GO2-04-165, License Amendment Request - Removal of the Monthly Operating Report and the Occupational Radiation Exposure Report from Technical Specification Using the Consolidated Line Item Improvement Process

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License Amendment Request - Removal of the Monthly Operating Report and the Occupational Radiation Exposure Report from Technical Specification Using the Consolidated Line Item Improvement Process
ML042880427
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 09/27/2004
From: Webring R
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-04-165
Download: ML042880427 (17)
v • d • e


Text

aN ENERGY Peoplo NORTHWEST

  • Vision -Solutions P.O. Box 968
  • Richland, WA
  • 99352-0968 September 27, 2004 G02-04-165 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Energy Northwest is submitting a request for an amendment to the technical specifications (TS) for Columbia Generating Station.

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 Register on June 23, 2004 (69 FR 35067) 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. Attachment 3 provides a summary of the regulatory commitment made in this submittal.

REMOVAL OF THE MONTLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Page 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Washington State Official.

Should you have any questions or require additional information regarding this matter, please contact Mr. DW Coleman, Regulatory Programs Manager, at (509) 377-4342.

Respectfully, RL Webring Vice President, Nuclear Generation Mail Drop PE04 Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (markup)
3. Regulatory Commitment cc: BS Mallett - NRC RIV WA Macon - NRC NRR NRC Sr. Resident Inspector - 988C RN Sherman - BPA/1399 TC Poindexter - Winston & Strawn JO Luce - EFSEC RR Cowley - WDOH

STATE OF WASHINGTON)

Subject:

Technical Specification

) Removal of the Monthly COUNTY OF BENTON Operating Report and Occupational Radiation Exposure Report 1,RL Webring, being duly sworn, subscribe to and say that I am the Vice President, Nuclear Generation for ENERGY NORTHWEST, the applicant herein; that I have the full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief, the statements made in it are true.

DATE '91 ,2004 RL Webrirtg Vice President, Nuclear Generation On this date personally appeared before me RL Webring, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act and deed for the uses and purposes herein mentioned.

GIVEN under my hand and seal this 0 / day of. 4~er 2004.

,otary Public in and for the STATE OF WASHINGTON Residing at Gaevlm' My Commission Expires_

REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Page 1 of 3 Description and Assessment

1.0 INTRODUCTION

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.

The availability of this technical specification improvement was announced in the Federal Reqister 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 5.6.1 Occupational Radiation Exposure Report Deleted TS 5.6.4 Monthly Operating Reports Deleted As addressed in the safety evaluation published in the Notice of Availability for TSTF-369, the removal of TS 5.6.1 and TS 5.6.4 resulted in various editorial and formatting changes such as the renumbering of TS sections. These changes reflect the renumbering of TS-sections but do not revise technical or administrative requirements.

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 is adequately addressed by the NRC Notice of Availability published on June 23, 2004 (69 FR 35067) and TSTF-369.

REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Page 2 of 3

5.0 TECHNICAL ANALYSIS

Energy Northwest 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. Energy Northwest has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Columbia Generating Station and justify this amendment for the incorporation of the changes to the Columbia Generating Station 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 Commitment As discussed in the model SE published in the Federal Register on June 23, 2004 (69 FR 35067) for this TS improvement, Energy Northwest is making the following regulatory commitment:

Energy Northwest is making a regulatory commitment to provide to the NRC using the industry, Consolidated Data Entry (CDE) 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 21st of the month following the end of the calendar quarter.

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

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

REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Page 3 of 3 9.0 PRECEDENT This application is being made in accordance with the CLIIP. Energy Northwest is not proposing variations or deviations from the TS changes described in TSTF-369 or the NRC staffs model SE published on June 23, 2004 (69 FR 35067).

10.0 REFERENCE 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).

REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

PROPOSED TECHNICAL SPECIFICATION CHANGES (Markup)

Pages 1.1-2 5.5-1 5.6-1 5.6-2 5.6-3 5.6-4 5.6-5 3.3.3.1-1 3.3.3.1-2

Definitions 1.1 1.1 Definitions (continued)

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarm, interlock, display, and trip functions, and channel failure trips. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps so that the entire channel is tested.

CORE ALTERATION CORE ALTERATION shall be the movement of any fuel, sources, or reactivity control components within the reactor vessel with the vessel head removed and fuel in the vessel. The following exceptions are not considered to be CORE ALTERATIONS:

a. Movement of source range monitors, local power range monitors, intermediate range monitors, traversing incore probes, or special movable detectors (including undervessel replacement);

and

b. Control rod movement, provided there are no fuel assemblies in the associated core cell.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific limits shall be determined for each reload cycle in accordance with Specification 5.6,/ Plantt?3 operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I-131, I-132, 1-133, I-134, and I-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for (continued)

Columbia Generating Station 1.1- 2 Amendment No. +4-9 1691

Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.

5.5.1 Offsite Dose Calculation Manual (ODCM)

a. The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and
b. The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release reports required by Specification 5.6 and Specification 5.6
c. Licensee initiated c ges to the ODCM:
1. Shall be documented and records of reviews performed shall be retained. This documentation shall contain:

(a) Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s), and (b) A determination that the change(s) maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations;

2. Shall become effective after review and acceptance by the Plant Operations Committee and the approval of the Plant General Manager; and (continued)

Columbia Generating Station 5.5-1I Amendment No. +4-9 1691

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.

Occupational Radiation ExDosure ReDort tabulation on an annual basis of the number of stat utility, an her personnel (including contractors) for ets monitoring was per med, receiving an annual deep dose uivalent of

> 100 mremsal the associated collectivi e-eep dose equivalent (reported in man- ) according to and job functions (e.g.,

reactor operations an urveill e, inservice inspection, routine maintenance, special main ce Cdescribe maintenance), waste processing, and refuel . tabulation supplements the requirements of 10 20.2206. dose assignments to various duty functions y be estimated based olectronic or pocket dosimeter ermoluminescent dosimeter (TLD or film badge measu ents. Small exposures totalling < 20% o he individual t dose need not be accounted for. In the aggreg at least 80% of the total whole body dose received from external s ces should be assigned to specific major work functions. The rep i,~~h 1 hp ... mi tp ... ,,,,,, 0... nf P;r

,rI 5.6.te O Annual Radiological Environmental Oneratinq 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 Calculation Manual (ODCM), 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 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 (continued)

Columbia Generating Station 5.6-1 Amendment No. +49 1691

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6 $ W Annual Radiological Environmental Operating Report (continued) 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.

5.6.1 X Radioactive Effluent Release Report 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 the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

b. .__ Month Oeratinq Reports Routine report so and shutdown experience shal ed on a monthly basis no the 15th of each month following the calendar month covered hy thF r_

5.6 ,V 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 APLHGR for Specification 3.2.1;
2. The MCPR for Specification 3.2.2;
3. The LHGR for Specification 3.2.3; and
4. LCO 3.3.1.3, "Oscillation Power Range Monitor (OPRM)

Instrumentation."

(continued)

Columbia Generating Station 5.6-2 Amendment No. 149,169,171- 182

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6%/ CORE OPERATING LIMITS REPORT (COLR) (continued) 0 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. XN-NF-81-58(P)(A), "RODEX2 Fuel Rod Thermal-Mechanical Response Evaluation Model," Exxon Nuclear Company
2. XN-NF-85-67(P)(A), "Generic Mechanical Design for Exxon Nuclear Jet Pump BWR Reload Fuel," Exxon Nuclear Company
3. EMF-85-74(P) Supplement 1(P)(A) and Supplement 2(P)(A),

"RODEX2A (BWR) Fuel Rod Thermal-Mechanical Evaluation Model," Siemens Power Corporation

4. ANF-89-98(P)(A), "Generic Mechanical Design Criteria for BWR Fuel Designs," Advanced Nuclear Fuels Corporation
5. XN-NF-80-19(P)(A) Volume 1, "Exxon Nuclear Methodology for Boiling Water Reactors - Neutronic Methods for Design and Analysis," Exxon Nuclear Company
6. XN-NF-80-19(P)(A) Volume 4, "Exxon Nuclear Methodology for Boiling Water Reactors: Application of the ENC Methodology to BWR Reloads," Exxon Nuclear Company
7. EMF-2158(P)(A), "Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4/MICROBURN-B2," Siemens Power Corporation
8. XN-NF-80-19(P)(A) Volume 3, "Exxon Nuclear Methodology for Boiling Water Reactors, THERMEX: Thermal Limits Methodology Summary Description," Exxon Nuclear Company
9. XN-NF-84-105(P)(A) Volume 1, "XCOBRA-T: A Computer Code for BWR Transient Thermal-Hydraulic Core Analysis,"

Exxon Nuclear Company (continued)

Columbia Generating Station 5.6-3 Amendment No. A+d 185 149, 154,15E, 169s,

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6 Y CORE OPERATING LIMITS REPORT (COLR) (continued) 0 10. ANF-524(P)(A), "ANF Critical Power Methodology for Boiling Water Reactors," Advanced Nuclear Fuels Corporation

11. ANF-913(P)(A) Volume 1, "COTRANSA2: A Computer Program for Boiling Water Reactor Transient Analysis," Advanced Nuclear Fuels Corporation
12. ANF-1358(P)(A) "The Loss of Feedwater Heating Transient in Boiling Water Reactors," Advanced Nuclear Fuels Corporation
13. EMF-2209CP)(A), "SPCB Critical Power Correlation," Siemens Power Corporation
14. EMF-2245(P)(A), "Application of Siemens Power Corporation's Critical Power Correlations to Co-Resident Fuel," Siemens Power Corporation
15. EMF-2361(P)(A), "EXEM BWR-2000 ECCS Evaluation Model,"

Framatome ANP Richland

16. EMF-2292(P)(A), "ATRIUM' -10: Appendix K Spray Heat Transfer Coefficients," Siemens Power Corporation
17. EMF-CC-074(P)(A) Volume 4, "BWR Stability Analysis-Assessment of STAIF with Input from MICROBURN-B2," Siemens Power Corporation
18. CENPD-300-P-A, "Reference Safety Report for Boiling Water Reactor Reload Fuel," ABB Combustion Engineering Nuclear Operations
19. NEDO-32465-A, "BWR Owners' Group Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology and Reload Applications" (continued)

Columbia Generating Station 5.6 -4 Amendment No. 44+ 185 i49,154,158,169,

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.y n CORE OPERATING LIMITS REPORT (COLR) (continued)

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6 / Post Accident Monitoring (PAM) Instrumentation ReDort When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

Columbia Generating Station 5.6-5 Amendment No. +49-i54-169 1851

PAM Instrumentation 3.3.3.1 3.3 INSTRUMENTATION 3.3.3.1 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3.1 The PAM instrumentation for each Function in Table 3.3.3.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

NOTES------------------------------------

1. LCO 3.0.4 is not applicable.
2. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable. status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.fZ not met. a C. One or more Functions C.1 Restore all but one 7 days with two or more required channel to required channels OPERABLE status.

inoperable.

(continued)

Columbia Generating Station 3.3.3. 1 -1 Amendment No. 4-4-9 1691

PAM Instrumentation 3.3.3.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

0. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.3.1-1 for not met. the channel.

E. As required by E.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Required Action D.1 and referenced in Table 3.3.3.1-1.

F. As required by F.1 Initiate action in Immediately Required Action D.1 accordance with and referenced in Specification 5.6./'.

Table 3.3.3.1-1.

Columbia Generating Station 3.3.3. 1-2 Amendment No. +4-9 1691

REMOVAL OF THE MONTHLY OPERATING REPORT AND THE OCCUPATIONAL RADIATION EXPOSURE REPORT FROM TECHNICAL SPECIFICATION USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

LIST OF REGULATORY COMMITMENTS The following table identifies the action committed to by Columbia Generating Station 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 DW Coleman at (509) 377-4342.

COMMITMENT DUE DATE Columbia Generating Station will provide Due the 21st of the month following the the operating data (for each calendar end of the calendar quarter, beginning month) that is described in Generic Letter after the amendment is approved.

97-02, "Revised Contents of the Monthly Operating Report,' by the 21S't of the month following the end of the calendar quarter using the industry, Consolidated Data Entry (CDE) database.

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