W3F1-2004-0121, Submittal of License Amendment Request NPF-38-259 for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

Submittal of License Amendment Request NPF-38-259 for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports

ML043630375
Person / Time
Site:	Waterford
Issue date:	12/22/2004
From:	Venable J Entergy Nuclear South
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NPF-38-259, W3F1-2004-0121
Download: ML043630375 (13)

Text

Entergy Nuclear South AM Entergy Operations, Inc.

17265 River Road Killona. LA 70066

EnterTel 504 739 6660 Fax 504 739 6678 jvenabt~entergy.com Joseph E. Venable Vice President, Operations Waterford 3 W3F1 -2004-0121 December 22, 2004 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20 55

SUBJECT:

License Amendment Request NPF-38-259 Application for Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports and Occupational Radiation Exposure Reports Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NFP-38

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Waterford Steam Electric Station, Unit 3 (Waterford 3).

The proposed amendment would delete the TS requirements to submit monthly operating reports and occupational radiation exposure reports. The change is consistent with NRC-approved Revision 1 to Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, 'Removal of Monthly Operating Report and Occupational Radiation Exposure Report." The availability of this TS improvement was announced in the Federal Regaister on June 23, 2004, as part of the Consolidated Line Item Improvement Process (CLIIP).

Attachment 1 provides a description of the proposed change and confirmation of applicability.

Attachment 2 provides the existing TS pages marked-up to show the proposed change.

The proposed change includes a new commitment as summarized in Attachment 3.

Entergy requests approval of the proposed license amendment by April 30, 2005, with the amendment being implemented within 90 days of approval.

If you should have any questions regarding his submittal, please contact me or Matt Crawford at 601-437-2334.

Aool

W3F1 -2003-0121 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on December 22, 2004.

Sincerely, JEV/DBM/cbh Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Ups)

3. List of Regulatory Commitments

W3FI-2003-0121 Page 3 of 3 cc: Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector Waterford 3 P.O. Box 822 Killona, LA 70057 U.S. Nuclear Regulatory Commission Attn: Mr. Nageswaran Kalyanam MS 0-7D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway Attn: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn Attn: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. 0. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers Attn: Library Town Center Suite 300S 29th S. Main Street West Hartford, CT 06107-2445

Attachment I To W3FI -2004-0121 Description and Assessment to W3Fl -2004-0121 Page 1 of 3

1.0 INTRODUCTION

The proposed License amendment deletes the requirements in Technical Specification (TS) 6.9.1.5 for an annual report on occupational radiation exposures and TS 6.9.1.6 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, 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 6.9.1.5 Occupational Radiation Exposure Report Deleted TS 6.9.1.6 Monthly Operating Reports Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, Entergy is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." Specifically, TS 6.9.1.6 includes a requirement to include in the monthly operating reports any challenges to the 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.

It is also proposed to revise Index Page xvii to reflect the deletion of the Monthly Operating Report. This is an editorial change and will not be discussed further.

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.

5.0 TECHNICAL ANALYSIS

Entergy 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. Entergy has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Waterford Steam Electric Station, Unit 3 (Waterford 3) and justify this amendment to W3FI-2004-0121 Page 2 of 3 for the incorporation of the changes to the Waterford 3 TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, Entergy is making the following verifications and regulatory commitment:

1. Entergy 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. Waterford 3 does not have different reactor types or both operating and shutdown reactors.

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

8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to Waterford 3 and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Entergy 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

Attachment I to W3F1 -2004-0121 Page 3 of 3 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 To W3FI -2004-0121 Proposed Technical Specification Changes (Mark-Up) to W3F1 -2004-0121 Page 1 of 3 INDB ADMINISTRATIVE CONTROLS SECTIONQ 6.6 NOT USED 6.7 NOT USED 6.8 PROCEDURES AND PROGRAMS ................................................. 6-14 6.9 REPORTING REQUIREMENTS ................................................. 6-17 6.9.1 ROUTINE REPORTS ................................................. 6-17 STARTUP REPORT .................................................. 6-17 ANNUAL REPORTS .............................................................. . 6-17 JDZEE

) -NULRADIOLOGICALEVRONMENTAL OPERATING IOiRT ............................................................ 6-18

/ 4N UAL RADIOACTIVE EFFLUENT RELEASE REPORT 6-19 1.-IN STRIAL SURVEY OF TOXIC CHEMICALS REPORT 6-20 spC RE OPERATING LIMITS REPORT COLR .................. 6-20 6.9.2 S C l REPORTS ................................................. 6-20a

.%A WATERFORD - UNIT 3 AMENDMENT NO. 68,84,102,-MB to W3Fl -2004-0121 Page 2 of 3 AOMINIStATI-t LtUhIROLS ANNUAL REPORTS (Continued)

(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 inwhich the limit was exceeded; (4) Graph of the 1-131 concentration and one other radioiodine isotope concentration inmicrocuries per gram as a function of time for the duration of the specific activity above steady-state level; and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

lepgrfs requ /ed on an fshallual basi

,f4ach ye and cl a tabul ion on d, utili 1 and oth personneY (includf g was rformed, ceiving annual ep anid Je associa d collec e deep se e n ccording work an Job func ons* (

ce. inserv e inspec on rout e maintej mainten al. wast orocessi . and rez4 WATERFORD - UNIT 3 6-1 7a Amendment No. 8, 41 to W3F1I-2004-0121 Page 3 of 3 ADMINISTRATIVE CONTROLS 6t 6.9.1.6 RToutip,6 reporgFof ope~ratjg staftfigs 6.9.1.7 The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted before May I 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 (1) the ODCM and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I tol 0 CFR Part 50.

WATERFORD - UNIT 3 6-18 AMENDMENT NO.-68,48&-

Attachment 3 To W3FI -2004-0121 List of Regulatory Commitments to W3F1I-2004-0121 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE

.(Ceck one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy is making a regulatory commitment to X 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)).

W3Fl -2004-0121