ML14045A001

2014/02/12 NRR E-mail Capture - RAI: Adminstrative Controls

ML14045A001
Person / Time
Site:	Crystal River
Issue date:	02/12/2014
From:	Gratton C Plant Licensing Branch IV
To:	Westcott D Duke Energy Corp
References
Download: ML14045A001 (2)

Text

1 NRR-PMDAPEm Resource From: Gratton, Christopher Sent: Wednesday, February 12, 2014 4:27 PM To: Westcott, Daniel (Daniel.W estcott@duke-energy.com)

Cc: Rose, Philip (Philip.Rose@duke-energy.com)

Subject:

RAI: Adminstrative Controls DUKE ENERGY FLORIDA, INC. CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGES TO THE ADMINISTRATIVE CONTROLS SECTION OF THE TECHNICAL SPECIFICATIONS DOCKET NO. 50-302

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 25, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13128A286), supplemented by letter dated September 4, 2013, (ADAMS Accession No. ML13255A056) Duke Energy Florida, Inc. (DEF, the licensee), submitted a license amendment (LAR) to revise portions of Section 5.0, "Administrative Controls," of the Crystal River Unit 3 (CR3) Technical Specifications (TSs

). The NRC staff finds that additional information is needed to complete its review:

Title 10 of the Code of Federal Regulations (10 CFR), Section 20.1601, requires licensees to control access to High Radiation Areas (HRA, or areas > 100 millirem (mrem)/hour (hr)). This regulation is fairly prescriptive but does allow licensees (per 10 CFR 20.1601(c)) to request alternate controls. All power reactor licensees have adopted alternate controls that relieve the requirement to lock HRAs, unless they have dose rates > 1000 mrem/hr. In other words, these licensees do not need to lock HRAs from 100 mrem/hr to 1000 mrem/hr if they impl ement the compensatory requirements of the TSs.

In the 1990 revision to 10 CFR 20, the NRC defined a Very High Radiation Area (VHRA) as an area with dose rates > 500 rad/hr and added 10 CFR 20.1602 to require more stringent controls in addition to those required by 10 CFR 20.1601. The NRC subsequently revised the Standard Technical Specifications to clarify that the alternate controls approved in the TS did not apply to VHRAs.

Sections 5.8.2 and 5.8.3 of the proposed CR3 TS state that the alternate controls specified in each apply to "areas with radiation levels > 1000 mrem/hr at 30 cm." A plain reading of these would include areas greater than 500 rad/hr (e.g., a Very High Radiation Area), which is not consistent with Part 20.

Please clarify how the proposed wording meets the requirements of 10 CFR 20.1602, or propose wording that complies with the requirements of 10 CFR 20.1602.

Please call 301-415-1055 if you would like to set up a conference call to clarify the request for information. To complete its review, the NRC staff requests the following additional information be provided by February 28, 2014.

Hearing Identifier: NRR_PMDA Email Number: 1095 Mail Envelope Properties (Christopher.Gratton@nrc.gov20140212162700)

Subject:

RAI: Adminstrative Controls Sent Date: 2/12/2014 4:27:05 PM Received Date: 2/12/2014 4:27:00 PM From: Gratton, Christopher Created By: Christopher.Gratton@nrc.gov Recipients: "Rose, Philip (Philip.Rose@

duke-energy.com)" <Philip.Rose@duke-energy.com> Tracking Status: None "Westcott, Daniel (Daniel.Westcott@duke-energy.com)" <Daniel.Westcott@duke-energy.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 2521 2/12/2014 4:27:00 PM

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