ML19319C830

Tech Spec Change Request 10b Re Tech Specs 6.8-6.12,updating Reporting Requirements

ML19319C830
Person / Time
Site:	Crystal River
Issue date:	09/28/1977
From:	FLORIDA POWER CORP.
To:
Shared Package
ML19319C823	List: ML19319C822 ML19319C830
References
NUDOCS 8003040794
Download: ML19319C830 (9)

Text

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Technical Specification Change Request No.10b Replace page XVI and 6-13 through 6-15 with the attached replacement pages XVI, and 6-13 through 6-19.

Reason for Proposed Change The NRC has initiated a program to update the reporting requirements specified in technical specifications of power reactor licensees. The NRC, in their letter to Florida Power Corporation, dated August 4,1977, indicated that the reference in the Crystal River #3 Technical Specifi-cations to Regulatory Guide 1.16 should be replaced with words from Regulatory Guide 1.16 that are appropriate and applicable. This change would delete mandatory reporting of Events of Potential Public Interest and use of reporting Forms contained in the referenced Regulatory Guide.

The NRC letter of September 19, 1977 requested FPC to modify the CR#3 Technical Specifications to eliminate the requirements for an Annual Operating Report. Their September 19, 1977 letter also requested FPC to modify the content of our Monthly Operating Report starting with our monthly report for January 1978. These changes will significantly reduce paperwork and eliminate unnecessary information. -

The attached proposed Technical Specifications for Crys,tal River #3 are being submitted in response to the Commission's requests of August 4,1977 and September 19, 1977. The revised Monthly Operat-ing Report format will be used by Florida Power Corporation beginning with our monthly report for January 1978.

Safety Analysis Justifying Procosed Chance None of the requirements applicable to the Safety Analysis are diminished by the proposed changes and no unreviewed safety question is involved.

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. INDEX ADMINISTRATIVE CONTROLS SECTION PAGE

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Meeting Frequency...................................... .6-9 Quorum................................................. 6-9 Review................................................. 6-9 Audits................................................. 6-10 -

Au tho r i ty . . . . . . . . . . . . . . . . . . . . . . . t . . . . . . . . . . . . . . . . . . . . . . 6-10 Records................................................ 6-11 6.6 REPORTABLE OCCURRENCE ACTI0N............................ 6-11 6.7 SAFETY LIMIT VI0LATION.................................. 6-12 .

6.8 PROCEDURES.............................................. 6-12 6.9 REPORTING REQUIREMENTS 6.9.1 ROUNTINE AND REPORTABLE OCCURRENCES............... 6-13 Startup Report......................................... 6-13 Occupational Exposure Data ............................ 6-14 Monthly Operating Report............................... 6-15.

Reportable Occurrences................................. 6-15

, Frompt Notification with Written Followup.............. 6-15 t

Thirty Day Written Reports............................. 6-16 6.9.2 SPECIAL REP 0RTS................................... 6-17 6.10 RECORD RETENTION....................................... 6-18 j

,6.11 RADIATION PROTECTION PR0 GRAM........................... 6-19 6.12 HIGH RADIATION AREA ,.................................. 6-19 CRYSTAL RIVER - UNIT 3 XVI

J AD'ilNISTRATIVE CONTROLS 6.8.3 Temporary chances to procedures of 6.8.1 above may be made pro-vided:

a. The intent of the originial procedure is not altered.

b. The channe is approved by two members of the plant mananement staff, at least one of whom holds a Senior' Reactor Ooerator's License on the unit affected.

c. The chance is documented. reviewed by the PRC and approved by the Nuclear Plant Manager within 14 days of implementation.

6.9 REPORTING REGUIRE'1ENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the aoplicable reportina requirements of Title 10, Code of Federal Requiations, the following reports shall be submitted to the Director of the Recional Office of Inspection and Enforcement unless otherwise noted.

STARTUP REPORT 6.9.1.1 A summary report of plant startup and oower escalation testina shall be submitted followina (11 receipt of an operatina license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different desian or has been manu-factured by a different fuel sunplier, and (4) modifications that may l have significantly altered the nuclear, thermal, or hydraulic rerfor- l mance of the plant. The reoort shall address each of the test identi fied in the FSAR and shall include a description of the neasured values of the operatinq conditions or characteristics obtained durinq the test procram and a comparison of these values with design predictions and specifica-tions. Any corre'ctive actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be in-cluded in this report.

6.9.1.2 Startup reports shall be submitted within (1) 40 days followina ,

completion of the startup test pronram, (2) 90 days followino resumption

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i or commencement of commercial power operation, or (3) 9 months followina l initial criticality, whichever is earliest. If the Startup ?.eport does I not cover all three events (i .e. , initial criticality, comoleticn of startup test procram, and resumotion or commencement of commercial cKYSTAL RIVER - UNIT 3 6-13'

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ADMINISTRATIVE CONTROLS power operation), supplementary reports shall be submitied at least every three months until all three events have been completed.

OCCUPATIONAL EXPOSURE DATA 6.9.1.3 A tabulation on an annual basis aof the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem /yr and their associated man rem exposure accord-ing to work and job functions,l/ e.g., reactor. operations and sur-veillance, inservice inspection, routine. maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures . totalling less than 20% of the individual total dose need not be accounted for.

In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions.

1/ This tabulation supplements the requirements of 20.407 of 10 CFR Part 20.

CRYSTAL RIVER - UNIT 3 6-14 l

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ADMINISTR.4TIVE CONTROLS MONTHLY OPERATING REPORT 6.9.1.4 Routine reports of operating statistics and shutdown experience shall be submitted on a monthly basis to the Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20$55, with a copy to the Regional Office, .to arrive no later than the tenth of each month following the calendar month covered by the report.

REPORTABLE OCCURRENCES ,

6. 9 .1.5 The REPORTABLE' 0CCURRENCES of Specifications 6.9.1.6 and 6.9.1.7 -

below, including corrective actions and measures to prevent recurrence, shall be reported to the NRC. Supplemental reports may be required to fully describe final resolution of occurrence. In case of corrected or tupplemental reports, a licensee event report shall be completed and reference shall be made to the original report date.

PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP 6.9.1.6 The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Director of the Regional Office, or his designate no later than the first working day following the event, with a written .

followup report within two weeks. The written followup report shall include, as a minimum, a completed copy of a licensee event report form.

Information provided on the licensee event report form shall be supple-mented, as needed. .by additional narrative material to provide complete explanation of the circumstances surrounding the event.

a. Failure of the reactor protection system or other systems subject to limiting safety system settings to initiate the required protective function by the time a monitored para-meter reaches the setpoint specified as the limiting safety system setting in the technical specifications or failure to complete the required protective function,

b. Operation of the unit or affected systems when any parameter or operation subject.to a limiting condition for operation is.less conservative than the least conservative aspect of the limiting condition for operation established in the technical specifications.

c. Abnormal degradation discovered in fuei cladding, reactor coolant pressure boundary, or primary containment.

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ADMINISTRATIVE CnNTROLS

d. Reactivity anomalies involvina disaqreement with the credicted value of reactivity balance under steady state conditions during power operation greater than or equal to 17, ak/k; a calculated reactivity balance indicating a -SHUTDOWN MARGIN less conservative than specified in the technical specifica-tions; short-term reactivity increases that correspond to a reactor period of less than 5 seconds or, if subcritical, an unolanned reactivity insertion of more than 0.5?, ak/k; or occurrence of any unplanned criticality.

e. Failure or malfunction of one or more components which orevents or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the SAR.

f. Personnel error or procedural inadequacy which prevents or coul.d prevent, by itself, the fulfillment of the functional require- ,

ments of systems required to cope with accidents analyzed in the SAR.

g. Conditions arising from natural or man-made events that, as a -

direct result of the event require plant shutdown, operation of safety systems, or other protective measures required by technical specifications.

h. Errors discovered in th~e transient or accident analyses or in the meth3ds used for such analyses as described in the safety analysis report or in the bases for the technical specifications that have or could have permitted reactor operation in a manner less conservative than assuned in the analyses.

i. Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the safety analysis report or technical specifica-tions bases; or discovery durina plant life of conditions not specifically considered in the safety analysis report or technical specifications that require remedial action or cor-rective measures to prevent the existence or development of an unsafe conditicn.

THIRTY DAY HRITTEN REPORTS 6.9.1.7. The types of events listed below shall be the subject of written reports to the Director of the Regional Office within thirty days of l

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ADMINISTRATIVE CONTROLS occurrence of the event. . The written report shall include, as a minimum, a completed copy of a licensee event report form. Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.

a. Reactor protection system or engineered safety feature instrument settings which are found to be less conservative than those established by the technical specifications but which do not prevent the fulfillment of the functional requirements of affected systems.

b. Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.

c. Observed inadequacies in the implementation of administrative or procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.

d. Abnormal degradation of systems other than those specified in 6.9.1.6.c above designed to contain radioactive material resulting from the fission process.

SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Director of the Office of Inspection and Enforcement, Region II, within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification:

a. ECCS Actuation, Specification 3.5.2 and 3.5.3.

b. Inoperable Seismic Monitoring Instrumentation, Specification 3.3.3.3.

c. Inoperable Meteorological Monitoring Instrumentation, Specification 3.3.3.4.

d. Seismic event analysis, Specification 4.3.3.3.2.

e. Inoperable Fire Detection lionitoring Instrumentation, Specification 3.3.3.7.

f. Inoperable Fire Suppression System, Specifications 3.7.11.1, 3.7.11.2 and 3.7.11.3.

CRYSTAL RIVER - UNIT 3 6-17

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ADMINISTRATIVECONTROL$

i 5.10 RECORD RETENTION .

5.10.1 The following records shall be retained for at least five years:

r. . Records and logs Of facility' operation ~ covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, ,

repair and replacement of principal items of equipment related  !

to nuclear safety. .

c. All REPORTABLE OCCURRENCES submitted to the Ccamission.

d. Records of surveillance activities, inspectier.s and calibrations required by these Technical Specifications.

e. Records of reactor tests and experiments.

f. Records of changes made to Operating Procedures.

g. Records of radioactive shipments.

h. Records of sealed source and fission detector leak tests and resul ts .

i. Records of annual physical inventory of all sealed source material of record.

6.10.2 The following records shall be retained for the duration of the Facility Operating License:

a. Records and drawing changes reflecting facility design modifi-cations made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers and assemoly burnup histories.

c. Records of ' facility radiation and contamination surveys.

d. Records of radiaticn exposure for all individuals entering radiation control areas.

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e. Records of gaseous and liquid radioactive material released to the environs.

f. Records of transient or operational cycles for those facility components identified in Taole 5.7.-l.

g. Records of training and qualification for current members of the plant staff,

h. Records of inservice inspections performed pursuant to these Technical Specifications.

i. Records of Q'uality Assurance activities required by the QA Manual.

j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59. .

k. Records of meetings of the PRC and the NGRC.

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared con-sistent with the recuirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATICN AREA 6.12.1 In lieu of the " control device" or " alarm signal" required by

. paragraph 20.203(c) (2) of 10 CFR 20:

a. A High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or grcup of individ-uals permitted to enter such areas shall be provided with a radiation monitoring device wnich continuously indicates the radiation dose rate in the area.

b. A High Radiation Area in which the intensity of radiation is greater than 1000 mrem /hr shall be subject to the pro-visions of 6.12.la above, and in addition locked doors shall be provided to prevent unauthori::ed entry into such areas.

The keys shall be maintained under the administrative control of the Health Physics Supervisor with one key assigned to the administrative control of Shift Supervisor on duty.

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