ML060740537

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Issuance of Amendment Elimination of Monthly Operating Reports and Occupational Radiation Exposure Reports
ML060740537
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 04/06/2006
From: Richard Guzman
NRC/NRR/ADRO/DORL/LPLA
To: Mckinney B
Susquehanna
Guzman R, NRR/DLPM 415-1030
References
TAC MC8644, TAC MC8645
Download: ML060740537 (17)


Text

April 6, 2006 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS (TAC NOS.

MC8644 AND MC8645)

Dear Mr. McKinney:

The Commission has issued the enclosed Amendment No. 233 to Facility Operating License No. NPF-14 and Amendment No. 210 to Facility Operating License No. NPF-22 for the Susquehanna Steam Electric Station, Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 5, 2005, as supplemented by letter dated March 31, 2006.

These amendments revise TSs by eliminating the requirements to submit monthly operating reports and occupational radiation exposure reports.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice.

Sincerely,

/RA/

Richard V. Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosures:

1. Amendment No. 233 to License No. NPF-14
2. Amendment No. 210 to License No. NPF-22
3. Safety Evaluation cc w/encls: See next page

April 6, 2006 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT RE: ELIMINATION OF MONTHLY OPERATING REPORTS AND OCCUPATIONAL RADIATION EXPOSURE REPORTS (TAC NOS.

MC8644 AND MC8645)

Dear Mr. McKinney:

The Commission has issued the enclosed Amendment No. 233 to Facility Operating License No. NPF-14 and Amendment No. 210 to Facility Operating License No. NPF-22 for the Susquehanna Steam Electric Station, Units 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 5, 2005, as supplemented by letter dated March 31, 2006.

These amendments revise TSs by eliminating the requirements to submit monthly operating reports and occupational radiation exposure reports.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice.

Sincerely,

/RA/

Richard V. Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosures:

1. Amendment No. 233 to License No. NPF-14
2. Amendment No. 210 to License No. NPF-22
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC RidsNrrDorlLpla RidsNrrPmRGuzman RidsNrrLASLittle LPLI-1 RF RidsOGCMailCenter RidsAcrsAcnwMailCenter RidsRgn1MailCenter GHill(4) RidsNrrDirsItsb RidsNrrDpr ADAMS Accession Number: ML060740537 OFFICE CLIIP LPM LPLI-1/PM LPLI-1/LA LPLI-1/BC NAME WReckley RGuzman SLittle RLaufer DATE 12/21/2005 4/03/06 4/03/06 4/06/06 OFFICIAL RECORD COPY

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Robert A. Saccone Luis A. Ramos Vice President - Nuclear Operations Community Relations Manager, PPL Susquehanna, LLC Susquehanna 769 Salem Blvd., NUCSB3 PPL Susquehanna, LLC Berwick, PA 18603-0467 634 Salem Blvd., SSO Berwick, PA 18603-0467 Aloysius J. Wrape, III General Manager - Performance Bryan A. Snapp, Esq Improvement and Oversight Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation Two North Ninth Street, GENPL4 Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Allentown, PA 18101-1179 Terry L. Harpster Supervisor - Document Control Services General Manager - Plant Support PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSA4 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Rocco R. Sgarro Allegheny Electric Cooperative, Inc.

Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Walter E. Morrissey Pennsylvania Department of Supervising Engineer Environmental Protection Nuclear Regulatory Affairs Rachel Carson State Office Building PPL Susquehanna, LLC P.O. Box 8469 769 Salem Blvd., NUCSA4 Harrisburg, PA 17105-8469 Berwick, PA 18603-0467 Senior Resident Inspector Michael H. Crowthers U.S. Nuclear Regulatory Commission Supervising Engineer P.O. Box 35, NUCSA4 Nuclear Regulatory Affairs Berwick, PA 18603-0035 PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Regional Administrator, Region 1 Allentown, PA 18101-1179 U.S. Nuclear Regulatory Commission 475 Allendale Road Steven M. Cook King of Prussia, PA 19406 Manager - Quality Assurance PPL Susquehanna, LLC Board of Supervisors 769 Salem Blvd., NUCSB2 Salem Township Berwick, PA 18603-0467 P.O. Box 405 Berwick, PA 18603-0035

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803

PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-387 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 233 License No. NPF-14

1. The Nuclear Regulatory Commission (the Commission or the NRC) having found that:

A. The application for the amendment filed by PPL Susquehanna, LLC, dated October 5, 2005, as supplemented on March 31, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-14 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 233 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 6, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 233 FACILITY OPERATING LICENSE NO. NPF-14 DOCKET NO. 50-387 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT TS/TOC-4 TS/TOC-4 5.0-19 5.0-19 5.0-21 5.0-21

PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-388 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 210 License No. NPF-22

1. The Nuclear Regulatory Commission (the Commission or the NRC) having found that:

A. The application for the amendment filed by PPL Susquehanna, LLC, dated October 5, 2005, as supplemented on March 31, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-22 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 210 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 6, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 210 FACILITY OPERATING LICENSE NO. NPF-22 DOCKET NO. 50-388 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT TS/TOC-4 TS/TOC-4 5.0-19 5.0-19 5.0-21 5.0-21

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 233 TO FACILITY OPERATING LICENSE NO. NPF-14 AND AMENDMENT NO. 210 TO FACILITY OPERATING LICENSE NO. NPF-22 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 388

1.0 INTRODUCTION

By application dated October 5, 2005 (see Agencywide Document Access and Management System Accession No. ML052850299), as supplemented by letter dated March 31, 2006, PPL Susquehanna, LLC (the licensee), requested changes to the Technical Specifications (TSs) for Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2). The supplement dated March 31, 2006, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination.

The amendments will delete the TS requirements to submit monthly operating reports and annual occupational radiation exposure reports. The change is consistent with Revision 1 of Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF)

Change Traveler, TSTF-369, "Elimination of Requirements for Monthly Operating Reports and Occupational Radiation Exposure Reports." This TS improvement was published in the Federal Register (69 FR 35067) on June 23, 2004, as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 REGULATORY EVALUATION

Section 182a. of the Atomic Energy Act of 1954, as amended, (the Act) requires applicants for nuclear power plant operating licenses to state such TSs as the Commission may deem necessary. Such TSs shall be a part of the license issued. The Commission's regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) 50.36, ?Technical specifications. The regulation requires that TSs include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.

The Commission has provided guidance for the content of TSs in its "Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," (58 FR 39132, published July 22, 1993) in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a. of the Act. The Final Policy Statement identified four criteria to be used in determining whether a particular item should be addressed in the TSs as an LCO.

The criteria were subsequently incorporated into 10 CFR 50.36 (60 FR 36593, published July 19, 1995). While the criteria specifically apply to LCO, the Commission indicated that the intent of these criteria may be used to identify the optimum set of administrative controls in the TSs. Addressing administrative controls, 10 CFR Part 50.36 states that they are ?the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The specific content of the administrative controls section of the TSs is, therefore, related to those programs and reports that the Commission deems essential for the safe operation of the facility, which are not adequately covered by regulations or other regulatory requirements. Accordingly, the NRC staff may determine that specific requirements, such as those associated with this change, may be removed from the administrative controls in the TSs if they are not explicitly required by 10 CFR 50.36(c)(5) and are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.

The impetus for the monthly operating report (MOR) came from the 1973-1974 oil embargo.

Regulatory Guide 1.16, Revision 4, ?Reporting of Operating Information--Appendix A Technical Specifications, published for comment in August 1975, identifies operating statistics and shutdown experience information that was desired in the operating report at that time. In the mid-1990s, the NRC staff assessed the information that is submitted in the MOR and determined that while some of the information was no longer used by the NRC staff, the MOR was the only source of some data used in the NRC Performance Indicator (PI) Program of that time period (see NRC Generic Letter (GL) 97-02, ?Revised Contents of the Monthly Operating Report). Beginning in the late 1990s, the NRC developed and implemented a major revision to its assessment, inspection, and enforcement processes through its Reactor Oversight Process (ROP). The ROP uses both plant-level PI and inspections performed by NRC personnel. In conjunction with the development of the ROP, the NRC developed the Industry Trends Program (ITP). The ITP provides the NRC a means to assess overall industry performance using industry level indicators and to report on industry trends to various stakeholders (e.g., Congress). Information from the ITP is used to assess the NRC's performance related to its goal of having ?no statistically significant adverse industry trends in safety performance.

The ITP uses some of the same PI as the PI Program from the mid-1990s and, therefore, the NRC has a continuing use for the data provided in the MOR. The NRC also uses some data from the MOR to support the evaluation of operating experience, licensee event reports, and other assessments performed by the NRC staff and its contractors.

The reporting requirements for the MOR include challenges to the main steam safety/relief valves. The reporting of challenges to the main steam safety/relief valves was included in TSs based on the guidance in NUREG-0694, "[Three Mile Island] TMI-Related Requirements for New Operating Licensees." The industry proposed and the NRC accepted the elimination of the reporting requirements in TSs for challenges to main steam safety/relief valves in Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." The NRC staff's acceptance of TSTF-258 and subsequent approval of plant-specific adoptions of TSTF-258 is based on the fact that the information on challenges to relief and safety valves is not used in the evaluation of the MOR data, and that the information needed by the NRC is adequately addressed by the reporting requirements in 10 CFR 50.73, "Licensee event reports."

Licensees are required by TSs to submit annual occupational radiation exposure reports (ORER) to the NRC. These reports, developed in the mid-1970s, supplement the reporting requirements currently defined in 10 CFR 20.2206, ?Reports of individual monitoring, by providing a tabulation of data by work areas and job functions. The NRC included data from the ORER in its annual publication of NUREG-0713, ?Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities, through the year 1997, but no longer includes the data in that or other reports.

3.0 TECHNICAL EVALUATION

3.1 MORs As previously mentioned, the administrative requirements in the TSs are reserved for ?the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The current use of the information from the MOR is not related to reporting on or confirming the safe operation of specific nuclear power plants. Instead, the data is used by the NRC to assess and communicate with stakeholders regarding the overall performance of the nuclear industry. Data related to PI for specific plants are reported to the NRC as part of the ROP. The NRC staff has determined that the MOR do not meet the criteria defined for requirements to be included in the administrative section of TSs and the reporting requirement may, therefore, be removed.

Although the MOR does not satisfy the criteria for inclusion in TSs, the NRC staff, nevertheless, has a continuing need to receive the data in order to compile its reports on industry trends and to support other evaluations of operating experience. In addition, information such as plant capacity factors that are reported in the MOR are useful to the NRC staff and are frequently asked for by agency stakeholders.

The NRC staff interacted with licensees, industry organizations, and other stakeholders during the development of the Consolidated Data Entry (CDE) program (currently being developed and maintained by the Institute of Nuclear Power Operations), regarding the use of an industry database like CDE to provide data currently obtained from the MOR. These discussions also involved the related Revision 1 to TSTF-369, ?Elimination of Requirements for Monthly Operating Reports and Occupational Radiation Exposure Reports. As described in Section 4.0 of this safety evaluation (SE), the licensee is making a regulatory commitment to continue to provide the data identified in GL 97-02, following the removal of the TS requirement to submit MOR, and will, therefore, continue to meet the needs of the NRC staff for the ITP and other evaluations. The use of an industry database such as CDE is more efficient and cost-effective for both the NRC and licensees than would be having the NRC staff obtain the needed information from other means currently available. Should a licensee fail to satisfy the regulatory commitment to voluntarily provide the information, the NRC could obtain the information through its inspection program (similar to the process described in NRC Inspection Procedure 71150, ?Discrepant or Unreported Performance Indicator Data) with the licensee being charged for the time spent by the NRC staff.

The only significant changes resulting from the adoption of TSTF-369 are that the information will be provided quarterly instead of monthly (although the operating data will still be divided by month) and the form of the reporting will be from a consolidated database such as CDE instead of in correspondence from individual licensees. The change of reporting frequency to quarterly has some advantages for both the NRC staff and licensees, since it will coincide with the

collection and submission of the ROP PI data. In terms of the specific method used to transmit the data to the NRC, the licensee has committed (see Section 4.0 below) to provide data identified in GL 97-02 on a quarterly basis. The NRC staff believes that the most efficient process for licensees and the NRC will be for all licensees to use a system such as CDE. Such systems have advantages in terms of improved data entry, data checking, and data verification and validation. The NRC will recognize efficiency gains by having the data from all plants reported using the same computer software and format. Although the data may be transmitted to the NRC from an industry organization maintaining a database such as CDE, the licensee provides the data for the system and remains responsible for the accuracy of the data submitted to the NRC for its plant(s). The public will continue to have access to the data through official agency records accessible in ADAMS.

The content requirements for the MOR currently include information on challenges to the main steam safety/relief valves. As discussed in the previous section, the NRC staff has documented in its approval of TSTF-258 and related plant-specific amendments that the reporting of challenges to main steam safety/relief valves may be removed from TSs since the information needed by the NRC is adequately addressed by the reporting requirements in 10 CFR 50.73, ?Licensee event report. The NRC staff finds it acceptable to remove the requirement to report challenges to safety/relief valves along with the other reporting requirements associated with the MOR.

3.2 ORER The information that the NRC staff needs regarding occupational doses is provided by licensees in the reports required under 10 CFR Part 20. The data from the Part 20 reports are sufficient to support the NRC trending programs, radiation related studies, and preparation of reports such as NUREG-0713. Accordingly, the NRC's limited use of the ORER submitted pursuant to the existing TS requirements no longer warrants the regulatory burden imposed on licensees. Therefore, the NRC staff finds it acceptable that TS 5.6.1 is being deleted and the ORER will no longer be submitted by the licensee.

4.0 VERIFICATIONS AND COMMITMENTS In order to efficiently process incoming license amendment applications, the NRC staff requested each licensee requesting the changes addressed by TSTF-369 using the CLIIP to address the following plant-specific regulatory commitment.

Each licensee should make a regulatory commitment to provide to the NRC using an industry database the operating data (for each calender month) that is described in GL 97-02 ?Revised Contents of the Monthly Operating Report, by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's CDE program, currently being developed and maintained by the Institute of Nuclear Power Operations).

The licensee has made a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in GL 97-02 "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of

each calendar quarter.1 The regulatory commitment will be based on use of an industry database (e.g., the industry's CDE program, currently being developed and maintained by INPO). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (MOR and CDE)).

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment can be provided by the licensee's administrative processes, including its commitment management program. The NRC staff has agreed that Nuclear Energy Institute 99-04, Revision 0,

?Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see Regulatory Issue Summary 2000-17, ?Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000). The NRC staff notes that this amendment establishes a voluntary reporting system for the operating data that is similar to the system established for the ROP Pl Program. Should the licensee choose to incorporate a regulatory commitment into the final safety analysis report or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.

5.0 STATE CONSULTATION

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

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (71 FR 153; January 3, 2006). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 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 1

In subsequent discussions between the NRC staff and the Institute of Nuclear Power Operations, the NRC staff has agreed that the report may be provided within approximately 45 days instead of the 30 days described in the CLIIP model application. Licensees may revise their plant-specific regulatory commitments accordingly.

Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: W. Reckley Date: April 6, 2006