ML043620323

Request for Amendment to Delete Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports, Using the Consolidated Line Item Improvement Process

ML043620323
Person / Time
Site:	Palo Verde
Issue date:	12/16/2004
From:	Overbeck G Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05193-GRO/SAB/GAM
Download: ML043620323 (17)

Text

ZJAFS A subsidiary ofPinnacle JIest Capital Corporation 10 CFR 50.90 Gregg R.Overbeck Mail Station 7602 Palo Verde Nuclear Senior Vice President TEL (623) 393-5148 P.O. Box 52034 Generating Station Nuclear FAX (623) 393-6077 Phoenix, AZ 85072-2034 102-05193-GRO/SAB/GAM December 16, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Request for Amendment to Delete Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports, Using the Consolidated Line Item Improvement Process (CLIIP)

Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests to amend Operating Licenses NPF-41, NPF-51, and NPF-74 for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3, respectively.

The proposed License amendment would delete the requirements in Technical Specification (TS) 5.6.1 for an annual report on occupational radiation exposures and TS 5.6.4 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, except for a minor editorial section numbering deviation. 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). provides a notarized affidavit required by 10 CFR 50.30. Enclosure 2 provides a description of the proposed changes and confirmation of applicability.

APS requests approval of the proposed amendment by March 31, 2005, to avoid the need to prepare the TS 5.6.1 radiation exposure report which is being deleted by this change and would otherwise be due by April 30, 2005. An implementation period of 90 days is also requested.

4oD

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Request for Amendment to Delete Technical Specifications 5.6.1 and 5.6.4 Page 2 In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and the Offsite Safety Review Committee have reviewed and approved this proposed amendment. By copy of this letter, this submittal is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1).

A commitment associated with this amendment request is provided in Attachment A3.

If you have any questions, please contact Thomas N. Weber at (623) 393-5764.

Sincerely, GROISAB/GAM

Enclosures:

1 Notarized affidavit 2 Arizona Public Service Company's Evaluation of the Proposed Change(s)

Attachments:

Al Proposed Technical Specification Changes (mark-up)

A2 Proposed Technical Specification pages (retyped)

A3 Regulatory Commitment A4 Draft Technical Requirements Manual Change cc: B. S. Mallett NRC Region IV Regional Administrator M. B. Fields NRC NRR Project Manager N. L. Salgado NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

STATE OF ARIZONA )

) ss.

COUNTY OF MARICOPA )

1,Gregg R. Overbeck, represent that I am Senior Vice President - Nuclear, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, and that to the best of my knowledge and belief, the statements made therein are true and correct.

Gr R. Overbeck Sworn To Before Me This Day Of ta P & /\ 2004.

,; WMA LYNN ERGSHt Notary )

Nolary Pui~c - Ahkono Modcopa County My Comm. Expre JuI14,2007

__1 Notary Commission Stamp

ENCLOSURE 2 ARIZONA PUBLIC SERVICE COMPANY'S EVALUATION OF THE PROPOSED CHANGE

Subject:

Request for Amendment to Delete Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports, Using the Consolidated Line Item Improvement Process (CLIIP)

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria 5.3 Precedent 5.4 Verification and Commitments

7.0 REFERENCES

I

Enclosure 2 APS' Evaluation of Proposed Change

1.0 DESCRIPTION

This letter is a request from Arizona Public Service Company (APS) to amend Operating Licenses NPF-41, NPF-51, and NPF-74 for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3, respectively.

The proposed License amendment deletes the requirements in Technical Specification (TS) 5.6.1 for an annual report on occupational radiation exposures and TS 5.6.4 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, except for a minor editorial section numbering deviation. 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 PROPOSED CHANGE

Consistent with the NRC-approved Revision 1of TSTF-369, the proposed TS changes include:

TS 5.6.1 Occupational Radiation Exposure Report Deleted TS 5.6.4 Monthly Operating Reports Deleted This proposed change would allow the section numbers for TS 5.6.1 and 5.6.4 to remain in the TS, unused, and not renumber the sections as in TSTF-369. This minor editorial deviation from TSTF-369 would eliminate the need to revise all other TS and site document references to the other TS sections which would otherwise need to be renumbered, and would thus reduce the potential for errors.

As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, APS is proposing to adopt a part of NRC-approved Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." Specifically, PVNGS TS 5.6.4 includes a requirement to include in the monthly operating reports any challenges to shutdown cooling system suction line relief valves or pressurizer 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, except for the following:

1

Enclosure 2 APS' Evaluation of Proposed Change The PVNGS design does not use power operated relief valves (PORVs). At PVNGS, shutdown cooling system suction line relief valves are used to provide the low temperature overpressure protection function required by TS 3.4.13, "Low Temperature Overpressure Protection (LTOP) System," instead of PORVs specified in the Combustion Engineering Improved Standard Technical Specifications (NUREG-1432) Section 3.4.12, "Low Temperature Overpressure Protection (LTOP) System." Therefore, the TSTF-258 provision to delete the TS 5.6.4 requirement to report challenges to the PORVs applies at PVNGS to the TS 5.6.4 requirement to report challenges to the shutdown cooling system suction line relief valves.

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 TECHNICAL ANALYSIS

APS 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. APS has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to PVNGS Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the PVNGS Units 1, 2, and 3 TS.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration APS has reviewed the proposed no significant hazards consideration determination published on June 23, 2004 (69 FR 35067) as part of the CLIIP. APS has concluded that the proposed determination presented in the notice is applicable to PVNGS Units 1, 2, and 3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatorv Requirements/Criteria 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.

2

Enclosure 2 APS' Evaluation of Proposed Change 5.3 Precedent This application is being made in accordance with the CLIIP. APS is not proposing variations or deviations from the TS changes described in TSTF-369 (except for section numbering differences) or the NRC staffs model SE published on June 23, 2004 (69 FR 35067).

APS is not proposing variations or deviations from the TS changes described in the limited portion of TSTF-258 included with the CLIIP except for the following:

The PVNGS design does not use power operated relief valves (PORVs). At PVNGS, shutdown cooling system suction line relief valves are used to provide the low temperature overpressure protection function required by TS 3.4.13, "Low Temperature Overpressure Protection (LTOP) System," instead of PORVs specified in the Combustion Engineering Improved Standard Technical Specifications (NUREG-1432) Section 3.4.12, "Low Temperature Overpressure Protection (LTOP) System." Therefore, the TSTF-258 provision to delete the TS 5.6.4 requirement to report challenges to the PORVs applies at PVNGS to the TS 5.6.4 requirement to report challenges to the shutdown cooling system suction line relief valves.

5.4 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, APS is making the following regulatory commitment:

APS commits to add the following reporting criteria to the Palo Verde Technical Requirements Manual (TRM) upon implementation of a license amendment to delete the TS requirement for the monthly operating reports:

Provide to the NRC, using an industry database such as the Consolidated Data Entry program (CDE), 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.

Adding the reporting criteria to the TRM upon implementation of a license amendment to delete the TS requirement for the monthly operating reports will ensure that there will be no 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 draft TRM change is provided in Attachment A4.

The PVNGS site does not have different reactor types, and does not have both operating and shutdown reactors.

3

Enclosure 2 APS' Evaluation of Proposed Change

6.0 ENVIRONMENTAL CONSIDERATION

APS has reviewed the environmental evaluation included in the model SE published on June 23, 2004 (69 FR 35067) as part of the CLIIP. APS has concluded that the staffs findings presented in that evaluation are applicable to PVNGS Units 1, 2, and 3 and the evaluation is hereby incorporated by reference for this application.

7.0 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).

4

Attachment Al Proposed Technical Specification Changes (mark-up)

Pages:

5.6-1 5.6-2

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 Ocupational RadiatiR- Exp4eupe DRere-t WOTE A single submittal may be madc for a multiple unit station. Thc submittal should combinc sections common to all units at the statiqnn A tabulation on an annual basis of thc number of station. utility.

and other pcrsonncl (includingcontrpacors) rccciing xo uesurcs

- 100 mrcm/yr and thcir asrociated man rem cxposurc according to and job functiones

-ork (c.g.. rcactor operationes and surveillance, insepyline inspertieRn rFetine RaintennRa 1nrn RaiptenoRaR

+at * -RdS efuemlingn Thir_ +ShupPnI-nnl-mnts the requir-emnts of 10 rFR 20.2206. The dose assigRnmnts to various dut functions may be estimated based on pock d simeter.

thermoluminescent dosimeter (TLT). or film hadne measurements.

Sma11 exposures totalling c 2 of the individulr total dose need not be accounted for. In the aggregate, at least 80% of the total w'hole body dose received from cxternal sources sheould hbassigned to specificmor l:ork funcin ons. The report shall be sumitted byw ,Anril 30 of oeah year.

5.6.2 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 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 shal be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM). and in10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3.

and IV.C.

(continued)

PALO VERDE UNITS 1,2.3 5.6-1 AMENDMENT NO. 44-- 120

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

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 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

---

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station: however, for units with separate radwaste system, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit shall be submitted 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 and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I.Section IV.B.1.

5.6.4 Deleted Mnethly OperAating PRprts Routine reports of operating Gtatistic: and shutdown experiencz.

including doeumcntation of all challenges to the shutdowln cooling system suction line relief valves or pressurizer safety valves, shall bc submitted on a monthly basis no later than thc 15th of each month following the ealendar month covered by the rcport.

(continued)

PALO VERDE UNIT 1 AMENDMENT NO. 42d. 122 PALO VERDE UNITS 2.3 5.6-2 AMENDMENT NO. Ad-o. 121

Attachment A2 Proposed Technical Specification Changes (retyped)

Pages:

5.6-1 5.6-2

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 Del eted 5.6.2 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 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 Calculation Manual (ODCM), and in 10 CFR 50. Appendix I. Sections IV.B.2. IV.B.3.

and IV.C.

(continued)

PALO VERDE UNITS 1.2,3 5.6-1 AMENDMENT NO. 424,

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

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 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

---

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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station: however, for units with separate radwaste system, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit shall be submitted 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 and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I.Section IV.B.1.

5.6.4 Deleted (continued)

PALO VERDE UNIT 1 AMENDMENT NO. 4an, PALO VERDE UNITS 2,3 5.6-2 AMENDMENT NO. 4-24,

Attachment A3 Regulatory Commitment The following table identifies those actions committed to by APS in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Thomas N.Weber at (623) 393-5764.

REGULATORY COMMITMENT DUE DATE APS commits to add the following reporting criteria to the Upon implementation of a Palo Verde Technical Requirements Manual upon license amendment to implementation of a license amendment to delete the delete the Technical Technical Secification requirement for the monthly Secification requirement for operating report: the monthly operating reports.

Provide to the NRC, using an industry database such as the Consolidated Data Entry program (CDE), 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.

Attachment A4 Draft Technical Requirements Manual Change Page:

T5.0.600-2

Reporting Requirements TRM 5.0.600 Reporting Requirements (continued)

b. The startup report shall address the tests that are performed to demonstrate that the unit operating conditions affected by a change, as defined in T5.0.600.2.a. remain within the design predictions and specifications for that change. The startup report shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with the design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described.

c. Startup reports shall be submitted within (1)90 days following completion of the startup test program, (2)90 days following resumption or commencement of commercial operation, or (3)9 months following initial criticality. whichever is earliest.

If the startup Report does not cover all three events (i.e..

initial criticality, completion of startup test program. and ADD NEW resumption or commencement of commercial operation)

SECTION supplementary reports shall be submitted at least every 3 months until all three events have been completed.

T5.O.6O.3, Operating bataReporting; '

,Provide ito the NRC, us'ing an industiry'database'such as the't' Consolidated Data"Entry program, the operating data (for each n Scalendar month) that is described' inGeneric' Letter:97,O2,'

!"Revised'Contents of'the Monthly Operating Report," by the' 6last',-

'day'of 'the month following the end of each calendar quarter.

PALO VERDE UNITS 1. 2. 3 T5.0.600-2 Rev 22 3/7/03