BVY 04-078, Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process
| ML042640013 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim, Vermont Yankee, FitzPatrick File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/01/2004 |
| From: | Kansler M Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 04-078, ENO 2.04.068, JPN-04-015 | |
| Download: ML042640013 (37) | |
Text
En tergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President September 1, 2004 JPN-04-015 BVY 04-078 ENO 2.04.068 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Pilgrim Nuclear Power Station Docket No. 50-293 Vermont Yankee Nuclear Power Station Docket No. 50-271 Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process I
Gentlemen:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Nuclear Operations, Inc. (ENO) is submitting a request for amendments to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant, the Pilgrim Nuclear Power Station, and the Vermont Yankee Nuclear Power Station.
The proposed amendments would delete the TS requirements to submit monthly operating reports and occupational radiation exposure reports. The changes are consistent with NRC-approved industry Technical Specification Task Force (TSTF)
Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Rev. 1. The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed changes and confirmation of applicability, the existing TS pages marked-up to show the proposed changes, re-typed TS pages with the appropriate changes, and a summary of regulatory commitments for the James A. FitzPatrick Nuclear Power Plant.
Attachments 2 and 3 provide the same detailed descriptions of the proposed changes for the Pilgrim Nuclear Power Station and the Vermont Yankee Nuclear Power Station respectively.
ENO requests approval of the proposed license amendments by July 31, 2005, with the amendments being implemented within 60 days from the date of the approval.
ADD t
rs In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York, Massachusetts and Vermont State Officials.
The commitments made in this letter are contained in Attachments 1, 2, and 3. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1ft day of September, 2004.
Very truly yours ichael R. Kansl President Entergy Nuclear Operations, Inc cc: Next page Attachments:
- 1.
Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process - James A. FitzPartick Nuclear Power Plant
- 2.
Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process - Pilgrim Nuclear Power Station
- 3.
Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process - Vermont Yankee Nuclear Power Station c.I 2
cc:
Mr. Samuel J. Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Lee A. Licata, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Main Stop 0-8-Bl Washington, DC 20555-0001 Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-Bl Washington, DC 20555-0001 Mr. Peter R. Smith President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Mr. David O'Brien, Commissioner Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620 Resident Inspector James A. FitzPatrick Nuclear Power Plant U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093-0136 Resident Inspector Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission 600 Rocky Hill Road - Mail Stop 66 Plymouth, MA 02360 Resident Inspector Vermont Yankee Nuclear Power Station U.S. Nuclear Regulatory Commission 320 Governor Hunt Road P. 0. Box 157 Vernon, Vermont 05354 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223 Mr. Robert Walker Radiation Control Program Commonwealth of Massachusetts Exec. Offices of Health & Human Services 174 Portland Street Boston, MA 02114 Ms. Cristine McCombs, Director Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 3
ATTACHMENT 1 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 APPLICATION FOR TECHNICAL SPECIFICATIONS IMPROVEMENT TO ELIMINATE REQUIREMENTS TO PROVIDE MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Enclosures DESCRIPTION AND ASSESSMENT (3 pages)
TECHNICAL SPECIFICATION PAGES (MARKED-UP)
(2 pages)
TS Pages 5.6-1 5.6-2 TECHNICAL SPECIFICATION PAGES (RE-TYPED)
(3 pages)
TS Pages 5.6-1 5.6-2 5.6-3
SUMMARY
OF REGULATORY COMMITMENTS (1 page)
Entergy Nuclear Operations, Inc. - FitzPatrick Nuclear Power Plant Docket No. 50-333 Description and Assessment
1.0 INTRODUCTION
The proposed License amendment deletes the requirements in Technical Specification (TS) section 5.6.1 for an annual report on occupational radiation exposures and TS section 5.6.4 for a monthly report of operating statistics and shutdown experience.
The changes are consistent with NRC-approved industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1.
The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067), as part of the consolidated line item improvement process (CLIIP).
2.0 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:
Reporting Requirements-Occupational TS 5.6.1 Radiation Exposure Repori Deleted Reporting Requirements - Monthly TS 5.6.4 Operating Reports Deleted
3.0 BACKGROUND
The background for this application is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev.1.
5.0 TECHNICAL ANALYSIS
Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation (SE) published on June 23, 2004 (69 FR 35067) as part of the CLIIP Notice of Availability.
This verification included a review of the NRC staff's safety evaluation as well as the supporting information provided to support TSTF-369, Rev. 1. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to FitzPatrick and justify this amendment for the incorporation of the changes to the FitzPatrick TS.
1 Entergy Nuclear Operations, Inc. -
FitzPatrick Nuclear Power Plant Docket No. 50-333
6.0 REGULATORY ANALYSIS
A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
6.1 Verification and Commitments As discussed in the model safety evaluation published in the Federal Registeron June 23, 2004 (69 FR 35067) for this TS improvement, ENO is making the following regulatory commitment:
ENO is making a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months going forward from approval of this amendment will be provided using CDE).
In regards to the second commitment discussed in the Federal Register on June 23, 2004 (69 FR 35067) pertaining to the apportionment of station doses, FitzPatrick is a single unit site and neither has different reactor types nor both operating and shutdown reactors on the same site. Therefore, this commitment does not apply.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION ENO has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to FitzPatrick and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
8.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to FitzPatrick and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the CLIIP. ENO is not proposing variations or deviations from the TS changes described in TSTF-369, Rev. 1, or the NRC staff's model safety evaluation published on June 23, 2004 (69 FR 35067).
2 Entergy Nuclear Operations, Inc. - FitzPatrick Nuclear Power Plant Docket No. 50-333
10.0 REFERENCES
Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement To Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).
3 Entergy Nuclear Operations, Inc. - FitzPatrick Nuclear Power Plant Docket No. 50-333 TECHNICAL SPECIFICATION PAGES (MARKED-UP)
TS PAGES 5.6-1 5.6-2
Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.
5.6.1 ccu adiati xos
/ ( Atabulation gm-'an annual basis of the nmtofsation, utilit, and other sesonnel (including contrco, o hom monitoring X
/was pegfmed receiving an annual de!dose equivalent
/>
10 pEems and the associated co~dcie deep dose equivalent (r rted in person-rein) accor g to work and job function e.g.. reactor operations ansurveillance, inservice Ins ction.
routine maintenance, spec maintenance (describe mai_6nance),
waste processing, and uellng). This tabulation plements the requirements of 10 20.2206. The dose assignnts to various duty functions m e estimated based on ocke onization chamber, the uminescent dosimeter (TLD.
ectronic dosimeter, or film ba measurements.
Small expos s totalling < 20X of the indi total dose need not Oeri efor. In the aggreAnn at least 80% of the n
onmenta p dose equivalent recin e fr nrxernal sources should be a'i ned to specific major srk
(
Jucions. The report. coveri th prvious calendar RE shall XY be submitted by April 30 ooac yar.
Jr 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the plant during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period at the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be (continued)
JAFNPP 5.6-1 Amendment-274-
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted in a supplementary report as soon as possible.
5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the plant during the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I.Section IV.B.1.
5.6.4 onthl 0 e s
[Routige p r s of operating sritics and shutdown ger ence uJ s
be submitted on a mo fy basis no later th he 15th of a-ch month following t alendar month covere y the report.
5.6.5 CORE OPERATING LIMITS REPORT (COLR)
- a.
Core operating limits shall be established prior to each reload cycle, or nrior to any remaining portion of a reload cycle, and shall be documented in the COrR for the following:
- 1.
The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) of Specification 3.2.1;
- 2. The MINIMUM CRITICAL POWER RATIO (MCPR) of Specification 3.2.2:
- 3.
The LINEAR HEAT GENERATION RATE (LHGR) of Specification 3.2.3:
(continued)
JAFNPP 5.6-2 Amendment l,
Entergy Nuclear Operations, Inc. - FitzPatrick Nuclear Power Plant Docket No. 50-333 TECHNICAL SPECIFICATION PAGES (RE-TYPED)
TS PAGES 5.6-1 5.6-2 5.6-3
I Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.
5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the plant during the previous calendar year shall be submitted by May 15 of each year.
The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM),
and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period at the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1.
November 1979.
In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted in a supplementary report as soon as possible.
5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the plant during the previous year shall be submitted prior to May 1 of each year in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the plant. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.
(continued)
JAFNPP 5.6-1 Amendment XXX
Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.4 Not Used 5.6.5 CORE OPERATING LIMITS REPORT (COLR)
- a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COER for the following:
- 1. The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) of Specification 3.2.1;
- 2. The MINIMUM CRITICAL POWER RATIO (MCPR) of Specification 3.2.2;
- 3. The LINEAR HEAT GENERATION RATE (LHGR) of Specification 3.2.3;
- 4. The Reactor Protection System (RPS) APRM Neutron Flux-High (Flow Biased) Function Allowable Value of Table 3.3.1.1-1;
- 5. The Rod Block Monitor-Upscale Function Allowable Value of Table 3.3.2.1-1; and
- 6. The Power/Flow Exclusion Region of Specification 3.4.1.
- b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:
- 1. NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel;
- 2. NEDC-31317P, James A. FitzPatrick Nuclear Power Plant SAFER/GESTR-LOCA Loss-of-Coolant Accident Analysis; and
- 3. NEDO-31960-A, BWR Owners' Group Long-Term Stability Solutions Licensing Methodology.
The COLR will contain the complete identification for each of the Technical Specification referenced topical reports used to prepare the COLR (i.e.. report number, title, revision, date, and any supplements).
(continued)
JAFNPP 5.6-2 Amendment XXX
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)
- c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM. transient analysis limits, and accident analysis limits) of the safety analysis are met.
- d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
5.6.6 PAM Report When a report is required by Condition B or F of LCO 3.3.3.1.
"Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
JAFNPP 5.6-3 Amendment XXX Entergy Nuclear Operations, Inc. - FitzPatrick Nuclear Power Plant Docket No. 50-333
SUMMARY
OF REGULATORY COMMITMENTS The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Commitments Description Completion Schedule FitzPatrick will provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry 60 days from the date (CDE) program, currently being of approval of the developed and maintained by the proposed amendment.
Institute of Nuclear Power Operations).
This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months going forward from approval of this amendment will be provided using CDE).
1
ATTACHMENT 2 Pilgrim Nuclear Power Station Docket No. 50-293 APPLICATION FOR TECHNICAL SPECIFICATIONS IMPROVEMENT TO ELIMINATE REQUIREMENTS TO PROVIDE MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS Enclosures
- DESCRIPTION AND ASSESSMENT (3 pages)
- TECHNICAL SPECIFICATION PAGES (MARKED-UP)
(2 pages)
TS Pages 5.0-11 5.0-12
- TECHNICAL SPECIFICATION PAGES (RE-TYPED)
(2 pages)
TS Pages 5.0-11 5.0-12
SUMMARY
OF REGULATORY COMMITMENTS (1 page)
Entergy Nuclear Operations, Inc. -
Pilgrim Nuclear Power Station Docket No. 50-293 Description and Assessment
1.0 INTRODUCTION
The proposed License amendment deletes the requirements in Technical Specification (TS) section 5.6.1 for an annual report on occupational radiation exposures and TS section 5.6.4 for a monthly report of operating statistics and shutdown experience.
The changes are consistent with NRC-approved industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1.
The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067), as part of the consolidated line item improvement process (CLIIP).
2.0 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:
Reporting Requirements - Occupational TS 5.6.1 Radiation Exposure Report Deleted Reporting Requirements - Monthly TS 5.6.4 Operating Reports Deleted
3.0 BACKGROUND
The background for this application is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev.1.
5.0 TECHNICAL ANALYSIS
Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation (SE) published on June 23, 2004 (69 FR 35067) as part of the CLIIP Notice of Availability.
This verification included a review of the NRC staff's safety evaluation as well as the supporting information provided to support TSTF-369, Rev. 1. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Pilgrim and justify this amendment for the incorporation of the changes to the Pilgrim TS.
1 Entergy Nuclear Operations, Inc. -
Pilgrim Nuclear Power Station Docket No. 50-293
6.0 REGULATORY ANALYSIS
A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
6.1 Verification and Commitments As discussed in the model safety evaluation published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, ENO is making the following regulatory commitment:
ENO is making a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, 'Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months going forward from approval of this amendment will be provided using CDE).
In regards to the second commitment discussed in the Federal Register on June 23, 2004 (69 FR 35067) pertaining to the apportionment of station doses, Pilgrim is a single unit site and neither has different reactor types nor both operating and shutdown reactors on the same site. Therefore, this commitment does not apply.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION ENO has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to Pilgrim and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
8.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to Pilgrim and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the CLIIP. ENO is not proposing variations or deviations from the TS changes described in TSTF-369, Rev. 1, or the NRC staff's model safety evaluation published on June 23, 2004 (69 FR 35067).
2 Entergy Nuclear Operations, Inc. - Pilgrim Nuclear Power Station Docket No. 50-293
10.0 REFERENCES
Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement To Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).
3 Entergy Nuclear Operations, Inc. - Pilgrim Nuclear Power Station Docket No. 50-293 TECHNICAL SPECIFICATION PAGES (MARKED-UP)
TS PAGES 5.0-11 5.0-12
Reporting Requirements 5.6 5.0 ADMINISTRATiVE CONTROLS 5.6 Reporting Requirements The following reports shall b submitted in accordance with 10 CFR 50.4.
5.6.1 cu a a
A taua a
n annual basis of the number of station, utility, and o personnel (inclun ontractors) receiving exposures > 10 D
and their associated man rem rme according to work and joi n
(erg., reactor operations and surveillance, ce inspection, e maintenance, special maintenance (including description sing, and refueing). This tabulation supplements the requirem o
CFR 20.2206. The dose assignments to various duty fu ns may be es d based on pocket dosimeter, thermolumine dosimeter (TLD), or film measurements.
Small exposures t g <20% of the individual total dose nee t be.
accounted fo the aggregate, at least 80% of the total whole se receiv om external sources should be assigned to specific major work ions. The report shall be submitted by April 30 of each year.
5.6.2 Annual Radiological Environmental Operatina Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall Include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified In the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted In a supplementary report as soon as possible.
(Continued)
PNPS 5.0-11 Amendment No. Sty-I"
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be submitted In accordance with 10 CFR 50.36a by May 1 5th of each year. The report shall Include a summary of the quantities of.radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and process control procedures and In conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.
-Not use'd 5.6.4 o
ou erprsopera n
eprec submitted on a rn g
later than the nt1 h follwnth 5.6.5 Core Operating Limits Reoort (COLR)
- a.
Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented In the COLR for the following:
- 1.
Table 3.1.1 - APRM High Flux trip level setting
- 2.
Table 3.2.C -APRM Upscale trip level setting
- 3.
3.11.A - Average Planar Linear Heat Generation Rate (APLHGR)
- 4.
3.11.B - Linear Heat Generation Rate (LHGR)
- 5.
3.11.C -Minimum Critical Power Ratio (MCPR)
- 6.
3.11.D - Power/Flow Relationship During Power Operation
- b.
The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described In the following documents:
- 1.
NEDE-2401 1-P-A, 'General Electric Standard Application for Reactor Fuel,' (through the latest approved amendment at the time the reload analyses are performed as specified in the COLR).
(5Co.ir8,4A)
PNPS 5.0-12 Amei'dment No. 1-B7,4g.--
Entergy Nuclear Operations, Inc. - Pilgrim Nuclear Power Station Docket No. 50-293 TECHNICAL SPECIFICATION PAGES (RE-TYPED)
TS PAGES 5.0-11 5.0-12
Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.
5.6.1 Not Used 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and In 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include a summary of the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table In the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some Individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.
(Continued)
PNPS 5.0-1 1 Amendment No. 49
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be submitted in accordance with 10 CFR 50.36a by May 15th of each year. The report shall Include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined In the ODCM and process control procedures and In conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.
5.6.4 Not Used 5.6.5 Core Onerating Limits Renort (COLR)
- a.
Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented In the COLR for the following:
- 1.
Table 3.1.1 - APRM High Flux trip level setting
- 2.
Table 3.2.C -APRM Upscale trip level setting
- 3.
3.11.A - Average Planar Linear Heat Generation Rate (APLHGR)
- 4.
3.11.B - Linear Heat Generation Rate (LHGR)
- 5.
3.11.C -Minimum Critical Power Ratio (MCPR)
- 6.
3.11.D - Power/Flow Relationship During Power Operation
- b.
The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
- 1.
NEDE-2401 1-P-A, General Electric Standard Application for Reactor Fuel,u (through the latest NRC approved amendment at the time the reload analyses are performed as specified in the COLR).
(Continued)
PNPS 5.0-12 Amendment No. 48I,494-Entergy Nuclear Operations, Inc. - Pilgrim Power Station Docket No. 50-293
SUMMARY
OF REGULATORY COMMITMENTS The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Commitments Description Completion Schedule Pilgrim will provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry 60 days from the date (CDE) program, currently being of approm the developed and maintained by the of approval of the Institute of Nuclear Power Operations).
proposed amendment.
This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months going forward from approval of this amendment will be provided using CDE).
I
ATTACHMENT 3 Vermont Yankee Nuclear Power Station Docket No. 50-271 APPLICATION FOR TECHNICAL SPECIFICATIONS IMPROVEMENT TO ELIMINATE REQUIREMENTS TO PROVIDE MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TECHNICAL SPECIFICATIONS PROPOSED CHANGE NO. 269)
Enclosures
- DESCRIPTION AND ASSESSMENT (3 pages)
- TECHNICAL SPECIFICATION PAGES (MARKED-UP)
(2 pages)
TS Pages 258 259
- TECHNICAL SPECIFICATION PAGES (RE-TYPED)
(2 pages)
TS Pages 258 259
SUMMARY
OF REGULATORY COMMITMENTS (1 page)
Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271 Description and Assessment
1.0 INTRODUCTION
The proposed License amendment deletes the requirements in Technical Specification (TS) section 6.6.A for an annual report on occupational radiation exposures and TS section 6.6.B for a monthly report of operating statistics and shutdown experience.
The changes are consistent with NRC-approved industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1.
The availability of this TS improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067), as part of the consolidated line item improvement process (CLIIP).
2.0 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:
Reporting Requirements - Occupational TS 6.6.A Radiation Exposure Report Deleted Reporting Requirements - Monthly TS 6.6.B Operating Reports Deleted
3.0 BACKGROUND
The background for this application is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev.1.
5.0 TECHNICAL ANALYSIS
Entergy Nuclear Operations, Inc. (ENO) has reviewed the safety evaluation (SE) published on June 23, 2004 (69 FR 35067) as part of the CLIIP Notice of Availability.
This verification included a review of the NRC staff's safety evaluation as well as the supporting information provided to support TSTF-369, Rev. 1. ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Vermont Yankee and justify this amendment for the incorporation of the changes to the Vermont Yankee TS.
1 Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271
6.0 REGULATORY ANALYSIS
A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369, Rev. 1.
6.1 Verification and Commitments As discussed in the model safety evaluation published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, ENO is making the following regulatory commitment:
ENO is making a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar. month) that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months going forward from approval of this amendment will be provided using CDE).
In regard to the second commitment discussed in the Federal Register on June 23, 2004 (69 FR 35067) pertaining to the apportionment of station doses, Vermont Yankee is a single unit site and neither has different reactor types nor both operating and shutdown reactors on the same site. Therefore, this commitment does not apply.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION ENO has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to Vermont Yankee and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
8.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on June 23, 2004 (69 FR 35067) as part of the CLIIP. ENO has concluded that the staff's findings presented in that evaluation are applicable to Vermont Yankee and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the CLIIP. ENO is not proposing variations or deviations from the TS changes described in TSTF-369, Rev. 1, or the NRC staff's model safety evaluation published on June 23, 2004 (69 FR 35067) 2 Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271
10.0 REFERENCES
Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement To Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).
3 Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271 TECHNICAL SPECIFICATION PAGES (MARKED-UP)
TS PAGES 258 259
pc-6q VYNPS A.
Paragraph 20.1601, "Control of Access to High. Radiation Areas.
In lieu of the "control device" or "alarm signal" required by Paragraph 20.1601(a), each high radiation area in which the intensity of radiation is greater than 100 mrem/hr at 30 cm, but less than 1000 mrem/hr at 30 cm, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP).
Radiation Protection personnel qualified in radiation protection-procedutes (e.g., radiation protection technicians) may be'exempt from the'RWP issuance requirement during the performance of their assigned duties in high radiation areas, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.
Any individual or group of individuals permitted to enter such areas shall' be provided with one or more of the following:
- 1.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
- 2.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
- 3.
A Radiation Protection individual qualified in radiation protection procedures (e.g., radiation protection technicians) with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and who will perform direct or remote (such as closed circuit. TV cameras) periodic radiation surveillance at the frequency specified in the RWP.
The surveillance frequency will be established by the radiation protection manager.
B.
The above procedure shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr at 30 cm, but less than 500 rad/hr at 1 meter.
In addition, locked or continuously guarded entryways shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the shift supervisor on duty and/or the radiation protection manager.
6.6 REPORTING REQUIREMENTS Thee following reports shall be submitted in accordance with 10 CFR 50.4.
A.
Occu ational Raaia on Ex osure Renor An annual e-port covering t previous calendar shall be subm i prior to Apri 0 of each yea rt sha Amendment No. 3-&, 4Z, 44k, 214 258
VYNPS B.
Monthly Operatirg-Re OrtB g be >
i Routine rts of operat statistics and sh own experience sh\\
be s ted on a monrhry basis no later tithe fifteenth of I
mou following t ~calendar month coyv, d by the report.
ese ports shall dlude a narrative ary of operatin erience during the&
Rport period which scribes the opera n of the C.
Core Operating Limits Report The core operating limits shall be established and documented in the Core Operating Limits Report (COLR) before each reload cycle or any remaining part of a reload cycle for the following:
- 1.
The Average Planar Linear Heat Generation Rates (APLHGR) for Specifications 3.11.A and 3.6.G.la,
- 2.
The Minimum Critical Power Ratio (MCPR) for Specifications 3.l1.C and 3.6.G.la,
- 3.
The Linear Heat Generation Rates (LHGR) for Specifications 2.1.A.la and 3.11.B, and
- 4.
The Power/Flow Exclusion Region for Specifications 3.6.J.l.a and 3.6.J.l.b.
The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in:
Report, E. E. Pilat, "Methods for the Analysis of Boiling Water Reactors Lattice Physics," YAEC-1232, December 1980 (Approved by NRC SER, dated September 1S, 1982).
1/ This tabulation supplements the requirements of 20.2206 of 10 CFR Part 20.
Amendment No. 4X, C, a4Z, 4-7-1,,
219 259 Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271 TECHNICAL SPECIFICATION PAGES (RE-TYPED)
TS PAGES 258 259
VYNPS A.
Paragraph 20.1601, "Control of Access to High Radiation Areas.
In lieu of the "control device" or "alarm signal" required by Paragraph 20.1601(a), each high radiation area in which the intensity of radiation is greater than 100 mrem/hr at 30 cm, but less than 1000 mrem/hr at 30 cm, shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP).
Radiation Protection personnel qualified in radiation protection procedures (e:g., radiation protection technicians) may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.
Any individual or group of individuals permitted to enter such areas shall be provided with one or more of the following:
- 1.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
- 2.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.
Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
- 3.
A Radiation Protection individual qualified in radiation protection procedures (e.g., radiation protection technicians) with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and who will perform direct or remote (such as closed circuit TV cameras) periodic radiation surveillance at the frequency specified in the RWP.
The surveillance frequency will be established by the radiation protection manager.
B.
The above procedure shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr at 30 cm, but less than 500 rad/hr at 1 meter.
In addition, locked or continuously guarded entryways shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the shift supervisor on duty and/or the radiation protection manager.
6.6 REPORTING REQUIREMENTS The following reports shall be submitted in accordance with 10 CFR 50.4.
A.
Deleted Amendment No. 34, 4-2-, 171, 2-14 258
VYNPS B.
Deleted C.
Core Operating Limits Report The core operating limits shall be established and documented in the Core Operating Limits Report (COLR) before each reload cycle or any remaining part of a reload cycle for the following:
- 1.
The Average Planar Linear Heat Generation Rates (APLHGR) for Specifications 3.11.A and 3.6.G.la,
- 2.
The Minimum Critical Power Ratio (MCPR) for Specifications 3.11.C and 3.6.G.la,
- 3.
The Linear Heat Generation Rates (LHGR) for Specifications 2.1.A.la and 3.11.B, and
- 4.
The Power/Flow Exclusion Region for Specifications 3.6.J.l.a and 3.6.J.1.b.
The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in:
Report, E. E. Pilat, "Methods for the Analysis of Boiling Water Reactors Lattice Physics," YAEC-1232, December 1980 (Approved by NRC SER, dated September IS, 1982).
Amendment No. 4-,
- 44D,
+44, 1,
1
, 2 12 259 Entergy Nuclear Operations, Inc. - Vermont Yankee Nuclear Power Station Docket No. 50-271
SUMMARY
OF REGULATORY COMMITMENTS The following table identifies those actions committed to by ENO in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Commitments Description Completion Schedule Vermont Yankee will provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's 60 days from the date Consolidated Data Entry (CDE) of approval of the program, currently being developed and provaleofmthe maintained by the Institute of Nuclear proposed amendment.
Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e.,
data for all months going forward from approval of this amendment will be provided using CDE).
1