ML092640247

Issuance of Amendment Regarding Lowering the Minimum Allowed Level of the Ultimate Heat Sink Main Reservoir

ML092640247
Person / Time
Site:	Harris
Issue date:	10/14/2009
From:	Vaaler M Plant Licensing Branch II
To:	Burton C Carolina Power & Light Co
Vaaler, Marlayna, NRR/DORL 415-3178
References
TAC MD8676
Download: ML092640247 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 14, 2009 Chris L. Burton, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT REGARDING LOWERING THE MINIMUM ALLOWED LEVEL OF THE ULTIMATE HEAT SINK MAIN RESERVOIR (TAC NO. MD8676)

Dear Mr. Burton:

The Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 132 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), in response to your application dated April 30, 2008, as supplemented by letters dated December 3,2008, and June 30, 2009, to modify Technical Specification 3.7.5a to restore the ultimate heat sink main reservoir minimum level to the value allowed by the initial operating license as a result of improvements made to the emergency service water system.

The supplement dated June 30, 2009, provided a new evaluation of the proposed change and replaced the information previously submitted. As such, Enclosure 1 of the April 30, 2008, submittal is replaced in its entirety by Enclosure 1, "HNP Evaluation of the Proposed Change,"

of the submittal dated June 30, 2009. The supplements dated December 3,2008, and June 30, 2009, also provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 12, 2008 (73 FR 46929).

A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's regular biweekly Federal Register notice.

?/'~

Marlayna Vaaler, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Rector Regulation Docket No. 50-400

Enclosures:

1. Amendment No. 132 to NPF-63

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CAROLINA POWER & LIGHT COMPANY, et al.

DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 132 Renewed License No. NPF-63

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

A. The application for amendment by Carolina Power & Light Company (the licensee), dated April 30, 2008, as supplemented by letters dated December 3, 2008, and June 30, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 Code of Federal Regulations (10 CFR), Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

-2

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-63 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 132

• are hereby incorporated into this license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

~~ ~I ~ -fisv Thomas H. Boyce, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-63 and the Technical Specifications Date of Issuance: October 14, 2009

ATIACHMENT TO LICENSE AMENDMENT NO. 132 RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 Replace page 4 of Renewed Operating License No. NPF-63 with the attached page 4.

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 area of change.

Remove Page Insert Page 3/47-13 3/47-13

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

(1) Maximum Power Level Carolina Power & Light Company is authorized to operate the facility at reactor core power levels not in excess of 2900 megawatts thermal (100 percent rated core power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 132, are hereby incorporated into this license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Antitrust Conditions Carolina Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.

(4) Initial Startup Test Program (Section 14)1 Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) Steam Generator Tube Rupture (Section 15.6.3)

Prior to startup following the first refueling outage, Carolina Power & Light Company shall submit for NRC review and receive approval if a steam generator tube rupture analysis, including the assumed operator actions, which demonstrates that the consequences of the design basis steam generator tube rupture event for the Shearon Harris Nuclear Power Plant are less than the acceptance criteria specified in the Standard Review Plan, NUREG-0800, at §15.6.3 Subparts 11(1) and (2) for calculated doses from radiological releases. In preparing their analysis Carolina Power & Light Company will not assume that operators will complete corrective actions within the first thirty minutes after a steam generator tube rupture.

1The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-63 Amendment No. 132

PLMT SYSTEMS 3/4.7.5 ULTn~ATE HEAT SINK LIMITING CONDITION FOR OPERATION 3.7 5 The ultimate heat sink shall be OPERABLE wlth:

a A mlnimum auxiliary reservoir water level at or above elevation 250 feet Mean Sea Level, USGS datum, and a mlnimum main reserVOlr water level at or above 206 feet Mean Sea Level, USGS datum, and

b. A water temperature as measured at the respectlve intake structure of less than or equal to 94°F.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

Wlth the requlrements of the above speclflcation not satlsfied, be in at least HOT STMDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWIN within the followlng 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.5 The ultimate heat sink shall be determined OPERABLE at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the water temperature and water level to be within their limits.

SHEARON HARRIS - UNIT 1 3/4 7-13 Amendment No. 132

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 132 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-63 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

By application dated April 30, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081270089), as supplemented by letters dated December 3,2008 (ADAMS Accession No. ML083500364), and June 30,2009 (ADAMS Accession No. ML091890780), Carolina Power & Light Company (the licensee), now doing business as Progress Energy Carolinas, Inc., submitted a proposed amendment for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

The proposed amendment would revise Technical Specification (TS) Section 3.7.5a to restore the ultimate heat sink (UHS) main reservoir minimum level to the value allowed by the initial operating license as a result of improvements made to the emergency service water (ESW) system. The change will allow continued plant operation to a main reservoir minimum level of 206 feet mean sea level (MSL) in Mode 1-4, versus the current minimum allowed level of 215 feet MSL.

The supplement dated June 30, 2009, provided a new evaluation of the proposed change and replaced the information previously submitted. As such, Enclosure 1 of the April 30, 2008, submittal is replaced in its entirety by Enclosure 1, "HNP Evaluation of the Proposed Change,"

of the submittal dated June 30, 2009. The supplements dated December 3, 2008, and June 30, 2009, also provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 12, 2008 (73 FR 46929).

2.0 REGULATORY EVALUATION

The function of the UHS is to dissipate reactor decay heat and essential cooling system heat after a shutdown caused by an abnormal condition including a loss-of-coolant accident. The UHS has two sources of cooling water; the auxiliary reservoir is the preferred source of cooling

-2 water in emergency conditions, while the main reservoir is the back up source for cooling water if the auxiliary reservoir is unavailable.

The UHS is the source of water for the ESW system, which provides cooling water at a maximum temperature of 95 degrees Fahrenheit (OF) to remove essential plant heat loads during emergency operation.

The licensee submitted a license amendment request (LAR) to change the minimum allowed main reservoir level from 215 feet MSL to 206 feet MSL as outlined in the TS Limiting Condition for Operation (LCO) 3.7.5, "Ultimate Heat Sink." The bases for establishing a minimum allowed main reservoir level are to ensure that the UHS can meet:

1. The requirements of General Design Criteria (GDC) 44, "Cooling Water;"

2. The gUidelines of Regulatory Guide (RG) 1.27, "Ultimate Heat Sink;" and

3. The Standard Review Plan (SRP) for the Review of Safety Analysis Reports for Nuclear Power Plants (NUREG-0800), Section 9.2.5, "Ultimate Heat Sink" These requirements are met by ensuring the availability of an adequate volume and temperature of water to transfer the heat load of systems, structures and components (SSG) important to safety under normal and accident conditions.

The minimum allowed main reservoir level is also based on the guidelines of SRP Section 9.2.1, "Station Service Water," to ensure a sufficient depth of water to provide adequate net positive suction head (NPSH) to the ESW system pumps, which transfer the heat load of SSCs important to safety to the UHS under normal operating and accident conditions.

GDC 44 states that a system to transfer heat from SSCs important to safety to a UHS shall be provided. The system's safety function shall be to transfer the combined heat load of these SSCs under both normal operating and accident conditions. SRP Section 9.2.5 reiterates this regulatory requirement.

RG 1.27 states, in part, that a 30 day water supply should be provided such that the design basis temperatures of safety related equipment are not exceeded. The guidelines of RG 1.27 also state that a conservative transient analysis should be conducted to show that flows and inlet temperatures remain above design basis limits assuming worst case meteorological conditions for periods of up to 30 days for plants that use lakes as the UHS.

SRP Section 9.2.1 requires, in part, that the pumps supplying essential service water have sufficient available NPSH at the pump suction locations even in low water level scenarios.

HNP Final Safety Analysis Report (FSAR) Section 9.2.5.1, "Design Basis," states that the design bases for the UHS are that the UHS has sufficient capacity to: (1) provide a source of cooling water to the ESW system for at least 30 days to permit safe shutdown and cooldown of the plant and to maintain it in the safe shutdown condition; or (2) provide a source of cooling water for at least 30 days to permit emergency shutdown and cooldown of the plant and to maintain the Unit in the safe shutdown condition.

-3 HNP FSAR Section 2.4.11.7, "Heat Sink Dependability Requirements," states that the UHS analysis uses a main reservoir level of 205.7 feet MSL (-206 feet MSL) as the starting point to establish a final UHS temperature and level that ensures an adequate volume of water exists to remove the heat generated by the plant. However, in order to meet the flow requirements for safety related heat exchangers cooled by the ESW system (see Section 9.2.1 of the HNP FSAR), the current UHS minimum main reservoir level is 215 feet MSL. In the LAR, the licensee requests that the minimum main reservoir level be changed to 206 feet MSL based on recent improvements to the ESW system that negate the need for a higher level.

Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment," requested that each licensee confirm that the service water system will perform its intended function in accordance with the licensing basis for the plant, including a review of the ability to perform required safety functions in the event of failure of a single active component.

HNP FSAR Section 9.2.1, "Service Water," states that under accident conditions the service water booster pumps, in conjunction with closure of the containment fan cooler orifice bypass valves, will maintain service water pressure inside the containment fan coolers above the containment design pressure in order to prevent leaks into the service water system.

HNP FSAR Section 9.2.1 also states that the service water system is designed to provide cooling water at a maximum temperature of 95 of to remove essential plant heat loads by utilizing the auxiliary reservoir or its backup, the main reservoir, during emergency operation.

The NRC staff's review methodology for the LAR consisted of comparing the licensee's proposed changes against the applicable regulatory criteria cited above, as well as reviewing the licensee's operational input as it relates to the methodology for concluding that existing regulatory criteria will continue to be satisfied after the proposed changes are implemented.

3.0 TECHNICAL EVALUATION

3.1 Proposed Change The licensee has proposed to change HNP TS LCO 3.7.5 for the UHS regarding the allowable main reservoir minimum level. The change will lower the minimum allowed main reservoir level from 215 feet MSL to 206 feet MSL in Modes 1-4.

Currently the HNP TS reads as follows:

3.7.5 The ultimate heat sink shall be OPERABLE with:

a. A minimum auxiliary reservoir water level at or above elevation 250 feet Mean Sea Level, [United States Geological Survey]

USGS datum, and a minimum main reservoir water level at or above 215 feet Mean Sea Level, USGS datum, and

b. A water temperature as measured at the respective intake structure of less than or equal to 94°F.

- 4 After approval of the proposed change, the HNP TS will read:

3.7.5 The ultimate heat sink shall be OPERABLE with:

a. A minimum auxiliary reservoir water level at or above elevation 250 feet Mean Sea Level, USGS datum, and a minimum main reservoir water level at or above 206 feet Mean Sea Level, USGS datum, and

b. A water temperature as measured at the respective intake structure of less than or equal to 94°F.

The licensee's basis for lowering the minimum allowed level of the main reservoir are the improvements made to the ESW system as a means of complying with the follow-up actions outlined in GL 89-13. The originally licensed minimum level for HNP's main reservoir was 206 feet MSL; however, after performance of the reviews requested by GL 89-13, the licensee determined that there was little system flow margin available, particularly for the containment fan coolers (CFCs). To address this condition, the minimum main reservoir level was increased to 215 feet MSL by HNP License Amendment No. 80.

Subsequent to License Amendment No. 80, the licensee made changes to the ESW system to improve system performance. The improvements included replacing ESW pump rotating elements, which increased total developed head (TDH) of the ESW pumps by 35 feet TDH; increasing the orifice sizes downstream of the CFCs, thereby allowing more flow through the coolers; and coating the ESW booster pump casings with corrosion resistant Belzona.

3.2 Minimum ESW System Flow Rates The minimum required ESW flow rates, which are based on sufficient heat removal for each component cooled by the ESW system, are listed in HNP FSAR Table 9.2.1-1, "Service Water Requirements." Since flow rates decrease as reservoir level lowers, calculation SW-0080, "ESW Flow Requirements Based on Reservoir Level," was performed and the results documented in the LAR. This calculation establishes the minimum acceptable ESW flow rates, as a function of main and auxiliary reservoir levels, to ensure that the ESW flow rates would be adequately maintained if main reservoir level were at 206 feet MSL. The licensee compared the calculated minimum required ESW flow rates at various reservoir levels to actual flow rates measured in the plant by engineering periodic tests (EPTs) 250 and 251. The comparison showed that the ESW system can continue to meet the minimum required ESW flow rates with a main reservoir level of 206 feet MSL.

EPT-250 and EPT-251 are flow balancing tests of both trains of the ESW system and are performed at least once per cycle. Calculation SW-0080 uses hydraulic modeling to calculate the minimum required ESW flow rates through various components for assorted main or auxiliary reservoir water levels. The flow rates recorded during the EPTs at the actual main or auxiliary reservoir level are compared to the flow rates determined by calculation SW-0080 at the same levels, to ensure that the ESW system can supply the required flow to all components during an accident scenario. The licensee presented data in the LAR from EPT-250 and EPT-251, which show significant margin above the minimum required ESW flow rates through

-5 each component cooled by the ESW system. The licensee also presented data from the EPTs for years 2005, 2006, and 2007 showing flow margins have remained within a small variance.

Thus, the licensee will continue to meet the requirements of GDC-44 and the guidelines of SRP Section 9.2.5 by providing a system to transfer heat from SSCs that are important to safety under accident conditions when the main reservoir level is at 206 feet MSL and above.

3.3 Minimum ESW System Pressure Inside Containment The ESW system pressure in the CFCs should be maintained equal to or greater than the containment design pressure in order to prevent leaks into the service water system, thereby ensuring that an unmonitored release path does not become available. The ESW pumps and booster pumps provide the source of ESW system pressure inside the CFCs. Accordingly, a lower main reservoir level would result in a lower suction pressure (i.e., NPSH) for the ESW pumps and booster pumps, thus lowering ESW system pressure in the CFCs.

The licensee performed calculation HNP-M/MECH-1 011, "Pump Degradation Limits for ESW, CCW [Component Cooling Water], and ESCW [Essential Services Chilled Water]," to determine what combinations of ESW pump and booster pump differential pressures with the main reservoir level at 206 feet MSL would maintain the minimum required ESW flow rates and minimum required ESW system pressure inside the CFCs. The licensee provided figures in the LAR derived from calculation HNP-M/MECH-1011 that show the minimum differential pressures for both the ESW pumps and booster pumps.

In calculation HNP-M/MECH-1 011, the licensee also plotted the most recent results of Operational Surveillance Tests (OSTs) 1214 and 1215, which show that the ESW pumps and booster pumps will maintain ESW system pressure inside the CFCs above containment design pressure at a main reservoir level of 206 feet MSL. In addition, the results demonstrate that maintaining ESW Pump and Booster Pump differential pressures as outlined will ensure that each component cooled by the ESW system is receiving at least the minimum required flow.

The calculation was also used to develop the OST test window that will be utilized by the licensee as acceptance criteria for future OST-1214 and OST-1215 results.

A single failure may cause the loss of an ESW booster pump and/or a CFC orifice bypass valve, which could impact the ability of the ESW system to perform its design function. Emergency Operating Procedure (EOP), EOP-FRP-J.1, "Response to High Containment Pressure,"

requires isolation of the impacted CFC if containment pressure exceeds 10 psig and the associated ESW booster pump is not running, and/or the associated orifice bypass is not open.

This procedure will not be adversely affected by lowering the main reservoir level from 215 feet MSL to 206 feet MSL and will continue to preserve the design function of the system.

Thus, the licensee will continue to meet the licensing basis stated in HNP FSAR Section 9.2.1, which states that under accident conditions, the service water booster pumps, in conjunction with closure of the containment fan cooler orifice bypass valves, will maintain service water pressure inside the containment fan coolers above the containment design pressure in order to prevent leaks into the service water system.

-6 3.4 Adequate UHS Volume The current licensing basis in HNP FSAR Section 2.4.11.7, "Heat Sink Dependability Requirements," states that the UHS analysis uses a main reservoir level of 205.7 feet MSL as the starting point for determining the final UHS temperature and level, and if an adequate volume of water exists to remove the heat generated by the plant, during operational and accident scenarios. While at their minimum normal operational levels, and with an initial water temperature of 95 of, the analysis shows that both the auxiliary and main reservoirs, taken separately, are more than adequate to permit emergency shutdown and cooldown of the plant.

The HNP FSAR Section 2.4.11.7 also states that the UHS analysis demonstrates the adequacy of the main reservoir to provide at least a 30-day supply of water for emergency shutdown and cooldown, even in the event that level in the main reservoir begins at 205.7 feet MSL. In this scenario, the water level at the end of the 30-day emergency period would be 203.6 feet MSL, which continues to remain above the minimum operating level required for the service water and cooling tower makeup water pumps.

Therefore, the proposed change for the minimum allowable level of the main reservoir to 206 feet MSL remains within the already analyzed basis for ultimate heat sink volume, temperature, and adequacy during emergency situations. Accordingly, the licensee will continue to meet the licensing basis stated in HNP FSAR Sections 9.2.5.1 and 2.4.11.7, as well as the regulatory guidance of RG 1.27.

3.5 Maximum ESW Supply Temperature The licensee stated that calculation SW-0085 concludes that peak reservoir temperatures will not exceed 95 of (the TS 3.7.5b limit is 94 OF) under worst-case conditions. This analysis assumes an initial main reservoir level of 205.7 feet MSL. This calculation assumption bounds the proposed new main reservoir level limit of 206 feet MSL.

Thus, the licensee will continue to meet the current licensing basis stated in HNP FSAR Section 9.2.1, "Service Water System," which states that the system is designed to provide cooling water at a maximum temperature of 95 of to remove essential plant heat loads by utilizing the auxiliary reservoir or its backup, the main reservoir, during emergency operation.

The licensee will also continue to meet the regulatory guidance of RG 1.27, which states that for lakes used as the UHS, a transient analyses of supply temperature should be performed (Le., via calculation SW-0085 for HNP).

3.6 Minimum ESW Pump Submergence The licensee states in calculation SW-0082 that the ESW pumps require a minimum of 6 feet above the bottom of the bell to ensure adequate NPSH for performing all required functions.

This equates to a reservoir level of about 198 feet MSL; the maximum evaporation case is calculated to be at 203 feet MSL. The proposed minimum allowable main reservoir level of 206 feet MSL is above both of these limits, and remains bounded by calculation SW-0082.

-7 Thus, the licensee will continue to meet the guidelines of SRP Section 9.2.1 which states, in part, that the pumps supplying essential service water have sufficient available NPSH at the pump suction locations even in low water level scenarios.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (73 FR 46929; August 12, 2008). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

Principal Contributor: Gerard Purciarello Date: October 14,2009

• ML092640247 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA SBPB/BC ITSB/BC OGC LPL2-2/BC NAME MVaaler CSoia GCasto* RElliott BHarris (NLO) TBoyce DATE 9/30/2009 9/29/2009 8/18/2009 10/09/09 10/7/2009 10/14/09

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