ML12272A343

Submittal of Atmospheric Relative Concentration Values for Use in Control Room Envelope Radiological Dose Analysis

ML12272A343
Person / Time
Site:	Mcguire, 05000360
Issue date:	09/25/2012
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12272A343 (16)

Text

Duke STEVEN D. CAPPS Vice President

• Energy, McGuire Nuclear Station Duke Energy MG01VP / 12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4805 980-875-4809 fax Steven. Capps@duke-energy.com September 25, 2012 10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTENTION: Document Control Desk

Subject:

Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Submittal of Atmospheric Relative Concentration Values for use in Control Room Envelope Radiological Dose Analysis In accordance with the provisions of 10 CFR 50.90, Duke Energy Carolinas, LLC (Duke Energy) proposes a license amendment request (LAR) for the Renewed Facility Operating Licenses (FOL) for McGuire Nuclear Station, Units 1 and 2 (McGuire). The proposed LAR submits selected atmospheric relative concentration values (x/Q) for use in Control Room radiological dose analysis that were withdrawn during McGuire's request for full scope implementation of the Alternate Source Term (AST). McGuire received NRC approval for full scope implementation of AST on March 31, 2009 (ADAMS ML090890627).

By letter dated February 12, 2009 (ADAMS ML090540682), McGuire withdrew several release points from consideration for NRC review including points that were discovered to have a source-to-receptor distance of less than ten meters. Section C.3.4 of Regulatory Guide 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants," Rev. 0, does not allow the use of the ARCON96 computer code to calculate X/Q values at a distance of less than ten meters without a case-by-case review from the NRC. The removal from consideration for NRC review of these release points is also documented in Section 3.2.2 of the NRC's Safety Evaluation for McGuire's full scope AST dated March 31, 2009.

McGuire is now prepared to submit selected points for NRC review and has developed a sensitivity analysis for the points with a source-to-receptor distance of less than ten meters.

The proposed analysis was discussed with the NRC staff during a conference call on September 23, 2010. Release points that do conform to Regulatory Guide 1.194 are also being submitted at this. time.

www.duke-energy.com A

U. S. Nuclear Regulatory Commission September 25, 2012 Page 2 provides Duke Energy's evaluation of the LAR which contains a description of the proposed changes, the technical evaluation, the regulatory analysis, precedent, the determination that this LAR contains No Significant Hazards Considerations, and the basis for the categorical exclusion from performing an Environmental Assessment/Impact Statement. provides a drawing with relative locations of these release points and the Control Room intakes.

Duke Energy requests NRC review and approval of this LAR within one year of submittal. Duke Energy has determined that a 60 day implementation grace period will be sufficient to implement this LAR.

This LAR contains no regulatory commitments.

Necessary revisions to the McGuire Updated Final Safety Analysis Report (UFSAR) will be made in accordance with 10CFR50.71(e).

In accordance with Duke Energy internal procedures and the Quality Assurance Topical Report, the proposed amendment has been reviewed and approved by the McGuire Plant Operations Review Committee.

Pursuant to 10CFR50.91, a copy of this LAR has been forwarded to the appropriate North Carolina state officials.

Please direct any questions you may have in this matter to Lee A. Hentz at (980) 875-4187.

Sincerely, Steven D. Capps Attachments

U. S. Nuclear Regulatory Commission September 25, 2012 Page 3 cc w/ Attachments:

V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)

Project Manager (McGuire)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 W. L. Cox III, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645

U. S. Nuclear Regulatory Commission September 25, 2012 Page 4 Steven D. Capps affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Stev~n D. Capp,, Si 1ice President, McGuire Nuclear Station Subscribed and sworn to me: 6 kVh SQ p4Date "*//*"f2' n&, J., I , Notary Public My commission expires: ON /4 Date

ATTACHMENT 1 EVALUATION OF PROPOSED AMENDMENT 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENT 1 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Duke Energy Carolinas (Duke Energy) proposes a license amendment request (LAR) for McGuire Nuclear Station (McGuire) to submit selected atmospheric relative concentration values (x/Q) for use in Control Room radiological dose analyses that were withdrawn during McGuire's request for full scope implementation of the Alternate Source Term (AST). McGuire received NRC approval for full scope implementation of AST on March 31, 2009 (ADAMS ML090890627).

By letter dated February 12, 2009 (ADAMS ML090540682), McGuire withdrew several release points from consideration for NRC review including points that were discovered to have a source-to-receptor distance of less than ten meters. Section C.3.4 of Regulatory Guide (RG) 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants," Rev. 0, does not allow the use of the ARCON96 computer code to calculate X/Q values at a distance of less than ten meters without a case-by-case review from the NRC. The removal of these release points from consideration for NRC review is also documented in Section 3.2.2 of the NRC's Safety Evaluation for McGuire's full scope AST dated March 31, 2009. This request submits the following release points:

" Main steam line break from a break in the yard (MSLBy)

• Inboard/outboard doghouse release (DOGin and DOGout)

Duke Energy has developed, for NRC review, a sensitivity analysis for the main steam line break release points which have a source-to-receptor distance of less than ten meters. The proposed analysis was discussed with the NRC staff during a conference call on September 23, 2010. The doghouse release points could be assumed to be an area source but now have been conservatively modeled as a line source in conformance with RG 1.194.

2.0 DETAILED DESCRIPTION Control room X/Q values for several release points at McGuire have been re-evaluated. These points include: a main steam line break from a break in the yard (MSLBy) and an inboard and outboard doghouse release (DOGi, and DOGut). These release points and the control room intakes are shown on Attachment 2.

2.1 MSLB FROM A BREAK IN THE YARD (MSLBy) 2.1.1 Main Steam Line Release Points The inboard main steam line source in the yard at McGuire is within ten meters of the control room air intake receptor at its closest point (7.5 meters), which makes it necessary to conduct a sensitivity analysis for the case of a main steam line break (MSLB) occurring at that closest distance. The outboard main steam line in the yard is also within ten meters of the control room air intake receptor (9.5 meters) at its closest point.

Section C.3.4 of RG 1.194 states that ARCON96 should not be used for source-receptor pairs separated by distances less than about ten meters. This guidance also specifies that such an arrangement should be analyzed on a case by case basis. A sensitivity analysis was conducted 1

ATTACHMENT 1 by Duke Energy to test the validity of source-to-receptor distances less than ten meters in ARCON96. All analyzed sources were modeled as ground level releases by conservatively setting the vertical velocities to zero meters/second (m/s) in ARCON96, in spite of the release being thermally buoyant relative to the surrounding atmosphere. An additional conservatism includes the use of a point source to represent the break in the main steam line.

2.1.2 Methods and Assumptions for MSLB Sensitivity Analysis In an effort to determine any instability or inconsistency of ARCON96 for distances less than ten meters, a sensitivity analysis described below was performed. This analysis varied the distance along the direction of the minimum distance location between the main steam line and control room intakes from one meter up to 100 meters. Further analysis varied the source locations along the main steam line at multiple distances and receptor-source angles to assess how ARCON96 performs for points that do not meet the ten meter separation criterion outlined in RG 1.194. Varying the release point along the main steam line also ensured that the point of minimum distance actually maximizes the x/Q for the McGuire site geometry and meteorological conditions as there is no fixed release point (i.e. valve) along the steam line. Results show a well-behaved X/Q curve that peaks at the closest point and decreases steadily as the distance from source-to-receptor increases. This sensitivity analysis was performed for both units, for inboard and outboard steam lines.

2.1.3 MSLB Sensitivity Analysis Conclusions The sensitivity analysis shows that ARCON96 produced reasonable and well-behaved results for source-receptor pairs less than ten meters while still preserving the intended conservatism of the model.

2.2 MSLB INSIDE THE DOGHOUSE (DOGIN AND DOGOUT)

The doghouses at McGuire are the large reinforced structures directly attached to containment which house the main steam isolation valves and other equipment. There are two doghouses per each unit. A steam release could occur inside the doghouse as a result of a failure in the secondary system piping. The release pathway from the doghouse for any effluent would be from a series of louvers near the top of the doghouse. Theses louvers are located on the three sides of each doghouse. Although these openings could be assumed to be an area source, they have been conservatively modeled as a line source. The line source was created by assuming a vertical diffusion coefficient (a,) of zero and calculating the horizontal diffusion coefficient (ay) as the width of the total opening divided by six. Per Regulatory Guide 1.194 Section 3.2.4.5, the release is assumed to originate from a line projected perpendicular to the line of sight between the receptor and the building surface closest to the control room intake.

Cross unit release X/Q values are derived based on the doghouse releases modeled as point sources. Releases from within the doghouses could place both intake pairs within the 90 degree window centered about the line drawn between the source and closest receptor.

The entire release inside the doghouse was conservatively assumed to preferentially flow through only the louvers on the side adjacent to the control room intakes.

2

ATTACHMENT 1

3.0 TECHNICAL EVALUATION

Control room X/Q results are presented and discussed in this section. Geometry information is provided for each release location analyzed. Meteorological data spanning the years 2001 to 2005 was used for this analysis. Duke Energy previously submitted this data to the NRC on a compact disc by the AST LAR RAI response letter dated December 17, 2008. Additional input is summarized in Table 1 below.

Table 1: Dispersion Factor Geometry Information Source Type: MSLBy DOGin DOGout Release Height 1.5 m 12.2 m 12.2 m Sigma-Y 0m 1.48 m 1.48 m Sigma-Z 0m 0m 0m Bldg Cross-sectional Area (Use 0.01 m 2 if assuming 0 per 0.01 m 2 0.01 m 2 0.01 m 2 Regulatory Guide 1.194)

Same Unit (Unit 1):

Distance Dsouceand Between weeo 7.5 m / 1920 32.5 m /920 11.8 m / 3090 Source and Receptor /

Release Angle Same Unit (Unit 2):

Distance Disourcean Between weepr 7.5 m /1920 32.5 m /2940 11.8 m /730 Source and Receptor /

Release Angle Cross Unit (Unit 2 Source to Unit 1 Intake)

Distance Between 108 m / 1060 69.2 m /97 0 101.7 m /104 0 Source and Receptor/

Release Angle Cross Unit (Unit 1 Source to Unit 2 Intake):

Distance Between 108 m / 278' 69.2 m / 2870 101.7 m / 2800 Source and Receptor/

Release Angle 3.1 MSLB FROM A BREAK IN THE YARD (MSLBy) 3.1.1 Source-Receptor Characterization Table 1 contains the required information for modeling the source-receptor geometry relationship in ARCON96 for the MSLB from a break in the yard.

3.1.2 MSLB From a Break in the Yard Sensitivity Analysis Results The closest point on each steam line relative to the control room intakes is less than the ten meters minimum limit set forth in Regulatory Guide 1.194. To evaluate the source-receptor 3

ATTACHMENT 1 distance limitations of ARCON96, a sensitivity analysis was performed for the inboard and outboard steam lines for the MSLBY release point. Hypothetical release points were assumed, extending from the intake toward the point representing the minimum distance to the steam line and beyond. This sensitivity analysis only analyzes the site specific layout and other parameters relating only to the MSLBy accident at McGuire.

As the separation between source and receptor approaches zero, X/Q asymptotically approaches infinity. This relationship exists due to the mathematical models representing the diffusion coefficients in ARCON96. The X/Q values attained from the evaluation of each meteorological data point in ARCON96 are binned such that a resulting distribution can be created. Appropriate behavior would be represented by a monotonic series of data where the X/Q values increase at an exponential rate as separation distance decreases. Figure 1 shows the results for the Unit 1 MSLBy case. Note that these results are reasonable and well-behaved for source-receptor distances greater than 2.3 meters. Attempts to use ARCON96 for distances equal to or less than 2.3 meters (significantly less than any source-receptor distance at McGuire) produced error messages. Similar studies were made for the outboard MSLBy however a height difference of 4.5 meters between the source and the intake allows ARCON96 to calculate well-behaved results for all postulated horizontal distances between one and twenty meters without producing error messages. Unit 2 exhibited the same behavior which was expected due to plant symmetry.

Figure 1 - Unit 1 Inboard MSLB Variable Distance Sensitivity Unit 1 Inboard MSLB ARCON96 Variable Distance Sensitivity 1.OOE+O0 Ln.0E-01 E

X 1.OOE-02 1.OOE-O*3 -

1.OOE-04 0 10 20 30 40 50 60 70 80 90 100 Distance to Intake from Hypothetical Release Point (m)

The sensitivity analysis also examined points along the steam lines in the general area of the intake (See Figure 2). This ensured that the minimum distance case is truly the most limiting release point, since the wind variability coupled with the receptor-to-source angles could result in a release point farther away being the limiting dispersion factor. Figure 2 shows the X/Q 4

ATTACHMENT 1 results for release points along the Unit 1 inboard steam line with distance along the steam line being relative to the point of minimum distance to the intake.

Figure 2 - Unit 1 Inboard MSLB Variable Receptor-to-Source Angle Sensitivity Unit 1 Inboard MSLB Variable Receptor to Source Angle Sensitivity 1.OOE-01 9.10E-02 9.OOE-02 8.OOE-02 7.OOE-02 en 0 6.OOE-02 E

5.OOE-02 ci p 4.OOE-02 x ____(___ 0 3.OOE-02 U -U000 2.OOE-02 1.OOE-02 0.OOE+00

-10.00 -5.00 0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 Distance from closest release point along MSL (m)

The outboard MSLBy yielded similar findings. Unit 2 exhibited the same behavior which was expected due to plant symmetry. The results of the variable receptor-to-source angle indicate there is nothing McGuire site specific which is more bounding than the minimum distance scenario for the MSLB in the yard.

3.1.3 ARCON96 X/Q Results for MSLB from a break in the yard Using input from Table 1, ARCON96 produces the results detailed in Table 2. The dispersion factors reported in these tables reflect the maximum values from either Unit 1 or Unit 2.

Table 2 - MSLB ARCON96 X/Q Results Time Period Same Unit Inboard Cross Unit Inboard Same Unit Outboard TimePeriod I/Q (s/m3) x/Q (s/m 3) X/Q (s/m 3) 0 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 9.1OE-02 5.81 E-04 4.63E-02 2 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8.41 E-02 4.08E-04 3.42E-02 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 3.69E-02 1.61 E-04 1.25E-02 1 to 4 days 2.76E-02 1.24E-04 9.66E-03 4 to 30 days 2.09E-02 9.49E-05 7.45E-03 5

ATTACHMENT 1 3.2 MSLB Inside the Doghouse (DOGIN AND DOGOUT)

Table 1 contains the necessary geometry information to model the dispersion factors for a release from either the inboard or outboard doghouses. No vertical velocity or building cross section areas are modeled. These releases were modeled in accordance with RG 1.194.

The dispersion factors reported in this table reflect the maximum values from either Unit 1 or Unit 2.

Table 3 -Doghouse ARCON96 X/Q Results Same Unit Same Unit Cross Unit Inboard Outboard Outboard Doghouse X/Q Doghouse X/Q Doghouse X/Q 3

(s/m 3

) (s/e ) ( s/re 3

)

0 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 4.61 E-03 1.70E-02 6.54E-04 2 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 3.87E-03 1.62E-02 4.62E-04 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1.60E-03 7.61 E-03 1.75E-04 1 to 4 days 1.17E-03 5.53E-03 1.36E-04 4 to 30 days 8.53E-04 4.20E-03 1.05E-04 3.3 Dual Ventilation Outside Air Intakes All X/Q values presented in this document reflect the raw output from ARCON96. In some cases, a MSLB could occur at a location where both intakes are within the 90 degree window and both intakes would be contaminated but those instances are bounded by the limiting case shown in Section 3.1.3. The limiting case for the MSLB accident would not have both intakes in the 90 degree window.

3.4 Summary Dispersion factors have been calculated in accordance with Regulatory Guide 1.194. All submitted dispersion factors are provided in Tables 2 and 3.

4.0 REGULATORY SAFETY ANALYSIS 4.1 Applicable Regulatory Requirements/Criteria General Desian Criterion (GDC) 19. Control Room A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident 6

ATTACHMENT 1 conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

GDC-19 is the current licensing basis for the McGuire control room as discussed in UFSAR Sections 3.1 and 6.4. Radiological consequences for the loss of coolant accidents (LOCA) and MSLB are currently less than 5 rem total effective dose equivalent (TEDE) for the duration of the accident in accordance with 10 CFR 50.67 (AST). Following approval of this proposed amendment, the provisions of GDC-19 will continue to apply to McGuire.

Regulatory Guide 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants," Rev. 0.

Regulatory Guide (RG) 1.194 describes methods acceptable to the NRC for determining atmospheric relative concentration (X/Q) values that will be used in control room radiological habitability assessments performed in support of license amendments.

Section C.3.4 of RG 1.194 does not allow the use of the ARCON96 computer code to calculate x/Q values at a distance of less than ten meters without a case-by-case review from the NRC.

This proposed amendment provides a sensitivity analysis and industry precedent for the use of RG 1.194 guidance for release points under ten meters. Release points that do conform to RG 1.194 are also being submitted at this time. This proposed amendment submits X/Qs that were accurately calculated and in conformance with NRC guidance. The meteorological inputs previously submitted to the NRC and used to calculate these X/Qs were not revised or updated.

4.2 Precedent Waterford 3 (Entergy) submitted an AST LAR on July 15, 2004 (ADAMS ML042020294) which involved a release point at 6.6 meters. Waterford received NRC approval for AST on March 29, 2005 (ADAMS ML050890248). In addressing this X/Q, the original LAR references a response to RAIs from their concurrent request for an extended power uprate (EPU) LAR dated March 4, 2004 (ADAMS ML040690028). In the EPU LAR RAI Question 2 response, Waterford justified by analysis the use of ARCON96 for an atmospheric dump valve (ADV) release point 6.6 meters from the control room intake.

4.3 Significant Hazards Consideration In accordance with the provisions of 10 CFR 50.90, Duke Energy Carolinas (Duke Energy) proposes a license amendment request (LAR) for McGuire Nuclear Station (McGuire) to submit selected atmospheric relative concentration values (X/Q) for use in control room radiological dose analysis that were withdrawn during McGuire's request for full scope implementation of the Alternate Source Term (AST).

By letter dated February 12, 2009, McGuire withdrew several release points from consideration for NRC review including points that were discovered to have a source-to-receptor distance of less than ten meters, which cannot be evaluated by Regulatory Guide (RG) 1.194 guidance without NRC review. This LAR provides a sensitivity analysis for the use of RG 1.194 guidance 7

ATTACHMENT 1 for the release points under ten meters. Release points that do conform to RG 1.194 are also being submitted at this time.

Duke Energy has concluded that operation of McGuire in accordance with the proposed changes does not involve a significant hazards consideration. Duke Energy's conclusion is based on its evaluation, in accordance with 10CFR50.91 (a)(1), of the three standards set forth-in 10CFR50.59(c) as discussed below:

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

Response: No.

This proposed amendment submits x/Qs that were accurately calculated and in conformance with NRC guidance. Meteorological inputs that were previously submitted to the NRC and used to calculate these X/Qs were not revised or updated nor has any of the dose release points changed. Accident mitigation procedures and controls are in no way affected by this amendment. Duke Energy has also ensured that the control room doses determined with these re-calculated X/Qs are within the 10 CFR 50.67 AST limits.

As such, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This proposed amendment is analytical in nature. It does not involve a plant modification or a change in how the plant is operated. No new accident causal mechanisms are created as a result of this proposed amendment. No changes are being made to any structure, system, or component which will introduce any new accident causal mechanisms. This amendment request does not impact any plant systems that are accident initiators and does not impact any safety analysis.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in the margin of safety?

Response: No.

Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following accident conditions. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The proposed re-calculation of the X/Qs will have no affect on the performance of these barriers. This proposed amendment does not involve an addition or modification to any plant system, structure, or component. This proposed amendment will not affect the post accident operation of any plant system, structure, or component as directed in plant procedures.

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ATTACHMENT 1 Therefore, it is concluded that the proposed amendment does not involve a significant reduction in the margin of safety.

4.4 Conclusions Based upon the above evaluation, Duke Energy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

5.0 ENVIRONMENTAL CONSIDERATION

Duke Energy has evaluated the proposed amendment and has determined that this change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

6.0 REFERENCES

1. Letter from Thomas C. Geer (Duke Energy) to USNRC, Duke Energy Carolinas,LLC (Duke Energy), McGuire Nuclear Station Units 1 and 2, Dockets Nos. 50-369 and 50-370, Response to Request for Additional Information Related to the License Amendment Request (LAR) for Implementation of Alternative Source Term, February 12, 2009 (ADAMS ML090540682).

2. Letter from John Stang (USNRC) to Bruce H. Hamilton (Duke Energy), McGuire Nuclear Station Units I and 2, Issuance of Amendments Regarding Adoption of the Alternative Source Term RadiologicalAnalysis Methodology (TAC Nos. MD8400 and MD8401),

March 31, 2009 (ADAMS ML090890627).

3. US Nuclear Regulatory Commission Regulatory Guide 1.194, Atmospheric Relative Concentrationsfor Control Room RadiologicalHabitabilityAssessments at Nuclear Power Plants, Original Issue, June 2003.

4. Letter from Jon Thompson (USNRC) to Duke Energy, Summary of September 23, 2010, Conference Call with Duke Regarding PotentialLicense Amendment Request (TAC Nos.

ME4655 and ME4656), November 3, 2010 (ADAMS ML102730785).

5. Letter from Joseph E. Venable (Entergy) to USNRC, License Amendment Request NPF-38-256Alternate Source Term, Waterford Steam Electric Station Unit 3, Docket No.

50-382, License No. NPF-38, July 15, 2004 (ADAMS ML042020294).

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ATTACHMENT 1

6. Letter from N. Kalyanam (USNRC) to Joseph E. Venable (Entergy), Waterford Steam Electric Station Unit 3 (Waterford 3) - Issuance of Amendment Re: Full-Scope Implementation of an Alternative Accident Source Term (TAC No. MC3789), March 29, 2005 (ADAMS ML050890248).

7. Letter from Ken Peters (Entergy) to USNRC, Supplement to Amendment Request NPF-38-249Extended Power Uprate, Waterford Steam Electric Station Unit 3, Docket No. 50-382, License No. NPF-38, March 4, 2004 (ADAMS ML040690028).

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