JAFP-15-0143, License Amendment Request Revision to Technical Specification Administrative Controls for Permanently Defueled Condition
ML16015A456 | |
Person / Time | |
---|---|
Site: | FitzPatrick ![]() |
Issue date: | 01/15/2016 |
From: | Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
JAFP-15-0143 | |
Download: ML16015A456 (28) | |
Text
January 15, 2016
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
11555 Rockville Pike
Rockville, MD 20852
SUBJECT:
License Amendment Request - Revision to Technical Specification Administrative Controls for Permanently Defueled Condition James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059
REFERENCES:
- 1. Letter, Entergy Nuclear Operations, Inc., to USNRC, "Notification of Permanent Cessation of Power Operations," JAFP 15-0133, dated November 18, 2015 (ML15322A273)
- 2. Letter, Entergy Nuclear Operations, Inc., to USNRC, "Request for Approval of Certified Fuel Handler Training Program," JAFP 15-
0142 dated January 15, 2016
Dear Sir or Madam:
In accordance with 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) is proposing an
amendment to Renewed Facility Operating License (OL) DPR-059 for James A. FitzPatrick
Nuclear Power Plant (JAF).
In Reference 1, ENO notified the NRC that it has decided to permanently cease operations of
JAF at the end of the current operating cycle. Once certifications for permanent cessation of
operations and permanent removal of fuel from the reactor vessel are submitted to the NRC in
accordance with 10 CFR 50.82(a)(1)(i) and (ii), per 10 CFR 50.82(a)(2), the 10 CFR Part 50
license no longer will permit operation of the reactor or placement of fuel in the reactor vessel.
The basis for the proposed amendment is that certain license conditions and administrative
controls may be revised or removed to reflect the permanently defueled condition.
This request also proposes changes to the staffing and training requirements for the JAF staff
contained in Section 5.0, Administrative Controls, of the JAF Technical Specifications (TS).
Reference 2 was submitted proposing a Certified Fuel Handler training program for NRC
approval.
ENO has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes
it does not involve a significant hazards consideration.
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093
Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF
JAFP-15-0143 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of New York State Public Service Commission.
Attachment 1 to this letter provides a detailed description and evaluation of the proposed change. Attachment 2 contains a markup of the current TS pages. Attachment 3 contains the retyped TS pages. ENO requests review and approval of this proposed license amendment by November 1, 2016 and a 60 day implementation period from the effective date of the amendment.
ENO requests that the approved amendment become effective following NRC approval of the Certified Fuel Handler training program (Reference
- 2) and submittal of the certifications required by 10 CFR 50.82(a)(1
). This submittal contains no new regulatory commitments.
If you have any questions regarding the content of this submittal, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.
I declare under penalty of perjury that the foregoing is true and correct. Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/ble Attachments:
- 1. Description and Evaluation of the Proposed Changes 2. Markup of the Current Technical Specification Pages 3. Retyped Technical Specification Pages cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 JAFP-15-0143 Page 3 of 3 cc list continued:
Mr. Douglas V. Pickett, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O 8 G9A Washington, DC 20555
Ms. Bridget Frymire, NYSPSC
Mr. John B. Rhodes., President NYSERDA
NRC Resident Inspector
JAFP-15-0143 Docket 50-333
Attachment 1 James A. FitzPatrick Nuclear Power Plant License Amendment Request - Revision to Technical Specification Administrative Controls for Permanently Defueled Condition
JAFP 15-143 Page 1 of 13
- 1.
SUMMARY
DESCRIPTION On November 18, 2015, Entergy Nuclear Operations, Inc. (ENO) announced that James A.
FitzPatrick Nuclear Power Plant (JAF) would be permanently retired at the end of the current
operating cycle. In Reference 1, ENO provided form al notification of the intention to permanently cease power operations of JAF in accordance with 10 CFR 50.82(a)(1)(i).
This evaluation supports a request to amend R enewed Facility Operating License (OL) DPR-059 for JAF. The proposed changes would revise and remove certain requirements contained within
Section 5.0, Administrative Controls, of the JAF Technical Specifications (TS). The TS
requirements being changed would not be applicable once it has been certified that all fuel has
permanently been removed from the JAF reactor in accordance with 10 CFR 50.82(a)(1)(ii). Once
the certifications for permanent cessation of operations and permanent fuel removal from the
reactor vessel are made, the 10 CFR Part 50 license for JAF no longer will authorize operation of
the reactor or placement of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2).
The changes proposed by this amendment would not be effective until the certification of
permanent removal of fuel from the reactor vessel has been submitted to the NRC and the NRC
has approved the JAF Certified Fuel Handler training program submitted in Reference 2.
- 2. DETAILED DESCRIPTION AND BASIS FOR THE CHANGES The following table identifies each section that is being changed, the proposed changes, and the
basis for the changes:
Proposed Changes to JAF Technical Specification Section 5.0, Administrative Controls
5.1 Responsibility
Current TS 5.1.1
The plant manager shall be responsible for
overall plant operation and shall delegate in writing the succession to this responsibility
during his absence.
The plant manager or his designee shall
approve, prior to Implementation, each
proposed test, experiment, and modification
to systems or equipment that affect nuclear
safety.
Current TS 5.1.2
The shift supervisor shall be responsible for
the control room command function. During Proposed TS 5.1.1
The plant manager shall be responsible for
overall facility operation and shall delegate in
writing the succession to this responsibility during
his absence.
The plant manager or his designee shall
approve, prior to Implementation, each proposed
test, experiment, and modification to systems or
equipment that affect nuclear safety.
Proposed TS 5.1.2
The shift supervisor shall be responsible for the
shift command function.
JAFP 15-143 Page 2 of 13 any absence of the shift supervisor from the control room while the unit is in plant
startup or normal operation, an individual with
an active Senior Reactor Operator (SRO)
license shall be designated to assume the
control room command function. During any
absence of the shift supervisor from the
control room while the unit is in cold
shutdown or refueling with fuel in the reactor, an individual with an active SRO license or
Reactor Operator license shall be designated
to assume the control room command
function.
Basis This section identifies the responsibilities for the control room command function associated with
Modes of plant operation, and is based on personnel positions and qualifications for an operating
plant. It identifies the need for a delegation of authority for command in an operating plant when
the principal assignee leaves the control room.
This section is being changed to eliminate the Mode dependency for this function and personnel
qualifications associated with an operating plant. The proposed change establishes the shift
supervisor as having command of the shift. Delegation of command is unnecessary once JAF is
in the permanently defueled condition with fuel in the spent fuel pool. Any event involving loss of
pool cooling would evolve slowly enough that no immediate response would be required to
protect the health and safety of the public or station personnel.
5.2 Organization
Current TS 5.2.1, Onsite and Offsite Organizations
Onsite and offsite organizations shall be
established for plant operation and corporate
management, respectively. The onsite and
offsite organizations shall include the
positions for activities affecting safety of the
nuclear power plant.
- b. The plant manager shall be responsible for overall safe operation
of the plant and shall have control over
those onsite activities necessary for
safe operation and maintenance of the
plant c. The chief nuclear officer shall have Proposed TS 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.
- 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. The corporate officer shall have overall JAFP 15-143 Page 3 of 13 corporate responsibility for overall plant nuclear safety and shall take any
measures needed to ensure
acceptable performance of the staff in
operating, maintaining, and providing
technical support to the plant to ensure
nuclear safety; and
- d. The individuals who train the operating staff, 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 independence
from operating pressures.
responsibility for the safe handling and storage 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 organizational freedom to ensure
their ability to perform their assigned functions.
Basis The introduction to this section identifies that organizational positions are established that are
responsible for the safety of the nuclear plant. This is changed to require that positions be
established that are responsible for the safe handling and storage of nuclear fuel. This change
removes the implication that JAF can return to operation once the certifications required by 10
CFR 50.82(a)(1) are submitted to the NRC.
The terms "safe storage and maintenance of nuclear fuel" and "safe management of nuclear fuel"
are considered analogous to "nuclear safety" for a plant that will be in the permanently defueled
condition. Proposed changes to replace "nuclear safety" with one of these analogues serves to
narrow the focus of nuclear safety concerns to the nuclear fuel.
TS 5.2.1.a - No changes are proposed to this specification.
TS 5.2.1.b - This section identifies the organizational position responsible for the safe operation of the plant, and for control of activities necessary for the safe operation and maintenance of the
plant.
To reflect the change in safety concerns from an operating plant to a permanently defueled plant, the responsibility for control of activities necessary for the safe operation and maintenance of the
plant is changed to the responsibility for safe storage and maintenance of the nuclear fuel.
TS 5.2.1.c - This section identifies the organizational position responsible for overall nuclear plant safety.
To reflect the change in safety concerns from an operating plant to a permanently defueled plant, the responsibility for ensuring nuclear safety is changed to the responsibility for ensuring safe
management of nuclear fuel. The assignment of this responsibility is changed from the JAF site
vice president to a specified corporate officer. This change provides ENO the flexibility to assign
overall responsibility to a corporate officer position other than a site vice president. The site vice
president is considered a corporate officer position. This position has no qualification JAFP 15-143 Page 4 of 13 requirements beyond the applicable requirements established in ANSI/ANS 3.1-1978. The revised specification is consistent with TS 5.2.1.c of NUREG-1433, "Standard Technical
Specifications General Electric BWR/4 Plants," Revision 4 (Reference 3).
TS 5.2.1.d - This paragraph addresses the requirement for organizational independence of the personnel who train the operations staff, health physics personnel and quality assurance
personnel from operating pressures.
This is changed to replace "operating staff' with "Certified Fuel Handlers" and to replace "their
independence from operating pressures" to "their ability to perform their assigned functions."
These changes reflect the changed function of the previous operating staff to a focus on safe
handling and storage of nuclear fuel, and to remove the implication that JAF can return to
operation once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRC.
Current TS 5.2.2, Plant Staff
The plant staff organization shall include the
following:
- a. At least one non-licensed operator shall be on site when the plant is in
Mode 4 or 5. At least two non-
licensed operators shall be on site
when the plant is in Mode 1, 2, or 3.
- b. Shift crew composition may be less than the minimum requirement of 10
CFR 50.54(m)(2)(i) and 5.2.2.a and
5.2.2.f 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 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.
- d. Deleted e. The operations manager or assistant operations manager shall hold an
SRO license.
- f. When in MODES 1, 2, or 3 an Proposed TS 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.
- 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 movements 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 JAFP 15-143 Page 5 of 13 individual shall provide advisory technical support to the unit
operations shift crew in the areas of
thermal hydraulics, reactor
engineering, and plant analysis with
regard to the safe operations of the
unit. This individual shall meet the
qualifications specified by ANSI/ANS
3.1-1993 as endorsed by RG 1.8, Rev. 3, 2000.
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.
Basis TS 5.2.2.a - At least one non-licensed operator shall be on site when the plant is in Mode 4 or 5.
At least two non-licensed operators shall be on site when the plant is in Mode 1, 2, or 3.
Since this can never occur again at JAF once the certifications required by 10 CFR 50.82(a)(1)
are submitted to the NRC, the minimum requirement is changed to a minimum crew compliment
of one shift supervisor and one Non-certified Operator. This reflects the reduced number of
systems, compared to an operating reactor, r equired to provide and support spent fuel pool cooling and monitor spent fuel pool parameters, such as pool level and temperature, while still
maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner.
Moreover, the spectrum of credible accidents and operational events, and the quantity and
complexity of activities required for safety has been greatly reduced from that at an operating
plant. The shift supervisor will be qualified as a Certified Fuel Handler in accordance with new
paragraph 5.2.2.e. In this position, this individual will retain command and control responsibility for
operational decisions and will be responsible for the functions required for event reporting and
emergency response.
TS 5.2.2.b - This paragraph addresses the conditions under which the minimum shift compliment may be reduced. It contains a reference to 10 CFR 50.54(m) which establishes the minimum
requirements for a licensed operating staff for facility operation. It also allows for shift crew
composition to be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and
Specifications 5.2.2.a and 5.2.2.f 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 cr ew members, provided immediate action is taken to restore the shift crew composition to within the minimum requirements
The references to 10 CFR 50.54(m) are removed since JAF will not return to operation in the
future once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRC, and the
requirement for licensed operating personnel will no longer be required to protect public health
and safety. Reference to TS 5.2.2.f is removed to be consistent with the proposed change to
delete the Specification. Additional provisions are added to ensure that shift crew composition is
not below the minimum requirements when fuel movements are in progress, movements of loads
over fuel are in progress or shift turnover is in progress.
TS 5.2.2.c - This paragraph establishes the requirement for a person qualified in radiation protection procedures to be onsite when fuel is in the reactor. This paragraph also allows for the
position to 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.
JAFP 15-143 Page 6 of 13 This requirement is being deleted because once the fuel is certified removed from the reactor in
accordance with 10 CFR 50.82(a)(1)(ii), JAF will be prohibited by 10 CFR 50.82(a)(2) from
placing fuel back into the reactor vessel. Therefore, this requirement will no longer be applicable.
This requirement is being replaced with a requirement for an individual qualified in radiation
protection procedures to be present on-site during the movement of fuel and during the
movement of loads over fuel.
TS 5.2.2.d - This paragraph was originally deleted.
This paragraph is changed to establish the requirement for having oversight of fuel handling
operations performed by a Certified Fuel Handler. Fuel moves and heavy load moves that could
affect the safe handling and storage of nuclear fuel would be approved by the shift supervisor.
Proposed TS 5.2.2.e requires the shift supervisor to be a Certified Fuel Handler.
TS 5.2.2.e - This paragraph establishes the requirement for the operations manager, or an assistant operations manager, to hold a Senior Reactor Operator (SRO) license.
This paragraph is being revised to replace the requirement with a requirement that the shift
supervisor shall be a Certified Fuel Handler. Once the certifications required by 10 CFR
50.82(a)(1) have been submitted, the requirements of 10 CFR 50.54(m) will no longer be
applicable because the JAF Part 50 license no longer will authorize operation of the reactor or
emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need
for the operators' licenses specified in 10 CFR 55. Therefore, there is no longer a need for
operations management staff to hold a SRO license. Replacing this with a requirement that the
shift supervisor shall be a Certified Fuel Handler ensures that the senior individual on shift is
appropriately trained and qualified, in accordance with the NRC-approved Certified Fuel Handler
training program, to supervise shift activities.
The JAF management structure will not require positions above the shift supervisor to be a
Certified Fuel Handler or attend equivalent training. JAF has determined that once the plant is
permanently shutdown and defueled, the time availabl e to mitigate credible events is expected to be greater than that for current design basis event
- s. As such, management oversight of the plant can be performed by individuals meeting the app licable requirements of ANSI/ANS 3.1-1978 (as required by TS 5.3.1) and need not be qualified as Certified Fuel Handlers.
TS 5.2.2.f - This paragraph establishes the requirements for the Technical Advisor (TA) position.
This paragraph is deleted to remove the requirements for the TA since that position is only
required for a plant authorized for power operations. Once the certifications required by 10 CFR
50.82(a)(1) have been submitted, the requirements of this specification will no longer be
applicable because the JAF Part 50 license no longer will authorize operation of the reactor or
emplacement or retention of fuel in the reactor vessel.
This paragraph is changed to reflect the requirement for having one qualified watch stander (either a Non-certified Operator or Certified Fuel Handler) in the control room when fuel is stored
in the spent fuel pool. This reflects the reduced requirement for control room personnel training
and qualification for a plant authorized for nuclear fuel storage only. JAF has submitted a Certified
Fuel Handler training program for NRC approval in Reference 2. The training and qualification for
the Non-certified Operator will be determined in accordance with the systems approach to training (SAT) as defined in 10 CFR 55.4. This process ensures that the Non-certified Operator will be JAFP 15-143 Page 7 of 13 qualified to perform the functions necessary to monitor and ensure safe storage of fuel. The SAT process requires (1) systematic analysis of the jobs to be performed, (2) learning objectives
derived from the analysis which describe desired performance after training, (3) training design
and implementation based on the learning objectives, (4) evaluation of trainee mastery of the
objectives during training, and (5) evaluation and revision of the training based on the
performance of trained personnel in the job setting. There will be a sufficient number of
individuals qualified as Certified Fuel Handlers to staff the plant twenty four hours a day, seven
days a week. Additional on-shift staffing will be provided to satisfy applicable security, fire
protection, and emergency preparedness requirements.
The control room will remain the physical center of the command function. However, since control
of activities may be performed either remotely from the control room or locally in the plant, the
location of the command center is functionally where the shift supervisor is located, in accordance
with proposed TS 5.2.2.f. Activities that could be performed from the control room that have the
potential to affect forced cooling of spent nuclear fuel include starting and stopping cooling water
pumps, as well as changing the electrical power distribution system alignment.
All spent fuel handling activities are performed locally at the spent fuel pool. Indications and/or
alarms are also received in the control room that would be indicative of spent fuel pool
abnormalities. The shift supervisor is responsible for directing response to those abnormalities, from either the control room or local to the spent fuel pool, in accordance with applicable
response procedures.
For any conditions, incidents, or events that occu r when the Non-certified Operator is in the control room alone and are not within the scope of qualifications that are possessed by the Non-
certified Operator, the shift supervisor will be immediately contacted for direction by phone, radio, and/or plant page system. This philosophy is deem ed acceptable because the necessity to render immediate actions to protect the health and safety of the public is not challenged.
Current TS 5.3, Plant Staff Qualifications
- 1. Each member of the unit staff shall meet or exceed the minimum qualifications of
ANSI/ANS 3.1-1978 for comparable
positions with exceptions specified in
the Entergy Quality Assurance Program
Manual (QAPM).
- 2. For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in
addition to meeting the requirements of
TS 5.3.1, perform the functions
described in 10 CFR 50.54(m).
Proposed TS 5.3, Facility Staff Qualifications
- 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).
- 2. An NRC approved training and retraining program for Certified Fuel
Handlers shall be maintained.
Basis
JAFP 15-143 Page 8 of 13 TS 5.3.1 - This paragraph is being changed for consistency with other changes in this Amendment.
TS 5.3.2 - This paragraph defines SROs and ROs as the individuals who perform the functions defined in 10 CFR 50.54(m).
This paragraph is being deleted because neither 10 CFR 50.54(m) nor the requirement for
licensed operators per 10 CFR 54 apply following submittal of the certifications required by 10
CFR 50.82(a)(1).
TS 5.3.2 is being changed to require that an NRC approved training and retraining program for
the Certified Fuel Handlers shall be maintained. The Certified Fuel Handler training program
ensures that the qualifications of fuel handlers are commensurate with the tasks to be performed
and the conditions requiring response. 10 CFR 50.120, "Training and qualification of nuclear
power plant personnel," requires training progr ams to be derived using a systems approach to training (SAT) as defined in 10 CFR 55.4. Although the requirements of 10 CFR 50.120 apply to
holders of an operating license issued under Part 50, and the JAF license will no longer authorize
operation following submittal of the certifications required by 10 CFR 50.82(a)(1), the Certified
Fuel Handler training program nonetheless aligns with those requirements. The Certified Fuel
Handler training program provides adequate confidence that appropriate SAT based training of
personnel who will perform the duties of a Certified Fuel Handler is conducted to ensure the
facility is maintained in a safe and stable condition.
- 3. REGULATORY EVALUATION 3.1 APPLICABLE REGULATORY REQUIREMENT/CRITERIA
10 CFR 50.82(a)(1) requires that when a licensee has determined to permanently cease
operations the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been
permanently removed from the reactor vessel, the licensee shall submit a written
certification to the NRC that meets the requirements of 10 CFR 50.4(b)(9). On November 2, 2015, Entergy Nuclear Operations, Inc. (ENO) announced that JAF would be retired At the
end of the current operating cycle, the exact date to be determined. In Reference 1, ENO
provided formal notification of the intention to permanently cease power operations of JAF.
JAF recognizes that approval of these proposed changes is contingent upon the submittal
of the certifications required by 10 CFR 50.82(a)(1).
10 CFR 50.82(a)(2) states "Upon docketing of the certifications for permanent cessation of
operations and permanent removal of fuel from the reactor vessel, or when a final legally
effective order to permanently cease operations has come into effect, the 10 CFR part 50
license no longer authorizes operation of the reactor or emplacement or retention of fuel
into the reactor vessel."
10 CFR 50.36 establishes the requirements for Technical Specifications. 50.36(c)(5),
Administrative Controls, identifies that an Administrative Controls section shall be included
in the Technical Specifications and shall include provisions relating to organization and
management, procedures, recordkeeping, review and audit, and reporting necessary to
assure operation of the facility in a safe manner. This amendment request is proposing JAFP 15-143 Page 9 of 13 changes to the Administrative Controls section consistent with the pending
decommissioning status of the plant. This request applies the principles identified in
50.36(c)(6), Decommissioning, for a facility which has submitted certifications required by
50.82(a)(1) and proposes changes to the Administrative Controls appropriate for the JAF
permanently defueled condition. As 10 CFR 50.36(c)(6) states, this type of change should
be considered on a case-by-case basis.
10 CFR 50.54(m) establishes the requirements for having Reactor Operators and Senior
Reactor Operators licensed in accordance with Part 55 based on plant conditions. Based
on the impending permanent cessation of operation for JAF, the requirements of this
section will no longer apply once the certifications required by 10 CFR 50.82(a)(1) have
been submitted to the NRC and it will be permissible to remove those positions from the
Technical Specifications.
10 CFR 50.54(hh) establishes the requirements for developing, implementing and
maintaining procedures and strategies for addressing potential aircraft threats and large
area fires or explosions. 10 CFR 50.54(hh)(3) states that this section of the regulation does
not apply to nuclear power plants that have submitted the certifications required by 10 CFR
50.82(a).
3.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Pursuant to 10CFR50.92, Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed change and concludes that the change does not involve a significant hazards
consideration since the proposed change satisfies the criteria in 10CFR50.92(c). These
criteria require that operation of the facility in accordance with the proposed amendment
would not (1) involve a significant increase in the probability or consequences of an
accident previously evaluated; (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.
The proposed changes would revise and remove certain requirements contained within
Section 5.0, Administrative Controls, of the James A. Fitzpatrick Nuclear Power Plant (JAF)
Technical Specifications (TS). The TS requirements being changed would not be applicable
once it has been certified that all fuel has permanently been removed from the JAF reactor
in accordance with 10 CFR 50.82(a)(1)(ii). Once the certifications for permanent cessation
of operations and permanent fuel removal are made, the 10 CFR Part 50 license for JAF no
longer will authorize operation of the reactor or placement of fuel in the reactor vessel, in
accordance with 10 CFR 50.82(a)(2).
The discussion below addresses each of these criteria and demonstrates that the proposed
amendment does not constitute a significant hazard.
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment would not take effect until JAF has permanently
ceased operation and entered a permanently defueled condition. The
proposed amendment would modify the JA F TS by deleting the portions of the TS that are no longer applicable to a permanently defueled facility, while JAFP 15-143 Page 10 of 13 modifying the other sections to correspond to the permanently defueled
condition.
The deletion and modification of provisions of the administrative controls do
not directly affect the design of st ructures, systems, and components (SSCs) necessary for safe storage of irradiated fuel or the methods used for
handling and storage of such fuel in the fuel pool. The changes to the
administrative controls are administr ative in nature and do not affect any accidents applicable to the safe management of irradiated fuel or the
permanently shutdown and defueled condition of the reactor.
In a permanently defueled condition, the only credible accident is the fuel
handling accident.
The probability of occurrence of previously evaluated accidents is not
increased, since extended operation in a defueled condition will be the only
operation allowed, and therefore bounded by the existing analyses.
Additionally, the occurrence of postulated accidents associated with reactor
operation is no longer credible in a permanently defueled reactor. This
significantly reduces the scope of applicable accidents.
Therefore, the proposed amendment does not involve a significant increase
in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes have no impact on facility SSCs affecting the safe
storage of irradiated fuel, or on the methods of operation of such SSCs, or
on the handling and storage of irradiated fuel itself. The administrative
removal of or modifications of the TS that are related only to administration
of facility cannot result in different or more adverse failure modes or
accidents than previously evaluated bec ause the reactor will be permanently shutdown and defueled and JAF will no longer be authorized to operate the
reactor.
The proposed deletion of requirements of the JAF TS do not affect systems
credited in the accident analysis for the fuel handling accident at JAF. The
proposed TS will continue to require proper control and monitoring of safety
significant parameters and activities.
The proposed amendment does not result in any new mechanisms that
could initiate damage to the remaining relevant safety barriers for defueled
plants (fuel cladding and spent fuel cooling). Since extended operation in a
defueled condition will be the only operation allowed, and therefore bounded
by the existing analyses, such a condition does not create the possibility of a
new or different kind of accident.
Therefore, the proposed change does not create the possibility of a new or
different kind of accident from any previously evaluated.
JAFP 15-143 Page 11 of 13
- 3. Does the proposed amendment involve a significant reduction in a margin of safety? Response: No.
Because the 10 CFR Part 50 license for JAF will no longer authorize
operation of the reactor or emplacement or retention of fuel into the reactor
vessel once the certifications required by 10 CFR 50.82(a)(1) are submitted, as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents
associated with reactor operation is no longer credible. The only remaining
credible accident is a fuel handling accident (FHA). The proposed
amendment does not adversely affect the inputs or assumptions of any of
the design basis analyses that impact the FHA.
The proposed changes are limited to those portions of the OL and TS that
are not related to the safe storage of irradiated fuel. The requirements that
are proposed to be revised or deleted from the JAF OL and TS are not
credited in the existing accident analysis for the remaining applicable
postulated accident; and as such, do not contribute to the margin of safety
associated with the accident analysis. Postulated DBAs involving the reactor
are no longer possible because the reactor will be permanently shutdown
and defueled and JAF will no longer be authorized to operate the reactor.
Therefore, the proposed change does not involve a significant reduction in
the margin of safety.
Based on the above, ENO concludes that the proposed amendment presents 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.
3.3 PRECEDENT
The proposed changes are consistent with the existing TS Administrative Controls currently in effect for Vermont Yankee Nuclear Power Station (DPR-28), which was last substantively
revised on December 22, 2014 (Reference 7).
The proposed changes are consistent with the existing TS Administrative Controls currently in effect for Millstone Nuclear Power Station (DPR-21), which was last substantively revised on March 31, 2001 (Reference 4). The Millstone license amendment that was issued to reflect the permanently shutdown status of the plant on November 9, 1999 (Reference 5),
contains TS Administrative Controls similar to those being proposed herein.
The proposed changes are also consistent with the TS Administrative Controls issued to
Zion Nuclear Power Station on December 30, 1999 (Reference 6) to reflect the permanently
shutdown status of the plant.
3.4 CONCLUSION
Based on the considerations discussed above, (1) there is 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
JAFP 15-143 Page 12 of 13
- 4. ENVIRONMENTAL CONSIDERATIONS This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10CFR51.22(c)(9) as follows:
(i) The amendment involves no significant hazards consideration.
As described in Section 3 of this evaluation, the proposed change involves no significant
hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed amendment does not involve any physical alterations to the plant
configuration that could lead to a change in the type or amount of effluent release offsite.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed amendment does not involve a significant increase in individual or
cumulative occupational radiation exposure.
Based on the above, ENO concludes that the proposed change meets the eligibility criteria for
categorical exclusion as set forth in 10CFR51.22(c)(9). Pursuant to 10CFR51.22(b), no
environmental impact statement or environm ental assessment need be prepared in connection with the issuance of this amendment.
- 5. REFERENCES
- 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," JAFP 15-133, dated November 18, 2015
- 2. Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of Certified Fuel Handler Training Program," JAFP 15-142, dated January 15, 2016
- 3. NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants,"
Revision 4
- 4. Millstone Nuclear Power Station, Unit 1, Amendment No.109, License No. DPR-21, Date of Issuance March 31, 2001 (ADAMS Accession No. ML010920303)
- 5. NRC Safety Evaluation for Millstone Power Station Unit 1 in License Amendment 106 to DPR-21, dated November 9, 1999 (ADAMS Accession Nos. ML993330283
and ML993330269)
- 6. NRC Safety Evaluation for Zion Nuclear Station in License Amendments 180 and 167 (for Units 1 and 2 respectively (License Nos. DPR-39 and DPR-48)), dated
December 30, 1999 (ADAMS Accession Nos. ML003672704 and ML003672696)
JAFP 15-143 Page 13 of 13
- 7. Vermont Yankee Nuclear Power Station, Amendment No.260, License No. DPR-29, Date of Issuance December 22, 2014 (ADAMS Accession No. ML14217A072)
JAFP-15-143 Docket 50-333
Attachment 2 James A. FitzPatrick Nuclear Power Plant Markup of the Current Technical Specification Pages
(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools. (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. aGB, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 197 4; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993), 190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:
Amendment aG9 Renewed license No. DPR-59 Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility dtacility I 5.1.1 5.1.2 JAFNPP It The plant manager shall be responsible for overall p.'.J.aRt operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety. The shift supervisor (SS) shall be responsible for the control command function.
During any absence of the SS from the control room while the plant is in MODE 1, 2, or 3, an individual with an active (SRO) license shall be designated to ass tr room co11111and function.
During any absence of the SS from the control room while the plant is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control l'!Gmll c;ommand function.
5.1-1 Amendment 214 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS the safe handling and 5.2 Organization storage of nuclear fuel 5.2.1 The corporate officer facility Each duty shift shall be composed of at least one shift supervisor and one Non-certified Operator.
Onsite and offsite organizatio s shall be established for eperation and corporate manage ent, respectively.
The onsite and offsite organizations shall in lude the positions for activities affecting safety of the nuclea pgwer
- a. b. Lines of authority, respo sibility, and communication shall be defined and establishe throughout highest management levels, intermediate levels, and all operating organization positions.
These relatio ships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmen al responsibilities and relationships, and job de criptions for key personnel positions, or in equivale t forms of documentation.
These requirements.
including t e plant-specific titles of those personnel fulfilling the esponsibilities of the positions delineated in these Technical Specifications, shall be documented in the UFSAR; f .1.t t T plant manager sh ope ation of the an onsi activities necessa maint nee of the p+aRt, ac1 1 y s orage responsible for ov rall safe shall have contr over those for safe and nuclear fuel a ave corporate sibility for overall plant nuclear safety and shall take an sures needed to ensure acceptable performance of the staff in ating, maintaining, and providing technical support to ; and Certified Fuel Handlers The Non-Certified
- d. The individua s w o rain e op , arry out radiation protection, or perform quality assuran functions may report to the appropriate onsite manager: howe r, these individuals shall have sufficient organizational fre om to ensure their :U:ldep deRGe-frGm operating pressures . Operator position may be filled by a Certified Fuel Handler. JAFNPP ability to perform their safe management assigned functions of nuclear fuel facility staff organization shall include the following: (continued) 5.2*1 Amendment 274 5.2 Organization 5.2.2 Plant Staff (continued)
Organization 5.2 b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f 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 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 whefl f1::.1el is in the during the movement "---" 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 of fuel and during the order to provide for unexpected absence, provided immediate action is movement of loads taken to fill the required position.
over fuel d. Deleted e. The shift supervisor shall be a Certified Fuel Handler JAFNPP 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. 5.2-2 Oversight of fuel handling operations shall be provided by a Certified Fuel Handler. Amendment 3G4 Plant Staff Qualifications 5.3 Facility 5.0 5.3 Staff Qualifications ritacility I \J,-5.3.1 Each member of the t:ffiit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM). 5.3.2 For the purpose of 10 CFR §§.4, a lieensed Senior Reaetor Operator (SRO) and a lieensed Reaetor Operator (RO) are those indi* .. iduals 1+*1ho, in addition to meeting the requirements of TS 6.a.1, perform the funetions deseribed in 10 CFR 60.§4\). JAFNPP \_An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained 5.3-1 Amendment a04 JAFP-15-143 Docket 50-333
Attachment 3 James A. FitzPatrick Nuclear Power Plant Retyped Technical Specification Pages
Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS
5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.
The plant manager or his designee shall approve, prior to Implementation, each proposed test, experiment, and Modification to systems or equipment that affect nuclear
safety. 5.1.2 The shift supervisor (SS) shall be responsible for the shift command function.
JAFNPP 5.1-1 Amendment 274
Organization 5.0 ADMINISTRATIVE CONTROLS
5.2 5.2 Organization 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. The corporate officer shall have overall responsibility for the safe handling and storage 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 organizational 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.
- 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.
JAFNPP 5.2-1 Amendment 274
Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization (continued)
- c. A radiation protection technician shall be on site during the movement of fuel and during the movements 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.
JAFNPP 5.2-2 Amendment 274
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
January 15, 2016
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
11555 Rockville Pike
Rockville, MD 20852
SUBJECT:
License Amendment Request - Revision to Technical Specification Administrative Controls for Permanently Defueled Condition James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059
REFERENCES:
- 1. Letter, Entergy Nuclear Operations, Inc., to USNRC, "Notification of Permanent Cessation of Power Operations," JAFP 15-0133, dated November 18, 2015 (ML15322A273)
- 2. Letter, Entergy Nuclear Operations, Inc., to USNRC, "Request for Approval of Certified Fuel Handler Training Program," JAFP 15-
0142 dated January 15, 2016
Dear Sir or Madam:
In accordance with 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) is proposing an
amendment to Renewed Facility Operating License (OL) DPR-059 for James A. FitzPatrick
Nuclear Power Plant (JAF).
In Reference 1, ENO notified the NRC that it has decided to permanently cease operations of
JAF at the end of the current operating cycle. Once certifications for permanent cessation of
operations and permanent removal of fuel from the reactor vessel are submitted to the NRC in
accordance with 10 CFR 50.82(a)(1)(i) and (ii), per 10 CFR 50.82(a)(2), the 10 CFR Part 50
license no longer will permit operation of the reactor or placement of fuel in the reactor vessel.
The basis for the proposed amendment is that certain license conditions and administrative
controls may be revised or removed to reflect the permanently defueled condition.
This request also proposes changes to the staffing and training requirements for the JAF staff
contained in Section 5.0, Administrative Controls, of the JAF Technical Specifications (TS).
Reference 2 was submitted proposing a Certified Fuel Handler training program for NRC
approval.
ENO has reviewed the proposed amendment in accordance with 10 CFR 50.92 and concludes
it does not involve a significant hazards consideration.
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093
Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF
JAFP-15-0143 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of New York State Public Service Commission.
Attachment 1 to this letter provides a detailed description and evaluation of the proposed change. Attachment 2 contains a markup of the current TS pages. Attachment 3 contains the retyped TS pages. ENO requests review and approval of this proposed license amendment by November 1, 2016 and a 60 day implementation period from the effective date of the amendment.
ENO requests that the approved amendment become effective following NRC approval of the Certified Fuel Handler training program (Reference
- 2) and submittal of the certifications required by 10 CFR 50.82(a)(1
). This submittal contains no new regulatory commitments.
If you have any questions regarding the content of this submittal, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.
I declare under penalty of perjury that the foregoing is true and correct. Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/ble Attachments:
- 1. Description and Evaluation of the Proposed Changes 2. Markup of the Current Technical Specification Pages 3. Retyped Technical Specification Pages cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 JAFP-15-0143 Page 3 of 3 cc list continued:
Mr. Douglas V. Pickett, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O 8 G9A Washington, DC 20555
Ms. Bridget Frymire, NYSPSC
Mr. John B. Rhodes., President NYSERDA
NRC Resident Inspector
JAFP-15-0143 Docket 50-333
Attachment 1 James A. FitzPatrick Nuclear Power Plant License Amendment Request - Revision to Technical Specification Administrative Controls for Permanently Defueled Condition
JAFP 15-143 Page 1 of 13
- 1.
SUMMARY
DESCRIPTION On November 18, 2015, Entergy Nuclear Operations, Inc. (ENO) announced that James A.
FitzPatrick Nuclear Power Plant (JAF) would be permanently retired at the end of the current
operating cycle. In Reference 1, ENO provided form al notification of the intention to permanently cease power operations of JAF in accordance with 10 CFR 50.82(a)(1)(i).
This evaluation supports a request to amend R enewed Facility Operating License (OL) DPR-059 for JAF. The proposed changes would revise and remove certain requirements contained within
Section 5.0, Administrative Controls, of the JAF Technical Specifications (TS). The TS
requirements being changed would not be applicable once it has been certified that all fuel has
permanently been removed from the JAF reactor in accordance with 10 CFR 50.82(a)(1)(ii). Once
the certifications for permanent cessation of operations and permanent fuel removal from the
reactor vessel are made, the 10 CFR Part 50 license for JAF no longer will authorize operation of
the reactor or placement of fuel in the reactor vessel, in accordance with 10 CFR 50.82(a)(2).
The changes proposed by this amendment would not be effective until the certification of
permanent removal of fuel from the reactor vessel has been submitted to the NRC and the NRC
has approved the JAF Certified Fuel Handler training program submitted in Reference 2.
- 2. DETAILED DESCRIPTION AND BASIS FOR THE CHANGES The following table identifies each section that is being changed, the proposed changes, and the
basis for the changes:
Proposed Changes to JAF Technical Specification Section 5.0, Administrative Controls
5.1 Responsibility
Current TS 5.1.1
The plant manager shall be responsible for
overall plant operation and shall delegate in writing the succession to this responsibility
during his absence.
The plant manager or his designee shall
approve, prior to Implementation, each
proposed test, experiment, and modification
to systems or equipment that affect nuclear
safety.
Current TS 5.1.2
The shift supervisor shall be responsible for
the control room command function. During Proposed TS 5.1.1
The plant manager shall be responsible for
overall facility operation and shall delegate in
writing the succession to this responsibility during
his absence.
The plant manager or his designee shall
approve, prior to Implementation, each proposed
test, experiment, and modification to systems or
equipment that affect nuclear safety.
Proposed TS 5.1.2
The shift supervisor shall be responsible for the
shift command function.
JAFP 15-143 Page 2 of 13 any absence of the shift supervisor from the control room while the unit is in plant
startup or normal operation, an individual with
an active Senior Reactor Operator (SRO)
license shall be designated to assume the
control room command function. During any
absence of the shift supervisor from the
control room while the unit is in cold
shutdown or refueling with fuel in the reactor, an individual with an active SRO license or
Reactor Operator license shall be designated
to assume the control room command
function.
Basis This section identifies the responsibilities for the control room command function associated with
Modes of plant operation, and is based on personnel positions and qualifications for an operating
plant. It identifies the need for a delegation of authority for command in an operating plant when
the principal assignee leaves the control room.
This section is being changed to eliminate the Mode dependency for this function and personnel
qualifications associated with an operating plant. The proposed change establishes the shift
supervisor as having command of the shift. Delegation of command is unnecessary once JAF is
in the permanently defueled condition with fuel in the spent fuel pool. Any event involving loss of
pool cooling would evolve slowly enough that no immediate response would be required to
protect the health and safety of the public or station personnel.
5.2 Organization
Current TS 5.2.1, Onsite and Offsite Organizations
Onsite and offsite organizations shall be
established for plant operation and corporate
management, respectively. The onsite and
offsite organizations shall include the
positions for activities affecting safety of the
nuclear power plant.
- b. The plant manager shall be responsible for overall safe operation
of the plant and shall have control over
those onsite activities necessary for
safe operation and maintenance of the
plant c. The chief nuclear officer shall have Proposed TS 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.
- 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. The corporate officer shall have overall JAFP 15-143 Page 3 of 13 corporate responsibility for overall plant nuclear safety and shall take any
measures needed to ensure
acceptable performance of the staff in
operating, maintaining, and providing
technical support to the plant to ensure
nuclear safety; and
- d. The individuals who train the operating staff, 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 independence
from operating pressures.
responsibility for the safe handling and storage 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 organizational freedom to ensure
their ability to perform their assigned functions.
Basis The introduction to this section identifies that organizational positions are established that are
responsible for the safety of the nuclear plant. This is changed to require that positions be
established that are responsible for the safe handling and storage of nuclear fuel. This change
removes the implication that JAF can return to operation once the certifications required by 10
CFR 50.82(a)(1) are submitted to the NRC.
The terms "safe storage and maintenance of nuclear fuel" and "safe management of nuclear fuel"
are considered analogous to "nuclear safety" for a plant that will be in the permanently defueled
condition. Proposed changes to replace "nuclear safety" with one of these analogues serves to
narrow the focus of nuclear safety concerns to the nuclear fuel.
TS 5.2.1.a - No changes are proposed to this specification.
TS 5.2.1.b - This section identifies the organizational position responsible for the safe operation of the plant, and for control of activities necessary for the safe operation and maintenance of the
plant.
To reflect the change in safety concerns from an operating plant to a permanently defueled plant, the responsibility for control of activities necessary for the safe operation and maintenance of the
plant is changed to the responsibility for safe storage and maintenance of the nuclear fuel.
TS 5.2.1.c - This section identifies the organizational position responsible for overall nuclear plant safety.
To reflect the change in safety concerns from an operating plant to a permanently defueled plant, the responsibility for ensuring nuclear safety is changed to the responsibility for ensuring safe
management of nuclear fuel. The assignment of this responsibility is changed from the JAF site
vice president to a specified corporate officer. This change provides ENO the flexibility to assign
overall responsibility to a corporate officer position other than a site vice president. The site vice
president is considered a corporate officer position. This position has no qualification JAFP 15-143 Page 4 of 13 requirements beyond the applicable requirements established in ANSI/ANS 3.1-1978. The revised specification is consistent with TS 5.2.1.c of NUREG-1433, "Standard Technical
Specifications General Electric BWR/4 Plants," Revision 4 (Reference 3).
TS 5.2.1.d - This paragraph addresses the requirement for organizational independence of the personnel who train the operations staff, health physics personnel and quality assurance
personnel from operating pressures.
This is changed to replace "operating staff' with "Certified Fuel Handlers" and to replace "their
independence from operating pressures" to "their ability to perform their assigned functions."
These changes reflect the changed function of the previous operating staff to a focus on safe
handling and storage of nuclear fuel, and to remove the implication that JAF can return to
operation once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRC.
Current TS 5.2.2, Plant Staff
The plant staff organization shall include the
following:
- a. At least one non-licensed operator shall be on site when the plant is in
Mode 4 or 5. At least two non-
licensed operators shall be on site
when the plant is in Mode 1, 2, or 3.
- b. Shift crew composition may be less than the minimum requirement of 10
CFR 50.54(m)(2)(i) and 5.2.2.a and
5.2.2.f 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 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.
- d. Deleted e. The operations manager or assistant operations manager shall hold an
SRO license.
- f. When in MODES 1, 2, or 3 an Proposed TS 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.
- 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 movements 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 JAFP 15-143 Page 5 of 13 individual shall provide advisory technical support to the unit
operations shift crew in the areas of
thermal hydraulics, reactor
engineering, and plant analysis with
regard to the safe operations of the
unit. This individual shall meet the
qualifications specified by ANSI/ANS
3.1-1993 as endorsed by RG 1.8, Rev. 3, 2000.
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.
Basis TS 5.2.2.a - At least one non-licensed operator shall be on site when the plant is in Mode 4 or 5.
At least two non-licensed operators shall be on site when the plant is in Mode 1, 2, or 3.
Since this can never occur again at JAF once the certifications required by 10 CFR 50.82(a)(1)
are submitted to the NRC, the minimum requirement is changed to a minimum crew compliment
of one shift supervisor and one Non-certified Operator. This reflects the reduced number of
systems, compared to an operating reactor, r equired to provide and support spent fuel pool cooling and monitor spent fuel pool parameters, such as pool level and temperature, while still
maintaining the ability to ensure spent fuel handling operations are carried out in a safe manner.
Moreover, the spectrum of credible accidents and operational events, and the quantity and
complexity of activities required for safety has been greatly reduced from that at an operating
plant. The shift supervisor will be qualified as a Certified Fuel Handler in accordance with new
paragraph 5.2.2.e. In this position, this individual will retain command and control responsibility for
operational decisions and will be responsible for the functions required for event reporting and
emergency response.
TS 5.2.2.b - This paragraph addresses the conditions under which the minimum shift compliment may be reduced. It contains a reference to 10 CFR 50.54(m) which establishes the minimum
requirements for a licensed operating staff for facility operation. It also allows for shift crew
composition to be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and
Specifications 5.2.2.a and 5.2.2.f 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 cr ew members, provided immediate action is taken to restore the shift crew composition to within the minimum requirements
The references to 10 CFR 50.54(m) are removed since JAF will not return to operation in the
future once the certifications required by 10 CFR 50.82(a)(1) are submitted to the NRC, and the
requirement for licensed operating personnel will no longer be required to protect public health
and safety. Reference to TS 5.2.2.f is removed to be consistent with the proposed change to
delete the Specification. Additional provisions are added to ensure that shift crew composition is
not below the minimum requirements when fuel movements are in progress, movements of loads
over fuel are in progress or shift turnover is in progress.
TS 5.2.2.c - This paragraph establishes the requirement for a person qualified in radiation protection procedures to be onsite when fuel is in the reactor. This paragraph also allows for the
position to 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.
JAFP 15-143 Page 6 of 13 This requirement is being deleted because once the fuel is certified removed from the reactor in
accordance with 10 CFR 50.82(a)(1)(ii), JAF will be prohibited by 10 CFR 50.82(a)(2) from
placing fuel back into the reactor vessel. Therefore, this requirement will no longer be applicable.
This requirement is being replaced with a requirement for an individual qualified in radiation
protection procedures to be present on-site during the movement of fuel and during the
movement of loads over fuel.
TS 5.2.2.d - This paragraph was originally deleted.
This paragraph is changed to establish the requirement for having oversight of fuel handling
operations performed by a Certified Fuel Handler. Fuel moves and heavy load moves that could
affect the safe handling and storage of nuclear fuel would be approved by the shift supervisor.
Proposed TS 5.2.2.e requires the shift supervisor to be a Certified Fuel Handler.
TS 5.2.2.e - This paragraph establishes the requirement for the operations manager, or an assistant operations manager, to hold a Senior Reactor Operator (SRO) license.
This paragraph is being revised to replace the requirement with a requirement that the shift
supervisor shall be a Certified Fuel Handler. Once the certifications required by 10 CFR
50.82(a)(1) have been submitted, the requirements of 10 CFR 50.54(m) will no longer be
applicable because the JAF Part 50 license no longer will authorize operation of the reactor or
emplacement or retention of fuel in the reactor vessel. These certifications also obviate the need
for the operators' licenses specified in 10 CFR 55. Therefore, there is no longer a need for
operations management staff to hold a SRO license. Replacing this with a requirement that the
shift supervisor shall be a Certified Fuel Handler ensures that the senior individual on shift is
appropriately trained and qualified, in accordance with the NRC-approved Certified Fuel Handler
training program, to supervise shift activities.
The JAF management structure will not require positions above the shift supervisor to be a
Certified Fuel Handler or attend equivalent training. JAF has determined that once the plant is
permanently shutdown and defueled, the time availabl e to mitigate credible events is expected to be greater than that for current design basis event
- s. As such, management oversight of the plant can be performed by individuals meeting the app licable requirements of ANSI/ANS 3.1-1978 (as required by TS 5.3.1) and need not be qualified as Certified Fuel Handlers.
TS 5.2.2.f - This paragraph establishes the requirements for the Technical Advisor (TA) position.
This paragraph is deleted to remove the requirements for the TA since that position is only
required for a plant authorized for power operations. Once the certifications required by 10 CFR
50.82(a)(1) have been submitted, the requirements of this specification will no longer be
applicable because the JAF Part 50 license no longer will authorize operation of the reactor or
emplacement or retention of fuel in the reactor vessel.
This paragraph is changed to reflect the requirement for having one qualified watch stander (either a Non-certified Operator or Certified Fuel Handler) in the control room when fuel is stored
in the spent fuel pool. This reflects the reduced requirement for control room personnel training
and qualification for a plant authorized for nuclear fuel storage only. JAF has submitted a Certified
Fuel Handler training program for NRC approval in Reference 2. The training and qualification for
the Non-certified Operator will be determined in accordance with the systems approach to training (SAT) as defined in 10 CFR 55.4. This process ensures that the Non-certified Operator will be JAFP 15-143 Page 7 of 13 qualified to perform the functions necessary to monitor and ensure safe storage of fuel. The SAT process requires (1) systematic analysis of the jobs to be performed, (2) learning objectives
derived from the analysis which describe desired performance after training, (3) training design
and implementation based on the learning objectives, (4) evaluation of trainee mastery of the
objectives during training, and (5) evaluation and revision of the training based on the
performance of trained personnel in the job setting. There will be a sufficient number of
individuals qualified as Certified Fuel Handlers to staff the plant twenty four hours a day, seven
days a week. Additional on-shift staffing will be provided to satisfy applicable security, fire
protection, and emergency preparedness requirements.
The control room will remain the physical center of the command function. However, since control
of activities may be performed either remotely from the control room or locally in the plant, the
location of the command center is functionally where the shift supervisor is located, in accordance
with proposed TS 5.2.2.f. Activities that could be performed from the control room that have the
potential to affect forced cooling of spent nuclear fuel include starting and stopping cooling water
pumps, as well as changing the electrical power distribution system alignment.
All spent fuel handling activities are performed locally at the spent fuel pool. Indications and/or
alarms are also received in the control room that would be indicative of spent fuel pool
abnormalities. The shift supervisor is responsible for directing response to those abnormalities, from either the control room or local to the spent fuel pool, in accordance with applicable
response procedures.
For any conditions, incidents, or events that occu r when the Non-certified Operator is in the control room alone and are not within the scope of qualifications that are possessed by the Non-
certified Operator, the shift supervisor will be immediately contacted for direction by phone, radio, and/or plant page system. This philosophy is deem ed acceptable because the necessity to render immediate actions to protect the health and safety of the public is not challenged.
Current TS 5.3, Plant Staff Qualifications
- 1. Each member of the unit staff shall meet or exceed the minimum qualifications of
ANSI/ANS 3.1-1978 for comparable
positions with exceptions specified in
the Entergy Quality Assurance Program
Manual (QAPM).
- 2. For the purpose of 10 CFR 55.4, a licensed Senior Reactor Operator (SRO) and a licensed Reactor Operator (RO) are those individuals who, in
addition to meeting the requirements of
TS 5.3.1, perform the functions
described in 10 CFR 50.54(m).
Proposed TS 5.3, Facility Staff Qualifications
- 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).
- 2. An NRC approved training and retraining program for Certified Fuel
Handlers shall be maintained.
Basis
JAFP 15-143 Page 8 of 13 TS 5.3.1 - This paragraph is being changed for consistency with other changes in this Amendment.
TS 5.3.2 - This paragraph defines SROs and ROs as the individuals who perform the functions defined in 10 CFR 50.54(m).
This paragraph is being deleted because neither 10 CFR 50.54(m) nor the requirement for
licensed operators per 10 CFR 54 apply following submittal of the certifications required by 10
CFR 50.82(a)(1).
TS 5.3.2 is being changed to require that an NRC approved training and retraining program for
the Certified Fuel Handlers shall be maintained. The Certified Fuel Handler training program
ensures that the qualifications of fuel handlers are commensurate with the tasks to be performed
and the conditions requiring response. 10 CFR 50.120, "Training and qualification of nuclear
power plant personnel," requires training progr ams to be derived using a systems approach to training (SAT) as defined in 10 CFR 55.4. Although the requirements of 10 CFR 50.120 apply to
holders of an operating license issued under Part 50, and the JAF license will no longer authorize
operation following submittal of the certifications required by 10 CFR 50.82(a)(1), the Certified
Fuel Handler training program nonetheless aligns with those requirements. The Certified Fuel
Handler training program provides adequate confidence that appropriate SAT based training of
personnel who will perform the duties of a Certified Fuel Handler is conducted to ensure the
facility is maintained in a safe and stable condition.
- 3. REGULATORY EVALUATION 3.1 APPLICABLE REGULATORY REQUIREMENT/CRITERIA
10 CFR 50.82(a)(1) requires that when a licensee has determined to permanently cease
operations the licensee shall, within 30 days, submit a written certification to the NRC, consistent with the requirements of 10 CFR 50.4(b)(8), and once fuel has been
permanently removed from the reactor vessel, the licensee shall submit a written
certification to the NRC that meets the requirements of 10 CFR 50.4(b)(9). On November 2, 2015, Entergy Nuclear Operations, Inc. (ENO) announced that JAF would be retired At the
end of the current operating cycle, the exact date to be determined. In Reference 1, ENO
provided formal notification of the intention to permanently cease power operations of JAF.
JAF recognizes that approval of these proposed changes is contingent upon the submittal
of the certifications required by 10 CFR 50.82(a)(1).
10 CFR 50.82(a)(2) states "Upon docketing of the certifications for permanent cessation of
operations and permanent removal of fuel from the reactor vessel, or when a final legally
effective order to permanently cease operations has come into effect, the 10 CFR part 50
license no longer authorizes operation of the reactor or emplacement or retention of fuel
into the reactor vessel."
10 CFR 50.36 establishes the requirements for Technical Specifications. 50.36(c)(5),
Administrative Controls, identifies that an Administrative Controls section shall be included
in the Technical Specifications and shall include provisions relating to organization and
management, procedures, recordkeeping, review and audit, and reporting necessary to
assure operation of the facility in a safe manner. This amendment request is proposing JAFP 15-143 Page 9 of 13 changes to the Administrative Controls section consistent with the pending
decommissioning status of the plant. This request applies the principles identified in
50.36(c)(6), Decommissioning, for a facility which has submitted certifications required by
50.82(a)(1) and proposes changes to the Administrative Controls appropriate for the JAF
permanently defueled condition. As 10 CFR 50.36(c)(6) states, this type of change should
be considered on a case-by-case basis.
10 CFR 50.54(m) establishes the requirements for having Reactor Operators and Senior
Reactor Operators licensed in accordance with Part 55 based on plant conditions. Based
on the impending permanent cessation of operation for JAF, the requirements of this
section will no longer apply once the certifications required by 10 CFR 50.82(a)(1) have
been submitted to the NRC and it will be permissible to remove those positions from the
Technical Specifications.
10 CFR 50.54(hh) establishes the requirements for developing, implementing and
maintaining procedures and strategies for addressing potential aircraft threats and large
area fires or explosions. 10 CFR 50.54(hh)(3) states that this section of the regulation does
not apply to nuclear power plants that have submitted the certifications required by 10 CFR
50.82(a).
3.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Pursuant to 10CFR50.92, Entergy Nuclear Operations, Inc. (ENO) has reviewed the proposed change and concludes that the change does not involve a significant hazards
consideration since the proposed change satisfies the criteria in 10CFR50.92(c). These
criteria require that operation of the facility in accordance with the proposed amendment
would not (1) involve a significant increase in the probability or consequences of an
accident previously evaluated; (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.
The proposed changes would revise and remove certain requirements contained within
Section 5.0, Administrative Controls, of the James A. Fitzpatrick Nuclear Power Plant (JAF)
Technical Specifications (TS). The TS requirements being changed would not be applicable
once it has been certified that all fuel has permanently been removed from the JAF reactor
in accordance with 10 CFR 50.82(a)(1)(ii). Once the certifications for permanent cessation
of operations and permanent fuel removal are made, the 10 CFR Part 50 license for JAF no
longer will authorize operation of the reactor or placement of fuel in the reactor vessel, in
accordance with 10 CFR 50.82(a)(2).
The discussion below addresses each of these criteria and demonstrates that the proposed
amendment does not constitute a significant hazard.
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment would not take effect until JAF has permanently
ceased operation and entered a permanently defueled condition. The
proposed amendment would modify the JA F TS by deleting the portions of the TS that are no longer applicable to a permanently defueled facility, while JAFP 15-143 Page 10 of 13 modifying the other sections to correspond to the permanently defueled
condition.
The deletion and modification of provisions of the administrative controls do
not directly affect the design of st ructures, systems, and components (SSCs) necessary for safe storage of irradiated fuel or the methods used for
handling and storage of such fuel in the fuel pool. The changes to the
administrative controls are administr ative in nature and do not affect any accidents applicable to the safe management of irradiated fuel or the
permanently shutdown and defueled condition of the reactor.
In a permanently defueled condition, the only credible accident is the fuel
handling accident.
The probability of occurrence of previously evaluated accidents is not
increased, since extended operation in a defueled condition will be the only
operation allowed, and therefore bounded by the existing analyses.
Additionally, the occurrence of postulated accidents associated with reactor
operation is no longer credible in a permanently defueled reactor. This
significantly reduces the scope of applicable accidents.
Therefore, the proposed amendment does not involve a significant increase
in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes have no impact on facility SSCs affecting the safe
storage of irradiated fuel, or on the methods of operation of such SSCs, or
on the handling and storage of irradiated fuel itself. The administrative
removal of or modifications of the TS that are related only to administration
of facility cannot result in different or more adverse failure modes or
accidents than previously evaluated bec ause the reactor will be permanently shutdown and defueled and JAF will no longer be authorized to operate the
reactor.
The proposed deletion of requirements of the JAF TS do not affect systems
credited in the accident analysis for the fuel handling accident at JAF. The
proposed TS will continue to require proper control and monitoring of safety
significant parameters and activities.
The proposed amendment does not result in any new mechanisms that
could initiate damage to the remaining relevant safety barriers for defueled
plants (fuel cladding and spent fuel cooling). Since extended operation in a
defueled condition will be the only operation allowed, and therefore bounded
by the existing analyses, such a condition does not create the possibility of a
new or different kind of accident.
Therefore, the proposed change does not create the possibility of a new or
different kind of accident from any previously evaluated.
JAFP 15-143 Page 11 of 13
- 3. Does the proposed amendment involve a significant reduction in a margin of safety? Response: No.
Because the 10 CFR Part 50 license for JAF will no longer authorize
operation of the reactor or emplacement or retention of fuel into the reactor
vessel once the certifications required by 10 CFR 50.82(a)(1) are submitted, as specified in 10 CFR 50.82(a)(2), the occurrence of postulated accidents
associated with reactor operation is no longer credible. The only remaining
credible accident is a fuel handling accident (FHA). The proposed
amendment does not adversely affect the inputs or assumptions of any of
the design basis analyses that impact the FHA.
The proposed changes are limited to those portions of the OL and TS that
are not related to the safe storage of irradiated fuel. The requirements that
are proposed to be revised or deleted from the JAF OL and TS are not
credited in the existing accident analysis for the remaining applicable
postulated accident; and as such, do not contribute to the margin of safety
associated with the accident analysis. Postulated DBAs involving the reactor
are no longer possible because the reactor will be permanently shutdown
and defueled and JAF will no longer be authorized to operate the reactor.
Therefore, the proposed change does not involve a significant reduction in
the margin of safety.
Based on the above, ENO concludes that the proposed amendment presents 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.
3.3 PRECEDENT
The proposed changes are consistent with the existing TS Administrative Controls currently in effect for Vermont Yankee Nuclear Power Station (DPR-28), which was last substantively
revised on December 22, 2014 (Reference 7).
The proposed changes are consistent with the existing TS Administrative Controls currently in effect for Millstone Nuclear Power Station (DPR-21), which was last substantively revised on March 31, 2001 (Reference 4). The Millstone license amendment that was issued to reflect the permanently shutdown status of the plant on November 9, 1999 (Reference 5),
contains TS Administrative Controls similar to those being proposed herein.
The proposed changes are also consistent with the TS Administrative Controls issued to
Zion Nuclear Power Station on December 30, 1999 (Reference 6) to reflect the permanently
shutdown status of the plant.
3.4 CONCLUSION
Based on the considerations discussed above, (1) there is 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
JAFP 15-143 Page 12 of 13
- 4. ENVIRONMENTAL CONSIDERATIONS This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10CFR51.22(c)(9) as follows:
(i) The amendment involves no significant hazards consideration.
As described in Section 3 of this evaluation, the proposed change involves no significant
hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed amendment does not involve any physical alterations to the plant
configuration that could lead to a change in the type or amount of effluent release offsite.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed amendment does not involve a significant increase in individual or
cumulative occupational radiation exposure.
Based on the above, ENO concludes that the proposed change meets the eligibility criteria for
categorical exclusion as set forth in 10CFR51.22(c)(9). Pursuant to 10CFR51.22(b), no
environmental impact statement or environm ental assessment need be prepared in connection with the issuance of this amendment.
- 5. REFERENCES
- 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," JAFP 15-133, dated November 18, 2015
- 2. Letter, Entergy Nuclear Operations, Inc. to USNRC "Request for Approval of Certified Fuel Handler Training Program," JAFP 15-142, dated January 15, 2016
- 3. NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants,"
Revision 4
- 4. Millstone Nuclear Power Station, Unit 1, Amendment No.109, License No. DPR-21, Date of Issuance March 31, 2001 (ADAMS Accession No. ML010920303)
- 5. NRC Safety Evaluation for Millstone Power Station Unit 1 in License Amendment 106 to DPR-21, dated November 9, 1999 (ADAMS Accession Nos. ML993330283
and ML993330269)
- 6. NRC Safety Evaluation for Zion Nuclear Station in License Amendments 180 and 167 (for Units 1 and 2 respectively (License Nos. DPR-39 and DPR-48)), dated
December 30, 1999 (ADAMS Accession Nos. ML003672704 and ML003672696)
JAFP 15-143 Page 13 of 13
- 7. Vermont Yankee Nuclear Power Station, Amendment No.260, License No. DPR-29, Date of Issuance December 22, 2014 (ADAMS Accession No. ML14217A072)
JAFP-15-143 Docket 50-333
Attachment 2 James A. FitzPatrick Nuclear Power Plant Markup of the Current Technical Specification Pages
(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools. (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. aGB, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 197 4; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993), 190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:
Amendment aG9 Renewed license No. DPR-59 Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility dtacility I 5.1.1 5.1.2 JAFNPP It The plant manager shall be responsible for overall p.'.J.aRt operation and shall delegate in writing the succession to this responsibility during his absence. The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety. The shift supervisor (SS) shall be responsible for the control command function.
During any absence of the SS from the control room while the plant is in MODE 1, 2, or 3, an individual with an active (SRO) license shall be designated to ass tr room co11111and function.
During any absence of the SS from the control room while the plant is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control l'!Gmll c;ommand function.
5.1-1 Amendment 214 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS the safe handling and 5.2 Organization storage of nuclear fuel 5.2.1 The corporate officer facility Each duty shift shall be composed of at least one shift supervisor and one Non-certified Operator.
Onsite and offsite organizatio s shall be established for eperation and corporate manage ent, respectively.
The onsite and offsite organizations shall in lude the positions for activities affecting safety of the nuclea pgwer
- a. b. Lines of authority, respo sibility, and communication shall be defined and establishe throughout highest management levels, intermediate levels, and all operating organization positions.
These relatio ships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmen al responsibilities and relationships, and job de criptions for key personnel positions, or in equivale t forms of documentation.
These requirements.
including t e plant-specific titles of those personnel fulfilling the esponsibilities of the positions delineated in these Technical Specifications, shall be documented in the UFSAR; f .1.t t T plant manager sh ope ation of the an onsi activities necessa maint nee of the p+aRt, ac1 1 y s orage responsible for ov rall safe shall have contr over those for safe and nuclear fuel a ave corporate sibility for overall plant nuclear safety and shall take an sures needed to ensure acceptable performance of the staff in ating, maintaining, and providing technical support to ; and Certified Fuel Handlers The Non-Certified
- d. The individua s w o rain e op , arry out radiation protection, or perform quality assuran functions may report to the appropriate onsite manager: howe r, these individuals shall have sufficient organizational fre om to ensure their :U:ldep deRGe-frGm operating pressures . Operator position may be filled by a Certified Fuel Handler. JAFNPP ability to perform their safe management assigned functions of nuclear fuel facility staff organization shall include the following: (continued) 5.2*1 Amendment 274 5.2 Organization 5.2.2 Plant Staff (continued)
Organization 5.2 b. Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f 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 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 whefl f1::.1el is in the during the movement "---" 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 of fuel and during the order to provide for unexpected absence, provided immediate action is movement of loads taken to fill the required position.
over fuel d. Deleted e. The shift supervisor shall be a Certified Fuel Handler JAFNPP 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. 5.2-2 Oversight of fuel handling operations shall be provided by a Certified Fuel Handler. Amendment 3G4 Plant Staff Qualifications 5.3 Facility 5.0 5.3 Staff Qualifications ritacility I \J,-5.3.1 Each member of the t:ffiit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Entergy Quality Assurance Program Manual (QAPM). 5.3.2 For the purpose of 10 CFR §§.4, a lieensed Senior Reaetor Operator (SRO) and a lieensed Reaetor Operator (RO) are those indi* .. iduals 1+*1ho, in addition to meeting the requirements of TS 6.a.1, perform the funetions deseribed in 10 CFR 60.§4\). JAFNPP \_An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained 5.3-1 Amendment a04 JAFP-15-143 Docket 50-333
Attachment 3 James A. FitzPatrick Nuclear Power Plant Retyped Technical Specification Pages
Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS
5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.
The plant manager or his designee shall approve, prior to Implementation, each proposed test, experiment, and Modification to systems or equipment that affect nuclear
safety. 5.1.2 The shift supervisor (SS) shall be responsible for the shift command function.
JAFNPP 5.1-1 Amendment 274
Organization 5.0 ADMINISTRATIVE CONTROLS
5.2 5.2 Organization 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. The corporate officer shall have overall responsibility for the safe handling and storage 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 organizational 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.
- 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.
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Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization (continued)
- c. A radiation protection technician shall be on site during the movement of fuel and during the movements 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.
JAFNPP 5.2-2 Amendment 274
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