ML20058N226

Proposed Change 115 to License DPR-46 Ts,Extending Reporting Frequencies of Semiannual Radioactive Matls Release Rept from Semiannual to Annual & Annual Design Change Rept from Annual to Annually or Along W/Usar Updates

ML20058N226
Person / Time
Site:	Cooper
Issue date:	12/10/1993
From:	Horn G NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058N229	List: ML20058N226 ML20058N232
References
NSD930976, NUDOCS 9312210296
Download: ML20058N226 (8)

Text

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GENERAL OFFICE j '- . .@

P.O. BOX '99. COLUMBUS, NEBRASKA 68602-0499

} TELEPHONE (402) 564-8561 r S Nebraska Public Power Distr *ct -

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NSD930976 December 10, 1993 U. S. Nuclear Regulatory Commission Document Control Desk f

Washington, DC 20555

Subject:

Proposed Change No. 115 to Technical Specifications

" Extending Reporting Frequencies of 10CFR50.36 (a) and 10CFR50.59(b)"

Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 Gentlemen:

In accordance with the applicable provision specified in 10 CFR 50, the Nebraska Public Power District requests that the Cooper Nuclear Station (CNS) Technical Specifications be revised as specified in the attachment. This proposed change extends the reporting frequencies of the Semiannual Radioactive Materials Release Report 10CFR50.36(a) from semiannual to annual, and the Annual Design Change Report 10CFR50.59(b) from annual to annually or along with the Updated Safety Analysis Report (USAR) updates as required by 10CFR50.71(e) . These changes are being made as a result of new NRC rulemaking as published in the Federal Register (57FR39353) dated August 31, 1992. This proposed Technical Specification change will make the CNS Technical Specifications consistent with the new regulations.

The attachment contains a description of the proposed changes, the attendan,t 10CFR50.92 evaluation, and the applicable revised Technical Specification Pages in both final and marked up forms for your convenience. This proposed change has been reviewed by the necessary Safety Review Committees and incorporates all amendments to the CNS Facility Operating License through Amendment 165 issued July 16, 1993.

By copy of this letter and attachment the appropriate State of Nebraska official is being notified in accordance with 10CFR50.91(b) (1) . Copies to the NRC Region IV Office and CNS NRC Resident Inspector are also being sent in accordance with 10CFR50.4 (b) (2) .

Shou. yo have any questions or require additional information, please contact me.

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NSD930976 Page 2 December 10, 1993 STATE OF NEBRASKA )

)ss NEMAHA COUNTY )

G. R. Horn, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebraska Public Power District; and that the statements contained _.crein ar true to the best of his knowledge and belief.

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'G. R. Horn Subscribed in my presence and sworn to before me this day of 36C , 1993.

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. 1 REVISED TECHNICAL SPECIFICATION PAGES FOR EXTENSION OF 10CFR50.36(a) & 10CFR50.59(b) REPORTING FREQUENCIES Revised oaaes iv - Table of Contents 216n 216a12 216s 230 216a1 231 216a3 232 216a9 235b INTRODUCTION As discussed below, the Nebraska Public Power District (DISTRICT) hereby requests that the Cooper Nuclear Station (CNS) Technical Specifications be revised, as aroposed herein. The proposed changes implement the guidance provided in Federal legister (57 FR 39353) dated August 31, 1992, New Revised Rulemaking " Reducing the Regulatory Burden on Nuclear Licensees."

DISCUSSION The proposed amendment will revise the Cooper Nuclear Station (CNS) Technical Specifications sections 3/4.21 " Environmental / Radiological Effluents", and 6.5

" Station Reporting Requirements" to change the frequency of the reporting period of the " Semiannual Radioactive Materials Release Report" from semiannual to annual and to extend the reporting frequency of the Annual Design Change Report from an annual submittal to annually or along with the Updated Safety Analysis Report (USAR) updates required by 10CFR50.71(e).

Throughout section 3/4.21 the reference to Semiannual Radioactive Materials Release Report is proposed to be changed to annual, and for consistency the term Radioactive Materials Release Report will be used. Additionally. Technical Specification 6.5.1.F. the report submission date, would be revised from 60 days after January 1 and July 1 of each year to May 1 of each year. Moving the submittal date of this report to May 1 of eacii year will make this Specification consistent with the existing reporting requirements of the Annual Radioactive Environmental Report. Also, by moving the submittal date of this report to May 1 of each year the footnote allowing veroal extension from the NRC Project Manager of this report will be deleted. Furthermore. Technical Specification 6.5.1.C.2, would be amended to state that the 10CFR50.59(b) report can be submitted annually or along with the USAR updates as required by 10CFR50.71(e).

As published in the Federal register on August 31, 1992 (57 FR 39353), the NRC has amended both 10CFR50.36(a) and 10CFR50.59(b) to reduce the required frequency !

of reporting the quantity of each principal radionuclide released to unrestricted l areas in gaseous effluents from semiannual to annual, and reduce the frequency l

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NSD930976 Attachment Page 2 of 5 of the reports for facility changes, tests and experiments, under 10CFR50.59(b) to conform with the new reporting requirements for the USAR 10CFR50.71(e).

Additionally, as administrative changes, all defined terms on the affected pages are being capitalized.

DESCRIPTION OF CHANGES As documented in the Federal Register (57 FR 39353), 10CFR50.36(a) and 10CFR50.59(b) were amended to reduce the Regulatory burden on Nuclear Licensees.

Therefore, to be consistent with the revised regulations discussed in FR 39353, the DISTRICT requests the following CNS Technical Specification revisions to sections 3/4.21 and 6.5 as described below. A mark-up of the affected CNS Technical Specification pages are provided in A)pendix A, and the new affected CNS Technical S)ecification pages are providec in Appendix B. The specific changes proposec, to the CNS Technical Specifications are detailed below.

Page iv -

Table of Contents, revise Reporting Requirement 6.5.1.F to

, " Annual Radioactive Materials Release Report."

Page 216n -

In Specification 3.21.A.1.c. capitalize the word "0PERABLE",

this is a defined term.

Revise Specification 3.21.A.1.d. to read " Annual Radioactive Materials Release Report."

l Page 216s -

In Specification 3.21.A.2.b capitalize the word "IMMEDIATELY",

this is a defined term.

In Specification 3.21.A.2.c. capitalize the word "0PERABLE",

this is a defined term.

Revise Specification 3.21.A.2.d. to read " Annual Radioactive Materials Release Report."

Page 216a1 -

Revise Note (7) for Table 4.21.B.I. to read " Annual Radioactive Materials Release Report."

Page 216a3 - Revise Specification 3.21.B.3.c. to read " Annual Radioactive Materials Release Report."

Page 216a9 - Revise Note (6) for Table 4.21.C.1. to read " Annual Radioactive Materials Release Report."

Page 216a12 - Revise Specification 4.21.E.3, to read " Annual Radioactive Materials Release Report."

Page 230 -

Revise Specification 6.5.1.C. Annual Reports, by adding reference to specification 6.5.1.C.4, and changing submittal date of report to May 1 of each year.

, ,8 NSD930976 Attachment Page 3 of 5 Page 231 -

Specification 6.5.1.C.2, add sentence: "This report may be submitted annually or along with the Updated Safety Analysis Report (USAR) updates as required by 10CFR50.71(e)."

Page 232 -

Revise Specification 6.5.1.F. to read " Annual Radioactive Materials Release Report."

Revise Specification 6.5.1.F.1, to read "A report of radioactive materials released from the Station during the preceding year shall be submitted to the NRC by May 1 of each year." Also remove the asterisk at the end of this sentence.

Revise Specification 6.5.1.F.2, to read "The Annual Radioactive Materials Release Report. . ."

Revise Specification 6.5.1.F.2.c. to read "A summary of meteorological data collected during the year shall be included in the Annual Report submitted by May 1 of each year."

Remove the footnote (explanation of the asterisk) at the bottom of this page. This caveat will no longer be required with moving the submittal date of the report to May 1 of each year.

Page 235b -

Revise Specification 6.6.2.A. to read " Annual Radioactive Materials Release Report..."

Revise Specification 6.7.2.A. to read " Annual Radioactive Materials Release Report. . ."

SIGNIFICANT HAZARDS DETERMINATION 10 CFR 50.91(a)(1), requires that licensee requests for operating license amendments be accompanied by an evaluation of significant hazards aosed by the issuance of the amendment. This evaluation is to be performed wit 1 respect to the criteria given in 10 CFR 50.92(c). The following analysis meets these requirements.

Evaluation of this Amendment with Respect to 10 CFR 50.92 The enclosed revision to CNS Technical Specifications (Proposed Change No.115) is judged to involve no significant hazards based on the following:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Evaluation The proposed changes are administrative in nature and make the Cooper Nuclear Station (CNS) Technical Specifications (T/S) consistent with amended regulations of 10CFR50.36(a), and 10CFR50.59(b) by reducing the submittal frequency of certain reports to the NRC. The proposed revisions i

NSD930976 Attachment Page 4 of 5 do not involve any change to plant design, plant operation, or configuration of any plant equipment that is used to mitigate the consequences of an accident previously evaluated. Also, the proposed changes do not alter the conditions or assumptions in any of the Updated Safety Analysis Report (USAR) accident analyses. Since the USAR accident analyses remain bounding, the radiological consequences previously evaluated are not adversely affected by the proposed changes. As administrative changes, all defined terms on the affected pages have been capitalized. Therefor e, it can be concluded that the proposed changes do not involve a significur,t increase in the probability or consequences of ,

an accident previously evaluated.  !

l 3 2. Does the proposed License Amendment create the possibility of a new or i different kind of accident from any accident previously evaluated? )

Evaluation f

The proposed changes are administrative in nature and mne the CNS T/S consistent with amended regulations of 10CFR50.36(a), and 10CFR50.59(b) by reducing the submittal frequency of certain reports to the NRC. The proposed revisions do not involve any change to plant design, plant operation, or configuration of any plant equipment that is used to mitigate the consequences of an accident previously evaluated.

Accordingly, no new failure modes have been created for any plant system or component important to safety nor has any new limiting failure been identified as a result of the proposed changes. Also, there will be no change in the types or increase in the amount of effluents released offsite. As administrative changes, all defined terms on the affected pages have been capitalized. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change create a significant reduction in the margin of safety?

i Evaluation The proposed changes are administrative in nature and do not adversely impact the alant's ability to meet applicable regulatory requirements related to liquid or gaseous effluents, and solid waste releases. The proposed changes do not alter any administrative controls over radioactive effluents, nor do the proposed changes involve any physical alterations to the plant with respect to radioactive effluents. These changes do not affect the meaning, anlication, and function of the T/S requirements.

The proposed change wi' reduce the administrative burden of NRC reporting without reducing the protection for public health and safety. As administrative changes, all defined terms on the affected pages have been capitalized. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

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NSD930976 Attachment Page 5 of 5 ADDITIONAL BASIS FOR N0 SIGNIFICANT HAZAPsDS DETERMINATION The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7744). The examples include: (vii) A change to conform a license to changes in regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations. The proposed changes to the CNS T/S regarding reporting frequencies to make the CNS T/S more consistent with the new amended regulations, are within the scope of this example.

CONCLUSION The District has evaluated the proposed changes described above against the criteria of 10CFR50.92(c) in accordance with the requirements of 10CFR50.91(a)(1). This evaluation has determined that Proposed Change No.115 to the CNS Technical Specifications will not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility for a new or different kind of accident from any accident previously evaluated: or 3) create a significant reduction in the margin of safety. Therefore, the District requests NRC approval of proposed change No.115 to the CNS Technical Specifications.

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4 ,4 APPENDIX "A"