ML063620444

Comment (3) of George G. Yates on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical S

ML063620444
Person / Time
Site:	Callaway
Issue date:	12/20/2006
From:	Yates G AmerenUE
To:	Rulemaking, Directives, and Editing Branch
References
71FR67170 00003
Download: ML063620444 (9)

Text

C-Union Electric PO Box"00 Callaway Plant Fulton, MO665251 J December 20, 2006 CDm K9 Chief, Rulemaking, Directives, and Editing Branch Division of Administrative Services Office of Administration Mail Stop: T-6 D59 U.S. Nuclear Regulatory Commnission Washington, DC 20555-000 1 Comments on Federal, Register Notice 71 FR 67170-67175, dated November 20, 2006, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and W4m ~

Revision to Reactor Coolant System Specific Activity Technical Specification; Babcock and Wilcox'Pressurized Water Reactors, Westinghouse Pressurized Water Reactors, Combustion Engineering Pressurized Water Reactors YE Usina the Consorlidated Line Item Improvement Proc~ess'"

AmerenUE submits the following comments for consideration on the subject CLIIP Notice for Comment:

1. 71 FR 67171: There is currently one Technical Specification (TS) 3.4.16 limit on RCS gross specific activity, not "limits." The single limit is I00/E-Bar in all 3 affected STS NUREGs. There are two places on this page that refer to limits (plural). This page should refer to limit (singular).

2. 71 FR 67172, Model SE, Section 2.0: Correct the title of TID 14844. "Reactor" is singular in the title.

3.* 71 FR 67173, Model SE Section 3. 1.1: The list of Dose Conversion Factor (DCF) references should be bracketed since this change will be subject to plant-specific considerations. The optional DCF reference included in TSTF-490, and discussed in the traveler's justification section 3.0 (paragraph 2, lines 4-9), for alternate source term plants should be included here as follows:

or [Committed Dose Equivalent (CDE) -or Committed Effective- Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.]1"

4. 71 FR 67173, Model SE Section 3.1.2: All noble gas isotope lists and DCF citations should be bracketed since these changes are subject to plant-specific considerations. The 2nd paragraph is missing a forward slash mark between the words "and' and "or" in the text "by tritium and corrosion and or activation products ....".

5. 71 FR 67174, Model SE, Section 3. 1.33: The discussion on revised Required Action A.1I should be relocated to Model SE Section 3.1.5 that discusses the changes to TS 3.4.16 Condition A.

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6. 71 FR 67174, Model SE Section 3.1.6: This section states that Condition "C" is replaced with a new Condition "B."' This is only true for the B&W and CE STS NUREGs (1430 and 1432). It is not true for the Westinghouse STS NUREG- 143 1, and it should be noted that the Westinghouse plants developed this traveler for submittal to the NRC. This section should state that "TS 3.4.16 Condition B [in NUJREG-143 1; C in NUREG-1430 and NUREG-1432] is replaced with a new Condition B for DEX not within limits."

Model SE Section 3.1.6 should also discuss the addition of the LCO 3.0.4.c Note to revised Required.

Action B. 1, consistent with the Model Application, Enclosure 1, Section 2.0, item C on 71 FR 67172.

Suggested wording that could be used for this purpose is as follows:

"A Note is also added to the revised Required Action B. I that states LCO 3.0.4.c is applicable.

This Note would allow entry into a Mode or other specified condition in the LCO Applicability when LCO 3.4.16 is not being met and is the same Note that is currently stated for Required Actions A. I and A.2. The proposed Note would allow entry into the applicable Modes when the DEX is not within its limit; in other words, the plant could go up in the Modes from Mode 4 to Mode 1 (power operation) while the DEX limit is exceeded and the DEX is being restored to within its limit. This Mode change allowance is acceptable due to the significant conservatism incorporated into the DEX specific activity limit, the low probability of an event occurring which is limiting due to exceeding the DEX specific activity limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to, power operation."

7. 71 FR 67174, Model SE, Section 3.1.8: This section incorrectly states that revised SR 3.4.16.1 has a new LCO 3.0.4.c Note. It should state that SR 3.4.16.1 has a new performance modifying Note that reads: "Only required to be performed in MODE 1L" The application of this style of Note is discussed in Example .1.4-5 in the latest revision of the STS NIJREGs. The LCO 3.0.4.c Note addition applies only to revised Required Action B. 1.

The attached markups indicate where the above comments should be factored into the CLIII' Notice for Comment. I appreciate the opportunity to provide these comments.

Very truly yours, George G. (Bert) Yates Consulting Licensing Engineer AmerenUE Callaway Plant PWROG Licensing Subcommittee Vice Chairman

67170 67170Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices Matters To Be Considered The NRC provides reasonable water reactors to utilize a new indicator, accommodation to individuals with Dose Equivalent Xenon-133 instead of Week of November 20, 2006 disabilities where appropriate. If you the current indicator known as E Bar.

There are no meetings scheduled for need a reasonable accommodation to The purpose of these models is to the Week of November 20, 2006. participate in these public meetings, or permit the NRC to efficiently process Week of November 27, 2006-Tentative need this meeting notice or the amendments to incorporate these transcript or other information from the changes into plant-specific Technical Thursday, November 30, 2006 public meetings in another format (e.g. Specifications (TS) for Babcock and 12:55 p.m. Affirmation Session braille, large print), please notify the Wilcox, Westinghouse, and Combustion (Public Meeting) (Tentative), a. Hydro NRC's Disability Program Coordinator, Engineering Pressurized Water Reactors Resources, Inc. (Crownpoint. NM) Deborah Chan, at 301-415-7041,TDD: (PWRs). Licensees of nuclear power Intervenors' Petition for Review of LBP- 301-415-2100, or by e-mail at reactors to which the models apply can 06-19 (Final Partial Initial Decision- DLC~m'c.gov. Determinations on request amendments conforming to the NEPA Issues) (Tentative). requests for reasonable accommodation models. In such a request, a licensee will be made on a case-by-case basis. should confirm the applicability of the Week of December 4, 2006-Tentative This notice is distributed by mail to model LAR, model SE and NSHIC Thursday. December 7, 2006 several hundred subscribers: if you no determination to its plant. The NRC staff longer wish to receive it. or would like is requesting comments on the model 9:30 a.m. Discussion of Management to be added to the distribution, please bAR, model SE and NSHC Issues (Closed-Ex. 2). contact the Office of the Secretary, determination for referencing in license Week of December 11, 2006-Tentative Washington, DC 20555 (301-415-1969). amendment applications.

In addition, distribution of this meeting DATES: The comment period expires 30 Monday. December 11, 2006 notice over the Internet system is days from the date of this publication.

1:30 p.m. Briefing on Status of available. If you are interested in Comments received after this date will Decommissioning Activities (Public receiving this Commission meeting be considered if it is practical to do so.

Meeting) (Contact: Keith McConnell. schedule electronically, please send an but the Commission is able to ensure 301-415-7295). electronic message to dkwi@nrc.gov. consideration only for comments This meeting will be Webcast live at Dated: November 14, 2006. received on or before this date.

the Web address-http://wvwvw.nrc.gov.

R. Mfichelle Schroll, ADDRESSES: Comments may be Tuesday, December 12, 2006 Office of the Secretary. submitted either electronically or via 9:30 a.m. Briefing on Threat [FR Doc. 06-9292 Filed 11-16-06; 10:17 amJ U.S. mail.

Environment Assessment (Closed-Ex. BILLING CODE 7590-01-M Submit written comments to: Chief.

1) Rulemaking, Directives, and Editing 1:30 p.m. Discussion of Security Branch, Division of Administrative Issues (Closed-Ex. 1 *&3). NUCLEAR REGULATORY Services. Office of Administration. Mail COMMISSION Stop: T-6 D59, U.S. Nuclear Regulatory Wednesday, December 13. 2006 Commission. Washington, DC 20555-9:30 a.m. Briefing on Status of Equal Notice of Opportunity To Comment on 0001.

Employment Opportunity (EEO) Model Safety Evaluation and Model Hand deliver comments to: 11545 Programs (Public Meeting) (Contact: License Amendment Request on Rockville Pike. Rockville, Maryland.

Barbara Williams, 301-415-7388). Technical Specification Improvement between 7:45 a.m. and 4:15 p.m. on This meeting will be Webcast live at Regarding Deletion of E Bar Definition Federal workdays.

the Web address-http://svwv.nrc.gov. and Revision to Reactor Coolant Submit comments by electronic mail System Specific Activity Technical to: CLIP@lnr-c.gov.

Thursday, December 14, 2006 Specification; Babcock and Wilcox Copies of comments received may be 9:30 a.m. Meeting with Advisory Pressurized Water Reactors, examined at the NRC's Public Document Committee on Nuclear Waste (ACNW) Westinghouse Pressurized Water Room, One White Flint North, Public (Public Meeting) (Contact: John Larkins, Reactors, Combustion Engineering File Area 01-F21, 11555 Rockville Pike 301-415-7360). Pressurized Water Reactors Using the (first floor). Rockville, Maryland.

This meeting will be webicast live at Consolidated Line Item Improvement FOR FURTHER INFORMATION CONTACT:

the Web address-http://wvwwt.nrc.gov. Process Trent Wertz, Mail Stop: O-12H2, Week of December 18, 2006-Tentative AGENCY: Nuclear Regulatory Division of Inspection and Regional There are no meetings scheduled for Commission. Support Office of Nuclear Reactor the Week of December 18, 2006. ACTION: Request for comment. Regulation, U.S. Nuclear Regulatory Commission. Washington, DC 20555-Week of December 25, 2006--Tentative

SUMMARY

Notice is hereby given that 0001, telephone (301) 415-1568.

There are no meetings scheduled for the staff of the U.S. Nuclear Regulatory SUPPLEMENTARY INFORMATION:

the Week of December 25. 2006. Commission (NRC) has prepared a

• The schedule for Commission model license amendment request Background meetings is subject to change on short (LAR], model safety evaluation (SE). and Regulatory Issue Summary 2000-06, notice. To verify the status of meetings model proposed no significant hazards "Consolidated Line Item Improvement call (recording)-301-415-1292. consideration (NSHC) determination Process (CHIP) for Adopting Standard Contact person for more information: related to deletion of E Bar (average Technical Specifications Changes for Michelle Schroll, 301-415-1662. disintegration energy. 2) definition and Power Reactors." was issued on March The NRC Commission Meeting revision to reactor coolant system (RCS) 20, 2000. The CL[IP is intended to Schedule can be found on the Internet specific activity technical specification. improve the efficiency and transparency at: h ttp:I//wwiv.nrc.govlwhot-we-dol This request revises the RCS specific of NRC licensing processes. This is policy-making/schedule.Jitm]. activity specification for pressurized accomplished by processing proposed

Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices671 67171 changes to the Standard Technical To efficiently process the incoming that their actual application fulfills their Specifications (STS) in a manner that license amendment applications, the administrative requirements as well as NRC sup poils subsequent license amendment NRC staff requests that each licensee regulations.

applications. The CLTIP includes an applying for the changes addressed by U.S. Nuclear Regulatory Commission, opportunity for the public to comment TSTF-490, Revision 0, using the CLUIP Document Control Desk, on proposed changes to the STS submit an LAR that adheres to the Washington. DC 20555.

following a preliminary assessment by following model. Any variations from

SUBJECT:

Plant Name. Docket No. 50-lxx,oo) the NRC staff and finding that the the model LA.R should be explained in Re: Application for Technical Specification change will likely be offered for the licensee's submittal. Variations from Improvement to Adopt TSTF-490, adoption by licensees. This notice is the approach recommended in this Revision 0. "deletion of E-bar definition soliciting comment on a proposed and revision to RCS Specific Activity Tech notice may require additional review by Spec" change to the STS that deletes the E Bar the NRC staff, and may increase the time definition and revises the RCS specific

Dear Sir or Madam:

In accordance with the and resources needed for the review. provisions of Section 50.90 of Title 10 of the activity technical specification of the Significant variations from the Code of Federal Regulations (10 CFR),

Babcock and Wilcox PWvR STS, Revision approach. or inclusion of additional ILICENSEEI is submitting a request for an 3 of NUREG-1430, Westinghouse PWR amendment requests, may result in staff amendment to the technical specificatio STS Revision 3 NUREG-1431, and rejection of the CLUI adoption request. (TS) for [PLANT NAME, UNIT NOS.]. e Combustion Engineering PWR STS Instead, licensees desiring significant proposed changes would replace th urrent Revision 3 NUREC-1432. The CLlIP variations and/or additional changes pressurized water reactor (PWR) clhnical directs the NRC staff to evaluate any should submit a non-CLIIP LAR that Specification (TS) 3.4.16 limi on reactor comments received for a proposed does not request to edopt TSTF-490 via coolant system (RCS) gross specific activity change to the STS and to either CLI1P. with a new limit on RCS noble gas specific reconsider the change or proceed with activity. The noble gas specific activity limit announcing the availability of the Public Notices would be based on a new dose equivalent Xe-change for proposed adoption by 133 (DEXI definition that would replace the This notice requests comments from current E-Bar (E) average disintegration licensees. Those licensees opting to interested members of the public within energy definition. In addition, the current apply for the subject change to TSs are 30 days of the date of this publication. dose equivalent 1-131 (DEl) definition would responsible for reviewing the staff's Following the NRC staff's evaluation of be revised to allow the use of additional evaluation, referencing the applicable comments received as a result of this thyroid dose conversion factors (DCFs).

technical justifications, and providing notice, the NRC staff may reconsider the The changes are consistent with NRC-any necessary plant-specific proposed change or may proceed with approved Industry Technical Specification information. Following the public announcing the availability of the Task Force (TSTF) Standard Technical comment period, the model LAR and change in a subsequent notice (perhaps Specification Change Traveler. TSTF-490.

model SE will be finalized, and posted with some changes to the model LAR, Revision 0, "Deletion of E-13ar Definition and on the NRC webpage. Each amendment 'Model SE or model NSHC determination Revision to RCS Specific Activity Tech application made in response to the Spec." The availability of this TS as a result of public comments). If the improvement was announced in the Federal notice of availability will be processed NRC staff announces the availability of Register on [DATE] ([ IFR[ I) as part of the and noticed in accordance wth the change. licensees wishing to adopt Consolidated Line Item Inprovemnent Process applicable NRC rules and procedujes. the change will submit an application in (CLUIP).

Th~is notice involves rep acemt.t ofi accordance with applicable rules and .Enclosure 1 Provides a description and the current PWR TS 3.4.16 lim! )n other regulatory requirements. The NRC assessment of the proposed changes, as well RCS gross specific activity with new staff will, in turn, issue for each as confirmation of applicability. Enclosure 2 limit on RCS noble gas specific activity. application a notice of consideration of provides the existing TS pages and TS Bases The noble gas specific activity limit issuance of amendment to facility marked-up to show the proposed changes.

would be based on a new dose Enclosure 3 provides final TS pages and TS operating license(s), a proposed NSHC Bases pages.

equivalent Xe-133 (DEX) definition that determination, and an opportunity for a would replace the current E-Bar average [LICENSEE] requests approval of the hearing. A notice of issuance of an proposed license amendment by JDATEI, disintegration energy definition. In amendment to operating license will with the amendment being implemented [BY addition, the current dose equivalent I- announce the revised requirements for DATE OR WITHIN X DAYS). In accordance 131 (DEl) definition would be revised to each plant that applies for and receives with 10 CFR 50.91, a copy of this application.

allow the use of additional thyroid dose the requested change. with enclosures, is being provided to the conversion factors (DCFs). By letter designated [STATE] Official.

dated September 13, 2005, the Dated at Rockville. Maryland this 14th day I declare under penalty of perjury under Technical Specifications Task Force of November. 2006. the laws of the United States of America that (TSTF) proposed these changes for For the Nuclear Regulatory Commission. I am authorized by [LICENSEE] to make this incorporation into the STS as TSTF- Timothy J. Kobetz. request and that the foregoing is true and 490, Revision 0. Chief. Technical SpecificationsBranch, correct. [Note that request may be notarized Division of Inspection and Regional Support, in lieu of using this oath or affirmation Applicability Office of NuclearReactor Regulation. statement]. If you should have any questions regarding this submittal, please contact I

• These proposed changes will revise For inclusion on the technical specification the definition of DOSE EQUIVALENT I- Sincerely, web page. The following example of an Name. Title 131. delete the definition of "E-Bar," application was prepared by the NRC staff to AVERAGE DISINTEGRATION ENERGY, facilitate the adoption of Technical

Enclosures:

add a new definition for DOSE Specifications task force (TSTF) Traveler 1. Description and Assessment of Proposed EQUIVALENT XE-133, and revise LCO TSTF-490. Revision 0 "deletion of E-bar Changes definition and revision to RCS Specific 2. (Proposed Technical Specification 3.4.16 for Babcock and Wilcox, Activity Tech Spec." The model provides the Changes and Technical Specification Westinghouse. and Combustion expected level of detail and content for an Bases Changes]

Engineering PWRs, STS NUREGs 1430. application to adopt TSTF-490. Revision 0. 3. [Final Technical Specification and Bases 1431. and 1432. Licensees remain responsible for ensuring pages)

67172 67172 Federal Register/Vol. 71, No. 223 /Monday, November 20, 2006/Notices cc: NRR Project Manager, Regional Office,

• Deleted SR 3.4.16.3 requested changes are the adoption of TSTF-Resident Inspector. State Contact, ITSB 490, Revision 0. "Deletion of E Bar Definition Branch Chief. 3.0 Back-ground and Revision to RCS Specific Activity Tech The background for this application is as Spec" to the Pressurized Water Reactor -Description and Assessment of stated in the model SE in NRC's Notice of (PWR) Standard Technical Specifications Proposed Changes Availability published on (DATE W((] FR [1), (STS), which was proposed by the Technical 1.0 Description the NRC Notice for Comment published on Specifications Task Force (TSTF) by letter on IDATE] ([1IFR [ 1). and TSTF-490, Revision September 13. 2005. This TSTF involves This letter is a request to amend Operating

0. changes to NUREG-1430. NUREG-1431, and License(s) [LICENSE NUMBER(S)] for NUREG-1432 Section 3.4.16 limits on reactor

[PLANT/UNIT NAME(S)]. 4.0 Technical Analysis coolant system (RCS) gross specific activity The proposed changes would replace the [LICENSEE] has reviewed References I and with a new limit on RCS noble gas specific current limits on primary coolant gross 2, and the model SE published on [DATE] (U activity. The noble gas specific activity limit specific activity with limits on primary IFR [ 1) as part of the CLIIP Notice for would be based on a new dose equivalent coolant noble gas activity. The noble gas Availability. [LICENSEE] has applied the Xe--133 (DEX) definition that would replace activity would be based on DOSE methodology in Reference 1 to develop the the purrent E-Bar average disintegration EQUIVALENT XE-133 and would take into proposed TS changes. [LICENSEE) has also energy definition. In addition, the current account only the noble gas activity in the concluded that the justifications presented in dose equivalent 1-131 (DEl) definition would primary coolant. TSTF-490, Revision 0 and the model SE be revised to allow the use of additional Technical Specification Task Force (TSTF) to change traveler TSTF-490, Revision 0, F repared by the NRC staff are applicable thyroid dose conversion factors (DCFs).

PLANT, UNIT NOS.]. and justify T this "Deletion of E Bar Definition and Revision to amendment for the incorporation of the

2.0 REGULATORY EVALUATION

RCS Specific Activity Tech Spec" was changes to the [PLANT) TS. The Nuclear Regulatory Commission MNC) announced for availability in the Federal 5.0 RgltrAnlssstaff evaluated th e impact of the proposed Register on [DATE] as part of the Reguator Ana~siSchanges as they relate to the radiological consolidated line item improvement process A description of this proposed change and consequences of affected design basis (CLIIP). its relationship to applicable regulator accidents (DBAs) that use the reactor coolant requirements and guidance was provided in system (RCS) inventory as the source term.

2.0 Proposed Changes the NRC Notice of Availability published on The source term assumed in radiological Consistent with NRC-approved TSTF-490, [DATE] ([ I FR [ 1), the NRC Notice for analyses should be based on the activity Revision 0. the proposed TS changes Include: Comment published on [DATE) [IFR 11, associated with the projected fuel damage or

- Revised definition of DOSE and TSTF-490. Revision 0. the maximum TS RCS values, whichever EQUIVALENT 1-131

- Deletion of the definition of "E-Bar. 6.0 No Significant Hazards Consideration maximizes the radiological consequences.

The limits on RCS specific activity ensure AVERAGE DISINTEGRATION ENERGY [LICENSEE] has reviewed the proposed no that the offsite doses are appropriately

• Adding a new definition for DOSE significant hazards consideration limited for accidents that are based on EQUIVALENT XE-133 determination published in the Federal releases from the RCS with no significant

• Revised LCO 3.4.16, -RCS Specific Register on (DATEJ ([ I FR [ [)Ias part of the amount of fuel damage.

Activity' to delete references to gross CLII]'. [LICENSEE] has concluded that the The Steam Generator Tube Rupture (SGTR) specific activity, and reference limits on proposed determination presented in the DOSE EQUIVALENT 1-13 1 and DOSE notice is applicable to [PLANT] and the accident and the Main Steam Line Break (MSLB) accident, with a few exceptions, do EQUIVALENT XE-1 33, and delete Figure determination is hereby incorporated by not result in fuel damage and therefore the 3.4.16-1, "Reactor Coolant DOSE reference to satisfy the requirements of 10 radiological consequence analyses are based EQUIVALENT 1-131 Specific Activity Limit CFR 50.91 (a). on the release of primary coolant activity at versus Percent of RATED THIERMAL POWER." 7.0 EnvironmentalEvaluation maximum TS limits. For accidents that result

• Revised Applicability of LCO 3.4.16 to [LICENSEE] has reviewed the in fuel damage, the additional dose indicate the LCO is applicable in MODES environmental consideration included in the contribution from the initial activity in the 1,2,3, and 4 model SE published in the Federal Register RCS is not normally evaluated and is

• [Modified ACTIONS Table as follows: on [DATE) U[IFR [ 1)as part of the CLIIP. considered to be insignificant in relation to A. Condition A is modified to delete the [LICENSEE] has concluded that the stafr's the dose resulting from the release of fission reference to Figure 3.4.16-1, and define an findings presented therein are applicable to products from the damaged fuel. 9--X

[PLANTl] adtedtriainihrby [For licensees that incorporate'tho source upper limit that is applicable at all power tis heeyterm icroaned the determinatifon as defined in Technic kfnformation levels. apincroatedbi rfrncnorti Document (TI])) 14S844. C192 B. NUREG-1430 and NUIREG-1432 applcaton."Calculation of Dis fceFaci.tor fr Power ACTIONS are reordered, moving Condition 8.0 References and Test Reactor .ites," in their dose C to Condition B.

C. Condition B (was Condition C in NUREG- 1. Federal Register Notices: consequence anaryses. the staff uses the Notice for Comment published on [DATE] regulatory guidance provided in NUREG-1430 and NUREG 1432) is modified to provide a Condition and Required Action (([IFR [11) 0800. "Standard Review Plan (SRP) for the Notice of Availability published on [DATE Review of Safety Analysis Reports for for DOSE EQUIVALENT XE-133i instead of

[([FRI I) Nuclear Power Plants," Section 15.1.5, gross specific activity. The Completion "Steam System Piping Failures Inside and Time is changed from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. MODEL SAFETY EVALUATION Outside of Containment (PWR)," Appendix

ýA Note stating the applicability of LCO 3.0.4.c is added, consistent with the Note] U.S. Nuclear Regulatory CommissIon A, "Radiological Consequences of Main Steam Line Failures Outside Containment,"

Lto Required Action A.1. Office of Nuclear Reactor Regulation Revision 2, for the evaluation of MSLB3 D. Condition C (was Condition B in NUREG-1430 and NUREG-1432) is modified based Technical Specificatien Task Force TSTF- accident analyses and NUREG-0800, SRP 49,Revision 0 Section 15.6.3, "Radiological Consequences on the changes to Conditions A and B and 490, of Steam Generator Tube Failure (PWR)."

to reflect the change in the LCO "Deletion of E-Bar Definition and Revision to Revision 2, for evaluating SGTh accidents-Applicability] RCS Specific Activity Tech Spec" analyses. In addition, the staff uses the

- Revised SR 3.4.16.1 to verify the limit for 1.0 ITRODUTIONguidance from RG 1.195, "Methods and DOSE EQUIVALENT XE-1 33. A Note is 1.0 ITRODUTIONAssumptions for Evaluating Radiological added, consistent with SR 3.4.16.2 to allow By letter dated L, 20], [LICENSEE) (the Consequences of Design Basis Accidents at entry into MODES 4.3, and 2 prior to licensee] proposed changes to the technical Light Water Nuclear Power Reactors." May performance specifications (TS) for [PLANT NAME]. The 2003. for those licensees that chose to use its of the SR.

X

Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices677 67173 guidance for dose consequence analyses room under accident conditions without analyses become disconnected from plant using the TID 14844 source term.] personnel receiving radiation exposures in operation and the limiting condition for

[For licensees using the alternative source excess of 5 rem TEDE for the duration of the operation (LCO) becomes essentially term (AST) in their dose consequence accident.] meaningless. It also results in a TS limit that analyses, the staff uses the regulatory can vary during operation as different values guidance provided in NUJREG-0800 . SRP 3.0 TECHNICAL EVALUATION for E-Bar are determined.

Section 15.0.1. "Radiological Consequence 3.1 Technical Evaluation of TSTF-490 RCS This change will implement a LCO that is Analyses Using Alternative Source Terms," TS Changes consistent with the whole body radiological Revision 0. July 2000, and the methodology 3.1. tothe Reisio efiitio ofD~l consequence analyses which are sensitive to and assumptions stated in Regulatory Guide 3,1. tothe Reisio efiitio ofDET the noble gas activity in the primary coolant (RG) 1.183, "Alternative Radiological Source The list of acceptable DCFs for use in the but not to other, non-gaseous activity Terms for Evaluating Design Basis Accidents determination of DEL include the following: currently captured in the E-Bar definition.

at Nuclear Power Reactors". July 20300.] L: Table II of TID-14844, AEC, 1962, SR 3.4.16.1 specifies the limit for primary The applicable dose criteria for the "Calculation of Distance Factors for Power coolant gross specific activity as blooE-Bar evaluation of DBAs depends on the source and Test Reactor Sites." Ci/gin. The current E-Bar definition includes term incorporated in the dose consequence 9 Table E-7 of Regulatory Guide 1.109, radioisotopes that decay by the emission of analyses. [For Licensees using the TID 14844 Revision 1, NRC, 1977. both gamma and beta radiation. The current source term, the maximum dose criteria to e ICRP 30.1979, page 192-212, Table titled Condition B of LCO 3.4.16 would rarely, if the whole body and the thyroid that an "Committed Dose Equivalent in Target ever, be met for exceeding 100lE-Bar since individual at the exclusion area boundary Organs or Tissues per Intake of Unit the calculated value is very high (the (EAB) can receive for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Activity." denominator is very low) if beta emitters following an accident, and at the low

• Table 2.1 of EPA Federal Guidance such as tritiumn (H-3) are included in the population zone (LPZ) outer boundary for the Report No. 11, 1988, "Limiting Values of determination, as required by the E-Bar duration of the radiological release, are Radionuclide Intake and Air Concentration definition.

specified in Title 10 of the Code of Federal and Dose Conversion Factors for Inhalation. TS Section 1.1 definition for E-AVERAGE 4

Regulations (10 CFR) Part 100. 11. These Submersion, and Inge~stion."3 arC4hre DISINTEGRATION ENERGY fE-Bar] is criteria are 25 roentgen equivalent man (rem) Note: It is incumbent on the hicensee t9 .,Cdeleted and replaced with a new definition total whole body dose and 300 rem thyroid ensure that the OCFs used in the Cb~ C or DXwhich states:

dose from iodine exposure. The accident determination of DEl are consistent wit IDS dose criteria in 10 CFR 100.11 is applicable dose consequence anal e ~oncentration of Xe-133 (microcuries per QIAETX-3 supplemented by accident specific dose 3.1.2 Deletion of the Definition of -an ,ram) that alone would produce the hlsame ota acceptance criteria in SRP 15.1.5. Appendix the Addition of a New Deftinition for DE Xe- ctdoeothwolbdyate A, SRP 15.6.3 or Table 4 of RG 1.195, 133 combined activities of noble gas nuclide Kr-

"Methods and Assumptions for Evaluating 85m, Kr-85. Kr-87. Kr-88, Xe--131m. Xe-The determination of DEX wvillI be 133 ' Xe-133, Xe-135m, Xe--135, and Xe-Radiological Consequences of Design Basis performed in a similar manner to that 13fi~ctually present. If a specific noble gas Accidents at Light Water Nuclear Power currently used in determining DEL, except nu'Elide is not detected, it should be assumed Reactors," May 2003.1 that the calculation of DEX is based on the to be present at the minimum detectable

[For control room dose consequence acute dose to U1 whole body and considers activity. The determination of DOSE analyses that use the TID 14844 source term, the noble gaseq Kr-85m, Kr-87, Kr-88,' Xe- EQ ALEN XE-133 shall be performed the regulatory requirement for which the .ain, Xe-133,_Xe-135m, Xe-135, and' Xe sn effective dose conversion factors for air NRC staff bases its acceptance is General 13.1which are significant in terms of Submersion listed in Table 111.1 of EPA Design Criterion (GDC) 19 of Appendix A to contribution to whole body dose. Some noble Federal Guidance Report No. 12, or the 10 CFR Part 50. "Control Room". GDC 19 gas isotopes are not included due to low avrg m dsneatoeegiss requires that adequate radiation protection be concentration, short half life, or small dose avierag gamm diintegrliation enegie, a provided to permit access and occupancy of conversion factor. The calculation of DEX pRovdd in ICheRPPublications 38,. la the control room under accident conditions would use either the average gamma source."

without personnel receiving radiation disintegration energie.; for the nuclides or the The c' ange incorporating the newly exposures in excess of 5 rem whole body, or effective dose conversion factors from Table defined.quantity DEX is acceptable from a its equivalent to any part of the body, for the 111.1 of EPA Federal Guidance Report No.12, radiological dose perspective since it will duration of the accident. NUREC-0800. SRP "External Exposure to Radionuclides in Air, result in an LCO that more closely relates the Section 6.4, "Control Room Habitability Water. and Soil", 1993. Using this approach, non-iodine RCS activity limits to the dose System," Revision 2, July 1981, provides the limit on the amount of noble gas activity cosqeeanleswihfrter guidelines defining the dose equivalency of in the primary coolant would not fluctuate consequnc analyseINUM whic for NTHEi 5 rem whole body as 30 rem for both the with variations in the calculated values of E- basEs.NOTE: ITO ENSINUMBENTHT ONTHE D thyroid and skin dose. For licensees adopting Bar. If a specified noble gas nuclide is not USED IN THE DETERMINATION OF DEI the guidance from RG 1.196, "Control Room detected, the new definition states that it AN TH-E NEWLY DEFINED DEX ARE Habitability at Light Water Nuclear Power should be assumed the nuclide is present at CONSISTENT WITH THE DCFS USED IN Reactors," May 2003, Section C.4.5 of RG the minimum detectable activity. This Will THE APPLICAB3LE DOSE CONSEQUENCE 1.195, May 2003, states that in lieu of the result in a conservative calculation of DEX. ANLS.

dose equivalency guidelines from Section 6.4 When E-Bar is determined using a design ANLS.

of NUREG-OBOG, the 10 CFR 20.12 01 annual basis approach in which it is assumed that 3.1.3 Revision of LCO 3.4.16, -RCS Specific organ dose limit of 50 rem can be used for 1.0% of the power is being generated by fuel Activity" both the thyroid and skin dose equivalent of rods having cladding defects and it is also LCO 3.4.16 is modified to specify that 5 rem whole body.] assumed that there is no removal of fission iodine specific activity in terms of DEI and

[Licensees using the AST are evaluated gases from the letdown flow, the value of E- noble gas specific activity in terms of DEX against the dose criteria specified in 10 CFR Bar is dominated by Xe--133. The other shall be within limits. Currently the limiting Part 50.67. The off-site dose criteria are 25 nuclides have relatively small contributions, indicators are not explicitly identified in the rem total effective dose equivalent (TEDE) at However, during normal plant operation LCO, but are instead defined in current the EAB for any 2-hour period following the there are typically only a small amount of Condition C and Surveillance Requirement onset of the postulated fission product fuel clad defects and the radioactive nuclide (SR) 3.4.16.1 for gross non-iodine specific release and 25 rem TEDE at the outer inventory can become dominated by tritium. activity and in current Condition A and SR boundary of the LPZ for the duration of the and corsion antor activation products. 3.4.16.2 for iodine specific activity.

postulated fission product release. in resultn in the drmlnation of a value of The new LCO states "RCS DOSE addition, 10 CFR Part 50.67 requires that 5-Bar that is vry, different than wvould be EQUIVALENT 1-13 1 and DOSE adequate radiation protection be provided to calculated using ahdesign basis approach. EQUIVALENT XE-133 specific activity shall permit access and occupancy of the control Because of this cfference the accident dose be within limits." NOTE: IT IS INCUhiBENT

/ , 4,sC -e )V14/1 67174 Federal Register/Vol. 7X o 23Mody November 20, 2006/Notices ON THE LICENSEE TO ENSURE THAT THE based on low concentration, short half life, or 3.1.8 SR 3.4.16.1 Revision to include SI`TE SPECIFIC LIMITS FOR BOTH DEl AND sinai dose conversion factors. The primary Surveillance for DEX DEX ARE CONSISTENT WITH THE pur se of the TS 3.4.16 LCO on RCS The change replaces the current SR CURRENT SGTR AND msLB spec fic activity and its associated Conditions 3.4.16.1 surveillance for RCS gross specific RADIOLOGICAL CONSEQUENCE is to support the dose analyses for DBAs. The activity with a surveillance to verify that the who e body dose is primarily dependent on site specific reactor coolant DEX specific TS 3.4.16 Required Action A.1 is revised the oble gas activity, not the non-gaseous activity is ir [280] j+/-Ci/gm. This change to remove the reference to Figure 3.4.16-1 acti ity currently captured in the E-Bar provides a surveillance for the new LCO limit "Reactor Coolant DOSE EQUIVALENT 1-131 deft ition. added to TS 3.4.16 for DEX. The revised SR Specific Activity Limit versus Percent of TeCompletion Time for revised TS 3.4.163.1.1svelacreuespfomga HERMA POWE" andineto RATED af Reqi ired Action B.1 will require restoration gamistpcnlysasaesuefth limit of less than or equal to the site specific of D X to within limit in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This is nolgasmispecific acalyivity masr of thereco

• DEI spiking limit. Radiological dose consf stent with the Completion Time for coolangat lpeastioncetevery ofdays whichtis consequence analyses for SGTR and MSLB cuirr nit Required Action A.2 for DEL. The coath sameasfrquncy rvequred unders theci accidents, which take into account the pre- radi logical consequences for the SGTR and curensRm 3re4.16.1 seuirveillancefr tCe accident iodine spike, do not consider the the I SLB accidents demonstrate that the guross non-iodine1spreiiclanctivity.RTh elevated RCS iodine specific activities cac lated thyroidoeaegnrlya gosnn-dnepcfcatvt.Th permitted by Figure 3.4.16-1 for operation ca ddssaegnrlya surveillance provides an indication of any below 80% RTP. Instead, the pre-accident grea tnecriperenthageo the caplcuabe hle increase in the noble gas specific activity.

iodine spike analyses assume a DEl c ac rtratantecluae hl The results of the surveillance on DEX allow concentration 60 times higher than the bed doses (operation with iodine specific preremdaacintbeaknefe corresponding long term equilibrium value, acti i~ty levels greater than the LCO limit is prprremigtediaOliacionto bnertakebfre which corresponds to the specific activity Per ssible. if the activity levels do not opreaching th co litund erionnirmuial wjy limit associated with 100% RTP operati~on. x aex d the limits shown in Figure 3.4.16-1. oeaigcniin. fe-w~V4' SR 3.4.16.1 is modified by inclusion of ay TS 3.4.16 Required Action A.1 shal bebs in he applicable specification. for more than NOTE 1 hi~

on the short term site specific DEl spiking 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />). Therefore the Completion Time for .e limit to be consistent with the assumptions ni le gas activity being out of specification ______________________

contained in the radiological consequence the revised Required Action B.1 should be '"'o.h .plnb.

analyses. I.least as great as tha Completion Time fo W-hile relying OR the ACT1QNs. Tlfif.'t4'/'

3..4T 1 Apicbiit

.. evsin odine specific activity being out of *.llwenm~is acceptable due to the significant specification in current Required Action A.2 cnevts no.rae noteseii TS 3.4.16 Applicability is modified to Therefore the Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> activity limit, the low probability of an event include MODE 3 and MODE 4. It is necessary for revised Required Action B3.1 is acceptable which is limiting due to exceeding this limit.

for the LCO to apply during MODES 1 from a radiological dose perspective, and the ability to restore transient specific through 4 to limit the Condition Cailoia activity excursions while the plant remains GRoten posqecso LBtial railoial .1.7 TS 3.4.16 CnionCRevision at, or proceeds to power operation. This occur during these MODES. In MODES 5 and TS 3.4.16 Condition C is revised to include allows entry into MODE 4. MODE 3, and

6. the steam generators are not used for decay Condition B (DEX not within limit) if the MODE 2 prior to performing the surveillance.

heat removal, the RCS and steam generators Required Action and associated Completion This allows the surveillance to be performed are depressurized, and primary to secondary Time of Condition B is not met. This is in any of those MODES, prior to entering leakage is minimal. Therefore, the monitoring consistent with the changes made to MODE 1, similar to the current surveillance of RCS specific activity during MODES 5 and Condition B which now provides the same SR 3.4.16.2 for DEL.

6 is not required. The change to modify the completion time for both components of RCS 3.1.9 SR 3.4.16.3 Deletion TS 3.4.16 Applicability to include all of specific activity as discussed in the revision MODE 3 and MODE 4 is necessary to limit to Condition B. The revision to Condition C The current SR 3.4.16.3 which required the the potential radiological consequences of an also replaces the limit on DEl from the determination of E-Bar is deleted. TS 3.4.16 SGTR or MSLB that may occur during these deleted Figure 3.4.16-1 with a site specific LCO on RCS specific activity supports the MODES and is therefore acceptable from a value of,> 1601 pCi/gm. This change makes dose analyses for OBAs. in which the whole radiological dose perspective. Condition C consistent with the changes body dose is primarily dependent on the 3It3.1.5TS 3.4.16 Condition A Revision made to TS 3.4.16 Required Action A.I. noble gas concentration, not the non-gaseous The change to TS 3.4.16 Required Action. activity currently captured in the E-Bar TS 3.4.16 Condition A is revised by C.1 requires the plant to be in MODE 3 definition. With-the elimination of the limit replacing the DEl site specific lirni. > 1.0 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and adds a new Required for RCS gross specific activity and the

iCi/gm' with the words "not within limit' Action C.2 which requires the plant to be in addition of the new LCD limit for noble gas to be consistent with the revised TS 3.4.16 MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. These changes are specific activity. this SR to determine E-Bar LCO format. The site specific DEl limit of* ossetwt h cagsmd oteT i olne eurd 11.01 pCi/gm and Required Action A.1 is 3s4.1 Appicbilty TervsdLO5 3.P reed rent contained in SR 3.4.16.2. This change will applicable throughout all of MODES 13.Prcdn maintain the consistency of the proposed TS and s acepablefro a adioogialtose ough 4 to limit the potential radiological The Technical Specifications developed for erspective. consequences of an SGTR or MSLB that may the Westinghouse AP600 and AP1 000 occur during these MODES. In MODES 5 and advanced reactor designs incorporate an LCO 3.1.6 TS 3.4.16 Condition 13Revision to 6, the steam generators are not used for decay for RCS DEX activity in place of the LCO on include Action for DEX Limit heat removal, the RCS and steam generators non-iodine gross specific activity based on E-TS 3.4.16 Conditioil s replaced with a are depressurized, and primary to secondary 'Bar. This approach was approved by the NRC new Condition B3fo DPX ntwthin limits, leakage is minimal. Therefore, the monitoring for the AP600 in NUREG-1512, "Final Safety This change is made tol neconsIsent with the of RCS specific activity during MODES 5 and Evaluation Report Related to the Certification change to the TS 3.4.1qf LCO which requires 6 is not required. of the AP600 Standard Design. Docket No.

the DEX specific activfty to be within limits A new TS 3.4.16 Required Action C.2 52-003," dated August 1998 and for the as discussed above. T eDXlitsste Completion Time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is added for the AP1000 in the NRC letter to Westinghouse specific and then~ bri value in units of plant to reach MODES5. This Completion Electric Company dated September 13. 2004.

pjCi/gm is con de in revised SR 3.4.16.1. Time is reasonable, based on operating In addition the curve describing the The site specifc lijit of DEX jiCilgrn is experience, to reach MIODE 5 from full power maximum allowable iodine concentration established based $n the maximum accident conditions in an orderly manner and without during the 48-hour period of elevated activity analysis RCS acti ity corresponding to 1% challenging plant systems and the value of 36 as a function of power level, was not fuel clad defect with sufficient margin to hours is consistent with other TS which have included in the TS approved for the AP600 accommodate ie exclusion of those isotopes a Completion Time to reach MODE 5. and API 000 advanced reactor designs.

ý Nac- 14-31 C ;,A/mr,

_qIV1,n N - /4-26?o a4 /~aA677-I14-2. J

Federal Register/Vol. 71, No. 223/Monday. November 20, 2006/Notices677 67175

4.0 STATE CONSULTATION

Criterion I-The ProposedChange Does Not OVERSEAS PRIVATE INVESTMENT In accordance with the Commission'.s Involve a Significant Increase in the CORPORA71ON -

regulations, the [i State official was notified Probabilityor Consequences of on Accident of the proposed issuance of the amendment. Previously Evaluated Agency Information Collection The State official had 0)1 no comments or (2) Reactor coolant specific activity is not an Activities: Proposed Collection; the following comments-with subsequent initiator for any accident previously Comment Request disposition by the staff]. evaluated. The Completion Time when AGENCY: Overseas Private Investment

5.0 ENVIRONMENTAL CONSIDERATION

primary coolant gross activity is not within Corporation (OPIC).

limit is not an initiator for any accident The amendmnentisl changelsi a requirentent previously evaluated. The current variable ACTION: Request for comments.

with respect to the installation or use of a limit on primary coolant iodine facility component located within the

SUMMARY

In compliance with the concentration is not an initiator to any restricted area as dofined in 10 CFR Part 20 Paperwork Reduction Act (44 U.S.C.

accident previously evaluated. As a result.

or surveillance requirements. The NRC staff 3501 et seq.), this notice announces that the proposed change does not significantly has determined that the amendment involves increase the probability of an accident. The OPIC is planning to submit the no significant increase in the amounts, and proposed change will limit primary coolant following proposed Information no significant change in the types, of any Collection Request (ICR) to the Office of noble gases to concentrations consistent with effluents that may be released offsite. and Management and Budget (0MB): OPIC that there is no significant increase in the accident analyses. The proposed change to the Completion Time has no impact on the 2006 Client Satisfaction Survey. Before individual or cumulative Occupational submitting the ICR to OMB for review radiation exposure. The Commission has consequences of any design basis accident since the consequences of an accident during and approval. OPIC is soliciting public previously issued a proposed finding that the comment on the client survey.

amendment involves no signi ficant hazards the extended Completion Time are the same as the consequences of an accident d uring Comments are being solicited on the consideration and there has been no public comment on such finding published [DATE] the Completion Time. As a result, the need for the information, its practical

([IJFR IIJ). Accordingly, the amendment consequences of any accident previously utility, the accuracy of the Agency's meets the eligibility criteria for categorical evaluated are not significantly increased. burden estimate, and on ways to exclusion set forth in 10 CFR 51.22(c)(9). minimize the reporting burden. The Criterion2-The Proposed Change Does Not proposed ICR is summarized below.

Pursuant to 10 CFR 51.22(b). no Create the Possibilityof a New or Different environmental impact statement or Kind of Accident fromt any Previously DATES: All comments must be received environmental assessment need be prepared Evaluated by OPIC within 60 calendar days from in connection with the issuance of the the publication date of this Notice.

amendment. The proposed change in specific activity limits does not alter any physical part of the ADDRESSES: Information regarding this

6.0 CONCLUSION

plant nor does it affect any plant operating information collection request and/or a The Commission hans concluded, based on parameter. The change does not create the copy of the survey questions can be the considerations discussed above, that (11 potential for a new or different kind of obtained from the Agency Submitting there is reasonable assurance that the health accident from any previously calculated. Officer below. Comments on the survey and safety of the public wilt not be should be submitted to the Agency endangered by operation in the proposed Criterion3-The Proposed Change Does Not Submitting Officer.

Involve a Significant Reduction in the Margin manner. (2) such activities will be conducted FOR FURTHER INFORMATION CONTACT:

in compliance with the Commission's of Safety OPIC Agency Submitting Officer: Essie regulations, and (3) the issuance of the The proposed change revises the limits on Bryant, Records Manager. Overseas amendment will not be inimical to the noble gase radioactivity in the primary Private Investment Corporation. 1100 common defense and security or to the health coolant. The proposed change is consistent New York Av'enue, NW., Washington, and safety of the public. with the assumptions in the safety analyses DC 20527, telephone (202) 336--8563.

and will ensure the monitored values protect Proposed No Significant Hazards SUPPLEMENTARY INFORMATION:

Consideration Detertmination the initial assumptions in the safety analyses.

Based upon the reasoning presented above Type of Request: New information Description of Amendment Request: and the previous discussion of the collection.

[LICENSEE) requests adoption of an amendment request, the requested change

Title:

2006 OPIC Client Satisfaction approved Change to the standard technical does not involve a significant hazards Survey.

specifications (STS) for Pressurized Water 0MB Approval Number: None.

consideration.

Reactor (PWR) Plants [NUREG-143o, Frequency of Response: Once per NUREG-1431. or NUJREG-14321 and the Dated at Rockville. Maryland. this __day client.

[LICENSEE] technical specifications (TS), to of-, XXXX. Type of Respondents: Individual replace the current limits on primary coolant For The Nuclear Regulatory Commission business officer representatives of U.S.

gross specific activity with limits on primary companies sponsoring projects overseas.

coolant noble gas activity. The noble gas Project Manager, PlantLicensing Branch activity would be based on DOSE IL. Division of OperatingReactor Licensing, Respondent's Obligation:Voluntary.

EQUIVALENT XE-1 33 and would take into Office of Nuclear Reactor Regulation Affected Public:U.S. companies or account only the noble gas activity in the citizens sponsoring projects overseas.

Enclosure 2-[Proposed Technical Estimated Number of Respondents:

primary coolant. The changes are consistent Specification Changes and Technical with NRC approved Industry/Technical 100.

Specification Bases Changes] Estimated time Per Response: 30 Specification Task Force (TSTF) Standard Technical Specification Change Traveler, Enclosure 3-[Final Technical minutes.

TSTF-490. Specification and Bases Pages] Estimated Total Annual Burden: $0.

Basisfor proposed no-significont-hazt-rds- IFR Dec. 06-9330 Filed 11-17-06; 8:45 aml Authorityfor Information Collection:

consideration determination:As required by BILLING CODE 7590-0l-P Sections 231 and 234 of the Foreign 10 CFR 50.91 (a). an analysis of the issue of Assistance Act of 1961, as amended.

no-significant-hazards-consideration is Abstract (Needs and Uses of presented below: Information Collected): OPIC is

PagelI otIl NRCREP - Comments on TSTF-490 (E-Bar Deletion) CLIIP FR Notice for Comment From: "Yates, George G" <GYates@ameren.com>

To: <CLIIP @nrc .gov>

Date: 12/20/2006 8:43 PM

Subject:

Comments on TSTF-490 (E-Bar Deletion) CL11P FR Notice for Comment See attached comment letter which is also being mailed in hard copy.

Bert Yates gyates @ameren.com 314-554-3573

• • • • • • • • • • • • • • • • • • • • • • • • • The information contained inthis message may be privileged and/or confidential and protected from disclosure. Ifthe reader of this message isnot the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. Note that any views or opinions presented in this message are solely those of the author and do not necessarily represent those of Ameren. All emails are subject to monitoring and archival. Finally, the recipient should check this message and any attachments for the presence of viruses. Ameren accepts no liability for any damage caused by any virus transmitted by this email. If you have received this in error, please notify the sender immediately by replying to the message and deleting the material from any computer. Ameren Corporation***************

file :/C:\temp\GW 100001 .HTM 1/720 12/27/2006