Text

License Amendment Request 06-01 Revision to Technical Specification 1.1, Definitions, and Technical Specification 3.4.16, RCS Specific Activity
	ML060390359
Person / Time
Site:	Diablo Canyon
Issue date:	01/25/2006
From:	Oatley D; Pacific Gas & Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	DCL-06-008
	Download: ML060390359 (46)
	v • d • e

W Pacific Gas and I'

Electric Company David H. Oatley Diablo Canyon Power Plant Vice President and PO. Box 56 General Manager Avila Beach, CA 93424 January 25, 2006 805.545.4350 Fax: 805.545.4234 PG&E Letter DCL-06-008 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 License Amendment Request 06-01 Revision to Technical Specification 1.1. "Definitions," and Technical Specification 3.4.16. "RCS Specific Activity"

Dear Commissioners and Staff:

In accordance with 10 CFR 50.90, enclosed is an application for amendment to Facility Operating License Nos. DPR-80 and DPR-82 for Units 1 and 2 of the Diablo Canyon Power Plant (DCPP) respectively. The enclosed license amendment request (LAR) proposes to revise Technical Specification (TS) 1.1, "Definitions," and TS 3.4.16, "RCS Specific Activity."

The LAR proposes to replace the current TS 3.4.16 limit on reactor coolant system (RCS) gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new DOSE EQUIVALENT XE-1 33 definition (corresponding to the Xenon-1 33 isotope) that would replace the current E - AVERAGE DISINTEGRATION ENERGY definition. In addition, the current DOSE EQUIVALENT 1-131 definition (corresponding to the Iodine-131 isotope) would be revised to allow the use of alternate, NRC-approved thyroid dose conversion factors.

This change is being proposed in order to implement an RCS specific activity Limiting Condition for Operation (LCCI) that reflects the whole body radiological consequence analysis assumptions. Those assumptions are sensitive to the noble gas activity in the primary coolant, but not to the other, nongaseous activity currently captured in the current Edefinition. The current -Edefinition includes radioisotopes that decay by the emission of both gamma and beta radiation. Current Condition B of LCO 3.4.16 would rarely, if ever, be entered for exceeding 1O0/E since that value is very high (the denominator is very low) if beta emitters such as tritium and Fluorine-18 are included in that value, as required by the E definition.

A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek 140c

Document Control Desk PG&E Letter DCL-06-008 January 25, 2006 Page 2 Pacific Gas and Electric Company (PG&E) is submitting this LAR in conjunction with an industry consortium of six plants as a result of a mutual agreement known as Strategic Teaming and Resource Sharing (STARS). The STARS group consists of the six plants operated by TXU Power, AmerenUE, Wolf Creek Nuclear Operating Corporation, PG&E, STP Nuclear Operating Company, and Arizona Public Service Company.

PG&E's DCPP is the lead STARS plant for this amendment request. Wolf Creek Nuclear Operating Corporation submitted a similar amendment request on October 28, 2005. Other members of the STARS group can also be expected to submit an LAR similar to this one. The other LARs will be submitted with plant-specific information presented within brackets (i.e., within [ ]) in Enclosure 1 (other than TS LCO numbers which vary between the TS based on NUREG-0452, NUREG-1431, and NUREG-1432). All other enclosures are plant-specific in nature.

The TS developed for the Westinghouse AP600 and AP1000 advanced reactor designs utilize an LCO for RCS DOSE EQUIVALENT XE-133 specific activity in place of the LCO on gross specific activity based on E. This approach was approved by the NRC for the AP600 in NUREG-1 512, "Final Safety Evaluation Report Related to the Certification of the AP600 Standard Design, Docket No.52-003," dated August 1998, and for the AP1 000 in the NRC letter to Westinghouse Electric Company dated September 13, 2004. contains a description of the proposed change, the supporting technical analyses, and the no significant hazards consideration determination. Enclosures 2 and 3 contain marked-up and retyped (clean) TS pages, respectively. Enclosure 4 provides the marked-up TS Bases changes for information only. TS Bases changes will be implemented pursuant to TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment: is implemented. Enclosure 5 provides the marked-up Final Safety Analysis Report Update changes for information only. A revision to the fuel damage Emergency Plan Emergency Action Level that reflects the approved TS 3.4.16 limits will be implemented at the time the amendment is implemented.

PG&E has determined that this LAR does not involve a significant hazard consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The change in this LAR is not required to address an immediate safety concern.

PG&E requests approval of this LAR no later than January 1, 2007. PG&E requests A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek

Document Control Desk January 25, 2006 Page 3 PG&E Letter DCL-06-008 the license amendment(s) be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance.

This communication contains no new or revised commitments.

If you have any questions or require additional information, please contact Stan Ketelsen at 805-545-4720.

Sincerely, David H. Oatley Vice President and General Manager kjse/4328 Enclosures cc:

Edgar Bailey, DHS Terry W. Jackson Bruce S. Mallett Diablo Distribution cc/enc: Alan B. Wang A member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek

PG&E Letter DCL-06-008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

) Docket No. 50-275 In the Matter of

) Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY)

No. DPR-80

)

Diablo Canyon Power Plant

) Docket No. 50-323 Units 1 and 2

)

Facility Operating License

__)

No. DPR-82 AFFIDAVIT David H. Oatley, of lawful age, first being duly sworn upon oath says that he is Vice President and General Manager of Pacific Gas and Electric Company; that he has executed license amendment request 06-01 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.

David H. Oatley Vice President and General Manager Subscribed and sworn to before me this 25th day of January, 2006, by David H. Oatley, personally known to me or proved to me on the basis of satisfactory evidence to be the person who appeared before me.

PG&E Letter DCL-06-008 EVALUATION

1.0 DESCRIPTION

This letter is a request to amend Operating Licenses DPR-80 and DPR-82 for Units 1 and 2 of the Diablo Canyon Power Plant (DCPP), respectively.

The proposed amendment would revise Technical Specification (TS) 1.1, "Definitions," and TS 3.4.16, "RCS Specific Activity." The proposed changes would replace the current TS 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 TS DOSE EQUIVALENT XE-1 33 (DEX) definition that would replace the current TS E -AVERAGE DISINTEGRATION ENERGY definition. In addition, the current DOSE EQUIVALENT 1-131 (DEI) definition would be revised to allow alternate, NRC-approved thyroid dose conversion factors.

2.0 PROPOSED CHANGE

The TS Section 1.1 definition for DEl would be revised from:

"DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131,1-132,1-133,1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in [Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or those listed in Table E-7 of NRC Regulatory Guide 1.109, Rev. 1, October, 1977, or those listed in International Commission on Radiological Protection Publication 30, "Limits for Intakes of Radionuclides by Workers," 1979.]"

to "DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131,1-132,1-133, 1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from [Table III of TID-14844, AEC, 1962, "Calculation of Distance Factors for Power and Test Reactor Sites," or Table E-7 of Regulatory Guide 1.109, Revision 1, NRC, 1977, or International Commission on Radiological Protection (ICRP) Publication 30,1979, Supplement to Part 1, pages 192-212, Table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity," or Table 2.1 of EPA Federal 1

PG&E Letter DCL-06-008 Guidance Report No. 11, 1988, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."]"

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

"DOSE EQUIVALENT XE-1 33 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-87, Kr-88, 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 lactors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."]"

TS Limiting Condition for Operation (LCO) 3.4.16, "RCS Specific Activity," would be revised from:

"The specific activity of the reactor coolant shall be within limits."

to "RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-1 33 specific activity shall be within limits."

The current TS Figure 3.4.16-1, "E)ose Equivalent 1-131 Reactor Coolant Specific Activity Limit Versus Percent of Rated Thermal Power with the Reactor Coolant Specific Activity > 1 pCi/gram Dose Equivalent 1-131" would be deleted.

The Applicability of TS 3.4.16 would be revised from:

"MODES 1 and 2, MODE 3 with RCS average temperature (Tavg) 2 500°F."

to "MODES 1, 2, 3, and 4."

TS 3.4.16 Condition A would be revised from:

"DOSE EQUIVALENT 1-1311 specific activity > 1.0 pCi/gm."

to 2

Enclosure I PG&E Letter DCL-06-008 "DOSE EQUIVALENT 1-131 not within limit."

TS 3.4.16 Required Action A.1 would be revised from:

"Verify DOSE EQUIVALENT 1-131 specific activity within the acceptable region of Figure 3.4.16-1."

to "Verify DOSE EQUIVALENT 1-131 5 60 pCi/gm."

[TS 3.4.16 Required Action A.2 would be revised from:

"Restore DOSE EQUIVALENT 1-131 specific activity to within limit."

to "Restore DOSE EQUIVALENT 1-131 to within limit.']

TS 3.4.16 Condition B would be revised from:

"Gross specific activity of the reactor coolant 100/E pCi/gm."

to "DOSE EQUIVALENT XE-1 33 not within limit."

TS 3.4.16 Required Action B.1 would be revised from:

"Be in MODE 3 with Tavg to < 500°F."

to

NOTE--------------

LCO 3.0.4c is applicable.

Restore DOSE EQUIVALENT XE-1 33 to within limit."

TS 3.4.16 Required Action B.1 completion time would be revised from "6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months " to "48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ."

TS 3.4.16 Condition C would be revised from:

3 PG&E Letter DCL-06-008 "Required Action and associated Completion Time of Condition A not met.

OR DOSE EQUIVALENT 1-131 specific activity in the unacceptable region of Figure 3.4.16-1."

to "Required Action and associated Completion Time of Condition A or B not met. OR DOSE EQUIVALENT 1-131 > 60 pCi/gm."

TS 3.4.16 required action(s) for Condition C would be revised from:

"C.1 Be in MODE 3 with Tavg to < 500'F."

to "C.1 Be in MODE 3.

AND C.2 Be in MODE 5."

TS 3.4.16 Condition C would be revised to add a completion time for new Required Action C.2 of "36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ." Note: The completion time for Required Action C.1 would remain 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Surveillance Requirement (SR) 3.4.16.1 would be revised from:

"Verify reactor coolant gross specific activity S1 OOIE pCi/gm."

to

NOTE----------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT XE-1 33 specific activity s [600.0] pCi/gm."

Current SR 3.4.16.3 would be deleted.

In summary, the proposed changes will revise the definition of DEI, delete the definition of E-AVERAGE DISINTEGRATION ENERGY, add a new definition for DEX, revise TS 3.4.16 to specify an LCO limit on DEl, add a new LCO 3.4.16 limit for DEX, increase the completion time of Required Action B.1, delete TS Figure 3.4.16-1, and revise the conditions and required actions accordingly.

Also, the applicability of LCO 3.4.16 is extended to reflect the modes during 4

PG&E Letter DCL-06-008 which pertinent accidents (steam generator tube rupture (SGTR) or main steam line break (MSLB)) could be postulated to occur, SR 3.4.16.1 is revised to verify DEX prior to MODE 1 entry, and SR 3.4.16.3 is deleted.

The TS Bases for LCO 3.4.16 would be revised to reflect the proposed changes and to incorporate the bases for the proposed changes. The TS Bases changes are included for information only.

The proposed TS change is noted on the marked-up TS pages provided in. The proposed retyped TS pages are provided in Enclosure 3. The revised TS Bases is contained for information only in Enclosure 4. Enclosure 5 provides the marked-up Final Safety Analysis Report (FSAR) Update changes for information only.

3.0 BACKGROUND

3.1 Radiological consequence analyses Radiological consequence analyses are performed for the SGTR accident and for the MSLB accident since these events involve the release of primary coolant activity. For events that also result in fuel damage (such as locked rotor, rod ejection, and loss-of-coolant accident) as a result of the accident, the dose contribution from the initial activity in the RCS is insignificant.

The maximum dose to the whole body and the thyroid that an individual at the exclusion area boundary can receive for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months following an accident, or at the low population zone outer boundary for the radiological release duration, is specified in 10 CFR 100.11. The limits on RCS specific activity ensure that the offsIlte doses are appropriately limited, as required by NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," 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, for MSLB accidents and NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 15.6.3, "Radiological Consequences of Steam Generator Tube Failure (PWR)," Revision 2, for SGTR accidents.

The maximum dose to the whole body, or its equivalent to any part of the body, that an individual can receive in the plant control room for the duration of an accident is specified in General Design Criterion 19 (GDC 19) contained in Appendix A to 10 CFR 50. The limits on RCS specific activity ensure that the doses are less than the GDC 19 limits during analyzed transients and accidents, as required by NUREG-0800, Section 6.4, "Control Room Habitability System," Revision 2, and Regulatory Position C.4.5 of NRC Regulatory Guide (RG) 1.195, "Methods 5

PG&E Letter DCL-06-008 and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors."

The SGTR and MSLB radiological consequence analyses establish the acceptance limits for the TS 3.4.16 RCS specific activity. These analyses consider two cases of RCS iodine specific activity. Case 1 assumes that an accident-initiated iodine spike occurs, which results in an increase in the rate of iodine release from the fuel rods containing cladding defects to the primary coolant immediately after an MSLB or SGTR. Case 2 assumes that a preaccident iodine spike occurs due to a transient prior to the MSLB or SGTR. The results of the SGTR radiological consequence analyses are described in [FSAR Update sections 15.5.20.1 and 15.5.20.2]. The results of the MSLB radiological consequence analyses are described in [FSAR Update section 15.5.18.1].

[The Case 1 radiological consequence analyses for SGTR and MSLB assume that the initial reactor coolant iodine specific activity corresponds to an isotope mixture that bounds the proposed LCO 3.4.16 limit. The initial isotopic mix establishes the relative concentrations for each isotope.

The iodine concentrations are then changed to achieve a DEl of 1.0 pCi/gm, while maintaining the initial isotopic ratios.]

This analysis assumption provides the basis for the iodine specific activity limit of 1.0 pCi/gm contained in current TS 3.4.16 Condition A and SR 3.4.16.2. Thyroid dose conversion factors based on [Table E-7 of NRC RG 1.109, Revision 1, 1977, or ICRP Publication 30,1979, have been used in radiological consequence analyses performed to date.] Any of the NRC-approved thyroid dose conversion factor references cited in the revised definition of DOSE EQUIVALENT 1-131 may be used in future analyses after this amendment is approved.

Case 1 also assumes an accident-initiated iodine spike that increases the rate of iodine release from ithe fuel rods containing cladding defects to the primary coolant immediately after an MSLB or SGTR. The iodine spiking factor is assumed to be [500 for all of the MSLB and SGTR radiological consequence evaluation calculations except the SGTR exclusion area boundary calculation. The iodine spiking factor is assumed to be 335 for the SGTR radiological consequence evaluation calculation for the exclusion area boundary.]

[The Case 2 radiological consequence analyses for SGTR and MSLB assume the initial reactor coolant iodine specific activity is a factor of 60 higher than Case 1 due to a preaccident iodine spike caused by a transient prior the accident.] This [bounds] the allowable RCS specific activity value of 60 pCi/gm contained in current TS Figure 3.4.16-1 for 6

Enclosure I PG&E Letter DCL-06-008 RATED THERMAL POWER (RTP) between 80 percent and 100 percent. TS Figure 3.4.16-1 provides DEI concentration limits during short periods in which iodine spiking may occur due to a power transient.

In both Cases 1 and 2 radiological consequence analyses for SGTR and MSLB, the noble gas specific activity in the reactor coolant is assumed to be [651] guCi/grn DEX. The initial DEX concentrations were calculated assuming [1 percent failed fuel] and using [whole body dose conversion factors for air submission based on Table 111.1 of EPA Federal Guidance Report No. 12, EPA-402-R-93-081, "External Exposure to Radionuclides in Air, Water, and Soil," 1993].

3.2 RCS Specific Activity The RCS specific activity level is used in design basis accident analyses to determine the thyroid and whole body radiological consequences of accidents that involve the release of RCS activity. For events that also include fuel damage, the dose contribution from the initial activity in the RCS is insignificant.

The current definition for DIEl is based on thyroid dose conversion factors and reflects a licensing model in which the radiological consequences of iodine releases for accidents are reported as thyroid and whole body doses.

LCO 3.4.16 specifies the limit for RCS gross specific activity as 100/E pCi/gm. "E" is defined as:

"E shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives > [10] minutes, making up at least 95% of the total non-iodine activity in the coolant."

In performing accident dose analyses in which primary coolant is released, the concentration of noble gas activity in the coolant is assumed to be that level associated with [1 percent failed fuel], which closely approximates the TS 3.4.16 limit of 1O0/E pCi/gm under accident conditions.

LCO 3.4.16 specifies a limit for RCS iodine concentration during equilibrium operation. In recognition of the potential for exceeding the equilibrium iodine concentration due to iodine spiking following power transients, the LCO also permits the equilibrium value to be exceeded for 7

PG&E Letter DCL-06-008 a period of less than or equal to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . As currently presented, the value for the maximum allowable iodine concentration during the 48-hour period of elevated activity is a function of power level as provided in TS Figure 3.4.16-1. In accordance with the figure, as power is reduced below 80 percent RTP, the allowable RCS iodine concentration increases from 60 pCi/gm DEI to as high as [275] pCi/gm DEI at [25] percent RTP.

Below [25] percent RTP, no further increase is defined.

The curve contained in TS Figure 3.4.16-1 was initiated by the Atomic Energy Commission (AEC) in a June 12, 1974, letter from the AEC on the subject, "Proposed Standard Technical Specifications for Primary Coolant Activity." This letter does not provide any technical basis for the curve.

3.3 Purpose for Proposed Amendments The addition of the new DEX limit and TS 3.4.16 changes are being proposed in order to implement an RCS specific activity LCO that better reflects the whole body radiological consequence analyses, which are sensitive to the noble gas activity in the primary coolant but not to the other, nongaseous activity currently captured in the E definition. The E definition includes radioisotopes that decay by the emission of both gamma and beta radiation. Current Condition B of LCO 3.4.16 would rarely, if ever, be entered for exceeding 1 00/E since that value is very high (the denominator is very low) if beta emitters such as tritium (H-3) and Fluorine-1 8 (F-1 8) are included in that value, as required by the Edefinition. []

4.0 TECHNICAL ANALYSIS

4.1 TS Chanaes Revision to Definition of DEI The current TS 1.1 definition for DEI is revised [to specify the table in which the ICRP 30 thyroid (lose conversion factors are located and] to add a new reference for acceptable thyroid dose conversion factors. Also, the word "thyroid" is deleted from the first sentence, [the word "October" is deleted from the RG 1.109 reference, and the title of ICRP 30 is removed].

[The specific Table in ICRP 30 Supplement to Part 1 located on pages 192-212 and titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity" is added to the current definition for DEI. This change adds clarification to the location of the thyroid dose conversion factors in ICRP 30 and does not revise the ICRP 30 thyroid dose conversion factors currently allowed by TS 1.1. The revision to the 8

PG&E Letter DCL-06-008 TS 1.1, "Definitions," to allow use of the ICRP 30 thyroid dose conversion factors was previously approved by the NRC in License Amendments 155 and 155 for DCPP Units 1 and 2 respectively on October 21, 2002.]

A new thyroid dose conversion factor reference [is] added to the DEI definition. The new reference [is] "Table 2.1 of EPA Federal Guidance Report No. 11, 1988, "Limiling Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion." EPA Federal Guidance Report No. 11 is referenced in RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors," May 2003, Sectilon C, "Regulatory Position," Subsection 4, "Dose Calculational Methodology," Subsection 4.1, "Offsite Dose Consequences," assumption 4.1.2 as acceptable for determining thyroid dose from inhalation. [The thyroid dose conversion factor values contained in Table 2.1 of EPA Federal Guidance Report No. 11 are provided to 3 significant digits. The thyroid dose conversion factor values contained in ICRP 30 Supplement to Part I pages 192-212 and Table 2.1 of EPA Federal Guidance Report No. 11 are the same when the EPA Federal Guidance Report No. 11 values are rounded to 2 significant digits.]

The deletion of the word "thyroid" from the first sentence, [the word "October" from the RG 1.109 reference, and the title of ICRP 30] [are]

editorial change[s] only. [The month is removed from the RG 1.109 reference since it is unnecessary and the removal provides consistency in the DEI definition, which does not specify the month for the other referenced documents. The deletion of the title of ICRP 30 provides consistency with the current reference to RG 1.109 which does not include the title.]

Deletion of Definition for E-AVERAGE DISINTEGRATION ENERGY and Addition of New Definition for DEX The current TS 1.1 Definition for E -AVERAGE DISINTEGRATION ENERGY is deleted and replaced with a new definition for DEX.

When E is determined using a design basis approach in which it is assumed that 1 percent of the power is generated by fuel rods having cladding defects and there is no removal of fission gases from the RCS letdown flow, the value of E: is dominated by the Xe-1 33 isotope. The other nuclides have relatively small contributions. However, during normal plant operation there are typically only a small amount of fuel defects and the radioactive nuclide inventory can become dominated by tritium and corrosion and/or activation products, resulting in the determination of a 9

PG&E Letter DCL-06-008 value of E that is very different than that which would be calculated using the design basis approach. Therefore, the radiological consequence analyses for accidents become disconnected from normal plant operation and the current TS 3.4.16 limit on gross specific activity is essentially meaningless. The use of E also results in a TS limit that can vary during operation as different values for E are determined, resulting in different values for the gross specific activity limit (1 OOIE PCi/gm).

Additionally, since the concern associated with the RCS noble gas activity is the acute whole body dose that the operators and the general public might receive in the event of a postulated accident, the manner in which E is calculated gives undue importance to nuclides that are primarily beta radiation emitters. Beta radiation will contribute to a skin dose, but not to the whole body dose. Dose limits for the general population do not include consideration of the beta skin dose.

Therefore, the deletion of the current TS 1.1 Definition for E-AVERAGE DISINTEGRATION ENERGY and addition of a new definition for DEX will result in TS 3.4.16 requirements for RCS specific activity, which are consistent with the assumptions contained in the radiological consequence analyses.

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 DEI, except that the calculation of DEX is based on the acute dose to the whole body and considers the noble gases

[Kr-85m, Kr-87, Kr-88, Xe-1 33m, Xe-1 33, Xe-135m, Xe-1 35, and Xe-1 38],

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 dose conversion factor. Exclusion of Kr-85 and Xe-131 m results in less than 1 percent of the whole body dose contributions from noble gases in the SGTR and MSLB radiological consequence analyses.]

If a specific 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.

The new definition of DEX states that the determination of DEX shall be performed using the effective dose conversion factors for air submersion listed in Table 111.1 of EPA F~ederal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil." [ ]. These dose conversion factors are applicable for determination of DEX. The use of the dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12 is endorsed by RG 1.195, Subsection 4.1, assumption 4.1.4 as acceptable for determining whole 10 PG&E Letter DCL-06-008 body doses because of the uniform body exposure associated with semi-infinite cloud dose modeling.

TS 3.4.16 LCO Revision The TS 3.4.16 LCO is modified to specify that the iodine specific activity in terms of DEI and noble gas specific activity in terms of DEX shall be within limits.

Currently TS 3.4.16 states that the specific activity of the reactor coolant shall be within limits. The limits are currently not explicitly identified in the LCO but are instead defined in current Condition B and SR 3.4.16.1 for gross specific activity and in current Condition A and SR 3.4.16.2 for iodine specific activity.

The proposed change states "RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-1 33 specific activity shall be within limits." The DEI limit of less than or equal to 1.0 pCi/gm is contained in current Condition A and SR 3.4.16.2. In addition, the limit of 1.0 pCi/gm is consistent with the current SGTR and MSLB radiological consequence analyses discussed in Section 3.1 above.

The DEX limit of less than or equal to [600.0] pCi/gm is contained in revised SR 3.4.16.1 and is [less than the value of 651 pCi/gm. The DEX limit of 600.0 pCi/gm is bounded by the current SGTR and MSLB radiological consequences analyses discussed in Section 3.1 above which assumed a DEX value of 651 pCi/gm. The noble gas specific activity limit is based on the maximum accident analysis activity (equivalent to approximately 651 pCi/gm IDEX) with approximately 8 percent margin.

This margin more than accommodates the exclusion of those isotopes based on low concentration, short half life, or small dose conversion factors.]

The primary purpose of the TS 3.4.16 LCO on RCS specific activity is to support the dose analyses for design basis accidents. Whole body doses are primarily dependent on the noble gas concentration, not the nongaseous activity currently captured in the E definition. It is appropriate to have the TS 3.4.16 LCO apply to the noble gas specific activity in the RCS. Thus, it is acceptable that the current TS 3.4.16 limit on gross specific activity can be replaced by an LCO limit based on RCS noble gas specific activity in the form of DEX. The limit on the amount of noble gas activity in the RCS remains consistent with design basis accident radiological consequences analyses and would not fluctuate with variations in the calculated value of E during normal operation as is currently the case.

11 PG&E Letter DCL-06-008 TS 3.4.16 Applicability Revision The TS 3.4.16 Applicability is modified to include all of Mode 3 and Mode 4. It is necessary for the LCO to apply during all of Modes 1 through 4 to limit the potential radiological consequences of an SGTR or MSLB that may occur during these modes. In Modes 5 and 6, the steam generators (SG) are not used for decay heat removal, the RCS and SGs are depressurizeci, and primary to secondary leakage is minimal.

Therefore, the monitoring cf RCS specific activity during Modes 5 and 6 is not required.

TS 3.4.16 Condition A Revision TS 3.4.16 Condition A is revised by replacing the limit ">1.0 pCi/gm" with the words "not within limit" 1:o be consistent with the Revised TS 3.4.16 LCO format. The DEI limit of less than or equal to 1.0 pCi/gm is contained in SR 3.4.16.2. [The words; "specific activity" are removed from TS 3.4.16 Condition A. These words are not required because they are redundant to the words proposed in the revised LCO 3.4.16. This change makes the TS 3.4.16 Condition A consistent with the wording used in NUREG-1431, Volume 1, Revision 3, "Standard Technical Specifications Westinghouse Plants," dated June 2004.]

TS 3.4.16 Required Action sl A.1 [and A.21 Revision TS 3.4.16 Required Action A.1 is modified to remove the reference to Figure 3.4.16-1 and insert a limit of less than or equal to 60 j.Ci/gm for DEL.

The curve contained in Figure 3.4.16-1 was initiated by the AEC in a June 12, 1974, letter from the AEC on the subject, "Proposed Standard Technical Specifications for Primary Coolant Activity." However, this letter does not provide any technical basis for the curve.

The Case 2 radiological consequence analyses for SGTR and MSLB accidents that take into account the preaccident iodine spike do not consider the elevated RCS iodine specific activities permitted by current TS Figure 3.4.16-1 for operation at power levels below 80 percent RTP (i.e., DEI of 60 pCi/gm at 80 percent RTP increasing linearly to

[275] pCi/gm at [25] percent RTP). Instead, the Case 2 analyses assume a DEI concentration 60 times higher than the corresponding accident's Case 1 analysis assumption, [which corresponds to the 60 pCi/gm specific activity limit associated with 100 percent RTP operation as discussed in Section 3.1 above]. Therefore, TS 3.4.16 Required Action A.1 should be 12 PG&E Letter DCL-06-008 based on a limit of 60 pCi/gm to be consistent with the assumptions contained in the radiological consequence analyses. It is not expected that plant operation at reduced power levels would result in iodine specific activity levels that exceed the 60 pCi/gm upper limit defined for full power operation.

[The words "specific activity" are removed from TS 3.4.16 Required Actions A.1 and A.2. These words are not required because they are redundant to the words proposed in new LCO 3.4.16. This change makes the TS 3.4.16 Required Actions A.1 and A.2 consistent with the wording used in NUREG-1431, Volume 1, Revision 3, "Standard Technical Specifications Westinghouse Plants," dated June 2004.]

TS 3.4.16 Condition B Revision to Include Action for DEX Limit Current TS 3.4.16 Condition B is replaced with a new Condition B for DEX not within limits. This change is made to be consistent with the change to the TS 3.4.16 LCO, which requires the DEX specific activity to be within limits as discussed above. The DEX limit of [600.0] pCi/gm is contained in revised SR 3.4.16.1. The limit of [600.0] pCi/gm is [bounded by the current SGTR and MSLB radiological consequence analyses, which assume the steady state initial RCS noble gas specific activity is

[651] iCi/gm DEX for both the Case 1 and Case 2 analyses.] The primary purpose of the TS 3.4.16 L.OC on RCS specific activity and its associated conditions is to support the dose analyses for design basis accidents. The whole body dose is primarily dependent on the noble gas activity, not the nongaseous activity currently captured in the E definition and limited by current TS 3.4.16 Condition B.

The completion time for revised TS 3.4.16 Required Action B.1 will require restoration of DEX to within limit in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This is consistent with the completion time for current Required Action A.2 for DEL. [Since the radiological consequences reported for SGTR and MSLB in FSAR Update Section 15.5.18.1 and FSAR Update Table 15.5-71 demonstrate that thyroid doses are a greater percentage of the applicable Standard Review Plan acceptance criteria than whole body doses, it then follows that the completion time for noble gas activity being out of specification in revised Required Action B.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.] The completion time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for revised Required Action B.1 is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of an MSLB or SGTR occurring during this time period.

13 PG&E Letter DCL-06-008 A NOTE is added, which slates that LCO 3.0.4c is applicable. This is consistent with the NOTE applicable to current Required Actions A.1 and A.2 for DEL. This NOTE permits entry into the applicable mode(s), relying on Required Action B.1 while the DEX LCO limit is not met. This mode change allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient-specific activity excursions while the plant remains at, or proceeds to, power operation.

TS 3.4.16 Condition C Revision TS 3.4.16 Condition C is revised to include Condition B, if the required action and associated completion time of Condition B is not met. This is consistent with the changes made to Condition B, which will no longer specify a shutdown track. Condition C is also revised to replace the limit on DEI from Figure 3.4.16-1 with a value of greater than 60 pCi/gm. This change makes Condition C consistent with the changes made to TS 3.4.16 Required Action A.1.

TS 3.4.16 Required Action C.1 is changed to require the plant to be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and a new Required Action C.2 is added, which requires the plant to be in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . These changes are consistent with the changes made to the TS 3.4.16 Applicability. The revised LCO 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. Therefore, Condition C needs to default to a Mode 5 end state for TS 3.4.16 to no longer be applicable.

A new TS 3.4.16 Required Action C.2 completion time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is added 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.

The value of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with other TS, which have a completion time to reach Mode 5.

SR 3.4.16.1 Revision to Include Surveillance for DEX The current SR 3.4.16.1 surveillance for RCS gross specific activity is deleted and replaced with a surveillance to verify that the reactor coolant DEX specific activity is less than or equal to [600.0] ptCi/gm. This change provides a surveillance for the new LCO limit added to TS 3.4.16 for DEX.

The revised SR 3.4.16.1 surveillance requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the 14 PG&E Letter DCL-06-008 reactor coolant at least once every 7 days. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. The surveillance provides an indication of any increase in the noble gas specific activity.

The results of the surveillance on DEX allow proper remedial action to be taken before reaching the L.CO limit under normal operating conditions.

The 7-day frequency considers the unlikelihood of a gross fuel failure during this time.

If a specific noble gas nuclide listed in the new definition for DEX in TS 1.1 is not detected, it should be assumed to be present at the minimum detectable activity. This is consistent with the new TS 1.1 Definition for DEX and will ensure a conservative calculation of DEX when noble gas nuclides are not detected.

The SR is modified by a NC)TE, which allows entry into Mode 4, Mode 3, and Mode 2 prior to performing the surveillance. This allows the surveillance to be performed in those modes, prior to entering Mode 1, similar to the current surveillance SR 3.4.16.2 for DEL.

SR 3.4.16.3 Deletion Current SR 3.4.16.3 is deleted. The TS 3.4.16 LCO on RCS specific activity supports the dose analyses for design basis accidents, in which the whole body dose is primarily dependent on the noble gas concentration, not the nongaseous activity currently captured in the Edefinition. Therefore, with the elimination of the limit for RCS gross specific activity and the addition of the new LCO limit for noble gas specific activity, this SR to determine E is no longer required.

4.2 Impact on Radiological Consequence Analyses The proposed changes do not impact the radiological consequences of any design basis accident. Replacing the limit on E with a limit on DEX based on the values used in the current radiological consequence analyses will limit the RCS noble gas concentrations to values which are consistent with the radiological consequence analyses, for those noble gases which are significant in terms of contribution to dose. These changes will also limit any potential RCS iodine specific activity excursion to the value currently associated with full power operation (i.e., 60 pCi/gm DEI). This concentration is more restrictive on plant operation than the current LCO, which allows operation up to [275] pCi/gm DEI as indicated in Figure 3.4.16-1. The proposed changes eliminate the potential for 15 PG&E Letter DCL-06-008 radiological consequences of a postulated accident to exceed those previously calculated.

4.3 Summary In summary, the proposed changes will revise the definition of DOSE EQUIVALENT 1-131, delete the definition of E-AVERAGE DISINTEGRATION ENERGY, add a new definition for DOSE EQUIVALENT XE-1 33, revise TS 3.4.16 to specify an LCO limit on DOSE EQUIVALENT 1-131, add a new LCO limit to TS 3.4.16 for DOSE EQUIVALENT XE-1 33, increase the completion time of Required Action B.1, delete TS Figure 3.4.16-1, and revise the TS 3.4.16 conditions and required actions acconJingly. Also, the Applicability of LCO 3.4.16 is extended to reflect the modes during which pertinent accidents (SGTR and MSLB) could be postulated to occur, SR 3.4.16.1 is revised to verify DOSE EQUIVALENT XE-1 33 is within the prescribed limit, and SR 3.4.16.3 is deleted.

The revised definition of DOSE EQUIVALENT 1-131 allows the use of thyroid dose conversion factors, which are acceptable for determining thyroid dose. The above changes will result in TS 3.4.16 requirements for RCS specific activity, which are consistent with the assumptions contained in the radiological consequence analyses. The primary purpose of the TS 3.4.16 LCO on RCS specific activity is to support the dose analyses for design basis accidents in which the whole body dose is primarily dependent on the noble gas specific activity, not the nongaseous activity currently captured in the Edefinition. The TS 3.4.16 conditions, required actions, and surveillance requirements are revised accordingly to support the deletion of the requirements for gross specific activity based on E and the addition of the new LCC) limit for DOSE EQUIVALENT XE-1 33. The proposed changes do not impact the radiological consequences of any design basis accident.

5.0 REGULATORY ANALYSIS

I This section addresses the standards of 10 CFR 50.92 as well as the applicable regulatory requirements and acceptance criteria.

The proposed amendment would revise the definition of DOSE EQUIVALENT 1-131, delete the definition of E-AVERAGE DISINTEGRATION ENERGY, add a new definition for DOSE EQUIVALENT XE-1 33, revise TS 3.4.16 to specify an LCO limit on DOSE EQUIVALENT 1-131, add a new LCO limit to TS 3.4.16 for DOSE EQUIVALENT XE-133, increase the completion time of Required Action B.1, delete TS Figure 3.4.16-1, and revise the TS 3.4.16 conditions and required actions accordingly. In addition, the Applicability of LCO 3.4.16 is extended to 16

Enclosure I PG&E Letter DCL-06-008 reflect the modes during which pertinent accidents (SGTR and MSLB) could be postulated to occur, SR 3.4.16.1 is revised to verify DOSE EQUIVALENT XE-1 33 is within the prescribed limit, and SR 3.4.16.3 is deleted.

5.1 No Significant Hazards Consideration

[PG&E] has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the 3 standards set forth in 10 CFR 50.92, 'Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes to add a new thyroid dose conversion factor reference to the definition of DOSE EQUIVALENT 1-131, eliminate the definition of E-AVERAGE DISINTEGRATION ENERGY, add a new definition of DOSE EQUIVALENT XE-133, replace the Technical Specification (TS) 3.4.16 limit on reactor coolant system (RCS) gross specific activity with a limit on noble gas specific activity in the form of a Limiting Condition for Operation (LCO) on DOSE EQUIVALENT XE-1 33, replace TS Figure 3.4.16-1 with a maximum limit on DOSE EQUIVALENT 1-131, extend the Applicability of LCO 3.4.16, and make corresponding changes to TS 3.4.16 to reflect all of the above are not accident initiators and have no impact on the probability of occurrence for any design basis accidents.

The proposed changes will have no impact on the consequences of a design basis accident because they will limit the RCS noble gas specific activity to be consistent with the values assumed in the radiological consequence analyses. The changes will also limit the potential RCS iodine concentration excursion to the value currently associated with full power operation, which is more restrictive on plant operation than the existing allowable RCS iodine specific activity at lower power levels.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

17 PG&E Letter DCL-06-008

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

Response: No.

The proposed changes do not alter any physical part of the plant nor do they affect any plant operating parameters besides the allowable specific activity in the RCS. The changes that impact the allowable specific activity in the RCS are consistent with the assumptions assumed in the current radiological consequence analyses.

Therefore, the proposed changes do not create the possibility of a new or different accident from any accident previously evaluated.

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

Response: No.

The acceptance criteria related to the proposed changes involve the allowable control room and offsite radiological consequences following a design basis accident. The proposed changes will have no impact on the radiological consequences of a design basis accident because they will limit the RCS noble gas specific activity to be consistent with the values assumed in the radiological consequence analyses. The changes will also limit the potential RCS iodine specific activity excursion to the value currently associated with full power operation, which is more restrictive on plant operation than the existing allowable RCS iodine specific activity at lower power levels.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, [PG&E] concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatorv Requirements/Criteria The regulatory guidance documents associated with this LAR include:

NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 15.1.5, "Steam System Piping Failures Inside and Outside cf Containment (PWR)," Appendix A, 18 PG&E Letter DCL-06-008 "Radiological Consequence of Main Steam Line Failures Outside Containment," Revision 2, that identifies the thyroid and whole body offsite radiological consequence acceptance criteria for main steam line break accidents.

NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 15.6.3, "Radiological Consequences of Steam Generator Tube Failure (PWR)," Revision 2, that identifies the thyroid and whole body offsite radiological consequence acceptance criteria for steam generator tube rupture accidents.

NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 6.4, "Control Room Habitability System,"

Revision 2, that identifies the thyroid, whole body, and beta skin radiological consequence acceptance criteria for control room occupants.

RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors," that provides acceptable dose conversion factors, radiological consequence acceptance criteria, and other dose analysis methodology parameters.

There are no changes being proposed in this amendment application such that commitments to the regulatory guidance documents above would come into question. The evaluations documented above confirm that

[DCPP] will continue to comply with all applicable regulatory requirements.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will 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.

6.0 ENVIRONMENTAL CONSIDERATION

[PG&E] has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental 19 PG&E Letter DCL-06-008 impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

7.1 References

1. Environmental Protection Agency (EPA) Federal Guidance Report No. 11, EPA-520/1-88-020, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," September 1988.

2. Environmental Protection Agency (EPA) Federal Guidance Report No. 12, EPA-402-R-93-081, "External Exposure to Radionuclides in Air, Water, and Soil," 1993.

3. International Commission on Radiological Protection (ICRP)

Publication 30, "Limits for Intakes of Radionuclides by Workers," ICRP, 1979.

4. Atomic Energy Commission (AEC) letter "Proposed Standard Technical Specifications for Primary Coolant Activity," dated June 12, 1974.

5. Regulatory Guide 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Light-Water Nuclear Power Reactors," May 2003.

6. Regulatory Guide 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 I," October 1977.

7. Atomic Energy Commission (AEC) Report TID-14844, "Calculation of Distance Factors for Power and Test Reactor Sites," March 1962.

8. NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," 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, July 1981.

9. NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 15.6.3, "Radiological Consequences of a Steam Generator Tube Failure (PWR)," Revision 2, July 1981.

10. NUREG-0800, "U.S. Nuclear Regulatory Commission Standard Review Plan," Section 6.4, "Control Room Habitability System,"

Revision 2, July 1981.

20 PG&E Letter DCL-06-008

11. NUREG-1 512, "Final Safety Evaluation Report Related to the Certification of the AP600 Standard Design, Docket No.52-003,"

August 1998.

12. NUREG-1431, Volume 1, Revision 3, "Standard Technical Specifications Westinghouse Plants," dated June 2004.

13. NRC License Amendment No. 155 to Facility Operating License No. DPR-80 and Amendment No. 155 to Facility Operating License No. DPR-82 for DCPP, Units 1 and 2, respectively, "Diablo Canyon Nuclear Power Plant, Unit Nos. 1 and 2 - Issuance of Amendment RE: Revision of Technical Specifications Section 3.9.4, Containment Penetrations (TAC Nos. MB3595 and MB3596)," dated October 21, 2002.

7.2 Precedent The TS developed for the Westinghouse AP600 and AP1 000 advanced reactor designs utilize an LCO for RCS DEX activity in place of the LCO on gross specific activity based on E. This approach was approved by the NRC for the AP600 in NUREG-1 512, "Final Safety Evaluation Report Related to the Certification of the AP600 Standard Design, Docket No.52-003," dated August 1998, and for the AP1 000 in the NRC letter to Westinghouse Electric Company dated September 13, 2004. The curve in current TS Figure 3.4.16-1 was not included in the TS approved for the AP600 and AP1 000 advanced reactor designs.

21 PG&E Letter DCL-06-008 Proposed Technical Specification Changes (marked-up)

l wnn Inale J

I I

I I\\Definitions 1.1 Definitions (continued) combined activities DOSE EQUIVALENT 1-131 DOSE EQUI L

T 1-131 all be that concentrationf r---------

1-131 (mic~rocurigram) t t alone would produce th Insert 1 same 1hyFeiedose as the quantity and icotopic mixtur--of 1-131, 1-132,1-133,1-134, and 1-135 actually present. The Rthyroid dose cersio factors used for this calculation Revision 1, NRC d be Table III of TID-14844, AEC, 1962, alculation of Distance Factors for Power and Test ReactoIP Site or theseelisted -hTable E-7 of ffRt Regulatoy

)

1.109,-Re1-t--Getobe, 1977, or Li Commission on Radiological Protection pubrication 30,

' Llims-for Itak_

i

- --- ----- ~_

G <<

j=

=<Insert 2

E AAIER'\\E 9-E shall ben the average (weighted in proportion olthe the time of sampling) of the sum of the average beta and Insert 3

'gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives > 1 0 minutes, making up at least 9'S% of the total non-iodine activity in the coolant.

ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from r-- -----

FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation Insert 4 TIME 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.

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)

DIABLO CANYON - UNITS I & 2 1.1-3 Unit 1 - Amendment No. 135,155,156, 1

Unit 2 - Amendment No. 135,155,156,

'l

Technical Specification Inserts Insert 1 The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from Insert 2 Supplement to Part 1, pages 192-212, Table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity," or 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."

Insert 3 DOSE EQUIVALENT XE-1 33 Insert 4 DOSE EQUIVALENT XE-1 33 shall be that concentration of Xe-1 33 (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-87, Kr-88, Xe-1 33m, Xe-1 33, Xe-1 35m, Xe-1 35, and Xe-1 38 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-1 33 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."

RCS Specific Activity 3.4.16 r ---------

3.4 REACTOR COOLANT SYSTEM (RCS) a Insert5 "

3.4.16 RCS Specific Activity LCO 3.4.16 Thehe reactor coolant shall be witn m.

APPLICABILITY:

MODE Smeand 2, (MODE 3 with RCS average temperature (Tavg) 2 5000F. )

I ACTIONS CONDITION REIQUIRED ACTION COMPLETION TIME A.

LENT 1-131

NOTE-----------------

specific activity LCO 3.0.4c is applicable.

> 1. pCi A.1 Verify DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months not within limit.

EQUIVALENT 1-1 pecific activity within the acceptable re io t

C_<60g~/m AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Inser 6

rEQUIVALENT 1-131 Iner 6specific activi to within limit.;

B. JGross specific activity of B.1 B!Ee in MODE 3 with Tavg hours the reactor coolant

500-F.

Insert7 l

47 I

I I

C. Required Action and associated Completion Time of Condition A Dot met.

or OR C.1

) Be in MODE 3 with Tav1

\\to < 5000F.

' Insert 8 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months DIABLO CANYON - UNITS 1 & 2 1

3.4-35 Unit 1 - Amendment No. 435,469, Unit 2 - Amendment No. 435,170,

RCS Specific Activity 3.4.16

,a

- Insert 9 :

I I

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 o

Verifyreatorcoolant gross specific activi 7 days SR 3.4.16.2

-NCTE----------- -----

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 14 days specific activity < 1.0 pCi/gm.

AND Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of 2 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

NCTE -

Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for 2 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine E from a sample taken in MODE 1 after a 184 days minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor uwas last subcritical for > 48hus

-I DIABLO CANYON - UNITS I & 2 2

3.4-36 Unit 1 - Amendment No. 4A5, Unit 2 - Amendment No. 435,

A 250 0

C.)

U_ 150 5

Ž00 w

E 100 (I

1 50 z

0 0

u3 0

<100

£i1Iiete Page RCS Speci Ac ty

. 6 1 L--f..

11 I/I mall oo IlrltrTTTlTlmnllY lN4lIFI 0

20 30 40 50 60 70 80 90 100 PERCENT 0 TATED THERMAL POW 3-401 Figure 3.4-1 DOSE EQUIVALENT 1-13 REACTOR COOLANT SPECIFIC ACT ITY LIMIT VERSUS PERCENT OF D THERMAL POWER WITH THE REACT COOLANT SPECIFIC A

> 1 pCI/GRAM DOSE EQUIVALENT 1-131 kBLO CANYON - UNITS 1 & 2 3.4-37 Unit 1 - Amendment No. 135 3

Unit2 -Amendment No. 135 DlS

Technical Specification Inserts Insert 5 RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

Insert 6 DOSE EQUIVALENT XE-1 33 not within limit.

Insert 7

NOTE--------------

LCO 3.0.4c is applicable.

Restore DOSE EQUIVALENT XE-133 to within limit.

Insert 8 Be in MODE 3.

AND C.2 Be in MODE 5.

Insert 9 NOTE----------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT XE-1 33 specific activity s 600.0 pCi/gm.

PG&E Letter DCL-06-008 Proposed Technical Specification Changes (retyped)

Remove Page Insert Page 1.1-3 1.1-3 1.1 -3a 3.4-35 3.4-36 3.4-37 3.4-35 3.4-36

Definitions 1.1 1.1 Definitions (continued)

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT XE-133 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes 1-131,1-132,1-133,1-134, and 1-135 actually present. The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from Table III of TID-14844, AEC, 1962, "Calculation of Distance F-actors for Power and Test Reactor Sites," or Table E-7 of Regulatory Guide 1.109, Revision 1, NRC, 1977, or International Commission on Radiological Protection (ICRP) Publication 30, 1979, Supplement to Part 1, pages '192-212, Table titled "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity," or 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."

DOSE EQUIVALENT XE-133 shall be that concentration of Xe-1 33 (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-87, Kr-88, Xe-1 33m, Xe-1 33, Xe-1 35m, Xe-1 35, and Xe-1 38 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-1 33 shall be performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."

(continued)

DIABLO CANYON - UNITS 1 & 2 3

1.1-3 Unit 1 - Amendment No. 135,155,156, Unit 2 - Amendment No. 435,1554,56,

Definitions 1.1 1.1 Definitions (continued)

ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint al: 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.

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)

DIABLO CANYON - UNITS 1 & 2 4

1. 1-3a Unit 1 - Amendment No. 435,155,156, Unit 2 - Amendment No. 135,I155,56,

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-1 33 specific activity shall be within limits.

I APPLICABILITY:

MODES 1, 2, 3, and 4.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

DOSE EQUIVALENT 1-131

NOTE---------------

not within limit.

LCO 3.0.4c is applicable.

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

< 60 pCi/gm.

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

B. DOSE EQUIVALENT B.1

NOTE------------

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months XE-133 not within limit.

L.CO 3.0.4c is applicable.

Restore DOSE EQUIVALENT XE-133 to within limit.

C. Required Action and C.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion ND Time of Condition A or B A

not met.

C.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR DOSE EQUIVALENT 1-131

> 60 pCi/gm.

I I

DIABLO CANYON - UNITS 1 & 2 35 3.4-35 Unit 1 - Amendment No. 4,69, Unit 2 - Amendment No. 435,470,

RCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANC;E FREQUENCY SR 3.4.16.1 N-TE-------

7days Only required to be performed in MODE 1.

Verify reactor coolant DC)SE EQUIVALENT XE-1 33 specific activity < 600.0 pCi/gm.

SR 3.4.16.2

NOTE------------------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 14 days specific activity < 1.0 pCi/gm.

AND Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of> 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

-I DIABLO CANYON - UNITS 1 & 2 36 3.4-36 Unit 1 - Amendment No. 45, Unit 2 - Amendment No. 435, PG&E Letter DCL-06-008 Changes to Technical Specification Bases Pages (For information only)

B 3.4 REACTOR COOLANT SYSTEM (RCS-)

B 3.4.16 RCS Specific Activity BASES

/

exclusion area Insert I

)I

~Insr BACKGROUND r.

appropriately limited The maximum d s/tole body and the thyroij that an individual at the b oundary can receive for 2 hou following duinig ccident4;specified in 10 CFR 100.11 (Ref. 1). The limits on specifi ensure that the doses are held to a fraction of the 10 CFR 100 limits during analyzed transients and accidents.

The RCS specific activity LCO limits the allowable concentration level steam line of radionuclides in the reactor coolant. The LCO limits are established break No minimize the effeitm radieactivity dose consequences in the event of (SLB) or a steam generator tube rupture (SGTR) accident.

The LCO contains specific activity limits for both DOSE EQUIVALENT 1-131 angress specif activity. The allowable levels are intended to e-at the site boundary to a fraction of the Insert 3 10 CFR 100 deose guideline limits. T lilimits in the LCO are I Insert 4 standardized, based on parametric evaluationS of effcite radioactivity dose consequences for typical site locations.

The parametric evaluatio&s showed the potential offeite dose levels for a SGTR nc.;dntore an approprate fractont ofthe 1 CFR00 deo guidel^^

line limits Erach evaluation assumes a broG-adrnge of site applcable atmospheric dispersion factors in a parametric evaluation.

APPLICABLE SAFETY ANALYSES The LCO limits on the specific activity of the reactor coolant ensures that the resulting offsIte and control room 2 houw doses at the site boundarv will not exceeRd a fraction of the 10 CFR 100 dose Qiulideline limits feydna SGTR accident. The SGTR safety analyseis (Refs. 3 I) assumes the specific activity of the reactor coolant is at or Insert 5 more conservative than the LCO limits and an existing reactor coolant steam generator (SG) tube leakage rate of [1 gpm] exists. The safety analyseis assumes the specific activity of the secondary coolant t its limit of 0.1 gCi/clm DOSE EQUIVALENT 1-131 from LCO 3.7.18,

/Secondary Specific Activity."

The analysis for the SLB and SGTR accidents establishes the acceptance limits for RCS specific activity. Reference to theise analyseis is used to assess changes to the unit that could affect RCS specific activity, as they relate to the acceptance limits.

The analyssis twvo cases of reactor coolant specific activity. One mes specific activity at 1.0 gCi/gm DOSE EQUIVALENT I consider 1-131 with a concurrent large iodine spike that increases ho 1-131 consider activity in the reactor coolant by a fartor of about SW ima (continued)

BASES APPLICABLE the accident. The second case assumes the initial reactor coolant SAFETY iodine activity at [60.0] ptCi/gm DOSE EQUIVALENT 1-131 due to a pre-ANALYSES accident iodine spike caused by an RCS transient. In both cases, the (continued) noble gpactivity in the reactor coolant assumes 1% failed fuel, which Q

0 limit ef 1IOQ/t Ci/'gm for gross specific activity.

Insert 7 The SGTR analysis also assumes a loss of offsite power at the same time as the reactor trip SGTR event. The SGTR causes a reduction in reactor coolant inventory. The reduction initiates a reactor trip from a low pressurizer pressure signal [or an RCS overtemperature AT signal.]

The reiRGideit loss of offsite power causes the steam dump valves to close to protect the condenser. The rise in pressure in the ruptured SG discharges radioactively contaminated steam to the atmosphere through the SG power operated relief valves [and the main steam safety valves]. The unaffected SGs remove core decay heat by venting steam to the atmosphere until the cooldown ends l Insert 8 The safet' analysis shows the radiological Gonsequenres of an GPR accident are within a fraction of the Reference 1 dose guideline limits.

Operation with iodine specific activity levels greater than the LCO limit is permissible, if the activity levels do not exceed the limits shown in Figure 3.4.1464 [60.01 tCi/qm DOSE EQUIVALENT 1-131, for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . TheSafet analysis has concurrent and pre accident iodine spiking lev.els up to 60.0 j.i./gm DOSE EQUIVALENT 1131.

The remainder of the above limit permissible iodine levels shown in Figure 3.4.16 1 are acceptable because of the low probability of a SGTR accident occurring during the established 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months time limit. The occurrence of an SG-PR accident at these permissible levels could incease the site boun;dary dose levels, but still be within I 0CFRI 00 dose guideline limits.

The limits on RCS specific activity are also used for establishing standardization in radiation shielding and plant personnel radiatic protection practices.

RCS specific activity satisfies Criterion 2 of 11 LCO EQUIVAMENT 1-131, and the glospecific activity in the reactor coolant is limited to the number of Ci/ngm equal to 100 divie by,~

h (lverae diintiirafticin enorov of the sum of the pvcrncip hbta Rand gamma enerfgies of the coolant nRulides). The limit on nDOSE EQUIVALENT 1 131 ensures the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid dose to an individual at the site boundary during the Design Basis Accident (DBA) will be a fraction of the allowed thyroid dose. The limit on gross specific acstivpt' (continued)

BASES LCO ensures the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months uwhole body dose to an individual at the site (continued) boundary during the DBA will be a fraction of the allowed whole body dese.

The SLB and SGTR accident analysis (Refs. 3 and 4 2) shows that the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months site boundary calculated doses levels are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of an SLB or SGTR, lead to site bundary doses that exceed the 10 CFR 100 dose guideline limits

[SRP] acceptance criteria (Ref. 2).

APPLICABILITY In MODES 1 ad 2,,ard-MODE 3, and 4 with RCS average n

1 temperature Ž 5000F'- operation within the LCO limits for Insert 11 EQUIVALENT 1-131 and DOSE EQUIVALEN 3 gross specific activity are is necessary to Gontainf I'

e potential consequences of an a SLB or SGTR to within the p---e-ite boundary dose values.

l l

A r

s v

L r

_^_

'ioronrain n

UL!

1-M Wir

_N a'eraQe TAMnemnraT4r Aum-nA r-*

_--ww----*

i I ---

in MODES 4 aRd 5, the offtite release of radioativity from the affected SG in the event of a S'GTR is unlikely sinGe the saturation pressure of Insert 12 the reactor coolant is below the lift pressure settings of the main steam safety and relief valvos-ACTIONS l Insert 13 _\\ \\

A.1 and A.2

°r_

A Note permits the use of the provisions of LCO 3.0.4,)c. This allowance permits entry into the applicable MODE(S) while relying on the ACT-IONS. This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the plant remains at. or proceeds to Dower operation.

With the DOSE EQUIVALENT 1-131 greater than the LCO limit, samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to demonstrate that the limits of Figure 3.4.1 1 arc not exceeded specific activity is S 160.01 aCi/cim. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required allowed to obtain and analyze a sample. Sampling is done to continued to provide trend.

Insert 14 The DOSE EQUIVALENT 1-131 must be restored to i limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is Vwe to pe

recovery, if the limit vYolation resulted from normal iodine spiking.

(continued)

BASES AXCTIONS B.1 (continued) 7 With the gross specific activity in excess of the allowed limit, the unit

}

must be placed in a MODE in wA.9hich the rnequirement doe not apply.

change within 6hours to MODE 3 and RCS average temperature -

/ 500F lowers the saturation pressure of the reactor coolant below the Inse1 ctpoints of the main steam safety valves and prevents venting the affected SG to the environment in an SGTR event. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 5000F from full power conditions in an orderly manner Fand without challenging plant systems.

C. 1 and C.2 If the a Required Action and the associated Completion Time of Condition A or B is not met, or if the DOSE EQUIVALENT 1-131 is a r60.01 uCi/m ain the unacceptable region of Figure 3.1.16 1, the reactor must be brought to MODE 3 with RCS average temperature - 5002F Insert hin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Inset 17ef 6 heursis are reasonable, based on operating experience, to reach MODE 3 below 500 F from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the noble as gress specific activity of the reactor coolant at least once every 7 days. While basically a quantitative measure of radionuclides with half lives longer than 10 minutes, excluding iodines, Tthis measurement is the sum of the degassed beta-gamma activitiesy and the total of all identified gaseous gamma activities in the sample within to hours after the-s-a-Pe sl taken and etrapGlated back to when the sample was taken. Determination of the contributors to the gross 6pecifiG activity shall be based upon these energy peaks identifiable with a 95 h confidence level. The latest available data may be used for pure beta -emitting radionuclides. This Surveillance provides an indication of any increase in the noble gas Is specific activity.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The Suwaillance is applicable in MODES 1 and 2, and in Insert 181 MODE 3 with Tavg at least 500°F-. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time.

(continued)

BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.16.2 1 his Surveillancc is ;odmfed Dy a Note.

n e Note moedimes the t_

_ lo _

_ at

! kit_

_ _ al z

SAv_

_AAt'I_

Al A~i'JPrfP"iincP to ilioW 4ntrv int PnO nnc~rAVAP1A n in MUm A >- W(Ii-PAn MODE 2prier to peOrfrming this Surve ilknne Requiremelnt.

This Surveillance is performed to ensure iodine specific activity remains within the L-CO limit during normal operation and following fast power changes when iodine spiking fuel failure is more apt to occur.

The 14 day Frequency is adequate to trend changes in the iodine activity level, considering noble gas gress activity is monitored every 7 days. The Frequency, between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change >

15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine

[sr19levels peak during this time following iodine spike initiation fuel Iade; samples at other times would provide less Iidisativeeults.

SR3.4 inaccurate A radGiohwmi'al analysisfor

=detormination is required every 184 days (6 months) with the plant operating in MODE 1 equilibrium (as defined in SR 3.4.16.3 NOTE) conditinrs. The determination directly relates to the LCO aRd is required to verify plant operation within the specified gross activity LCO limit. The analysis for EeF the qualitative measurement of the specific activity for each radionuclid, except for radionuclides with half-lives less than 10 minutes and all radipioldines which are identified in the reactor coolant. The specific activity for these individual radionuclides shall be used in the determination of EGTic reactor coolant sample. Determination of the contributors to tshabe based upon those energy peaks identifiable with a 95% confidence level. The Frequency of 181 days recognizes

-dees-not Ghange^ apid4-This SR has been modified by a Nato that indicates sampling for -E-determination is required to be performed within 31 days after a minimum of 2 effetive full power days and 20 days of MODE 1 operation have elapsed since the reactor was I st rubGrifiGal for at least 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . This ensures that the radioactive materials are at equilibrium so the analysis for -is epresetative and not skewed by a crud burst or other similar abnormal event.

REFERENCES

1. [10CFR100.11, 1973.]

2.

[Standard Review Plan (SRP), Section 6.4 (SLB and SGTR control room dose limits). Section 15.1.5 Appendix A (SLB offsite dose limits) and Section 15.6.3 (SGTR offsite dose limits)1

32. FSAR, Section[s 15.4.3 and 15.5.20.]

4.

FSAR Section [15.1.51

TS BASES INSERTS Insert 1.

or at the low population zone outer boundary for the radiological release duration, Insert 2.

Doses to the control room operators must be limited per GDC 19.

Insert 3.

DOSE EQUIVALENT XE-1 33.

Insert 4.

ensure that offsite and control room doses meet the appropriate acceptance criteria in the

[Standard Review Plan (Ref. 2)]

Insert 5.

meet the appropriate [SRP] acceptance criteria following a SLB or Insert 6.

the rate of release of iodine from the fuel rods containing cladding defects to the primary coolant immediately after a SLB [(by a factor of 500) or SGTR (by a factor of 500 or 335 for the SGTR analysis exclusion area boundary calculation)], respectively.

Insert 7.

specific activity is assumed to be [651] gCi/gm DOSE EQUIVALENT XE-1 33.

Insert 8.

and the RHR system is placed in service.

Insert 9.

in the reactor coolant

TS BASES INSERTS (continued)

Insert 10.

noble gas specific activity in the reactor coolant is limited to [600.0] ACi/gm DOSE EQUIVALENT XE-133, as contained in SR 3.4.16.2 and SR 3.4.16.1 respectively. The limits on specific activity ensure that offsite and control room doses will meet the appropriate [SRP]

acceptance criteria (Ref. 2).

Insert 11.

[SRP] acceptance criteria (Ref. 2).

Insert 12.

In MODES 5 and 6, the steam generators are not being used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal. Therefore, the monitoring of RC'S specific activity is not required.

Insert 13.

Required Actions A.1 and A.2 while the E)OSE EQUIVALENT 1-131 LCO limit is not met.

Insert 14.

acceptable since it is expected that, if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period.

Insert 15.

With the DOSE EQUIVALENT XE-133 in excess of the allowed limit, DOSE EQUIVALENT XE-1 33 must be restored to within limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The allowed Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period.

TS BASES INSERTS (continued)

Insert 16.

A Note permits the use of the provisions of LCO 3.0.4c. This allowance permits entry into the applicable MODE(S), relying on Required Action B.1 while the DOSE EQUIVALENT XE-1 33 LCO limit is not met. This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient-specific activity excursions while the plant remains at, or proceeds to, power operation.

Insert 17.

the required plant conditions Insert 18.

If a specific noble gas nuclide listed in the definition of DOSE EQUIVALENT XE-133 in Specification 1.1, "Definitions," is not detected, it should be assumed to be present at the minimum detectable activity.

The Note modifies this SR to allow entry into and operation in MODE 4, MODE 3, and MODE 2 prior to performing the SR. This allows the Surveillance to be performed in those MODES, prior to entering MODE 1.

Insert 19.

The Note modifies this SR to allow entry into and operation in MODE 4, MODE 3, and MODE 2 prior to performing the SR. This allows the Surveillance to be performed in those MODES, prior to entering MODE 1.

DCL-06-008, License Amendment Request 06-01 Revision to Technical Specification 1.1, Definitions, and Technical Specification 3.4.16, RCS Specific Activity

Contents

Text

Dear Commissioners and Staff:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Navigation menu

DCL-06-008, License Amendment Request 06-01 Revision to Technical Specification 1.1, Definitions, and Technical Specification 3.4.16, RCS Specific Activity

Text

Dear Commissioners and Staff:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Navigation menu

Search