ML050610671

Plants - Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports

ML050610671
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	02/22/2005
From:	Hagan J FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3080, L-05-001, PY-CEI/NRR-2852L
Download: ML050610671 (33)

Text

FENOC "EOCt 76 South Main Street FirstEnergy Nuclear Operating Company Akron, Ohio 44308 Joseph J. Hagan 330-761-7895 Senior Vice President, Fax: 330-384-3799 Engineering and Services 10CFR50.90 BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L February 22, 2005 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station Unit 1 Beaver Valley Power Station Unit 2 Docket Number 50-334 Docket Number 50-412 Operating License Number DPR-66 Operating License Number NPF-73 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant Docket Number 50-346 Docket Number 50-440 Operating License Number NPF-3 Operating License Number NPF-58 Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports And Occupational Radiation Exposure Reports Ladies and Gentlemen:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), the FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for amendments to the Technical Specifications (TS) for the Beaver Valley Power Station, Units 1 and 2 (BVPS), the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS), and the Perry Nuclear Power Plant (PNPP).

The proposed amendments would revise the Administrative Controls section of the Technical Specifications to delete the requirements to submit Monthly Operating Reports and Occupational Radiation Exposure Reports.

The proposed changes are 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).

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 2 In order for FENOC to accrue the benefits afforded by the rule change in a timely manner, approval of the proposed amendments is requested by December 30, 2005. Once approved, the amendments shall be implemented within 60 days.

The proposed changes have been reviewed by the onsite and offsite review committees at each of the respective stations.

Should you have any questions or require additional information, please contact Mr. Henry L. Hegrat, Supervisor-Fleet Licensing, at (330) 315-6944. Enclosure 1 includes a description and assessment of the proposed amendments. A list of regulatory commitments made in this letter is included in Enclosure 2.

The statements contained in this submittal, including its associated enclosures and attachments, are true and correct to the best of my knowledge and belief. I am authorized by the FirstEnergy Nuclear Operating Company to make this submittal. I declare under penalty of perjury that the foregoing is true and correct.

Executed on c2-ZL-o c Joseph J. Hagan Senior Vice President, Engineering and Services MKL - License Amendment Application Description and Assessment - Proposed Mark-Up Of Technical Specification Pages for the BVPS - Proposed Mark-Up Of Technical Specification Pages for the DBNPS - Proposed Mark-Up Of Technical Specification Pages for the PNPP - Proposed Retyped Technical Specification Pages for the DBNPS - Proposed Retyped Technical Specification Pages for the PNPP - Technical Specification Bases Pages for the BVPS - Commitment List

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 3 cc:

S. J. Collins, Regional Administrator, NRC Region I J. L. Caldwell, Regional Administrator, NRC Region III T. G. Colburn, NRC/NRR Senior Project Manager - Beaver Valley Power Station J. B. Hopkins, NRC/NRR Senior Project Manager - Davis-Besse Nuclear Power Station W. A. Macon, NRC/NRR Project Manager - Perry Nuclear Power Plant P. C. Cataldo, NRC Region I, Sr. Resident Inspector - Beaver Valley Power Station C. S. Thomas, NRC Region III, Sr. Resident Inspector -

Davis-Besse Nuclear Power Station R. J. Powell, NRC Region III, Sr. Resident Inspector - Perry Nuclear Power Plant D. J. Shipley, Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board D. A. Allard, Director PA BRP/DEP L. E. Ryan, BRP/DEP

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEIINRR-2852L Page 1 APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO ELIMINATE REQUIREMENTS TO PROVIDE MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS Station License Amendment Request No.

Beaver Valley Power Station, Units 1 and 2 329 Unit 1 / 198 Unit 2 Davis-Besse Nuclear Power Station, Unit 1 04-0023 Perry Nuclear Power Plant 04-090 DESCRIPTION AND ASSESSMENT

2.0 DESCRIPTION

OF PROPOSED AMENDMENT

3.0 BACKGROUND

4.0 REGULATORY REQUIREMENTS AND GUIDANCE

6.0 REGULATORY ANALYSIS

6.1 Verification and Commitments 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION 8.0 ENVIRONMENTAL EVALUATION 9.0 PRECEDENT

10.0 REFERENCES

11.0 ATTACHMENTS

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 2

1.0 INTRODUCTION

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), the FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for amendments to the Technical Specifications (TS) for the following Operating Licenses:

Beaver Valley Power Station Unit 1 Beaver Valley Power Station Unit 2 Docket Number 50-334 Docket Number 50-412 Operating License Number DPR-66 Operating License Number NPF-73 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant Docket Number 50-346 Docket Number 50-440 Operating License Number NPF-3 Operating License Number NPF-58 The proposed amendments would revise the Administrative Controls section of the Technical Specifications to delete the requirements to submit Monthly Operating Reports and Occupational Radiation Exposure Reports.

The proposed 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 (69 FR 35067), as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENTS Consistent with the NRC-approved Revision 1 of TSTF-369, the proposed changes would revise the Administrative Controls section of the Technical Specifications to delete the requirements to submit Monthly Operating Reports and Occupational Radiation Exposure Reports. The specific changes are as follows:

For the Beaver Valley Power Station, Units 1 and 2 (BVPS):

• TS 6.9.1, pertaining to the annual Occupational Radiation Exposure Report, would be deleted.

• TS 6.9.4, pertaining to the Monthly Operating Report, would be deleted.

• Consistent with the change to TS 6.9.4, TS 3/4.1.3.2, "Reactivity Control Systems, Position Indication Systems - Operating," Footnote 3, will be revised by deleting the phrase "...in the monthly operating report." (Unit 1 only)

• Associated changes to the TS Index would be made.

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 3

• Technical Specification pages (including index pages) will be revised and repaginated as necessary to meet format requirements and reflect the changes being proposed by this license amendment request.

For the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS):

• TS 6.9.1.5.a, pertaining to the annual Occupational Radiation Exposure Report, would be deleted.

• TS 6.9.1.6, pertaining to the Monthly Operating Report, would be deleted.

For the Perry Nuclear Power Plant (PNPP):

• TS 5.6.1, pertaining to the annual Occupational Radiation Exposure Report, would be deleted.

• TS 5.6.4, pertaining to the Monthly Operating Reports, would be deleted.

As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, FENOC is also proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls," for the BVPS and the DBNPS. Specifically, BVPS TS 6.9.4 includes a requirement to include in the Monthly Operating Report "documentation of all challenges to the pressurizer power operated relief valves or pressurizer safety valves."

Similarly, DBNPS TS 6.9.1.6 includes a requirement to include in the Monthly Operating Report documentation of any "challenges to the Pressurizer Pilot Operated Relief Valve (PORV) and the Pressurizer Code 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.

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.

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 4

5.0 TECHNICAL ANALYSIS

FENOC has reviewed the Nuclear Regulatory Commission (NRC) staff's 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, as well as the supporting information provided to support TSTF-369. FENOC has concluded that the information presented in the TSTF proposal and the SE prepared by the NRC staff are applicable and support this amendment for the incorporation of the changes to the TS.

Footnote 3 of the BVPS Unit 1 TS 3/4.1.3.2 presently states: "Malfunctions of the group demand counters or analog RPI, providing no actual rod misalignment existed during the malfunction, shall be reported in the monthly operating report." The phrase "...in the monthly operating report," is proposed to be deleted. The BVPS Unit 1 TS Bases will be revised to state that the mechanism for the required report will be the electronic monthly operating report via the combined industry database. This change is acceptable because the administrative requirement specifying the revised method of reporting will be retained within the TS Bases.

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 NRC staffs model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, FENOC is making the following regulatory commitment and verification:

1.

FENOC 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)).

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080-PNPP Letter PY-CEI/NRR-2852L Page 5

2.

None of the three sites, taken individually, have different reactor types or both operating and shutdown reactors.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION FENOC has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. FENOC has concluded that the proposed determination presented in the notice is applicable to the BVPS, the DBNPS, and the PNPP, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION FENOC has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. FENOC has concluded that the staffs findings presented in that evaluation are applicable to the BVPS, the DBNPS, and the PNPP, and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. FENOC 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) other than format differences and deletion of reference to the Monthly Operating Report in BVPS Unit 1 Technical Specification 3/4.1.3.2, Footnote 3.

10.0 REFERENCES

1.

"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 in the Federal Register on June 23, 2004 (69 FR 35067).

2.

TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report," Revision 1.

3.

TSTF-258, "Changes to Section 5.0, Administrative Controls," Revision 4.

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L Page 6 11.0 ATTACHMENTS

1.

Proposed Mark-Up Of Technical Specification Pages for the BVPS.

2.

Proposed Mark-Up Of Technical Specification Pages for the DBNPS.

3.

Proposed Mark-Up Of Technical Specification Pages for the PNPP.

4.

Proposed Retyped Technical Specification Pages for the DBNPS.

5.

Proposed Retyped Technical Specification Pages for the PNPP.

6.

Technical Specification Bases Pages for the BVPS.

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEIINRR-2852L Enclosure I PROPOSED MARK-UP OF TECHNICAL SPECIFICATION PAGES FOR THE BVPS (8 pages follow)

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.8 PROCEDURES........................................

6-6 6.9 REPORTING REOUIREMENTS............................

6-17 6.9.1 DELETEDOcupatiena1 Radiation EXpoeure Repert 6 -6 4 6.9.2 Annual Radiological Environmental Operating Report.........................

6-17 6.9.3 Annual Radioactive Effluent Release Report.6-18 6.9.4 DELETED..onth6y Oprating Rcport 6

l 6.9.5 Core Operating Limits Report (COLR) 6-18 6.9.6 Pressure and Temperature Limits Report (PTLR).6-20 6.10 DELETED 6.11 RADIATION PROTECTION PROGRAM.....................

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

6.13 PROCESS CONTROL PROGRAM (PCP)....................

6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)...........

6.16 MAJOR CHANGES TO RADIOACTIVE WASTE.

TREATMENT SYSTEMS................................

6.17 CONTAINMENT LEAKAGE RATE TESTING PROGRAM.........

6.18 TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM.........................................

6-21 6-23 6-24 6-24 6-25 6-25 6-26 BEAVER VALLEY -

UNIT 1 XV Amendment No.

Qs-,-6 1

REACTIVITY CONTROL SYSTEMS POSITION INDICATION SYSTEMS-OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2 The shutdown and control rod position indication system shall be OPERABLE as follows:

Group Demand Counter"), 1 per group Individual analog rod position instrument channel, 1 per rod

+/-12 stepsXl) accuracy(3)

(1) During the first hour following rod motion, the group demand counter is the primary indicator of precise rod position information, with the analog channels displaying general rod movement information.

For power levels below 50%, a 1-hour thermal soak time is allowed before the analog channels are required to perform within the specified accuracy.

(2) For power levels below 50% a one hour thermal soak time is allowed.

(3) Malfunctions of the group demand counters or analog RPI, providing no actual rod misalignment existed during the malfunction, shall be reported in the monthly operating report.

I BEAVER VALLEY - UNIT 1 3/4 1-20 Amendment No.

24&

ADMINISTRATIVE CONTROLS The provisions of Specifications 4.0.2 and 4.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

6.9 REPORTING REOUIREMENTS The following reports shall be submitted in accordance with 10 CFR 50.4.

6.9.1 T

gat l Rad e

E NOTE A single submittal may be made for a multiple unit station.

The submaittal sheuld combine sections common toe all units at the statien A tabulation en an annual basis ef the number of station, utility, and other personnel (including contraeters) receiving exposurre greatcr than 100 mrem/yr and their aseciated man rem exposure according to work and job functions (e.g., reactor operations and ourveillanoc, inerviee inspeetien, reutine maintenance, special maintenanee (deLcribe maintenanee), waste prA4oeing, and refueling).

This tabulation supplements the reuirements of 10 CFR 20.2206.

The dose assignments to various duty functions may be estimated based on poeket doeimetcr, thermolumineseent dosimeter (TLD), or film badge measurements.

Small exposures totalling less than 20 percent of the individual teal dose need not be accunted for.

in the aggregate, at: least 80 percent of the total whole body dese recei-ved froem extcrnal seurecs should be assigned to specific major werk functions.

The report shall be submitted by April 30 of each year.

6.9.2 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 before 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 Part 50 Appendix I Sections IV.B.2, IV.B.3, and IV.C.

BEAVER VALLEY - UNIT 1 6-17 Amendment No.

Q-54 I

IThis page includes change proposed by LAR 310 l

ADMINISTRATIVE CONTROLS 6.9.3 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

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

A single submittal may be made for a multi-unit station.

The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

The Annual 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 Process Control Program (PCP) and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I Section IV.B.1.

6.9.4 DELETEDMONTHLY OPERATINC REPORT Routine reperts ef operating statistics and shutdwan experiecec, including deeumentation of all challenges to the preoourizcr power eperated relief valves er prezourizcr safety valves, ohall be submitted on a monthly basis ne later than the 15th ef eah montoh fllewing the calendar menth eve Ad by the rAeor-t_.

6.9.5 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:

2.1.1 Reactor Core Safety Limits 3.1.3.5 Shutdown Rod Insertion Limits 3.1.3.6 Control Rod Insertion Limits 3.2.1 Axial Flux Difference-GenstantRelaxed Axial Offset Control 3.2.2 Heat Flux Hot Channel Factor-F,(Z) 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor-FeA 3.2.5 DNB Parameters 3.3.1.1 Reactor Trip System Instrumentation -

Overtemperature and Overpower AT Setpoint Parameter Values BEAVER VALLEY - UNIT 1 6-18 Amendment No. Gin I

INDEX ADMINISTRATIVE CONTROLS SECTION 6.3 FACILTTY STAFF OUALTFTCATTONS PAGE 6-6 6.4 DELETED 6.5 DELETED 6.6 REPORTABLE EVENT ACTION..........................

6-6 6.7 DELETED 6.8 PROCEDURES........................................

6-7 6.9 REPORTIN(

6.9.1 6.9.2 6.9.3 6.9.4 6.9.5 6.9.6 REOUIREMENTS TELEEOccupatienal Radiation Exposure Report 6 17 Annual Radiological Environmental Operating Report.........................

6-18 Annual Radioactive Effluent Release Report...................................

6-18 MT'~adhl SOpeaigRp f\\bn Dab-Core Operating Limits Report.............

6-19 Pressure and Temperature Limits Report (PTLR)...................................

6-21 I

I 6.10 DELETED 6.11 RADIATION PROTECTION PROGRAM.....................

6-22 BEAVER VALLEY -

UNIT 2 XIV Amendment No.

1-34 I

ADMINISTRATIVE CONTROLS PROCEDURES (Continued)

The program shall include:

1.

The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained.

Such limits shall ensure that the concentration of hydrogen and oxygen is maintained below the flammability limits.

2.

A surveillance program to ensure that the quantity of radioactivity contained in each connected group of Gaseous Waste Storage Tanks is less than the amount that would result in a whole body exposure of > 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents, and

3.

A surveillance program to ensure that the quantity of radioactivity contained in all outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations greater than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

The provisions of Specifications 4.0.2 and 4.0.3 are applicable to the Explosive Gas and Storage Tank Radioactivity Monitoring Program surveillance frequencies.

6.9 REPORTING REOUIREMENTS The following reports shall be submitted in accordance with 10 CFR 50.4.

6.9.1 DELETED~ccupational Radiation Eeposure Reertl NOTE A single submittal may be made for a multiple unit station.

The submittal should combine scetions common to all units at the statien.

BEAVER VALLEY - UNIT 2 6-17 Amendment No.

1-34 1

ADMINISTRATIVE CONTROLS REPORTING REQUIREMENTS (Continued)

A tabulation en an annual basis of the number ef statien,

_utilit-y4, and other pereonnel (including contractors) receiving expoeure greater than 100 mrem/yr and their associated man rem oxpoeure V

A

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accnordnn to -oi andna~h j.obnfunctni~n wnog.,

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Thig tabulation supplementos the rmnts of 10 CFR 20.2206.

ThI dese assignments to variu duty funetiens may be edtimated based on pocket dosimeter, thermolumincseent dosimeter (TLD), or film badge measuremoent.

Small expeoures totalling less than 20 percnt of the individual total dooc need net be aeee-^t, d for.

in the aggregate_,

at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.

The report shall be submitted by April 30 of each year.

6.9.2 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 before 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 Part 50, Appendix I Sections IV.B.2, IV.B.3, and IV.C.

6.9.3 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT

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

A single submittal may be made for a multi-unit station.

The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

BEAVER VALLEY - UNIT 2 6-18 Amendment No.

1-3-0 1

I This page includes change proposed by LAR 182 ADMINISTRATIVE CONTROLS REPORTING REOUIREMENTS (Continued)

The Annual 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 Process Control Program (PCP) and in conformance with 10 CFR 50.36a and 10 CFR Part 50, Appendix I Section IV.B.1.

6

.94 vELE T DGNT1116Y OPERNTING REPGR-T Reutine reports of operating otatiotics and shutdown cxperincnc, including decumentatien of all challenges te the pressuriz-PoW-r-operated relief valves or prcssurizcr safety valves, shall be submitted on a monthly basis no later than the 15th of cach month following the calendar month covered by the report.

6.9.5 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:

2.1.1 Reactor Core Safety Limits 3.1.3.5 Shutdown Rod Insertion Limits 3.1.3.6 Control Rod Insertion Limits 3.2.1 Axial Flux Difference-GenstantRelaxed Axial Offset Control 3.2.2 Heat Flux Hot Channel Factor-F0(Z) 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor-FO4 3.2.5 DNB Parameter 3.3.1.1 Reactor Trip System Instrumentation -

Overtemperature and Overpower AT setpoint parameter values

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:

WCAP-9272-P-A, "WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY," July 1985 (Westinghouse Proprietary).

BEAVER VALLEY - UNIT 2 6-19 Amendment No. 13-G

ADMINISTRATIVE CONTROLS ANNUAL OPERATING REPORT 6.9.1.4 Annual reports covering the activities of the unit during the previous calendar year shall be submitted prior to March 31 of each year.

6.9.1.5 Reports required on an annual basis shall include:

a.

A tabulation on an annual basis of the number of station, utility and otheF personnel (including contractors) rFceiving exposures greater than 100 mrenTL' and their assoeiated man rem exposure according to work and job funct onnste sg.,Feaeef operatiens and sufveillance, insenvce inspection, routine maintenance, speeial rniitenancc (described maintenanee), waste processing, and refueling. The dose

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1ESSEiMlruni tH var+4ou auL'V iuncMons ma; lip caimanrs easea on nnntO anosmliir. I W.

or film badge measurements. Small expesures totalling less than 20-o of the individual tetal dose need not be accounted for. In the aggregate, at least 80%o of the total whole IL^

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A-11 IL a

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a"ei eeeves fieieaP-1etcd U vfefIt eft~mal urifet.

sa.lU C EW uEsIgnea to tipeeCCoII1 mafijor wonrm

b. The complete results of steam generator tube inservice inspections (Specification 4.4.5.5.b).

c.

The results of specific activity analysis in which the primary 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; (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) Clean-up system 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 and one other radioiodine isotope concentration in e

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Warren An_ _rwA Ad.

on t1his tabulation supplements the requirements ot1 6 r41: ef 10 CAv. Pairt n.'.

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DAVIS-BESSE, UNIT I 6-15 Amendment No. 9, 12, 41, 52, 73, 87, 104, 135, 258,

ADMINISTRATIVE CONTROLS microcuries per gram 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 primary coolant exceeded the radioiodine limit; MONTHLY OPERATING REPORT 6.9.1.6 Reutine r-eports of operating statistics, shutdewn exper-ienee and challenges te the Pfessurnzer-Pilet Operated Relief Valve (PORV9 and the Nessudzer-Cede Safety Vl'pves shall be submitted on monthly basis to arrive no later than the 1 5th of each month following the calendar month covered by the report, as follows: The signed original to the Nuclear Regulator) Commission, Document Centrol Dcsk, Washingten, D. C. 20555, and one copy each to the Region m Administrater and the Davis Besse Resident Inspeeter-~j CORE OPERATING LIMITS REPORT 6.9.1.7 Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT before each reload cycle and any remaining part of a reload cycle for the following:

2.1.2 2.2.1 3.1.1.3c 3.1.3.6 3.1.3.7 3.1.3.8 3.1.3.9 3.2.1 3.2.2 3.2.3 3.2.4 AXIAL POWER IMBALANCE Protective Limits for Reactor Core Specification 2.1.2 Trip Setpoint for Flux - AFlux/Flow for Reactor Protection System Setpoints Specification 2.2.1 Negative Moderator Temperature Coefficient Limit Regulating Rod Insertion Limits Rod Program Xenon Reactivity Axial Power Shaping Rod Insertion Limits AXIAL POWER IMBALANCE Nuclear Heat Flux Hot Channel Factor, FQ Nuclear Enthalpy Rise Hot Channel Factor, F,0H QUADRANT POWER TILT The analytical methods used to determine the core operating limits addressed by the individual Technical Specifications shall be: those previously reviewed and approved by the NRC, as described in BAW-10179P-A, "Safety Criteria and Methodology for Acceptable Cycle Reload Analyses", or any other new NRC-approved analytical methods used to determine core operating limits that are not yet referenced in the applicable approved revision of BAW-101 79P-A. The applicable approved revision number for BAW-10179P-A at the time the reload analyses are performed shall be identified in the CORE OPERATING LIMITS REPORT. The CORE OPERATING LIMITS REPORT shall also list any new NRC-approved analytical methods used to determine core operating limits that are not yet referenced in the applicable approved revision of BAW-10179P-A.

DAVIS-BESSE, UNIT I 6-16 Amendment No. 8, 12, 93, 104, 135, 144, 154, 189,

SVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L PROPOSED MARK-UP OF TECHNICAL SPECIFICATION PAGES FOR THE PNPP (2 pages follow)

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 Occupational Radiation Exposure Report u ation-on an annua asis of the number of station. utility a a>ther personnel (including contractors), for whom monitorin

/

was p rmed. receiving an annual deep dose equivalent > 1 rem and the a iated collective deep dose equivalent (re in person-rem) a diN to work and job functions. (e.

reactor operations and su illance. inservice inspectia outine maintenance, special ntenance (describe m& enance). waste processing. and refuelin This tabulat supplements the requirements of 10 CFR 2.22 The d assignments to various duty functions may be estimated on pocket ionization chamber, thermoluminescent dosim TLD). electronic dosimeter.

or film badge measurements.

I1 expo es totalling < 20% of the individual total dose ednot be acco ed for. In the aggregate. at least 80 f the total deep dos quivalent received from external sour should be assigned to spec *c major work functions.

The Occu onal Radiation Exposure Re rt covering the a ities of t nit for the previous year shallbe submitted by Apri 5.6.2 Annual Radiological Environmental Oberating Renort The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous year shall be submitted by May 1 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 (00CM), 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 (continued)

PERRY - UNIT 1 5.0-16 Amendment No. 120

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual RadioloQical Environmental Operating Report (continued) 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.

Radioactive Effluent Release RewOrt The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted by May 1 of each year. 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.

5.6.3 5.6.4 5.6.5 Core Oneratina Limits ReDort (COLR)

a. Core operating limits shall be established prior to each reload cycle, or nrior to any remaining portion of a reload cycle, and shall De documented in the COLR for the following:

1.

LCO 3.2.1. Average Planar Linear Heat Generation Rate (APLHGR),

2.

LCO 3.2.2. Minimum Critical Power Ratio (MCPR).

3.

LCO 3.2.3. Linear Heat Generation Rate (LHGR).

(continued)

PERRY - UNIT I 5.0-17 Amendment No. 120

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CELINRR-2852L PROPOSED RETYPED TECHNICAL SPECIFICATION PAGES FOR THE DBNPS (2 pages follow)

ADMINISTRATIVE CONTROLS ANNUAL OPERATING REPORT 6.9.1.4 Annual reports covering the activities of the unit during the previous calendar year shall be submitted prior to March 31 of each year.

6.9.1.5 Reports required on an annual basis shall include:

a. Deleted

b. The complete results of steam generator tube inservice inspections (Specification 4.4.5.5.b).

c. The results of specific activity analysis in which the primary 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; (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) Clean-up system 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 and one other radioiodine isotope concentration in I

I DAVIS-BESSE, UNIT 1 6-15 Amendment No. 9, 12, 41, 52, 73, 87, 104, 135, 258,

ADMINISTRATIVE CONTROLS microcuries per gram 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 primary coolant exceeded the radioiodine limit.

MONTHLY OPERATING REPORT 6.9.1.6 Deleted CORE OPERATING LIMITS REPORT 6.9.1.7 Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT before each reload cycle and any remaining part of a reload cycle for the following:

2.1.2 AXIAL POWER IMBALANCE Protective Limits for Reactor Core Specification 2.1.2 2.2.1 Trip Setpoint for Flux -- AFlux/Flow for Reactor Protection System Setpoints Specification 2.2.1 3.1.1.3c Negative Moderator Temperature Coefficient Limit 3.1.3.6 Regulating Rod Insertion Limits 3.1.3.7 Rod Program 3.1.3.8 Xenon Reactivity 3.1.3.9 Axial Power Shaping Rod Insertion Limits 3.2.1 AXIAL POWER IMBALANCE 3.2.2 Nuclear Heat Flux Hot Channel Factor, FQ N

3.2.3 Nuclear Enthalpy Rise Hot Channel Factor, F H 3.2.4 QUADRANT POWER TILT The analytical methods used to determine the core operating limits addressed by the individual Technical Specifications shall be: those previously reviewed and approved by the NRC, as described in BAW-IO 179P-A, "Safety Criteria and Methodology for Acceptable Cycle Reload Analyses", or any other new NRC-approved analytical methods used to determine core operating limits that are not yet referenced in the applicable approved revision of BAW-101 79P-A. The applicable approved revision number for BAW-10179P-A at the time the reload analyses are performed shall be identified in the CORE OPERATING LIMITS REPORT. The CORE OPERATING LIMITS REPORT shall also list any new NRC-approved analytical methods used to determine core operating limits that are not yet referenced in the applicable approved revision of BAW-101 79P-A.

DAVIS-BESSE, UNIT 1 6-16 Amendment No. 8, 12, 93, 104, 135, 144, 154, 189,

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L PROPOSED RETYPED TECHNICAL SPECIFICATION PAGES FOR THE PNPP (2 pages follow)

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 Occupational Radiation Exposure Report Deleted 5.6.2 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous year shall be submitted by May 1 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 CODCM). and in 10 CFR 50. Appendix I. Sections IV.B.2, IV.B.3.

and IV.C.

The Annual Radiological Environmental Operating Re ort 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 (continued)

PERRY - UNIT 1 5.0-16 Amendment No.

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

5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted by May 1 of each year. 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.

Monthly Operating Reports 5.6.4 Deleted Core Operating Limits Report (COLR) 5.6.5

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. LCO 3.2.1, (APLHGR).

Average Planar Linear Heat Generation Rate

2.

LCO 3.2.2. Minimum Critical Power Ratio (MCPR),

3. LCO 3.2.3, Linear Heat Generation Rate (LHGR),

(continued)

PERRY - UNIT 1 5.0-17 Amendment No.

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEI/NRR-2852L TECHNICAL SPECIFICATION BASES PAGES FOR THE BVPS (2 pages follow)

Note: The Bases pages are provided for information only.

REACTIVITY CONTROL SYSTEMS P

11Provided for W~ormation Only.

BASES 3/4.1.3 MOVABLE CONTROL ASSEMBLIES The specifications of this section ensure that (1) acceptable power distribution limits are maintained, (2) the minimum SHUTDOWN MARGIN is maintained, and (3) the potential effects of rod misalignment on associated accident analyses are limited.

OPERABILITY of the movable control assemblies is established by observing rod motion and determining that rods are positioned within +/- 12 steps (indicated position), of the respective group demand counter position.

The OPERABILITY of the rod position indication system is established by appropriate periodic CHANNEL CHECKS and verification that the analog rod position indicators agree with the demand position indicators within 12 steps over the full range of indicated rod travel.

The verification of individual rod position indicators and demand position indicators within the required 12 steps over the full range of indicated rod travel is accomplished by comparisons of the indications at specific rod positions (identified in the applicable surveillance procedure) and calibrations as necessary to ensure the required accuracy is achieved.

OPERABILITY of the control rod position indicators is required to determine control rod position and thereby ensure compliance with the control rod alignment and insertion limits.

The OPERABLE condition for the analog rod position indicators is defined as being capable of indicating rod position within +/- 12 steps of the associated group demand indicator.

For power levels below 50 percent, the specifications of this section permit a one hour stabilization period to permit stabilization of known thermal drift in the analog rod position indicator channels.

During this stabilization period, greater reliance is placed upon the group demand position indicators to determine rod position.

Above 50 percent power, rod motion is not expected to induce thermal transients of sufficient magnitude to exceed the rod position indicator instrument accuracy of +/- 12 steps.

Limited use of rod position indication primary detector voltages is allowed as a backup method of determining control rod positions.

Comparison of the group demand indicator to the calibration curve is sufficient to allow determination that a control rod is indeed misaligned from its bank when primary voltage measurements are used.

Comparison of the group demand counters to the bank insertion limits with verification of rod position with the analog rod BEAVER VALLEY - UNIT 1 B 3/4 1-3 Change No. l-001

REACTIVITY CONTROL SYSTEMS Provided for Information Only.

l BASES position indicators (after thermal soak after rod motion) is sufficient verification that the control rods are above the insertion limits below 50 percent power.

Above 50 percent power, reliance is placed on the analog rod position indicator channels to assure that control rods are above the insertion limits.

The ACTION statements which permit limited variations from the basic requirements are accompanied by additional restrictions which ensure that the original design criteria are met.

Misalignment of a rod requires measurement of peaking factors and a restriction in THERMAL POWER.

These restrictions provide assurance of fuel rod integrity during continued operation.

In addition, those safety analyses affected by a misaligned rod are reevaluated to confirm that the results remain valid during future operation.

For Specification 3.1.3.1 ACTION c. and d., it is incumbent upon the plant to verify the trippability of the inoperable control rod(s).

Trippability is defined in Attachment C

to a

letter dated December 21, 1984, from E. P. Rahe (Westinghouse) to C. 0. Thomas (NRC).

This may be by verification of a control system failure, usually electrical in nature, or that the failure is associated with the control rod stepping mechanism.

In the event the plant is unable to verify the rod(s) trippability, it must be assumed to be untrippable and thus falls under the requirements of ACTION a.

Malfunctions of the arouD demand countesor ano RPI described in Footnote 3 of Specification 3.1.3.2 shall be reported to the NRC in the electronic monthly operating report via the combined industry BEAVER VALLEY -

UNIT 1 B 3/4 1-4 Amendment No.

Q4&

I

BVPS Letter Number L-05-001 DBNPS Letter Serial Number 3080 PNPP Letter PY-CEIINRR-2852L COMMITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMITTED TO BY FENOC IN THIS DOCUMENT. ANY OTHER ACTIONS DISCUSSED IN THE SUBMITTAL REPRESENT INTENDED OR PLANNED ACTIONS, AND ARE DESCRIBED ONLY FOR INFORMATION AND ARE NOT REGULATORY COMMITMENTS. PLEASE NOTIFY HENRY L. HEGRAT, SUPERVISOR - FLEET LICENSING, AT (330) 315-6944 OF ANY QUESTIONS REGARDING THIS DOCUMENT OR ANY ASSOCIATED REGULATORY COMMITMENTS.

COMMITMENTS DUE DATE FENOC 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)).