NL-04-135, Proposed Change to Technical Specifications Regarding Removal of Monthly Operating Report and Occupational Radiation Exposure Report (TSTF-369, Revision 1.)
| ML043140229 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/25/2004 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-04-135 | |
| Download: ML043140229 (14) | |
Text
AM Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB
'v:Z" EnteTelP9147346700 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Adminrstration October 25, 2004 Re:
Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-04-135 Document Control Desk U.S. Nuclear Regulatory Commission Mail Stop O-P1-17 Washington, DC 20555-0001
Subject:
Proposed Change to Technical Specifications Regarding Removal of Monthly Operating Report and Occupational Radiation Exposure Report (TSTF-369, Revision 1)
Reference:
- 1) Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-369, Revision 1.
- 2) Federal Register Notice 69 FR 35067, "Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process," dated June 23, 2004.
Dear Sir:
Pursuant to 10CFR50.90, Entergy Nuclear Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3).
The proposed amendment will delete the requirements in the TS to submit monthly operating reports and occupational radiation exposure reports. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report" (Reference 1). The availability of this TS improvement was announced in the Federal Register on June 23, 2004 as part of the consolidated line item improvement process (Reference 2). provides a description of the proposed change, the confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change.
NL-04-135 Docket 50-247 & 50-286 Page 2 of 3 The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92 (c) and Entergy has determined that these proposed changes involve no significant hazards considerations. A copy of this application and the associated attachments are being submitted to the designated New York State official.
The new regulatory commitments required for implementation of the requested license amendment is summarized in Attachment 3. Entergy requests approval of the proposed amendment by August 2005 with the amendment being implemented within 30 days. If you have any questions or require additional information, please contact Mr. Kevin Kingsley at (914) 734-6695.
I declare under penalty of perjury that the foregoing is true and correct. Executed on L //
)
Fred R. Dacimo Site Vice President Indian Point Energy Center cc: next page
NL-04-135 Docket 50-247 & 50-286 Page 3 of 3 cc:
Mr. Patrick D. Milano, Senior Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2 Washington, DC 20555-0001 Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office Indian Point Unit 2 Nuclear Power Plant U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Mr. Peter R. Smith, President New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-6399
ATTACHMENT 1 TO NL-04-135 DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING REMOVAL OF MONTHLY OPERATING REPORT AND OCCUPATIONAL RADIATION EXPOSURE REPORT ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286 to NL-04-135 Docket 50-247 and 50-286 Page 1 of 3
1.0 INTRODUCTION
The proposed License amendment changes Technical Specification (TS) sections 5.6.1 and 5.6.4 for both Indian Point Unit 2 (1P2) and Indian Point Unit 3 (1P3) regarding the Monthly Operating and Occupational Radiation Exposure Reports.
The changes are consistent with Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-369, Revision 1, 'Removal of Monthly Operating Report and Occupational Radiation Exposure Report." The availability of this technical improvement was announced in the Federal Register on June 23, 2004 as part of the consolidated line item improvement process (CLIIP).
2.0 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with Revision 1 of TSTF-369, the proposed TS changes include:
Indian Point 2
- TS 5.6.1 Occupational Radiation Exposure Report Deleted
- TS 5.6.4 Monthly Operating Report Deleted v Indian Point 3
- TS 5.6.1 Occupational Radiation Exposure Report Deleted
- TS 5.6.4 Monthly Operating Report Deleted
3.0 BACKGROUND
The background for this application is addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067), TSTF-369 Revision 1, 'Removal of Monthly Operating Report and Occupational Radiation Exposure Report.
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), TSTF-369 Revision 1, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report".
Attachment I to NL-04-135 Docket 50-247 and 50-286 Page 2 of 3
5.0 TECHNICAL ANALYSIS
Entergy has reviewed the model safety evaluation (SE) published on June 23, 2004 (69 FR 35067), and verified its applicability as part of the CLIIP. This verification included a review of the NRC staff's model SE, as well as the information provided to support TSTF-369, Revision 1.
Entergy has concluded that the justifications presented in the TSTF proposal and the model SE prepared by the NRC staff are applicable to IP2 and IP3 and justify this amendment for the incorporation of the changes to the respective plant Technical Specifications as described in Section 2.0 above.
Indian Point 3 TS Section 5.6.4 includes a requirement for reporting challenges to the pressurizer power operated relief valves and pressurizer safety valves. TSTF-258, Revision 4, "Changes to Section 5.0, Administrative Controls", documents the conclusion that this information is not used by the NRC staff for evaluation of Monthly Operating Report data. The information needed by the NRC regarding challenges to these relief and safety valves is adequately addressed by the reporting requirements of 10 CFR 50.73. Therefore, this aspect of the Monthly Operating Report in IP3 TS Section 5.6.4 is eliminated.
Entergy is also the licensee (Docket 50-3) for Indian Point Unit 1 (IP1) which is a shutdown facility co-located with IP2 and IP3. The IP1 Technical Specifications regarding reporting requirements (TS Section 6.0) refers to the IP2 Technical Specifications and therefore no change to the IP1 license is required.
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), TSTF-369, Revision 1. This notice included a discussion of the availability of TSTF-258, Revision 4 regarding the disposition of reporting requirements for challenges to pressurizer power operated relief valves and safety valves.
6.1 Verification of Commitments As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067), for this TS improvement, Entergy is making the following verifications and regulatory commitment:
- 1. Entergy 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 will be provided using one or both systems (monthly operating reports and CDE)). The regulatory commitment to provide the operating data that is to NL-04-135 Docket 50-247 and 50-286 Page 3 of 3 described in Generic Letter 97-02 will be included in the Technical Requirements Manuals for 1P2 and IP3.
- 2. Entergy is making a regulatory commitment to provide occupational exposure information to the NRC annually, in accordance with 10 CFR 20.2206, to support the apportionment of station doses to differentiate between the operating and shutdown units. The data will provide the summary distribution of annual whole body doses as presented in Appendix B of NUREG-0713 for operating and shutdown units. This commitment to provide occupational exposure information will be included in the Technical Requirements Manuals or IP2 and IP3.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. Entergy has concluded that the proposed determination presented in the notice is applicable to IP2 and IP3, and the determination is hereby. incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on
'.June 23, 2004 (69 FR 35067) as part of the CLIIP. Entergy has concluded that the staff's
-findings presented in that evaluation are applicable to 1P2 and IP3, and the evaluation is hereby
.incorporated by reference for this application.
9.0
- PRECEDENT This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-369, Revision 1 or the NRC staff's model SE published on June 23, 2004 (69 FR 35067).
ATTACHMENT 2 TO NL-04-135 MARK-UP OF TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING REMOVAL OF MONTHLY OPERATING REPORT AND OCCUPATIONAL RADIATION EXPOSURE REPORT Indian Point 2:
Page 5.6-1 Page 5.6-2 Indian Point 3:
Page 5.0-32 Page 5.0-33 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286
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 Geeunetienal Redietien Expesure Repor
,j)4 Lksed A single ubmitta y be ade for a Itiple i tion sub should combi sections ommo to all units the stat' n.
A t ulation o an ann basis of e numbe ostation, tity, and er personel (i cluding c tractor, for who monitori was perf rmed, rec ving an an ual eep dos equiv nt > 100 mreis a the ass iated collctive deep ose equivale (repo d in pers
- rem) ccording t work and 'ob function (e.g.,
reactor perati ns and su eillance, nservice i pection, r utine maint nance, speci maint ance, wae process Ig, and refu ing). This bulation su lements the equire ents of 1, CFR 20.
- 06.
The ose assig ments to v ious duty fu ctions may be estimat based on pock ionization chamber ermol inescenc dosimer (ILD),
lectronic osimeter, or film bad e meas ements.
all expo res totalin <20 perce t of the indivi ual total d se nee ot be acc unted for/In the aggr gate, at le t 80 percent the total eep do equivale received rom externa ources sh Id be assigne to specifi major rk functio
. The re6rt covering the previous alendar years all be submitted by pril 30 of ach year 5.6.2 Annual Radiological Environmental Operating Report
- NOTE -
A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.
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.
A full listing of the information to be contained in the Annual Radiological Environmental Operating Report is provided in the ODCM.
INDIAN POINT 2 5.6 - 1 Amendment No. 238
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report
- NOTE -
A single submittal may be made for a multiple unit station. The submittal shall combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.
The Radioactive Effluent Release Report covering the operation of the unit in 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 unit. 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 Monthly Ooatin=
PiRe ts - No
.)SQX-s Routine reports of operating statistics and shutdon experience s be sumitte e-a monthly basis--nG-aterhan the 5th ach month following the calendar
.onth covcred by the report.
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 COLR for the following:
- 1.
Technical Specification 2.1, Safety Limits (SL);
- 2.
Technical Specification 3.1.1, SHUTDOWN MARGIN (SDM);
- 3.
Technical Specification 3.1.3, Moderator Temperature Coefficient (MTC);
- 4.
Technical Specification 3.1.5, Shutdown Bank Insertion Limits;
- 5.
Technical Specification 3.1.6, Control Bank Insertion Limits;
- 6.
Technical Specification 3.2.1, Heat Flux Hot Channel Factor (FO(Z));
- 7.
Technical Specification 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor; INDIAN POINT 2 5.6 - 2 Amendment No. 238
Reporting Requi rements 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 Qccuvational rgadiato2xoueRpr
- Noi LkseA A tabulat.on on a annua basis of the nu er of s ation, utility, and ot r pers nel (in uding ntracto s), fo whom monitor ng was erform d, receiv ng an nual deep dose equiv ent 0 mrem and the ssocia d colle tive d p dos equi lent C eported in perso rem) ccordin to word and ob fun tions
.g., r ctor oper tions d surve'lance/inser ce in pectiao routi mainten ce, sp ial mai tenanc, wast ocessi
, and r fueling).
This bulatio suppl96ents e
equire ents of 0 CFR 20 206.
e dose ssignm ts to ariou duty f nctions ay be ess mated _ased on ocket onizati n charb r, ther oluminesc ce dosimeter CT D), el ctroni dosi eter, o film bad measu ements.
small xposur tota ing percen of the i ividu total d se nee not b accou ted fir. In e aggregae, at 1 ast 80 p rcent f the tal d ep ose equi ialent rec ved fr m exter 1 sources sho d be.'
assigne to specif/ major work fu tions./ The reort c ering the pr ious cale ar ye shall submi ted by pril of each ear.
5.6.2 Annual Radiological Environmental Operatina Report
NOTE-------------------------------
A single submittal may be made for a multiple unit station.
The submittal should combine sections common to all units at the station.
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.
(continued)
INDIAN POINT 3 5.0 - 32 Amendment 205
Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued)
A full listing of the information to be contained in the Annual Radiological Environmental Operating Report is provided in the ODCM.
5.6.3 Radioactive Effluent Release Report
NOTE----------------------------
A single submittal may be made for a multiple unit station.
The submittal shall combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.
The Radioactive Effluent Release Report covering the operation of the unit in 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 unit.
The material provided shall be consistent with the objectives outlined in the ODCM and Process control Program and in conformance with 10 CFR Part 50.36a and 10 CFR 50, Appendix I, section IV.B.1.
5.6.4 M-nthhi, Oerating eppor-t bcA k~sR.
5 Rout.ne reports o operating statist'cs a d shutdown experience, inc uding dcumen ation of al chal engef to t pre uriz r p0 er ope ted r 1ief alves/or pr ssury er safety valyes shall b
submitted on/a mon hly b sis n lat'r than the J9 th of each onth f1 lowin the alend r mon co ered by the kepor 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 COLR for the following:
(continued)
INDIAN POINT 3 5.0 - 33 Amendment 205
ATTACHMENT 3 TO NL-04-135 COMMITMENT FOR IMPLEMENTATION OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-369, REVISION I ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286
IJ., to NL-04-135 Docket 50-247 and 50-286 Page 1 of 1 Commitment for Implementation of Licensing Amendment Request ID DESCRIPTION DATE NL-04-135-A Entergy is making a regulatory commitment to provide to 30 days (for IP2) the NRC using an industry database the operating data following NRC (for each calendar month) that is described in Generic approval of NL-04-135-1 Letter 97-02, "Revised Contents of the Monthly the License (for IP3)
Operating Report," by the last day of the month following Amendment the end of each calendar quarter. The regulatory Request 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 will be provided using one or both systems (monthly operating reports and CDE)). The regulatory commitment to provide the operating data that is described in Generic Letter 97-02 will be included in the Technical Requirements Manuals for IP2 and IP3.
NL-04-135-B Entergy is making a regulatory commitment to provide 30 days (for IP2) occupational exposure information to the NRC annually, following NRC in accordance with 10 CFR 20.2206, to support the approval of NL-04-135-2 apportionment of station doses to differentiate between the License (for IP3) the operating and shutdown units. The data will provide Amendment the summary distribution of annual whole body doses as Request presented in Appendix B of NUREG-0713 for operating and shutdown units. This commitment to provide occupational exposure information will be included in the Technical Requirements Manuals for IP2 and IP3.