NLS2004088, Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

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

ML043350030
Person / Time
Site:	Cooper
Issue date:	11/22/2004
From:	Minahan S Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
50.90, NLS2004088
Download: ML043350030 (14)

Text

Nebraska Public Power District Always there when you need us 50.90 NLS2004088 November 22, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

Subject:

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

Cooper Nuclear Station, Docket 50-298, DPR-46 The purpose of this letter is for the Nebraska Public Power District (NPPD) to request an amendment to Facility Operating License DPR46 in accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90 to revise the Cooper Nuclear Station (CNS) Technical Specifications (TS).

The proposed amendment would delete the TS requirements to submit monthly operating reports and annual occupational radiation exposure reports. The change is consistent with Nuclear Regulatory Commission (NRC) approved Revision I 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. provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides the final, clean typed versions of the affected TS pages. Attachment 4, List of Regulatory Commitments, reflects the 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.

NPPD requests approval of the proposed license amendment by October 31, 2005, with the amendment being implemented within 60 days.

The proposed TS change has been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). Amendments to the CNS Facility Operating License through Amendment 207 issued October 15, 2004, have been incorporated into this request. NPPD has concluded that the proposed changes do not involve a significant hazards consideration and that they satisfy the categorical exclusion criteria of 10 CFR 51.22(c).

By copy of this letter and its attachments, the appropriate State of Nebraska official is notified in accordance with 10 CFR 50.91 (b)(l). Copies to the NRC Region IV office and the CNS Resident Inspector are also being provided in accordance with 10 CFR 50.4(b)( 1). A Ho COOPER NUCLEAR STAON P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2004088 Page 2 of 2 Should you have any questions concerning this matter, please contact Mr. Paul Fleming, Licensing Manager, at (402) 825-2774.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: _ _ _ _ _ _ _ _

Date Stewart B. Minahan General Manager of Plant Operations

/clb Attachments cc: Regional Administrator w/attachments USNRC - Region IV Senior Project Manager w/attachments USNRC - NRR Project Directorate IV- I Senior Resident Inspector w/attachments USNRC Nebraska Health and Human Services w/attachments Department of Regulation and Licensure NPG Distribution w/o attachments Records w/attachments

NLS2004088 Attachment I Page 1 of 4 NPPD's Evaluation Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Cooper Nuclear Station, Docket 50-298, DPR-46 Revised TS Pages 5.0-18 5.0-19 (There are no Bases pages associated with this change)

1. Introduction

2. Description of Proposed Amendment

3. Background

4. Regulatory Requirements and Guidance

5. Technical Analysis

6. Regulatory Analysis 6.1 Verification and Commitments

7. No Significant Hazards Consideration

8. Environmental Evaluation

9. Precedent

10. References

NLS2004088 Attachment I Page 2 of 4

1.0 INTRODUCTION

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

The changes are consistent with Nuclear Regulatory Commission (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 AMENDMENT Consistent with the NRC-approved Revision I of TSTF-369, the proposed TS changes include:

TS 5.6.1 [Annual] Occupational Radiation Exposure Report Deleted TS 5.6.4 Monthly Operating Report Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, Nebraska Public Power District (NPPD) 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 (for boiling water reactors). 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.

NLS2004088 Attachment I Page 3 of 4

5.0 TECHNICAL ANALYSIS

NPPD 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 staff's SE and the supporting information provided to support TSTF-369. NPPD has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Cooper Nuclear Station (CNS) and justify this amendment for the incorporation of the changes to the CNS 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 I. NPPD 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. CNS does not have different reactor types or both operating and shutdown reactors.

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

8.0 ENVIRONMENTAL EVALUATION NPPD has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. NPPD has concluded that the staff's findings

NLS2004088 Attachment I Page 4 of 4 presented in that evaluation are applicable to CNS and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. NPPD is not proposing variations or deviations from the TS changes described in TSTF-369 and the limited portion of TSTF-258 or the NRC staff's 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).

NLS2004088 Page I of 3 Proposed Technical Specification Change (Mark-Up)

Cooper Nuclear Station, Docket 50-298, DPR-46 Revised TS Pages 5.0-18 5.0-19

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 _btupational Radiation Exposure Re l Aort A tabu at on annual basis of the number of station, utility, and other personnel (including contra tceiving exposures > 100 mrem/yr and their assote man rem exposure accrd ork and job functions (e.g., reacat ons and surveillance, inservice inp ci n e maintenance, spa intenance (describe maintenance), waste processing, and re *ng). T ulation supplements the requirements of 10 CFR 20.2206. The do ments to various duty functions may be estimated based on electronic o et dosimete, rmoluminescent dosimeter (TLD), or film badge meas nts. Small exposures total <20% of the individual total dose need o ounted for. In the aggregate, at least 8 f_he total whole bod e received from external sources should be assigned to s ic major wo nctions. The report shall be submitted by April 30 of each year.

5.6.2 Annual Radiological Environmental Report The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), 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 ODAM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in Regulatory Guide 4.8, December 1975. 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.

(continued)

Amendment 5.0-1 8 501 O/W7- I

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be sub-mitted 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 ODAM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

6.6.4 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

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

1. The Average Planar Linear Heat Generation Rates for Specification 3.2.1.

2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.7.7.

3. The three Rod Block Monitor Upscale Allowable Values for Specification 3.3.2.1.

4. The power/flow map defining the Stability Exclusion Region for Specification 3.4.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. NEDE-2401 1-P-A, "General Electric Standard Application for Reactor Fuel" (Revision specified in the COLR).

(continued)

Amendment 50-1 5.0-1 9 1I

NLS2004088 Page I of 3 Proposed Technical Specification Pages Re-typed Cooper Nuclear Station, Docket 50-298, DPR-46 Revised TS Pages 5.0-18 5.0-19

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 (Deleted) 5.6.2 Annual Radiological Environmental ReDort The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Assessment Manual (ODAM), 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 ODAM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in Regulatory Guide 4.8, December 1975. 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.

Amendment 5.0-1 8

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the unit shall be sub-mitted 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 ODAM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 (Deleted) 5.6.5 CORE OPERATING LIMITS REPORT (COLR)

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

1. The Average Planar Linear Heat Generation Rates for Specification 3.2.1.

2. The Minimum Critical Power Ratio for Specifications 3.2.2 and 3.7.7.

3. The three Rod Block Monitor Upscale Allowable Values for Specification 3.3.2.1.

4. The power/flow map defining the Stability Exclusion Region for Specification 3.4.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. NEDE-2401 1-P-A, 'General Electric Standard Application for Reactor Fuel" (Revision specified in the COLR).

(continued)

Amendment 5.0-1 9

NLS2004088 Page I of 2 List of Regulatory Commitments Cooper Nuclear Station, Docket 50-298, DPR-46

I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSI Correspondence Number: NLS2004088 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE NPPD 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 Within 60 days of an industry database (e.g., the industry's Consolidated Data approval.

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)).

4.

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I PROCEDURE 0.42 l REVISION 15 l PAGE 18 OF 24 l