ML13294A576

Issuance of Amendment Nos. 192, 192, and 192, Adopt TSTF-490, Revision 0, Deletion of E-Bar Definition and Revision to RCS Specific Activity Technical Specifications

ML13294A576
Person / Time
Site:	Palo Verde
Issue date:	11/25/2013
From:	Jennivine Rankin Plant Licensing Branch IV
To:	Edington R Arizona Public Service Co
Rankin J
References
TAC MF0397, TAC MF0398, TAC MF0399
Download: ML13294A576 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 25, 2013 Mr. Randall K. Edington Executive Vice President Nuclear/

Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3-ISSUANCE OF AMENDMENTS RE: ADOPTION OF TSTF-490, REVISION 0, DELETION OF E-BAR DEFINITION AND REVISION TO RCS SPECIFIC ACTIVITY TECHNICAL SPECIFICATIONS (TAC NOS. MF0397, MF0398, AND MF0399)

Dear Mr. Edington:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 192 to Renewed Facility Operating License No. NPF-41, Amendment No. 192 to Renewed Facility Operating License No. NPF-51, and Amendment No. 192 to Renewed Facility Operating License No. NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 12, 2012.

The amendments revise the TSs relating to reactor coolant system (RCS) activity limits by replacing the current TS limits on primary coolant gross specific activity with limits on primary coolant noble gas activity. The noble gas activity would reflect a new DOSE EQUIVALENT XE-133 definition that would replace the current E-Bar average disintegration energy definition.

The changes are consistent with NRC-approved Industry/Technical Specifications Task Force (TSTF) Standard Technical Specification change traveler, TSTF-490, Revision 0, "Deletion of E-Bar Definition and Revision to RCS (Reactor Coolant System] Specific Activity Technical Specifications," with deviations.

R. Edington A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Jennie K. Rankin, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 192 to NPF-41

2. Amendment No. 192 to NPF-51

3. Amendment No. 192 to NPF-74

4. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 192 License No. NPF-41

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 12, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

R. Edington 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C(2) of Renewed Facility Operating License No. NPF-41 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-41 and Technical Specifications Date of Issuance: November 25, 2013

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY. ET AL.

DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 192 License No. NPF-51

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 12, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C(2) of Renewed Facility Operating License No. NPF-51 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-51 and Technical Specifications Date of Issuance: November 25, 2013

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION. UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 192 License No. NPF-74

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 12, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C(2) of Renewed Facility Operating License No. NPF-74 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-74 and Technical Specifications Date of Issuance: November 25, 2013

ATTACHMENT TO LICENSE AMENDMENT NOS. 192, 192, AND 192 RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51. AND NPF-74 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 Replace the following pages of the Renewed Facility Operating Licenses Nos. NPF-41, NPF-51, and NPF-74, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. NPF-41 REMOVE INSERT 5 5 Renewed Facility Operating License No. NPF-51 REMOVE INSERT 6 6 Renewed Facility Operating License No. NPF-74 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 1.1-3 1.1-3 1.1-4 1.1-4 1.1-5 1.1-5 1.1-6 1.1-6 3.4.17-1 3.4.17-1 3.4.17-2 3.4.17-2 3.4.17-3 3.4.17-4

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed license.

(4) Operating Staff Experience Requirements Deleted (5) Post-Fuel-Loading Initial Test Program {Section 14. SER and SSER 2)'

Deleted (6) Environmental Qualification Deleted (7) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed Facility Operating License No. NPF-41 Amendment No. 192

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Operating Staff Experience Requirements (Section 13.1.2, SSER 9)'

Deleted (5) Initial Test Program (Section 14, SER and SSER 2)

Deleted (6) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(7) lnservice Inspection Program (Sections 5.2.4 and 6.6, SER and SSER 9)

Deleted

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed Facility Operating License No. NPF-51 Amendment No. 192

(4) Pursuant to the Act and 10 CFR Part 30, 40, and 70, APS to receive, possess, and use in amounts required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, APS to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 192, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Initial Test Program (Section 14, SER and SSER 2)

Deleted (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. 171, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Additional Conditions.

Renewed Facility Operating License No. NPF-74 Amendment No. 192

Definitions 1.1 1.1 Definitions CORE ALTERATION CORE ALTERATION shall be the movement or manipulation of any fuel. sources. or reactivity control components [excluding control element assemblies (CEAs) withdrawn into the upper guide structure]. within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

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 5.6.5. 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/gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes I-131. I-132. I-133.

1-134. and 1-135 actually present. If a specific iodine isotope is not detected. it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT I-131 shall be performed using ICRP-30. 1979.

Supplement to Part 1. page 192-212. Table titled.

"Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m. Kr-85. Kr-87. Kr-88.

Xe-131m. Xe-133m. Xe-133. Xe-135m. Xe-135. and Xe-138 actually present. If a specific noble gas nuclide is not detected. it should be assumed to be present at the minimum detectable activity.

The determination of DOSE EQUIVALENT XE-133 shall (continued)

PALO VERDE UNITS 1.2.3 1.1-3 AMENDMENT NO. +/-+/-+. 192

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT XE-133 be performed using effective dose conversion (continued) factors for air submersion listed in Table B-1 of Regulatory Guide 1.109. Rev. 1. NRC. 1977.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval FEATURE (ESF) RESPONSE from when the monitored parameter exceeds its ESF TIME actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e .. the valves travel to their required positions. pump discharge pressures reach their required values. etc.). Times shall include diesel generator starting and sequence loading delays. where applicable. The response time may be measured by means of any series of sequential.

overlapping, or total steps so that the entire response time is measured. In lieu of measurement. response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

Kn. 1 is the K effective calculated by considering the actual CEA configuration and assuming that the fully or partially inserted full strength CEA of highest worth is fully withdrawn.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE. such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff).

that is captured and conducted to collection systems or a sump or collecting tank:

2. LEAKAGE into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE: or (continued)

PALO VERDE UNITS 1.2.3 1.1-4 AMENDMENT NO. +&+/-. 192

Definitions 1.1 1.1 Definitions LEAKAGE (continued) 3. Reactor Coolant System CRCS) LEAKAGE through a steam generator (SG) to the Secondary System (primary to secondary LEAKAGE).

b. Unidentified LEAKAGE All LEAKAGE that is not identified LEAKAGE:

c. Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a nonisolable fault in an RCS component body. pipe wall. or vessel wall.

MODE A MODE shall correspond to any one inclusive combination of core reactivity condition. power level. cold leg reactor coolant temperature. and reactor vessel head closure bolt tensioning specified in Table 1.1-1 with fuel in the reactor vessel.

NEUTRON RATED The indicated neutron flux at RTP.

THERMAL POWER CNRTP)

OPERABLE

• OPERABILITY A system. subsystem. train. component. or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation. controls. normal or emergency electrical power. cooling and seal water.

lubrication. and other auxiliary equipment that are required for the system. subsystem. train.

component. or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation.

These tests are:

a. Described in Chapter 14. Initial Test Program of the UFSAR:

(continued)

PALO VERDE UNITS 1.2.3 1.1-5 AMENDMENT NO.+/-&+/-. 192

Definitions 1.1 1.1 Definitions PHYSICS TESTS b. Authorized under the provisions of (continued) 10 CFR 50.59: or

c. Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND The PTLR is the site specific document that TEMPERATURE LIMITS provides the reactor vessel pressure and REPORT CPTLR) temperature limits. including heatup and cooldown rates. for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.6.9.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer CRTP) rate to the reactor coolant of 3990 MWt.

REACTOR PROTECTIVE The RPS RESPONSE TIME shall be that time interval SYSTEM CRPS) RESPONSE from when the monitored parameter exceeds its RPS TIME trip setpoint at the channel sensor until electrical power to the CEAs drive mechanism is interrupted. The response time may be measured by means of any series of sequential. overlapping. or total steps so that the entire response time is measured. In lieu of measurement. response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

SHUTDOWN MARGIN CSDM) SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a. All full strength CEAs (shutdown and regulating) are fully inserted except for the single CEA of highest reactivity worth. which is assumed to be fully withdrawn. With any full strength CEAs not capable of being fully inserted. the withdrawn reactivity worth of these CEAs must be accounted for in the determination of SDM and

b. There is no change in part strength CEA position.

PALO VERDE UNITS 1.2.3 1.1-6 AMENDMENT NO. 1+9. 192

RCS Specific Activity 3.4.17 3.4 REACTOR COOLANT SYSTEM <RCS) 3.4.17 RCS Specific Activity LCO 3.4.17 RCS DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

APPLICABILITY: MODES 1. 2. 3. and 4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 ------------NOTE-----------

not within limit. LCD 3.0.4.c is applicable.

A.1 Verify DOSE Once per EQUIVALENT I-131 ~ 60 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> t.~Ci/gm.

-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 I-131 to within limit.

B. DOSE EQUIVALENT XE-133 not within ------------NOTE-----------

limit. LCD 3.0.4.c is applicable.

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

(continued)

PALO VERDE UNITS 1.2.3 3.4.17-1 AMENDMENT NO. +/-ea. 192

HCS Speciflc Actlvlty 3.4 17 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

c. Required Action and cl Be in MODE 3. 6 hours associated Completion T1me of Condition AND A or B not met.

OR C.2 Be in MODE 5. 36 hours DOSE EQUIVALENT l-131

> 60 tJCi/gm.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify reactor coolant DOSE EQUIVAlENT In accordance with XE-133 specific activity s 550 pCi/gm. the Surveillance Frequency Control Prograrr SR 3.4.17.2 Verify reactor coolant DOSE In accordance with EQUIVALENT I-131 specific activity the Surveillance s 1. 0 tiC i I gm . Frequency Control Program AND Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after THERMAL POWER change of ~ 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 PALO VERDE UNITS 1.2.3 3.4.17-2 AMENDMENT NO. +BS. 192

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 192. 192. AND 192 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51. AND NPF-74 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2. AND 3 DOCKET NOS. STN 50-528. STN 50-529, AND STN 50-530

1.0 INTRODUCTION

By application dated December 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12353A158), Arizona Public Service Company (the licensee) requested changes to the Technical Specifications (TSs) for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3 to adopt Technical Specifications Task Force (TSTF)-490, Revision 0, "Deletion of E-Bar Definition and Revision to RCS [Reactor Coolant System] Specific Activity Technical Specifications." The proposed changes would revise the TSs relating to reactor coolant system (RCS) activity limits to replace the current TS limits on primary coolant gross specific activity with TS limits on primary coolant noble gas activity.

The noble gas specific activity limit would reflect a new dose equivalent xenon-133 (DEX) definition that would replace the current E-Bar average disintegration energy definition. The current dose equivalent iodine-131 (DEl) definition would be revised to specify the appropriate reference for the thyroid dose conversion factors (DCFs), consistent with the dose consequence analyses for PVNGS. Changes are proposed toTS 3.4.17, "RCS Specific Activity," and its associated bases and surveillance requirements. These changes delete references to gross specific activity and E-Bar, add limits for DEl and DEX, and revise the modes of applicability, sampling requirements, and allowable DEl transient values.

2.0 REGULATORY EVALUATION

In Title 10 of the Code of Federal Regulations (1 0 CFR), Section 50.36, 'Technical specifications," the U.S. Nuclear Regulatory Commission (NRC) established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: ( 1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

Enclosure 4

TS LCO 3.4.17 limits the allowable concentration level of radionuclides in the reactor coolant.

The LCO limits are established to minimize the dose consequences in the event of a main steam line break (MSLB) or steam generator tube rupture (SGTR) accident. RCS specific activity satisfies 10 CFR 50.36(c)(2)(ii)(B), Criterion 2, which states:

A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The proposed changes replace the licensee's 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. Since the purpose of the TS LCO on gross activity is to support the dose analyses for design-basis accidents (DBAs), it would be more appropriate to have the LCO apply to the noble gas concentration in the primary coolant. With the implementation of specific changes to the LCO Conditions and SRs, the intent of the regulatory requirements will continue be met.

The NRC staff evaluated the impact of the proposed changes as they relate to the radiological consequences of affected DBAs that use the RCS activity inventory as the source term. The source term assumed in radiological analyses is based on the activity associated with the projected fuel damage or the maximum TS RCS values, whichever maximizes the radiological consequences. The limits on RCS specific activity ensure that the offsite doses are appropriately limited for accidents that are based on releases from the RCS with no significant amount of fuel damage.

The SGTR and MSLB accidents typically do not result in fuel damage and therefore the radiological consequence analyses are based on the release of primary coolant activity at maximum TS limits. The most limiting DBA at PVNGS which depends on RCS activity levels as an initial assumption is the SGTR with a loss of offsite power and a single failure of an atmospheric dump valve to close. For accidents that result in fuel damage, the additional dose contribution from the initial activity in the RCS is not normally evaluated and is considered to be insignificant in relation to the dose resulting from the release of fission products from the damaged fuel.

For licensees that incorporate the source term as defined in Atomic Energy Commission (AEC)

Technical Information Document (TID)-14844, "Calculation of Distance Factors for Power and Test Reactors Sites," dated March 23, 1962 (proprietary), in their dose consequence analyses, the NRC staff uses the regulatory guidance provided in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), Section 15.1.5, "Steam System Piping Failures Inside and Outside of Containment (PWR)," Appendix A, "

Radiological Consequences of Main Steam Line Failures Outside Containment," Revision 2 (ADAMS Accession No. ML052350118), for the evaluation of MSLB accident analyses. The staff uses SRP Section 15.6.3, "Radiological Consequences of Steam Generator Tube Failure (PWR)," Revision 2 (ADAMS Accession No. ML052350149), for evaluating SGTR accidents analyses. In addition, the staff uses the guidance from Regulatory Guide (RG) 1.195, "Methods

and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light Water Nuclear Power Reactors," May 2003 (ADAMS Accession No. ML031490640).

The applicable dose criteria for the evaluation of DBAs depends on the source term incorporated in the dose consequence analyses. For licensees using the TID-14844 source term, the maximum dose criteria to the whole body and the thyroid that an individual at the exclusion area boundary (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 /> following an accident, and at the low population zone (LPZ) outer boundary for the duration of the radiological release, are specified in 10 CFR 100.11, "Determination of exclusion area, low population zone, and population center distance." These criteria are 25 roentgen equivalent man (rem) total whole body dose and 300 rem thyroid dose from iodine exposure. The accident dose criteria in 10 CFR 100.11 are supplemented by accident-specific dose acceptance criteria in SRP Section 15.1.5, Appendix A, and SRP Section 15.6.3 or Table 4 of RG 1.195.

For control room dose consequence analyses that use the TID-14844 source term, the regulatory requirement for which the NRC staff bases its acceptance is General Design Criterion (GDC) 19, "Control room," of Appendix A to 10 CFR Part 50. GDC 19 requires that adequate radiation protection be provided to permit access and occupancy of the control room under accident 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. SRP Section 6.4, "Control Room Habitability System," Revision 2, July 1981 (ADAMS Accession No. ML052340712), provides guidelines defining the dose equivalency of 5 rem whole body and 30 rem for both the thyroid and skin dose. For licensees adopting the guidance from RG 1.196, "Control Room Habitability at Light-Water Nuclear Power Reactors," January 2007 (ADAMS Accession No. ML063560144), Section C.4.5 of RG 1.195, states that in lieu of the dose equivalency guidelines from SRP Section 6.4, the 10 CFR 20.1201, "Occupational dose limits for adults," annual organ dose limit of 50 rem can be used for both the thyroid and skin dose acceptance criteria.

By letter dated September 13, 2005 (ADAMS Accession No. ML052630462), the TSTF submitted TSTF-490 for NRC staff review. The NRC staff issued a Federal Register Notice (72 FR 12217) on March 15, 2007, that gave notice that the NRC staff had provided a revised model license amendment request (LAR), model safety evaluation (SE), and model proposed no significant hazards consideration (NSHC) determination related to deletion of the E-Bar definition and revision of the RCS specific activity TS. The purpose of these models is to permit the NRC staff to efficiently process LARs to incorporate these changes into plant-specific TSs for Babcock and Wilcox, Westinghouse, and Combustion Engineering pressurized-water reactors (PWRs).

3.0 TECHNICAL EVALUATION

3.1 Technical Evaluation of TSTF-490 TS Changes 3.1.1 Revision to the Definition of DEl The licensee proposes to revise the definition of DEl to state:

DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/

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.

If a specific iodine isotope is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT 1-131 shall be performed using ICRP-30, 1979, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

TSTF-490 lists the acceptable thyroid dose calculation factors (DCFs) for use in the determination of DEl as the following:

• Table Ill of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites."

• Table E-7 of Regulatory Guide (RG) 1.109, Revision 1, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1," October 1977 (ADAMS Accession No. ML003740384).

• International Commission on Radiological Protection (ICRP) 30, 1979, page 192-212, Table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

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

• Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

PVNGS proposed the use of the DCFs from ICRP 30 in its DEl definition, which is consistent with the DCFs used in the current DEl definition and the dose consequence analysis. The purpose of the TS limit for DEl is to satisfy 10 CFR 50.36(c)(2)(ii)(B), Criterion 2, which establishes an operating restriction that is an initial condition for a DBA. The most limiting DBA at PVNGS which depends on RCS activity levels as an initial assumption is the SGTR with a loss-of-offsite power and a single failure of an atmospheric dump valve to close. Maintaining the DEl value less than or equal to the TS limit of 1 microcurie per gram (IJCi/gm) is consistent with the assumptions used in the DBA dose consequence analyses. Therefore, the NRC staff

concludes that the licensee's proposed revision of the DEl definition and the proposed use of the DCFs from ICRP 30 are consistent with the NRC staff's approved position in TSTF-490 and are therefore acceptable.

3.1.2 Deletion of the Definition of E-Bar and Addition of a New Definition for DEX The new definition for DEX is similar to the definition for DEl. The determination of DEX will be performed in a similar manner to that currently used in determining DEl, except that the calculation of DEX is based on the acute dose to the whole body and considers the noble gases (Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138) which are significant in terms of contribution to whole body dose. Some noble gas isotopes are not included due to low concentration, short half-life, or small DCF. The calculation of DEX will use the effective DCFs from Table B-1 of RG 1.109. Using this approach, the limit on the amount of noble gas activity in the primary coolant would not fluctuate with variations in the calculated values of E-Bar. If a specified noble gas nuclide is not detected, the new definition states that it should be assumed the nuclide is present at the minimum detectable activity. This will result in a conservative calculation of DEX.

When E-Bar is determined using a design basis approach in which it is typically assumed that 1.0 percent of the power is being generated by fuel rods having cladding defects and it is also assumed that there is no removal of fission gases from the letdown flow, the value of E-Bar is dominated by Xe-133. The other noble gas nuclides have relatively small contributions.

However, during normal plant operation, there are typically only a small amount of fuel clad defects and the radioactive nuclide inventory can become dominated by tritium and corrosion and/or activation products, resulting in the determination of a value of E-Bar that is very different than would be calculated using the design basis approach. Because of this difference, the accident dose analyses become disconnected from plant operation and the LCO becomes essentially meaningless. It also results in a TS limit that can vary during operation as different values forE-Bar are determined.

This change will implement an LCO that is consistent with the whole body radiological consequence analyses which are sensitive to the noble gas activity in the primary coolant but not to other non-gaseous activity currently captured in the E-Bar definition. The licensee's current TS SR 3.4.17 .1 specifies the limit for primary coolant gross specific activity as 100/E-Bar microcuries per cubic centimeter (IJCilcc). The current Condition C of TS LCO 3.4.17 requires additional actions be taken if the gross specific activity is not within limit. The current E-Bar definition includes radioisotopes that decay by the emission of both gamma and beta radiation. Therefore, the current Condition C of LCO 3.4.17 would rarely, if ever, be entered for exceeding 100/E-Bar !JCi/cc since the calculated value is very high (the denominator is very low) if beta emitters such as tritium (H-3) are included in the determination, as required by the E-Bar definition.

TS Section 1.1 definition for "E- AVERAGE DISINTEGRATION ENERGY" is deleted and replaced with a new definition for DEX, which states:

DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body 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 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table B-1 of Regulatory Guide 1.109, Rev. 1, NRC, 1977.

The change incorporating the newly defined quantity DEX is acceptable from a radiological consequence dose perspective since it will result in an LCO that more closely relates the non-iodine RCS activity limits to the dose consequence analyses which form their bases. The licensee has proposed to use the DCFs from RG 1.109 for the calculation of DEX values. The staff confirmed that the licensee's proposed DEX limit of 550 !JCi/gm is a conservative representation of the mix of nuclides in the RCS used in the dose consequence analysis.

Therefore, the NRC staff concludes that the licensee's proposed definition of DEX and the proposed DEX limit are acceptable.

3.1.3 LCO 3.4.17. "RCS Specific Activity" LCO 3.4.17 is modified to specify that iodine specific activity in terms of DEl and noble gas specific activity in terms of DEX shall be within limits. Currently, the limiting indicators are not explicitly identified in the LCO, but are instead defined in current Condition C and SR 3.4.17.1 for gross non-iodine specific activity and in current Condition A and SR 3.4.17.2 for iodine specific activity. The change states "RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits." The NRC staff concludes that the proposed change is acceptable because it is consistent with the NRC staff's approved position in TSTF-490, Revision 0.

3.1.4 TS 3.4.17 Applicability TS 3.4.17 Applicability is modified to be applicable in Modes 1, 2, 3, and 4. Currently, TS 3.4.17 is applicable in Modes 1 and 2, and in Mode 3 with RCS cold leg temperature greater than or equal to 500 degrees Fahrenheit CF). It is necessary for the LCO to apply during Modes 1 through 4 to limit the potential radiological consequences of an SGTR or MSLB accident that may occur during these modes. In Mode 5 with the RCS loops filled, the steam generators are specified as a backup means of decay heat removal via natural circulation. In this mode, however, due to the reduced temperature of the RCS, the probability of a DBA involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required. In Mode 5 with the RCS loops not filled and in Mode 6, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal. Therefore, monitoring of RCS specific activity is not required. The change to modify the TS 3.4.17 Applicability to include all of Mode 3 and Mode 4 is necessary to limit the potential radiological consequences of an SGTR or MSLB that may occur during these modes and is therefore acceptable from a radiological dose perspective. The NRC staff concludes that the proposed change is acceptable because it is consistent with the NRC staff's approved position in TSTF-490, Revision 0.

3.1.5 TS 3.4.17 Condition A TS 3.4.17 Condition A is revised by replacing the DEl site-specific limit of"> 1.0 IJCi/gm" with the words "not within limit" to be consistent with the revised TS 3.4.17 LCO format. The site-specific DEl limit of :5 1.0 IJCi/gm is now contained in proposed TS SR 3.4.17.2. This proposed format change will not alter current TS requirements and is acceptable from a radiological dose perspective.

TS 3.4.17 Condition A, Required Action A.1 is revised to remove the reference to Figure 3.4.17-1, "Reactor Coolant DOSE EQUIVALENT 1-131 Specific Activity Limit versus Percent of RATED THERMAL POWER" and insert a limit of less than or equal to the site-specific DEl spiking limit of60 IJCi/gm. The curve contained in Figure 3.4.17-1 was provided by the AEC by letter dated June 12, 1974, on the subject, "Proposed Standard Technical Specifications for Primary Coolant Activity." Radiological dose consequence analyses for SGTR and MSL8 accidents that take into account the pre-accident iodine spike do not consider the elevated RCS iodine specific activities permitted by Figure 3.4.17-1 for operation at power levels below 80 percent rated thermal power (RTP). Instead, the pre-accident iodine spike analyses assume a DEl concentration 60 times higher than the corresponding long-term equilibrium value, which corresponds to the specific activity limit associated with 100 percent RTP operation. The NRC staff concludes that it is acceptable for proposed TS 3.4.17 Required Action A.1 to be based on the short-term site-specific DEl spiking limit because it is consistent with the assumptions contained in the radiological consequence analyses. Therefore, the NRC staff concludes that the proposed change is acceptable because the revised TS 3.4.17 Condition A is consistent with the NRC staff's approved position in TSTF-490, Revision 0.

3.1.6 TS 3.4.17 Condition 8 Revision to include Action for DEX Limit Current TS 3.4.17 Condition C for gross specific activity is deleted and replaced with a new Condition 8 for DEX not within limits. This change is made to be consistent with the change to the TS 3.4.17 LCO which requires the DEX specific activity to be within limits, as discussed above in Section 3.1.3. The DEX limit is site-specific and the numerical value of 550 1JCi/gm is contained in revised SR 3.4.17.1, as discussed below in Section 3.1.8. The site-specific limit for DEX is established based on the maximum accident analysis RCS activity corresponding to 1 percent fuel clad defects with sufficient margin to accommodate the exclusion of those isotopes based on low concentration, short half-life, or small DCFs. The primary purpose of the TS 3.4.17 LCO on RCS specific activity and its associated Conditions is to support the dose analyses for D8As. The whole body dose is primarily dependent on the noble gas activity, not the non-gaseous activity currently captured in the E-8ar definition.

The proposed Completion Time for proposed TS 3.4.17 Required Action 8.1 will require restoration of DEX 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 consistent with the Completion Time for Required Action A.2 for DEl. The radiological consequences for the SGTR and the MSL8 accidents demonstrate that the calculated thyroid doses are generally a greater percentage of the applicable acceptance criteria than the calculated whole body doses. It then follows that the proposed Completion Time for noble gas activity being out of specification in the proposed Required Action 8.1 should be at least as great as the Completion Time for iodine specific activity being out of specification in current Required Action A.2. Therefore, the proposed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for proposed Required Action 8.1 is acceptable from a radiological

dose perspective. A note is also proposed to be added to the revised Required Action 8.1 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 proposed TS LCO 3.4.17 is not being met, and is the same note that is currently stated for Required Actions A.1 and A.2. The proposed note would allow entry into the applicable 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 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 excursions while the plant remains at, or proceeds to power operation. Therefore, the NRC staff concludes that the proposed change is acceptable because the revised TS 3.4.17 Condition B is consistent with the NRC staff's approved position in TSTF-490, Revision 0.

3.1. 7 TS 3.4.17 Condition C Current TS 3.4.17 Condition C for gross specific activity is replaced by a revised current Condition B for DEX not within limits. The proposed TS 3.4.17 Condition C is a revision of the current Condition B to include the new Condition B for DEX. The proposed Condition C is for when the Required Action and associated Completion Time of Conditions A or B are not met.

This is consistent with the changes made to proposed Condition B, which now provides the same completion time for both components of RCS specific activity, as discussed in the revision to Condition B in Section 3.1.6. The proposed Condition C also replaces the limit on DEl from the deleted Figure 3.4.17-1, with a site-specific value of> 60 IJCi/gm. This change makes proposed Condition C consistent with the changes made in proposed TS 3.4.17 Required Action A.1.

Proposed TS 3.4.17 Required Action C.1 requires the plant to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and a new Required Action C.2 is added which requires the plant to be in 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 consistent with the proposed changes made to the TS 3.4.17 Applicability.

The proposed TS LCO 3.4.17 is applicable throughout all of Modes 1 through 4 to limit the potential radiological consequences of an SGTR or MSLB that may occur during these modes.

In Mode 5 with the RCS loops filled, the steam generators are not normally used for decay heat removal. In this mode, however, due to the reduced temperature of the RCS, the probability of a DBA involving the release of significant quantities of RCS inventory is greatly reduced.

Therefore, monitoring of RCS specific activity is not required. In Mode 5 with the RCS loops not filled and Mode 6, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal. Therefore, monitoring of RCS specific activity is not required.

A newTS 3.4.17 Required Action C.2 Completion Time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is also proposed for the plant to reach Mode 5. This completion time is reasonable, based on operating experience, to reach Mode 5 from full power conditions in an orderly manner and without challenging plant systems, and the value of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is consistent with other proposed TS which have a completion time to reach Mode 5. Therefore, the NRC staff concludes that the proposed change is acceptable because the revised TS 3.4.17 Condition C is consistent with the NRC staff's approved position in TSTF-490, Revision 0.

3.1.8 SR 3.4.17.1 DEX Surveillance The proposed change replaces the current TS SR 3.4.17.1 for RCS gross specific activity with a surveillance to verify that the reactor coolant DEX specific activity iss 550 IJCi/gm. This change provides a surveillance to verify the new LCO limit added to proposed TS 3.4.17 for DEX. The proposed TS SR 3.4.17 .1 surveillance requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant in accordance with licensee's Surveillance Frequency Control Program, which is the same frequency required under the current TS SR 3.4.17 .1 surveillance for RCS gross non-iodine specific activity. The surveillance provides an indication of any increase in the noble gas specific activity. The current TS surveillance requires the licensee to verify reactor primary coolant gross specific activity to s 100/E-Bar 1JCi/gm. The licensee is deleting the definition and reference to E-Bar, the average disintegration energy, and adding a limit for primary coolant noble gas activity based on DEX, which would take into account only the noble gas activity in the primary coolant. .The proposed TS SR 3.4.17 .1 states, "Verify reactor coolant DOSE EQUIVALENT XE-133 specific activity s 550 1JCi/gm." The results of the surveillance on DEX allow proper remedial action to be taken before reaching the LCO limit under normal operating conditions. As discussed in Section 3.1.2, the NRC staff confirmed that the licensee's proposed DEX limit of 550 1JCi/gm is a conservative representation of the mix of nuclides in the RCS used in the dose consequence analysis. The NRC staff concludes that the proposed change is acceptable because the revised TS SR 3.4.17 .1 is consistent with the NRC staffs approved position in TSTF-490, Revision 0.

3.1.9 SR 3.4.17.2 DEl Surveillance Current TS 3.4.17 .2 is revised to remove the note regarding frequency that states "Only required to be performed in Mode 1." The applicability requirement of proposed TS LCO 3.4.17 is for Modes 1, 2, 3, and 4. Therefore, the DEl Surveillance is required to be met during all modes of applicability forTS 3.4.17. The NRC staff concludes that the proposed change is acceptable because it is consistent with the applicability of proposed TS 3.4.17, and it is conservative because it applies to more operational modes than the current TS SR.

3.1.1 0 SR 3.4.17.3 Deletion Current TS SR 3.4.17.3 which required the determination of E-Bar is deleted. Proposed TS 3.4.17 LCO on RCS specific activity supports the dose analyses for DBAs, in which the whole body dose is primarily dependent on the noble gas concentration, not the non-gaseous activity currently captured in the E-Bar definition. With the elimination of the limit for RCS gross specific activity and the addition of the new LCO limit for noble gas specific activity. The NRC staff concludes that this SR to determine E-Bar is no longer required.

3.1.11 Consistency of Site-Specific Limits and DCFs for DEX and DEl Surveillances The NRC staff verified that the site-specific limits for DEl and DEX, and the DCFs proposed are consistent with the current applicable DBA dose analyses for PVNGS. The most limiting DBA at PVNGS which depends on RCS activity levels as an initial assumption is an SGTR with a loss-of-offsite power and a single failure of an atmospheric dump valve to close. SGTR accidents are analyzed using the maximum RCS activity. The current and proposed TS

definition of DEl states that DEl will be calculated using DCFs from ICRP 30, and the current and proposed DEl limit is 1.0 1-1Ci/gm.

The NRC staff verified that the current DEl limit is consistent with the value assumed in the most limiting DBA dose analysis. The NRC staff also verified that the pre-accident and accident-generated iodine spike source terms used in the most limiting DBA dose analyses are based on ICRP 30 DCFs. The NRC staff further verified that the pre-accident iodine spike source term used in the most limiting DBA dose analyses is consistent with the maximum iodine spike value permitted by the proposed TS, which is 60 !JCi/gm for PVNGS.

The proposed TS definition of DEX states that DEX will be calculated using the DCFs from RG 1.109 in order to ensure that offsite and control room accident doses are within the limits of 10 CFR 100.11 and GDC 19. The DCFs used by PVNGS to determine dose from noble gases and the calculation of DEX are from RG 1.1 09. DEX is that concentration of Xe-133 that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it will be assumed to be present at the minimum detectable activity. The NRC staff evaluated the information presented in the LAR regarding the RCS concentrations for noble gas isotopes and verified that the site-specific limit for DEX represents a conservative value for the activity of the mix of nuclides in the RCS relative to that used in the DBA dose consequence analysis.

Therefore, the NRC staff concludes that the proposed site-specific limits for DEl and DEX, as described above in Sections 3.1.5, 3.1.6, and 3.1.7, and the DCFs used for the determination of DEl and DEX, as described above in Sections 3.1.1 and 3.1.2, are acceptable because they are consistent with the current DBA dose analyses and the NRC staff's approved position in TSTF-490, Revision 0.

3.2 Precedent The TSs developed for the Westinghouse AP600 and AP1 000 advanced reactor designs incorporate an LCO for RCS DEX activity in place of the LCO on non-iodine gross specific activity based on E-Bar. This approach was approved by the NRC staff for the AP600 in NUREG-1512, "Final Safety Evaluation Report Related to the Certification of the AP600 Standard Design, Docket No.52-003," August 1998, and for the AP1 000 in the NRC letter to Westinghouse Electric Company dated September 13, 2004. In addition, the curve describing the maximum allowable iodine concentration during the 48-hour period of elevated activity as a function of power level was not included in the TS approved for the AP600 and APIOOO advanced reactor designs.

3.3 Conclusion The NRC staff has reviewed the proposed amendment to revise the definition of DEl, delete the definition of E Bar, add a new definition for DEX, modify TS Section 3.4.17, and delete Figure 3.4.17 -1. In addition, the NRC staff has evaluated the consistency of site-specific limits and DCFs for DEl and DEX. As described above, the staff reviewed the assumptions, inputs, and methods used by the licensee to assess the radiological impacts of the proposed license amendment. The NRC staff concludes that the analysis methods and assumptions consistent

with the conservative regulatory requirements and guidance identified in Section 2.0 above were used. The NRC staff concludes with reasonable assurance that the licensee's estimates of the EAB, LPZ, and control room doses will continue to comply with the applicable criteria in Section 2.0 of this evaluation. The proposed changes will not impact the dose consequences of the applicable DBAs because the proposed changes will limit the RCS iodine and noble gas specific activity to ensure consistency with the values assumed in the site-specific DBA radiological consequence analyses. Therefore, the NRC staff concludes that the proposed changes are acceptable with respect to the radiological dose consequences of the DBAs.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arizona State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on March 4, 2013 (78 FR 14128).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: M. Kichline, NRR/DRA/AADB Date: November 25 ~ 2013

R. Edington A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA/

Jennie K. Rankin, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 192 to NPF-41

2. Amendment No. 192 to NPF-51

3. Amendment No. 192 to NPF-74

4. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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