JAFP-16-0142, Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 2

Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 2

ML16263A237
Person / Time
Site:	FitzPatrick
Issue date:	09/19/2016
From:	Brian Sullivan Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF7280, JAFP-16-0142
Download: ML16263A237 (18)

Text

JAFP-16-0142 ATTACHMENT 1RESPONSE TO OPEN ITEMS(3 Pages)

JAFP-16-0142Attachment 1 Response to Open ItemsPage 1 of 3REGARDING PROPOSED CHANGES TO TECHNICAL SPECIFICATIONADMINISTRATIVE CONTROLS FOR STAFFING AND TRAINING UPONPERMANENT CESSATION OF OPERATIONJAMES A. FITZPATRICK NUCLEAR POWER PLANTENTERGY NUCLEAR OPERATIONS, INCDOCKET NO. 50-333RENEWED FACILITY OPERATING LICENSE NO. DPR-59By letter dated January 15, 2016 [Reference 1], Entergy Nuclear Operations, Inc. (ENOI)submitted a proposed amendment to renewed facility operating license DPR-059 to revise theTechnical Specification (TS) administrative controls for staffing and training upon permanentremoval of fuel from the reactor vessel at the James A. FitzPatrick Nuclear Power Plant (JAF).On June 3, 2016, ENOI submitted Supplement 1 of the proposed License Amendment torespond to an U.S. Nuclear Regulatory Commission (NRC) request for additional information[Reference 2]. On August 15, 2016 [Reference 3], the NRC identified several open itemsassociated with that response. These specific open items are addressed below:RAI-1, Item (f)The NRC staff asked the licensee to provide additional information regarding theminimum qualifications for the "Non-Certified Operator" position. The licensee clarifiedduring the phone call that the terminology "non-certified operator" is used todifferentiate that individual from a Certified Fuel Handler. The licensee further stated thatVermont Yankee used the same terminology in its application (which the staffsubsequently verified to be correct). Our concern is that "non-certified operator" is notdefined anywhere (not in the TS, ANSI/ANS 3.1-1978 standard, etc.) The staff'ssuggestion to the licensee during the phone call was that they consider adding adefinition somewhere (in the TSs or some other appropriate place).ResponseSection 1.1 of the JAF TS has been modified to include the following definition for NON-CERTIFIED OPERATOR:"A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with thequalification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER."In addition, Sections 5.2.2.a and 5.2.2.f of the JAF TS, as previously modified in References 1and 3, are modified to define that the term NON-CERTIFIED OPERATOR is a definition byplacing it in all caps in accordance with the Note in JAF TS 1.1.The changes are depicted in Attachments 2 and 3.

JAFP-16-0142Attachment 1 Response to Open ItemsPage 2 of 3RAI-1, Item (g)The NRC staff asked the licensee why there are no additional provisions in TS 5.2.2.b toensure that the shift crew composition is not below minimum requirements when fuelmovements are in progress, movements of loads over fuel are in progress, or shiftturnover is in progress. The licensee stated during the phone call that they modeled theirapplication after Crystal River, which was the last STS plant to undergodecommissioning, and their TS did not include such provisions. During the phone call,the licensee indicated that they principally agreed that the shift crew composition shouldnot fall below minimum requirements during fuel movements, load movements, and shiftturnover (however, they plan on controlling this administratively, as stated in theirwritten response). The staff's suggestion to the licensee was that they consider addingsuch provisions to the TS.ResponseSection 5.2.2.b of JAF TS is modified to state:"Shift crew composition may be less than the minimum requirements of 5.2.2.a for a periodof 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 shiftcrew members provided immediate action is taken to restore the shift crew composition towithin the minimum requirementsand all of the following conditions are met:1) No fuel movements are in progress;2) No movement of loads over fuel are in progress; and3) No unmanned shift positions during shift turnover shall be permitted while theshift crew is less than the minimum

."The text presented inbold and italics is added to address this open item. The changes aredepicted in Attachments 2 and 3.RAI-5The NRC staff asked the licensee what was meant in its RAI response by "ENOI haselected not to include 'CERTIFIED FUEL HANDLER' in JAF TS Section 1.1 at this time -"The licensee stated that its defueled TS LAR had been put on hold and that they hadchosen Crystal River as a template because it was the most recent ITS plant. Thisdefinition is not in the Crystal River defueled TSs. The NRC staff noted that this may havebeen an oversight in the CR3 TSs, as it is included in the Kewaunee, SONGS, and VYTSs, and therefore, the NRC staff's preference would be to include this definition in theTSs. During the phone call, the licensee agreed to include the definition in its current TSrevision. The NRC staff would also consider an option for the licensee to provide astatement that this definition will be included as part of the future defueled TS LAR.

JAFP-16-0142Attachment 1 Response to Open ItemsPage 3 of 3ResponseSection 1.1 of the JAF TS has been modified to include the following definition for CERTIFIEDFUEL HANDLER:"A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of theCERTIFIED FUEL HANDLER training program."In addition, Sections 5.2.1.d, 5.2.2.a, 5.2.2.d, 5.2.2.e, 5.2.2.f, 5.3.2 of the JAF TS, as previouslymodified in References 1 and 3, are modified to define that the term CERTIFIED FUELHANDLER is a definition by placing it in all caps in accordance with the Note in JAF TS 1.1.The changes are depicted in Attachments 2 and 3.REFERENCES 1.ENOI letter to the NRC, "License Amendment Request - Revision to TechnicalSpecification Administrative Controls for Permanently Defueled Condition,"JAFP-15-0143, dated January 15, 2016 (ADAMS Accession No. ML16015A456) 2.ENOI letter to the NRC, "Response to Request for Additional Information (RAI)Regarding Revision to Technical Specification (TS) Administrative Controls for Staffingand Training Upon Permanent Cessation of Operation (CAC No. MF7280) -Supplement 1," JAFP-16-077, dated June 3, 2016 (ADAMS Accession No.ML16155A326) 3.Email from T. Wengert (NRC) to P. Couture (ENOI), "FitzPatrick - Open Issues following8/3/16 Clarification Call Concerning TS Admin Controls LAR (CAC No. MF7280)," datedAugust 15, 2016 JAFP-16-0142 ATTACHMENT 2MARK-UP OF JAMES A. FITZPATRICKTECHNICAL SPECIFICATION PAGESTS 1.1-1 (Current TS Page)TS 1.1-4 (Current TS Page)TS 5.2-1 (Mark-up of Previously Modified Page)TS 5.2-2 (Mark-up of Previously Modified Page)TS 5.3-1 (Mark-up of Previously Modified Page)

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)CHANNEL CALIBRATION CHANNEL CHECK 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 assembly at the specified height divided by the number of fuel rods in the fuel assembly 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 be performed by means of any series of sequential, overlapping, or total channel steps.A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation.

This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.(continued)

JAFNPP 1.1-1 Amendment 274 Definitions 1.1 1.1 Definitions (continued)

LINEAR HEAT GENERATION RATE (lHGR) LOGIC SYSTEM FUNCTIONAL TEST MINIMUM CRITICAL POWER RATIO (MCPR) MODE OPERABLE -OPERABILITY PRESSURE AND TEMPERATURE LIMITS REPORT (pTLR) The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY.

The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested. The MCPR shall be the smallest critical power that exists in the core for each type of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power. A MODE shall correspond to anyone inclusive combination of mode switch position, average reactor coolant temperature, and reactor vessel head closure bolttenslonlng specified in Table 1.1-1 with fuel in the reactor vessel. 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). 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. (continued)

JAFNPP 1.1-4 Amendment 2q2 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization (continued)

JAFNPP 5.2-1 Amendment 5.2.1 Onsite and Offsite Organizations 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 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 these

Technical Specifications, shall be documented in the UFSAR;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 the nuclear fuel;c.A specified corporate officer shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in

operating, maintaining, and providing technical support to the

facility to ensure safe management of nuclear fuel; andd.The individuals who train the Certified Fuel Handlers, carry out radiation protection, 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.5.2.2Facility Staff The facility staff organization shall include the following:

a.Each duty shift shall be composed of at least one shift supervisorand one Non-certified Operator.

The Non-ertified Operator positionmay be filled by a Certified Fuel Handler.

Organization 5.2 JAFNPP 5.2-2 Amendment XXX 5.2 Organization 5.2.2 Facility Staff (continued) b. Shift crew composition may be less than the minimum requirements of 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. A radiation protection technician shall be on site during the movement of fuel and during the movement of loads over fuel. 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. d. Oversight of fuel handling operations shall be provided by a Certified Fuel Handler. e. The shift supervisor shall be a Certified Fuel Handler. f. At least one person qualified to stand watch in the control room (Non-Certified Operator or Certified Fuel Handler) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.

Facility Staff Qualifications 5.3

5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications

5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with

exceptions specified in the Quality Assurance Program Manual (QAPM).

5.3.2 An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained.

JAFNPP 5.3-1 Amendment 274

JAFP-16-0142 ATTACHMENT 3RE-TYPED JAMES A. FITZPATRICK TECHNICAL SPECIFICATIONPAGESTS 1.1-1TS 1.1-4TS 5.2-1TS 5.2-2TS 5.3-1 Definitions 1.1 JAFNPP 1.1-1 Amendment XXX 1.0 USE AND APPLICATION 1.1 Definitions

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

Term Definition ACTIONS Actions shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times. AVERAGE PLANER LINEAR HEAT GENERATION RATE (APLHGR) 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 assembly at the specified height divided by the number of fuel rods in the fuel assembly at the height. CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training program CHANNEL CALIBRATION 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. CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

(continued)

Definitions 1.1 JAFNPP 1.1-4 Amendment XXX 1.1 Definitions (continued)

LINEAR HEAT GENERATION RATE (LHGR)The LHGR shall be the heat generation rate per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. LOGIC SYSTEM FUNCTIONAL TESTA LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all logic components required for OPERABILITY of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.MINIMUM CRITICAL POWER RATIO (MCPR) The MCPR shall be the smallest critical power that exists in the core for each type of fuel. The CPR is that power in the assembly that is calculated by application of the appropriate correlation(s) to cause some point in the assembly to experience boiling transition, divided by the actual assembly operating power.MODE 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 a non-licensed operator who complies with the qualification requirements of Specification 5.3.1, but is not a CERTIFIED FUEL HANDLER. 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) 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.

(continued)

Organization 5.2 JAFNPP 5.2-1 Amendment XXX 5.0 ADMINISTRATIVE CONTROLS

5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be establish 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 operating organization positions. These relationships shall be documented and updated, as appropriate, in organizations 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 these Technical Specifications, shall be documented in the UFSAR;

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 the nuclear fuel;

c. A specified corporate officer shall have corporate responsibility for the safe storage and handling of nuclear fuel and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure safe management of nuclear fuel; and

d. The individuals who train the CERTIFIED FUEL HANDLERS, carry out radiation protection, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organization freedom to ensure their ability to perform their assigned functions.

5.2.2 Facility Staff The facility staff organization shall include the following:

a. Each duty shift shall be composed of at least one shift supervisor and one NON-CERTIFIED OPERATOR. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

(continued)

Organization 5.2 JAFNPP 5.2-2 Amendment XXX 5.2 Organization 5.2.2 Facility Staff (continued) b. Shift crew composition may be less than the minimum requirements of 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 and all of the following conditions are met: 1) No fuel movements are in progress; 2) No movement of loads over fuel are in progress; and 3) No unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum. c. A radiation protection technician shall be on site during the movement of fuel and during the movement of loads over fuel. 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. d. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER. e. The shift supervisor shall be a CERTIFIED FUEL HANDLER.

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

Facility Staff Qualifications 5.3 JAFNPP 5.3-1 Amendment XXX 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM). 5.3.2 An NRC approved training and retraining program for CERTIFIED FUEL HANDLERS shall be maintained.