ML043280503

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Application for Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports (TSTF-369, Revision 1)
ML043280503
Person / Time
Site: Harris, Brunswick, Crystal River, Robinson  
Issue date: 11/17/2004
From: Hinnant C
Progress Energy Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PE&RAS04-104, TSTF-369, Rev 1
Download: ML043280503 (38)
v • d • e


Text

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C. S. Hinnant Progress Energy Senior Vce President and Chief Nuclear Officer Progress Energy, Inc.

November 17,2004 10 CFR 50.90 Serial: PE&RAS04-104 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400 / License No. NPF-63 H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / License No. DPR-23 Crystal River Unit 3 Nuclear Generating Plant Docket No. 50-302 / License No. DPR-72 Application For Technical Specifications Improvement To Eliminate Requirements To Provide Monthly Operating Reports And Occupational Radiation Exposure Reports (TSTF-369, Revision 1)

Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), and Florida Power Corporation, now doing business as Progress Energy Florida, Inc. (PEF), request license amendments for the H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, the Shearon Harris Nuclear Power Plant (SHNPP), Unit No. I and the Crystal River Unit 3 Nuclear Generating Plant (CR3). PEC is the principal owner of HBRSEP, BSEP, and SHNPP. PEF is the principal owner of CR3.

The proposed amendments would delete the Technical Specifications (TS) requirements to submit Monthly Operating Reports (MOR) and Occupational Radiation Exposure Reports (ORER). The change is consistent with NRC-approved Revision I to Industry/Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report." 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). Additionally, administrative changes necessary to support TSTF-369 are included; P.O.

Box 1551 PEB 1323 Raleigh, NC 27602 T> 919.546.4222 4)(

F > 919.546.5473

United States Nuclear Regulatory Commission PE&RAS04-104 Page 2 of 4 most notably, HBRSEP, Unit No. 2, TS 5.6.8.b which currently requires the licensee to submit steam generator tube inspection results in the next MOR. Since the MOR will no longer exist, HBRSEP, Unit No. 2, is requesting that the TS be changed to require the licensee to submit the inspection results to the NRC as a separate report within sixty (60) days of inspection completion. Mr. William Reckley, Division of Licensing Project Management, Office of Nuclear Reactor Regulation, concurred with inclusion of this change for HBRSEP, Unit No. 2. provides a description of the proposed changes and confirmation of applicability. Attachment 2 provides the existing TS pages marked-up to show the proposed changes. Attachment 3 provides the typed proposed TS pages. Attachment 4 provides a list of regulatory commitments being made by PEC and PEF.

The proposed changes have been reviewed by the Plant Nuclear Safety Committee at each of the respective plants.

PEC and PEF request approval of the proposed license amendments by April 28, 2005, with the amendments being implemented within 60 days of approval.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the Florida, North Carolina, and South Carolina designated state officials.

If you should have any questions regarding this submittal, please contact Mr. Tony Groblewski at (919) 546-4579.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: NO 1 7, C 'S C. S. Hinnant Senior Vice President and Chief Nuclear Officer CSH/kmh Attachments: 1. Description and Assessment

2. Proposed Technical Specifications Changes (Mark-Up)
3. Proposed Technical Specifications Pages
4. List of Regulatory Commitments

United States Nuclear Regulatory Commission PE&RAS04-104 Page 3 of 4 cc: (with attachments):

U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission AT'TN: NRC Senior Resident Inspector - Crystal River Unit 3 U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector - Shearon Harris Nuclear Power Plant U. S. Nuclear Regulatory Commission ATTN: NRC Senior Resident Inspector - H. B. Robinson Steam Electric Plant, Unit No. 2 U. S. Nuclear Regulatory Commission ATrN: Mr. Chandu P. Patel, (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission AITN: Ms. Brenda L. Mozafari, (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

United States Nuclear Regulatory Commission PE&RAS04-104 Page 4 of 4 Mr. T. P. O'Kelley Director, Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Mr. Henry J. Porter Division Director, Radioactive Waste Management Section South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 The Honorable Henry McMaster Attorney General - State of South Carolina P.O. Box 11549 Columbia, SC 29211 Mr. William A Passetti, Chief Department of Health, Bureau of Radiation Control 4052 Bald Cypress Way, SE Bin #C21 Tallahassee, FL 32399-1741 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue, Second Floor Inverness, FL 344504245

United States Nuclear Regulatory Commission PE&RAS04-104, Attachment 1 Page 1 of 4 ATTACHMENT 1 Description and Assessment

1.0 INTRODUCTION

The proposed license amendments revise the Technical Specifications (TS) for the H. B.

Robinson Steam Electric Plant (HBRSEP), Unit No. 2, the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, the Shearon Harris Nuclear Power Plant (SHNPP), Unit No. 1 and Crystal River Unit 3 Nuclear Generating Plant (CR3). The changes are primarily associated with implementation of the NRC-approved Industry/Technical Specifications Task Force (TSTF) Standard Technical Specifications Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1. The availability of this technical specifications improvement was announced in the Federal Register on June 23, 2004 (69 FR 35067), as part of the Consolidated Line Item Improvement Process (CLIIP). Other administrative changes made in this submittal directly support implementation of TSTF-369, Revision 1.

2.0 DESCRIPTION

OF PROPOSED AMENDMENTS The following table summarizes the TS changes proposed in this amendment request.

Summary of Proposed Changes

D Deletion-of PORV Deletion of ORER

-Deletion of MOR Safet Valve Plant perTSTF-369 -

per TST 69 Documentation Administrative BSEP Units TS 5.6.1 Deleted TS 5.6.4 -Deleted TS 5.6.4 -Deleted N/A 1 and 2 CR3 TS 5.7.1.1.a - Deleted TS 5.7.1.2 -Deleted TS 5.7.1.2 - Deleted N/A SHNPP TS 6.9.1.2.a - Deleted TS 6.9.1.5 - Deleted TS 6.9.1.2.c - Deleted Index page xix per TSTF-258 Existing TS 6.9.1.2.b renumbered to TS 6.9.1.2.a HBRSEP TS 5.6.1 - Deleted TS 5.6.4 -Deleted TS 5.6.4 - Deleted TS 5.6.8.b revised to require submittal of steam generator tube inspection results with 60 days of the completion of the inspections.

United States Nuclear Regulatory Commission PE&RAS04-104, Attachment I Page 2 of 4 As addressed in the safety evaluation (SE) published in the Notice of Availability for TSTF-369, Progress Energy Carolinas, Inc. (PEG) is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls," for SHNPP. Specifically, TS 6.9.1.2.c includes a requirement to report all challenges to pressurizer PORVs or pressurizer safety valves. The NRC model safety evaluation addressed the removal of requirements to submit challenges to pressurizer PORVs and safety valves (i.e., if a licensee had not yet adopted the associated part of TSTF-258). PEC is requesting to delete the reporting requirement of TS 6.9.1.2.c for SHNPP. The proposed change is consistent with the option described in the Notice of Availability published on June 23, 2004 (69 FR 35067), and the related documentation for both TSTF-369 and the limited portion of TSTF-258 included in this application.

There is an additional request to amend HBRSEP, Unit No. 2, TS 5.6.8.b which currently requires the licensee to submit steam generator tube inspection results in the next MOR.

Since the MOR will no longer exist, HBRSEP, Unit No. 2, is requesting that the TS be changed to require the licensee to submit the inspection results to the NRC as a separate report within sixty (60) days of inspection completion.

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 as described within TSTF-258 and TSTF-369.

4.0 REGULATORY REOUIREMENTS 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 as described in TSTF-369, except for the request to modify the requirements of HBRSEP, Unit No. 2, TS 5.6.8.b. On the subject of steam generator inspection reports, TSTF-369 states:

1. Reports required by the licensee's current licensing basis regarding steam generator tube surveillance requirements shall be included here. An appropriate administrative controls format should be used.
2. These reports may be required covering inspection, test, and maintenance activities. These reports are determined on an individual basis for each unit and their preparation and submittal are designated in the Technical Specifications.

While the TSTF acknowledges the existence of these reporting requirements, it does not reference a TS that requires the licensee to report inspection results in a document that will no longer be required (i.e., the MOR). HBRSEP, Unit No. 2, TS 5.6.8.b currently requires the licensee to submit steam generator tube inspection results in the next MOR. HBRSEP, Unit No. 2, is requesting a change to TS 5.6.8.b to require submittal to the NRC within sixty (60) days of inspection completion as a separate report.

United States Nuclear Regulatory Commission PE&RAS04-104, Attachment 1 Page 3 of 4

5.0 TECHNICAL ANALYSIS

PEC and Progress Energy Florida, Inc. (PEF) have reviewed the safety evaluation (SE) and supporting information published on June 23, 2004 (69 FR 35067) as part of the CLUP Notice of Availability. PEC and PEF have concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to BSEP Unit Nos. 1&2, CR3, SHNPP, Unit No. 1, and HBRSEP, Unit No. 2, and justify this amendment for the incorporation of the changes to the respective PEC and PEF nuclear plants TS.

PEC has also concluded that there is justification for requesting that the HBRSEP, Unit No. 2, TS 5.6.8.b be modified to change the requirement for the licensee to submit the steam generator tube inspection results in the Monthly Operating Report (MOR) for the period after the final inspection is completed. Since the MOR will no longer exist, PEC is requesting that the TS be modified to require that the results of the steam generator tube inspection be submitted to the NRC by a separate report within sixty (60) days of inspection completion.

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 as described within TSTF-369.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, PEC and PEF are making the following regulatory commitments:

1. PEC and PEF will continue to provide to the NRC, for each calendar month, the operating data that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report." This data will be submitted by the last day of the month following the end of each calendar quarter. This commitment is 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). To prevent any gaps in the monthly operating statistics and shutdown experience data provided to the NRC, data for all months will be provided using one or both methods (i.e., monthly operating reports and/or CDE).
2. None of the PEC or PEF sites have different reactor types or both operating and shutdown reactors. Therefore, no commitment is required with regard to ORER elimination.

United States Nuclear Regulatory Commission PE&RAS04-104, Attachment 1 Page 4 of 4 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION PEC and PEF have reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067), as part of the CLIIP. PEC and PEF have concluded that the proposed determination presented in the notice is applicable to all PEC and PEF nuclear plants and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION PEC and PEF have reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. PEC and PEF have concluded that the Staff's findings presented in that evaluation are applicable to all PEC and PEF nuclear plants and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. PEC and PEF are not proposing variations or deviations from the TS changes described in TSTF-369 and the limited portion of TSTF-258, or the NRC Staff's model SE published on June 23, 2004 (69 FR 35067).

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).

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES (MARK-UP)

The following table contains a list of affected TS pages for each licensee.

BSEP, Unit Nos. 1&2 5.0-18, 5.0-19 CR3 5.0-27, 5.0-28 SHNPP, Unit No. 1 xix, 6-20, 6-21, 6-23 HBRSEP, Unit No. 2 5.0-26, 5.0-27, 5.0-32

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submItted in accordance with 10 CFR 50A.

5.6.1 ationa,

n osure Re xs4/ngle sua may be~g for a utpo tati n. Thesuttl hould

/cornb ctins 116 t l units at Stton.

A tabulatio n annual bas e number of s

, utility, and other person (including contr i's), for whom mo oring was performed receri g an a ual deep dose e evalent> 100 mre nd their associated colle dup dose equlvale reported In perso em) according to work a b

unctions (e.g.,

ctor operations a surveillance, inservice in

'on, routine malntenanc pedal maintenan~cdescribe maintenance) ste processing, and reful g). This labulatioXupplements the require nts of 10 C 0.2206. The do assignments to variou functions may be est' ated based on et dosimeter, the mol nescent dosimeter (TLD),

ctronic dosimete r film badge measur ents. Small exposures tot g

c 20/

of the In dual total dose nee ot be accounted for. In tAh

ggregate, at least 80%

the total deep dos uivalent received from nimal sources should b ssigned to specific ajor work functions. Th port, covering the Spreads calendar year, sha e submitted by April each year.

5.6.2 Annual Radiological Environmental Operating Report D

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 frnflnl tmH%

Brunswick Unit I 5.0-18 Amendment No. 216 l

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radioloalcal Environmental Operating ReDort (continued) 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 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 Table 3 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.

Radioactive Effluent Release Reoort 5.6.3 NOTED-A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Radioactive Effluent Release Report covering the operation of the unit shall be submitted 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 the Process Control Program and In conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.

MnthiQ i Re~ortsD utine reports of g statistics sutdown expeq includin documentatio all challenges main steam

/relief valves e

submitte a monthly baoo later than the of each mon ollowing the alend r month coyey the report./

5.6.4,

(continued)

Brunswick Unit 1 5.0-19 Amendment No. 216 l

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 10 CF 20.2206. The se assignmen various duty fu pons may be esiated based on et dosimete ermoluminescf dosimeter (TLD)

,rectronic dosim r or film badge easurements. >all exposures tow

< 20% of the dual total d need not be a6unted for. In the sgreE at least 800of the total de dose equivale ecoived from e al sourc should assigned to sa efic major wornctlons. The r ri, covering t pr us calendar yeshall be subm lad by April 30 olcl year.

Annual Radioloilcal Environmental Operating Report 5.6.2 tt^TU 1MI t 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 (continued)

Brunswick Unit 2 5.0-18 Amendment No. 250 l

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) the objectives outlined In the Offsite Dose Calculation Manual (ODCM), and In 10 CFR 50, Appendix 1, Sections IV.B2, 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 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 Table 3 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

-NOTE-A single submittal may be made for a multiple unit station. The submittal shall combine sections common to all units at the station.

The Radioactive Effluent Release Report covering the operation of the unit 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 unit. The material provided shall be consistent with the objectives outlined in the ODCM and the Process Control Program and In conformance with 10 CFR 5036a and 10 CFR Part 50, Appendix I, Section IV.B.1.

5.6.4 ANY utine reports Of oig statistics an down experien s, Including documentation 0 challenges to t am steam safety lef valves, s be submittedgs monthly basis ter than the 15th wach month wing the calen month covered b e report (continued)

Brunswick Unit 2 5.0-1 9 Amendment No. 250 l

Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports 5.7.1.1 Reports required on an annual basis include:

lation E osure Re rt an nual is of the er pers.el Oinclu i vas quired, r~.<'vinc

b. 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 for the reporting period.

The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM).

(continued)

Crystal River Unit 3 5.0-27 Amendment No. 149

Reporting Requirements 5.7 5.7 Reporting Requirements 5.7.1.1

b. Annual Radiological Environmental Operating Report (continued)

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 pursuant to the locations specified in the table and figures in the ODM, 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.

5.7.1.1

c.

Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be submitted prior to May 1 of each year, and 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 50, Appendix I, Section IV B.1.

5.7.1. 2 Month peratin eports q

otne re s's of Opet tng statistc and shut6w exper en e 5

r includin ocument on of all lenges t e pressur

{

pwer 8Grate yief valves ~frsurizeaft lvs'hl be sub ted on monthly ba no later an the 15t f each month 5.7.2 Special Reports Special Reports shall be submitted in accordance with 10 CFR 50.4 within the time period specified for each report.

(continued)

Crystal River Unit 3 5.0-28 Amendment No. 149

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.6 REPORTABLE EVENT ACTION...................... 6-16 6.7 SAFETY LIMIT VIOLATION.

................... 6-16 6.8 PROCEDURES AND PROGRAMS...................... 6-16 6.9 REPORTING REQUIREMENTS 6.9.1 ROUTINE REPORTS.................

. 6-20 Startup Report.

6-20 Annual Reports..................

6-20 Annual Radiological Environmental Operating Report 6-21 Annual Radioactive Effluent Release Report

.......6-22 tyYer i o s Core Operating Limits Report................... 6-24 6.9.2 SPECIAL REPORTS.......................... 6-24 6.10 DELETED..................

......... 6-24 6.11 RADIATION PROTECTION PROGRAM................... 6-26 6.12 HIGH RADIATION AREA........................ 6-26 6.13 PROCESS CONTROL PROGRAM (PCP)................... 6-27 SHEARON HARRIS - UNIT 1 xix Amendment No.92

ADMINISTRATIVE CONTROLS 6.9 REPORTINC REQUIWE!ENTS ROUTINE REPORTS 6.9.1 In addi tion to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the NRC in accordance with 10CFR50.4.

STARTUP REPORT 6.9.1.1 A summa ry report of plant startup and pover escalation testing shall be iubmitted following: (1) receipt of an Operating License, (2) amendment to the license involving a planned increase in pover level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit.

The Startup Report shall address each of the tests identified in the Final Safety Analysis Report and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications.

Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license condi-tions based on other commitments shall be included in this report.

Startup Reports shall be submitted within:

(1) 90 days following completion of the Startup Test Program, (2) 90 days following resumption or comcencement of coumercial power operation, or (3) 9 months folloving initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e., initial criticality, completion of Startup Test Program, and resumption or commencement of commercial operation), supplementary reports shall be sub-mitted at least every 3 months until all three events have been completed.

ANNUAL REPORTS 6.9.1.2 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year following initial criticality.

Reports required on an annual basis shall include:

a.. 4 tabulon on annual be of the num r of sta ion, utility, dc otr perso.1 (includ' g contractor receivig exposures g6reat r than 10# urmyr d their assoc' ted man-eexposure

/

accoding to rk and job functions* (e g., react r operation and

/

sueillancm inservic.

ospection, ro tine ain

ance, p ial g

1ntenanc (describe intenance],

ste proc sing, and fueling) e dose signments a various dut function may be est ted based on pocket dosi ter th 1

nescent osimeter (

), or

(

is tabu ation/upple=n7ts th,

equir ynts ofS 0.407 f 1O

-Par

0.

1 SHEARON HARRIS -

UNIT 1 6-20 %

Amendment No. 13

ADMINISTRATIVE CONTROLS ANNUAL REPORTS (Continued) e esr

.Sinap xposuresjta ing less an 20o thfnivdul,6tldose 'e d not be o~cunted for.,n the I

\\agregate, 3'eSt 80%);f the total <Ole-body dgg receiveto I

xernal sure shoulr be assigner to specific ajr workK

?

.i The results of specific activity analyses in which the reactor coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded (in graphic and tabular format); (2) results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radiolodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) cleanup flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) graph of the 1-131 concentration (uCi/gm) and one other radio-iodine isotope concentration (uCi/gm) as a function of time for the duration of the specific activity above the steady-state level; and (5) the time duration when the specific activity of the reactor coolant exceeded the radioiodine limit.

/

.D<mnaifalenges >,~-ress u

werl

,"rePO K andSafety-valves. /_

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.3 The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May I of each year. The report shall include summaries, interpretations, and analysis 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 (1) the ODCM and (2)

Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

SHEARON HARRIS - UNIT 1 6-21 Amendment No.58

ADMINISTRATIVE CONTROLS e j1 6.9 ou orts of opyxating sttistics and shutdow xperienceI nal bgsubm~ed on a mog y~

basis tohe Diryefor, Off e of Reso4p'e HanagpdSent,,.S.

Nuclea> iegulatory, nmmisslo

, ^Washing d D.C. 2955S, wit a copY'to t Regional ministrat of the lanai 0,ce of the MRC, no ter t~uin th 1th of e month fo owing the caendar. onth covered by the report.

SHEARON HARRIS - UNIT I 6-23 Amendment No. 58

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 i

5.6.2 Annual RadioloQical 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 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 Table 3 in the Radiological Assessment Branch Technical Position, Revision 1. November 1979.

(continued)

HBRSEP Unit No. 2 5.0-26 Amendment No. 176

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued)

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.

Radioactive Effluent Release Report 5.6.3 The Radioactive Effluent Release Report covering the operation of the unit shall be submitted 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 50, Appendix I.

Section IV.B.1.

5.6.4 4f onthl atm Reprts Ro ne reports of rating statisti and shutdown Hrience.

  • cluding doc ation of all cha nges to the ssurizer r

operated relief valves or press izer safety va es. shall submitted d~n a monthly basis rfo later than t 15th of e month followi the calendar mo covered by t 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. Shutdown Margin (SDM) for Specification 3.1.1:
2. Moderator Temperature Coefficient limits for Specification 3.1.3:
3. Shutdown Bank Insertion Limits for Specification 3.1.5:

(continued)

HBRSEP Unit No. 2 5.0-27 Amendment No. 176

Reporting Requirements 5.6

  • 5.6 Reporting Requirements (continued) 5.6.t Tendon Surveillance Report
a. Notification of a pending sample tendon test, along with detailed acceptance criteria, shall be submitted to the NRC at least two months prior to the actual test.
b. A report containing the sample tendon test evaluation shall be submitted to the NRC within six months of conducting the.

test.

5.6.8 Steam Generator Tube Inspection Report

a.

A report of the number of tubes plugged in each steam 4generator shall be submitted to the NRC within 14 days after conpletion of the tube plugging.

r~'

srS

b. A report oft te r fults of the steam generator tube r0 AlKl inspection shall "tpMM AOR W1 a

AfH0N2s o

after the final'inspection is I 1P Reports shall include:

P 0 a.1.

Number and extent of tubes inspected

2.

Location and percent of wall thickness penetration for each eddy current indication and any leaks.

3.

Identification of tubes plugged.

c. - A report of examination results falling in Category C-3 of Table 5.5-1 shall be submitted to the NRC within 30 days.

and prior to resumption of plant operation.

A report of investigations conducted to determine cause(s) of the tube degradation and corrective measures taken to prevent recurrence shall be submitted within 90 days following completion of the startup test program.

I HBRSEP Unit No. 2 5.0-32 Amendment No. 46, 185 I-

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS PAGES The following table contains a list of affected TS pages for each licensee.

BSEP, Unit Nos. 1&2 5.0-18,5.0-19 CR3 5.0-27,5.0-28 SHNPP, Unit No. 1 xix, 6-20, 6-21, 6-23 HBRSEP, Unit No. 2 5.0-26,5.0-27, 5.0-32

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 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 (continued)

Brunswick Unit 1 5.0-18 Amendment No.

I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) 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 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 Table 3 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 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 Radioactive Effluent Release Report covering the operation of the unit shall be submitted 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 the 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 Not Used (continued)

Brunswick Unit 1 5.0-1 9 Amendment No.

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 5.6.2 Not Used 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 (continued)

Brunswick Unit 2 5.0-18 Amendment No.

I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) 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 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 Table 3 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 I

NOTE A single submittal may be made for a multiple unit station. The submittal shall combine sections common to all units at the station.

The Radioactive Effluent Release Report covering the operation of the unit 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 unit The material provided shall be consistent with the objectives outlined in the ODCM and the 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 Not Used (continued)

Brunswick Unit 2 5.0-1 9 Amendment No.

I

Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports 5.7.1.1 Reports required on an annual basis include:

a. Not Used
b. 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 for the reporting period.

The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM).

I (continued)

Crystal River Unit 3 5.0-27 Amendment No.

Reporting Requirements 5.7 5.7 Reporting Requirements 5.7.1.1

b. Annual Radiological Environmental Operating Report (continued)

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 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.

5.7.1.1

c. Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be submitted prior to May 1 of each year, and 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 50, Appendix I, Section IV B.1.

5.7.1.2 Not Used 5.7.2 Special Re worts Special Reports shall be submitted in accordance with 10 CFR 50.4 within the time period specified for each report.

Crystal River Unit 3 5.0-28 Amendment No.

Crystal River Unit 3 5.0-28 Amendment No.

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.6 REPORTABLE EVENT ACTION.....................

6.7 SAFETY LIMIT VIOLATION......................

6.8 PROCEDURES AND PROGRAMS.....................

6.9 REPORTING REQUIREMENTS 6.9.1 ROUTINE REPORTS.........................

Startup Report......................

Annual Reports......................

Annual Radiological Environmental Operating Report. ;..

Annual Radioactive Effluent Release Report........

. 6-16

. 6-16

. 6-16

. 6-20

. 6-20

. 6-20

. 6-21

. 6-22 I

Core Operating Limits Report 6.9.2 SPECIAL REPORTS..........

6.10 DELETED..............

6.11 RADIATION PROTECTION PROGRAM...

6.12 HIGH RADIATION AREA........

6.13 PROCESS CONTROL PROGRAM (PCP)...

............. 6-24

............ 6-24c 6-24c

.............6-26

............. 6-26

............. 6-27 SHEARON HARRIS - UNIT 1 xix Amendment No.

ADMINISTRATIVE CONTROLS I

6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10. Code of Federal Regulations, the following reports shall be submitted to the NRC in accordance with 10CFR50.4.

STARTUP REPORT 6.9.1.1 A summary report of plant startup and power escalation testing shall be submitted following: (1) receipt of an Operating License. (2) amendment to the license involving a planned increase in power level. (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear. thermal, or hydraulic performance of the unit.

The Startup Report shall address each of the tests identified in the Final Safety Analysis Report and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report.

Startup Reports shall be submitted within: (1) 90 days following completion of the Startup Test Program. (2) 90 days following resumption or commencement of commercial power operation. or (3) 9 months following initial criticality.

whichever is earliest. If the Startup Report does not cover all three events (i.e.. initial criticality. completion of Startup Test Program, and resumption or commencement of commercial operation), supplementary reports shall be submitted at least every 3 months until all three events have been completed.

ANNUAL REPORTS 6.9.1.2 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year. The initial report shall be submitted prior to March 1 of the year following initial criticality.

Reports required on an annual basis shall include:

SHEARON HARRIS - UNIT 1 6-20 Amendment No.

ADMINISTRATIVE CONTROLS r,

ANNUAL REPORTS (Continued)

a.

The results of specific activity analyses in which the reactor coolant exceeded the limits of Specification 3.4.8. The following information shall be included:

(1) reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded (in graphic and tabular format): (2) results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than limit.

Each result should include date and time of sampling and the radioiodine concentrations; (3) cleanup flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded: (4) graph of the I-131 concentration (pCi/gm) and one other radio-iodine isotope concentration (pCi/gm) as a function of time for the duration of the specific activity above the steady-state level: and (5) the time duration when the specific activity of the reactor coolant exceeded the radioiodine limit.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.1.3 The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries.

interpretations, and analysis 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 (1) the ODCM and (2) Sections IV.B.2. IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

SHEARON HARRIS - UNIT 1 6-21 Amendment No.

ADMINISTRATIVE CONTROLS 6.9.1.5 Deleted SHEARON HARRIS - UNIT 1 6-23 Amendment No.

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 5.6.2 DELETED I

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 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 Table 3 in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

(continued)

HBRSEP Unit No. 2 5.0-26 Amendment No. I HBRSEP Unit No. 2 5.0-26 Amendment No.

I

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued)

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 unit shall be submitted 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 50. Appendix I.

Section IV.B.1.

5.6.4 DELETED 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.

Shutdown Margin (SDM) for Specification 3.1.1:

2. Moderator Temperature Coefficient limits for Specification 3.1.3:
3.

Shutdown Bank Insertion Limits for Specification 3.1.5:

(continued)

HBRSEP Unit No. 2 5.0-27 Amendment No.

I

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.7 Tendon Surveillance Report

a. Notification of a pending sample tendon test, along with detailed acceptance criteria, shall be submitted to the NRC at least two months prior to the actual test.
b. A report containing the sample tendon test evaluation shall be submitted to the NRC within six months of conducting the test.

5.6.8 Steam Generator Tube Inspection Report

a.

A report of the number of tubes plugged in each steam generator shall be submitted to the NRC within 14 days after completion of the tube plugging.

b.

A report of the results of the steam generator tube inspection shall be submitted to the NRC within 60 days after completion of the final inspection.

Reports shall include:

1. Number and extent of tubes inspected
2. Location and percent of wall thickness penetration for each eddy current indication and any leaks.
3. Identification of tubes plugged.
c. A report of examination results falling in Category C-3 of Table 5.5-1 shall be submitted to the NRC within 30 days, and prior to resumption of plant operation.

A report of investigations conducted to determine cause(s) of the tube degradation and corrective measures taken to prevent recurrence shall be submitted within 90 days following completion of the startup test program.

HBRSEP Unit No. 2 5.0-32 Amendment No.

I

t ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS Sheet 1 of 2 The following table identifies those actions committed to by Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC) - Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 in this document. Any other statements in this submittal, other than the commitments in this attachment, are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding this commitment to Mr. Leonard Beller at (910) 457-2073.

REGULATORY COMMITMENT DUE DATE

.1-BSEP will continue to provide to the NRC, for each calendar month, the operating data that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report." This data will be submitted by the last day of the month following the end of each calendar quarter.

This commitment is 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).

To prevent any gaps in the monthly operating statistics and shutdown experience data provided to the NRC, data for all months will be provided using one or both methods (i.e., monthly operating reports and/or CDE).

Upon implementation of the approved amendment.

The following table identifies those actions committed to by PEC - Shearon Harris Nuclear Power Plant (SHNPP), Unit No. 1. Any other statements in this submittal, other than the commitments in this attachment, are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding this commitment to Mr. David Corlett at (919) 362-3137.

REGULATORY COMMITMENT DUE DATE SHNPP will continue to provide to the NRC, for each calendar month, the operating data that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report." This data will be submitted by the last day of the month following the end of each calendar quarter.

This commitment is 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).

To prevent any gaps in the monthly operating statistics and shutdown experience data provided to the NRC, data for all months will be provided using one or both methods (i.e., monthly operating reports and/or CDE).

Upon implementation of the approved amendment.

ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS Sheet 2 of 2 The following table identifies those actions committed to by PEC - H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. Any other statements in this submittal, other than the commitments in this attachment, are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding this commitment to Mr. Charles Baucom at (843) 857-1253.

REGULATORY COMMITMENT DUE DATE 4-HBRSEP will continue to provide to the NRC, for each calendar month, the operating data that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report." This data will be submitted by the last day of the month following the end of each calendar quarter.

This commitment is 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).

To prevent any gaps in the monthly operating statistics and shutdown experience data provided to the NRC, data for all months will be provided using one or both methods (i.e., monthly operating reports and/or CDE).

Upon implementation of the approved amendment.

The following table identifies those actions committed to by Florida Power Corporation, now doing business as Progress Energy Florida, Inc. (PEF) - Crystal River Unit 3 (CR3) Nuclear Generating Plant. Any other statements in this submittal, other than the commitments in this attachment, are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding this commitment to Mr. Sidney Powell at (352) 5634883.

REGULATORY COMMITMENT DUE DATE CR3 will continue to provide to the NRC, for each calendar month, the operating data that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report." This data will be submitted by the last day of the month following the end of each calendar quarter.

This commitment is 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).

To prevent any gaps in the monthly operating statistics and shutdown experience data provided to the NRC, data for all months will be provided using one or both methods (i.e., monthly operating reports and/or CDE).

Upon implementation of the approved amendment.

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