 1 6-2 Amendment No. 40, 26, 55, 69,.93,445,446,477,400

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 9 of 12 6.0 ADMINISTRATIVE CONTROLS 6.2 ORGANIZATION (Continued)

UNIT STAFF 6.2.2 The unit organization shall be subject to the following:

a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b.

DELETED

c.

A health physics technician# shall be on site when fuel is in the reactor.

d. EitlieF a Iieef scd SRO Or llcensed SRO limited toe fuo-l handling who has no

.O..U.nt re. po.i.....l d.rig this operation shall be present durng. ul kll;d.if§-e a1shall dircctly,uper-As; all CORE AL-E ATIERGNS

e.

DELETED

f.

DELETED

g.

The operations supervisor shall hold a Senior Reactor Operator License.

1. The health physics technician may be less than the minimum requirement for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

ST. LUCIE - UNIT 2 6-2 Amendment No. 29, 55, 65, 03, 428, 446,466

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 10 of 12 Word Processed TS Unit 1 Page 6-2 Unit 2 Page 6-2

St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 11 of 12 6.0 ADMINISTRATIVE CONTROLS 6.2 ORGANIZATION (continued)

UNIT STAFF 6.2.2 The unit organization shall be subject to the following:

a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b.

Deleted.

c.

A health physics technician# shall be on site when fuel is in the reactor.

d.

Deleted.

e.

Deleted.

The health physics technician may be less than the minimum requirement for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

ST. LUCIE - UNIT 1 6-2 Amendment No. 40, 25, 55, 69, 3, 445,44-1, 4,4,499

9 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 License Amendment Request L-2012-437 Enclosure Page 12 of 12 6.0 ADMINISTRATIVE CONTROLS 6.2 ORGANIZATION (Continued)

UNIT STAFF 6.2.2 The unit organization shall be subject to the following:

a.

Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.

b.

DELETED

c.

A health physics technician# shall be on site when fuel is in the reactor.

d.

DELETED I

e.

DELETED

f.

DELETED

g.

The operations supervisor shall hold a Senior Reactor Operator License.

1. The health physics technician may be less than the minimum requirement for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence, provided immediate action is taken to fill the required positions.

ST. LUCIE - UNIT 2 6-2 Amendment No. 2-9, 65, 65, 93,428, 1446,466