ML20137D837
| ML20137D837 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/28/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20136C539 | List:
|
| References | |
| FOIA-96-485 TAC-M90425, TAC-M90426, TIA-94-023, TIA-94-23, NUDOCS 9703260324 | |
| Download: ML20137D837 (2) | |
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UNITED STATES 1
NUCLEAR REGULATORY COMMISSION j
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WASHINGTON, D. C. 20555
- ....,d HUMAN FACTORS SAFETY EVALUATION REGARDING REFUELING PROCEDURES fE i
ST. LUCIE UNITS 1 AND 2 (TAC Nos. M90425 and M90246) i
1.0 INTRODUCTION
The Human Factors Assessment Branch has reviewed the memorandum from Bruce Boger to Gus Lainas, dated September 19, 1994. The memorandum addressed two specific issues of concern with St. Lucie's refueling procedures. The first issue is whether it is the intent of the licensee's technical specifications to have a licensed operator present as an observer during crane operation and -
fuel movement. The second is whether the Recommended Move List is part of the refueling procedure, and subject to the licensee's Technical Specifications (TS) requirement for review and approval of changes to procedures.
2.0 EVALUATION First Issue:
St. Lucie's Technical Specifications In the September 19 memorandum, Region 11 requested NRR interpretation of St.
Lucie's Technical Specification 6.2.2.d.
Technical Specification (TS) 6.2.2.d states:
ALL CORE ALTERATIONS shall be observed by a licensed operator and supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation. The SR0 in charge of fuel handling normally supervises from the control room and has the flexibility to directly supervise at either the refueling deck or the spent fuel pool.
10 CFR 50.54(m)(2)(iv) requires that "each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer) a person holding a senior operator (SRO) license or senior operator license limited to fuel handling (LSR0) to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person." The NRC interpretation of "directly supervise the activity" is that the SR0 will supervise at the location of the activity of core alterations and fuel movement.
In contrast to this requirement, the licensee's technical specification allows for observation of core alterations and fuel movement by a Reactor Operator and supervision by an SR0 or LSR0 who may supervise from the control room.
This position was confirmed in a letter from Region II to the licensee dated September 30, 1981.
9703260324 970301 PDR FOIA I '/
BINDER 96-485 PDR
. L NRR has no regulatory basis for interpreting the licensee's technical specifications regarding their requirement for a licensed operator observer.
There is no requirement for such an observer in the regulations. However, because the regulations require direct supervision by an SR0 or LSR0 who has r
no other concurrent duties, NRR believes that the licensee should modify their technical specifications to bring them into compliance with the regulations, j
NRR recommends that the region along with NRR Projects request that the licensee modify their technical specification accordingly.
Standard Technical a
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Specification Section 5.2.2 prow; des an acceptable example.
If the 11censee does not choose to amend their technical specifications, we are prepared to support a compliance backfit.
Second Issue: Refueling List as Part of the Procedure The second issue is whether the Recommended Move List is part of the refueling procedure, and subject to the licensee's TS requirement for review and approval of changes to procedures.
I In previous cases dealing with this question, the NRC has determined that the i
fuel movement list is part of the refueling procedure and any changes to the movement list must go through the licensee's procedure change process.
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