Text

Issuance of Amendment No. 162 Revisions to Technical Specifications Associated with Movable Control Rods
	ML19224A563
Person / Time
Site:	Seabrook
Issue date:	11/18/2019
From:	Justin Poole; Plant Licensing Branch 1
To:	Moul D; NextEra Energy Seabrook
	Poole J, NRR/DORL/LPLI, 415-2048
References
	EPID L-2018-LLA-0272
	Download: ML19224A563 (36)
	v • d • e

UNITED STATES WASHINGTON, D.C. 20555-0001 November 18, 2019 Mr. Don Moul Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company NextEra Energy Seabrook, LLC Mail Stop: NT3/JW 15430 Endeavor Drive Jupiter, FL 33478

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO 162 RE: REVISIONS TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH MOVABLE CONTROL RODS (EPID L-2018-LLA-0272)

Dear Mr. Moul:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 162 to Renewed Facility Operating License No. NPF-86 for the Seabrook Station, Unit No. 1. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated October 4, 2018, as supplemented by letter dated September 30, 2019.

The amendment revises the TSs to adopt changes provided in Technical Specification Task Force (TSTF-234), "Add Action for More than One (Digital Rod Position Indication) [D]RPI Inoperable" and TSTF-547, "Clarification of Rod Position Requirements"; and make various other changes to align the Seabrook TSs more closely with NUREG-1431, "Standard Technical Specifications Westinghouse Plants."

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

Sincerely, Justin C. Poole, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosures:

1. Amendment No. 162 to NPF-86

2. Safety Evaluation cc: Listserv

NEXTERA ENERGY SEABROOK, LLC, ET AL.*

DOCKET NO. 50-443 SEABROOK STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 162 Renewed License No. NPF-86

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

A. The application for amendment filed by NextEra Energy Seabrook, LLC, et al.

(the licensee), dated October 4, 2018, as supplemented by letter dated September 30, 2019, 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 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.

NextEra Energy Seabrook, LLC, is authorized to act as agent for the: Hudson Light & Power Department, Massachusetts Municipal Wholesale Electric Company, and Taunton Municipal Lighting Plant and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.

Enclosure 1

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-86 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 162, are incorporated into the Renewed Facility Operating License No. NPF-86. NextEra Energy Seabrook, 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 by May 28, 2020.

FOR THE NUCLEAR REGULATORY COMMISSION

~~ ~

Ja:les G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 1 8, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 162 SEABROOK STATION, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-86 DOCKET NO. 50-443 Replace the following page of Renewed Facility Operating License No. NPF-86 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert 3 3 Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove Insert 3/4 1-1 3/4 1-1 3/4 1-3 3/4 1-3 3/4 1-15 3/4 1-15 3/4 1-16 3/4 1-16 3/4 1-18 3/4 1-18 3/4 1-18a 3/4 1-19 3/41-19 3/4 1-21 3/4 1-21 3/4 1-22 3/4 1-22 3/4 10-5 3/4 10-5 6-17 6-17 6-18 6-18 6-19 6-19 6-20 6-20

(3) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) NextEra Energy Seabrook, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility authorized herein.

(7) DELETED C. This renewed 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 NextEra Energy Seabrook, LLC, is authorized to operate the facility at reactor core power levels not in excess of 3648 megawatts thermal ( 100% of rated power).

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 162, are incorporated into the Renewed Facility Operating License No. NPF-86. NextEra Energy Seabrook, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3/4.1 REACTIVITY CONTROL SYSTEMS 3/4.1.1 BORATION CONTROL SHUTDOWN MARGIN -Tfil!9. GREATER THAN 200°F LIMITING CONDITION FOR OPERATION 3.1.1.1 The SHUTDOWN MARGIN for four-loop operation shall be greater than or equal to the limit specified in the COLR.

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

ACTION:

With the SHUTDOWN MARGIN less than the limiting value, immediately initiate and continue boration equivalent to 30 gpm at a boron concentration greater than or equal to the limit specified in the COLR for the Boric Acid Storage System until the required SHUTDOWN MARGIN is restored.

SURVEILLANCE REQUIREMENTS 4.1.1.1.1 The SHUTDOWN MARGIN shall be determined to be greater than or equal to the limiting value:

a. DELETED

b. DELETED

c. When in MODE 2 with kett less than 1, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving reactor criticality by verifying that the predicted critical control rod position is within the limits of Specification 3.1.3.6;

d. Prior to initial operation above 5% RATED THERMAL POWER after each fuel loading, by consideration of the factors of Specification 4.1.1.1.1e below, with the control banks at the maximum insertion limit of Specification 3.1.3.6; and

See Special Test Exceptions Specification 3.10.1.

SEABROOK - UNIT 1 3/4 1-1 Amendment No. Q, Q6, 141, 162

REACTIVITY CONTROL SYSTEMS BORATION CONTROL SHUTDOWN MARGIN -Tfil!.9. LESS THAN OR EQUAL TO 200°F LIMITING CONDITION FOR OPERATION 3.1.1.2 The SHUTDOWN MARGIN shall be greater than or equal to the limit specified in the COLR. Additionally, the Reactor Coolant System boron concentration shall be greater than or equal to the limit specified in the COLR when the reactor coolant loops are in a drained condition.

APPLICABILITY: MODE 5.

ACTION:

With the SHUTDOWN MARGIN less than the limit specified in the COLR or the Reactor Coolant System boron concentration less than the limit specified in the COLR, immediately initiate and continue boration equivalent to 30 gpm at a boron concentration greater than or equal to the limit specified in the COLR for the Boric Acid Storage System until the required SHUTDOWN MARGIN and boron concentration are restored.

SURVEILLANCE REQUIREMENTS 4.1.1.2 The SHUTDOWN MARGIN shall be determined to be greater than or equal to the limit specified in the COLR and the Reactor Coolant System boron concentration shall be determined to be greater than or equal to the limit specified in the COLR when the reactor coolant loops are in a drained condition:

a. DELETED

b. In accordance with the Surveillance Frequency Control Program by

consideration of the following factors:

1) Reactor Coolant System boron concentration,

2) Control rod position,

3) Reactor Coolant System average temperature,

4) Fuel burnup based on gross thermal energy generation,

5) Xenon concentration, and

6) Samarium concentration.

SEABROOK - UNIT 1 3/4 1-3 Amendment No. Q, 96, 141, 162

REACTIVITY CONTROL SYSTEMS 3/4.1.3 MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPERATION 3.1.3.1 All full-length shutdown and control rods shall be OPERABLE and positioned within +/- 12 steps of their group step counter demand position.

APPLICABILITY: MODES 1* and 2*.

ACTION:

a. With one or more full-length rods inoperable because of being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN is within the limits specified in the COLR within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one full-length rod misaligned from its group step counter demand height by more than +/- 12 steps, POWER OPERATION may continue provided that within 1 hour:

1. The remainder of the rods in the group with the misaligned rod are aligned to within +/- 12 steps of the misaligned rod while maintaining the rod sequence and insertion limits of Specification 3.1.3.6. The THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or

2. The SHUTDOWN MARGIN is within the limits specified in the COLR.

POWER OPERATION may then continue provided that:

a) A reevaluation of each accident analysis of Table 3.1-1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions; b) The SHUTDOWN MARGIN is verified within the limits specified in the COLR at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ;

See Special Test Exceptions Specifications 3.10.2 and 3.10.3.

SEABROOK - UNIT 1 3/4 1-15 Amendment No. Q, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES GROUP HEIGHT LIMITING CONDITION FOR OPE;RATION 3.1.3.1 ACTION b.2 (Continued) c) A power distribution maP. is obtained from the lncore Detector System and Fa(Z) and FNLlH are verified to be within their limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and d) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within the next hour and within the following 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the High Neutron Flux Trip Setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER.

c. DELETED

d. With more than one rod misaligned from its group step counter demand height by more than +/- 12 steps:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN in within the limits specified in the COLR, and

2. Be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS

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

Surveillance Requirement 4.1.3.1.1 is not required to be performed for rods associated with inoperable digital rod position indicator or demand position indicator.

4.1.3.1.1 The position of each full-length rod shall be determined to be within the group demand limit by verifying the individual rod positions in accordance with the Surveillance Frequency Control Program.

4.1.3.1.2 Each full-length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program.

SEABROOK - UNIT 1 3/4 1-16 Amendment No. 30, 141, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.3.2 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE and capable of determining the control rod positions within +/- 12 steps.

APPLICABILITY: MODES 1 and 2.

ACTION:

a. With a maximum of one DRPI per group inoperable, in one or more groups, either:

1. Determine the position of the non indicating rod(s) indirectly by the lncore Detector System at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With more than one DRPI per group inoperable in one or more groups:

1. Immediately place the control rods in manual control,

2. Verify the position of the rods with inoperable DRPls using the lncore Detector System once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or reduce THERMAL POWER to less than 50% RATED THERMAL POWER, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore inoperable DRPls to OPERABLE status such that a maximum of one DRPI per group is inoperable, or be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. When one or more rods with inoperable DRPI have moved greater than 24 steps in one direction since the last determination of the rod's position:

1. Verify that the position of the rods with inoperable DRPI using the lncore Detector System within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or

2. Reduce THERMAL POWER to less than 50% RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SEABROOK - UNIT 1 3/4 1-18 Amendment No. 27, 141, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES POSITION INDICATION SYSTEMS - OPERATING LIMITING CONDITION FOR OPERATION (Continued)

d. With one or more demand position indicator(s) per bank inoperable in one or more banks, either:

1. Verify that all DRPls for the affected banks are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 12 steps of each other at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SURVEILLANCE REQUIREMENTS

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

Surveillance Requirement 4.1.3.2 is not required to be met for DRPls associated with rods that do not meet Specification 3.1.3.1.

4.1.3.2 Each of the required DRPl(s) shall be determined to be OPERABLE by verifying that the digital rod position indicators agree with the demand position indicators within 12 steps when exercised over the full range of rod travel in accordance with the Surveillance Frequency Control Program.

SEABROOK - UNIT 1 3/4 1-18a Amendment No. 27, 141, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES 3/4.1.3.3 THIS SPECIFICATION NUMBER IS NOT USED SEABROOK - UNIT 1 3/41-19 Amendment No. 44-i, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES SHUTDOWN BANK INSERTION LIMIT LIMITING CONDITION FOR OPERATION 3.1.3.5 All shutdown banks shall be fully withdrawn as specified in the COLR.

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

Not applicable to shutdown banks inserted while performing Surveillance Requirement 4.1.3.1.2.

APPLICABILITY: MODES 1* and 2* **.

ACTION:

a. With one or more shutdown banks not fully withdrawn for reasons other than ACTION b:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

2. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restore the shutdown banks to fully withdrawn as specified in the COLR or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one shutdown bank inserted ::;; 10 steps beyond fully withdrawn as specified in the COLR:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify all control banks are within the insertion limits specified in the COLR,

2. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore the shutdown bank to fully withdrawn as specified in the COLR, or be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.5 Each shutdown bank shall be determined to be fully withdrawn as specified in the COLR:

a. Within 15 minutes prior to withdrawal of any rods in Control Bank A, B, C, or D during an approach to reactor criticality, and

b. In accordance with the Surveillance Frequency Control Program thereafter.

See Special Test Exceptions Specifications 3.10.2 and 3.10.3.

- With kett greater than or equal to 1.

I SEABROOK - UNIT 1 3/4 1-21 Amendment No. 8, Q, 141, 162

REACTIVITY CONTROL SYSTEMS MOVABLE CONTROL ASSEMBLIES CONTROL ROD INSERTION LIMITS LIMITING CONDITION FOR OPERATION 3.1.3.6 The control banks shall be limited in physical insertion as specified in the COLR.

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

Not applicable to control banks inserted while performing Surveillance Requirement 4.1.3.1.2.

APPLICABILITY: MODES 1* and 2* **.

ACTION:

a. With the control banks inserted beyond the insertion limits specified in the COLR for reasons other than ACTION b:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

2. Restore the control banks to within the limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or

3. Reduce THERMAL POWER within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the bank position using the insertion limits specified in the COLR, or

4. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With control bank A, B, or C inserted :s; 10 steps beyond the insertion limit specified in the COLR:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify all shutdown banks are fully withdrawn as specified in the COLR,

2. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore the control bank to within the insertion limits specified in the COLR, or be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.6 The position of each control bank shall be determined to be within the insertion limits in accordance with the Surveillance Frequency Control Program.

See Special Test Exceptions Specifications 3.10.2 and 3.10.3.

- With ketr greater than or equal to 1.

SEABROOK - UNIT 1 3/4 1-22 Amendment No. Q, 141, 162

SPECIAL TEST EXCEPTIONS 3/4.10.5 THIS SPECIFICATION NUMBER IS NOT USED SEABROOK - UNIT 1 3/4 10-5 Amendment No. 44+,

162

ADMINISTRATIVE CONTROLS 6.8.1.6.b The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in:

1. WCAP-12945P-A, "Code Qualification Document for Best Estimate LOCA Analysis," Volume 1, Revision 2, and Volumes 2 through 5, Revision 1; Bajorek, S. M., et al, 1998.

Methodology for Specification:

3.2.2 Heat Flux Hot Channel Factor

2. WCAP-10079-P-A, (Proprietary) and WCAP-10080-A (Non proprietary),

"NOTRUMP: A Nodal Transient Small Break and General Network Code",

August 1985.

Methodology for Specification:

3.2.2 Heat Flux Hot Channel Factor

3. YAEC-1363-A, "CASM0-3G Validation," April, 1988.

YAEC-1659-A, "SIMULATE-3 Validation and Verification,"

September, 1988.

WCAP-11596-P-A, (Proprietary), "Qualification of the PHOENIX-P/ANC Nuclear Design System for Pressurized Water Reactor Cores", June, 1988.

WCAP-10965-P-A, (Proprietary), "ANC: A Westinghouse Advanced Nodal Computer Code", September, 1986.

Methodology for Specifications:

3.1.1.1 SHUTDOWN MARGIN for MODES 1,2, 3, and 4 3.1.1.2 SHUTDOWN MARGIN for MODE 5 3.1.1.3 Moderator Temperature Coefficient 3.1.3.5 Shutdown Bank Insertion Limit 3.1.3.6 Control Rod Insertion Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor

4. Seabrook Station Updated Final Safety Analysis Report, Section 15.4.6, "Chemical and Volume Control System Malfunction That Results in a Decrease in the Boron Concentration in the Reactor Coolant System".

Methodology for Specifications:

3.1.1.1 SHUTDOWN MARGIN for MODES 1, 2, 3, and 4 3.1.1.2 SHUTDOWN MARGIN for MODE 5 SEABROOK - UNIT 1 6-17 Amendment No. 22, 66, 104, 115, 162

ADMINISTRATIVE CONTROLS 6.8.1.6.b (Continued)

5. YAEC-1241, "Thermal-Hydraulic Analysis of PWR Fuel Elements Using the CHIC-KIN Code", R. E. Helfrich, March, 1981.

WCAP-14565-P-A, (Proprietary), "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis",

October, 1999.

WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids," April 1999.

Methodology for Specification:

2.1 Safety Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor 3.2.5 DNB Parameters

6. YAEC-1849P, "Thermal-Hydraulic Analysis Methodology Using VIPRE-01 For PWR Applications," October, 1992.

WCAP-11397-P-A, (Proprietary), "Revised Thermal Design Procedure", April, 1989.

WCAP-8745-P-A, Design Basis for the Thermal Overpower~T and Thermal Overtemperature ~ T Trip Functions," September 1986.

Methodology for Specification:

2.2.1 - Limiting Safety System Settings 3.2.1 - AXIAL FLUX DIFFERENCE 3.2.2 - Heat Flux Hot Channel Factor 3.2.3 - Nuclear Enthalpy Rise Hot Channel Factor

7. YAEC-1854P, "Core Thermal Limit Protection Function Setpoint Methodology For Seabrook Station," October, 1992 Methodology for Specification:

2.2.1 Limiting Safety System Settings 3.1.3.5 - Shutdown Bank Insertion Limit 3.1.3.6 Control Rod Insertion Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor SEABROOK - UNIT I 6-18 Amendment No. Q, 22, 34, 66, 96, 104, 107, 115, 162

ADMINISTRATIVE CONTROLS 6.8.1.6.b (Continued)

8. YAEC-1856P, "System Transient Analysis Methodology Using RETRAN for PWR Applications," December, 1992.

Methodology for Specification:

2.2.1 Limiting Safety System Settings 3.1.1.3 - Moderator Temperature Coefficient 3.1.3.5 Shutdown Bank Insertion Limit 3.1.3.6 Control Rod Insertion Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor

9. YAEC-1752, "STAR Methodology Application for PWRs, Control Rod Ejection, Main Steam Line Break," October, 1990.

Methodology for Specification:

3.1.1.3 - Moderator Temperature Coefficient 3.1.3.5 Shutdown Bank Insertion Limit 3.1.3.6 Control Rod Insertion Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor

10. YAEC-1855PA, "Seabrook Station Unit 1 Fixed lncore Detector System Analysis," October, 1992.

ANP-3243P, "Seabrook Station Unit 1 Fixed lncore Detector System Analysis Supplement to YAEC-1855PA," Revision 1, May 2014.

Methodology for Specification:

3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor

11. YAEC-1624P, "Maine Yankee RPS Setpoint Methodology Using Statistical Combination of Uncertainties - Volume 1 - Prevention of Fuel Centerline Melt,"

March, 1988.

Methodology for Specification:

3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor SEABROOK - UNIT I 6-19 Amendment No. 88,104,107,115,143, 162

ADMINISTRATIVE CONTROLS 6.8.1.6.b (Continued)

12. NYN-95048, Letter from T. C. Feigenbaum (NAESCo) to NRC, "License Amendment Request 95-05: Positive Moderator Temperature Coefficient",

May 30, 1995.

Methodology for Specification:

3.1.1.3 Moderator Temperature Coefficient

13. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report".

April, 1995, (Westinghouse Proprietary).

WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'",

July 2006.

Methodology for Specification:

3.2.2 Heat Flux Hot Channel Factor

14. WCAP-10216-P-A, Revision 1A (Proprietary), "Relaxation of Constant Axial Offset Control Fa Surveillance Technical Specification", February, 1994.

Methodology for Specification:

3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor

15. WCAP-9272-P-A, (Proprietary), "Westinghouse Reload Safety Evaluation Methodology", July, 1985.

Methodology for Specifications:

2.1 Safety Limits 3.1.1.1 SHUTDOWN MARGIN for MODES 1,2,3, and 4 3.1.1.2 SHUTDOWN MARGIN for MODE 5 3.1.1.3 Moderator Temperature Coefficient 3.1.2.7 Isolation of Unborated Water Sources - Shutdown 3.1.3.5 Shutdown Bank Insertion Limit 3.1.3.6 Control Rod Insertion Limits 3.2.1 AXIAL FLUX DIFFERENCE 3.2.2 Heat Flux Hot Channel Factor 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor 3.2.5 DNB Parameters 3.5.1.1 Accumulators for MODES 1, 2, and 3 3.5.4 Refueling Water Storage Tank for MODES 1, 2, 3, and 4 3.9.1 Boron Concentration

16. WCAP-13749-P-A, (Proprietary) "Safety Evaluation Supporting the Conditional Exemption of the Most Negative Moderator Temperature Coefficient Measurement," March, 1997.

Methodology for Specifications:

3.1.1.3 Moderator Temperature Coefficient SEABROOK - UNIT 1 6-20 Amendment No. 66, 88, 104, 107, 115, 13Q, 162

UNITED STATES SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 162 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-86 NEXTERA ENERGY SEABROOK. LLC SEABROOK STATION. UNIT NO. 1 DOCKET NO. 50-443

1.0 INTRODUCTION

By letter dated October 4, 2018, as supplemented by letter dated September 30, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML18277A377 and ML19274D342), NextEra Energy Seabrook, LLC (the licensee) submitted License Amendment Request (LAR) No. 18-02, requesting changes to the Technical Specifications (TSs) for Seabrook Station, Unit No. 1 (Seabrook). Specifically, the licensee proposed to revise the TSs to adopt changes provided in Technical Specification Task Force (TSTF-234), "Add Action for More than One (Digital Rod Position Indication) [D]RPI Inoperable" and TSTF-547, "Clarification of Rod Position Requirements"; and make various other changes to align the Seabrook TSs more closely with NUREG-1431, "Standard Technical Specifications Westinghouse Plants."

2.0 REGULATORY EVALUATION

2.1 System Description Seabrook uses rod cluster control assemblies (RCCA). The licensee describes this system as follows:

The rod cluster control assemblies (RCCA), or rods, are moved by their control rod drive mechanisms (CROM). Each CROM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates depending on the signal output from the rod control system. The RCCAs are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. If a bank of RCCAs consists of two groups, the groups are moved in a staggered fashion but always within one step of each other. Seabrook has four control banks and five shutdown banks.

Enclosure 2

The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are moved in an overlap pattern, using the following withdrawal sequence: when control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues until control banks A, B, and C are at the fully withdrawn position, and control bank D is approximately halfway withdrawn. The insertion sequence is the opposite of the withdrawal sequence.

The control banks are used for precise reactivity control of the reactor. The positions of the control banks are normally automatically controlled by the rod control system but can also be manually controlled. The control banks must be maintained above insertion limits and are typically near the fully withdrawn position during normal full power operations.

The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the bank demand position indication system

( commonly called group step counters) and the digital rod position indication (DRPI) system. The bank demand position indication system counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The bank demand position indication system is considered relatively precise(+/- 1 step or+/- 5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse but incorrectly reflect the position of the rod.

However, the DRPI system provides a more accurate indication of actual rod position, but at a lower precision than the step counters. DRPI measures the actual position of each full-length rod using a detector that consists of discrete coils mounted concentrically with the rod drive pressure housing. The coils are located axially along the pressure housing and magnetically sense the entry and presence of the rod drive shaft through its centerline. For each detector, the coils are interlaced into two data channels, and are connected to the containment electronics (Data A and B) by separate multi-conductor cables. By employing two separate channels of information, the DRPI system can continue to function (at reduced accuracy) if one channel fails.

2.2 Description of TS Changes The proposed change adopts, in part, the changes provided in TSTF-547, "Clarification of Rod Position Requirements," which addresses a conflict between surveillance requirements (SRs) in TS 3.1.3.1, "Group Height" and TS 3.1.3.2, "Position Indications Systems-Operating" when using the DRPI. The change also relocates TS 3.1.3.3, "Position Indication System-Shutdown" because it does not meet the criteria for inclusion in the TSs. The proposed change also adopts the changes provided in TST-234, "Add Action for More than One (Digital Rod Position Indication) [D]RPI Inoperable," to allow for more than one DRPI to be inoperable for a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , given that other indirect means of monitoring changes in rod position are available.

On October 15, 1987, the B&W Owners Group submitted a report to the U.S. Nuclear

Regulatory Commission (NRC or the Commission) proposing to relocate certain TSs in response to the Commission's Interim Policy Statement on Technical Specification Improvements, published in February 1987. The NRC staff published its conclusions of that report in May 1988 (ADAMS Accession No. ML11264A057). In addition, the proposed amendment clarifies operability requirements for the control rods and eliminates duplicate SRs and simplifies directions to the operators who must implement and ensure adherence to the TSs. The identified TSs are proposed to be relocated to the Technical Requirements Manual and Surveillance Frequency Control Program.

The proposed changes to the TSs are shown as follows ( added text shown in bold and deleted text shown in strikeout):

TS 3.1.1.1, "Shutdown Margin - Tavg Greater than 200°F" 4.1.1.1.1 The SHUTDOWN MARGIN shall be determined to be greater than or equal to the limiting value:

a. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after detection of an inoperable control rod(s) and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter while the rod(s) is inoperable. If the inoperable control rod is immovable or untrippable, the above required SHUTDOVVN MARGIN shall be verified acceptable with an increased allmvance for the withdrai.vn worth of the immoi.<able or untrippable control rod(s);DELETED

b. When in MODE 1 or MODE 2 *.*.<ith keff greater than or equal to 1 in accordance with the Surveillance Frequency Control Program by verifying that control bank withdrawal is within the limits of Specification 3.1.3.6;DELETED

TS 3.1.1.2, "Shutdown Margin - Tavg Less than or Equal to 200°F" 4.1.1.2 The SHUTDOWN MARGIN shall be determined to be greater than or equal to the limit specified in the COLR and the Reactor Coolant System boron concentration shall be determined to be greater than or equal to the limit specified in the COLR when the reactor coolant loops are in a drained condition:

a. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after detection of an inoperable control rod(s) and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 'Nhile the rod(s) is inoperable. If the inoperable control rod is immovable or untrippable, the SHUTDOVVN MARGIN shall be verified acceptable with an increased allowance for the withdravm worth of the immovable or untrippable control rod(s);

BR4DELETED

TS 3.1.3.1, "Group Height" 3.1.3.1 All full-length shutdown and control rods shall be OPERABLE and positioned within +/- 12 steps (indicated position) of their group step counter demand position.

APPLICABILITY: MODES 1* AND 2*.

ACTION:

a. With one or more full-length rods inoperable because of being immovable as a result of excessive friction or mechanical interference or known to be untrippable, determine that the SHUTDOWN MARGIN is within the limits specified in the COLR requirement of Speoifioation 3.1.1.1 is satisfied within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one full-length rod trippable but inoperable due to oauses other than addressed by ACTION a., abm,e, or misaligned from its group step counter demand height by more than +/- 12 steps (indioated position),

POWER OPERATION may continue provided that within 1 hour:

1. The rod is restored to OPERABLE status within the abo',<e alignment requirements, or

12. The red is declared inoperable and the remainder of the rods in the group with the misalignedinoperable rod are aligned to within

+/- 12 steps of the misalignedinoperable rod while maintaining the rod sequence and insertion limits of Specification 3.1.3.6. The THERMAL POWER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, or 2J. The rod is declared inoperable and the SHUTDOWN MARGIN is within the limits specified in the COLRrequirement of Speoifioation 3.1.1.1 is satisfied. POWER OPERATION may then continue provided that:

a) A reevaluation of each accident analysis of Table 3.1 -1 is performed within 5 days; this reevaluation shall confirm that the previously analyzed results of these accidents remain valid for the duration of operation under these conditions; b) The SHUTDOWN MARGIN is verified within the limits specified in the COLRrequirement of Specifioation 3.1.1.1 is determined at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; c) A power distribution map is obtained from the lncore Detector System and Fq(Z) and FNi\H are verified to be within their limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and d) The THERMAL POWER level is reduced to less than or equal to 75% of RATED THERMAL POWER within the next hour and within the following 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the High Neutron Flux Trip Setpoint is reduced to less than or equal to 85% of RATED THERMAL POWER.

c. DELETEDVVith more than one rod trippable but inoperable due to causes other than addressed by ACTION a. abo 11e, POVVER OPERATION may continue provided that:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the remainder of the rods in the bank(s) 'Nith the inoperable rods are aligned to 'Nithin :t 12 steps of the inoperable rods 'Nhile maintaining the rod sequence and insertion limits of Specification 3.1.3.6. The THERMAL POVVER level shall be restricted pursuant to Specification 3.1.3.6 during subsequent operation, and

2. The inoperable rods are restored to OPERABLE status within 72_hours.

d. With more than one rod misaligned from its group step counter demand height by more than +/- 12 steps: (indicated position), be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, and

2. Be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS

- - - - --*-**-*--------*--**-**-----*---*****--------NOTE------------***-***---------******----------*

Surveillance Requirement 4.1.3.1.1 is not required to be performed for rods associated with inoperable digital rod position indicator or demand position indicator.

4.1.3.1.1 The position of each full-length rod shall be determined to be within the group demand limit by verifying the individual rod positions in accordance with the Surveillance Frequency Control Program, except during time intervals when the rod position deviation monitor is inoperable; then verify the group positions at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

4.1.3.1.2 Each full-length rod not fully inserted in the core shall be determined to be OPERABLE by movement of at least 10 steps in any one direction in accordance with the Surveillance Frequency Control Program.

TS 3.1.3.2, "Position Indication Systems-Operating" 3.1.3.2 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE and capable of determining the control rod positions within +/- 12 steps.

APPLICABILITY: MODES 1 AND 2.

ACTION:

a. With a maximum of one DRPldigital rod position indicator per groupaa.Ak inoperable in one or more groups, either:

1. Determine the position of the nonindicating rod(s) indirectly by the lncore Detector System at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and immediately after any motion of the nonindicating rod which exceeds 24 steps in one direction since the last determination of the rod's position, or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b. With more than one DRPI per group inoperable in one or more groups:

1. Immediately place the control rods in manual control,

2. Verify the position of the rods with inoperable DRPls using the lncore Detector System once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or reduce THERMAL POWER to less than 50% RATED THERMAL POWER, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore inoperable DRPls to OPERABLE status such that a maximum of one DRPI per group is inoperable, or be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. When one or more rods with inoperable DRPI have moved greater than 24 steps in one direction since the last determination of the rod's position:

1. Verify the position of the rods with inoperable DRPI using the lncore Detector System within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or

2. Reduce THERMAL POWER to less than 50% RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

db. With a maximum of one or more demand position indicators per bank inoperable in one or more banks, either:

1. Verify that all DRPlsdigital rod position indicators for the affected banks are OPERABLE and that the most withdrawn rod and the least withdrawn rod of the bank are within a maximum of 12 steps of each other at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

SURVEILLANCE REQUIREMENTS

l"IIC>Tl:---------------------------------------------

Surveillance Requirement 4.1.3.2 is not required to be met for DRPls associated with rods that do not meet Specification 3.1.3.1.

4.1.3.2 l:ach of the required DRPl(s) shall be determined to be C>Pl:RABLI: by verifying that the digital rod position indicators agree with the demand position indicators within 12 steps when exercised over the full range of rod travel in accordance with the Surveillance Frequency Control Program Each digital rod position indicator shall be determined to be OPERP,BLE by verifying that tho Demand Position Indication System and tho Digital Rod Position Indication System agree within 12 stops in accordance with tho Surveillance Frequency Control Program, except during time intervals when tho rod position deviation monitor is inoperable; then compare tho Demand Position Indication System and tho Digital Rod Position Indication System at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

TS 3.1.3.3, "Position Indication System-Shutdown" The licensee is proposing to delete this TS and replace the title with "3/4.1.3.3 THIS SPECIFICATION NUMBER IS NOT USED." SR 4.1.3.3 is being proposed as SR 4.1.3.2 as shown above.

TS 3.1.3.5, "Shutdown Bank-Roo Insertion Limit" 3.1.3.5 All shutdown banksfOGS-shall be fully withdrawn# as specified in the CORE OPERATING LIMITS REPORT (COLR).

l"IIC>Tl:---------------------------------------------

l"llote applicable to shutdown banks inserted while performing Surveillance Requirement 4.1.3.1.2.

APPLICABILITY: MODES 1* AND 2* **.

ACTION:

a. With a maximum of one or more shutdown banksfOG not fully withdrawn#, except f.or surveillance testing pursuant to Specification 4.1.3.1.2, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months oitherfor reasons other than ACTIC>l"II b:

1a. Fully v:ithdraw tho rod, orWithin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDC>Wl"II MARGll"II is within the limits specified in the COLR, or initiate boration to restore SHUTDC>Wl"II MARGll"II to within limit, and 2a. Declare tho rod to be inoperable and apply Specification 3.1.3.1Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restore the shutdown banks to fully withdrawn as specified in the CC>LR or be in HC>T STAl"IIDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one shutdown bank inserted S 10 steps beyond fully withdrawn as specified in the COLR:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify all control banks are within the insertion limits specified in the COLR,

2. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore the shutdown bank to fully withdrawn as specified in the COLR, or be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.5 Each shutdown bankraa shall be determined to be fully withdrawn# as specified in the COLR:

The fully withdrawn position is defined as the interval within 225 to the mechanically fully withdrawn position, inclusive.

TS 3.1.3.6, "Control Rod Insertion Limits" 3.1.3.6 The control banks shall be limited in physical insertion as specified in the CORE OPERATING LIMITS REPORT (COLR).

NOTE:---------------------------------------------

Note applicable to control banks inserted while performing Surveillance Requirement 4.1.3.1.2.

APPLICABILITY: MODES 1* AND 2* **.

ACTION:

a. With the control banks inserted beyond the insertion limits specified in the COLR for reasons other than ACTION b, except for surveillance testing pursuant to Specification 4.1.3.1.2:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and 2a. Restore the control banks to within the limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or

39. Reduce THERMAL POWER within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to less than or equal to that fraction of RATED THERMAL POWER which is allowed by

the bank position using the insertion limits specified in the COLR, or 4e. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With control bank A, 8, or C inserted :S 10 steps beyond the insertion limit specified in the COLR:

1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify all shutdown banks are fully withdrawn as specified in the COLR,

2. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , verify SHUTDOWN MARGIN is within the limits specified in the COLR, or initiate boration to restore SHUTDOWN MARGIN to within limit, and

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , restore the control bank to within the insertion limits specified in the COLR, or be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.3.6 The position of each control bank shall be determined to be within the insertion limits in accordance with the Surveillance Frequency Control Program, except during time inteP.1als *.vhen the rod insertion limit monitor is inoperable; then verify tho individual rod positions at least onoo per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

TS 3/4.10.5, "Position Indication System-Shutdown" The licensee is proposing to delete this TS and replace the title with "THIS SPECIFICATION NUMBER IS NOT USED."

TS 6.8.1.6.b TS 6.8.1.6.b references TS 3.1.3.5 in five times {TS 6.8.1.6.b.3, TS 6.8.1.6.b.7, TS 6.8.1.6.b.8, TS 6.8.1.6.b.9, and TS 6.8.1.6.b.15). As stated above, the licensee is proposing to change the title of TS 3.1.3.5 from "Shutdown Rod Insertion Limit" to "Shutdown Bank Insertion Limit." The changes to TS 6.8.1.6.b reflect this title change.

2.3 Regulatory Requirements and Guidance The regulatory requirements and guidance documents that the NRC staff considered in its review of the proposed amendment included the following:

Section 182a of the Atomic Energy Act of 1954, as amended requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in Section 50.36, "Technical specifications," of Title 10 of the Code of Federal Regulations ( 10 CFR),

which requires that the TSs include items in the following specific categories:

(1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design; and (5) administrative controls.

However, the regulation does not specify the particular requirements to be included in TSs.

General Design Criterion (GDC) 13 "Instrumentation and control." Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

GDC 26 "Reactivity control system redundancy and capability." Two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.

GDC 28 "Reactivity limits." The reactivity control systems shall be designed with appropriate limits on the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents can neither: ( 1) result in damage to the reactor coolant pressure boundary greater than limited local yielding nor (2) sufficiently disturb the core, its support structures or other reactor pressure vessel internals to impair significantly the capability to cool the core.

NUREG-1431, Volume 1, "Standard Technical Specifications, Westinghouse Plants,"

Revision 4, is the NRC guidance document for format and content of TSs for Westinghouse plants.

3.0 TECHNICAL EVALUATION

3.1 Control Rod Operability Current TS 3.1.3.1, "Movable Control Assemblies - Group Height," contain Actions that address control rods that are trippable but inoperable. The licensee proposed to revise and clarify the operability requirements for the control rods. Consistent with NUREG-1431, "Standard Technical Specifications Westinghouse Plants," the rod operability requirement is satisfied provided the rod will fully insert in the required rod drop time assumed in the safety analysis.

Rod control malfunctions that result in the inability to move a rod with no impact to trippability do not result in rod inoperability. Additionally, TSTF-107-A, "Separate Control Rods that are Untrippable Versus Inoperable," revised NUREG-1431 to clarify that the alignment limit is separate from the operability of the rod; a rod can remain operable even though it may be beyond the step alignment limit. The NRC staff reviewed the proposed change and found that the generic methods were appropriately applied to Seabrook. Based on these considerations,

the NRC staff concludes that the proposed changes to TS 3.1.3.1 to the Seabrook TSs provides reasonable assurance of public health and safety, and therefore, is acceptable.

3.2 Shutdown Margin - Tavg Greater than 200°F SR 4.1.1.1.1.a, associated with TS 3.1.1.1, requires verification of the shutdown margin. The licensee stated that SR 4.1.1.1.1.a is proposed for elimination because it is a duplicate requirement. That is, TS 3.1.3.1 requires a shutdown margin to be determined within one hour of the detection of an inoperable control rod. SR 4.1.1.1.1.a is applicable in Modes 1 through 4.

However, control rods are only required to be operable in Modes 1 and 2. TS 3.1.1.1 retains the requirement for shutdown margin for Modes 1 and 2; shutdown margin verification is not needed for Modes 3 and 4. Additional details in SR 4.1.1.1.1.a, such as accounting for rod worth in the shutdown margin determination will be maintained in the TS bases. The change is also consistent with the standard TSs in NUREG-1431, where the Required Actions in TS 3.1.4, "Rod Group Alignment Limits," direct verifying shutdown-margin when rods are inoperable or outside alignment limits, and the Bases discuss including the worth of an untrippable rod in the shutdown margin determination.

SR 4.1.1.1.1.b requires verifying that the shutdown margin is within the limits of TS 3.1.3.6, "Control Rod Insertion Limits." The licensee proposed to eliminate SR 4.1.1.1.1.b because it is a duplicate requirement and makes no technical changes to the requirement. The licensee also stated that the proposed change reduces burden on the operators by eliminating the need to comply with duplicate requirements in different TSs.

Based on the above considerations, the NRC staff concludes that the proposed changes to SR 4.1.1.1.1.a and 4.1.1.1.1.b to the Seabrook TSs provide reasonable assurance of public health and safety, and therefore, is acceptable.

3.3 Shutdown Margin - Tavg Less than or Equal to 200°F Currently, SR 4.1.1.2.a requires verifying the shutdown margin in Mode 5. The proposed change removes the requirement to perform a shutdown margin determination for an inoperable rod in Mode 5. The licensee stated that because the control rods are only required to be operable in Modes 1 and 2, the verification is not necessary. Since there are no operability requirements for control rods in Mode 5, performing a shutdown margin determination in Mode 5 is not needed when control rod operability is not a consideration. In Mode 5, the shutdown margin determination considers the factors listed in SR 4.1.1.2.a, which includes control rod position. Based on the above considerations, the NRC staff concludes that the proposed changes to SR 4.1.1.2.a to the Seabrook TSs provide reasonable assurance of public health and safety, and therefore, is acceptable.

3.4 Group Height The Limiting Condition for Operation (LCO) and Actions b and d for TS 3.1.3.1 use the term

"(indicated position)" when referring to the control rod alignment requirement. The licensee proposed to delete this term because the clarification is not necessary. This proposed change is consistent with NUREG-1431.

TS 3.1.3.1 Action a requires a determination that the shutdown margin requirement of Specification 3.1.1.1 is satisfied within one hour following the discovery of an untrippable control

rod. The licensee proposed to delete the reference to TS 3.1.1.1 and replace it with a reference to the Core Operating Limits Report (COLR). TS 3.1.1.1 requires that the shutdown margin is within the limit specified in the COLR. This change does not alter any technical requirements and is administrative in nature. The licensee noted that it also reduces burden on the operators by eliminating the need to reference TS 3.1.1.1 and refers the TS user directly to the COLR.

TS.3.1.3.1 Action b addresses a condition in which a control rod is trippable but inoperable or misaligned. In alignment with the TS change to TS 3.1.1.1, the licensee proposed to change this Action to address only the condition of a misaligned control rod and eliminate the reference to inoperable. This change will also delete Action b.1, which requires restoring an inoperable or misaligned control rod. The restoration of an LCO condition is always an option, and therefore the statement of this Action is not necessary. This change is consistent with TSTF-547 which deleted a similar action to restore a misaligned rod within limits with one hour on the basis that restoring the equipment to operable status is understood to be an option and does not require an explicit statement of the Action. Action b.2 and b.3 have proposed conforming changes to address the misaligned condition only and reference the COLR and are renumbered to Action b.1 and b.2, respectively.

TS 3.1.3.1 Action c addresses when more than one control rod is trippable but inoperable. The licensee proposed to delete this Action because, consistent with NUREG-1431, the rod operability requirement is satisfied provided the rod will fully insert in the required rod drop time assumed in the safety analysis.

TS 3.1.3.1 Action d is revised to add a new requirement to verify the shutdown margin due to the misalignment of more than one rod. This proposed Action is consistent with NUREG-1431 for the misalignment of more than one rod and the potential to affect the shutdown margin.

SR 4.1.3.1.1 requires periodic verification that individual rod positions are within the group demand limit. This SR cannot be performed for rods with an inoperable group demand position indicator or inoperable DRPI. This condition would require entry into TS 3.1.3.1 Action d for more than one misaligned rod and may require shutdown to Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . TS 3.1.3.2 would allow continued operation with an inoperable group demand position indicator provided that the DRPls for the affected group are operable and the affected rods are within 12 steps of each other, or the power is reduced to less than 50 percent. TS 3.1.3.2 would also allow the continued operation with the DRPI being inoperable, provided the position of the affected rods is periodically verified using the incore detector system or the power is reduced to less than 50 percent. To address the conflicting requirements in TS 3.1.3.1 and 3.1.3.2, the licensee proposed a new note to provide an exception to performing SR 4.1.3.1.1 for rods associated with inoperable DRPI or demand position indicators. The licensee stated that this change is acceptable because the Actions in TS 3.1.3.2 provide the appropriate compensatory measures for inoperable DRPls or demand position indicators. In addition, the proposed change is also consistent with a change approved in TSTF-547. SR 3.1.4.1 in NUREG-1431 is similar to Seabrook SR 4.1.3.1.1 and requires verifying that individual rod positions are within the alignment limits. TSTF-547 modified SR 3.1.4.1 with a note that states that the SR is not required to be performed for rods associated with an inoperable rod position indicator or demand position indicator.

Based on the above considerations, the NRC staff concludes that the proposed changes to TS 3.1.3.1 and SR 4.1.3.1.1 to the Seabrook TSs provide reasonable assurance of public health and safety, and therefore, are acceptable.

3.5 Position Indication Systems-Operating The application proposed to revise the wording of TS 3.1.3.2 for entry into Action a of TS 3.1.3.2 from "per bank" to "per group" "in one or more groups." This proposed change is consistent with NUREG-1431.

Current Action b in TS 3.1.3.2 is changed to Action d and proposes a new Action b to address the condition that more than one DRPI in one or more groups is inoperable. The current TS Action addresses the situation in which a maximum of one demand position indicator per bank is inoperable. However, a demand position indicator is provided for each group of control rods, so control rod banks consisting of two rod groups have two demand position indicators. This proposed change is consistent with NUREG-1431, TSTF-547, and TSTF-234, "Add Action for More Than One [D]RPI Inoperable." The new proposed Action b provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the DRPI to operable status so that a maximum of one DRPI per group is inoperable.

Also consistent with NUREG-1431, proposed Action c is relocating TS 3.1.3.2, Action a.1 for verifying the rod position for a rod with an inoperable position indicator when the rod has moved in excess of 24 steps in one direction to a separate Action. Proposed Action c, which applies when one or more rods with inoperable DRPI have moved greater than 24 steps in one direction since the last determination of the rods' position and verifies the position of the non-indicating rods within four hours using the incore detector system.

This proposed change deletes SR 4.1.3.2, which is intended to demonstrate the DRPI operability by verifying that the DRPI and demand position indications agree within 12 steps.

This SR duplicates SR 4.1.3.1.1, which verifies that individual rods are within the group demand limit (+12 steps). The licensee stated that this SR is not a good assessment of the operability of the DRPI. For example, if a control rod becomes misaligned from its group, the difference between the DRPI for that rod and the demand position indication could be greater than 12 steps while both the DRPI and demand the position indication remain operable. A difference of greater than 12 steps between the indicators does not necessarily mean that the DRPI is inoperable; therefore, this SR is proposed to be deleted. SR 4.1.3.1.1 will continue to verify that the DRPI are within the group's demand limit to confirm proper control rod alignment.

SR 4.1.3.3 demonstrates the DRPls operability by verifying that the DRPI agrees with the demand position indication within 12 steps when the rods are exercised over their full range of travel. This SR replaces the current SR 4.1.3.2 to demonstrate the DRPI operability and is modified by a note that states the SR is not required to be met for rods that do not meet TS 3.1.3.1. If a control rod is misaligned and not within 12 steps of its demand position indication, SR 4.1.3.2 would not be met, and consequently, LCO 3.1.3.2 would not be met. The Actions in TS 3.1.3.2 only address inoperable DRPI and demand position indications, but in this situation, the rod position indicators are operable and accurately reflect the rod position. With no Action in TS 3.1.3.2 for this condition, TS 3.0.3 would require a plant shutdown. The proposed note that modifies SR 4.1.3.2, resolves this conflict. The proposed changes are consistent with TS 3.1.4, "Rod Group Alignment Limits," and TS 3.1.7, "Rod Position Indication," in NUREG-1431.

Similar to the proposed changes, SR 3.1.4.1 in NUREG-1431 verifies that the individual rod positions are within the alignment limits to meet LCO 3.1.4, and SR 3.1.7.1 verifies that the DRPI agrees with the demand position indication over the full range of rod travel to demonstrate the DRPls operability. The addition of the note that modifies SR 4.1.3.2 was a change approved in TSTF-547.

Based on the above considerations and that the analysis performed to calculate the Seabrook numeric values remain based upon NRG-approved methodologies, the NRC staff finds the proposed changes to TS 3.1.3.2, SR 4.1.3.2, and SR 4.1.3.3 provide reasonable assurance of public health and safety, and therefore, are acceptable.

3.6 Position Indication System-Shutdown TS 3.1.3.3, with the exception of SR 4.1.3.3, is proposed to be relocated to the licensee control in the Technical Requirements Manual. The licensee discussed that the DRPI does not meet the criteria in 10 CFR 50.36 for mandatory inclusion in the TS in Mode 3 and below. In response to the industry's proposal on moving TSs which, based on the Commission's Interim Policy Statement on Technical Specification Improvements, published in February 1987, the NRC staff concluded that TS 3.1.3.3, "Position Indication System - Shutdown" may be relocated from TS. However, if the associated SRs are necessary to meet the operability requirements, the SR should be relocated to the retained LCO. Consistent with this NRC staff conclusion, the licensee proposes to relocate SR 4.1.3.3 to TS 3.1.3.2. Further, the licensee noted that NUREG-1431 does not include a TS for the DRPls in Mode 3 and below.

Consistent with the proposed change to remove TS 3.1.3.3 from the TSs, the proposed change also deletes special test exception 3.10.5 associated with TS 3.1.3.3. The licensee proposed that the requirements of TS 3.10.5 be relocated to the Technical Requirements Manual without change, except for the surveillance frequency that refers to the Surveillance Frequency Control Program (SFCP). The SFCP controls the frequencies of the SRs contained in the TS but does not apply to frequencies of activities outside the TSs. Therefore, with the relocation of the SR 4.10.5 from the TSs, the licensee proposed that the reference to the SFCP be replaced by the actual surveillance frequency (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ), as specified in the SFCP.

Based on the above considerations and that the Seabrook licensing analysis is based upon NRG-approved methods, the NRC staff finds the proposed changes to TS 3.1.3.3, special test exception 3.10.5, and the relocation of SR 4.1.3.3 to TS 3.1.3.3 provide reasonable assurance of public health and safety, and therefore, are acceptable.

3. 7 Shutdown Rod Insertion Limit, Control Rod Insertion Limit and Core Operating Limits Report The licensee proposed to add new Actions 3.1.3.5.b and 3.1.3.6.b that apply when one shutdown bank or control bank, respectively, is inserted less than or equal to 10 steps. These proposed changes are consistent with the approved TSTF-547. The number of steps specified in these Actions is a bracketed number in TSTF-547 that is replaced with the plant-specific number of steps that the rods must be moved to satisfy SR 3.1.4.2. Seabrook SR 4.1.3.1.2, which is the equivalent of SR 3.1.4.2 in NUREG-1431, requires movement of the rods by at least 10 steps. The Actions provide 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the control rod bank to within the insertion limits. The LCO in TS 3.1.3.5 is proposed to be revised to require that all shutdown "banks" rather than all shutdown "rods" are fully withdrawn. Consistent with this change to the LCO, SR 4.1.3.5 is revised to require that each shutdown bank shall be determined to be fully withdrawn as specified in the COLR. Action a is revised to address the condition in which one or more shutdown banks are not fully withdrawn. The proposed change is consistent with TS 3.1.3.6, which addresses control rod banks rather than single control rods, and TS 3.1.5, "Shutdown Bank Insertion Limits," in NUREG-1431. The licensee stated that the proposed change is appropriate because TS 3.1.3.1 addresses individual rod positions and deviations.

The proposed change revises the title of TS 3.1.3.5 to make conforming changes to replace

shutdown "rods" with shutdown "banks" as discussed above. This change also proposes to add a new requirement to TS 3.1.3.6 as Action a.1 to verify that the shutdown margin is within limits or initiate boration within one hour. Maintaining the control banks above the rod insertion limits ensures that the shutdown margin is maintained. The new Action to verify adequate shutdown margin or borate if necessary, is appropriate when the insertion limit is not met. This proposed change is consistent with NUREG-1431 and new Action b in TS 3.1.3.6, which is adopted from TSTF-547.

Based on the above considerations, the NRC staff finds that the proposed changes to TS 3.1.3.5 and TS 3.1.3.6, and conforming changes to TS 6.8.1.6.b provide reasonable assurance of public health and safety, and therefore, are acceptable.

3.8 Technical Evaluation Conclusion The changes provided in TSTF-547 address a conflict between SRs in TS 3.1.3.1, "Group Height" and TS 3.1.3.2, "Position Indications Systems-Operating" when using the DRPI. The change also relocates TS 3.1.3.3, "Position Indication System-Shutdown" because it does not meet the criteria for inclusion in the TSs. The proposed amendment clarifies operability requirements for the control rods and eliminates duplicate SRs and simplifies directions to the operators who must implement and ensure adherence to the TSs.

The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The capability of any operable TS required equipment to perform its specified safety function is not impacted by the proposed change. As a result, the outcomes of the accidents previously evaluated are unaffected and GDC 13, GDC 26, and GDC 28 continue to be met.

Based on the above considerations, the NRC staff finds that the proposed changes to the TS in the application provide reasonable assurance of public health and safety, and therefore, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Hampshire State and Commonwealth of Massachusetts officials were notified of the proposed issuance of the amendment on August 9, 2019. The officials 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 and changes SRs.

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 in the Federal Register on April 9, 2019 (84 FR 14151). 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) there is reasonable assurance that 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: C. Jackson Date: November 18, 2019

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 162 RE: REVISIONS TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH MOVABLE CONTROL RODS (EPID L-2018-LLA-0272) DATED NOVEMBER 18, 2019 DISTRIBUTION:

Public RidsNrrLALRonewicz Resource PM File Copy RidsACRS_MailCTR Resource RidsNrrDssStsb Resource RidsNrrDorlLpl1 Resource RidsRgn1 MailCenter Resource RidsNrrDssSrxb Resource RidsNrrPMSeabrook Resource CJackson, NRR ADAMS Access1on No.: ML19224A563 *b>Y memoran dum **b1y e-ma1*1 OFFICE NRR/DORULPL 1:PM NRR/DORULPL 1 :LA NRR/DSS/SRXB:BC* NRR/DSS/STSB:BC**

NAME JPoole CSmith JWhitman VCusumano (MHamm for)

DATE 9/06/2019 8/26/2019 5/22/2019 9/13/2019 OFFICE OGC - NLO w/comments* NRR/DORULPL 1 :BC NRR/DORULPL1:PM NAME AGhosh JDanna JPoole DATE 10/07/2019 11/15/2019 11/18/2019 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2018-LLA-0272, (Approved, Closed)
Initiation Acceptance Supplement Administration Questions Answers Results Approval Other: ML20120A047
MONTHYEAR2019-11-18 [Table View]

ML19224A563

Text

SUBJECT:

Dear Mr. Moul:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

SUBJECT:

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