Text

License Amendment Request 279, Elimination of Technical Specification 3.7.14, Primary Auxiliary Building Ventilation
	ML16015A112
Person / Time
Site:	Point Beach
Issue date:	01/15/2016
From:	Mccartney E; Point Beach
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC 2015-0075
	Download: ML16015A112 (17)
	v • d • e

January 15, 2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Units 1 and 2 Docket Nos. 50-266 and 50-301 NEXTeraM EN ERGY~

~

NRC 2015-0075 10 CFR 50.90 Renewed Facility Operating Licenses Nos. DPR-24 and DPR-27 License Amendment Request 279, Elimination of Technical Specification 3.7.14, Primary Auxiliary Building Ventilation In accordance with 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests a license amendment to revise the technical specifications (TS) for Point Beach Units 1 and 2. The proposed change eliminates TS 3.7.14, Primary Auxiliary Building Ventilation (VNPAB).

The Enclosure to this letter provides NextEra's evaluation of the proposed change. to the enclosure provides a markup of the TS showing the proposed change, and provides the proposed TS Bases changes. The changes to the TS Bases are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment.

As discussed in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. This change has been reviewed by the Point Beach Onsite Review Group.

In accordance with 10 CFR 50.91, a copy of this letter is being forwarded to the State of Wisconsin designee.

This letter contains no new or revised regulatory commitments.

NextEra requests approval of the amendment by January 31, 2017 and implementation within 90 days.

Should you have any questions regarding this submittal, please contact Mr. Bryan Woyak, Licensing Manager, at 920-755-7599.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 15, 2016 Sincerely, NextEra Energy Point Beach, LLC

~YVz~

Eric McCartney Site Vice President Enclosure cc:

Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

1.0

SUMMARY

DESCRIPTION NextEra Energy Point Beach, LLC (NextEra) proposes to delete Technical Specification (TS) 3.7.14, Primary Auxiliary Building Ventilation (VNPAB) and its associated TS Bases. The VNPAB system is not part of the primary success path for mitigation of a design basis accident (DBA) and does not meet the criteria of 10 CFR 50.36 that require a TS limiting condition for operation (LCO).

2.0 DETAILED DESCRIPTION The proposed change deletes TS 3.7.14, Primary Auxiliary Building Ventilation (VNPAB) in its entirety on the basis that the VNPAB is not credited for accident mitigation and meets none of the criteria of 10 CFR 50.36 for inclusion in the TS. Attachment 1 contains a markup of TS 3.7.14 showing the proposed deletion. The proposed change also (1) removes a previously credited operator action related to operation of the VNPAB system, and (2) eliminates a commitment for administrative controls that ensures the control room emergency filtration system and the VNPAB will not be in concurrent TS action conditions.

3.0 TECHNICAL EVALUATION

3.1 Description of the VNPAB System The auxiliary building ventilation air is supplied by a central supply fan which includes an air filter, heating coils, and service water supplied cooling coils.

Sufficient outside air is supplied to maintain a once-through system with provisions available to recirculate air from the auxiliary building central area. The system is balanced to maintain the auxiliary building at a slightly negative pressure with respect to outside pressure and adjacent building pressures. This is accomplished by providing an exhaust flow capacity larger than the supply capacity. All the exhaust air is filtered through roughing and high efficiency filters for removal of particulates.

The VNPAB exhaust system consists of two filter fans, two stack fans, and the associated ductwork, filter housings, and dampers necessary to ensure the required exhaust flow path can be maintained. Each of the two filter fans and each of the two stack fans are powered by independent safety related power supplies with emergency diesel generator backup.

The VNPAB system is classified as non-safety related; however, components in the exhaust system required to direct radioactive releases in the auxiliary building to the vent stack are classified as Augmented Quality. The VNPAB exhaust system design provides redundancy for all active mechanical components and active and passive electrical components needed to provide PAB exhaust flow.

Point Beach UFSAR Chapter 9.5.3, Primary Auxiliary Building Ventilation System

-System Evaluation states: "No credit is given for the VNPAB exhaust system in the control room or offsite dose bounding analyses described in UFSAR Chapter 14.3.5, Radiological Consequences of a Loss of Coolant Accident."

Page 1 of 7

3.2 Evaluation Elimination of TS 3. 7. 14 NextEra submitted License Amendment Request (LAR) 241 in December 2008 for full implementation of alternative source term (AST) as described in 10 CFR 50.67 [Reference 1]. The design basis accident radiological dose analysis for implementation of AST initially credited the VNPAB exhaust system to mitigate dose to control room personnel. Therefore, the VNPAB exhaust system satisfied criterion 3 of 10 CFR 50.36 for a TS LCO (a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier).

As a result, NextEra supplemented LAR 241 with a request to add newTS 3.7.14, Primary Auxiliary Building Ventilation (VNPAB) [Reference 2]. Previously, the VNPAB was not under the control of the TS.

Subsequent to submitting the supplement proposing the addition of TS 3.7.14, NextEra provided a summary of the control room dose analysis performed without credit for the VNPAB in response to an NRC request for additional information regarding LAR 241 [Reference 3]. The analysis used was the same that was used for the AST methodology initially submitted to the NRC in LAR 241. The assumptions were the same as those used in the original submittal except that the control room atmospheric dispersion factors (x/Q values) for the run considering emergency core cooling system (ECCS) leakage to the auxiliary building were revised to reflect no credit for VNPAB, and flashing fractions for ECCS leakage were revised based on the time dependent sump temperature.

Utilizing the AST methodology provided in the LAR and applying the same inputs with the exception of the ones noted above, the revised loss of coolant accident control room dose analysis resulted in a control room total dose of 4.51 REM.

The NRC issued Amendments 240 and 244 for implementation of AST on April 14, 2011 [Reference 4]. The safety evaluation for the amendments recognized that Point Beach provided a summary of the control room dose analysis performed without credit for the VNPAB. This included a revision to the control room x/Q values for the assessment considering ECCS leakage with no credit for the VNPAB. The NRC staff review concluded the x/Q values were acceptable for use in the control room dose assessments. The safety evaluation again recognized that the AST analysis did not credit VNPAB in the statement:

"Although the licensee is not taking credit for the use of VNPAB in its AST analysis, the licensee has proposed a TS for the VNPAB, TS 3.7.1.4, "Primary Auxiliary Building Ventilation (VNPAB)," which is described in an April17, 2009, letter."

Point Beach TS 3.7.14 currently requires operability of the VNPAB exhaust system on the basis that the system meets criterion 3 of 10 CFR 50.36(c)(2)(ii) because it is credited to control exposure to the operators during a large break loss of coolant accident. However, the analysis for dose to the operators does not credit the VNPAB exhaust system, and this condition results in an inconsistency between the TS and the accident analysis. As a result, NextEra proposes to eliminate TS 3.7.14.

Page 2 of 7

Elimination of Credit for Manual Operator Actions AST implementation credited the following operator action:

Manual operator action to restore the VNPAB will occur within 30 minutes following the alignment of RHR to containment sump recirculation mode of operation. If a loss of coolant accident (LOCA) occurs coincident with a loss of off-site power (LOOP), the VNPAB will be manually restarted to ensure that the auxiliary building vent stack is the source of the release associated with the emergency core cooling system (ECCS) leakage phase of the event.

The analysis supporting AST does not credit the VNPAB exhaust system; therefore, NextEra proposes to delete the previously credited operator actions related to operation of the VNPAB system.

Elimination of Commitment AST implementation committed to the following administrative controls:

Administrative controls will be established to ensure that control room emergency filtration system (CREFS) and the primary auxiliary building ventilation (VNPAB) system will not be in concurrent Technical Specification Action Conditions (TSACs) during planned preventive maintenance activities on components of the CREFS and VNPAB systems. These administrative controls are not applicable to planned preventive maintenance activities performed on common support system components. [Reference 5]

With the elimination of TS 3.7.14, the commitment for administrative controls to ensure the control room emergency filtration system and the VNPAB will not be in concurrent TS action conditions will no longer be applicable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, Technical specifications-provides the requirements for the TS including the four criteria that require establishing a LCO.

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

The VNPAB exhaust system does not include installed instrumentation for monitoring the reactor coolant pressure boundary, and therefore, does not meet criterion 1 of 10 CFR 50.36.

Page 3 of 7

Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The VNPAB exhaust system is not a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis, and consequently, does not meet criterion 2 of 10 CFR 50.36.

Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

As discussed in the Point Beach UFSAR, the VNPAB system is not required to perform any safety related functions. No credit is given for the VNPAB exhaust system in the control room or offsite dose bounding analysis described in UFSAR Chapter 14.3.5, Radiological Consequences of a Loss of Coolant Accident. Additionally, the NRC's safety evaluation for Point Beach Amendments 240 and 244 for AST implementation acknowledged that NextEra did not take credit for the use of VNPAB in its AST analysis. Therefore, the VNPAB does not meet criterion 3 of 10 CFR 50.36.

Criterion 4. A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The \\(NPAB is not a system that is significant to public health and safety, and therefore, does not meet criterion 4 of 10 CFR 50.36.

10 CFR 50.67, Accident source term-specifies the requirements for the accident source term used in design basis radiological analyses.

4.2 Precedent The NRC previously issued license amendments that deleted TS requirements for systems that were not credited in design basis accident analyses and did not meet the criteria of 10 CFR 50.36 for inclusion in the TS.

Millstone Unit 3 received Amendment 219 [Reference 6] on March 17, 2004 for selective implementation of AST. The amendment deleted TS 3.9.9 for the containment purge and exhaust isolation system on the basis that the fuel handling accident design-basis analysis does not require operation of the system to satisfy the dose values of 10 CFR 50.67, and none of the criteria of 10 CFR 50.36 apply to the system. Similarly, the same amendment deleted TS 3.9.12 for the fuel building exhaust filter system.

On September 15, 2006, Millstone Unit 3 received Amendment 232 [Reference 7]

with changes to the TS for full-scope implementation of AST. The amendment Page 4 of 7

deleted TS 3.7.8, Control Room Envelope Pressurization System. In implementing the AST, Millstone did not take credit for the operation of the system to reduce unfiltered in-leakage to the control room in the design-basis analyses.

4.3 Significant Hazards Consideration The proposed change deletes Technical Specification (TS) 3.7.14, Primary Auxiliary Building Ventilation (VNPAB) and its associated TS Bases. The VNPAB system is not part of the primary success path for mitigation of a design basis accident (DBA) and does not meet the criteria of 10 CFR 50.36 that requires a TS limiting condition for operation.

As required by 10 CFR 50.91 (a), NextEra has evaluated the proposed change to the Point Beach TS using the criteria in 10 CFR 50.92 and determined that the proposed change does not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below.

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

Response: No The proposed change does not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. No actual facility equipment or accident analyses are affected by the proposed changes.

The control room dose analysis for a loss of coolant accident using alternate source term (AST) initially credited operation of the VNPAB exhaust system.

However, the analysis was subsequently revised to remove credit for the VNPAB prior to NRC final approval of implementation of AST. As a result, NextEra is proposing to remove the VNPAB system from the TS. The VNPAB system is not an initiator of accidents and does not function to mitigate the consequences of DBAs.

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

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). The proposed change does not create any new failure modes for existing equipment or any new limiting single failures. Additionally, the proposed change does not involve a change in the methods governing normal plant operation, and all safety functions will continue to perform as previously assumed in the accident analyses. Thus, the proposed change does not adversely Page 5 of 7

affect the design function or operation of any structures, systems, and components important to safety.

No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed change does not challenge the performance or integrity of any safety-related system.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The margin of safety associated with the acceptance criteria of any accident is unchanged. The proposed change will have no affect on the availability, operability, or performance of safety-related systems and components. The proposed change will not adversely affect the operation of plant equipment or the function of equipment assumed in the accident analysis.

The proposed amendment does not involve changes to any safety analyses assumptions, safety limits, or limiting safety system settings.

The changes do not adversely impact plant operating margins or the reliability of equipment credited in the safety analyses.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, NextEra concludes that the proposed amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92(c), "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Page 6 of 7

5.0 ENVIRONMENTAL CONSIDERATION

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Point Beach letter NRC 2008-0081, "Submittal of License Amendment Request 241, Alternative Source Term," December 8, 2008 (ML083450683)

2. Point Beach letter NRC 2009-0045, "Supplement to License Amendment Request 241 Proposed Technical Specifications for Primary Auxiliary Building Ventilation (VNPAB)," April 17, 2009 (ML091100182)

3. Point Beach letter NRC 2010-0141, "License Amendment Request 241, Alternate Source Term, Response to Request for Additional Information," September 3, 2010 (ML102460115)

4. NRC letter "Point Beach Nuclear Plant (PBNP), Units 1 and 2 - Issuance of License Amendments Regarding Use of Alternate Source Term (TAC Nos. ME0219 and ME0220)," April14, 2011 (ML110240054)

5. Point Beach letter NRC 2011 -0029, "License Amendment Request 241, Alternative Source Term, Revision of Previous Commitment," March 11, 2011 (ML110730295)

6. NRC letter "Millstone Power Station, Unit No.3 - Issuance of Amendment Re:

Selective Implementation of Alternate Source Term (TAC No. MB8137)," March 17, 2004 (ML040610926)

7. NRC letter "Millstone Power Station, Unit No.3-issuance of Amendment Re:

Alternate Source Term (TAC No. MC3333)," September 15, 2006 (ML061990135)

Page 7 of 7

ATTACHMENT 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 279 Markup of the Technical Specification Pages 2 pages follow

3.7 PlANT SYSTEMS 3.7.14 Primary Auxiliary Building Ventilation (VNPAB) lCO 3.7.14 VNPAB shall be OPERABlE.

APPliCABiliTY:

MODES 1, :!, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION

~ VNPAB inof)erable.

A-1.

Restore VNPA.B to VNPAB

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COMPlETION TIME 7 days OPER.~. BlE status.

.a.

Reguired.~.(:;tion and S-,...1.

asso(:;iated Comflletion Tim9 not met.

AN.Q a-2 t

Point Bea(:;h Be in MODE 3.

Be in MODE S.

3.7.14 1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Unit 1 Amendment I'Jo. :!S3 Unit :!

Amendment I'Jo. :!S7

VNPAB

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SURVEILLANCE REQUIREMENTS SURVEILLANCE J;:REQUENC¥ SR ~. 7. ~4. ~

Gpe~ate tl:le VNP.A,B filte~ a1=1d staGk fa1=1s fg~

11=1 aGGQ~Qai=IGe

~ ~ ~ r:Ril=lbltes. Ve~ify tl:le assgGiated lm~ flgw lisl:lts witl:l tl:le fg~ filter: fa !=IS al=ld fg~ staGk fa1=1s ar:e I=IGt lit.

S b1 Pte iII a 1=1 Ge J;:~egblei=IGY CGI=Itr:gl p~gs~ar+l SR

~. 7. ~ 4

. :;1 Ver:ify tl:le VNP,A,B syster:R Gal=! r:Rai1=1tai1=1 a PAB IR e!GGQ~Qai=!Ge p~es s bl ~e less tl:l a 1=1 atr:RGSpl:ler:iG pr:eSSbl~l al=ld witl:l tl:le less tl:la1=1 tblr:bil=le bblildi1=19 pr:eSSbll=e.

Sb1Pteillai=IGl J;:~eg blei=IGY CGI=Itr:gl p~gs~ar:R SR

~.7. ~4

. ~

~ler:ify ~lNPAB r+lal=lblal sta~t Gapability al=ld IR aGGQ~Qeli=!Ge ali§!l=lr:Rel=lt.

witl:l tl:le S bl Pte iII a 1=1 Ge J;:r:egblei=IGY CGI=It~gl P~G§J~ar+l t

PGil=lt BeaGI:l

~. 7. ~4 :;1 U1=1it ~

Ar+lel=ldr:Rel=lt NG. :;1~~

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ATTACHMENT 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 279 Markup of Technical Specification Bases 4 pages follow

VNPAI3 13 3.7.14 13 3.7 PlANT SYSTEMS 13 3.7.14 Primary Ablxiliary 13blilding V9ntilation (VNPAI3) 13ASES 13ACKGROUND Point 13each Th9 VNPAI3 9Xhablst sysh:~m maintains PAI3 pr9ssblr9 l9ss than atmosph9ric pr9ssblr9 and less than tblrbine bblilding pressblre. The VNPAI3 system operates dblring normal blnit operation.

The VNPAI3 exhablst system consists of tvvo filter fans (W 30.AJI3), two stack fans 0/V 21.AJI3), and the associated dblctwork and backdraft damp9rs necessary to the extent that the reqblirsd exhablst flow path can be maintained.

Exhablst air is filtered throblgh roblghing and high efficiency filters (F 29) for r9moval of particbllat9s. The air exhablsted from the primary ablxiliary bblilding is continbloblsly monitored by a noble gas radiation monitor (RE 214). A detector obltpblt above its set point will initiate exhablst filtration throblgh activated charcoal filters (F 23). No filters are credited in the dose analyses.

Operation of the VNPAI3 with one filter fan and one stack fan rblnning,

f and verification that the associated low flmv lights for filter fans and fur stack fans are not lit and that the VNPAI3 system can maintain a PAI3 pr9ssblre less than atmospheric pressblre and less than tblrbine bblilding

.Y pressblre, assblres the system can perform its design fblnction.

1 The VNPAI3 does not abltomatically restart after being load shed following a loss of offsite power, and manblal Operator action from the Control Room is reqblired to restart VNPAI3 within 30 minbltes following th9 alignm~Snt of RHR to containm~Snt sblmp recircbllation. Th9 VNPAI3 filter and stack fans have been inclblded in the emergency diesel g~Snerator loading profile dblring the r~Scircbllation phase of a loss of coolant accid~Snt.

13 3.7.14 1 Unit 1 Amendment No. 240 Unit 2 Amendment No. 244

APPLICABLE SAFETY ANALYSES APPbiC.A.B 1 biTY Point Beach VNPAB B 3.7.14 The\\/NPAB

iF~ *.

Nas 1n1t1ally credited b,

11 analysis for assblring the ro e

' 't the n ST LOCA control room dose release of EGGS recircbll:tio~ I~~ Q valbles associated with airborne stack for the airborne radiologi ~ age th~oblgh th1 PAB ventilation pers?nnel. Additional jblstificatfa protection of control room proVIded by a Sblbseqbl1nt dose on of th~ 7 ~ay aiiO\\'VSd Obltage time was EGGS leakage with no credit for~::lr;'s ~smg revised X!Q valbles f~;

resbllt meets the acceptance c.

vNPn B. The revised analysis analysis of record for AST.

ntena for dose and is th1 LOCA dose The \\1NP11B f f v

h sa IS ISS Cnterion 3 of 10 CFR 50

. 36(c)(2)(11).

control room habitability limitR:.BLE to ensblre that the VNPAB is considered OPER~~~eE ~~t foi~O'N*',~-g the LOCA The AU;essary to ensblre that the rima; *, hen !~dhldbl~l _components soblrce of the radiological em*p.

't ablxl_hary bblildmg vent stack is the leakage dblring the containm~~~lon assocl_ated with EGGS eqblipment The \\/~IP 11 B exh t

v

~

abls IS reqblired to be OPE A OPERABLE. The \\/NPAB.

s~mp ree~rcbllation phase are v

IS considered OPERABLE when*

a,. Both VI'IPAB filter fans (\\N 30A and lfll 30B) w n

are OPERABLE*

b.,. Both VNPAB stack fans (VIJ 21A and lfll 21 B)

I n

are OPERABLE*

G.,. The associated low flow li ht f I

not lit with one VI'JP 11 Bf iltg tor filter fans and for stack fans are n

er an and one VNP 11B stack f Q,. T n

an rblnnlng*

he VNPAB system can maintain a A

I atmospheric pressblre and I th P..B_ pressblre less than ess an tblrblne bblilding pressblre*

e.,. Dblctwork and backdraft d I

an exh t

ampers are OPER 11BLE t abiS path can be maintained; am; n

O the extent that f,.

VI'IPAB exhablst is ca bl pa e of being manw;!lly initiated.

operator exposblre dblring a larn b st be OPERABLE to control gs reak LOCA In MODES 1 I 21 3, and 4 VNP 11 B mbl B 3.7.14 2 Unit 1 Amendment No. 240 Unit 2 Amendment No. 244

t

~ASES FSAR. Section 9.5.

+.

VNPA~

~ 3.7.14 FS" R Sootion 14.:l.O.

0

" mondmonts 6

n loouan"" of biGQns.

M 2G11.

~ NRC S

'I k*e gfAiternate Soblrce ER P~NP Units 1 and 2 Term, dated.A.pnl14, Regarding =