ML043640409
| ML043640409 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  (NPF-010, NPF-015) |
| Issue date: | 12/27/2004 |
| From: | Nunn D Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PCN 557 | |
| Download: ML043640409 (17) | |
Text
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SOUTHERN CALIFORNIA EDISONt An EDISONV INTERNATIONAL9 Company Dwight E. Nunn Vice President December 27, 2004 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555
SUBJECT:
San Onofre Nuclear Generating Station, Units 2 and 3 Docket Nos. 50-361 and 50-362 Proposed Change Number (PCN) 557 Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Gentlemen:
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Southern California Edison (SCE) is submitting a request for an amendment to the Technical Specifications (TS) for the San Onofre Nuclear Generating Station, Units 2 and 3.
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 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).
Attachment I 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. Attachment 3 provides the revised (clean) TS pages.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated California State Official.
P.O. Box 128 San Clemente, CA 92674-0128 949-368-1480 Fax 949-368-1490
Document Control Desk December 27, 2004 SCE is herewith making the following regulatory commitments in Attachment 1 uDescription and Assessment' (6.1):
- 1.
To provide quarterly operating data to the NRC, and
- 2.
To provide information annually to the NRC to support the apportionment of station dose for SONGS Unit I (shutdown) and SONGS Units 2 and 3 (operating).
If you should have any questions regarding this submittal, please contact Mr. Jack Rainsberry at (949) 368-7420.
Sincerely, Attachments: 1. Description and Assessment
- 2. Proposed Technical Specification Changes (marked-up)
- 3. Revised Technical Specification Pages cc: B. S. Mallett, Regional Administrator, NRC Region IV, B. M. Pham, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Sciences, Radiologic Health Branch
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. for a Class 103 License to Acquire, Possess, and Use A Utilization Facility as Part of Unit No. 2 of the San Onofre Nuclear Generating Station
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Docket No. 50-361 Amendment Application No. 230 SOUTHERN CALIFORNIA EDISON COMPANY, et al. pursuant to IOCFR50.90, herby submit Amendment Application No. 230. This amendment application consists of Proposed Change Number (PCN) 557 to Facility Operating License NPF-10. PCN-557 is a request to delete the requirements to submit monthly operating reports and occupational radiation exposure reports in Technical Specification (TS) 5.7.1.1 a and 5.7.1.4 for San Onofre Nuclear Generating Station Unit 2. The availability of this TS improvement was announced by the Nuclear Regulatory Commission in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).
State of California County of San Diego bscribed and sworn to (or affirmed) before me this day of
,2004 Dwight E. Nunn Vice President Notary Public A
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON COMPANY, ETAL. for a Class 103 License to Acquire, Possess, and Use A Utilization Facility as Part of Unit No. 3 of the San Onofre Nuclear Generating Station
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Docket No. 50-362 Amendment Application No. 214 SOUTHERN CALIFORNIA EDISON COMPANY, et al. pursuant to 10CFR50.90, herby submit Amendment Application No. 214. This amendment application consists of Proposed Change Number (PCN) 557 to Facility Operating License NPF-15. PCN-557 is a request to delete the requirements to submit monthly operating reports and occupational radiation exposure reports in Technical Specification (TS) 5.7.1.1a and 5.7.1.4 for San Onofre Nuclear Generating Station Unit 3. The availability of this TS improvement was announced by the Nuclear Regulatory Commission in the Federal Register on June 23, 2004 (69 FR 35067) as part of the consolidated line item improvement process (CLIIP).
State of California County of San Diego Subscribed and sworn to (or affirmed) before me thiso7 4_rday of
____________,2004 Dwight E. Nunn Vice President had as, Notary Public
-CMi Commaj it 13?5 470 Notory putbgc.Ca~tmo0 Sar Dieg County M y o r
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ATTACHMENT 1 Description and Assessment
1.0 INTRODUCTION
The proposed License amendment deletes the requirements in Technical Specification (TS) 5.7.1.1a for an annual report on occupational radiation exposures and TS 5.7.1.4 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, uRemoval 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 DESCRIPTION
OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed TS changes include:
TS 5.7.1.1a Occupational Radiation Exposure Report Deleted TS 5.7.1.4 Monthly Operating Reports Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, Southern California Edison (SCE) is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls."
Specifically, TS 5.7.1.4 includes a requirement to include in the monthly operating reports any challenges to pressurizer safety 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 (69 FR 35067) and the related documentation for both TSTF-369 and the limited portion of TSTF-258 included in this application.
This application involves a site with both operating and shutdown reactors. As addressed in the Notice of Availability for TSTF-369, Southern Califomia Edison (SCE) has included in this application a regulatory commitment to support the NRC need to apportion doses reported under 10 CFR Part 20 to the different categories of reactors at the site.
Page 1 of 3
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 June 23, 2004 (69 FR 35067) and TSTF-369.
5.0 TECHNICAL ANALYSIS
Southern California Edison (SCE) 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. SCE has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3), and justify this amendment for the incorporation of the changes to the SONGS 2 and 3 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, SCE is making the following verifications and regulatory commitments:
- 1.
SCE 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)).
Page 2 of 3
- 2.
SONGS has both operating and shutdown units.
SCE is making a regulatory commitment to provide information to the NRC annually (e.g., with the annual submittal in accordance with 10 CFR 20.2206) to support the apportionment of station dose for SONGS Unit 1 (shutdown) and SONGS Units 2 and 3 (operating). 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.
7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Southern California Edison (SCE) has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. SCE has concluded that the proposed determination presented in the notice is applicable to San Onofre Nuclear Generating Station Units 2 and 3, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
8.0 ENVIRONMENTAL EVALUATION Southern California Edison (SCE) has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. SCE has concluded that the staffs findings presented in that evaluation are applicable to San Onofre Nuclear Generating Station Units 2 and 3, and the evaluation is hereby incorporated by reference for this application.
9.0 PRECEDENT This application is being made in accordance with the CLIIP. Southern California Edison (SCE) 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 Specification 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)
Page 3 of 3
ATTACHMENT 2 Proposed Technical Specification Changes Units 2 and 3 (Mark-Up)
Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4. The reports shall be addressed to the U.S. Nuclear Regulatory Commission, Attention:
Document Control Desk, Washington, D.C., with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.
5.7.1.1 Annual Reports
NOTE-------------------__
A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.
Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted by March 31 of each year.
Reports required on an annual basis include:
- a.
Occupational Radiation Exposure Report (Deleted)
A tabulation on an annual basis of the number of station, utility, and other perso;nnl (including cntraetors) rcivi__.'_
exposures greater than 100 mrem/yr and their associated man reff exposure according to work and job functions (c.g.,
reactor operations and surecillance, inscrvicc inspection, routine maintenance, special maintenanc (describe
,,aintenanee), wasto p ig, and refueling).
This tabulation supplcmcnts the requiremfnts of 10 CFR 20.407. The dose assignments to various duty functions may be estimated based on pocket dosimetcr, thermolumineseent dosimetcr (TLD),
or film badgc measurefment5.
Small cxposures totalling l1ss than 20 percent of the individual total dose need not be accounted for.
In the aggregate, at least 80 percent of the total whole body dosc received from external sources should be assigned to specific major work functions, and (continued)
SAN ONOFRE--UNIT 2 5.0-23 Amendment No. 12-7
Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 A
anthly Operating Rpaprts (Del Routine reports of operating statistics and shutdown oxparianc, including documnentation of all challenges to pressurizer safcty valves, shall be submitted on a monthly basis to the U.S.
tuclcar Reulatory Commission, Attention. Documcnt Cantrol Desk, Washinqton, D.C., with a copy to the Regional Administrator of the Regional Office of the ziRc, no later than the 15th of each month following the calendar molnth covered by the repar-t.
5.7.1.5 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.
Specification 3.1.4, "Moderator Temperature Coefficient;"
- 2.
Specification 3.1.5, Control Element Assembly (CEA)
Alignment;"
- 3.
Specification 3.1.7, "Regulating CEA Insertion Limits;"
- 4.
Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"
- 5.
Specification 3.2.1, "Linear Heat Rate;"
- 6.
Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"
- 7.
Specification 3.2.5, "Axial Shape Index;"
- 8.
Specification 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 in:
1.a.1 Letter, dated September 5, 1985, M. 0. Medford (SCE) to G. W. Knighton (NRC), "Docket No. 50-361 and 50-362 Reload Analysis Report," San Onofre Nuclear Generating Station Units 2 and 3 (Cycle 3)
(continued)
SAN ONOFRE--UNIT 2 5.0-26 Amendment No. +a-7
Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4. The reports shall be addressed to the U.S. Nuclear Regulatory Commission, Attention:
Document Control Desk, Washington, D.C., with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.
5.7.1.1 Annual Reports
NOTE-----------------__-______-___
A single submittal may be made for a multiple unit station.
The submittal should combine sections common to all units at the station.
Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted by March 31 of each year.
Reports required on an annual basis include:
- a.
Occupational Radiation Exposure Report (Deleted)
A tabulation an an annual basis of the nuV.rnbI r of station, utility, and other personnel (including contractors) receiving exposures greater than 100 frrefn/'yr and their associated man rem cxposure according to w;ork and job functions (e.g.,
reactor operations and surveillance, inservice inspection, routine mFaintenanec, special maintenance (describe faint.nanece),..aste _prssing, and refueling).
Th i _
tabulation supplemcnts the requirements of 10 CFR 20.407. The dosec assignments to various duty functions may be estimated based on p__ket dosimAt.r, thArAmolumfinesAnt dosimAtAfl r
(TLDI),
or film badge measurements.
Jall exposures totalling less than 20 percent of the individual total dose need not be aecounted for.
In the aggregate, at least v0 percent of the total w;hale-body dose reeeived from ext rnal sources should bEe assigned to specific major
-;1 r funtionsI and (continued)
SAN ONOFRE--UNIT 3 5.0-23 Amendment No. 4-16
Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 lonthly Operating Reports {e (Dl eted)
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A1r.
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Routine reports of IpUeratig statistics and shutdow:n experiLncc, U&
including dozumontation of all challenges to prcsaurizer sfaety valves, shall be submitted an a monthly basis to the U.S. Nuclear Regulatory Commission, Attention: Docmt Cntrolsk, Washington, D.C., with a copy to the Rcgional Administrator of the Regional Office of the NRC, no later than the 1Wth of each month follawing the calendar molnth covered by the repor-t.
5.7.1.5 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.
Specification 3.1.4, "Moderator Temperature Coefficient;"
- 2.
Specification 3.1.5, Control Element Assembly (CEA)
Alignment;"
- 3.
Specification 3.1.7, "Regulating CEA Insertion Limits;"
- 4.
Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"
- 5.
Specification 3.2.1, "Linear Heat Rate;"
- 6.
Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"
- 7.
Specification 3.2.5, "Axial Shape Index;"
- 8.
Specification 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 in:
1.a.1 Letter, dated September 5, 1985, M. 0. Medford (SCE) to G. W. Knighton (NRC), "Docket No. 50-361 and 50-362 Reload Analysis Report," San Onofre Nuclear Generating Station Units 2 and 3 (Cycle 3)
(continued)
SAN ONOFRE--UNIT 3 5.0-26 Amendment No. 4-16
ATTACHMENT 3 Revised Technical Specification Changes Units 2 and 3
Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4.
The reports shall be addressed to the U.S. Nuclear Regulatory Commission, Attention:
Document Control Desk, Washington, D.C., with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.
Annual Reports
NOTE--------------___-________-_
A single submittal may be made for a multiple unit station.
The submittal should combine sections common to all units at the station.
5.7.1.1 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted by March 31 of each year.
Reports required on an annual basis include:
- a.
(Deleted)
(continued)
SAN ONOFRE--UNIT 2 5.0-23 Amendment No.
Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 (Deleted) 5.7.1.5 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.
Specification 3.1.4, "Moderator Temperature Coefficient;"
- 2.
Specification 3.1.5, Control Element Assembly (CEA)
Alignment;"
- 3.
Specification 3.1.7, "Regulating CEA Insertion Limits;"
- 4.
Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"
- 5.
Specification 3.2.1, "Linear Heat Rate;"
- 6.
Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"
- 7.
Specification 3.2.5, "Axial Shape Index;"
- 8.
Specification 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 in:
1.a.1 Letter, dated September 5, 1985, M. 0. Medford (SCE) to G. W4. Knighton (NRC), "Docket No. 50-361 and 50-362 Reload Analysis Report," San Onofre Nuclear Generating Station Units 2 and 3 (Cycle 3)
(continued)
SAN ONOFRE--UNIT 2 5.0-26 Amendment No.
Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 Reporting Requirements 5.7.1 Routine Reports In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4. The reports shall be addressed to the U.S. Nuclear Regulatory Commission, Attention:
Document Control Desk, Washington, D.C., with a copy to the Regional Administrator of the Regional Office of the NRC, unless otherwise noted.
Annual Reports
NOTE----------------------_-
A single submittal may be made for a multiple unit station.
The submittal should combine sections common to all units at the station.
5.7.1.1 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted by March 31 of each year.
Reports required on an annual basis include:
- a.
(Deleted)
I (continued)
SAN ONOFRE--UNIT 3 5.0-23 Amendment No.
Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 (Deleted) 5.7.1.5 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.
Specification 3.1.4, "Moderator Temperature Coefficient;"
- 2.
Specification 3.1.5, Control Element Assembly (CEA)
Alignment;"
- 3.
Specification 3.1.7, "Regulating CEA Insertion Limits;"
- 4.
Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"
- 5.
Specification 3.2.1, "Linear Heat Rate;"
- 6.
Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"
- 7.
Specification 3.2.5, "Axial Shape Index;"
- 8.
Specification 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 in:
1.a.1 Letter, dated September 5, 1985, M. 0. Medford (SCE) to G. W. Knighton (NRC), "Docket No. 50-361 and 50-362 Reload Analysis Report," San Onofre Nuclear Generating Station Units 2 and 3 (Cycle 3)
(continued)
SAN ONOFRE--UNIT 3 5.0-26 Amendment No.