ML20065K182
| ML20065K182 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/12/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20065K188 | List: |
| References | |
| NSD940383, NUDOCS 9404190206 | |
| Download: ML20065K182 (4) | |
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COOPEA NUCLEAR STATION
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.--==.2 NSD940383 April 12,1994 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
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Subject:
Proposed Change No. I17 to Technical Specifications 10 CFR Part 20 Implementation Cooper Nuclear Station NRC Docket No. 50-298, DPR-46
Reference:
Letter (No. NSD930758) from G. R. Horn (NPPD) to U.S. NRC Document Control Desk dated June 14,1993, " Proposed Change No. I17 to the Cooper Nuclear Station Technical Specifications; 10 CFR Part 20 Implementation" Gentlemen:
In the above reference, the Nebraska Public Power District (District) submitted a proposed change to the Cooper Nuclear Station (CNS) Technical Specifications that would revise those portions of the Technical Specifications impacted by the implementation of the revised 10 CFR
- 20. During subsequent NRC review of this application, the NRC suggested that the District revise this proposed change to 1) remove proposed definitions which are redundant to 10 CFR 20, and 2) reference 10 CFR Part 20.1302 as opposed the proposed reference to 10 CFR Part 20, Appendix H, pertaining to the Limiting Condition for Operation (LCO) controlling liquid effluent concentrations.
This revision to Proposed Change No. I17 is based on discussions between the NRC and the District held on December 6th and 7th,1993 where the primary concern centered around a proposed wording change to LCO 3.21.B.I.a of the CNS Technical Specifications. The District had originally proposed to substitute the term "10 CFR Part 20.106" with the term "10 CFR 20, Appendix B. Table 2, annual averaged concentrations" During this discussion it was agreed that the CNS licensing basis, as given in the Radiological Effnents Technical Specifications (RETS) issued per CNS License Amendment No. 89, allowed for the averaging of release rates over one year. However, it was also agreed that release rates could be averaged over a month. This averaging is currently specilled in Surveillance Requirement 4.21.lLI b and would be retained by revising LCO 3.21.B.l.a to reference 10 CFR Part 20.1302 in place of the current reference of 10 CFR Part 20.106.
During this discussion, the NRC also noted that the District had included definitions that are contained in the revised Part 20. Inclusion of these definitions were considered unnecessary and could result in the need to process a future Technical Specification change should the subject definitions change. The District agreed to remove these definitions.
As a result of the above summarized discussion, the following three specific revisions to Proposed Change No. I17 are submitted for NRC review:
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' U.S. Nuclear Regulatory Commission Page 2 of 4 April 12,1994
'Page No DescIiption of Changes Subsequent to Submittal of the Reference 5a & 5c These pages are being submitted to reflect the removal of Definitions 1.0.Z.B.1 -
5.
These definitions pertain to the revised Part 20 terms " Controlled Area, Occupational Dose, Restricted Area, Unrestricted Area, and Site Boundary" Due to these changes, Page Sc is no longer affected by Proposed Change No.
117.
216a21 This page is being resubmitted to reflect a change to LCO 3.21.B.I.a (Line 5) regarding the reference to 10 CFR Part 20.106. The proposed reference is 10 CFR Part 20.1302. The District had originally proposed the term "10 CFR 20, Appendix B, Table 2, annual averaged concentrations."
216x This page is being resubmitted to reflect a change to Paragraphs 1,4,5 and 6 (Lines 6,3,8 and 2 respectively) regarding the reference to 10 CFR Part 20.106.
The proposed reference.is 10 CFR Part 20.1302. The District had originally proposed the term "10 CFR 20, Appendix B, Table 2, annual averaged concentrations" and references to 10 CFR Part 20, Appendix B, Table 2.
Both the affected revised pages and the corresponding marked-up pages are attached for consideration. This revision to Proposed Change No. I17 has been reviewed by the necessary Safety Review Committees. Due to the fact that the changes, contained in this revision, are I
minor in nature, the District considers the no significant hazards determination, contained in the reference, to still be valid.
As stated in the reference, the District implemented the revised Part 20 rule on January 1, 1994.
For this reason, the District respectfully requests that the approved Technical 1
Specification Change be approved as soon as practical in order to minimize any confusion that could result from implementing the revised Part 20 concurrent with the Technical Specifications referencing the old Part 20 sections.
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By copy of this letter and attachment, the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91(b)(1). Copies to the NRC Region IV Office and the CNS Resident inspector are also being sent in accordance with 10 CFR 50.4(b)(2).
If you have any questions or require any additional information, please contact me.
l Sincerely,
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ccJresident - Nuclear 1
GRil/dnm Attachment 4
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U.S. Nuclear Regulatory Commission -
Page 3 of 4 April 12,1994
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- 11. R.' 13crchert e
~ Department ofIlealth State of Nebraska NRC Regional Office Region IV Arlington, TX NRC Resident inspector Cooper. Nuclear Station 1
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U.S. Nuclear Regulatory Commission Page 4 of 4 April 12,1994 STATE OF NEBRASKA)
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NEMAllA COUNTY
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G. R. Ilorn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge, and belief.
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/w su C R.IIorn Subscribed in my presence and sworn to before me this
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day of (14L
, 1994.
0 GFJtERALNOTARY41sh of Nebrists
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MARYFRANCESARMSTRONG
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)TARY PUBLIC
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