ML043440027

Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

ML043440027
Person / Time
Site:	Calvert Cliffs
Issue date:	12/01/2004
From:	Vanderheyden G Constellation Energy Group, Constellation Generation Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML043440027 (9)

Text

George Vanderheyden 1650 Calvert Cliffs Parkway Vice President Lusby, Maryland 20657 Calvert Cliffs Nuclear Power Plant 410.495.4455 Constellation Generation Group, LLC 410.495.3500 Fax I Constellation Energy December 1, 2004 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Renorts In accordance with the provisions of 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP) is submitting a request for an amendment to the Technical Specifications for Calvert Cliffs Units 1 and 2.

The proposed amendment would delete Technical Specification requirements to submit monthly operating reports and the annual occupational radiation exposure report. The change is consistent with Nuclear Regulatory Commission-approved Revision I to Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report." The availability of this Technical Specification improvement was announced in the Federal Register on June 3, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).

Attachment (1) provides a description of the proposed change and confirmation of applicability.

Attachment (2) provides the existing Technical Specification pages marked-up to show the proposed change.

We request approval of the proposed license amendment as soon as possible, but not later than July 1, 2005. Earlier approval will allow us to achieve the stated regulatory burden reduction sooner.

• ~ Ctol

Document Control Desk December 1, 2004 Page 2 Should you have questions regarding this matter, we will be pleased to them with you.

Very STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, George Vanderheyden, being duly sworn, state that I am Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other CCNPP employees and/or onsultants. Such information has been reviewed in accordance with company practice and I bel to e reliable.

Subs ibed-and sworn before me, a Notary blic in and for the State of Maryland and County of this day of 2004.

VATNESS my Hand and Notarial Seal:

Notary Pubic My Commission Expires: 2t 6 '

Dat6 GV/CAN/bjd Attachments: (1) Description and Assessment (2) Technical Specification Marked-up Pages cc: J. Petro, Esquire S. J. Collins, NRC J. E. Silberg, Esquire Resident Inspector, NRC R. V. Guzman, NRC R. I. McLean, DNR

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT TABLE OF CONTENTS

4.0 REGULATORY ANALYSIS

5.0 NO SIGNIFICANT HAZARDS CONSIDERATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 PRECEDENT 8.0 REFERENCE Calvert Cliffs Nuclear Power Plant, Inc.

December 1, 2004

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT

1.0 INTRODUCTION

The proposed license amendment deletes the requirements in Technical Specification 5.6.1 for an annual report on occupational radiation exposures and Technical Specification 5.6.4 for a monthly report of operating statistics and shutdown experience.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved 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 Technical Specification 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 PROPOSED CHANGE

Consistent with the NRC-approved Revision I of TSTF-369, the proposed Technical Specification changes include:

Technical Specification 5.6.1 Occupational Radiation Exposure Report Deleted Technical Specification 5.6.4 Monthly Operating Reports Deleted Note that we are not renumbering the Technical Specifications following removal of these reporting requirements. The marked up Technical Specification pages are contained in Attachment (2).

3.0 TECHNICAL ANALYSIS

We have reviewed the safety evaluation 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 and the information provided to support TSTF-369, Revision 1. We have concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Calvert Cliffs Nuclear Power Plant, Units 1 and 2 and justify this amendment for the incorporation of the changes to the CCNPP Technical Specification.

4.0 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, Revision 1.

As discussed in the model safety evaluation published in the Federal Register on June 23, 2004 (69 FR 35067) for this Technical Specification improvement, we are making the following regulatory commitment:

1. 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 model Safety Evaluation also contained a commitment for stations with both boiling and pressurized water reactors, and for stations with both operating and shutdown reactors. Calvert Cliffs Nuclear Power I

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT Plant does not have different reactor types or both operating and shutdown reactors at our site. Therefore, we are not adopting the associated commitment.

5.0 NO SIGNIFICANT HAZARDS CONSIDERATION We have reviewed the proposed No Significant Hazards Consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. We have concluded that the proposed determination presented in the notice is applicable to CCNPP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

6.0 ENVIRONMENTAL CONSIDERATION

We have reviewed the environmental evaluation included in the model safety evaluation published on June 23, 2004 (69 FR 35067) as part of the CLIIP. We have concluded that the staff's findings presented in that evaluation are applicable to CCNPP and the evaluation is hereby incorporated by reference for this application.

7.0 PRECEDENT This application is being made in accordance with the CLIIP. We are not proposing variations or deviations from the Technical Specification changes described in TSTF-369, Revision I or the NRC staff's model safety evaluation published on June 23, 2004 (69 FR 35067).

8.0 REFERENCE Federal Register Notice published June 23, 2004 (69 FR 35067): "Notice of Availability of Model Application Concerning Technical Specifications Improvement to Elimination Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process."

2

ATTACHMENT (2)

MARKED UP TECHNICAL SPECIFICATION PAGES V

5.6-1 5.6-3 Calvert Cliffs Nuclear Power Plant, Inc.

December 1, 2004

TABLE OF CONTENTS 5.5.16 Containment Leakage Rate Testing Program ........... 5.5-23 5.6 Repo R . ....... 5.6-1 5.6.1

( eupa aion l ogaicat nio nnr axo E p er t ng. rprt..

. .. 5...............

-1 le a 5.6.2 5.6.3 Radioactive Effluent Release Report ................ 5.6-2 5.6.4 5.6.5 CORE OPERATING LIMITS REPO 5.6.6 Not Used ................................ 5.6-9 5.6.7 Post-Accident Monitoring Report .................... 5.6-9 5.6.8 Tendon Surveillance Report ......................... 5.6-9 5.6.9 Steam Generator Tube Inspection Report ............. 5.6-9 CALVERT CLIFFS - UNIT 1 v Amendment No. 267 CALVERT CLIFFS - UNIT 2 Amendment No. 236

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 / OCunatNenal Rad~at4;e ExPSF 'eport -e IE ect

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NOTE----------------------------

A s gle submittal may be made for both units, but shall not inclu the occupational radiation exposure from the Ind ndent Spent Fu Storage Installation. The submittal shoul combine sections co n to both units at the station.

A tabulation on a a ual basis of the nu e of station, utility, and other personnel (in uding contra rs) receiving exposures

> 100 mrem/yr and their as ciated an rem exposure according to work and job functions (e.g., tor operations and surveillance, inservice inspection, routin tenance, special maintenance, waste processing, and ref ing). is tabulation supplements the requirements of 10 CFR .2206. The e assignments to various duty functions may estimated based on cket dosimeter, electronic perso dosimeter, or thermolum scent dosimeter.

Small exposur totaling < 20% of the individua otal dose need /

not be acc ted for. In the aggregate, at least 8 of the total whole b dose received from external sources should be signed to s cific major work functions. The report shall be subm ed hvAntril 30 nf Parh I -

var.-

J-It I r I I I,,

I/

5.6.2 Annual Radiolonairal Fnvirnnmental Oneratina Rennrt

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NOTE--------------- ___ -_

A single submittal may be made for both units. The submittal should combine sections common to both 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 CALVERT CLIFFS - UNIT 1 5.6-1 Amendment No. 259 CALVERT CLIFFS - UNIT 2 Amendment No. 236

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.4 Mont

\ shllb bi sumittd WS tidj4u~m==LIh~r thn te 15th of A 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:

3.1.1 SHUTDOWN MARGIN 3.1.3 Moderator Temperature Coefficient 3.1.4 CEA Alignment 3.1.6 Regulating Control Element Assembly Insertion Limit 3.2.1 Linear Heat Rate 3.2.2 Total Planar Radial Peaking Factor 3.2.3 Total Integrated Radial Peaking Factor 3.2.5 AXIAL SHAPE INDEX 3.3.1 RPS Instrumentation - Operating 3.9.1 Boron Concentration

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. CENPD-199-P, "C-E Setpoint Methodology: C-E Local Power

--Density. and.DNB LSSS and LCO Setpoint Methodology for Analog Protection Systems"

2. CEN-124(B)-P, "Statistical Combination of Uncertainties Methodology Part 1: C-E Calculated Local Power Density and Thermal Margin/Low Pressure LSSS for Calvert Cliffs Units I and II"I CALVERT CLIFFS - UNIT 1 5.6-3 Amendment No. 259 CALVERT CLIFFS - UNIT 2 Amendment No. 236