Text

License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition
	ML19109A031
Person / Time
Site:	Duane Arnold
Issue date:	04/19/2019
From:	Dean Curtland; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2019-050, NG-19-0021
	Download: ML19109A031 (51)
	v • d • e

April 19, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 NEXTeraM ENERGY~

DUANE ARNOLD NG-19-0021 L-2019-050 10 CFR 50.90 License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold, LLC (NEDA) is submitting a request for an amendment to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC). The proposed changes will revise TS 1.1, "Definitions," and TS 5.0, "ADMINISTRATIVE CONTROLS."

By letter dated January 18, 2019 (Accession No. ML19023A196), NEDA provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.82(a)(1 )(i) and 10 CFR 50.4(b)(8) of the intention to permanently cease power operations at the DAEC in the fourth quarter of 2020.

After the certifications of permanent cessation of power operation and of permanent removal of fuel from the DAEC reactor vessel are docketed, in accordance with 10 CFR 50.82(a)(1)(i) and (ii) respectively, and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, certain TS staffing and administrative controls may be revised or removed to reflect the permanently defueled condition. This proposed amendment supports implementation of the Certified Fuel Handler training program that was submitted to the NRC for approval by letter dated January 29, 2019 (ML19037A016).

The Enclosure to this letter provides NEDA's evaluation of the proposed change. to the enclosure provides markups of the TS showing the proposed changes, and Attachment 2 provides the clean TS pages containing the proposed TS changes. There are no impacts to the TS Bases associated with this change.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-19-0021 Page 2 of 2 NEDA requests approval of the proposed license amendment by July 1, 2020. NEDA requests that the approved amendment become effective following NRC approval of the Certified Fuel Handling training program (ML19037A016) and following submittal of the required 10 CFR 50.82(a)(1)(ii) certification that DAEC has been permanently defueled.

In accordance with 10 CFR 50.91, a copy of this application with enclosure is being provided to the designated State of Iowa official.

As discussed in the Enclosure, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. The DAEC Onsite Review Group has reviewed the proposed license amendment.

This letter contains no new or revised regulatory commitments.

If you have any questions or require additional information, please contact Michael Davis, Licensing Manager, at 319-851-7032.

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

Executed on April 19, 2019 SkUfl Dean Curtland Site Director NextEra Energy Duane Arnold, LLC Enclosure cc:

Regional Administrator, USNRC, Region Ill, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)

Enclosure NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER NG-19-0021 LICENSE AMENDMENT REQUEST (TSCR-181)

DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 2 of 26 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition EVALUATION OF PROPOSED CHANGE 1.0 Summary Description 2.0 Detailed Description 2.1 Description of LHGR 2.2 Current TS Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions 5.0 Environmental Considerations 6.0 References - Proposed Technical Specification Changes (Mark-Up) - Revised Technical Specification Pages (Clean, with Proposed Changes)

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 3 of 26 1.0

SUMMARY

DESCRIPTION NextEra Energy Duane Arnold, LLC (NEDA) requests an amendment to the Duane Arnold Energy Center (DAEC) Technical Specifications (TS). The proposed changes will revise the DAEC TS Section 1.1, "Definitions," and Section 5.0, "ADMINISTRATIVE CONTROLS."

By letter dated January 18, 2019 (Reference 1 ), NEDA provided formal notification to the U.S. Nuclear Regulatory Commission (NRG) pursuant to 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8) of the intention to permanently cease power operations at the DAEC in the fourth quarter of 2020.

After the certifications of permanent cessation of power operation and of permanent removal of fuel from the DAEC reactor vessel are docketed, in accordance with 10 CFR 50.82(a)(1)(i) and (ii) respectively, and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, certain TS staffing and administrative controls may be revised or removed to reflect the permanently defueled condition.

Additionally, by letter January 29, 2019 (Reference 2), NEDA submitted a Certified Fuel Handler training program for NRG approval. This proposed LAR will support implementation of this program once approved, since licensed reactor operators will no longer be required to support plant operations. The need for licensed reactor operators is specified in Section 5.0 of the current TS.

The proposed changes would not become effective until the NRG has approved the DAEC Certified Fuel Handler training program and the submittal of the required 10 CFR 50.82(a)(1)(ii) certification that DAEC has been permanently defueled.

2.0 DETAILED DESCRIPTION The proposed change is requested as a result of NEDA's formally-stated intention to permanently cease power operation at DAEC in the fourth quarter of 2020 and to transfer all fuel in the reactor to the Spent Fuel Pool (SFP) soon thereafter. With the reactor in a permanently defueled condition, there will be no need to maintain the operating staffing requirements. The proposed amendment would, therefore, modify the TS to make administrative changes and reflect decommissioning staffing requirements.

A change to Section 1.1 "Definitions," will be revised to add the following definitions:

Certified Fuel Handler (CFH) - A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of Technical Specification 5.3.1.; and

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 4 of 26 Non-Certified Operator (NCO) - A NON-CERTIFIED OPERA TOR is an individual who complies with the provisions of the Non-Certified Operator training program required by Technical Specification 5.3.2.

Changes to Section 5.0, "ADMINISTRATIVE CONTROLS" are presented below.

Current TS Proposed TS 5.1.1 The plant manager shall be 5.1.1 The plant manager shall be responsible for overall unit operation responsible for overall oo-it--facility and shall designate in writing the operation and shall designate in succession to this responsibility writing the succession to this during his absence.

responsibility during his absence.

The plant manager or his designee The plant manager or his designee shall approve, prior to shall approve, prior to implementation, each proposed test, implementation, each proposed experiment or modification to test, experiment or modification to systems or equipment that affects systems or equipment that affects nuclear safety.

nuclear safety safe storage and maintenance of spent nuclear fuel.

5.1.2 The Operations Shift Manager shall 5.1.2 The Operations Shift Manager shall be responsible for the control room be responsible for the control command function. During any

-reemshift command function.

absence of the Operations Shift gurin§I any aesence of tl=le Manager from the control room while G13erations Sl=lift Mana§ler froFfl tl=le the unit is in MODE 1, 2, or 3, an control rooFfl *.vl=lile tl=le unit is in individual with an active Senior MQgE ~, 2, or 3, an inEliviElual witl=I Reactor Operator (SRO) license an active Senior Reactor G13erator shall be designated to assume the (SRG) license sl=lall ee Elesi§lnateEI control room command function.

to assuFfle tl=le control rooFfl During any absence of the coFf!FflanEI function. gurin§I any Operations Shift Manager from the aesence of tl=le G13erations Sl=lift control room while the unit is in Mana§ler froFfl tl=le control rooFfl MODE 4 or 5, an individual with an wl=lile tl=le unit is in MQgE 4 or 5, an active SRO license or Reactor inEli1e1iElual witl=I an active SRG Operator license shall be designated license or Reactor G13erator license to assume the control room sl=lall ee Elesi§lnateEI to aSSUFfl9 tl=le command function.

control rooFfl COFflFflanEI function.

5.2.1 Onsite and Offsite Organizations 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall Onsite and offsite organizations be established for unit operation and shall be established for oo-it corporate management,

-

:~'.:'"'facility staff and corporate I

I

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 5 of 26 respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in the Technical Specifications shall be documented in the UFSAR or QA Program Description;

b. The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;

c. The corporate officer with direct responsibility for the plant shall have corporate res onsibility for management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plantfuel.

a. Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating facility organization positions. These relationships shall be documented and updated, as appropriate, in organizational charts, functional descriptions. ef departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements including the plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in the Technical Specifications shall be documented in the UFSAR or QA Program DescriptionThese organizational descriptions shall be documented in the UFSAR or QA Program Description;

b. The plant manager shall be responsible for overall safe operation of the ~facility and shall have control over those onsite activities necessary for safe operation and maintenance of the f>>affistorage and maintenance of spent nuclear fuel;

c. The corporate officer will'.l ffifeetshall have responsibility for the overall facility plant shall have

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 6 of 26 overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; and

d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

5.2.2 Unit Staff The unit staff organization shall also include the following:

a. A non-licensed operator shall be assigned to the reactor when containing fuel and an additional non-licensed operator shall be assigned to the reactor when operating in MODES 1, 2, or 3.

b. Shift crew composition shall meet the requirements stipulated

d.

5.2.2 f}taffi-nuclear safety and shall take I

aRJ'-measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safetyfacility to ensure safe management of spent nuclear fuel; and The individuals who train the operating staffCERTIFIED FUEL HANDLERS and those who, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functionsinsepensence frorn operating pressures.

Ymt-Facility Staff The unit stafffacility organization shall also inclusemeet the following:

a. A non licenses operator sl:iall ee assignes to tl:ie reactor wl:ien containing fuel ans an assitional non licenses operator sl:iall ee assignes to tl:ie reactor 1.vl:ien operating in MODES 1, 2, or 3.Each on-duty shift shall include at least the following shift staffing:

One (1) Operations Shift Manager (see f below)

Two (2) NON-CERTIFIED OPERATORS (see g below)

9. Sl:iift crew eornposition sl:iall I

---J. J.l-.- ---..

~-----"'-

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 7 of 26 herein and in 10 CFR 50.54(m).

c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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.

d. A person qualified to implement 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to provide for unexpected absence, provided stipulated herein and in 10 CFR 50.54(m).

b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.g 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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. During such absences, no fuel movement or movement of loads over the spent fuel shall be permitted. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming shift crew member being late or absent.

c. At times when nuclear fuel is stored in the spent fuel pool, at least one (1) person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room.

&.-d.

Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

the.

A person qualified to implement radiation protection procedures shall be on site 1.vhen fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in order to

~--*.:...J- &-r in,....

1 -.,....-.&.-...J

,..... -* -- - -,_ ~r-*--... --

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 8 of 26 immediate action is taken to fill the required position.

e. Not used

' f.

The Operations Manager or Operations Supervisors shall hold an SRO license.

g. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the commission Policy Statement on Engineering Expertise on Shift.

This function is not required in MODES 4 and 5.

5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions in ANSI/ANS 3.1-1978. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

5.3.2 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 5.3 5.3.1 5.3.2 asseRSe, f3F9ViEleEl iFRFReEliate aetioR is takeR to fill the requireEl 13ositioR.during movement of fuel and during movement of loads over the fuel.

e-:f. Not useElThe Operations Shift Manager shall be a CERTIFIED FUEL HANDLER.

f:.g. +he G13erati0Rs MaRa§er or G13erati0Rs Su13ervisors shall holEl aR SRG lieeRse. The position of NON-CERTIFIED OPERA TOR may be filled by a CERTIFIED FUEL HANDLER.

AR iREli1.iiElual shall 13roviEle aElvisory teehRieal su1313ort to the uRit 013erati0Rs shift erew iR the areas of therrnal hyElraulies, reaetor eR§iReeriR§, aREl 13laRt aRalysis 1Nith re§arEl to the safe 013eratioR of the uRit. +his iREliviElual shall rneet the qualifieatiORS s13eeifieEl SJ' the eoFRFRissioR Poliey StaterneRt OR ER§iReeriR§ Ex13ertise OR Shift. +his fuRetioR is Rot

'--....J

~ l\\Af""\\r'IC::C A

~~...J C

-Yffit-Facility Staff Qualifications I

Each member of the ooit-facility staff shall meet or exceed the minimum qualifications referenced for comparable positions in ANSI/ANS 3.1-1978. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

i;:or the 13ur13ose of ~ Q Gi;:R aa.4, a lieeRseEl SeRior Reaetor G13erator

~SRG~ aREl a lieeRseEl Reaetor G13erator ~RQ~ are those iREliviEluals who, iR aElElitioR to

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 9 of 26 requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m).

5.6 Reporting Requirements 5.6.1 DELETED 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environment Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), and in 10 CFR 50, Appendix I, Sections IV.8.2, IV.8.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table of meetiR§! U:ie FeEl~iFemeRts ef +s a. J. ~' ~eFfeFm U:ie f~RstieRS ElessFiseEI iR ~ G Gr;'.R aG. a4(m~.The CERTIFIED FUEL HANDLER shall be qualified to the NRG-approved training and retraining program for CERTIFIED FUEL HANDLERS.

The NRG-approved training and retraining program for CERTIFIED FUEL HANDLERS shall be I

maintained.

5.6 Reporting Requirements 5.6.1 DELETED 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environment Operating Report covering the operation of the w:Ht I

facility during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), and in 10 CFR 50, Appendix I, Sections IV.8.2, IV.8.3, and IV.C.

I The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 10 of 26 Regulatory Guide 4.8. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Material Release Report The Radioactive Material Release Report covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODAM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 DELETED 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

The Average Planar specified in the table of Regulatory Guide 4.8. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Material Release Report The Radioactive Material Release Report covering the operation of the w:Ht-facility during the previous calendar year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a.

The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the tu=Htfacility. The material provided shall be consistent with the objectives outlined in the ODAM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 DELETED 5.6.5 DELETED CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

The Average Planar

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 11 of 26

b.

c.

d.

Linear Heat Generation Rate (APLHGR) for Specification 3.2.1;

2.

The Minimum Critical Power Ratio (MCPR) for Specification 3.2.2;

3.

Exclusion Region in the Power/Flow Map for Specification 3.4.1 ;

and

4.

The Maximum Critical Power Ratios (MCPR) in Table 3.3.2.1-1 for Specification 3.3.2.1.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in General Electric Standard Application for Reactor Fuel, NEDE-24011-P-A, (GESTAR II). The revision number is the one approved at the time the reload fuel analyses are performed.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

b.

C.

d.

Linear Heat Generation Rate (/\\PLHGR) for Specification 3.2.1 ;

2.

The Minimum Critical Po*Ner Ratio (MCPR) for Specification 3.2.2;

3.

Exclusion Region in the Power/Flow Map for Specification 3.4.1; and

4.

The Maximum Critical Pmver Ratios (MCPR) in Table 3.3.2.1 1 for Specification 3.3.2.1.

The analytical methods used to determine the core operating limits shall be those previously revie*Ned and approved by the NRG in General Electric Standard Application for Reactor Fuel, NEDE 24011 P /\\,

(GEST/\\R II). The revision number is the one approved at the time the reload fuel analyses are performed.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (EGGS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the

~

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 12 of 26 5.6.7 Reactor Coolant System (RCS) 5.6.7 DELETED Reactor Coolant PRESSURE AND TEMPERATURE Svstem (RCS) PRESSURE AND LIMITS REPORT (PTLR)

TEMPERATURE LIMITS REPORT

a.

RCS pressure and (PTLR) tern peratu re Ii m its for heat up,

-a-. _ _..,.R......,c.-."s..... pf.Hr-e-ss-u-++r-e~a..... n..... d...... t-e++m..... p-e-ra-t++u r...-e cooldown, low temperature limits for heat up, cooldm.vn, low operation, criticality, and temperature operation, criticality, hydrostatic testing as well as and hydrostatic testing as *11ell as heat up and cooldown rates heat up and cooldm.vn rates shall shall be established and be established and documented in documented in the PTLR for the PTLR for the following:

the following:

i.

Limiting Conditions for

i.

Limiting Conditions for Operation Section 3.4.9, Operation Section "RCS Pressure and 3.4.9, "RCS Pressure Temperature (P!T) Limits" and Temperature (PIT) ii Surveillance Requirements Limits" Section 3.4.9, "RCS ii Surveillance Pressure and Temperature Requirements Section (P!T) Limits" 3.4. 9, "RCS Pressure rtb.,--. --T++Hhe~a++nd1a IHl-ytffii crn-attl--Hml-tte~ttth 01=11dctts.,_.uttls~e"ftdt-tttto and Temperature (PIT) determine the RCS pressure and Limits" temperature limits shall be those

b.

The analytical methods used previously reviewed and approved to determine the RCS by the NRG, specifically those pressure and temperature described in the following limits shall be those document:

previously reviewed and i)

SIR 05 044 A, "Pressure approved by the NRG, Temperature Limits Report specifically those described in Methodology for Boiling the following document:

'.Nater Reactors," Revision i)

SIR-05-044-A, 1, dated June 2013.

"Pressure-Temperature

.t,;C~

. --T-t-tthe~P,T-1:::L:PR<-1Ssthn:att1ll-1:bfteHpettrtio'V-1ViK:::1d~etrd ~tol7-Hth~e Limits Report NRG upon issuance for each Methodology for r~actor vessel fluence period and Boiling Water for any revision or supplement Reactors," Revision 1, thereto.

dated June 2013.

c.

The PTLR shall be provided to the NRG upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 13 of 26

3.0 TECHNICAL EVALUATION

This technical evaluation is for administrative changes to DAEC Technical Specifications (TS) Sections 1.1, "Definitions," and 5.0, "ADMINISTRATIVE CONTROLS." These changes will become effective following NRC's approval of the CFH training program and following submittal of the required 10 CFR 50.82(a)(1)(ii) certification that DAEC has been permanently defueled.

Section 1.1 - Definitions Once DAEC power operations have ceased and the reactor is permanently defueled, Reactor Operators (ROs) and Senior Reactor Operators (SROs) will no longer be required to support plant operating activities. Consequently, there will be no need to maintain qualification programs for ROs and SROs as they currently exist. NEDA intends to replace the Reactor Operator qualification program with a Certified Fuel Handler (CFH) training program as described in Reference 2. Consequently, definitions for "Certified Fuel Handler" and "Non-Licensed Operator" are added to section 1.1.

Section 5.0 -Administrative controls The terms "unit," "unit operation," "power plant," and "plant" are typically associated with an operating reactor. The proposed changes in Section 5.0 revise these terms where applicable with terms such as "facility," "facility staff,"

and "spent nuclear fuel," which are considered more appropriate in representing the permanently shut down and defueled condition.

The terms "safe storage and maintenance of spent nuclear fuel" and "safe management of spent nuclear fuel" are considered analogous to "nuclear safety" for a plant that will be in the permanently defueled condition. The proposed changes remove the implication that DAEC can return to operation once the final certification required by 10 CFR 50.82(a)(1)(ii) is submitted to the NRC.

Further changes to Section 5.0 are as follows:

Section 5.1 - Responsibility TS Section 5.1, "Responsibility," provides a description and requirements regarding certain key operational management responsibilities. This section includes certain requirements associated with power operation of the reactor.

Following submittal of the certifications required by 10 CFR 50.82(a), NEDA will be prohibited from operating the plant or placing fuel in the reactor vessel.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 14 of 26 Therefore, TS requirements associated with power operation will no longer be needed.

This section is being revised to define the individuals and their responsibilities following permanent cessation of operations. Responsibilities will be those that are germane to a permanently defueled reactor with an emphasis on safe management of spent nuclear fuel.

TS 5.1.1 - TS 5.1.1 describes the plant manager position as having responsibility for overall unit operation. Once the DAEC has permanently ceased operation, this responsibility is unnecessary because the unit will no longer be licensed to operate. The plant manager position responsibility is therefore changed to overall facility operation. Requirements for the delegation of plant manager responsibilities are unchanged by this LAR. Currently, the plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affects nuclear safety. To reflect the permanently defueled reactor, this is changed to require that the plant manager or his designee approve, prior to implementation, each proposed test, experiment of modification to systems or equipment that affect safe storage and maintenance of spent nuclear fuel. The terms "safe storage and maintenance of spent nuclear fuel" and "safe management of spent nuclear fuel" are considered analogous to "nuclear safety" for a plant that will be in the permanently defueled condition. The proposed changes serve to narrow the focus of nuclear safety concerns to those pertaining to maintaining spent nuclear fuel. This change removes the implication that DAEC can return to operation once the final certification required by 10 CFR 51.82(a)(1 )(ii) is submitted to the NRC.

TS 5.1.2 - TS 5.1.2 describes the Operations Shift Manager as having the command function of the control room. This specification is being modified to describe the Operations Shift Manager as having the command function of the shift. Safe operation in the permanently defueled condition consists primarily of ensuring safe management of the spent irradiated fuel that is stored on site, consequently, the main control room (MCR) required shift staffing is reduced. The proposed TS changes recognize that the delegation of authority for command and control aspects is different in a permanently shut down and defueled reactor from that for an operating plant. The MCR will remain the physical center of the command function; however, since control of activities may be performed either remotely from the MCR or locally in the plant, the location of the command center is functionally where the Operations Shift Manager is located. MODE-specific MCR staffing requirements when the Operations Shift Manager is absent from the control room will be removed. These requirements do not apply to a permanently defueled reactor. Facility staffing requirements, including MCR staffing requirements are added in TS 5.2.2.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 15 of 26 5.2 - Organization TS Section 5.2, "Organization," provides a description and requirements regarding onsite and offsite facility organization and unit staffing. This section contains certain requirements associated with reactor operation. Those requirements are not needed for a permanently defueled condition because 10 CFR 50.81(a)(2) prohibits NEDA from operating the DAEC or placing fuel in the reactor vessel.

This section is being revised to align the applicable TS requirements with those associated with the permanently defueled condition.

TS Section 5.2.1 - The positions required for onsite and offsite organizations are revised to reflect a permanently defueled reactor as follows:

5.2.1.a - The proposed changes remove the requirements for documenting lines of authority, responsibility and communications relationships for key personnel positions. These requirements, including plant specific titles of those personnel fulfilling the responsibilities of the positions delineated in the Technical Specifications, are not applicable to a reactor that is permanently shut down, defueled and whose focus has shifted solely to safe management of the spent nuclear fuel. The proposed changes require lines of authority, responsibility and communications relationships be documented in organizational descriptions. These organizational descriptions shall be documented in the Updated Final Safety Analysis Report (UFSAR) or Quality Assurance Program Description.

5.2.1.b - The terms "plant" and "operation and maintenance of the plant" are changed to "facility" and "storage and maintenance of spent nuclear fuel," respectively. This terminology aligns with activities at a permanently defueled reactor.

5.2.1.c - The responsibilities of a corporate officer are changed from "overall nuclear safety" and providing support to the "plant to ensure nuclear safety" to responsibility for the "overall facility" and providing support to the "facility to ensure safe management of spent nuclear fuel,"

respectively. Following plant shutdown and permanent cessation of operations, nuclear safety will focus predominately on ensuring the safe control and management of spent nuclear fuel. These responsibilities align with those required for a permanently defueled reactor.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 16 of 26 5.2.1.d - The proposed changes to this paragraph will modify the requirements related to organizational independence of the personnel who train the operations staff, health physics personnel, and quality assurance personnel from operating pressures. This change proposes to replace "operating staff' with "Certified Fuel Handlers" and to replace "their independence from operating pressures" with "their ability to perform their assigned functions." These proposed changes reflect the changed function of the operating staff to a focus on safe handling and storage of spent nuclear fuel. These proposed changes also remove the implication that DAEC can return to operation once permanently defueled and the final certification required by 10 CFR 50.82(a)(1 )(ii) is submitted to the NRG. Therefore these changes align section 5.2.1.d with requirements appropriate for a permanently defueled reactor.

TS Section 5.2.2 - The term "Unit Staff" is changed to "Facility Staff" to more appropriately represent the permanent shutdown condition of the reactor.

Following submission to the NRG of the certifications required by 10 CFR 50.82(a)(1), DAEC will no longer be authorized to operate the reactor or load fuel into the reactor vessel, and the requirements of 10 CFR 50.54(m) requiring a licensed operating staff will no longer apply, and therefore these requirements have also been removed. Facility staff organization is revised in section 5.2.2 as follows:

5.2.2.a - This section describes the minimum shift staffing for plant operations. Since plant operations cannot recur at DAEC once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRG, the minimum staffing requirement is changed to a minimum crew compliment of one Operations Shift Manager and two Non-Certified Operators. The number and complexity of operating systems will be reduced to the systems required to provide and support spent fuel pool cooling. This crew compliment is sufficient to monitor spent fuel pool parameters, such as pool level and temperature, while maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner. Moreover, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safety have been greatly reduced from that at an operating plant. The Operations Shift Manager will be qualified as a Certified Fuel Handler in accordance with the new paragraph 5.2.2.e. In this position, this individual will retain command and control responsibility for operational decisions and will be responsible for the functions required for event reporting and emergency response. The Non-Certified Operator position can be filled by either a Non-Certified Operator or by a Certified Fuel Handler in accordance with new paragraph 5.2.2.g.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 17 of 26 The requirement for a non-licensed operator assigned to the reactor that contains fuel is not required for a permanently defueled reactor. The requirement for an additional non-licensed operator assigned to the reactor when in MODES 1, 2, or 3 is not required for a permanently defueled reactor since operating MODES are no longer applicable and the reactor has been defueled. Therefore, these requirements are removed.

Instead, an on-duty shift shall include at least one Operation Shift Manager and two Non-Certified Operators. These duty shift requirements reflect the reduced number of systems, compared to an operating reactor, required to provide and support spent fuel pool cooling and monitor spent fuel pool parameters, such as pool level and temperature, while still maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner. Moreover, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safety has been greatly reduced from that of an operating plant.

5.2.2.b - The requirement for an operating crew composition in accordance with 10 CFR 50.54(m) is removed. Following submittal of the certifications required by 10 CFR 50.82(a)(1), DAEC will not be required to have operators licensed pursuant to 10 CFR 55. This requirement is deleted.

5.2.2.c - This requirement is renumbered as 5.2.2.b. In addition, the requirements for crew composition and staffing are revised to align with the needs of a permanently defueled reactor.

New 5.2.2.c - A new requirement for staffing at a permanently defueled reactor is added such that, at times when nuclear fuel is stored in the spent fuel pool, at least one (1) person qualified to stand watch in the control room (Non-Certified Operator or Certified Fuel Handler) shall be present in the control room.

New 5.2.2.d - A requirement that oversight of fuel handling operations shall be provided by a Certified Fuel Handler is added.

Existing 5.2.2.d - This requirement is renumbered 5.5.2.e. The requirement for a person qualified to implement radiation protection procedures to be on site when fuel is in the reactor, and actions to take should the position be vacant, are removed. Once the certification of 10 CFR 50.82 is submitted, DAEC will no longer be licensed to have fuel in the reactor and these requirements are not necessary. These requirements are replaced with a requirement for a person qualified to

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 18 of 26 implement radiation protection procedures to be on site during movement of fuel and during movement of loads over the fuel.

5.2.2.f - The requirement for the Operations Manager or Operations Supervisors to hold an SRO license is removed. Licensed Operators are not required for reactors that have permanently ceased operation.

Instead, a requirement for the Operations Shift Manager to be a Certified Fuel Handler is added. This requirement ensures that the individual on shift is appropriately trained and qualified, in accordance with the NRC-approved Certified Fuel Handler training program, to supervise shift activities.

The DAEC management structure will not require positions above the Operations Shift Manager to be a Certified Fuel Handler or to attend equivalent training. NEDA has determined that, once the plant is permanently shut down and defueled, the time available to mitigate credible events is expected to be greater than that for current design basis events. As such, management oversight of the plant can be performed by individuals meeting the applicable requirements of ANSI/ANS 3.1-1978 and need not be qualified as Certified Fuel Handlers.

New 5.2.2.g - The requirement for an advisory technical support position as part of the shift crew is being eliminated. This requirement is only required for a plant authorized for power operations. Once the certifications required by 10 CFR 50.82(a)(1) have been submitted, the requirements of this specification will no longer be applicable because the DAEC Part 50 license will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. In its place, a statement that the Non-Certified Operator position may be filled by a Certified Fuel Handler is added. This section provides that the Non-Certified Operator position required in TS 6.2.2.a may be filled by either a Non-Certified Operator or by a Certified Fuel Handler. This minimum shift crew composition is appropriate for the safe management of spent irradiated nuclear fuel at a permanently defueled facility.

5.3 - Unit Staff Qualifications TS Section 5.3, "Unit Staff Qualifications," provides minimum qualifications for certain unit staffing. This section contains certain requirements associated with reactor operation. Those requirements are not needed for a permanently defueled condition because 10 CFR 50.81 (a)(2) prohibits NEDA from operating the DAEC or placing fuel in the reactor vessel.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 19 of 26 This section will be retitled "Facility Staff Qualifications," and will be revised to align the applicable TS requirements with the reactor in a permanently defueled condition as follows:

5.3.1 - This section establishes that each member of the unit staff shall meet or exceed the minimum qualifications specified in ANSI/ANS 3.1 of 1978. The term "unit" will be replaced with the term "facility" to reflect the permanently defueled condition at DAEC following the certifications required by 10 CFR 50.82(a)(1) being submitted to the NRG. The requirement for the Radiation Protection Manager to meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, is unchanged.

5.3.2 - This section establishes the requirement that, for the purpose of 10 CFR 55.4, a Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) must meet the requirements of TS 5.3.1 and perform the functions described in 10 CFR 50.54(m). This requirement is being deleted. Once the certifications required by 10 CFR 50.82(a)(1) have been submitted, the requirements of 10 CFR 50.54(m) will no longer be applicable because the DAEC Part 50 license no longer will authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need for the operators' licenses specified in 10 CFR 55. This paragraph is being replaced with a requirement that the Certified Fuel Handlers be qualified to the NRG-approved training and retraining program for Certified Fuel Handlers and that this program be maintained. The Certified Fuel Handler training program ensures that the qualifications of fuel handlers are commensurate with the tasks to be performed and the conditions requiring response. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," requires training programs to be derived using a systems approach to training (SAT) as defined in 10 CFR 55.4. Although the requirements of 10 CFR 50.120 apply to holders of an operating license issued under Part 50, and the DAEC license will no longer authorize operation following submittal of the certifications required by 10 CFR 50.82(a)(1 ), the Certified Fuel Handler training program will, nonetheless, align with those requirements. The Certified Fuel Handler training program provides adequate confidence that appropriate SAT based training of personnel who will perform the duties of a Certified Fuel Handler is conducted to ensure the facility is maintained in a safe and stable condition.

There are no changes to Technical Specifications Section 5.4, "Procedures" and Section 5.5, "Programs and Manuals."

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 20 of 26 5.6-Reporting Requirements TS Section 5.6, "Reporting Requirements," outlines the reports that shall be submitted in accordance with 10 CFR 50.4. Once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRC, the DAEC will no longer be licensed to operate or to place or store nuclear fuel in the reactor. The changes to this section reflect the permanently defueled condition at DAEC as follows.

5.6.1 - This section is currently identified as DELETED. This will be unchanged.

5.6.2 - This section provides requirements for the Annual Radiological Environmental Operating Report. In this section, the word "unit" is replaced with "facility" to reflect the permanently defueled condition at DAEC. No other changes to the Annual Radiological Environmental Operating Report requirements are made.

5.6.3 - This section provides requirements for the Radioactive Material Release Report. In this section, the word "unit" is replaced with "facility" to reflect the permanently defueled condition at DAEC. No other changes to the Radioactive Material Release Report requirements are made.

5.6.4 - This Section is currently identified as DELETED. This will be unchanged.

5.6.5 - This section details the requirements for DAEC's CORE OPERATING LIMITS REPORT (COLR). The COLR establishes, prior to each reload cycle, cycle specific parameter limits for plant operation. The COLR pertains only to an activity that does not apply in a permanently defueled condition. Once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are submitted to the NRC pursuant to 10 CFR 50.82(a)(1)(i) and (ii), NRC regulations stipulated in 10 CFR 50.82(a)(2) will no longer authorize operation of the reactor or placement of fuel into the reactor vessel under the 10 CFR 50 license. Based on these considerations, the requirements to develop and submit the COLR will be deleted from the TS.

Consequently, Section 5.6.5 will be identified as DELETED.

5.6.6 - This Section is unchanged.

5.6.7 - This section details the requirements for the DAEC's Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR). The PTLR establishes reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period. The PTLR pertains only to an activity that does not apply in a permanently defueled

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 21 of 26 condition. Once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel are submitted to the NRG pursuant to 10 CFR 50.82(a)(1)(i) and (ii), NRG regulations stipulated in 10 CFR 50.82(a)(2) will no longer authorize operation of the reactor or placement of fuel into the reactor vessel under the 10 CFR 50 license. Based on these considerations, the requirements to develop and submit the PTLR will be deleted from the TS. Consequently, Section 5.6.7 will be identified as DELETED.

5.7 -This section is unchanged.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

10 CFR 50.36, Technical specifications, requires each licensee to have technical specifications which will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to§ 50.34. The technical specifications will include safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, surveillance requirements, design features, and administrative controls.

NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants," Revision 4

10 CFR 50.82, Termination of license, outlines the required NRG decommissioning-related submittals that must be docketed and timeliness of those submittals.

10 CFR 50.54, Condition of licenses, Section (m) provides the minimum requirements per shift for on-site staffing of Nuclear Power Units by Operators and Senior Operators licensed under 10 CFR Part 55.

10 CFR 55, Operators' Licenses, this Part establishes procedures and criteria for the issuance of licenses to operators and senior operators and the terms and conditions upon which those licenses are issued or modified and maintained or renewed.

The proposed changes are consistent with the above regulatory guidance and regulation.

4.2 Precedent The proposed changes are consistent with the existing TS administrative control requirements currently in effect for the permanently shutdown and defueled Vermont Yankee Nuclear Power Station (DPR-28), for which an

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 22 of 26 amendment was issued on December 22, 2014 (Reference 4) and for the permanently shutdown and defueled Kewaunee Power Station (DPR-43), for which an amendment was issued on February 13, 2015 (Reference 5) and for the permanently shutdown and defueled Oyster Creek Nuclear Generating Station (DPR-16), for which an amendment was issued on March 7, 2017 (Reference 6) and for the permanently shutdown and defueled Fort Calhoun Station (DPR-40), for which an amendment was issued on July 28, 2017 (Reference 7).

4.3 No Significant Hazards Consideration NextEra Energy Duane Arnold, LLC (NEDA), pursuant to 50.90, requests an amendment to the Duane Arnold Energy Center (DAEC) Technical Specifications (TS). The proposed change would revise and/or remove certain requirements contained within TS Section 1.1, "Definitions," and Section 5.0, "ADMINISTRATIVE CONTROLS," of the DAEC TS. The TS requirements being changed would be applicable once it has been certified that all fuel has been permanently removed from the DAEC reactor in accordance with 10 CFR 50.82(a)(1 )(ii). Once the final certification is submitted documenting the permanent cessation of operations and permanent fuel removal, the 10 CFR 50 license for DAEC no longer will authorize operation of the reactor or placement of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2).

NEDA has evaluated the proposed change against the criteria of 10 CFR 50.92(c) and concludes that the proposed changes do not involve any significant hazards, since the proposed changes satisfy the criteria of 10 CFR 50.92(c). The following is the evaluation of each of the 10 CFR 50.92(c) criteria:

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

Response: No The proposed changes do not involve any physical changes to plant Structures, Systems, and Components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting control settings, limiting conditions for operation, surveillance requirements, or design features.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 23 of 26 The deletion and modification of provisions of the administrative controls do not directly affect the design of SSCs necessary for safe storage of spent irradiated fuel or the methods used for handling and storage of such fuel in the Spent Fuel Pool (SFP). The proposed changes are administrative in nature and do not affect any accidents applicable to the safe management of spent irradiated fuel or the permanently shutdown and defueled condition of the reactor.

DAE C's accident analyses are contained in Chapter 15 of the Updated Final Safety Analysis Report (UFSAR). In a permanently defueled condition, the only credible UFSAR described accident that remains is the Fuel Handling Accident (FHA). Other Chapter 15 accidents will no longer be applicable to a permanently defueled reactor plant.

The probability of occurrence of previously evaluated accidents is not increased, since extended operation in a permanently defueled condition will be the only operation allowed, and therefore, bounded by the existing analyses. Additionally, the occurrence of postulated accidents associated with reactor operation is no longer credible in a permanently defueled reactor. This significantly reduces the scope of applicable accidents.

Therefore, the proposed changes do not involve an increase in the probability or consequences of a previously evaluated accident.

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

Response: No The proposed changes have no impact on facility SSCs affecting the safe storage of the spent irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of spent irradiated fuel itself. The proposed changes do not result in different or more adverse failure modes or accidents than previously evaluated because the reactor will be permanently shut down and defueled and DAEC will no longer be authorized to operate the reactor.

The proposed changes do not affect systems credited in the accident analysis for the FHA at DAEC. The proposed changes will continue to require proper control and monitoring of safety significant parameters and activities.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 24 of 26 The proposed changes do not result in any new mechanisms that could initiate damage to the remaining relevant safety barriers in support of maintaining the plant in a permanently shutdown and defueled condition (e.g., fuel cladding and SFP cooling). Since extended operation in a defueled condition will be the only operation allowed, and therefore bounded by the existing analyses, such a condition does not create the possibility of a new of different kind of accident.

The proposed changes do not alter the protection system design, create new failure modes, or change any modes of operation. The proposed changes do not involve a physical alteration of the plant, and no new or different kind of equipment will be installed. Consequently, there are no new initiators that could result in a new or different kind of accident.

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?

Response: No The proposed changes involve adding TS definitions and deleting and/or modifying certain TS administrative controls once the DAEC facility has been permanently shut down and defueled. As specified in 10 CFR 50.82(a)(2), the 10 CFR 50 license for DAEC will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel following submittal of the certifications required by 10 CFR 50.82(a)(1). As a result, the occurrence of certain design basis postulated accidents are no longer considered credible when the reactor is permanently defueled.

The only remaining credible UFSAR described accident is a FHA. The proposed changes do not adversely affect the inputs or assumptions of any of the design basis analyses that impact the FHA.

The proposed changes are limited to those portions of the TS definitions and administrative controls that are related to the safe storage and maintenance of spent irradiated fuel. The requirements that are proposed to be revised and/or deleted from the DAEC TS are not credited in the existing accident analysis for the remaining postulated accident (i.e.,

FHA); therefore, they do not contribute to the margin of safety associated

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 25 of 26 with the accident analysis. Certain postulated DBAs involving the reactor are no longer possible because the reactor will be permanently shut down and defueled and DAEC will no longer be authorized to operate the reactor.

Therefore, the proposed changes have no impact to the margin of safety.

Based on the above, NEDA concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

S The proposed amendment involves revising the DAEC TS by adding definitions described in Section 1.1 and deleting and/or modifying certain portions of the administrative controls described in Section 5.0 in support of proposed decommissioning efforts to reflect the permanently shut down and defueled condition at DAEC. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) because it does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

In addition, the proposed changes involve changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request Enclosure to NG-19-0021 Page 26 of 26

6.0 REFERENCES

6.1 Letter from Mano K. Nazar, NextEra Energy Duane Arnold, LLC to U.S.

Nuclear Regulatory Commission - "Duane Arnold Energy Center - Certification of Permanent Cessation of Power Operations," dated January 18, 2019, (ADAMS Accession No. ML19023A196).

6.2 Letter from Dean Curtland, NextEra Energy Duane Arnold, LLC to U.S.

Nuclear Regulatory Commission - "Request for Approval of Certified Fuel Handler Training Program," dated January 29, 2019, (ML19037A016).

6.3 NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants," Revision 4.

6.4 Vermont Yankee Nuclear Power Station Amendment 260, License No. DPR-28, dated March 31, 2014(ML14217A072).

6.5 Kewaunee Power Station, Amendment 215, License No. DPR-43, dated February 13, 2015 (ML14237A045).

6.6 Oyster Creek Nuclear Generating Station Amendment 290, License No. DPR-16, dated March 7, 2017(ML16235A413).

6.7 Fort Calhoun Station, Unit No. 1, Amendment 292, License No. DPR-40, dated July 28, 2017(ML17165A465).

LIST OF ATTACHMENTS - Proposed Technical Specification Changes (Mark-Up) - Revised Technical Specification Pages

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request NG-19-0021 Enclosure, Attachment 1 Page 1 of 11 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

1.0 USE AND APPLICATION 1.1 Definitions Definitions 1.1

NOTE----------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

ACTIONS AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

CHANNEL CALIBRATION Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

The APLHGR shall be applicable to a specific planar height and is equal to the sum of the heat generation rate per unit length of fuel rod for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with Resistance Temperature Detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may overla ing or total channe s e g-..:* ~.......,...............................,.................,.................

be performed by means of any series of sequential,

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CERTIFIED FUEL HANDLER DAEC A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the Certified Fuel Handler training program required by Technical Specifications Section 5.3.2.

1.1-1 (continued)

Amendment No. ~

1.1 Definitions (continued)

MINIMUM CRITICAL POWER RATIO (MCPR)

MODE Definitions 1.1 film boiling occur intermittently with neither type being completely stable.

A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

OPERABLE -

OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

RATED THERMAL POWER (RTP)

REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME The PTLR is the unit specific document that provides the reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.7.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 1912 MWt.

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that

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tli n re re p n e 1m 1 e s e.

NON-CERTIFIED OPERATOR DAEC A NON-CERTIFIED OPERATOR is an individual who Section 5.3.1.

1.1-7 Amendment -365-

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 5.1.2 DAEC The plant manager shall be responsible for overall &fttt operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect

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The Operations Shift Manager shall be responsible for the oom command function. DuriAg aAy abseAee of the OperatioAs Shift Mai 1ager fro11i the control room while the ur:iit is iA MODE 1, 2, or 3, a A inelivielual with aA active SeAior Reactor Operator (SRO) lieeAse shall be desigAated to assume the control room command function. During any abseAee of the Ope ratio As Shift MaAager from the eoAtrol room while the uAit is iA MODE 4 or 5, aA iAeli'o'ieual 'Nith BA acti*o'e SRO liceAse or Reactor Operator license shall be elesigneel to assume the ceAtrol room co111111a11d fu11ctio11.

5.0-1 Amendment 223-

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established fo u11it ope1atio11 and corporate management, respectively. The onsite and offsite organizations shall inclu ositions for activities affecting safety of the nuclear;

. uel

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, in erme 1a e eves, an operatiflg organization positions.

These relationshi s shall be documented and updated, as

~------------.,...-----..,-~___,----..,

a propriate, in organizatio cl 1ai ts, fu11ctio11al descriptio '*

. These organizational descriptions shall be documented in the UFSAR or QA Program Des ri ti n departmental responsibilities and relationships, and job descriptions for key personnel positions, or in eql:livalent forms of eleeUFl'lefltatiefl. H1ese reeiuirefl'lefltS iflelueliflg the plaflt speeifie titles ef these perseF1F1el fulfilliflg the respoFlsibilities of the pesitiefls elelifleateel ifl the Technical 81'eeificatio1is shall be doeu111e1ited i11ti1e UFSAR 01 QA P1ogra11i Deseriptio1 1; r----__

b

..:_*-,T~h~e~

plant manager shall be responsible for overall safe operation

~ and shall have control over those onsite activities

~~~~~~-

necessary for s OJ'.'el ation and maintenance of the l'lant; with elirect responsibility for the ~~~-H'I.............................. -"-~

-f'tt!~:ee-t'rffWS'~:es-"61R5tbttttv-1=er~ef1rH;:~=tt-n l:l GI ear safety and shall take -etty-measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing

~~Y--Y--Y-..y--y--~<""'\\-~te~c~h~n:ic::a:l _:.s~u~p~

p~

ort~to~

th plant to ensl:lre nl:lclear safety; and The individuals who train t physics, or perform (continued)

DAEC 5.0-2 Amendment ZZ3-

Each on-duty shift shall include at least the following shift staffing :

0 One (1) Operations Shift Manager (see f below); and 0 Two (2) NON-CERTIFIED OPERATORS (see g below).

(continued)

Organization 5.2 tfftit Sta ff

b.

c.

A non licensed operator shall be assigned to the reactor when containing fuel and an additional non licensed operator shall be assigned to the FeactoF *ovhen 019eFating in MODES 1, 2, eF 3.

Shift crew composition shall meet the Feeiuirements stipulated hmcin and in 10 CFR 50.54(m).

Shift crew composition may be less than the minimum requirement of 10 GFR 50.64(m)(2)(i) and 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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. ~------------.......

A person qualified to implement radiation protection procedures shall be on site

e.

f.

c. At times when nuclear fuel is stored in the spent fuel pool, at least one (1) person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room.

d. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

g. The position of NON-CERTIFIED OPERATOR may be filled by a CERTIFIED FUEL HANDLER.

During such absences, no fuel movement or movement of loads over the spent fuel shall be permitted. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming DA shift crew member being I ate ~~a---,......_,.,...._,,'--"'..__.,....._.,,..__,..._.,,..._,,....--".P\\14.Jo.L~~

or absent.

-t

Organization 5.2 5.2 Organization

~

Unit ;ta# (oontinued)

DAEC

§':'

An individual shall provide advisory teohnioal support to the unit operations shift orew in the areas of thermal hydraulios, reaotor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the EfUalifioations speoified by the Commission Polioy ;tatement on Engineering Expertise on ;hif:t. This funotion is not reEf uired in MODE; 4 and 5.

This page intentionally left blank.

5.0-4 Amendment 24&

l

Unit Staff Qualifications 5.3 5.3 Y-A+t-Staff Qualifications 5.3.1 Each member of the -HfHt staff shall meet or exceed the minimum qualifications referenced for comparable positions in ANSI/ANS 3.1-1978. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

5.3.2 F"or the purpose of 10 CF"R 55.4, a lioensed Senior Reaotor Operator (SRO) and a lioensed Reaotor Operator (RO) are those individuals *.vho, in addition to meeting the requirements of TS 5.d.1, perform the funotions desoribed in 10 CF"R 50.54(m).

DAEC The CERTIFIED FUEL HANDLER shall be qualified to the NRC-approved training and retraining program for CERTIFIED FUEL HANDLERS. The NRC-approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.

5.0-5 Amendment ~

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 DELETED 5.6.2 DAEC The Annual Radiological ironmental Operating Report covering the operation of the -l:ffH.t ring the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODAM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in Regulatory Guide 4.8.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

(continued) 5.0-19 Amendment No. ~

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.3 Radioactive Material Release Report The Radioactive Material Release Report covering the operation of the

-r---~~

during the previous calendar year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from t

. The material provided shall be consistent with the objectives outlined in the ODAM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 DELETED 5.6.5 CORE OPERATING LIMITS REPORT (COLR) a:-

Core operating limits sl:iall be establisl:ied prior to easl:i reload sysle, or prior to any remainiRg portioR of a reload sysle, and sl:iall be dosumeRted in tl:ie COLR f.or tl:ie f.ollowing:

Tl:ie Average PlaRar LiRear Float GeReration Rate (APU=IGR) f.or SpesifisatioR ~. 2. 1; Tl:ie Minimum Critisal Power Ratio (MCPR) f.or SpesifisatioRI _

~

1 DAEC EXslusioR RegioR iR tl:ie Power/rlow Map f.or SpesifisatioR 3.4.1; aRd Tl:ie MiRimum Critisal Power Ratios (MCPR) iR Table 3.3.2.1 1 f.or SpesifisatioR 3.3.2.1.

0-:-

Tl:ie aRalytisal metl:iods used to determine tl:ie sore operatiRg limits sl:iall be tl:iose previously reviewed aRd approved by tl:ie NRG iR GeReral Elestris StaRdard ApplisatioR f.or Roaster ruel, NEDE 24011 PA, (GESTAR II). Tl:ie revision Rumber is tl:ie ORO approved at tl:ie time tl:ie reload fuel aRalyses are perf.ormed.

(soRtiRued) t 5.0-20 Amendment No. ~

Reporting Requirements 5.6 5.6 Reporting Requirements

~

CORE OPERAT l ~JG LIMITe REPORT (COLR) (sontinued)

The sore operating limits shall be determined sush that all applisable limits (e.g., fuel thermal meshanisal limits, sore thermal hydraulis limits, Emergensy Core Cooling eystems (ECCe) limits, nuslear limits sush as eDM, transient analysis limits, and assident analysis limits) of the safety analysis are met.

The COLR, insluding any midsysle revisions or supplements, shall be provided upon issuanse for eash reload sysle to the ~JRC.

5.6.6 PAM Report DAEC When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method(s) of monitoring, describe the degree to which the alternate method(s) are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Reastor Coolant evstem (RCe) PREeeURE A~JD TEMPERATURE LIMITe REPORT (PTLR)

a. RCe pressure and temperature limits for heat up, sooldown, low temperature operation, sritisality, and hydrostatis testing as well as heatup and sooldO'tvn rates shall be established and dosumented in the PTLR for the fo llowing:

i) Limiting Conditions for Operation eestion 3.4.9, "RCe Pressure and Temperature (PIT) Limits" ii) eurveillanse Requirements eestion 3.4.9, "RCe Pressure and Temperature (Pff) Limits"

b. The analytisal methods used to determine the RCe pressure and temperature limits shall be those previously reviewed and approved by the ~JRC, spesifisally those dessribed in the following dosument:

5.0-21 Amendment ~

5.6 Reporting Requirements

\\ \\

Reporting Requirements

~

&.-&.+

Reastor Coolant Svstem (RCS) PRESSURE A~m TEMPERATURE LIMITS REPORT (PTLR) (sontinued) i)

SIR 05 044 A, "Pressure Temperature Limits Report Methodology for Boiling 'Nater Roasters," Revision 1, dated June 2013.

s. The PTLR shall be provided to the ~JRC upon issuanse for eash reastor vessel fluense period and for any revision or supplement thereto.

Delete this page entirely. Page 5.0-21 a will no longer exist in the Technical Specifications.

5.0 21a Amendment 294

Duane Arnold Energy Center Docket No. 50-331 License Amendment Request NG-19-0021 Enclosure, Attachment 2 Page 1 of 10 ATTACHMENT 2 REVISED TECHNICAL SPECIFICATION PAGES (CLEAN, WITH PROPOSED CHANGES)

1.0 USE AND APPLICATION 1.1 Definitions Definitions 1.1

NOTE----------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term ACTIONS AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

CERTIFIED FUEL HANDLER CHANNEL CALIBRATION DAEC Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

The APLHGR shall be applicable to a specific planar height and is equal to the sum of the heat generation rate per unit length of fuel rod for all the fuel rods in the specified bundle at the specified height divided by the number of fuel rods in the fuel bundle at the height.

A CERTIFIED FUEL HANDLER is an individual who complies with provisions of the Certified Fuel Handler training program required by T.S. 5.3.2.

A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with Resistance Temperature Detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

1.1-1 (continued)

Amendment No.

1.1 Definitions (continued)

MINIMUM CRITICAL POWER RA TIO (MCPR)

MODE Definitions 1.1 film boiling occur intermittently with neither type being completely stable.

A MODE shall correspond to any one inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is an individual who complies with the provisions of Technical Specifications Section 5.3.1.

OPERABLE -

OPERABILITY A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

RATED THERMAL POWER (RTP)

REACTOR PROTECTION SYSTEM (RPS) RESPONSE TIME DAEC The PTLR is the unit specific document that provides the reactor vessel pressure and temperature limits, including heatup and cooldown rates, for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.7.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 1912 MWt.

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until de-energization of the scram pilot valve solenoids. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

1.1-7 (continued)

Amendment

Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect safe storage and maintenance of spent nuclear fuel.

5.1.2 The Operations Shift Manager shall be responsible for the shift command function.

DAEC 5.0-1 Amendment

Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations DAEC Onsite and offsite organizations shall be established for facility staff and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear fuel.

a.

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all facility organization positions. These relationships shall be documented and updated, as appropriate, in organizational descriptions. These organizational descriptions shall be documented in the UFSAR or QA Program Description;

b.

The plant manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of spent nuclear fuel;

c.

The corporate officer shall have responsibility for the overall facility safety and shall take measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of spent nuclear fuel.

d.

The individuals who train the CERTIFIED FUEL HANDLERS and those who carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

(continued) 5.0-2 Amendment

Organization 5.2 5.2 Organization (continued) 5.2.2 Facility Staff DAEC The facility organization shall meet the following:

a.

Each on-duty shift shall include at least the following shift staffing:

One (1) Operation Shift Manager (see f below); and Two (2) NON-CERTIFIED OPERATORS (see g below)

b.

Shift crew composition may be less than the minimum requirement of 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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.

During such absences, no fuel movement or movement of loads over the spent fuel shall be permitted. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming shift crew member being late or absent.

c.

At times when nuclear fuel is stored in the spent fuel pool, at least one (1) person qualified to stand watch in the Control Room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the Control Room.

d.

Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

e.

A person qualified to implement radiation protection procedures shall be on site during movement of fuel and during movement of loads over the fuel.

f.

The Operations Shift Manager shall be a CERTIFIED FUEL HANDLER.

g.

The position of NON-CERTIFIED OPERATOR may be filled by a CERTIFIED FUEL HANDLER.

5.0-3 Amendment

This page intentionally left blank.

DAEC 5.0-4 Organization 5.2 Amendment

5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications Unit Staff Qualifications 5.3 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions in ANSI/ANS 3.1-1978. The radiation protection manager shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

5.3.2 The CERTIFIED FUEL HANDLER shall be qualified to the NRC-approved training and retraining program for CERTIFIED DAEC FUEL HANDLERS. The NRG-approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.

5.0-5 Amendment

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 DELETED 5.6.2 Annual Radiological Environmental Operating Report DAEC The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shalrbe submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period f)Ursuant to the locations specified in the table and figures in the ODAM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in Regulatory Guide 4.8.

In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

(continued) 5.0-19 Amendment No.

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.3 Radioactive Material Release Report The Radioactive Material Release Report covering the operation of the facility during the previous calendar year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outlined in the ODAM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 DELETED 5.6.5 DELETED (continued)

DAEC 5.0-20 Amendment No.

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.6 PAM Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method(s) of monitoring, describe the degree to which the alternate method(s) are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 DELETED DAEC 5.0-21 Amendment

v t e Letter Sequence Request
EPID:L-2019-LLA-0082, License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition (Approved, Closed)
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MONTHYEAR2019-04-19 [Table View]

L-2019-050, License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition

Text

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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L-2019-050, License Amendment Request (TSCR-181): Application to Align Technical Specification Staffing and Administrative Requirements for Permanently Defueled Condition

Text

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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