NRC 2008-0018, License Amendment Request 259, Application for Tech Spec Improvement to Adopt TSTF-490, Rev. 0, Deletion of E Bar Definition and Revision to Reactor Coolant System (RCS) Specific Activity Technical Specification

License Amendment Request 259, Application for Tech Spec Improvement to Adopt TSTF-490, Rev. 0, Deletion of E Bar Definition and Revision to Reactor Coolant System (RCS) Specific Activity Technical Specification

ML080930073
Person / Time
Site:	Point Beach
Issue date:	03/31/2008
From:	Mccarthy J Florida Power & Light Energy Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC 2008-0018
Download: ML080930073 (25)

Text

FPL Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 FPL Energy Point Beach Nucilear Plant March 31,2008 NRC 2008-0018 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Request 259 Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to Reactor Coolant System (RCS) Specific Activitv Technical Specification

References:

(1) Nuclear Regulatory Commission (NRC) Safety Evaluation (SE) approving TSTF-490, Revision 0, (ML070250176)

(2) Federal Resister Notice for Comment published on November 20, 2006, 71 FR 67170, (ML062780062)

(3) Federal Renister Notice of Availability dated March 15, 2007, 72 FR 12217 (ML070250176)

In accordance with the provisions of 10 CFR 50.90, "Application for amendment of license or construction permit," FPL Energy Point Beach, LLC is submitting a request for an amendment to the Point Beach Nuclear Plant (PBNP) Technical Specifications (TS) for Facility Operating Licenses DPR-24 and DPR-27, Units 1 and 2, respectively.

The proposed amendments would replace the current TS 3.4.16 limit on reactor coolant system (RCS) gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new DOSE EQUIVALENT Xe-133 (DEX) definition that would replace the current E Bar AVERAGE DISINTEGRATION ENERGY definition. In addition, the current DOSE EQUIVALENT 1-131 (DEI) definition would be revised to clarify the use of additional thyroid dose conversion factors (DCFs).

The proposed changes are consistent with NRC-approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Technical Specification." The availability of this TS improvement was announced in the Federal Resister on March 15, 2007, 72 FR 12217, as part of the consolidated line item improvement process (CLIIP).

An FPL Group company

Document Control Desk Page 2 Enclosure 1 provides a description and assessment of the proposed changes, as well as confirmation of applicability. Enclosure 2 provides the existing TS pages marked-up to show the proposed changes. Enclosure 3 provides the existing TS Bases pages marked-up to show the proposed changes.

FPL Energy Point Beach requests approval of the proposed license amendment by September 30, 2008. Once approved, the amendment will be implemented within 30 days.

This submittal has been reviewed by the Plant Operations Review Committee. This application contains no new commitments or revisions to existing commitments.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Wisconsin Official.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 31,2008.

Very truly yours, FPL ENERGY POINT BEACH, LLC r - d f 7

/ Site Vice President  !

Enclosures cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE I FPL ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS IAND 2 LICENSE AMENDMENT REQUEST 259 DELETION OF E BAR DEFINITION AND REVISION TO T HE REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATION IN ACCORDANCE WITH TSTF-490, REVISION 0,

SUMMARY

DESCRIPTION PROPOSEDCHANGES BACKGROUND TECHNICAL ANALYSIS REGULATORY ANALYSIS NO SIGNIFICANT HAZARDS CONSIDERATION ENVIRONMENTAL CONSIDERATION REFERENCES 3 pages follow

1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," FPL Energy Point Beach proposes changes to Renewed Licenses Nos. DPR-24 and DPR-27 and Technical Specifications for Point Beach Nuclear Plant, Units 1 and 2, respectively.

The proposed changes would replace the current limits on primary coolant gross specific activity with limits on primary coolant noble gas activity. The noble gas activity would be based on DOSE EQUIVALENT Xe-133 and would take into account only the noble gas activity in the primary coolant. The changes were approved by the NRC staff Safety Evaluation (SE)

(ML070250176) (Reference 1). Technical Specification Task Force (TSTF) change traveler TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Technical Specification," was announced for availability in the Federal Reaister on March 15, 2007 (ML070250176) (Reference 3), as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

S Consistent with NRC-approved TSTF-490, Revision 0, the proposed TS changes:

A. Revise the definition of DOSE EQUIVALENT 1-131 B. Delete the definition of "E Bar, AVERAGE DISINTEGRATION ENERGY."

C. Add a new TS definition for DOSE EQUIVALENT Xe-133.

D. Revise LC0 3.4.16, "RCS Specific Activity" to delete references to gross specific activity; add limits for DOSE EQUIVALENT 1-1 31 and DOSE EQUIVALENT Xe-133; and delete Figure 3.4.16-1, "Reactor Coolant DOSE EQUIVALENT 1-131 Specific Activity Limit versus Percent of RATED THERMAL POWER."

E. Revise LC0 3.4.16 "APPLICABILITY to specify the LC0 is applicable in MODES 1, 2, 3, and 4.

Page 1 of 3

F. Modify ACTIONS Table as follows:

1. CONDITION A is modified to delete the reference to Figure 3.4.16-1, and define an upper limit that is applicable at all power levels.

2. CONDITION B is modified to provide a CONDITION and REQUIRED ACTION for DOSE EQUIVALENT Xe-133 instead of gross specific activity. The Completion 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 />. A Note allowing the APPLICABILITY of LC0 3.0.4.c is added, consistent with the Note to REQUIRED ACTION A.1.

3. CONDITION C is modified based on the changes to CONDITIONS A and B and to reflect the change in the LC0 APPLICABILITY.

G. Modify SURVEILLANCE REQUIREMENTS (SR) Table as follows:

1. Revise SR 3.4.16.1 to verify the limit for DOSE EQUIVALENT Xe-133. A Note is added, consistent with SR 3.4.16.2 to allow entry into MODES 2, 3, and 4 prior to performance of the SR.

2. Delete SR 3.4.16.3.

3.0 BACKGROUND

The background for this application is as stated in the model Safety Evaluation (SE) in NRC's Notice of Availability dated March 15, 2007, 72 FR 12217, the NRC Notice for Comment published on November 20, 2006,71 FR 67170, and TSTF-490, Revision 0.

4.0 TECHNICAL ANALYSIS

FPL Energy Point Beach has reviewed References 1,2 and 3, and the model SE, 71 FR 67170, as part of the CLllP Notice for Comment. FPL Energy Point Beach has applied the methodology in Reference 1 to develop the proposed TS changes. FPL Energy Point Beach has also concluded that the justifications presented in TSTF-490, Revision 0 and the model SE prepared by the NRC staff are applicable to PBNP, Units 1 and 2, and justify this amendment for the incorporation of the changes to the PBNP TS.

5.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability dated March 15, 2007, 72 FR 12217, the NRC Notice for Comment published in 71 FR 67170, and TSTF-490, Revision 0.

PBNP was licensed to operate prior to Appendix A being incorporated into 10 CFR 50 in 1971.

Therefore, the applicable PBNP GDC for the control room at the time of initial plant licensing was GDC 11, not GDC 19, as stated in the regulatory analysis of this CLIIP. PBNP conforms to Appendix A GDC 19, however, via full compliance with NUREG-0737, ltem Ill D.3.4.

6.0 NO SIGNIFICANT HAZARDS CONSIDERATION FPL Energy Point Beach has reviewed the proposed no significant hazards consideration determination published in the Federal Register on March 15, 2007, 72 FR 12217 as part of the CLIIP. FPL Energy Point Beach has concluded that the proposed determination presented in the notice is applicable to PBNP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

7.0 ENVIRONMENTAL EVALUATION FPL Energy Point Beach has reviewed the environmental consideration included in the model SE published in the Federal Register on March 15, 2007, 72 FR 12217 as part of the CLIIP.

FPL Energy Point Beach has concluded that the staff's findings presented therein are applicable to PBNP and the determination is hereby incorporated by reference for this application.

8.0 REFERENCES

I. NRC Safety Evaluation approving TSTF-490, Revision 0 (ML070250176)

2. Federal Resister Notice for Comment published on November 20, 2006, 71 FR 67170, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification lmprovement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification; Babcock and Wilcox Pressurized Water Reactors, Westinghouse Pressurized Water Reactors, Combustion Engineering Pressurized Water Reactors Using the Consolidated Line ltem lmprovement Process."

3. Federal Register Notice of Availability dated March 15, 2007, 72 FR 12217, Model Safety Evaluation, U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Technical Specification Task Force TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Technical Specification."

ENCLOSURE 2 FPL ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 259 PROPOSED TECHNICAL SPECIFICATION CHANGES 6 pages follow

Definitions

1. I 1.IDefinitions CHANNEL OPERATIONAL A COT shall be the injection of a simulated or TEST (COT) actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps.

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.4. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. II,1988, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion,"

Point Beach 1. I - 2 Unit 1 - Amendment No. Z24 Unit 2 - Amendment No.

Definitions

1. I 1.IDefinitions DOSE EQUIVALENT DOSE EQUIVALENT Xe-133 shall be that concentration of Xe-I 33 Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body D e e ~ Dose Eauivalent as the combined activities of noble gas nuclides Kr-85m, Kr-85. Kr-87, Kr-88, Xe-131 m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actuallv present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activitv.

The determination of DOSE EQUIVALENT Xe-133 shall be performed usins effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil" or the average aamma disintegration energies as provided in ICRP Publication 38, "Radionuclide Transformations," or similar source.

Point Beach 1.I-2a Unit 1 - Amendment No. &&I Unit 2 - Amendment No. XQ

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT Xe-133 specific activitv shall be within limits:

APPLICABILITY: MODES &ac-&& 1, 2, 3, and 4.

I-, nrc -.A a

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT ------------------ Note-----------------

1-131 not within limit. L C 0 3.0.4.c is applicable.

A. 1 Verify DOSE Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> EQUIVALENT 1-131

-!iw+@f9 A fi

. . .4c S O uCi/qm.

AND A.2 Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT 1-131 to within limit.

B.

w&&h&kk DOSE EQUIVALENT ~ e - 1 3 3 ------------------ Note-----------------

not within limit. L C 0 3.0.4.c is applicable.

B. I Restore DOSE 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> EQUIVALENT Xe-133 to within limit.

(continued)

Point Beach 3.4.16-1 Unit 1 - Amendment No.

Unit 2 - Amendment No.

RCS Specific Activity 3.4.16 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C. 1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A AND not met.

C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> DOSE EQUIVALENT 1-131 i&k

>50 uCi1am.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 7 days Onlv required to be performed in MODE 1.

Verifv reactor coolant DOSE EQUIVALENT Xe-133 specific activitv 1520 uCi/am.

SR 3.4.16.2 ........................... NOTE--------------------------

Only required to be performed in MODE 1. 14 days AND Verify reactor coolant DOSE EQUIVALENT 1-131 specific activity 10.8 pCiIgm. Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a THERMAL POWER change of 2 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period Point Beach 3.4.16-2 Unit 1 - Amendment No. 2W Unit 2 - Amendment No.

RCS Specific Activity 3.4.16 Point Beach Unit 1 -Amendment No. XM=

Unit 2 - Amendment No. 2%

RCS Specific Activity 3.4.16 Point Beach 3.4.16-4 Unit 1 - Amendment No.

Unit 2 - Amendment No. 2%

ENCLOSURE 3 FPL ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 259 TECHNICAL SPECIFICATION BASES CHANGES 11 pages follow

RCS Specific Activity B 3.4.16 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.16 RCS Specific Activity BASES BACKGROUND The maximum dose that an individual at the exclusion area boundary can receive for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following an accident, or at the low population zone outer boundary for the radiological release duration, is specified in 10 CFR 100.11 (Ref. 1). Doses to control room operators must be limited per GDC 19. The limits on specific activity ensure that the offsite and control room doses are appropriately limited during analyzed transients and accidents.

The RCS specific activity LC0 limits the allowable concentration level of radionuclides in the reactor coolant. The LC0 limits are established to minimize the dose consequences in the event of a steam line break

{SLB) or steam generator tube rupture (SGTR) accident.

The LC0 contains specific activity limits for both DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT Xe-133. The allowable levels are intended to ensure that offsite and control room doses meet the appropriate acceptance criteria in the Standard Review Plan (Ref. 2).

Point Beach B 3.4.16-1 9+Qiwxa Unit 1 - Amendment No.

Unit 2 - Amendment No.

RCS Specific Activity B 3.4.16 BASES APPLICABLE SAFETYANALYSES The LC0 limits on the specific activity of the reactor coolant ensure that the resultinq offsite and control room doses meet the appropriate SRP acceptance criteria following a SLB or SGTR accident. The safety analyses (Refs. 3 and 4) assume the specific activitv of the reactor coolant is at the LC0 limits, and an existing reactor coolant steam generator (SG) tube leakage rate of 500 gallons per dav per steam generator exists. The safety analvses assume the specific activitv of the secondary coolant is at its limit of 1.0 uCilqm DOSE EQUIVALENT 1-131 from LC0 3.7.13. "Secondary Specific Activity."

The analvses for the SLB and SGTR accidents establish the acceptance limits for RCS specific activitv. Reference to these analvses is used to assess chanqes to the unit that could affect RCS specific activity, as they relate to the acceptance limits.

Point Beach Unit 1 -Amendment No.

Unit 2 - Amendment No.

RCS Specific Activity B 3.4.16 BASES APPLICABLE SAFETY ANALYSES (continued)

Point Beach Unit 1 -Amendment No. L W Unit 2 - Amendment No.

RCS Specific Activity B 3.4.16 BASES APPLICABLE The safetv analvses consider two cases of reactor coolant iodine SAFETY ANALYSES specific activitv. One case assumes specific activity at 0.8 uCilqm (continued) DOSE EQUIVALENT 1-131 with a concurrent large iodine spike that increases, bv a factor of 500, the rate of release of iodine from the fuel rods containing claddinq defects to the primaw coolant immediatelv after a SLB or SGTR, respectivelv. The second case assumes the initial reactor coolant iodine activitv at 50 uCilgm DOSE EQUIVALENT 1-131 due to an iodine spike caused bv a reactor or RCS transient prior to the accident. In both cases, the noble gas specific activitv is assumed to be 520 uCilgm DOSE EQUIVALENT Xe-133.

The analvsis also assumes a loss of offsite power at the same time as the SGTR event. The SGTR causes a reduction in reactor coolant inventow. The reduction initiates a reactor trip from a low pressurizer pressure signal or an RCS overtemperature AT siqnal.

The coincident loss of offsite power causes the steam dump valves to close to protect the condenser. The rise in pressure in the ru~turedSG discharqes radioactivelv contaminated steam to the atmosphere through the atmos~hericsteam dump valves and the main steam safetv valves. The unaffected SGs remove core decav heat bv venting steam to the atmosphere until the cooldown ends.

The SLB radiological analvsis assumes that offsite power is lost at the same time as the pipe break occurs outside containment. The affected SG blows down completelv and steam is vented directlv to the atmosphere. The unaffected SG removes core decav heat bv ventinq steam to the atmosphere until the cooldown ends and the RHR svstem is placed in service.

O~erationwith iodine specific activitv levels greater than the LC0 limit is permissible, if the activity levels do not exceed 50 uCilgm for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The limits on RCS specific activitv are also used for establishinq standardization in radiation shielding and plant personnel radiation protection practices.

RCS specific activitv satisfies Criterion 2 of 10 CFR 50.36 (c)(Z)(ii).

Point Beach Unit 1 -Amendment No.

Unit 2 - Amendment No.

RCS Specific Activity B 3.4.16 BASES The iodine specific activitv in the reactor coolant is limited to 0.8 uCilam DOSE EQUIVALENT 1-131, and the noble gas specific activitv in the reactor coolant is limited to 520 uCilam DOSE EQUIVALENT Xe-133.

The limits on specific activitv ensure that offsite and control room doses will meet the appropriate SRP acceptance criteria (Ref. 2).

The SLB and SGTR accident analvses (Refs. 3 and 4) show that the calculated doses are within acceptable limits. Violation of the LC0 may result in reactor coolant radioactivitv levels that could, in the event of a SLB or SGTR, lead to doses that exceed the SRP acceptance criteria (Ref. 2).

APPLICABILITY

?4akJs In MODES 1, 2, 3, and 4, operation within the LC0 limits for DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT Xe-133 is necessary to limit the potential consequences of a SLB or SGTR to within the SRP acceptance criteria (Ref. 2).

Point Beach B 3.4.16-3 Unit 1 - Amendment No. 245 Unit 2 -Amendment No.

RCS Specific Activity B 3.4.16 BASES APPLICABILITY In MODES 5 and 6, the steam generators are not being used for decav (continued) heat removal, the RCS and steam generators are depressurized, and primarv to secondary leakage is minimal. Therefore, the monitoring of RCS specific activitv is not required.

ACTIONS A.l and A.2 With the DOSE EQUIVALENT 1-131 greater than the LC0 limit, samples at intervals of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> must be taken to demonstrate that the specific activitv is 6 0 uCilgm. The Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is required to obtain and analvze a sample. Sampling is continued everv 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to provide a trend.

The DOSE EQUIVALENT 1-131 must be restored to within limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is acceptable since it is expected that, if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. Also, there is a low probabilitv of a SLB or SGTR occurring during this time period.

A Note permits the use of the provisions of LC0 3.0.4.c. This allowance permits entrv into the applicable MODE(s), relvinq on Required Action A.l and A.2 while DOSE EQUIVALENT 1-131 LC0 limit is not met. This allowance is acceptable due to the significant Point Beach Unit 1 - Amendment No.

Unit 2 -Amendment No.

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued) conservatism incorporated into the specific activitv limit, the low probabilitv of an event which is limiting due to exceeding this limit, and the abilitv to restore transient-specific activitv excursions while the plant remains at, or proceeds to, power operation.

With the DOSE EQUIVALENT Xe-133 greater than the LC0 limit, DOSE EQUIVALENT Xe-133 must be restored to within limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is acceptable since it is expected that, if there were a noble aas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probabilitv of a SLB or SGTR occurrinq during this time period.

A note permits the use of the provisions of LC0 3.0.4.c. This allowance permits entrv into the applicable MODE(s), relvina on Required Action B.l while the DOSE EQUIVALENT Xe-133 LC0 limit is not met. This Point Beach Unit 1 -Amendment No. 244 Unit 2 -Amendment No. 2243

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued) allowance is acceptable due to the siqnificant conservatism incorporated into the specific activitv limit, the low probabilitv of an event which is limitinq due to exceeding this limit, and the ability to restore transient-specific activitv excursions while the plant remains at, or proceeds to, power operation.

C.l and C.2 If the Required Action and associated Completion Time of Condition A or B is not met, or if the DOSE EQUIVALENT 1-131 is > 50 uCilgm, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant SURVEILLANCE REQUIREMENTS SR 3.4.16.1 reauires performinq a qamma isotopic analvsis as a measure of the noble gas specific activitv of the reactor coolant at least once every 7 days. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of anv increase in the noble gas specific activitv.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LC0 limit under normal o~eratinq conditions. The 7 dav Frequencv considers the low probabilitv of a gross fuel failure during the time.

Point Beach Unit 1 - Amendment No. a Unit 2 - Amendment No. ?XI

RCS Specific Activity B 3.4.16 BASES SURVEILLANCE Due to the inherent difficulty in detecting Kr-85 in a reactor coolant REQUIREMENTS sample due to maskinq from radioisotopes with similar decay energies, (continued) such as F-18 and 1-134, it is acceptable to include the minimum detectable activity for Kr-85 in the SR 3.4.16.1 calculation. If a s~ecific noble gas nuclide listed in the definition of DOSE EQUIVALENT Xe-133 is not detected, it should be assumed to be present at the minimum detectable activity.

A Note modifies this SR to allow entry into and o~erationin MODE 4, MODE 3, and MODE 2 prior to performing the SR. This allows the Surveillance to be performed in those MODES, prior to enterinq MODE 1.

Point Beach Unit 1 - Amendment No. A4 Unit 2 -Amendment No. 22Q

RCS Specific Activity B 3.4.16 BASES SURVEILLANCE REQUIREMENTS (continued)

This surveillance is performed to ensure iodine specific activity rerr-within the LC0 limit during normal operation and followins fast P O M ~

changes when iodine spiking is more apt to occur. The 14 day Frequency is adequate to trend changes in the iodine activity level,.

considering noble gas activity is monitored everv 7 days. The Frequency, between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a power chanse 25% RTF) within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period, is established because the iodine levels peal-(

during this time following iodine spike initiation: samples at other ti^^

would provide inaccurate results.

The Note modifies this SR to allow entrv into and operation in MODE 4, MODE 3, and MODE 2 prior to performins the SR. This allows the, Surveillance to be preformed in those MODES, prior to enterinq MODE 1.

Point Beach Unit 1 -Amendment No. %4 Unit 2 - Amendment No. 24%

RCS Specific Activity B 3.4.16 BASES REFERENCES 1. 1 0 C F R 1 0 0 . 1 1 ~

2.

Standard Review Plan (SRP). Section 15.1.5 Appendix A (SLB) and Section 15.6.3 (SGTR).

3. FSAR, Section 14.2.4.

Point Beach Unit 1 - Amendment No.

Unit 2 - Amendment No. 2QfS