ML063620444

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Comment (3) of George G. Yates on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical S
ML063620444
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/20/2006
From: Yates G G
AmerenUE
To:
Rulemaking, Directives, and Editing Branch
References
71FR67170 00003
Download: ML063620444 (9)
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{{#Wiki_filter:Union Electric Callaway Plant K9 C-PO Box"00 Fulton, MO665251 J CDm December 20, 2006 Chief, Rulemaking, Directives, and Editing Branch Division of Administrative Services Office of Administration Mail Stop: T-6 D59 U.S. Nuclear Regulatory Commnission Washington, DC 20555-000 1 W4m Comments on Federal, Register Notice 71 FR 67170-67175, dated November 20, 2006,"Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification; ~ Babcock and Wilcox'Pressurized Water Reactors, Westinghouse Pressurized Water Reactors, Combustion Engineering Pressurized Water Reactors YE Usina the Consorlidated Line Item Improvement Proc~ess'" AmerenUE submits the following comments for consideration on the subject CLIIP Notice for Comment: 1. 71 FR 67171: There is currently one Technical Specification (TS) 3.4.16 limit on RCS gross specific activity, not "limits." The single limit is I 00/E-Bar in all 3 affected STS NUREGs. There are two places on this page that refer to limits (plural). This page should refer to limit (singular).

2. 71 FR 67172, Model SE, Section 2.0: Correct the title of TID 14844. "Reactor" is singular in the title.3.* 71 FR 67173, Model SE Section 3. 1. 1: The list of Dose Conversion Factor (DCF) references should be bracketed since this change will be subject to plant-specific considerations.

The optional DCF reference included in TSTF-490, and discussed in the traveler's justification section 3.0 (paragraph 2, lines 4-9), for alternate source term plants should be included here as follows: or [Committed Dose Equivalent (CDE) -or Committed Effective-Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.]1" 4. 71 FR 67173, Model SE Section 3.1.2: All noble gas isotope lists and DCF citations should be bracketed since these changes are subject to plant-specific considerations. The 2nd paragraph is missing a forward slash mark between the words "and' and "or" in the text "by tritium and corrosion and or activation products ....".5. 71 FR 67174, Model SE, Section 3. 1.33: The discussion on revised Required Action A.1I should be relocated to Model SE Section 3.1.5 that discusses the changes to TS 3.4.16 Condition A.S z) 6~J2 ;$e~ Kio-a subsidiary of Aneren Corporation 6. 71 FR 67174, Model SE Section 3.1.6: This section states that Condition "C" is replaced with a new Condition "B."' This is only true for the B&W and CE STS NUREGs (1430 and 1432). It is not true for the Westinghouse STS NUREG- 143 1, and it should be noted that the Westinghouse plants developed this traveler for submittal to the NRC. This section should state that "TS 3.4.16 Condition B [in NUJREG-143 1; C in NUREG-1430 and NUREG-1432] is replaced with a new Condition B for DEX not within limits." Model SE Section 3.1.6 should also discuss the addition of the LCO 3.0.4.c Note to revised Required.Action B. 1, consistent with the Model Application, Enclosure 1, Section 2.0, item C on 71 FR 67172.Suggested wording that could be used for this purpose is as follows: "A Note is also added to the revised Required Action B. I that states LCO 3 .0.4.c is applicable. This Note would allow entry into a Mode or other specified condition in the LCO Applicability when LCO 3.4.16 is not being met and is the same Note that is currently stated for Required Actions A. I and A.2. The proposed Note would allow entry into the applicable Modes when the DEX is not within its limit; in other words, the plant could go up in the Modes from Mode 4 to Mode 1 (power operation) while the DEX limit is exceeded and the DEX is being restored to within its limit. This Mode change allowance is acceptable due to the significant conservatism incorporated into the DEX specific activity limit, the low probability of an event occurring which is limiting due to exceeding the DEX specific activity limit, and the ability to restore transient specific activity excursions while the plant remains at, or proceeds to, power operation." 7. 71 FR 67174, Model SE, Section 3.1.8: This section incorrectly states that revised SR 3.4.16.1 has a new LCO 3.0.4.c Note. It should state that SR 3.4.16.1 has a new performance modifying Note that reads: "Only required to be performed in MODE 1L" The application of this style of Note is discussed in Example .1.4-5 in the latest revision of the STS NIJREGs. The LCO 3.0.4.c Note addition applies only to revised Required Action B. 1.The attached markups indicate where the above comments should be factored into the CLIII'Notice for Comment. I appreciate the opportunity to provide these comments.Very truly yours, George G. (Bert) Yates Consulting Licensing Engineer AmerenUE Callaway Plant PWROG Licensing Subcommittee Vice Chairman 67170 67170Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices Matters To Be Considered Week of November 20, 2006 There are no meetings scheduled for the Week of November 20, 2006.Week of November 27, 2006-Tentative Thursday, November 30, 2006 12:55 p.m. Affirmation Session (Public Meeting) (Tentative), a. Hydro Resources, Inc. (Crownpoint. NM)Intervenors' Petition for Review of LBP-06-19 (Final Partial Initial Decision-NEPA Issues) (Tentative). Week of December 4, 2006-Tentative Thursday. December 7, 2006 9:30 a.m. Discussion of Management Issues (Closed-Ex. 2).Week of December 11, 2006-Tentative Monday. December 11, 2006 1:30 p.m. Briefing on Status of Decommissioning Activities (Public Meeting) (Contact: Keith McConnell. 301-415-7295). This meeting will be Webcast live at the Web address-http://wvwvw.nrc.gov. Tuesday, December 12, 2006 9:30 a.m. Briefing on Threat Environment Assessment (Closed-Ex. 1)1:30 p.m. Discussion of Security Issues (Closed-Ex. 1 *& 3).Wednesday, December 13. 2006 9:30 a.m. Briefing on Status of Equal Employment Opportunity (EEO)Programs (Public Meeting) (Contact: Barbara Williams, 301-415-7388). This meeting will be Webcast live at the Web address-h ttp://svwv.nrc.gov. Thursday, December 14, 2006 9:30 a.m. Meeting with Advisory Committee on Nuclear Waste (ACNW)(Public Meeting) (Contact: John Larkins, 301-415-7360). This meeting will be webicast live at the Web address-http://wvwwt.nrc.gov. Week of December 18, 2006-Tentative There are no meetings scheduled for the Week of December 18, 2006.Week of December 25, 2006--Tentative There are no meetings scheduled for the Week of December 25. 2006.*The schedule for Commission meetings is subject to change on short notice. To verify the status of meetings call (recording)-301-415-1292. Contact person for more information: Michelle Schroll, 301-415-1662. The NRC Commission Meeting Schedule can be found on the Internet at: h ttp:I//wwiv.nrc.govlwhot-we-dol policy-making/schedule.Jitm]. The NRC provides reasonable accommodation to individuals with disabilities where appropriate. If you need a reasonable accommodation to participate in these public meetings, or need this meeting notice or the transcript or other information from the public meetings in another format (e.g.braille, large print), please notify the NRC's Disability Program Coordinator, Deborah Chan, at 301-415-7041,TDD: 301-415-2100, or by e-mail at DLC~m'c.gov. Determinations on requests for reasonable accommodation will be made on a case-by-case basis.This notice is distributed by mail to several hundred subscribers: if you no longer wish to receive it. or would like to be added to the distribution, please contact the Office of the Secretary, Washington, DC 20555 (301-415-1969). In addition, distribution of this meeting notice over the Internet system is available. If you are interested in receiving this Commission meeting schedule electronically, please send an electronic message to dkwi@nrc.gov. Dated: November 14, 2006.R. Mfichelle Schroll, Office of the Secretary. [FR Doc. 06-9292 Filed 11-16-06; 10:17 amJ BILLING CODE 7590-01-M NUCLEAR REGULATORY COMMISSION Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and 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 Item Improvement Process AGENCY: Nuclear Regulatory Commission. ACTION: Request for comment.

SUMMARY

Notice is hereby given that the staff of the U.S. Nuclear Regulatory Commission (NRC) has prepared a model license amendment request (LAR], model safety evaluation (SE). and model proposed no significant hazards consideration (NSHC) determination related to deletion of E Bar (average disintegration energy. 2) definition and revision to reactor coolant system (RCS)specific activity technical specification.

This request revises the RCS specific activity specification for pressurized water reactors to utilize a new indicator, Dose Equivalent Xenon-133 instead of the current indicator known as E Bar.The purpose of these models is to permit the NRC to efficiently process amendments to incorporate these changes into plant-specific Technical Specifications (TS) for Babcock and Wilcox, Westinghouse, and Combustion Engineering Pressurized Water Reactors (PWRs). Licensees of nuclear power reactors to which the models apply can request amendments conforming to the models. In such a request, a licensee should confirm the applicability of the model LAR, model SE and NSHIC determination to its plant. The NRC staff is requesting comments on the model bAR, model SE and NSHC determination for referencing in license amendment applications. DATES: The comment period expires 30 days from the date of this publication. Comments received after this date will be considered if it is practical to do so.but the Commission is able to ensure consideration only for comments received on or before this date.ADDRESSES: Comments may be submitted either electronically or via U.S. mail.Submit written comments to: Chief.Rulemaking, Directives, and Editing Branch, Division of Administrative Services. Office of Administration. Mail Stop: T-6 D59, U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001.Hand deliver comments to: 11545 Rockville Pike. Rockville, Maryland.between 7:45 a.m. and 4:15 p.m. on Federal workdays.Submit comments by electronic mail to: CLIP@lnr-c.gov. Copies of comments received may be examined at the NRC's Public Document Room, One White Flint North, Public File Area 01-F21, 11555 Rockville Pike (first floor). Rockville, Maryland.FOR FURTHER INFORMATION CONTACT: Trent Wertz, Mail Stop: O-12H2, Division of Inspection and Regional Support Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001, telephone (301) 415-1568.SUPPLEMENTARY INFORMATION:

Background

Regulatory Issue Summary 2000-06,"Consolidated Line Item Improvement Process (CHIP) for Adopting Standard Technical Specifications Changes for Power Reactors." was issued on March 20, 2000. The CL[IP is intended to improve the efficiency and transparency of NRC licensing processes. This is accomplished by processing proposed Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices671 67171 changes to the Standard Technical Specifications (STS) in a manner that sup poils subsequent license amendment applications. The CLTIP includes an opportunity for the public to comment on proposed changes to the STS following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. This notice is soliciting comment on a proposed change to the STS that deletes the E Bar definition and revises the RCS specific activity technical specification of the Babcock and Wilcox PWvR STS, Revision 3 of NUREG-1430, Westinghouse PWR STS Revision 3 NUREG-1431, and Combustion Engineering PWR STS Revision 3 NUREC-1432. The CLlIP directs the NRC staff to evaluate any comments received for a proposed change to the STS and to either reconsider the change or proceed with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to TSs are responsible for reviewing the staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information. Following the public comment period, the model LAR and model SE will be finalized, and posted on the NRC webpage. Each amendment application made in response to the notice of availability will be processed and noticed in accordance wth applicable NRC rules and procedujes. Th~is notice involves rep acemt.t ofi the current PWR TS 3.4.16 lim! )n RCS gross specific activity with 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 I-131 (DEl) definition would be revised to allow the use of additional thyroid dose conversion factors (DCFs). By letter dated September 13, 2005, the Technical Specifications Task Force (TSTF) proposed these changes for incorporation into the STS as TSTF-490, Revision 0.Applicability

  • These proposed changes will revise the definition of DOSE EQUIVALENT I-131. delete the definition of "E-Bar," AVERAGE DISINTEGRATION ENERGY, add a new definition for DOSE EQUIVALENT XE-133, and revise LCO 3.4.16 for Babcock and Wilcox, Westinghouse.

and Combustion Engineering PWRs, STS NUREGs 1430.1431. and 1432.To efficiently process the incoming license amendment applications, the NRC staff requests that each licensee applying for the changes addressed by TSTF-490, Revision 0, using the CLUIP submit an LAR that adheres to the following model. Any variations from the model LA.R should be explained in the licensee's submittal. Variations from the approach recommended in this notice may require additional review by the NRC staff, and may increase the time and resources needed for the review.Significant variations from the approach. or inclusion of additional amendment requests, may result in staff rejection of the CLUI adoption request.Instead, licensees desiring significant variations and/or additional changes should submit a non-CLIIP LAR that does not request to edopt TSTF-490 via CLI1P.Public Notices This notice requests comments from interested members of the public within 30 days of the date of this publication. Following the NRC staff's evaluation of comments received as a result of this notice, the NRC staff may reconsider the proposed change or may proceed with announcing the availability of the change in a subsequent notice (perhaps with some changes to the model LAR,'Model SE or model NSHC determination as a result of public comments). If the NRC staff announces the availability of the change. licensees wishing to adopt the change will submit an application in accordance with applicable rules and other regulatory requirements. The NRC staff will, in turn, issue for each application a notice of consideration of issuance of amendment to facility operating license(s), a proposed NSHC determination, and an opportunity for a hearing. A notice of issuance of an amendment to operating license will announce the revised requirements for each plant that applies for and receives the requested change.Dated at Rockville. Maryland this 14th day of November. 2006.For the Nuclear Regulatory Commission. Timothy J. Kobetz.Chief. Technical Specifications Branch, Division of Inspection and Regional Support, Office of Nuclear Reactor Regulation. For inclusion on the technical specification web page. The following example of an application was prepared by the NRC staff to facilitate the adoption of Technical Specifications task force (TSTF) Traveler TSTF-490. Revision 0 "deletion of E-bar definition and revision to RCS Specific Activity Tech Spec." The model provides the expected level of detail and content for an application to adopt TSTF-490. Revision 0.Licensees remain responsible for ensuring that their actual application fulfills their administrative requirements as well as NRC regulations. U.S. Nuclear Regulatory Commission, Document Control Desk, Washington. DC 20555.

SUBJECT:

Plant Name. Docket No. 50-lxx,oo) Re: Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0. "deletion of E-bar definition and revision to RCS Specific Activity Tech Spec"

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), ILICENSEEI is submitting a request for an amendment to the technical specificatio (TS) for [PLANT NAME, UNIT NOS.]. e proposed changes would replace th urrent pressurized water reactor (PWR) clhnical Specification (TS) 3.4.16 limi 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 (DEXI definition that would replace the current E-Bar (E) average disintegration energy definition. In addition, the current dose equivalent 1-131 (DEl) definition would be revised to allow the use of additional thyroid dose conversion factors (DCFs).The changes are consistent with NRC-approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler. TSTF-490.Revision 0, "Deletion of E-13ar Definition and Revision to RCS Specific Activity Tech Spec." The availability of this TS improvement was announced in the Federal Register on [DATE] ([ IFR[ I) as part of the Consolidated Line Item Inprovemnent Process (CLUIP)..Enclosure 1 Provides a description and assessment of the proposed changes, as well as confirmation of applicability. Enclosure 2 provides the existing TS pages and TS Bases marked-up to show the proposed changes.Enclosure 3 provides final TS pages and TS Bases pages.[LICENSEE] requests approval of the proposed license amendment by JDATEI, with the amendment being implemented [BY DATE OR WITHIN X DAYS). In accordance with 10 CFR 50.91, a copy of this application. with enclosures, is being provided to the designated [STATE] Official.I declare under penalty of perjury under the laws of the United States of America that I am authorized by [LICENSEE] to make this request and that the foregoing is true and correct. [Note that request may be notarized in lieu of using this oath or affirmation statement]. If you should have any questions regarding this submittal, please contact I Sincerely, Name. Title

Enclosures:

1. Description and Assessment of Proposed Changes 2. (Proposed Technical Specification Changes and Technical Specification Bases Changes]3. [Final Technical Specification and Bases pages) 67172 67172 Federal Register/Vol.

71, No. 223 /Monday, November 20, 2006/Notices cc: NRR Project Manager, Regional Office, Resident Inspector. State Contact, ITSB Branch Chief.Enclosure 1-Description and Assessment of Proposed Changes 1.0 Description This letter is a request to amend Operating License(s) [LICENSE NUMBER(S)] for[PLANT/UNIT NAME(S)].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.Technical Specification Task Force (TSTF)change traveler TSTF-490, Revision 0,"Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec" was announced for availability in the Federal Register on [DATE] as part of the consolidated line item improvement process (CLIIP).2.0 Proposed Changes Consistent with NRC-approved TSTF-490, Revision 0. the proposed TS changes Include:-Revised definition of DOSE EQUIVALENT 1-131-Deletion of the definition of "E-Bar.AVERAGE DISINTEGRATION ENERGY* Adding a new definition for DOSE EQUIVALENT XE-133* Revised LCO 3.4.16, -RCS Specific Activity' to delete references to gross specific activity, and reference limits on DOSE EQUIVALENT 1-13 1 and DOSE EQUIVALENT XE-1 33, and delete Figure 3.4.16-1, "Reactor Coolant DOSE EQUIVALENT 1-131 Specific Activity Limit versus Percent of RATED THIERMAL POWER."* Revised Applicability of LCO 3.4.16 to indicate the LCO is applicable in MODES 1,2,3, and 4* [Modified ACTIONS Table as follows: A. 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.B. NUREG-1430 and NUIREG-1432 ACTIONS are reordered, moving Condition C to Condition B.C. Condition B (was Condition C in NUREG-1430 and NUREG 1432) is modified to provide a Condition and Required Action for DOSE EQUIVALENT XE-133i instead of gross specific activity. The Completion Time is changed from 6 hours to 48 hours.ýA Note stating the applicability of LCO 3.0.4.c is added, consistent with the Note]Lto Required Action A.1.D. Condition C (was Condition B in NUREG-1430 and NUREG-1432) is modified based on the changes to Conditions A and B and to reflect the change in the LCO Applicability] -Revised SR 3.4.16.1 to verify the limit for DOSE EQUIVALENT XE-1 33. A Note is added, consistent with SR 3.4.16.2 to allow entry into MODES 4.3, and 2 prior to performance of the SR. X* Deleted SR 3.4.16.3 3.0 Back-ground The background for this application is as stated in the model SE in NRC's Notice of Availability published on (DATE W((] FR [1), the NRC Notice for Comment published on IDATE] ([1I FR [ 1). and TSTF-490, Revision 0.4.0 Technical Analysis[LICENSEE] has reviewed References I and 2, and the model SE published on [DATE] (U IFR [ 1) as part of the CLIIP Notice for Availability. [LICENSEE] has applied the methodology in Reference 1 to develop the proposed TS changes. [LICENSEE) has also concluded that the justifications presented in TSTF-490, Revision 0 and the model SE F repared by the NRC staff are applicable to PLANT, UNIT NOS.]. and justify this requested changes are the adoption of TSTF-490, Revision 0. "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec" to the Pressurized Water Reactor (PWR) Standard Technical Specifications (STS), which was proposed by the Technical Specifications Task Force (TSTF) by letter on September

13. 2005. This TSTF involves changes to NUREG-1430.

NUREG-1431, and NUREG-1432 Section 3.4.16 limits 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 purrent E-Bar average disintegration energy definition. In addition, the current dose equivalent 1-131 (DEl) definition would be revised to allow the use of additional thyroid dose conversion factors (DCFs).amendment for the incorporation T of the

2.0 REGULATORY EVALUATION

changes to the [PLANT) TS. The Nuclear Regulatory Commission MNC)5.0 RgltrAnlssstaff evaluated th e impact of the proposed Reguator Ana~siSchanges as they relate to the radiological A description of this proposed change and consequences of affected design basis its relationship to applicable regulator accidents (DBAs) that use the reactor coolant requirements and guidance was provided in system (RCS) inventory as the source term.the NRC Notice of Availability published on The source term assumed in radiological [DATE] ([ I FR [ 1), the NRC Notice for analyses should be based on the activity Comment published on [DATE) [IFR 11, associated with the projected fuel damage or and TSTF-490. Revision 0. the maximum TS RCS values, whichever 6.0 No Significant Hazards Consideration maximizes the radiological consequences. The limits on RCS specific activity ensure[LICENSEE] has reviewed the proposed no that the offsite doses are appropriately significant hazards consideration limited for accidents that are based on determination published in the Federal releases from the RCS with no significant Register on (DATEJ ([ I FR [ [)Ias part of the amount of fuel damage.CLII]'. [LICENSEE] has concluded that the The Steam Generator Tube Rupture (SGTR)proposed determination presented in the notice is applicable to [PLANT] and the accident and the Main Steam Line Break (MSLB) accident, with a few exceptions, do determination is hereby incorporated by not result in fuel damage and therefore the reference to satisfy the requirements of 10 radiological consequence analyses are based CFR 50.91 (a). on the release of primary coolant activity at 7.0 Environmental Evaluation maximum TS limits. For accidents that result[LICENSEE] has reviewed the in fuel damage, the additional dose environmental consideration included in the contribution from the initial activity in the model SE published in the Federal Register RCS is not normally evaluated and is on [DATE) U[ IFR [ 1) as p art of the CLIIP. considered to be insignificant in relation to[LICENSEE] has concluded that the stafr's the dose resulting from the release of fission findings presented therein are applicable to products from the damaged fuel. 9--X[PLANTl] adtedtriainihrby [For licensees that incorporate'tho source icroaned the determinatifon tis heeyterm as defined in Technic kfnformation apincroatedbi rfrncnorti Document (TI])) 14S844. C192 applcaton."Calculation of Dis fceFaci.tor fr Power 8.0 References and Test Reactor .ites," in their dose 1. Federal Register Notices: consequence anaryses. the staff uses the Notice for Comment published on [DATE] regulatory guidance provided in NUREG-[[[IFR [11) 0800. "Standard Review Plan (SRP) for the Notice of Availability published on [DATE Review of Safety Analysis Reports for[([FRI I) Nuclear Power Plants," Section 15.1.5,"Steam System Piping Failures Inside and MODEL SAFETY EVALUATION Outside of Containment (PWR)," Appendix U.S. Nuclear Regulatory CommissIon A, "Radiological Consequences of Main Steam Line Failures Outside Containment," Office of Nuclear Reactor Regulation Revision 2, for the evaluation of MSLB3 Technical Specificatien Task Force TSTF- accident analyses and NUREG-0800, SRP 49,Revision 0 Section 15.6.3, "Radiological Consequences 490, of Steam Generator Tube Failure (PWR).""Deletion of E-Bar Definition and Revision to Revision 2, for evaluating SGTh accidents-RCS Specific Activity Tech Spec" analyses. In addition, the staff uses the 1.0 ITRODUTIONguidance from RG 1.195, "Methods and 1.0 ITRODUTIONAssumptions for Evaluating Radiological By letter dated L, 20], [LICENSEE) (the Consequences of Design Basis Accidents at licensee] proposed changes to the technical Light Water Nuclear Power Reactors." May specifications (TS) for [PLANT NAME]. The 2003. for those licensees that chose to use its Federal Register/Vol. 71, No. 223/Monday, November 20, 2006/Notices677 67173 guidance for dose consequence analyses using the TID 14844 source term.][For licensees using the alternative source term (AST) in their dose consequence analyses, the staff uses the regulatory guidance provided in NUJREG-0800 .SRP Section 15.0.1. "Radiological Consequence Analyses Using Alternative Source Terms," Revision 0. July 2000, and the methodology and assumptions stated in Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors". July 20300.]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 hours following an accident, and at the low population zone (LPZ) outer boundary for the duration of the radiological release, are specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 100. 11. 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 is supplemented by accident specific dose acceptance criteria in SRP 15.1.5. Appendix A, SRP 15.6.3 or Table 4 of RG 1.195,"Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light Water Nuclear Power Reactors," May 2003.1[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 of Appendix A to 10 CFR Part 50. "Control Room". 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. NUREC-0800. SRP Section 6.4, "Control Room Habitability System," Revision 2, July 1981, provides guidelines defining the dose equivalency of 5 rem whole body as 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," May 2003, Section C.4.5 of RG 1.195, May 2003, states that in lieu of the dose equivalency guidelines from Section 6.4 of NUREG-OBOG, the 10 CFR 20.12 01 annual organ dose limit of 50 rem can be used for both the thyroid and skin dose equivalent of 5 rem whole body.][Licensees using the AST are evaluated against the dose criteria specified in 10 CFR Part 50.67. The off-site dose criteria are 25 rem total effective dose equivalent (TEDE) at the EAB for any 2-hour period following the onset of the postulated fission product release and 25 rem TEDE at the outer boundary of the LPZ for the duration of the postulated fission product release. in addition, 10 CFR Part 50.67 requires that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without analyses become disconnected from plant personnel receiving radiation exposures in operation and the limiting condition for excess of 5 rem TEDE for the duration of the operation (LCO) becomes essentially accident.] meaningless. It also results in a TS limit that can vary during operation as different values 3.0 TECHNICAL EVALUATION for E-Bar are determined.

3.1 Technical

Evaluation of TSTF-490 RCS This change will implement a LCO that is TS Changes consistent with the whole body radiological

3.1. Reisio

tothe efiitio ofD~l consequence analyses which are sensitive to 3,1. Reisio tothe efiitio ofDET the noble gas activity in the primary coolant The list of acceptable DCFs for use in the but not to other, non-gaseous activity determination of DEL include the following: currently captured in the E-Bar definition. L: Table II of TID-14844, AEC, 1962, SR 3.4.16.1 specifies the limit for primary"Calculation of Distance Factors for Power coolant gross specific activity as blooE-Bar and Test Reactor Sites." Ci/gin. The current E-Bar definition includes 9 Table E-7 of Regulatory Guide 1.109, radioisotopes that decay by the emission of Revision 1, NRC, 1977. both gamma and beta radiation. The current e ICRP 30.1979, page 192-212, Table titled Condition B of LCO 3.4.16 would rarely, if"Committed Dose Equivalent in Target ever, be met for exceeding 100lE-Bar since Organs or Tissues per Intake of Unit the calculated value is very high (the Activity." denominator is very low) if beta emitters* Table 2.1 of EPA Federal Guidance such as tritiumn (H-3) are included in the Report No. 11, 1988, "Limiting Values of determination, as required by the E-Bar Radionuclide Intake and Air Concentration definition. and Dose Conversion Factors for Inhalation. TS Section 1.1 definition for E-AVERAGE Submersion, and Inge~stion."3 arC4hre 4 DISINTEGRATION ENERGY fE-Bar] is Note: It is incumbent on the hicensee t9 .,Cdeleted and replaced with a new definition ensure that the OCFs used in the Cb~ C or DXwhich states: determination of DEl are consistent wit IDS QIAETX-3 hl ota applicable dose consequence anal e ~oncentration of Xe-133 (microcuries per 3.1.2 Deletion of the Definition of -an ,ram) that alone would produce the same the Addition of a New Deftinition for DE Xe- ctdoeothwolbdyate 133 combined activities of noble gas nuclide Kr-85m, Kr-85. Kr-87. Kr-88, Xe--131m. Xe-The determination of DEX wvillI be 133 ' Xe-133, Xe-135m, Xe--135, and Xe-performed in a similar manner to that 13fi~ctually present. If a specific noble gas currently used in determining DEL, except nu'Elide is not detected, it should be assumed that the calculation of DEX is based on the to be present at the minimum detectable acute dose to U1 whole body and considers activity. The determination of DOSE the noble gaseq Kr-85m, Kr-87, Kr-88,' Xe- EQ ALEN XE-133 shall be performed.ain, Xe-133,_Xe-135m, Xe-135, and' Xe sn effective dose conversion factors for air 13.1which are significant in terms of Submersion listed in Table 111.1 of EPA contribution to whole body dose. Some noble Federal Guidance Report No. 12, or the gas isotopes are not included due to low avrg m dsneatoeegiss concentration, short half life, or small dose avierag gamm diintegrliation enegie, a conversion factor. The calculation of DEX pRovdd in ICheRPPublications 38,. la would use either the average gamma source." disintegration energie.; for the nuclides or the The c' ange incorporating the newly effective dose conversion factors from Table defined .quantity DEX is acceptable from a 111.1 of EPA Federal Guidance Report No.12, radiological dose perspective since it will"External Exposure to Radionuclides in Air, result in an LCO that more closely relates the Water. and Soil", 1993. Using this approach, non-iodine RCS activity limits to the dose the limit on the amount of noble gas activity cosqeeanleswihfrter in the primary coolant would not fluctuate consequnc analyse whic for INUM NTHEi with variations in the calculated values of E- basEs.NOTE: ITO ENSINUMBENTHT ONTHE D Bar. If a specified noble gas nuclide is not USED IN THE DETERMINATION OF DEI detected, the new definition states that it AN TH-E NEWLY DEFINED DEX ARE should be assumed the nuclide is present at CONSISTENT WITH THE DCFS USED IN the minimum detectable activity. This Will THE APPLICAB3LE DOSE CONSEQUENCE result in a conservative calculation of DEX. ANLS.When E-Bar is determined using a design ANLS.basis approach in which it is assumed that 3.1.3 Revision of LCO 3.4.16, -RCS Specific 1.0% of the power is being generated by fuel Activity" rods having cladding defects and it is also LCO 3.4.16 is modified to specify that assumed that there is no removal of fission iodine specific activity in terms of DEI and gases from the letdown flow, the value of E- noble gas specific activity in terms of DEX Bar is dominated by Xe--133. The other shall be within limits. Currently the limiting nuclides have relatively small contributions, indicators are not explicitly identified in the However, during normal plant operation LCO, but are instead defined in current there are typically only a small amount of Condition C and Surveillance Requirement fuel clad defects and the radioactive nuclide (SR) 3.4.16.1 for gross non-iodine specific inventory can become dominated by tritium. activity and in current Condition A and SR and corsion antor activation products. 3.4.16.2 for iodine specific activity.resultn in the drmlnation of a value of The new LCO states "RCS DOSE 5-Bar that is vry, different than wvould be EQUIVALENT 1-13 1 and DOSE calculated using ah design basis approach. EQUIVALENT XE-133 specific activity shall Because of this cfference the accident dose be within limits." NOTE: IT IS INCUhiBENT / , 4,s C -e )V14/1 Federal Register/Vol. 7X o 23Mody November 20, 2006/Notices 67174 ON THE LICENSEE TO ENSURE THAT THE based on low concentration, short half life, or 3.1.8 SR 3.4.16.1 Revision to include SI`TE SPECIFIC LIMITS FOR BOTH DEl AND sinai dose conversion factors. The primary Surveillance for DEX DEX ARE CONSISTENT WITH THE pur se of the TS 3.4.16 LCO on RCS The change replaces the current SR CURRENT SGTR AND msLB spec fic activity and its associated Conditions 3.4.16.1 surveillance for RCS gross specific RADIOLOGICAL CONSEQUENCE is to support the dose analyses for DBAs. The activity with a surveillance to verify that the who e body dose is primarily dependent on site specific reactor coolant DEX specific TS 3.4.16 Required Action A.1 is revised the oble gas activity, not the non-gaseous activity is ir [280] j+/-Ci/gm. This change to remove the reference to Figure 3.4.16-1 acti ity currently captured in the E-Bar provides a surveillance for the new LCO limit"Reactor Coolant DOSE EQUIVALENT 1-131 deft ition. added to TS 3.4.16 for DEX. The revised SR Specific Activity Limit versus Percent of TeCompletion Time for revised TS 3.4.163.1.1svelacreuespfomga RATED HERMA POWE" andineto af Reqi ired Action B.1 will require restoration gamistpcnlysasaesuefth limit of less than or equal to the site specific of D X to within limit in 48 hours. This is nol gasm ispecific acalyivity masr of thereco*DEI spiking limit. Radiological dose consf stent with the Completion Time for coolan gat lpeastioncetevery ofdays whichtis consequence analyses for SGTR and MSLB cuirr nit Required Action A.2 for DEL. The coath sameas frquncy rvequred unders theci accidents, which take into account the pre- radi logical consequences for the SGTR and curen sRm 3re4.16.1 seuirveillancefr tCe accident iodine spike, do not consider the the I SLB accidents demonstrate that the guross non-iodine1 spreiiclanctivity.RTh elevated RCS iodine specific activities cac lated thyroidoeaegnrlya gosnn-dnepcfcatvt.Th permitted by Figure 3.4.16-1 for operation ca ddssaegnrlya surveillance provides an indication of any below 80% RTP. Instead, the pre-accident grea tnecriperenthageo the caplcuabe hle increase in the noble gas specific activity.iodine spike analyses assume a DEl c ac rtratantecluae hl The results of the surveillance on DEX allow concentration 60 times higher than the bed doses (operation with iodine specific preremdaacintbeaknefe corresponding long term equilibrium value, acti i~ty levels greater than the LCO limit is prprremigtediaOliacionto bner takebfre which corresponds to the specific activity Per ssible. if the activity levels do not opreaching th co litund erionn irmuia l wjy aex d the limits shown in Figure 3.4.16-1. oeaigcniin. fe-w~V4'limit associated with 100% RTP operati~on. x SR 3.4.16.1 is modified by inclusion of ay TS 3.4.16 Required Action A.1 shal bebs in he applicable specification. for more than NOTE 1 hi~on the short term site specific DEl spiking 48 hours). Therefore the Completion Time for .e limit to be consistent with the assumptions ni le gas activity being out of specification ______________________ contained in the radiological consequence the revised Required Action B.1 should be '"'o.h .plnb.analyses. I. least as great as tha Completion Time fo W-hile relying OR the ACT1QNs. Tlfif.'t4'/' 3..4T ..1 Apicbiit evsin odine specific activity being out of *.llwenm~is acceptable due to the significant specification in current Required Action A.2 cnevts no.rae noteseii TS 3.4.16 Applicability is modified to Therefore the Completion Time of 48 hours activity limit, the low probability of an event include MODE 3 and MODE 4. It is necessary for revised Required Action B3.1 is acceptable which is limiting due to exceeding this limit.for the LCO to apply during MODES 1 from a radiological dose perspective, and the ability to restore transient specific through 4 to limit the Condition Cailoia activity excursions while the plant remains posqecso GRoten LBtial railoial .1.7 TS 3.4.16 CnionCRevision at, or proceeds to power operation. This occur during these MODES. In MODES 5 and TS 3.4.16 Condition C is revised to include allows entry into MODE 4. MODE 3, and 6. the steam generators are not used for decay Condition B (DEX not within limit) if the MODE 2 prior to performing the surveillance. heat removal, the RCS and steam generators Required Action and associated Completion This allows the surveillance to be performed are depressurized, and primary to secondary Time of Condition B is not met. This is in any of those MODES, prior to entering leakage is minimal. Therefore, the monitoring consistent with the changes made to MODE 1, similar to the current surveillance of RCS specific activity during MODES 5 and Condition B which now provides the same SR 3.4.16.2 for DEL.6 is not required. The change to modify the completion time for both components of RCS 3.1.9 SR 3.4.16.3 Deletion TS 3.4.16 Applicability to include all of specific activity as discussed in the revision MODE 3 and MODE 4 is necessary to limit to Condition B. The revision to Condition C The current SR 3.4.16.3 which required the the potential radiological consequences of an also replaces the limit on DEl from the determination of E-Bar is deleted. TS 3.4.16 SGTR or MSLB that may occur during these deleted Figure 3.4.16-1 with a site specific LCO on RCS specific activity supports the MODES and is therefore acceptable from a value of,> 1601 pCi/gm. This change makes dose analyses for OBAs. in which the whole radiological dose perspective. Condition C consistent with the changes body dose is primarily dependent on the 3It3.1.5 TS 3.4.16 Condition A Revision made to TS 3.4.16 Required Action A.I. noble gas concentration, not the non-gaseous The change to TS 3.4.16 Required Action. activity currently captured in the E-Bar TS 3.4.16 Condition A is revised by C.1 requires the plant to be in MODE 3 definition. With-the elimination of the limit replacing the DEl site specific lirni. > 1.0 within 6 hours and adds a new Required for RCS gross specific activity and the;iCi/gm' with the words "not within limit' Action C.2 which requires the plant to be in addition of the new LCD limit for noble gas to be consistent with the revised TS 3.4.16 MODE 5 within 36 hours. These changes are specific activity. this SR to determine E-Bar LCO format. The site specific DEl limit of ossetwt h cagsmd oteT i olne eurd 11.01 pCi/gm and Required Action A.1 is 3s 4.1 Appicbilty TervsdLO5 3.P reed rent contained in SR 3.4.16.2. This change will applicable throughout all of MODES 13.Prcdn maintain the consistency of the proposed TS and s acepablefro a adioogialtose ough 4 to limit the potential radiological The Technical Specifications developed for erspective. consequences of an SGTR or MSLB that may the Westinghouse AP600 and AP1 000 occur during these MODES. In MODES 5 and advanced reactor designs incorporate an LCO 3.1.6 TS 3.4.16 Condition 13 Revision to 6, the steam generators are not used for decay for RCS DEX activity in place of the LCO on include Action for DEX Limit heat removal, the RCS and steam generators non-iodine gross specific activity based on E-TS 3.4.16 Conditioil s replaced with a are depressurized, and primary to secondary 'Bar. This approach was approved by the NRC new Condition B3 fo DPX ntwthin limits, leakage is minimal. Therefore, the monitoring for the AP600 in NUREG-1512, "Final Safety This change is made tol neconsIsent with the of RCS specific activity during MODES 5 and Evaluation Report Related to the Certification change to the TS 3.4.1qf LCO which requires 6 is not required. of the AP600 Standard Design. Docket No.the DEX specific activfty to be within limits A new TS 3.4.16 Required Action C.2 52-003," dated August 1998 and for the as discussed above. T eDXlitsste Completion Time of 36 hours is added for the AP1000 in the NRC letter to Westinghouse specific and then~ bri value in units of plant to reach MODES5. This Completion Electric Company dated September

13. 2004.pjCi/gm is con de in revised SR 3.4.16.1.

Time is reasonable, based on operating In addition the curve describing the The site specifc lijit of DEX jiCilgrn is experience, to reach MIODE 5 from full power maximum allowable iodine concentration established based $n the maximum accident conditions in an orderly manner and without during the 48-hour period of elevated activity analysis RCS acti ity corresponding to 1% challenging plant systems and the value of 36 as a function of power level, was not fuel clad defect with sufficient margin to hours is consistent with other TS which have included in the TS approved for the AP600 accommodate ie exclusion of those isotopes a Completion Time to reach MODE 5. and API 000 advanced reactor designs.ý _qIV1,n Nac- 14-31 C ;,A/mr, N -/4-26?o a4 / ~a A677-I14-2. J Federal Register/Vol. 71, No. 223/Monday. November 20, 2006/Notices677 67175

4.0 STATE CONSULTATION

In accordance with the Commission'.s regulations, the [i State official was notified of the proposed issuance of the amendment. The State official had 0)1 no comments or (2)the following comments-with subsequent disposition by the staff].5.0 ENVIRONMENTAL CONSIDERATION The amendmnentisl changelsi a requirentent with respect to the installation or use of a facility component located within the restricted area as dofined in 10 CFR Part 20 or surveillance requirements. The NRC staff has determined that the amendment involves 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 amendment involves no signi ficant hazards consideration and there has been no public comment on such finding published [DATE]([I JFR IIJ). Accordingly, the amendment meets 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 amendment.

6.0 CONCLUSION

The Commission hans concluded, based on the considerations discussed above, that (11 there is reasonable assurance that the health and safety of the public wilt not be endangered by operation in the proposed manner. (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.Proposed No Significant Hazards Consideration Detertmination Description of Amendment Request:[LICENSEE) requests adoption of an approved Change to the standard technical specifications (STS) for Pressurized Water Reactor (PWR) Plants [NUREG-143o, NUREG-1431. or NUJREG-14321 and the[LICENSEE] technical specifications (TS), to 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-1 33 and would take into account only the noble gas activity in the primary coolant. The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-490.Basis for proposed no-significont-hazt-rds-consideration determination: As required by 10 CFR 50.91 (a). an analysis of the issue of no-significant-hazards-consideration is presented below: Criterion I-The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of on Accident Previously Evaluated Reactor coolant specific activity is not an initiator for any accident previously evaluated. The Completion Time when primary coolant gross activity is not within limit is not an initiator for any accident previously evaluated. The current variable limit on primary coolant iodine concentration is not an initiator to any accident previously evaluated. As a result.the proposed change does not significantly increase the probability of an accident. The proposed change will limit primary coolant noble gases to concentrations consistent with the accident analyses. The proposed change to the Completion Time has no impact on the consequences of any design basis accident since the consequences of an accident during the extended Completion Time are the same as the consequences of an accident d uring the Completion Time. As a result, the consequences of any accident previously evaluated are not significantly increased. Criterion 2-The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident fromt any Previously Evaluated The proposed change in specific activity limits does not alter any physical part of the plant nor does it affect any plant operating parameter. The change does not create the potential for a new or different kind of accident from any previously calculated. Criterion 3-The Proposed Change Does Not Involve a Significant Reduction in the Margin of Safety The proposed change revises the limits on noble gase radioactivity in the primary coolant. The proposed change is consistent with the assumptions in the safety analyses and will ensure the monitored values protect the initial assumptions in the safety analyses.Based upon the reasoning presented above and the previous discussion of the amendment request, the requested change does not involve a significant hazards consideration. Dated at Rockville. Maryland. this __day of-, XXXX.For The Nuclear Regulatory Commission Project Manager, Plant Licensing Branch IL. Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation Enclosure 2-[Proposed Technical Specification Changes and Technical Specification Bases Changes]Enclosure 3-[Final Technical Specification and Bases Pages]IFR Dec. 06-9330 Filed 11-17-06; 8:45 aml BILLING CODE 7590-0l-P OVERSEAS PRIVATE INVESTMENT CORPORA71ON -Agency Information Collection Activities: Proposed Collection; Comment Request AGENCY: Overseas Private Investment Corporation (OPIC).ACTION: Request for comments.

SUMMARY

In compliance with the Paperwork Reduction Act (44 U.S.C.3501 et seq.), this notice announces that OPIC is planning to submit the following proposed Information Collection Request (ICR) to the Office of Management and Budget (0MB): OPIC 2006 Client Satisfaction Survey. Before submitting the ICR to OMB for review and approval.

OPIC is soliciting public comment on the client survey.Comments are being solicited on the need for the information, its practical utility, the accuracy of the Agency's burden estimate, and on ways to minimize the reporting burden. The proposed ICR is summarized below.DATES: All comments must be received by OPIC within 60 calendar days from the publication date of this Notice.ADDRESSES: Information regarding this information collection request and/or a copy of the survey questions can be obtained from the Agency Submitting Officer below. Comments on the survey should be submitted to the Agency Submitting Officer.FOR FURTHER INFORMATION CONTACT: OPIC Agency Submitting Officer: Essie Bryant, Records Manager. Overseas Private Investment Corporation. 1100 New York Av'enue, NW., Washington, DC 20527, telephone (202) 336--8563. SUPPLEMENTARY INFORMATION: Type of Request: New information collection. Title: 2006 OPIC Client Satisfaction Survey.0MB Approval Number: None.Frequency of Response: Once per client.Type of Respondents: Individual business officer representatives of U.S.companies sponsoring projects overseas.Respondent's Obligation: Voluntary. Affected Public: U.S. companies or citizens sponsoring projects overseas.Estimated Number of Respondents: 100.Estimated time Per Response: 30 minutes.Estimated Total Annual Burden: $0.Authority for Information Collection: Sections 231 and 234 of the Foreign Assistance Act of 1961, as amended.Abstract (Needs and Uses of Information Collected): OPIC is PagelI otIl NRCREP -Comments on TSTF-490 (E-Bar Deletion) CLIIP FR Notice for Comment From: "Yates, George G" <GYates@ameren.com> To: <CLIIP @nrc .gov>Date: 12/20/2006 8:43 PM

Subject:

Comments on TSTF-490 (E-Bar Deletion) CL11P FR Notice for Comment See attached comment letter which is also being mailed in hard copy.Bert Yates gyates @ ameren.com 314-554-3573

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