ML080950096

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Response to NRC Request for Additional Information License Amendment Request 210. Technical Specification Modifications Regarding Control Room Envelope Habitability
ML080950096
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 04/03/2008
From: Gerald Bichof
Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
08-0055
Download: ML080950096 (16)
v • d • e


Text

Dominion Energy Kewaunee, Inc.

"Illlil Dominion Boulevard, Clen Allen, VA 251l1>l1 April 3, 2008 ATTN: Document Control Desk Serial No. 08-0055 U. S. Nuclear Regulatory Commission L1C/JF/R1 Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEE POWER STATION RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST 210. "TECHNICAL SPECIFICATION MODIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY" Pursuant to 10 CFR 50.90, on September 14, 2007, Dominion Energy Kewaunee, Inc.

(DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS) (Reference 1). This proposed amendment would revise the Operating License by modifying the KPS Technical Specifications (TS) to adopt Technical Specification Task Force (TSTF) traveler TSTF-448-A, Revision 3, "Control Room Habitability," consistent with the KPS plant design. DEK also proposed additional changes as identified in Reference 1.

Subsequent to the posting of Nuclear Regulatory Commission (NRC) approval for adoption of TSTF-448-A in the Federal Register, a memorandum (Reference 2) was issued correcting a typographical error in section 2.3 of the model LAR regarding the license condition specifying the schedule for initial performance of new surveillance and assessment requirements. The memorandum states that in two places the model LAR was in error when it stated 15 months as the scheduling allowance of TS Surveillance (SR) 3.0.2 for the 6-year surveillance test interval for performing the control room envelope unfiltered in-leakage determination surveillance. Rather, the model LAR should have specified 18 months, since 18 months is 25% of this 72-month frequency.

Therefore, the 15 months scheduling allowance has been changed to 18 months.

Based on this memorandum, DEK is submitting a revised KPS Operating License page 5, showing the proposed modification of a new license condition 11, which was originally submitted in Reference 1. The modified license condition 11 is similar to the model LAR section 2.3, item (a), but with the 15 months changed to 18 months. contains the revised proposed marked-up Operating License page.

In addition, the NRC transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 3). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.

Serial No. 08-0055 Response to RAls Regarding LAR 210 Page 2 of 3 DEK continues to request approval of the proposed amendment as stated in Reference

1. Once approved, the amendment will be implemented within 60 days.

The KPS Facility Safety Review Committee has approved the proposed changes and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91 (b).

If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.

Very truly yours, IdJ'1!?-V Gerald T. Bischof Vice President - Nuclear Engineering COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 3 ty> day of ~ ,2008.

My Commission expires: au.~yJJ.t 31, dooK MARGARET 8. BENNEn Notary Public Notary Public E>SI.J.~O;}.

Commonweotth of Virginia

  • l My Commllllon Expire. Aug 31. 2008
  • Serial No. 08-0055 Response to RAls Regarding LAR 210 Page 3 of 3 Attachments
1. Response To NRC Request For Additional Information Re: License Amendment Request 210, "Technical Specification Modifications Regarding Control Room Envelope Habitability"
2. Marked-up KPS Operating License Page 5 Commitments made by this letter: None

References:

1. Letter from Gerald T. Bischof (DEK) to Document Control Desk (NRC), "License Amendment Request 210, "Technical Specification Modifications Regarding Control Room Envelope Habitability," dated September 14, 2007 (ADAMS Accession No. ML072620144).
2. Memorandum from C. Craig Harbuck (NRC) to Timothy J. Kobetz (NRC), "Model Application for TSTF-448, Control Room Habitability, Revision 3," dated February 2,2007 (ADAMS Accession No. ML070330657).
3. Letter from Patrick D. Milano (NRC) to David A Christian (Dominion), "Kewaunee Power Station - Request for Additional Information Related to Control Room Habitability (TAC No. MD6773)," dated January 30, 2008 (ADAMS Accession No. ML080280107).

cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Ms. M. H. Chernoff Senior Project Manager U.S. Nuclear Regulatory Commission OWFN Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 08-0055 ATTACHMENT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST 210, "TECHNICAL SPECIFICATION MODIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY" DOMINION ENERGY KEWAUNEE'S RESPONSE TO NUCLEAR REGULATORY COMMISSION'S REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 2 of 11 DOMINION ENERGY KEWAUNEE'S RESPONSE TO NUCLEAR REGULATORY COMMISSION'S REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE POWER STATION DOCKET NO. 50-305 Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) submitted a request for approval of a proposed amendment to the Kewaunee Power Station (KPS)

Technical Specifications (Reference 1). The proposed amendment would modify KPS Technical Specification (TS) by adopting a new program for control room habitability in accordance with Technical Specification Task Force (TSTF) traveler TSTF-448-A (Reference 2.) and other associated changes to incorporate this program.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 3). The RAI questions and associated DEK responses are provided below.

By letter dated September 14, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072620144), Dominion Energy Kewaunee Inc.

(DEK) submitted a request for an amendment to the technical specifications (TSs) associated with the control room post-accident recirculation system at Kewaunee Power Station (KPS). In reviewing the application, the Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed in order to complete its review:

Question 1a:

1. On page 4 of Attachment 1 to the application, the following TS change was proposed:

Modify KPS TS Table TS 3.5-4, "Instrument Operating Conditions for Isolation" to include a "Control Room Isolation" function.

a. Provide the set point value for the control room radiation monitor R-23, and describe the methodology used to choose this set point value.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 3 of 11 DEK Response:

The response to Question 1b, below, contains further background and details on the operation of R-23. The response to this question has been confined to the setpoints for R-23.

The R-23 radiation monitor has an alert and an alarm set point. The alert setpoint alerts the operators of an off-normal condition while the alarm setpoint alerts the operators of a worsening off-normal condition, and actuates control room ventilation isolation and post-accident recirculation. Normal background radiation levels are approximately 100 to 130 CPM. The alert set point is 5.00 x 103 CPM (counts per minute) while the alarm set point is 1.00 x 104 CPM.

The current setpoints of this monitor are selected to be approximately one and one-half decades above normal background radiation levels for the alert setpoint and approximately two decades above normal background radiation levels for the alarm setpoint.

These setpoints have been demonstrated to be effective at protecting the control room operator for the events where R-23 is credited for mitigation of the event as discussed in section 3.4 and 4.1 of the original license amendment request 210 (Reference 1). See these discussions for further details.

Question 1b:

b. Describe how this value is used to actuate the control room isolation function, including the comparison and actuation devices. This may be done by providing a logic diagram and the description of the circuitry.

DEK Response:

Process Radiation Channel R-23 continuously monitors the Control Room environment for an indication of airborne activity (radiation) entering through the Control Room ventilation system. If R-23 senses a high radiation condition, the monitor initiates closure of the outside air intake, provides a signal that isolates the control room ventilation system and starts the control room post-accident recirculation system. This radiation monitor is equipped with a beta-sensitive plastic scintillator detector that is mounted in the air supply duct to the Control Room.

Indication is provided in the Control Room on multipoint recorders and at a rate meter station with two alarm settings, called alert (low) and alarm (high). The high or alarm

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 4 of 11 circuit actuates the necessary dampers and fans to isolate the Control Room environment and recirculate the air through High Efficiency Particulate Air (HEPA) filters and charcoal adsorber banks. This monitor has a measuring range of 4.31 E-7 to 4.31 E-1 uCilcc.

The radiation monitor is designed to function in the following manner (see Figure 1).

The detector in R-23 generates pulses which are fed through a signal pre-amplifier then through a signal filter that converts the pulse signal into a 3D-second averaged output signal. This 3D-second averaged signal is then compared to the alert and alarm setpoints.

When the 30-second averaged signal exceeds a pre-selected alarm setpoint, an alarm signal is generated. The signal is "locked in" until reset by use of a key switch located on the front panel of the radiation monitor channel. When an alarm signal is generated, an inhibit signal is sent to the opening logic associated with the control room inlet isolation dampers open control circuit causing the control room ventilation inlet isolation dampers to fail closed.

In Figure 1 dampers ACC-1A and ACC-1 B are isolation dampers for redundant control room intake ducts. Dampers ACC-2 and ACC-5 are redundant isolation dampers upstream of ACC-1A and ACC-1 B. For a flow diagram of the Kewaunee control room air conditioning system, see the KPS USAR (Reference 4, Figure 9.6-6, "Control Room Air Conditioning System-Flow Diagram").

Question 1c:

c. Provide the set point values of the control room area radiation monitor R-1, the fuel handling area monitor R-5, and the auxiliary building ventilation exhaust monitors R-13 and R-14, and describe the methodology used to choose these set point values.

DEK Response:

Setpoi nts for R-1 . R-5. R-13 and R-14 Each of the radiation monitors (R-1, R-5, R-13 and R-14) is designed to annunciate upon reaching two separate setpoints: an alert and an alarm setting. Actuation of either annunciator setting warns the operators to the presence of an abnormal condition as measured by the radiation monitor. R-1 and R-5 are area radiation monitors and therefore only provide alarm functions. R-13 and R-14 are gaseous effluent process monitors and provide an associated automatic action that occurs at the alarm setpoint threshold.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 5 of 11 Table 1 below provides the alert and alarm settings for the subject radiation monitors.

TABLE 1 RADIATION MONITOR SETPOINTS RADIATION MONITOR ALERT SET POINT ALARM SET POINT R-1 2 mR/hr 5 mR/hr R-5 10 mR/hr 50 mR/hr R-13 2 x 104 CPM 8 x 104 CPM R-14 2 x 104 CPM 8 x 104 CPM Setpoi nt Methodology R-1 , "Control Room Area Radiation Monitor" The R-1 radiation monitor channel utilizes a fixed position gamma sensitive GM tube detector. The detector output is amplified and the log count rate is determined by the integral amplifier at the detector. The radiation level is indicated in the Control Room where it is recorded. The computer-indicator module amplifies the radiation level signal, as computed by the low-level amplifier, for indication and recording. A high radiation alarm is displayed on the radiation-monitoring panel in the Control Room.

A meter is mounted on the front of the R-1 computer indicator module and is calibrated logarithmically from 0.1 mR/hr to 100 R/hr. Normal background radiation levels for the R-1 monitor are typically in the 0.1 - 0.2 mR/hr range. The setpoints for R-1 were determined based on values that are considered statistically significantly above normal background levels.

R-5, "Fuel Handling Area Radiation Monitor" The R-5 radiation monitor channel utilizes an ion chamber detector. The detector output is amplified and the log count rate is determined by the integral amplifier at the detector.

The radiation level is indicated locally at the detector, and in the Control Room where it is recorded. The computer-indicator module amplifies the radiation level signal, as computed by the low-level amplifier, for indication and recording. A high radiation alarm is displayed on the radiation-monitoring panel in the Control Room, and at the detector location.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 6 of 11 A meter is mounted on the front of the R-5 computer indicator module and is calibrated logarithmically from 0.1 mR/hr to 100 R/hr. Normal background radiation levels for the R-5 monitor are typically in the 0.1 - 0.2 mR/hr range. The setpoints for R-5 were determined based on values that are considered statistically significantly above normal background levels.

R-13 and R-14, "Auxiliary Building Vent Monitors" The Auxiliary Building vent monitors are used to monitor the Auxiliary Building ventilation flow path on a continuous basis. The detectors are used to measure airborne radioactivity in the air as it is discharged out the stack.

An off-line sampler is used to monitor and sample the Auxiliary Building ventilation stack. The sampler consists of an isokinetic nozzle inserted in the auxiliary building ventilation ductwork where a representative sample of air is drawn through a series of filters: a particulate filter and a charcoal collection filter. The charcoal filter is used for the accumulation of iodine isotope activity. The particulate filter is used for the collection of particulate activity such as Cs-134 and Cs-137.

When a high activity (high radiation) condition is encountered, the radiation monitor transmits an alarm signal to the Control Room where it is recorded on multipoint recorders and activates alarms. Remote indication and annunciation are provided on the Waste Disposal System control board. Upon receipt of a high radiation alarm, the system performs the following functions:

1. Shuts down normal Auxiliary Building ventilation.
2. Activates the Special Zone Auxiliary Building ventilation.
3. Initiates isolation of all normal ducting to the Auxiliary Building ventilation stack.
4. Closes the waste gas decay tank gas release valve.
5. Reroutes R11/12 sample exhaust flow from Auxiliary Building ventilation to Containment.
6. Isolates the 2-inch containment depressurization line and stops the 2-inch containment supply blower.
7. Automatically diverts the Spent Fuel Pool Ventilation System exhaust through its charcoal filter banks.
8. Automatically isolates the Waste Gas Analyzer via redundant isolation valves.

These monitors have a measuring range of 4.31 E-7 to 4.31 E-1 uCi/cc.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 7 of 11 The set poi nts for R-13 and R-14 are determi ned in accordance with the Offsite Dose Calculation Manual (ODCM) (Reference 5). Per the requirements of the KPS ODCM, alarm setpoints are established for the gaseous effluent monitoring instrumentation to ensure that the release rate of noble gases does not exceed corresponding dose rate at the site boundary of 500 mR/year to the total body or 3000 mR/year to the skin. The ODCM also limits the dose rate to no more than 1500 mR/yr to any organ for 1-131, 1-133, tritium and other radionuclides in particulate form with half lives of > 8 days.

Additionally, the KPS ODCM provides the equations used in calculating the radiation monitor alarm setpoints for an actual or default value. DEK uses conservative default values to eliminate the potential need for periodic adjustment of the setpoint to reflect minor changes in radionuclide distribution and variations in release rate. These conservative default values are based on the maximum ventilation flow rate, a bounding radionuclide distribution, and application of a 0.5 multiplier to assure that any simultaneous releases do not exceed the maximum allowable release rate in the ODCM.

Question 2:

2. On page 5 of Attachment 1, the proposed TS change to modify KPS current TS
4. 17.a.2 states:

Automatic initiation of each train on an actual or simulated actuation signal.

a. Does DEK use or plan to use an actual or simulated signal?
b. If DEK plans to use simulated actuation signal, provide the diagram and description of how the signal is generated, and how the control room post-accident recirculation system will be tested.

DEK Response:

DEK plans to use a simulated signal to test R-23.

DEK performs a quarterly test to verify operability of R-23 using the test mode feature built into the detector. In test mode, the detector signal is replaced by an 80,000 CPM pulse stream originating from a light emitting diode mounted in the light pipe of the detector. This pulse stream tests the light pipe, photomultiplier tube, cabling, rate meter, alarm set points and alarm circuitry. When R-23 is functioning properly the test signal of 80,000 CPM will trigger the R-23 high alarm, close the control room ventilation inlet isolation dampers, and activate the Control Room Post Accident Recirculation system.

The quarterly test procedure requires documentation of the observed count rate and verification that all components of the Control Room Post Accident Recirculation system actuated as expected.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 8 of 11 Question 3:

3. TS Task Force (TSTF) Change Traveler TSTF-448, "Control Room Habitability",

was developed for plants with pressurized control room envelopes (CREs). DEK stated that KPS has a non-pressurized CRE. Note that in the programs and manuals section of the standard technical specifications (S TS), as modified by TSTF-448 revision 3, paragraph (d) of Section [5.5. 18J, "Control Room Envelope Habitability Program," specifies a differential pressure (dp) test to be conducted between performances of inleakage testing for the purpose of providing input to a periodic assessment of the CRE boundary. The NRC staff recognizes that non-pressurized CREs may not be able to conduct a dp test. Nevertheless, the NRC staff believes that all licensees requesting the adoption of TSTF-448 should include in its request, a method to collect data that will serve as input to a periodic assessment of the CRE boundary. This position is supported by the technical analysis section of TSTF-448, revision 3, on page 8 where an explanation of the basis for paragraph (d) was provided. Consequently, the NRC staff is requesting that you provide a method to collect data, and an explanation of how you intend to use it, so that it can be used as input to a periodic assessment of your CRE boundary. The method should, to the extent practicable, provide information similar to the information requested by paragraph (d) of section [5.5.18J of the programs and manuals section of the STS as modified by revision 3 of TSTF-448.

DEK Response:

DEK recognized that TSTF-448, Revision 3 specified in Section 5.5.18, paragraph d a differential pressure test was to be conducted between performances of inleakage testing for the purpose of providing input to a periodic assessment of the CRE boundary. As the NRC has noted, the KPS control room ventilation system is designed to maintain the control room at a neutral pressure. As a neutral pressure control room, the results of measuring differential pressure between the control room and adjacent areas are subject to much variation. This variation may be caused by ventilation system configurations, location and sensitivity of instrumentation, and the effects of weather conditions and bUilding structures on intake air. Furthermore, in Generic Letter 2003-01 (Reference 6) the NRC also called into question the usefulness of differential pressure measurements of CREs in general. Based upon this information and a review of the differential pressure data taken during the December 2004 tracer gas testing performed on the KPS CRE*, it is concluded that a pressurization (differential pressure) test for the

  • The test report for the KPS CRE tracer gas test indicated that some adjacent areas were at positive pressure with respect to the eRE and other adjacent areas were at negative pressure.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 9 of 11.

CRE boundary would not yield useful data regarding the status of the KPS neutral pressure control room.

In lieu of a differential pressurization test, DEK conducts preventative maintenance (PM) and surveillance tests (STs) that provide assurance that the CRE boundary is maintained in a manner that will provide protection for the operators. The data from these PMs and STs will be used as a means of monitoring the health of the CRE between the quantitative in-leakage tracer gas tests. A discussion of these PMs and STs are provided below.

1. Damper Maintenance (PM) - Once every two cycle inspection of the Control Room Ventilation dampers' mechanical components and internal blade seals with parts replaced as necessary.
2. Control Room Air Conditioning Mechanical Inspection and Maintenance (PM) -

Once per year inspection and replacement of control room ventilation boundary components including:

  • Door inspections - Inspection and repair/replacement of weather strip seals of the control room envelope doors.
  • Cable tray penetration inspections - Inspection and repair, as necessary, of the relay room electrical cable tray penetrations.
3. Penetration Fire Barrier Inspection (PM) - Once per cycle inspection/repair, as necessary, of fire and steam exclusion barrier penetrations associated with the CRE.
4. Post Accident Recirculation Test (ST) - Monthly functional test of the emergency ventilation filter components.
5. Control Room Post Accident Recirculation Train Operability Testing (ST) -

Monthly functional test of the Control Room emergency ventilation system.

6. Control Room Post Accident Train Recirculation Filter Testing (ST) - At least once per operating cycle test of HEPA filters and charcoal adsorber banks. Fan flows are also obtained during this testing. Fan flows are maintained within allowable limits of design flow rates during this test. The charcoal adsorber flow rates are maintained within the TS limits. Ensuring maintenance of proper flow rates reduces the possibility of control room pressure changes which may affect unfiltered in-leakage.
7. Auxiliary Building Special Ventilation Operability Test (ST) - Monthly verification of closure of some of the CRE boundary dampers, which are also steam exclusion dampers.
8. RMS Channel R-23 Control Room Ventilation Radiation Monitor Quarterly Test (ST) - Quarterly test for actuation of the control room ventilation system from a high radiation signal.

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 10 of 11

9. Barrier Control Procedure - Provides instructions for managing and controlling the integrity of the CRE. This includes permitting and managing opening and total opening size in the CRE, managing impairments and logging TS requirements for the CRE.

Any criteria that are not met while performing any of these activities are documented and resolved in accordance with the KPS Corrective Action Program. Appropriate actions are identified and implemented to restore the degraded conditions and assess the impact on the CRE boundary. These procedures and processes ensure that the KPS CRE boundary can perform its safety function in a similar manner to performing a pressurization test and trending the test data.

References

1. Bischof (DEK) to Document Control Desk, "License Amendment Request 210 -

"Technical Specification Modifications Regarding Control Room Envelope Habitability," dated September 14, 2007 (ADAMS Accession No. ML072620144).

2. Letter, TSTF-448-A, "Control Room Habitability," Revision 3, dated August 8, 2006.

(ADAMS Accession No. ML062210095).

3. Letter from Patrick D. Milano (NRC) to D. A. Christian (DEK), "Kewaunee Power Station - Request for Additional Information Related to Control Room Habitability (TAC No. MD6773)," dated January 30, 2008 (ADAMS Accession No. ML080280107).
4. Updated Safety Analysis Report, Revision 20, dated 12/28/2007.
5. Offsite Dose Calculation Manual (ODCM), Revision 11, dated February 22,2007.
6. Generic Letter 2003-01, "Control Room Habitability", dated June 12,2003 (ADAMS Accession No. ML031620248).

Serial No. 08-0055 Docket No. 50-305 Attachment 1 Page 11 of 11 Figure 1 - R Control Room Ventilation Radiation Monitor r-------------------------------------------------------,

R*23 Check Functional Source Test LED Pre-Amp Filter R23 Failure Safety Injection Train A Safety Injection Train B Steam Exclusion Steam Exclusion Zone SV Area Signal Zone SV Area Signal Train A Train B ACC-1A ACC-18 ACC-5 ACC-2

Serial No. 08-0055 ATTACHMENT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST 210, "TECHNICAL SPECIFICATION MODIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY" REVISED OPERATING LICENSE PAGE 5 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

(11) Upon implementation of Amendment No. xxx, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air in-leakage as required by TS 4.17,c, in accordance with TS 6,23,c,(j), and the assessment of CRE habitability as required by TS 6,23.c.(jj), shall be considered met.

Following implementation:

(a) The first performance of TS 4.17.c, in accordance Yl(ilb I§ §.g3,c,(j}, shall be within the specified Frequency of 6 years, plus the J ' _ allowance of TS 4,0 b. as measured from December 15, 2004. the date of the most recent successful tracer gas test. as stated in the April 1r 2005 letter response to Generic Letter 2003-01 r or within the next 1:1:~:_thi if the time period since the most recent successful tracer gas test is greater than 6 years, (b) The first performance of the periodic assessment of CRE habitability. TS 6,23.c.(jj), shall be within 3 years. plus the 9-month allowance of TS 4.Q,b, as measured from December 15. 2004, the date of the most recent successful tracer gas test. as stated in the April 1. 2005 letter response to Generic Letter 2003-01. or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years, D, The licensee shall comply with applicable effluent limitations and other limitations and monitoring requirements, if any, specified pursuant to Section 401 (d) of the Federal Water Pollution Control Act Amendments of 1972, E. This license is effective as of the date of issuance, and shall expire at midnight on December 21, 2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A, Giambusso, Deputy Director for Reactor Projects Directorate of Licensing

Attachment:

Appendices A and B - Technical Specifications Date of Issuance: December 21, 1973

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