NOC-AE-04001786, License Amendment Request to Eliminate the Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

License Amendment Request to Eliminate the Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

ML042860037
Person / Time
Site:	South Texas
Issue date:	09/30/2004
From:	Jordan T South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-04001786, STI: 31788471, TSTF-369
Download: ML042860037 (14)

Text

Nuclear Operating Company South TtslP'mrJ Electrik Gcnrdn5SWtIon P. Sar 289 ff.d*oth. Tws 77483 September 30, 2004 NOC-AE-04001786 10CFR50.90 STI: 31788471 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request to Eliminate the Requirements to provide Monthly Operating Reports and Occupational Radiation Exposure Reports In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), STP Nuclear Operating Company (STPNOC) is submitting a request for an amendment to the Technical Specifications for South Texas Project Units 1 and 2.

The proposed amendment would delete the Technical Specification (TS) requirements to submit Monthly Operating Reports and Occupational Radiation Exposure Reports. The proposed TS changes are consistent with Revision 1 of NRC-approved Inrdustry/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 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). provides a description of the proposed changes and confirmation of applicability. provides the existing TS pages marked-up to show the proposed changes.

STPNOC requests approval of the proposed license amendment by March 15, 2005, and requests 90 days for implementation of the amendment after it is approved.

NOC-AE-04001786 Page 2 of 3 The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications.

In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments. If there are any questions regarding the proposed amendment, please contact Mr. S. M. Head at (361) 972-7136 or me at (361) 972-7902.

This application includes a new commitment to provide operating data described in Generic Letter 97-02 to the NRC via an industry database.

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

Executed on .gep(eeit he( C3,/ '9 Vice President, Engineering & Technical Services Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-up)

3. Proposed Technical Specification Changes

NOC-AE-04001786 Page 3 of 3 cc:

(paper copy) (electronic copy)

Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission David H. Jaffe Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff C. A. Johnson Bureau of Radiation Control AEP Texas Central Company Texas Department of State Health Services 1100 West 49th Street Jon C. Wood Austin, TX 78756-3189 Matthews & Branscomb Jeffrey Cruz U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MNI16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

Attachment 1 NOC-AE-04001 786 Page 1 of 3 ATTACHMENT 1 Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes the requirements in Technical Specification (TS) 6.9.1.2 for an annual report on occupational radiation exposures and TS 6.9.1.5 for a monthly report of operating statistics and shutdown experience. The changes are consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report, Revision 1".

The availability of this technical specification improvement was announced in the Federal Register on June 23, 2004 (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 6.9.1.2 Occupational Radiation Exposure Report -Deleted TS 6.9.1.5 Monthly Operating Reports --Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, STPNOC is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258 "Changes to Section 6.0, Administrative Controls". Specifically, TS 6.9.1.5 includes a requirement to include in the monthly operating reports any challenges to pressurizer power operated relief valves or pressurizer safety valves. The NRC safety evaluation for TSTF-258 addressed the removal of the requirements to submit monthly operating reports in those cases where the TS includes a requirement to address challenges to relief or safety valves. 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.

STPNOC is proposing not to renumber the Specifications in Section 6.9 as proposed in TSTF-369, Revision 1. Renumbering of the Specifications in Section 6.9 would result in additional unnecessary procedure changes.

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.

Attachment 1 NOC-AE-04001786 Page 2 of 3 4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

5.0 TECHNICAL ANALYSIS

STPNOC 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. STPNOC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to South Texas Project Units 1 and 2 and justify this amendment for the incorporation of the changes to the STP 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, STPNOC is making the following regulatory commitment:

1. STPNOC 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)) The regulatory commitment to provide the operating data is described in Generic Letter 97-02 will be included in the Technical Requirements Manual.

2. STP does not have different reactor types or both operating and shutdown reactors.

Attachment 1 NOC-AE-04001786 Page 3 of 3 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION STPNOC has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. STPNOC has concluded that the proposed determination presented in the notice is applicable to STP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

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

9.0 PRECEDENT This application is being made in accordance with the CLIIP. STPNOC 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), except for minor TS section numbering differences associated with the STPNOC TS format.

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specifications Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Using the Consolidated Line Item Improvement Process, published June 23, 2004 (69 FR 35067).

Attachment 2 NOC-AE-04001 786 Page 1 of4 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RESPONSIBILITY ..................................... 6-1 6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS .............. ....................... 6-2 6.2.2 UNIT STAFF ..................................... 6-2 TABLE 6.2-1 (Deleted) 6.2.3 (Not Used) 6.2.4 (Not Used) 6.3 UNIT STAFF QUALIFICATIONS .6-4 6.4 (Not Used) 6.5 (Not Used) 6.6 (Not Used) 6.7 (Not Used) 6.8 PROCEDURES, PROGRAMS and MANUALS .6-6 6.9 REPORTING REQUIREMENTS 6.9.1 OccupationalRidbtion E.:...;..;...'.; ............................... .3 Annual Radiological Environmental Report .6-13 Radioactive Effluent Release Report .6-14 Monthly O o#ating' Rcports ................................ ;.;.................................. ............ 6 11 Core Operating Limits Report .6-14 6.9.2 (Not Used) 6.10 (Not Used)

SOUTH TEXAS - UNITS 1 & 2 xviii Unit 1 - Amendment No. 3. 4. 112, 151 Unit 2 - Amendment No. QO9-, 139

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1 The following reports shall be submitted in accordance with 10 CFR 50.4.

6.9.1.1 Not Used 6.9.1.2 nr gtie  ;-E;su RGGAr Not Used

-NOTE A Gingle submittal may be made for the South Texac Project. The submittal chould combine coctione that re common tbth ic.

Thi6 rFeport providoe a to ARt o rn arnnul bacic of tho numhbr of ctotn utility, and othor peORnnel (includiRg GontractGor), forwhnom Monitoring wc rwquired, rFecoiVIng aR annual deep dose equivalent greater than 100 mromc and the accociatod collective deep dose equivalent (roported in peron rFemR) acGording to ;r&k aRd jobh futonI i (eFg. racte;r eper~ationr aRd curv e incer'ice incpoction, routine maintena'nce, special maintenance, waste processing, and refueling). The tabulation may include individualr for whom monitoring wac provided but not required. Thi- tahbl-ation cupplementr thee requirementE of 10 CFRR20.2206.

The deos accignments to various duty functionc may be ectimated based on pocketzionization chamber thormolumineccontdecimeter (TL electronicdeimeter orflRm bd meacurmomntc. Small oxpocurec totaling less than 20 percent of the individual total dios need net hb aouRnted for, In the aggregate, at loasc 80 per~eRt of the tetal deep dorb equivalent received from external courcec should be acsigned to cpGcific major Work functions. Th6e eport covering the previouc calendar year shall be submitted by April 30 of each year.

6.9.1.3 Annual Radiological Environmental Operating Report NOTE A single submittal may be made for the South Texas Project. The submittal should combine sections that are common to both units.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted prior to May 15 of each year. The report shall include summaries, interpretations, and analysis 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 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-13 Unit 1 - Amendment No. 47,57,68,151 Unit 2 - Amendment No. 36,46,57,139

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.4 Radioactive Effluent Release Report

__NQJ.E.

A single submittal may be made for the South Texas Project, which shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit in 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 be in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.I.

6.9.1.5 Monthly Opoeatinq Roprt Reoutno reporfc of opertirng cbtictiGe ;and

-r utdoen

+ oxeriec, ncrlu6ding documrientation of all challengoc to the pressurizor power operatod roliof valvos or preccurizor nrg;; e-rts,' valhoc, rze Ad~t m-. e6 ehall A yah be _---

subnittod

.... . Rna1lzmonthly f; bacir no

~ later thaR

. the

-5v-of each month fol1owing the calendar month covered by the report.

6.9.1.6 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. The core operating limits shall be documented in the COLR for the following:

1. Safety limits for thermal power, pressurizer pressure, and the highest operating loop coolant temperature (Ta.g) for Specification 2.1,

2. Limiting Safety System Settings for Reactor Coolant Flow-Low Loop design flow, Overtemperature AT, and Overpower AT setpoint parameter values for Specification 2.2,

3. SHUTDOWN MARGIN limits for Specification 3/4.1.1.1,

4. Moderator Temperature Coefficient BOL and EOL limits, and 300 ppm surveillance limit for Specification 3/4.1.1.3,

5. Shutdown Bank Insertion Limit for Specification 3/4.1.3.5,

6. Control Bank Insertion Limits for Specification 3/4.1.3.6,

7. Axial Flux Difference limits and target band for Specification 3/4.2.1, (continued)

SOUTH TEXAS - UNITS 1 & 2 6-14 Unit 1 - Amendment No. 47,52,68,151 Unit 2 - Amendment No. 36,44,57,139

Attachment 3 NOC-AE-04001 786 Page 1 of4 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION PAGES

INDEX ADMINISTRATIVE CONTROLS SECTION PAGE 6.1 RESPONSIBILITY ..................................... 6-1 6.2 ORGANIZATION 6.2.1 OFFSITE AND ONSITE ORGANIZATIONS .............. ....................... 6-2 6.2.2 UNIT STAFF ..................................... 6-2 TABLE 6.2-1 (Deleted) 6.2.3 (Not Used) 6.2.4 (Not Used) 6.3 UNIT STAFF QUALIFICATIONS .6-4 6.4 (Not Used) 6.5 (Not Used) 6.6 (Not Used) 6.7 (Not Used) 6.8 PROCEDURES, PROGRAMS and MANUALS .6-6 6.9 REPORTING REQUIREMENTS 6.9.1 Annual Radiological Environmental Report ..................................... 6-13 I Radioactive Effluent Release Report ..................................... 6-14 I

Core Operating Limits Report ..................................... 6-14 6.9.2 (Not Used) 6.10 (Not Used)

SOUTH TEXAS - UNITS 1 & 2 xviii Unit 1 - Amendment No.

Unit 2 - Amendment No.

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1 The following reports shall be submitted in accordance with 10 CFR 50.4.

6.9.1.1 Not Used 6.9.1.2 Not Used I 6.9.1.3 Annual Radiological Environmental Operating Report NOTE A single submittal may be made for the South Texas Project. The submittal should combine sections that are common to both units.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted prior to May 15 of each year. The report shall include summaries, interpretations, and analysis 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 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-13 Unit 1 - Amendment No. 47,57,6,154-Unit 2 - Amendment No. 36,46,57,39

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.4 Radioactive Effluent Release Report NOTE A single submittal may be made for the South Texas Project, which shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit in 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 be in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.I.

6.9.1.5 Not Used 6.9.1.6 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. The core operating limits shall be documented in the COLR for the following:

1. Safety limits for thermal power, pressurizer pressure, and the highest operating loop coolant temperature (Tavg) for Specification 2.1,

2. Limiting Safety System Settings for Reactor Coolant Flow-Low Loop design flow, Overtemperature AT, and Overpower AT setpoint parameter values for Specification 2.2,

3. SHUTDOWN MARGIN limits for Specification 3/4.1.1.1,

4. Moderator Temperature Coefficient BOL and EOL limits, and 300 ppm surveillance limit for Specification 3/4.1.1.3,

5. Shutdown Bank Insertion Limit for Specification 3/4.1.3.5,

6. Control Bank Insertion Limits for Specification 3/4.1.3.6,

7. Axial Flux Difference limits and target band for Specification 3/4.2.1, (continued)

SOUTH TEXAS - UNITS I & 2 6-14 Unit 1 - Amendment No. 47,52,68,451 Unit 2 - Amendment No. 36,41,57,449