ML13198A142
| ML13198A142 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/17/2013 |
| From: | Gratton C Plant Licensing Branch II |
| To: | Westcott D Duke Energy Progress |
| References | |
| TAC MF1504 | |
| Download: ML13198A142 (6) | |
Text
1 NRR-PMDAPEm Resource From:
Gratton, Christopher Sent:
Wednesday, July 17, 2013 8:03 AM To:
Westcott, Daniel (Daniel.Westcott@duke-energy.com)
Subject:
Draft RAI - Request to amend Section 5.0 of the CR-3 Technical Specifications (MF1504)
Mr. Westcott, By letter dated April 25, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A286), Florida Power Corporation (FPC, or the licensee) submitted a license amendment request regarding Crystal River Nuclear Plant Unit 3 (CR-3) Facility Operating License. The proposed amendment would revise the administrative controls section of technical specifications for permanently defueled conditions.
The Nuclear Regulatory Commission (NRC) staff has performed a preliminary review of the request and found that some further information is needed to complete the staffs review. The staffs information request is included below.
The NRC considers that timely responses to request for additional information (RAIs) help ensure sufficient time is available for the NRC staff review and contribute toward the NRCs goal of efficient and effective use of staff resources.
Please provide your response by September 6, 2013.
You may request to discuss the contents of this RAI with the NRC staff in a conference call, including any change to the proposed schedule.
Please dont hesitate to contact me if you have any questions or concerns.
Sincerely, Christopher Gratton Sr. Project Manager PM Crystal River Nuclear Generating Plant PM Brunswick Steam Electric Plant NRR/DORL/LPL 2-2 301-415-1055 Mail Stop O-8G9a Christopher.Gratton@nrc.gov REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION CRYSTAL RIVER NUCLEAR PLANT UNIT 3 DOCKET NO. 50-302 TAC MF1504 Basis for the Request TS-1
2 FPC stated in its application that the proposed change to TS 5.1.1 is based on defining the responsible position for overall unit operation and for approval of each proposed test, experiment or modification to systems or equipment that affect stored nuclear fuel, and the position scope is changing from the effect on nuclear safety to the effect on stored nuclear fuel.
RAI TS-1 The proposed change to TS 5.1.1 changes the title of Plant General Manager to Plant Manager; however there is no proposed change that addresses stored nuclear fuel instead of nuclear safety. In addition, TS 5.1.1 states that the manager is responsible for overall unit operation, however pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82(a)(2), the operating license for CR-3 no longer authorizes operation of the reactor. Please provide a basis that addresses these differences.
Basis for the Request TS-2 FPC proposes to replace TS 5.2.2.a with a new crew complement for the duty shift, and states that the new crew complement reflects the reduced demand on the operating crew to maintain the safety of fuel stored in the fuel pools.
RAI TS-2 FPC stated that as of May 28, 2011, all the fuel from the reactor has been placed into storage in the spent fuel pools. The NRC staff does not agree with FPC's statement that there is a reduced demand to maintain the safety of the fuel stored in the fuel pools. Please explain why FPC believes there is a reduced demand to maintain the safety of the fuel stored in the fuel pools.
3 Basis for the Request TS-3 FPC proposes to delete paragraph d of TS 5.2.2 which states:
An individual qualified in Radiation Protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
FPC states that this paragraph is being deleted because there is an expanded response time available for radiation protection staff, in the event of a loss of cooling or inventory in the spent fuel pools, as compared to power operation considering the stored fuel exposure history.
RAI TS-3 By deleting current paragraph d of TS 5.2.2, CR-3 is allowed to perform fuel handling operations and movement of loads over storage racks containing fuel without a radiation protection staff being on site. FPCs basis for deleting this paragraph does not discuss fuel handling operations or movement of loads over storage racks containing fuel, nor does it discuss any accidents and/or events that might occur during these evolutions. The NRC staff does not agree that fuel movements or movement of loads over storage racks containing fuel should be allowed without on-site radiation protection staff support being available. Please provide a technical basis for not needing a radiation protection staff on site during fuel handling operations and movement of loads over storage racks containing fuel.
Basis for the Request TS-4 FPC is proposing to delete the reference to 10 CFR 50.54(m)(2)(i) in paragraph b of TS 5.2.2 below:
Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a 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 of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
RAI TS-4 Paragraph b of TS 5.2.2 allows during such absences of the shift crew composition that fuel movement and/or movement of loads over fuel are permitted and permits a shift crew position to be unmanned during shift change due to lateness or absence of the oncoming member. The NRC staff does not agree that fuel movements, movement of loads over fuel, and unmanned shift positions during shift turnover should be permitted while the shift crew is less than the minimum. Please provide a technical basis for allowing the fuel movements, movement of loads over fuel, and unmanned shift positions during shift turnover when the shift crew is less than the minimum.
Basis for the Request TS-5 On February 24, 2012, the NRCs Office of Enforcement released Enforcement Guidance Memorandum (EGM) 12-001 (ADAMS Accession No. ML11258A243), Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests. The EGM explains that the restructuring of TS chapters during the development of improved standard TS (STSs) resulted in unintended consequences when Section 3.0, Surveillance Requirement Applicability provisions were made applicable to Section 5.0 TSs. Specifically, applying STS rules of usage would prohibit licensees from using the Surveillance Requirements (SRs) 3.0.2 and 3.0.3 allowances contained in Section 5.0 TSs. Applying the guidance in the memorandum will ensure SR 3.0.2 or SR 3.0.3, or both, are made available for TS programs and will properly apply 10 CFR 50.36 requirements for tests associated with inservice test activities under 10 CFR 50.55a(f).
4 During the staffs review of CR-3 TSs, it was noticed that TS 5.6.2.9.c and TS 5.6.2.9.d state that the provisions of SR 3.0.2 and SR 3.0.3 are applicable to inservice testing activities. This is not an accurate statement. SR 3.0.2 and SR 3.0.3 only apply to SRs listed in TSs. SR 3.0.2 and SR 3.0.3 does not apply to inservice test activities under 10 CFR 50.55a(f) that are not listed in TS. CR-3 TS Section 1.0, Use and Application, and Section 3.0, Surveillance Requirement (SR) Applicability, explains how SR 3.0.2 and SR 3.0.3 are applied to SRs in TSs.
In addition, CR-3 TS 5.6.2.9.e states, Nothing in the ASME OM Code [ASME Code for Operation and Maintenance of Nuclear Power Plants] shall be construed to supersede the requirements of any TS. This statement is contrary to 10 CFR 50.55a(f)(5)(i), which states that the inservice test program for a boiling or pressurized water-cooled nuclear power facility must be revised by the licensee, as necessary, to meet the requirements of paragraph (f)(4) of this section. In other words, if there is a conflict between the 10 CFR 50.55a regulation and TSs, then the regulation should be followed and the TS should be changed to comply with the regulation.
RAI TS-5 CR-3 TS 5.6.2.9 paragraph c, d, and e are in conflict with10 CFR 50.55a(f) and FPC has not proposed any changes to TS 5.6.2.9, Inservice Testing Program, so that TS 5.6.2.9 will comply with 10 CFR 50.55a(f).
Please provide changes to TS 5.6.2.9 so that it no longer conflicts with 10 CFR 50.55a(f).
Basis for the Request TS-6 CR-3 TS 3.3.17, Post Accident Monitoring (PAM) Instrumentation required actions B.1 and F.1 require taking action in accordance with TS 5.7.2.a.
RAI TS-6 FPC is proposing to delete TS 5.7.2.a. However, FPC has not proposed any changes to TS 3.3.17 Required Actions B.1 and F.1 in this application and TS 3.3.17 required actions B.1 and F.1 require taking action in accordance with TS 5.7.2.a.
Please remove the proposed change to TS 5.7.2.a, or provide changes that address TS 5.7.2.a in TS 3.3.17 required actions B.1 and F.1.
RAI AHPB-1 Prior to their performance, who approves heavy load moves that could affect the safe handling and storage of nuclear fuel? Is this person a Certified Fuel Handler?
RAI AHPB-2 Can any control actions that could affect the safe handling and storage of nuclear fuel be taken from the control room?
RAI AHPB-3 Will the control room remain the center of the command function? If not, where will the alternate command center be located?
RAI AHPB-4 Will procedures, drawings and instructions continue to be controlled in accordance with 10 CFR, Part 50, Appendix B, Criterion VI, Document Control, requirements?
5 RAI AHPB-5 Describe how a fuel-handling accident with serious injuries would be identified and mitigated. Focus on the alarms, displays, and other cues that would allow identification of the problem, how the chain of command would communicate, time constraints, and reporting responsibilities.
RAI AHPB-6 Confirm that no one in the chain-of-command above the Shift Supervisor is required to be a Certified Fuel Handler or to attend equivalent training.
RAI AHPB-7 How many people in the organization will be Certified Fuel Handlers?
RAI AHPB-8 Clarify if any current Radiation Protection procedures will be impacted as a result of this amendment request.
RAI AHPB-9 Confirm that the Explosive Gas and Storage Tank will remain operable until all radioactive gas is eliminated from the site
Hearing Identifier:
NRR_PMDA Email Number:
765 Mail Envelope Properties (Christopher.Gratton@nrc.gov20130717080200)
Subject:
Draft RAI - Request to amend Section 5.0 of the CR-3 Technical Specifications (MF1504)
Sent Date:
7/17/2013 8:02:36 AM Received Date:
7/17/2013 8:02:00 AM From:
Gratton, Christopher Created By:
Christopher.Gratton@nrc.gov Recipients:
"Westcott, Daniel (Daniel.Westcott@duke-energy.com)" <Daniel.Westcott@duke-energy.com>
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