ML082830137

Brunswick Units 1 & 2, Shearon Harris Unit 1, H.B. Robinson Unit 2 & Crystal River Unit 3 - License Amendment Request to Eliminate Work Hour Controls to Support Compliance with Revised 10 CFR 26

ML082830137
Person / Time
Site:	Harris, Brunswick, Crystal River, Robinson
Issue date:	10/06/2008
From:	Scarola J Progress Energy Carolinas, Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PE&RAS-08-037
Download: ML082830137 (23)

Text

UProgress Energy PO Box 1551 411 Fayetteville Street Mall Raleigh NC 27602 10 CFR 50.90 Serial: PE&RAS-08-037 October 6, 2008 United States Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 Q SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302/LICENSE NO. DPR-72 LICENSE AMENDMENT REQUEST TO ELIMINATE WORK HOUR CONTROLS TO SUPPORT COMPLIANCE WITH REVISED 10 CFR 26 Ladies and Gentlemen:

In accordance with the provisions of the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., and Florida Power Corporation (FPC), now doing business as Progress Energy Florida, Inc., hereby submit a request to amend the Technical Specifications (TS) for the facility operating licenses listed above. The TS for the stations listed above include working hour controls in the administrative controls section. The current requirements have been superseded by the requirements of 10 CFR 26, Subpart I, "Managing Fatigue," published March 31, 2008.Removal of work hour controls will support the requirement to be in compliance with 10 CFR 26, Subpart I, no later than October 1, 2009.In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the States of North Carolina, South Carolina, and Florida.CP&L and FPC request that the proposed amendments be issued no later than May 1, 2009, to support implementation concurrent with implementation of the new 10 CFR 26, Subpart I requirements by October 1, 2009.This letter contains one regulatory commitment as identified in Attachment

4.

U. S. Nuclear Regulatory Commission PE&RAS08-037 Page 2 If you have additional questions, please call Donna Alexander at (919) 546-5357 or Brian McCabe at (919)546-4579.I declare under penalty of perjury that the foregoing is true and correct.Executed on: Sincerely, James Scarola S Senior Vice President and Chief Nuclear Officer dba Attachment 1 -Licensees' Evaluation Attachment 2 -Marked-up TS Pages Attachment 3 -Revised TS Pages Attachment 4 -List of Regulatory Commitments cc w/att: Luis Reyes, USNRC Regional Administrator

-Region II Ms. Farideh E. Saba, NRR Project Manager -BSEP, Unit Nos. 1 and 2; CR3 M. Vaaler, NRR Project Manager -SHNPP, Unit No. 1; HBRSEP, Unit No. 2 USNRC Resident Inspector

-BSEP, Unit Nos. 1 and 2 USNRC Resident Inspector

-CR3 USNRC Resident Inspector

-SHNPP, Unit No. 1 USNRC Resident Inspector

-HBRSEP, Unit No. 2 A. A. Gantt, Director, Bureau of Radiological Health (SC)S. E. Jenkins, Manager, Radioactive and Infectious Waste Management Section (SC)Attorney General (SC)Beverly 0. Hall, Section Chief, North Carolina Dept. of Environmental and Natural Resources Chair, North Carolina Utilities Commission Chair, Citrus Country Board of Commissioners William A. Passetti, Chief, Div. of Environmental Health -Bureau of Radiation Control (FL)

U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 1 of 7 Licensees' Evaluation

1.0 Description

2.0 Proposed

Changes 3.0 Background

4.0 Technical

Analysis 5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration

5.2 Applicable

Regulatory Requirements and Criteria 6.0 Environmental Consideration

7.0 References

U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 2 of 7 Licensees' Evaluation

1.0 Description

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., and Florida Power Corporation (FPC), now doing business as Progress Energy Florida, Inc., request amendments to the Facility Operating Licenses listed in the table below.Station Facility Operating License Nos.Brunswick Steam Electric Plant, Unit Nos. 1 and 2 DPR-71 and DPR-62 Shearon Harris Nuclear Power Plant, Unit No. 1 NPF-63 H. B. Robinson Steam Electric Plant, Unit No. 2 DPR-23 Crystal River Unit 3 Nuclear Generating Plant DPR-72 The Technical Specification (TS) of the Operating Licenses listed above currently include controls on working hours.On April 17, 2007, the NRC Commissioners approved a final rule amending 10 CFR Part 26 which, among other changes, established requirements for managing worker fatigue at operating nuclear power plants. Subpart I specifically addresses managing worker fatigue by designating individual break requirements, work hour limits, and annual reporting requirements.

Subpart I was published in the Federal Register (73 FR 16966) on March 31, 2008, with a required implementation period of 18 months. Compliance is, therefore, required by October 1, 2009.2.0 Proposed Changes The proposed changes remove work hour controls and/or references to NRC Generic Letter 82-12 from the Administrative control sections of the TS. CP&L and FPC are proposing to remove these work hour controls from the sections of their station's TS pages listed in the table below.Station TS Section Brunswick Steam Electric Plant, Unit Nos. 1 and 2 5.2.2.e Shearon Harris Nuclear Power Plant, Unit No. 1 6.2.2.f H. B. Robinson Steam Electric Plant, Unit No. 2 5.2.2.e Crystal River Unit 3 Nuclear Generating Plant 5.2.2.e U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 3 of 7 Licensees' Evaluation

3.0 Background

On June 15, 1982, the NRC issued GL 82-12, "Nuclear Power Plant Staff Working Hours," which was a revision of past guidance and discussions regarding the limitation of work hours to mitigate worker fatigue and the impact of fitness-for-duty on safety. GL 82-12 established overtime guidance for work hours beyond a "normal 8-hour day, 40-hour week." Issued prior to GL 82-12, GL 82-02, "Nuclear Power Plant Staff Working Hours," requested that all licensees revise the administrative section of their technical specifications to require that administrative procedures follow policy statement guidelines.

GL 82-12 invoked this request and controls on worker fatigue were incorporated in the TS referenced above.On April 17, 2007, the NRC Commissioners approved a final rule amending Title 10, Part 26, of the Code of Federal Regulations (CFR) which, among other changes, established requirements for managing worker fatigue at operating nuclear power plants. Subpart I specifically addresses managing worker fatigue by designating individual break requirements, work hour limits, and annual reporting requirements.

Subpart I was published' in the Federal Register on March 31, 2008, with a required implementation period of 18 months. Compliance is, therefore, required by October 1, 2009.With the publication of 10 CFR Part 26, these work hour controls are no longer needed in the TS and may be deleted.4.0 Technical Analysis The new rule established by 10 CFR 26, Subpart I supersedes existing worker fatigue guidance.10 CFR 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens requirements for both. Under the new rule, work hour controls include not only work hour limitations for 24-hour, 48-hour, and 7-day periods, but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from controls) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility.

Subpart I also strengthens reporting requirements.

Finally, the new rule's work hour controls scope includes operating and maintenance personnel, as well as those directing operating and maintenance personnel, performing work on risk-significant equipment, health physics and chemistry personnel who are a part of the on-site emergency response organization minimum shift complement, the fire brigade leader or advisor, and security personnel.

U. S. Nuclear Regulatory Commission Attachment 1 ,to Serial: PE&RAS08-037 Licensees' Evaluation Page 4 of 7 Licensees' Evaluation The proposed changes remove working hour controls in the TS in order to support compliance with 10 CFR Part 26, Subpart I. Work hour controls and fatigue management requirements have been incorporated into 10 CFR 26, therefore, it is unnecessary to have work hour control requirements in the TS.Removal of the plant-specific TS requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements.

5.0 Regulatory

Analysis 5.1 No Significant Hazards Consideration CP&L and FPC request amendments to the Facility Operating Licenses listed in the table below.Facility Operating Station License Nos.Brunswick Steam Electric Plant, Unit Nos. 1 and 2 DPR-71 and DPR-62 Shearon Harris Nuclear Power Plant, Unit No. 1 NPF-63 H. B. Robinson Steam Electric Plant, Unit No. 2 DPR-23 Crystal River Unit 3 Nuclear Generating Plant DPR-72 The proposed changes remove work hour controls and/or references to NRC GL 82-12 from the administrative controls section of the TS. These requirements have been superseded by the requirements of 10 CFR 26, Subpart I.According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to. an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) Involve a significant increase in the probability or consequence of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 5 of 7 Licensees' Evaluation CP&L and FPC have evaluated the proposed changes, to the TS for the stations listed above, using the criteria in 10 CFR 50.92, and have determined that the proposed changes do not involve a significant hazards consideration.

The following information is provided to support a finding of no significant hazards consideration.

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

Response:

No The proposed changes remove iTS controls on working hours for personnel who perform safety related functions.

The TS controls are superseded by the worker fatigue requirements in 10 CFR Part 26. Removal of the TS requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements.

The proposed changes do not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected.

The proposed changes do not impact the initiators or assumptions of analyzed events, nor do they impact the mitigation of accidents or transient events.Therefore, it is concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response:

No The proposed changes remove TS controls on working hours for personnel who perform safety related functions.

The TS controls are superseded by the worker fatigue requirements in 10 CFR Part 26. Work hours will continue to be controlled in accordance with NRC requirements.

The new rule allows for deviations from controls to mitigate or prevent a condition adverse to safety or as necessary to maintain the security of the facility.

This ensures that the new rule will not restrict work hours and thereby create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not alter plant configuration, require that new plant equipment be installed, alter assumptions made about accidents previously evaluated, add any initiators, or effect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected.

U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 6 of 7 Licensees' Evaluation Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?Response:

No The proposed changes remove TS controls on working hours for personnel who perform safety related functions.

The TS controls are superseded by the worker fatigue requirements in 10 CFR Part 26. The proposed changes do not involve any physical changes to plant or the manner in which plant systems are operated, maintained, modified, tested, or inspected.

The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined.

The safety analysis acceptance criteria are not affected by this change. The proposed changes will not result in plant operation in a configuration outside the design basis. The proposed changes will not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

Removal of plant-specific TS administrative requirements will not reduce a margin of safety because the requirements in 10 CFR Part 26 are adequate to ensure that worker fatigue is managed. Therefore, it is concluded that these changes do not involve a significant reduction in a margin of safety.Based upon the above, CP&L and FPC conclude that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable

Regulatory Requirements and Criteria The proposed change eliminates the plant-specific TS administrative controls on working hours. The TS guidance has been superseded by 10 CFR Part 26.10 CFR Part 26, Subpart I, "Managing Fatigue," contains requirements for managing worker fatigue at operating nuclear power plants.10 CFR 50.36 (d)(5), "Administrative controls," provides the regulatory requirements for the content required in the administrative controls section of TS. Requirements to control working hours and manage fatigue are not required to be in the Administrative Controls by 10 CFR Part 50.36. Because the requirement to control working hours and U. S. Nuclear Regulatory Commission Attachment 1 to Serial: PE&RAS08-037 Licensees' Evaluation Page 7 of 7 Licensees' Evaluation manage fatigue is now provided in 10 CFR Part 26, Subpart I, it is unnecessary for the TS to contain similar controls.Based on the considerations discussed above, (1) there is a 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 NRC's regulations; and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.6.0 Environmental Consideration A review has determined that the proposed amendments are administrative in nature and do not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and do not change an inspection or surveillance requirement.

The proposed amendments do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (3) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

7.0 References

(1) NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982 (2) VR-SECY-06-0244, "Final Rulemaking

-10 CFR Part 26 -Fitness-for-Duty Programs," dated April 17, 2007 (3) Federal Register, Vol. 73, No. 62, p. 16966, "Fitness for Duty Programs," dated March 31, 2008 (4) NRC Generic Letter 82-02, "Nuclear Power Plant Staff Working Hours," dated February 8, 1982 U. S. Nuclear Regulatory Commission Attachment 2 to Serial: PE&RAS08-037 Marked-up Technical Specification Pages 6 Pages (including cover page)Station Technical Specifications Affected Pages Brunswick Steam Electric Plant, Unit Nos. 1 and 21 5.0-3 Shearon Harris Nuclear Power Plant, Unit No. 1 6-2 H. B. Robinson Steam Electric Plant, Unit No. 2 5.0-3, 5.0-4 Crystal River Unit 3 Nuclear Generating Plant 5.0-3 Since TS 5.2.2.e for Unit 1 and Unit 2 are identical, only the mark-up for Unit 2 is provided.

Organization 5.2 5.2 Organization

5.2.2 Facility

Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, when either unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO)shall be present in the control room. With one unit in MODE 1, 2, or 3 and the other unit defueled, the minimum shift crew shall include a total of two SROs and two ROs.c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e.devel-ed aRd impleweRted te 10 Deleted whe peFfGFF:R Gafety Felated fi -rAmeRs i- ýOs, health physiesists, aw*i1iaFy epeFat9f-,, wokighou guidelines publishd bytc ulcar Regublator ep ffiGemm in GooicLttor 82 12-.f. The operations manager or assistant operations manager shall hold an (SRO license.g. The shift technical advisor shall serve in an advisory capacity to the shift superintendent on matters pertaining to the engineering aspects assuring safe operation of the unit when either unit is in MODE 1, 2, or 3.Brunswick Unit 2 5.0-3 Amendment No. 2-4 I

....AOI4INI STRATIVE CONTROLS UNIT STAFF (Continued)

f. I Deleted by Amendment No.o -.1 S~ MI n-aiaiu requre sbstntia ~iiitau~ uurtiu Li ie usedi, at' during~j s h a l la i a r -l b a~ W in , stru~hexcluding shift t urover tirver 2. An indivii-dima1should mat be permtea ~~mr hn1 oa 4A a.ny 14-ho5urp-pried, nrMW r then 24I huri n48hw'ru~, Willa %I 1&111w%&.-

MY an 7 e.,prkd, ll slýi hi f t- tarue Itfaeu.ARIA e osiee4~ ui CAN1t1ia bae anot for thle-entire ~ t WtWI k% a hit-period ex u ~ ~ s t t-1 i. a ve- Ii a ........ ...... ..... ~ a i Any e~iaion rom he bc~eguidline zhal b aul ericu by-e--inluded in the nal llrnigth cita. otu::ul-o---

41111111 A _M4 I .'1m- 1 4s Ill4 a -- --- -!I A-0 .1116 I 11 11c :I! IN I 1 11 Ii -ill 11 11 !1 1 1 iiiii1i I 11,1A I I'll, I .!1 11 i --a I a 1 .41 %6`11, w~~i~re that excmulvo ho~..r2 hw;e not been a231~fled.

Routine itauj ati an fr~ th: ~~!@ r.1 deli nco Is net authorized.

SHE4AHN HARRIS -UNIT I1, 6.-2 Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) operator shall be assigned to the shift crew while the unit is operating in MODES 1. 2, 3, or 4.b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1. 2, 3; or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specification 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified as a radiation control technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e. ]Deleted&b!e deve'l.oped andýn t staff , m safety~xiiar Cpratrsand key-mai-ntcmnacee-persorfit.-

Adequate sit c1VVragc shall be maitained without routine-h~avy us cf ....im. Th bec__h01b t ae operating personnel workl a 12 heur day, neminal 40 hou- week-while the unit is operating.

"-'h-, "- -'- thaL..r.esee .pr"m re q ue sutntil a mountsI allelu n 1f evert. e Lo be uud, yr uurdoy Ingextende pero ,ds of shtd wrI F1r refulin. maor aitenance, or major- plant modificati~on,-

on... teoar.y basis the following gaidie! hies a bs-fol 1owed.1. ... a should ,,t be-ped to .... ' -I IIII Shurs ..... .. exl.d..t. "never time,ft (continued)

HBRSEP Unit No. 2 5.0-3 Amendment No. 1-76--

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) 2 A , ,duvidtm shoul d note permitted to work mere than 16h in any 24hor ,v, i",, neor ,orc t...han 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> i any 43 hou period, nor more thn , -72 ou i ay 7 day peerid, all ex^luding shift turnIver -.tie 3. A break of at least 0hours should be allowed-between-work perieds, icluding shift turnover-t.im-

4. Except during extendcd shutdown periods. the ue e time shoeul-d-bo cnsidered en nindividual basisx and nnt fnr the entire staff on a shift.Any deviation fro-m the above guidelines shall be ed-in a _-c by the Plant Manager or his ,A,-,, in acorane ith approeved admin~iStraiv przdrs rbY-highern levcli o-rn, agmen. in aeeer-darne with stbli ;hsaled p-1 ocedures-and vith d.....ttion of t-he. bis for. grFAnting the deviatlon.

Ceotiols shall be ,inc.luded i,, the pioUeduies suLh that individual overt-ime shl orvee othly by the Plant Managcr oc to ensure that hessiv hours have nut been assigned.

Routin d t from the above.idines is not authorized.

f. The Operations Manager or Superintendent in charge of the operations shift crews shall hold an SRO license.g. During MODES 1. 2, 3, and 4, the shift technical advisor (STA) shall provide advisory technical support to the SSO with regard to the safe operation of the unit. If an individual that holds an SRO license also meets the STA requirements, that individual may act in both capacities.

HBRSEP Unit No. 2 5.0-4 Amendment No. +7f-Organi zati on 5.2 5.2 Organization 5.2.2 Unit Staff (continued) an additional auxiliary nuclear operator shall be assigned in MODES 1, 2, 3 and 4.b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.d. An individual qualified in Radiation Protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e. The amount of vcert.me w.r..-d by unit staff- members.performing safety rclated funeteio.

shall be ..........

cpnmtr-ell1 d in aEccrdancc with app roevd admi ni str-at vc p~eEeduwe&s-.

Crystal River Unit 3 5.0-3 Amendment No. -144 U. S. Nuclear Regulatory Commission Attachment 3 to Serial: PE&RAS08-037 Revised Technical Specification Pages 7 Pages (including cover page)Station Technical Specifications Affected Pages Brunswick Steam Electric Plant, Unit Nos. 1 and 2 5.0-3 Shearon Harris Nuclear Power Plant, Unit No. 1 6-2 H. B. Robinson Steam Electric Plant, Unit No. 2 5.0-3, 5.0-4 Crystal River Unit 3 Nuclear Generating Plant 5.0-3 Organization 5.2 5.2 Organization

5.2.2 Facility

Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, when either unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO)shall be present in the control room. With one unit in MODE 1, 2, or 3 and the other unit defueled, the minimum shift crew shall include a total of two SROs and two ROs.c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.g for a period of time. not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e. Deleted f. The operations manager or assistant operations manager shall hold an SRO license.g. The shift technical advisor shall serve in an advisory capacity to the shift superintendent on matters pertaining to the engineering aspects assuring safe operation of the unit when either unit is in MODE 1, 2, or 3.Brunswick Unit 1 5.0-3 Amendment No. I Organization 5.2 5.2 Organization

5.2.2 Facility

Staff (continued)

b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, when either unit is in MODE 1, 2, or 3, at least one licensed Senior Reactor Operator (SRO)shall be present in the control room. With one unit in MODE 1, 2, or 3 and the other unit defueled, the minimum shift crew shall include a total of two SROs and two ROs.c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specifications 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e. Deleted f. The operations manager or assistant operations manager shall hold an SRO license.g. The shift technical advisor shall serve in an advisory capacity to the shift superintendent on matters pertaining to the engineering aspects assuring safe operation of the unit when either unit is in MODE 1, 2, or 3.Brunswick Unit 2 5.0-3 Amendment No. I UNIT STAFF (Continued)

f. Deleted by Amendment No.SHEARON HARRIS -UNIT 1 6-2 AMENDMENT NO.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued) operator shall be assigned to the shift crew while the unit is operating in MODES 1, 2, 3, or 4.b. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.c. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and Specification 5.2.2.a and 5.2.2.g for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

d. An individual qualified as a radiation control technician shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.e. Deleted (continued)

HBRSEP Unit No. 2 5.0-3 Amendment No.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The Operations Manager or Superintendent in charge of the operations shift crews shall hold an SRO license.g. During MODES 1, 2, 3, and 4, the shift technical advisor (STA) shall provide advisory technical support to the SSO with regard to the safe operation of the unit. If an individual that holds an SRO license also meets the STA requirements, that individual may act in both capacities.

HBRSEP Unit No. 2 5.0-4 Amendment No.

Organi zati on 5.2 5.3 Organization 5.2.2 Unit Staff (continued) an additional auxiliary nuclear operator shall be assigned in MODES 1, 2, 3 and 4.b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.

c. At least one licensed Reactor Operator (RO) shall be present in the control room when fuel is in the reactor. In addition, while the unit is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator (SRO) shall be present in the control room.d. *An individual qualified in Radiation Protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.Crystal River Unit 3 5.0-3 Amendment No.

U. S. Nuclear Regulatory Commission Attachment 4 to Serial: PE&RAS08-037 List of Regulatory Commitments Page 1 of 1 The following table identifies those actions committed by CP&L and FPC in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Commitment Schedule Removal of the plant-specific TS This commitment will be completed no requirements will be performed later than October 1, 2009.concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements.