ML14178B284

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Response to Requests for Additional Information and Supplement 2 to License Amendment Request #316, Revision 0
ML14178B284
Person / Time
Site:  Duke Energy icon.png
Issue date: 06/17/2014
From: Elnitsky J
Duke Energy Florida
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0614-01 TAC MF3089
Download: ML14178B284 (12)
v • d • e


Text

DUKE Crystal River Nuclear Plant 15760 W. Power Line Street ENERGY. Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.90 June 17, 2014 3F0614-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 -Response to Requests for Additional Information and Supplement 2 to License Amendment Request #316, Revision 0

References:

1. CR-3 to NRC letter dated October 29, 2013, "Crystal River Unit 3 -License Amendment Request #316, Revision 0, Revise and Remove License Conditions and Revision to Improved Technical Specifications to Establish Permanently Defueled Technical Specifications" (ADAMS Accession No.ML13316C083)
2. NRC to CR-3 Electronic Mail dated May 9, 2014, "MF3089 -Defueled TS Amendment Request for Additional Information," (ADAMS Accession No.ML14132A205)

Dear Sir:

Pursuant to 10 CFR 50.90, Duke Energy Florida, Inc. (DEF) hereby provides the Response to Requests for Additional Information (RAIs) regarding License Amendment Request (LAR) #316, Revision 0. In Reference 1, Crystal River Unit 3 (CR-3) proposed changes to the Facility Operating License (FOL) and the Improved Technical Specifications.

This correspondence also provides Supplement 2 to LAR #316 providing replacement pages for the Permanently Defueled Technical Specifications.

In Reference 2, the NRC provided RAIs regarding proposed changes to Improved Technical Specification Sections 1.0, 2.0, and 3.0. Attachment A to this letter contains the responses to the RAIs. Attachment B to this letter contains Supplement 2 to LAR #316 which changes the original proposals for revising Limiting Condition for Operations 3.0.1 and 3.0.2.The conclusions of the LAR #316 No Significant Hazards Consideration and the Environmental Impact Evaluation contained in Reference 1 are not affected by, and remain applicable to, this Supplement.

There are no new regulatory commitments made within this submittal.

The CR-3 Plant Nuclear Safety Committee has reviewed this Supplement and recommended it for approval.If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Manager, Nuclear Regulatory Affairs, at (352) 563-4796.Aj02/

U. S Nuclear Regulatory Commission Page 2 of 2 3F0614-01 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 17, 2014.r jec M gy, emeta Cnt ject Management and Construction JE/scp Attachments:

A. Response to Requests for Additional Information B. Supplement 2 to LAR #316 Revision 0 C. Proposed Technical Specification Page Changes, Strikeout and Shadowed Text Format D. Proposed Technical Specification Page Changes, Revision Bar Format xc: NRR Project Manager Regional Administrator, Region I DUKE ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #316, REVISION 0 ATTACHMENT A RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION U. S Nuclear Regulatory Commission Attachment A 3F0614-01 Page 1 of 3 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION In letter dated October 29, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13316C083), Duke Energy Florida, Inc., (the licensee) submitted a License Amendment Request (LAR) regarding Crystal River Unit 3 [CR-3] Facility Operating License. The amendment proposes to remove or revise certain License Conditions that are no longer applicable to CR-3 in the permanently defueled condition.

In addition, the LAR proposes to extensively revise the CR-3 Improved Technical Specifications in order to create the CR-3 Permanently Defueled Technical Specifications (PDTS).The NRC staff has reviewed the licensee's proposed changes to TS sections 1.0, 2.0, and 3.0 and identified the need for additional information as explained below: Proposed chanae in Limiting Condition for Operations (LCO) 3.0.1: LCO 3.0.1 currently states, "LCOs shall be met during the MODES or other-specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7 and LCO 3.0.8." One of the proposed changes concerns the deletion of reference to LCO 3.0.2.Request for Additional Information

  1. 1 LCO 3.0.2, though modified, will still be included in the PDTS. No specific basis for deleting the reference to TS 3.0.2 from TS 3.0.1 is provided in the application.

Please provide the basis for deleting the reference to LCO 3.0.2 from TS 3.0.1.Response to Request for Additional Information

  1. 1 Based on a teleconference with the NRC on May 22, 2014, during which additional clarification to this request was provided, CR-3 is returning the reference to LCO 3.0.2 in the proposed change to LCO 3.0.1. Replacement pages are included in Attachments C and D to this letter.Proposed change in LCO 3.0.2: This LCO currently states,"Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and 3.0.6.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated." The licensee's proposed change to LCO 3.0.2 deletes the above paragraph in'bold.' The licensee's application does not specifically discuss the reason for the proposed change. It simply states, "Proposed for revision to be consistent with the permanently defueled condition by removing reference to 3.0.x LCOs that are proposed for removal from the PDTS."

U. S Nuclear Regulatory Commission Attachment A 3F0614-01 Page 2 of 3 Request for Additional Information

  1. 2 The licensee proposes to delete "[I]f the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated," from the TS 3.0.2 in the PDTS, but does not provide a basis for the change in the application.

Please provide a basis for the deletion of this text from TS 3.0.2.Response to Reauest for Additional

  1. 2 Based on the additional clarification to this request, CR-3 is returning the second paragraph of LCO 3.0.2 from the Improved Technical Specifications in the proposed change to LCO 3.0.2 for the PDTS. Replacement pages are included in Attachments C and D to this letter.Request for Additional Information
  1. 3 SR 3.0.3 currently states, "A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed." Please explain the risk evaluation methodology approach that will be used for the defueled reactor.Response to Request for Additional Information
  1. 3 The risk evaluation methodology used for the defueled reactor has evolved from the shutdown safety risk management process used for refueling outages during the period of operation developed from the requirements of NRC Generic Letter 88-17, "Loss of Decay Heat Removal." The process ensures adequate defense-in-depth for Key Safety Functions associated with Spent Fuel Cooling during decommissioning activities.

CR-3 risk management procedures are used for work schedule planning and to evaluate emergent conditions.

Spent Fuel Pool risk is managed by performing the following:

1. Providing systems, structures, and components to ensure backup of key safety functions using redundant, alternate or diverse methods.2. Planning and scheduling activities in a manner that maintains key safety system availability.
3. Providing administrative controls that support and/or supplement the above elements.The Key Safety Functions that are monitored are:* Spent Fuel Inventory Makeup Flow Path and associated Instrumentation Requirements
  • Spent Fuel Cooling Flow Path and associated Instrumentation Requirements" Electrical Distribution Requirements, and* Switchyard Electrical Distribution Requirements Risk colors are used to display the level of defense-in-depth for each key safety function.

Risk colors are utilized to raise station awareness to conditions that reduce defense-in-depth or challenge key safety functions.

Once per day, a Key Safety Function Status review is performed by the Shift Supervisor to ensure the Key Safety Function equipment requirements continue to be met.

U. S Nuclear Regulatory Commission Attachment A 3F0614-01 Page 3 of 3 When emergent conditions arise which affect equipment supporting Key Safety Functions, the Shift Supervisor determines if there has been a change to plant risk color. In the permanently defueled condition there are significantly fewer ongoing concurrent work activities, which permits Operations to focus their attention towards the activities taking place. This, in conjunction with the CR-3 risk evaluation process, assures emergent conditions are thoroughly and safely managed.When planning work activities, Risk Assessments are performed to address scope additions, scope removal, and emergent conditions.

Independent reviews of the Risk Assessments are required for scheduled activities.

Request for Additional Information

  1. 4 LCO 3.7.15 Figure 3.7.15-2 on page 3.7-7 in CR 3 PDTS, is applicable to "Burnup versus Enrichment Curve for Spent Fuel Storage Pool," whereas, the page heading is titled as "Diesel Driven EFW Pump Fuel Oil, Lube Oil and Starting Air 3.7.19." Please make the correction.

Response to Request for Additional Information

  1. 4 A replacement page with the correct page heading was provided in the CR-3 to NRC letter dated May 7, 2014, "Crystal River Unit 3 -Response to Requests for Additional Information and Supplement 1 to License Amendment Request #316, Revision 0." (ADAMS Accession No.ML14139A006)

DUKE ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #316, REVISION 0 ATTACHMENT B SUPPLEMENT 2 TO LAR #316 REVISION 0 U. S Nuclear Regulatory Commission Attachment B 3F0614-01 Page 1 of 1 SUPPLEMENT 2 TO LAR #316, REVISION 0

1.0 DESCRIPTION

By letter dated October 29, 2013 (Reference 4.1), Duke Energy Florida, Inc. (DEF) requested an amendment to the Crystal River Unit 3 (CR-3) Facility Operating License (FOL) in License Amendment Request (LAR) #316, Revision 0. The proposed amendment would revise the CR-3 FOL and the Improved Technical Specifications, creating the Permanently Defueled Technical Specifications (PDTS).Based on discussions with the NRC staff during the ongoing review of LAR #316, and recent Requests for Additional Information, CR-3 is providing Supplement 2 to LAR #316 which includes replacement pages for the proposed PDTS. The replacement pages for the PDTS will restore text from the Improved Technical Specifications, Limiting Condition for Operations (LCOs) 3.0.1 and 3.0.2, that was proposed for deletion for the PDTS.2.0 Proposed Changes With this proposed change, the reference to LCO 3.0.2 in LCO 3.0.1 will be restored and the second paragraph of LCO 3.0.2 will also be restored.

These changes to the LCOs will retain the internal consistency between the two LCOs and consistency with previously approved Defueled Technical Specifications.

Replacement pages are included in Attachments C and D to this letter.3.0 Regulatory Analysis No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in Reference 4.1 are not affected by, and remain applicable to, this proposed change.Environmental Impact Evaluation The conclusions of the environmental considerations contained in Reference 4.1 are not affected by, and remain applicable to, this proposed change.Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in Reference 4.1 are not affected by, and remain applicable to, this proposed change.4.0 References 4.1 CR-3 to NRC letter, "Crystal River Unit 3 -License Amendment Request #316, Revision 0, Revise and Remove License Conditions and Revision to Improved Technical Specifications to Establish Permanently Defueled Technical Specifications," dated October 29, 2013. (ADAMS Accession No. ML13316C083)

DUKE ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #316, REVISION 0 ATTACHMENT C PROPOSED TECHNICAL SPECIFICATION PAGE CHANGES, STRIKEOUT AND SHADOWED TEXT FORMAT LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2. -" 3. .7 and -f' 3 .0 0 LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in [CO 3.0.5 and 3.0.6.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.[CO 3.0.3 When an [CO is not met, except as provided inth assoiated ACTIONS, and an associated ACTION is not met or provided, the unit shall be plaed in a MODE or other specified elondition in which the Specification is not, applicable.

Action shall be initiated within 1: hour to placle the unit, as applicable,in Sa .MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;b-. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and ,MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.Exeptions to this Speeification are stated in the individual Specifications.

W.0here elorreetive measures are completed that permit operatio in accOrdance with the [CO or ACTIONS, completion Of the acin required by [CO 3.0.3 is not required.[CO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.[CO 3.0.4 When an [CO is not met, entry into a MODE or ote speeified condition in the Applicability shall only be a. When the associated ACTIONS to be entered permit ,ontinued operation in the MODE or other speci endition in the Applicability for an unlimited period of time; or Crystal River Unit 3 3.0-1 Amendment No. 2-2-4 DUKE ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #316, REVISION 0 ATTACHMENT D PROPOSED TECHNICAL SPECIFICATION PAGE CHANGES, REVISION BAR FORMAT LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met.If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.Crystal River Unit 3 3.0-1 Amendment No.

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