GNRO-2004/00061, Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports
| ML043570217 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/17/2004 |
| From: | Gerald Williams Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2004/00061 | |
| Download: ML043570217 (10) | |
Text
- -En tergy Entergy P.O. Box 756 Port Gibson, MS 39150 Tel 601 437 6409 George A. Williams Vice President -Operations Grand Gulf Nuclear Station GNRO-2004/00061 December 17, 2004 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20 55
SUBJECT:
Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
Dear Sir or Madam:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1 The proposed amendment would delete the TS requirements to submit monthly operating reports and occupational radiation exposure reports. The change is consistent with NRC-approved Revision 1 to Industry/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 TS improvement was announced in the Federal Register on June 23, 2004, as part of the Consolidated Line Item Improvement Process (CLIIP). provides a description of the proposed change and confirmation of applicability. Attachment 2 provides the existing TS pages marked-up to show the proposed change.
The proposed change includes a new commitment as summarized in Attachment 3.
Entergy requests approval of the proposed license amendment by April 30, 2005, with the amendment being implemented within 90 days of approval.
In accordance with 10CFR50.91, a copy of this application, with enclosures, is being provided to the designated Mississippi State Officials.
A ''C'
GNRO-2004/00061 Page 2 I declare under penalty of perjury under the laws of the United States of America that I am authorized by Entergy to make this request and that the foregoing is true and correct.
If you should have any questions regarding his submittal, please contact me or Matt Crawford at 601-437-2334.
Sincerely GAWtMLC/amt Attachments: 1.
Description and Assessment
- 2.
Proposed Technical Specification Changes (Mark-Ups)
- 3.
List of Regulatory Commitments cc:
(All Below w/o Attachments)
NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam Attn: Addressee Only Mail Stop OWFNI7D-1 Washington, DC 20555-0001 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Attn: Dr. Bruce S. Malleft 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-4005 U.S Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Mr. D. E. Levanway (Wise Carter)
Mr. L. J. Smith (Wise Carter)
Mr. N. S. Reynolds Mr. H. L. Thomas
ATTACHMENT I to GNRO-2004100061 Description and Assessment to GNRO-2004/00061 Page 1 of 2
1.0 INTRODUCTION
The proposed License amendriient deletes the requirements in Te6hnical Specification (TS) 5.6.1 for an annual report on occupational radiation exposures and TS 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 technical specification 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 the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:
TS 5.6.1 Occupational Radiation Exposure Report Deleted TS 5.6.4 Monthly Operating Reports Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, Entergy is proposing to adopt a part of NRC approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." Specifically TS 5.6,4 includes a requirement to include in the monthly operating reports any challenges to safety/relief valves. The NRC model safety evaluation addressed the removal of requirements to submit monthly operating reports in those cases where the TS includes a requirement to address challenges to relief and safety valves (i.e., if a licensee had not yet adopted the associated part of TSTF-258). The proposed change is consistent with the option described in the Notice of Availability published on June 23, 2004 and the related documentation for both TSTF-369 and the limited portion of TSTF-258 included in this application.
As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, the removal of TS 5,6.1 and TS 5.6.4 resulted in various editorial and formatting changes such as the renumbering of TS sections. These changes do not reflect the renumbering of TS sections nor do they revise technical or administrative requirements.
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.
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.
5.0 TECHNICAL ANALYSIS
Entergy 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 staffs SE and the supporting information provided to support TSTF-369. Entergy has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are to GNRO-2004/00061 Page 2 of 2 applicable to GGNS and justify this amendment for the incorporation of the changes to the GGNS TS.
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.
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, Entergy is making the following verifications and a 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)).
- 2.
GGNS does not have different reactor types or both operating and shutdown reactors.
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 GGNS 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 staffs findings presented in that evaluation are applicable to GGNS 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 (and the limited portion of TSTF-258) or the NRC staffs 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 SPECIFICATION CHANGES (MARK-UP) to GNRO-2004/00061 Page 1 of 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 5.6.2 Occu ational Radiation Ex osure Report A ta tlon on an annual basis of the number of station, u y,
and othe rsonnel (Including contractors), for whom oring was require,
celving exposures > 100 mreu/yr and Ir associated man xposure according to work a ob functions (e g., reactor ape n i s and surveillance ervice inspection, routine maintenance sp I maintenance escribe maintenance),
waste processing, and refue T
tabulation supplements the requarements of CFR o0m2206 ose assignments to vareRus duty functions lay be estliatienta lOn pocket dosireter n
thermolurinescent dosifet uni t dn or prvibadgu aeasureaents.
Sball exposures totaly I
2C of the rneprltosall dose need not be acrounted tatIn thes, atd analyses 80o of the total whole body pd.
hev frma external sourceh sho e assigned to specif s
ou k functions The OccupatfonDs Cau atinaon (cosuM e
and ri c0 :rRng the activities of thi u It frVthl?
prprus catendar yar shall be submitted by Marc 31 of each ar
\\
Annual Raddological Environmental Operating Report The Annual Radiological Environmental Operating Report coverlng the operatein of the unit durtng the prevaions calendar year shall be subfitted by Kty I of each year.
The report shall include sultaries, onterpretathsns, and analyses of trends of the results of the RadiologRcal Environmental tonitorang Progral for the revorting per1od.
ohe 1aterial protided shall be consistent wdth th obJ ctives outlined in the Offsite Dose Calculation Manual (ODCH), and in 10 CfR 50, Appendix I, Sections IV B.2, IY B 3, and IY.C.
The Annual Radiological Envirormental 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 ODCH, as well as summarized and tabulated res ults of these analyses and measurements in the format of the table In the Radiological Assessment Branch Technical Position, Revision 1, Novemfber 1979.
In the event that some individual f-nntinU~fl GRAND GULF 5.C-17 Amendment No. 120 to GNRO-2004/00061 Page 2 of 2 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radjoolwical En.Jironmontal Ooeratina Renort (continued) 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 during the previous calendar year shall be submitted by May I of each year.
The report shall Include a suommary 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 CDCH and process control program and In conformance with 10 CFR 50.36a and 10 CFR
- 50. Appendix 1. Section IY.B.1.
5.6.4 Routine reports o statitic down experience, including documentation of al enges to the rain stearn safety/relief valves.
e submit La monthly basis no later than t each month following ndar month co er report.
5.6.5 Core Operating tiets Report (COLR)
- a.
Core operating limits shall be established prior to each reload cycle, or prior to any remalning portion of a reload cycle, and shall be docunented in the COLR for the following:
- 1) LCO 3.2.1. Average Planar Linear Heat Generation Rate (APLHGR1.
- 2) LCO 3.Z.2. Minimum Critical Power Ratio (tMCPR).
- 4)
LCO 3.2.4, Fraction of Core Boiling Boundary (FCBB).
- 5)
LCO 3.3.2.1, RPS Instruxentation. Table 3.3.1.1-1 function 2.d, and
- 6)
LCO 3.3.1.3, Period Based Detection System (PBOS).
GRAND GULF 5.0.18 Amendment No. -I4. j
6RAND GULF 5.0-18 Amendment Ho.
,14 M2 To GNRO-2004100061 List of Regulatory Commitments
- to GNRO-2004/00061 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check one)
SCHEDULED ONE-CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)
Entergy is making a regulatory commitment to X
Within 90 days provide to the NRC using an industry database the of amendment operating data (for each calendar month) that is issuance.
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)