[Federal Register Volume 72, Number 50 (Thursday, March 15, 2007)]
[Notices]
[Pages 12217-12223]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E7-4754]


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NUCLEAR REGULATORY COMMISSION


Notice of Availability of Model Application Concerning Technical 
Specification Improvement Regarding Deletion of E Bar Definition and 
Revision to Reactor Coolant System Specific Activity Technical 
Specification Using the Consolidated Line Item Improvement Process

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of Availability.

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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 the E Bar 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 staff 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 NSHC determination to its plant.

DATES: The NRC staff issued a Federal Register Notice (71 FR 67170, 
November 20, 2006) which provided a model LAR, model SE, and model NSHC 
related to deletion of E Bar definition and revision to RCS specific 
activity technical specification; similarly the NRC staff herein 
provides a revised model LAR, a revised model SE, and a revised model 
NSHC. The NRC staff can most efficiently consider applications based 
upon the model LAR, which references the model SE, if the application 
is submitted within one year of this Federal Register Notice.

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 (CLIIP) for Adopting Standard Technical 
Specifications Changes for Power Reactors,'' was issued on March 20, 
2000. The CLIIP is intended to improve the efficiency and transparency 
of NRC licensing processes. This is accomplished by processing proposed 
changes to the Standard Technical Specifications (STS) in a manner that 
supports subsequent license amendment applications. The CLIIP 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. The CLIIP 
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 NRC staff's evaluation, 
referencing the applicable technical justifications, and providing any 
necessary plant-specific information. Each amendment application made 
in response to the notice of availability will be processed and noticed 
in accordance with applicable NRC rules and procedures.
    This notice involves replacement of the current PWR TS 3.4.16 limit 
on RCS gross specific activity with a new limit on RCS noble gas 
specific activity. The noble gas specific activity limit would be based 
on a new dose equivalent Xe-133 (DEX) definition that would replace the 
current E Bar average disintegration energy definition. In addition, 
the current dose equivalent I-131 (DEI) definition would be revised to 
allow the use of additional thyroid dose conversion factors (DCFs). By 
letter dated September 13, 2005, the Technical Specification Task Force 
(TSTF) proposed these changes for incorporation into the STS as TSTF-
490, Revision 0, which was referenced in the Federal Register Notice 
(FRN) 71 FR 67170, of November 20, 2006, and can be viewed on the NRC's 
Web page at http://www.nrc.gov/reactors/operating/licensing/techspecs.html.

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.
    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 CLIIP submit an LAR that 
adheres to the following model. Any variations from the model LAR 
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 changes to the license, will result in staff rejection of 
the submittal. Instead, licensees desiring significant variations and/
or additional changes should submit a LAR that does not claim to adopt 
TSTF-490.

Public Notices

    The staff issued a Federal Register Notice (71 FR 67170, November 
20, 2006) that requested public comment on the NRC's pending action to 
delete the E Bar definition and revise the RCS specific activity 
technical specification. In particular, following an assessment and 
draft safety evaluation by the NRC staff, the staff sought public 
comment on proposed changes to the STS, designated TSTF-490 Revision 0. 
The TSTF-490 Revision 0 can be viewed on the NRC's Web page at http://www.nrc.gov/reactors/operating/licensing/techspecs.html. TSTF-490 
Revision 0 may be examined, and/or copied for a fee, at the NRC Public 
Document Room, located at One White Flint North, 11555 Rockville Pike 
(first floor), Rockville, Maryland. Publicly available records are 
accessible electronically from the ADAMS Public Library component on 
the NRC Web site, (the Electronic Reading Room) at

[[Page 12218]]

http://www.nrc.gov/reading-rm/adams.html.
    In response to the notice soliciting comments from the interested 
members of the public about NRC's pending action to delete the E Bar 
definition and revise the RCS specific activity technical 
specification, the staff received four sets of comments (from licensees 
and the TSTF Owners Groups, representing the licensees). Specific 
comments on the model SE, model LAR, and the model NSHC were offered, 
and are summarized and discussed below:
    1. Comment: In Sections 3.1.4 and 3.1.7 the model safety evaluation 
states: ``In MODES 5 and 6, the steam generators are not used for decay 
heat removal, the RCS and steam generators are depressurized, and 
primary to secondary leakage is minimal.'' However, using the 
Westinghouse Standard Technical Specifications as an example, NUREG-
1431, Vol. 2, Rev. 3.0, Bases 3.4.7 (RCS Loops-Mode 5, Loops Filled) 
states ``In MODE 5 with the RCS loops filled, the primary function of 
the reactor coolant is the removal of decay heat and transfer this heat 
either to the steam generator(SG) secondary side coolant via natural 
circulation (Ref. 1) or the component cooling water via the residual 
heat removal (RHR) heat exchangers.'' Therefore, the steam generators 
are taken credit for as a means of removing decay heat during MODE 5. 
Additionally, the RCS may be pressurized during MODE 5. The statement 
as written in the model safety evaluation may prevent licensees from 
stating that their application is consistent with the model technical 
evaluation.
    Response: The comment addresses the MODES for which the LCO would 
be applicable. The NRC staff agrees that the statement in sections 
3.1.4 and 3.1.7 does not acknowledge the condition of MODE 5 with the 
RCS loops filled. The Model SE will be modified to account for this 
condition.
    2. Comment: There is currently one Technical Specification (TS) 
3.4.16 limit on RCS gross specific activity, not ``limits''. The single 
limit is 100/E Bar in all 3 affected STS NUREGs. There are two places 
that refer to limits (plural).
    Response: This editorial comment is correct, and the Supplemental 
Information section and the Model LAR will be revised accordingly.
    3. Comment: In the Model SE, Section 2.0: Correct the title of TID 
14844. ``Reactor'' is singular in the title.
    Response: This editorial comment is correct, and the Model SE will 
be revised accordingly.
    4. Comment: In the 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.]''

    Response: The Model SE endorsed the use of DCFs from Table 2.1 of 
FGR-11, 1988, ``Limiting Values of Radionuclide Intake and Air 
Concentration and Dose Conversion Factors for Inhalation, Submersion, 
and Ingestion.'' As stated in the model SE, it is incumbent on the 
licensee to ensure that the DCFs used in the determination of DEI are 
consistent with the DCFs used in the applicable dose consequence 
analyses. As such, the references for the applicable DCFs would indeed 
be plant specific and the model SE has been changed accordingly.
    5. Comment: In the 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 activation products * * *''.
    Response: This editorial comment is correct, and the Model SE will 
be corrected.
    6. Comment: In the Model SE, Section 3.1.3: The discussion on 
revised Required Action A.1 should be relocated to Model SE Section 
3.1.5 that discusses the changes to TS 3.4.16 condition A.
    Response: The NRC staff agrees that the discussion on revised 
Required Action A.1 should be relocated. The Model SE will be updated 
to reflect the change.
    7. Comment: In the 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-1431, and it should also 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 NUREG-1431; 
C in NUREG-1430 and NUREG-1432] is replaced with a new Condition B for 
DEX not within limits.''
    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. Suggested wording that 
could be used for this purpose is:

    ``A Note is also added to the revised Required Action B.1 that 
states LCO 3.0.4.c is applicable. This Note would allow entry into a 
Mode or other specified condition in the LCO Applicability when LCO 
3.4.16 is not being met and is the same Note that is currently 
stated for Required Actions A.1 and A.2. The proposed Note would 
allow entry into the applicable Modes 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, and the ability 
to restore transient specific activity excursions while the plant 
remains at, or proceeds to, power operation.''

    Response: The NRC staff agrees with the wording with this editorial 
comment and the Model SE will be updated to reflect the differences in 
the NUREGs. Also, a discussion concerning the LCO 3.0.4.c note to 
required Action B.1 will be added to the Model SE Section 3.1.6.
    8. Comment: In the 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 1.'' The 
application of this style of Note is discussed in Example 1.4-5 in the 
latest revision of the STS NUREGs. The LCO 3.0.4.c Note addition 
applies only to revised Required Action B.1
    Response: The NRC staff believes that the new Note for SR 3.4.16.1 
is consistent with Example 1.4-5 and the Note in SR 3.4.16.2 and 
therefore does not need to be changed.
    9. Comment: In the Model SE, Section 3.1.2 states ``The 
determination of DOSE EQUIVALENT XE-133 shall be performed using 
effective dose conversion factors for air submersion listed in Table 
III.1 of EPA Federal Guidance Report No. 12 or the average gamma 
disintegration energies as provided in ICRP Publication 38, 
``Radionuclide Transformations'' or similar source.'' What exactly is 
``similar source''? Does ``similar source'' apply to average gamma 
energies or to the DCFs such as published in Reg. Guide 1.109?
    Response: The selection of the dose conversion factors used in the 
definition of DEX should be consistent with the dose conversion factors 
currently employed in the licensee's dose consequence analyses and as 
such the

[[Page 12219]]

reference for the dose conversion factors or the source of the gamma 
energies used in the definition will be site specific. Brackets will be 
placed around the references to indicate where site specific 
information should be included.
    10. Comment: In the Model SE, Section 3.1.2 states ``* * * 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-133M, XE-133, XE-
135M, XE-135 and XE-133 * * *''. Under the same Section two additional 
nuclides are added to the new definition for E-AVERAGE DISINTEGRATION 
ENERGY; Kr-85 and XE-131M. The addition of the additional nuclides 
appears to conflict with the preceding technical Evaluation. Is it the 
expectation that these two nuclides be added to the DEX calculation in 
addition to those listed in the preceding section?
    Response: The selection of the isotopes used in the definition of 
DEX will be site specific and based on the dose significant noble gas 
isotopes identified in the appropriate DBA dose consequence analyses. 
The list of noble gas isotopes will be placed in brackets to indicate 
that the actual list will be site specific.
    11. Comment: The title of TSTF-490 is not capitalized consistently 
and is not consistent with the submitted Traveler. The title of TSTF-
490 is ``Deletion of E Bar Definition and Revision to RCS Specific 
Activity Tech Spec.'' Note that there is no hyphen used in the term ``E 
Bar.''
    Response: This editorial comment is correct, and the Model SE will 
be corrected.
    12. Comment: In the proposed NSHC, to be consistent with 10 CFR 
50.92(c)(2), the title of Criterion 2 should be revised to add the word 
``Accident'' before ``Previously Evaluated.'' Specifically, it should 
state, ``The Proposed Change Does Not Create the Possibility of a New 
or Different Kind of Accident from any Accident Previously Evaluated.''
    Response: This editorial comment is correct, and the proposed NSHC 
will be corrected.
    13. Comment: In the Model LAR it states, ``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.'' This statement is not consistent with the 
recommended statement given in RIS 2001-18, ``Requirements for Oath and 
Affirmation.'' RIS 2001-18 recommends the statement, ``I declare [or 
certify, verify, state] under penalty of perjury that the foregoing is 
true and correct.'' Note that RIS 2001-18 states that this statement 
must be used verbatim. We recommend that the Model Application be 
revised to be consistent with RIS 2001-18.
    Response: The statement in the Model LAR is consistent with RIS 
2001-18. The purpose of RIS 2001-18 was to inform licensees that there 
is an alternative to the oath or affirmation statement contained in 28 
U.S.C. 1746. Both are considered acceptable. The NRC staff includes 
only the first option listed in 28 U.S.C. 1746 for brevity.
    14. Comment: In the Model LAR , Section 8.0 the second reference 
should be numbered. Note that Section 4.0 refers to References 1 and 2.
    Response: The references in Section 8.0 are numbered, however, for 
clarification, the Notice for Comment and the Notice for Availability 
will be listed as separate references.

    Dated at Rockville, Maryland this 8th day of March, 2007.

    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 SPECIFICATION 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 N. 50-[xxx,] 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), [LICENSEE] is 
submitting a request for an amendment to the technical 
specifications (TS) for [PLANT NAME, UNIT NOS.]. The proposed 
changes would replace the current pressurized water reactor (PWR) 
Technical Specification (TS) 3.4.16 limit on reactor coolant system 
(RCS) gross specific activity with a new limit on RCS noble gas 
specific activity. The noble gas specific activity limit would be 
based on a new dose equivalent Xe-133 (DEX) definition that would 
replace the current E Bar average disintegration energy definition. 
In addition, the current dose equivalent I-131 (DEI) 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 Bar 
Definition and Revision to RCS Specific Activity Tech Spec.'' The 
availability of this TS improvement was announced in the Federal 
Register on [DATE] ([ ]FR[ ]) as part of the consolidated line item 
improvement process (CLIIP).
    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 [DATE], 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 [ ].

 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
cc: NRR Project Manager
    Regional Office
    Resident Inspector
    State Contact
    ITSB Branch Chief

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. The changes were approved by the 
NRC staff Safety Evaluation (SE) dated September 27, 2006 (ADAMS 
ML062700612) (Reference 1). 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

[[Page 12220]]

consolidated line item improvement process (CLIIP).

2.0 Proposed Changes

    Consistent with NRC-approved TSTF-490, Revision 0, the proposed 
TS changes:
    <bullet> Revise the definition of DOSE EQUIVALENT I-131.
    <bullet> Delete the definition of ``E Bar, AVERAGE 
DISINTEGRATION ENERGY.''
    <bullet> Add a new TS definition for DOSE EQUIVALENT XE-133.
    <bullet> Revise LCO 3.4.16, ``RCS Specific Activity'' to delete 
references to gross specific activity; add limits for DOSE 
EQUIVALENT I-131 and DOSE EQUIVALENT XE-133; and delete Figure 
3.4.16-1, ``Reactor Coolant DOSE EQUIVALENT I-131 Specific Activity 
Limit versus Percent of RATED THERMAL POWER.''
    <bullet> Revise LCO 3.4.16 ``Applicability'' to specify the LCO 
is applicable in MODES 1, 2, 3, and 4.
    <bullet> Modify 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 NUREG-1432 ACTIONS are reordered, moving 
Condition C to Condition B to be consistent with the Writer's Guide.
    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-133 instead of gross specific activity. The Completion 
Time is changed from 6 hours to 48 hours. A Note allowing the 
applicability of LCO 3.0.4.c is added, consistent with the Note to 
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.
    Revise SR 3.4.16.1 to verify the limit for DOSE EQUIVALENT XE-
133. A Note is added, consistent with SR 3.4.16.2 to allow entry 
into MODES 2, 3, and 4 prior to performance of the SR.
    Delete SR 3.4.16.3.

3.0 Background

    The background for this application is as stated in the model SE 
in NRC's Notice of Availability published on [DATE ]([ ] FR [ ]), 
the NRC Notice for Comment published on [DATE] ([ ] FR [ ]), and 
TSTF-490, Revision 0.

4.0 Technical Analysis

    [LICENSEE] has reviewed References 1, 2 and 3, and the model SE 
published on [DATE] ([ ]FR [ ]) as part of the CLIIP Notice for 
Comment. [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 prepared by the NRC staff are applicable to [PLANT, UNIT NOS.], 
and justify this amendment for the incorporation of the changes to 
the [PLANT] TS.

5.0 Regulatory Analysis

    A description of this proposed change and its relationship to 
applicable regulatory requirements and guidance was provided in the 
NRC Notice of Availability published on [DATE] ([ ] FR [ ]), the NRC 
Notice for Comment published on [DATE] ([ ] FR [ ]), and TSTF-490, 
Revision 0.

6.0 No Significant Hazards Consideration

    [LICENSEE] has reviewed the proposed no significant hazards 
consideration determination published in the Federal Register on 
[DATE] ([ ] FR [ ]) as part of the CLIIP. [LICENSEE] has concluded 
that the proposed determination presented in the notice is 
applicable to [PLANT] and the determination is hereby incorporated 
by reference to satisfy the requirements of 10 CFR 50.91(a).

7.0 Environmental Evaluation

    [LICENSEE] has reviewed the environmental consideration included 
in the model SE published in the Federal Register on [DATE] ([ ] FR 
[ ]) as part of the CLIIP. [LICENSEE] has concluded that the staff's 
findings presented therein are applicable to [PLANT] and the 
determination is hereby incorporated by reference for this 
application.

8.0 References

    1. NRC Safety Evaluation (SE) approving TSTF-490, Revision 0 
dated September 27, 2006
    2. Federal Notice for Comment published on [DATE] ([ ] FR [ ])
    3. Federal Notice of Availability published on [DATE ] ([ ] FR [ 
])
    Model Safety Evaluation, U.S. Nuclear Regulatory Commission, 
Office of Nuclear Reactor Regulation, Technical Specification Task 
Force TSTF-490, Revision 0, ``Deletion of E Bar Definition and 
Revision to RCS Specific Activity Tech Spec''.

1.0 Introduction

    By letter dated [------, 20--], [LICENSEE] (the licensee) 
proposed changes to the technical specifications (TS) for [PLANT 
NAME]. The requested changes are the adoption of TSTF-490, Revision 
0, ``Deletion of E Bar Definition and Revision to RCS Specific 
Activity Tech Spec'' for pressurized water reactor (PWR) Standard 
Technical Specifications (STS). By letter dated September 13, 2005, 
the Technical Specification Task Force (TSTF) submitted TSTF-490 for 
Nuclear Regulatory Commission (NRC) staff review. This TSTF involves 
changes to NUREG-1430, NUREG-1431, and NUREG-1432 STS Section 3.4.16 
reactor coolant system (RCS) gross specific activity limits with the 
addition of a new limit for noble gas specific activity. The noble 
gas specific activity limit would be based on a new dose equivalent 
Xe-133 (DEX) definition that replaces the current E Bar average 
disintegration energy definition. In addition, the current dose 
equivalent I-131 (DEI) definition would be revised to allow the use 
of additional thyroid dose conversion factors (DCFs).

2.0 Regulatory Evaluation

    The NRC staff evaluated the impact of the proposed changes as 
they relate to the radiological consequences of affected design 
basis accidents (DBAs) that use the RCS inventory as the source 
term. The source term assumed in radiological analyses should be 
based on the activity associated with the projected fuel damage or 
the maximum RCS technical specifications (TS) values, whichever 
maximizes the radiological consequences. The limits on RCS specific 
activity ensure that the offsite doses are appropriately limited for 
accidents that are based on releases from the RCS with no 
significant amount of fuel damage.
    The Steam Generator Tube Rupture (SGTR) accident and the Main 
Steam Line Break (MSLB) accident typically do not result in fuel 
damage and therefore the radiological consequence analyses are based 
on the release of primary coolant activity at maximum TS limits. For 
accidents that result in fuel damage, the additional dose 
contribution from the initial activity in the RCS is not normally 
evaluated and is considered to be insignificant in relation to the 
dose resulting from the release of fission products from the damaged 
fuel.
    For licensees that incorporate the source term as defined in 
Technical Information Document (TID) 14844, AEC, 1962, ``Calculation 
of Distance Factors for Power and Test Reactors Sites,'' in their 
dose consequence analyses, the NRC staff uses the regulatory 
guidance provided in NUREG-0800, ``Standard Review Plan (SRP) for 
the Review of Safety Analysis Reports for Nuclear Power Plants,'' 
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 the 
evaluation of MSLB accident analyses and NUREG-0800, SRP Section 
15.6.3, ``Radiological Consequences of Steam Generator Tube Failure 
(PWR),'' Revision 2, for evaluating SGTR accidents analyses. In 
addition, the NRC staff uses the guidance from RG 1.195, ``Methods 
and Assumptions for Evaluating Radiological Consequences of Design 
Basis Accidents at Light Water Nuclear Power Reactors,'' May 2003, 
for those licensees that chose to use its 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 NRC staff uses the regulatory 
guidance provided in NUREG-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 
2000.
    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

[[Page 12221]]

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.
    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. NUREG-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-0800, the 10 CFR 20.1201 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(b)(2). 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(b)(2)(iii) 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 TEDE for the duration of the accident.

3.0 Technical Evaluation

3.1 Technical Evaluation of TSTF-490 TS Changes

3.1.1 Revision to the Definition of DEI

    The list of acceptable DCFs for use in the determination of DEI 
include the following:
    <bullet> [Table III of TID-14844, AEC, 1962, ``Calculation of 
Distance Factors for Power and Test Reactor Sites.'']
    <bullet> [Table E-7 of Regulatory Guide 1.109, Revision 1, NRC, 
1977.]
    <bullet> [ICRP 30, 1979, page 192-212, Table titled ``Committed 
Dose Equivalent in Target Organs or Tissues per Intake of Unit 
Activity.'']
    <bullet> [Committed Dose Equivalent (CDE) or Committed Effective 
Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA 
Federal Guidance Report No. 11.'']
    <bullet> [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.'']

    Note: It is incumbent on the licensee to ensure that the DCFs 
used in the determination of DEI are consistent with the applicable 
dose consequence analyses.

3.1.2 Deletion of the Definition of E Bar and the Addition of a New 
Definition for DE Xe-133

    The new definition for DEX is similar to the definition for DEI. 
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-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-
133, Xe-135m, Xe-135, and Xe-138] which are significant in terms of 
contribution to whole body dose. Some noble gas isotopes are not 
included due to low concentration, short half life, or small dose 
conversion factor. The calculation of DEX would use either the 
average gamma disintegration energies for the nuclides or the 
effective dose conversion factors from Table III.1 of EPA FGR No. 
12. Using this approach, the limit on the amount of noble gas 
activity in the primary coolant would not fluctuate with variations 
in the calculated values of E Bar. If a specified noble gas nuclide 
is not detected, the new definition states that it should be assumed 
the nuclide is present at the minimum detectable activity. This will 
result in a conservative calculation of DEX.
    When E Bar is determined using a design basis approach in which 
it is assumed that 1.0% of the power is being generated by fuel rods 
having cladding defects and it is also assumed that there is no 
removal of fission gases from the letdown flow, the value of E Bar 
is dominated by Xe-133. The other nuclides have relatively small 
contributions. However, during normal plant operation there are 
typically only a small amount of fuel clad defects and the 
radioactive nuclide inventory can become dominated by tritium and 
corrosion and/or activation products, resulting in the determination 
of a value of E Bar that is very different than would be calculated 
using the design basis approach. Because of this difference, the 
accident dose analyses become disconnected from plant operation and 
the limiting condition for operation (LCO) becomes essentially 
meaningless. It also results in a TS limit that can vary during 
operation as different values for E Bar are determined.
    This change will implement a LCO that is consistent with the 
whole body radiological consequence analyses which are sensitive to 
the noble gas activity in the primary coolant but not to other non-
gaseous activity currently captured in the E Bar definition. LCO 
3.4.16 specifies the limit for primary coolant gross specific 
activity as 100/E Bar --Ci/gm. The current E Bar definition includes 
radioisotopes that decay by the emission of both gamma and beta 
radiation. The current Condition B of LCO 3.4.16 would rarely, if 
ever, be entered for exceeding 100/E Bar since the calculated value 
is very high (the denominator is very low) if beta emitters such as 
tritium (H-3) are included in the determination, as required by the 
E Bar definition.
    TS Section 1.1 definition for E--AVERAGE DISINTEGRATION ENERGY 
(E Bar) is deleted and replaced with a new definition for DEX which 
states:

``DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 
(microcuries per gram) that alone would produce the same acute dose 
to the whole body as the combined activities of noble gas nuclides 
[Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-
135, and Xe-138] actually present. If a specific noble gas nuclide 
is not detected, it should be assumed to be present at the minimum 
detectable activity. The determination of DOSE EQUIVALENT XE-133 
shall be performed using [effective dose conversion factors for air 
submersion listed in Table III.1 of EPA Federal Guidance Report No. 
12, 1993, ``External Exposure to Radionuclides in Air, Water, and 
Soil'' or the average gamma disintegration energies as provided in 
ICRP Publication 38, ``Radionuclide Transformations'' or similar 
source.]''

    The change incorporating the newly defined quantity DEX is 
acceptable from a radiological dose perspective since it will result 
in an LCO that more closely relates the non-iodine RCS activity 
limits to the dose consequence analyses which form their bases.

    Note: It is incumbent on the licensee to ensure that the DCFs 
used in the determination of DEI and the newly defined DEX are 
consistent with the DCFs used in the applicable dose consequence 
analysis.

3.1.3 LCO 3.4.16, ``RCS Specific Activity''

    LCO 3.4.16 is modified to specify that iodine specific activity 
in terms of DEI and noble gas specific activity in terms of DEX 
shall be within limits. Currently the limiting indicators are not 
explicitly identified in the LCO, but are instead defined in current 
Condition C and Surveillance Requirement (SR) 3.4.16.1 for gross 
non-iodine specific activity and in current Condition A and SR 
3.4.16.2 for iodine specific activity.
    The change states ``RCS DOSE EQUIVALENT 1-131 and DOSE 
EQUIVALENT XE-133 specific activity shall be within limits.'' NOTE: 
IT IS INCUMBENT ON THE LICENSEE TO ENSURE THAT THE SITE SPECIFIC 
LIMITS FOR BOTH DEI AND DEX ARE CONSISTENT WITH THE CURRENT SGTR AND 
MSLB RADIOLOGICAL CONSEQUENCE ANALYSES.

3.1.4 TS3.4.16 Applicability

    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 MODES 1 through 
4 to limit the potential radiological consequences of an SGTR or 
MSLB that may occur during these MODES. In MODE 5 with the RCS loops 
filled, the steam generators are specified as a backup means of 
decay heat removal via natural circulation. In this mode, however, 
due to the

[[Page 12222]]

reduced temperature of the RCS, the probability of a DBA involving 
the release of significant quantities of RCS inventory is greatly 
reduced. Therefore, monitoring of RCS specific activity is not 
required. In MODE 5 with the RCS loops not filled and in MODE 6 the 
steam generators are not used for decay heat removal, the RCS and 
steam generators are depressurized and primary to secondary leakage 
is minimal. Therefore, the monitoring of RCS specific activity is 
not required. The change to modify the TS 3.4.16 Applicability to 
include all of MODE 3 and MODE 4 is necessary to limit the potential 
radiological consequences of an SGTR or MSLB that may occur during 
these MODES and is therefore acceptable from a radiological dose 
perspective.

3.1.5 TS3.4.16 Condition A

    TS 3.4.16 Condition A is revised by replacing the DEI site 
specific limit ``> [1.0] --Ci/gm'' with the words ``not within 
limit'' to be consistent with the revised TS 3.4.16 LCO format. The 
site specific DEI limit of <= [1.0] --Ci/gm is contained in SR 
3.4.16.2. This proposed format change will not alter current STS 
requirements and is acceptable from a radiological dose perspective.
    TS 3.4.16 Required Action A.1 is revised to remove the reference 
to Figure 3.4.16-1 ``Reactor Coolant DOSE EQUIVALENT I-131 Specific 
Activity Limit versus Percent of RATED THERMAL POWER'' and insert a 
limit of less than or equal to the site specific DEI spiking limit. 
The curve contained in Figure 3.4.16-1 was provided by the AEC in a 
June 12, 1974 letter from the AEC on the subject, ``Proposed 
Standard Technical Specifications for Primary Coolant Activity.'' 
Radiological dose consequence analyses for SGTR and MSLB accidents 
that take into account the pre-accident iodine spike do not consider 
the elevated RCS iodine specific activities permitted by Figure 
3.4.16-1 for operation at power levels below 80% RTP. Instead, the 
pre-accident iodine spike analyses assume a DEI concentration [60] 
times higher than the corresponding long term equilibrium value, 
which corresponds to the specific activity limit associated with 
100% RTP operation. It is acceptable that TS 3.4.16 Required Action 
A.1 should be based on the short term site specific DEI spiking 
limit to be consistent with the assumptions contained in the 
radiological consequence analyses.

3.1.6 TS3.4.16 Condition B Revision To Include Action for DEX Limit

    TS 3.4.16 Condition C is replaced with a new Condition B [in 
NUREG-1431; C in NUREG-1430 and NUREG-1432] 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 in Section 3.1.3. The DEX limit is site 
specific and the numerical value in units of --Ci/gm is contained in 
revised SR 3.4.16.1. The site specific limit of DEX in --Ci/gm is 
established based on the maximum accident analysis RCS activity 
corresponding to 1% fuel clad defects with sufficient margin to 
accommodate 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 
and its associated Conditions is to support the dose analyses for 
DBAs. The whole body dose is primarily dependent on the noble gas 
activity, not the non-gaseous activity currently captured in the E 
Bar definition.
    The Completion Time for revised TS 3.4.16 Required Action B.1 
will require restoration of DEX to within limit in 48 hours. This is 
consistent with the Completion Time for current Required Action A.2 
for DEI. The radiological consequences for the SGTR and the MSLB 
accidents demonstrate that the calculated thyroid doses are 
generally a greater percentage of the applicable acceptance criteria 
than the calculated whole body doses. It then follows that the 
Completion Time for noble gas activity being out of specification in 
the 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. Therefore the 
Completion Time of 48 hours for revised Required Action B.1 is 
acceptable from a radiological dose perspective. A Note is also 
added to the revised Required Action B.1 that states LCO 3.0.4.c is 
applicable. This Note would allow entry into a Mode or other 
specified condition in the LCO Applicability when LCO 3.4.16 is not 
being met and is the same Note that is currently stated for Required 
Actions A.1 and A.2. The proposed Note would allow entry into the 
applicable Modes from MODE 4 to MODE 1 (power operation) while the 
DEX limit is exceeded and the DEX is being restored to within its 
limit. This Mode change is acceptable due to the significant 
conservatism incorporated into the DEX specific activity limit, the 
low probability of an event occurring which is limiting due to 
exceeding the DEX specific activity limit, and the ability to 
restore transient specific excursions while the plant remains at, or 
proceeds to power operation.

3.1.7 TS 3.4.16 Condition C

    TS 3.4.16 Condition C is revised to include Condition B (DEX not 
within limit) 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 now provide the same completion time for both 
components of RCS specific activity as discussed in the revision to 
Condition B. The revision to Condition C also replaces the limit on 
DEI from the deleted Figure 3.4.16-1, with a site specific value of 
> [60] --Ci/gm. This change makes Condition C consistent with the 
changes made to TS 3.4.16 Required Action A.1.
    The change to TS 3.4.16 Required Action C.1 requires the plant 
to be in MODE 3 within 6 hours and adds a new Required Action C.2, 
which requires the plant to be in MODE 5 within 36 hours. 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. In MODE 5 with the 
RCS loops filled, the steam generators are specified as a backup 
means of decay heat removal via natural circulation. In this mode, 
however, due to the reduced temperature of the RCS, the probability 
of a DBA involving the release of significant quantities of RCS 
inventory is greatly reduced. Therefore, monitoring of RCS specific 
activity is not required. In MODE 5 with the RCS loops not filled 
and MODE 6, the steam generators are not used for decay heat 
removal, the RCS and steam generators are depressurized, and primary 
to secondary leakage is minimal. Therefore, the monitoring of RCS 
specific activity is not required.
    A new TS 3.4.16 Required Action C.2 Completion Time of 36 hours 
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 and the value of 36 hours is consistent with other TS which 
have a Completion Time to reach MODE 5.

3.1.8 SR3.4.16.1 DEX Surveillance

    The change replaces the current SR 3.4.16.1 surveillance for RCS 
gross specific activity with a surveillance to verify that the site 
specific reactor coolant DEX specific activity is <= [X] --Ci/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 reactor coolant at least once every 7 days, 
which is the same frequency required under the current SR 3.4.16.1 
surveillance for RCS gross non-iodine specific activity. 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 LCO limit 
under normal operating conditions.
    SR 3.4.16.1 is modified by inclusion of a NOTE which 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 ACTIONS. 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. This allows entry 
into MODE 4, MODE 3, and MODE 2 prior to performing the 
surveillance. This allows the surveillance to be performed in any of 
those MODES, prior to entering MODE 1, similar to the current 
surveillance SR 3.4.16.2 for DEI.

3.1.9 SR3.4.16.3 Deletion

    The current SR 3.4.16.3, which required the determination of E 
Bar, is deleted. TS 3.4.16 LCO on RCS specific activity supports the 
dose analyses for DBAs, in which the whole body dose is primarily 
dependent on the noble gas concentration, not the non-gaseous 
activity currently captured in the E Bar definition. With the 
elimination of the limit for RCS gross specific activity and the 
addition of the new LCO limit for noble gas specific activity, this 
SR to determine E Bar is no longer required.

3.2 Precedent

    The technical specifications developed for the Westinghouse 
AP600 and AP1000

[[Page 12223]]

advanced reactor designs incorporate an LCO for RCS DEX activity in 
place of the LCO on non-iodine gross specific activity based on E 
Bar. This approach was approved by the NRC staff for the AP600 in 
NUREG-1512, ``Final Safety Evaluation Report Related to the 
Certification of the AP600 Standard Design, Docket No. 52-003,'' 
dated August 1998 and for the AP1000 in the NRC letter to 
Westinghouse Electric Company dated September 13, 2004. In addition, 
the curve describing the maximum allowable iodine concentration 
during the 48-hour period of elevated activity as a function of 
power level, was not included in the TS approved for the AP600 and 
API000 advanced reactor designs.

4.0 State Consultation

    In accordance with the Commission's regulations, the [------] 
State official was notified of the proposed issuance of the 
amendment. The State official had [(1) no comments or (2) the 
following comments--with subsequent disposition by the staff].

5.0 Environmental Consideration

    The amendment[s] change[s] a requirement with respect to the 
installation or use of a facility component located within the 
restricted area as defined 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 
significant hazards consideration and there has been no public 
comment on such finding published [DATE] ([ ] FR [ ]). 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 has concluded, based on the considerations 
discussed above, that (1) There is reasonable assurance that the 
health and safety of the public will not be endangered by operation 
in the proposed manner, (2) 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 Determination

    Description of Amendment Request: [LICENSEE] requests adoption 
of an approved change to the Standard Technical Specifications (STS) 
for pressurized water reactor (PWR) plants (NUREG-1430, NUREG-1431, 
& NUREG-1432) and plant specific 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-133 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, Revision 0.
    Basis for proposed no-significant-hazards-consideration 
determination: As required by 10 CFR 50.91(a), an analysis of the 
issue of no-significant-hazards-consideration is presented below:

Criterion 1-The Proposed Change Does Not Involve a Significant Increase 
in the Probability or Consequences of an 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 during 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 From any Accident 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 [ ],
Division of Operating Reactor Licensing,
Office of Nuclear Reactor Regulation.
[FR Doc. E7-4754 Filed 3-14-07; 8:45 am]
BILLING CODE 7590-01-P