Text

Issuance of Amendment Nos. 129 and 32 Regarding Changes to Technical Specifications 3.8.1, 3.8.7, 3.8.8, and 3.8.9
	ML19238A005
Person / Time
Site:	Watts Bar
Issue date:	11/26/2019
From:	Kimberly Green; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Saba, Farideh
References
	EPID L-2018-LLA-0492
	Download: ML19238A005 (48)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 26, 2019 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2- ISSUANCE OF AMENDMENT NOS. 129 AND 32 REGARDING CHANGES TO TECHNICAL SPECIFICATIONS 3.8.1, 3.8.7, 3.8.8, AND 3.8.9 (EPID L-2018-LLA-0492)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 129 and 32 to Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (Watts Bar), Unit 1 and Unit 2, respectively. These amendments are in response to your application dated November 26, 2018, as supplemented by letters dated May 13, 2019, and October 9, 2019.

The amendments revise Watts Bar, Units 1 and 2, Technical Specification {TS) 3.8.1, "AC [Alternating Current] Sources - Operating"; TS 3.8.7, "Inverters - Operating"; TS 3.8.8, "Inverters - Shutdown"; and TS 3.8.9, "Distribution Systems - Operating," to support performance of the 6.9 kilovolt and 480 Volt shutdown boards maintenance.

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,

/,,,,,*U E ~~

ft'y" Kimberly J. Green, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-390 and 50-391

Enclosures:

1. Amendment No. 129 to NPF-90

2. Amendment No. 32 to NPF-96

3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-390 WATTS BAR NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 129 License No. NPF-90

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

A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated November 26, 2018, as supplemented by letters dated May 13, 2019, and October 9, 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.

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 Facility Operating License No. NPF-90 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 129 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: November 2 6, 2 O1 9

ATTACHMENT TO AMENDMENT NO. 129 WATTS BAR NUCLEAR PLANT, UNIT 1 FACILITY OPERATING LICENSE NO. NPF-90 DOCKET NO. 50-390 Replace page 3 of Facility Operating License No. NPF-90 with the attached revised page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain vertical lines indicating the area of change.

Remove Pages Insert Pages 3.8-1 3.8-1 3.8-2 3.8-2 3.8-2a 3.8-2a 3.8-2b 3.8-2b 3.8-3 3.8-3 3.8-4 3.8-4 3.8-5 3.8-5 3.8-38 3.8-38 3.8-40 3.8-40 3.8-41 3.8-41 3.8-42 3.8-42 3.8-42a 3.8-42a

(4) TVA, 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, instrument calibration, or other activity associated with radioactive apparatus or components; and (5) TVA, 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.

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

( 1) Maximum Power Level TVA is authorized to operate the facility at reactor core power levels not in excess of 3459 megawatts thermal.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 129 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Safety Parameter Display System (SPDS) (Section 18.2 of SER Supplements 5 and 15)

Prior to startup following the first refueling outage, TVA shall accomplish the necessary activities, provide acceptable responses, and implement all proposed corrective actions related to having the Watts Bar, Unit 1 SPDS operational.

(4) Vehicle Bomb Control Program (Section 13.6.9 of SSER 20)

During the period of the exemption granted in paragraph 2.D.(3) of this license, in implementing the power ascension phase of the approved initial test program, TVA shall not exceed 50% power until the requirements of 10 CFR 73.55(c)(7) and (8) are fully implemented. TVA shall submit a letter under oath or affirmation when the requirements of 73.55(c)(7) and (8) have been fully implemented.

Facility License No. NPF-90 Amendment No. 129

AC Sources-Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Four diesel generators (DGs) capable of supplying the onsite Class 1E AC Electrical Power Distribution System.

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

ACTIONS

NO TES------------------------------------------------------------

1. LCO 3.0.4.b is not applicable to DGs.

2. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating,"

when any Condition(s) is entered with no AC power source to any shutdown board resulting in a de-energized shutdown board.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable for reasons required OPERABLE offsite other than Condition D. circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power available discovery of no inoperable when its redundant offsite power to one required feature(s) is train concurrent with inoperable. inoperability of redundant required feature(s)

(continued)

Watts Bar-Unit 1 3.8-1 Amendment 55, 84, 103, 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore required offsite circuit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to OPERABLE status.

AND I

13 days from discovery of failure to meet LCO B. One DG inoperable. 8.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months required offsite circuits.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND 8.2 Evaluate availability of 6.9 kV 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months FLEX DG.

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND 8.3 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B required redundant feature(s) concurrent with is inoperable. inoperability of redundant required feature(s)

AND (continued)

Watts Bar-Unit 1 3.8-2 Amendment 39, 84, 103, 110, 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.4.1 Determine OPERABLE DGs 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are not inoperable due to common cause failure.

OR B.4.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DGs.

AND B.5 Restore DG to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from status. discovery of unavailability of 6.9 kV FLEX DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition B entry

~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concurrent with unavailability of 6.9 kV FLEX DG 10 days 13 days from discovery of failure to meet LCO (continued)

Watts Bar-Unit 1 3.8-2a Amendment 39, 84, 110, 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two DGs in Train A C.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. required offsite circuits.

AND OR Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Two DGs in Train B thereafter inoperable.

AND C.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DGs inoperable when its Condition C required redundant feature(s) concurrent with is inoperable. inoperability of redundant required feature(s)

AND C.3.1 Determine OPERABLE DGs 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are not inoperable due to common cause failure.

OR C.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DGs.

C.4 Restore DGs to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months status.

6 days from discovery of failure to meet LCO (continued)

Watts Bar-Unit 1 3.8-2b Amendment 30, 39, 84, 103, 110 , 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NO TES-----------------

1. Only applicable during planned maintenance of a Unit 2 AC electrical power distribution subsystem.

2. Only applicable when Unit 2 is defueled.

D. One required offsite circuit D.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable solely due to an required OPERABLE offsite offsite power source to circuit.

6.9 kV Shutdown Board 2A-A or 28-8 inoperable. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter D.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power available discovery of no inoperable when its redundant offsite power to required feature(s) is 6.9 kV Shutdown inoperable. Board 2A-A or 28-8 concurrent with inoperability of redundant required feature(s)

D.3 Restore required offsite circuit 7 days to OPERABLE status.

(continued)

Watts Bar-Unit 1 3.8-3 Amendment 30, 39, 84, 103,110, 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two required offsite circuits E.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable. inoperable when its redundant discovery of required feature(s) is Condition E inoperable. concurrent with inoperability of redundant required features.

AND E.2 Restore one required offsite 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months circuit to OPERABLE status.

F. One required offsite circuit F.1 Restore required offsite circuit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable for reasons to OPERABLE status.

other than Condition D.

OR AND F.2 Restore DG(s) to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One or more DG(s) in status.

Train A inoperable.

OR One or more DG(s) in Train B inoperable.

G. One or more DG(s) in G.1 Restore DG(s) in Train A to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Train A inoperable. OPERABLE status.

AND OR One or more DG(s) in G.2 Restore DG(s) in Train B to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Train B inoperable. OPERABLE status.

(continued)

Watts Bar-Unit 1 3.8-4 Amendment 39, 84, 103, 110, 129

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A, B, C, AND D, E, F, or G not met.

H.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I. Two required offsite circuits 1.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more DG(s) in Train A inoperable.

OR One or more DG(s) in Train B inoperable.

J. One required offsite circuit J.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more DG(s) in Train A inoperable.

AND One or more DG(s) in Train B inoperable.

(continued)

Watts Bar-Unit 1 3.8-5 Amendment 39, 84, 103,110, 129

Inverters-Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and 7 days alignment to required AC vital bus.

Watts Bar-Unit 1 3.8-38 Amendment 129

Inverters-Shutdown 3.8.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, and 7 days alignments to required AC vital bus.

Watts Bar-Unit 1 3.8-40 Amendment 129

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, four channels of vital DC, and four channels of AC vital bus electrical power distribution subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical A.1 Restore Unit 1 AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months power distribution power distribution subsystem subsystems inoperable due to OPERABLE status. AND to one or more Unit 1 AC shutdown boards 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from inoperable. discovery of failure to meet LCO B. One or more AC vital buses B.1 Restore AC vital bus( es) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in one channel inoperable OPERABLE status.

for reasons other than AND Condition C.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

NOTES-------------------

1. Only applicable during planned maintenance of AC vital bus 2-1, 2-11, 2-111, or 2-IV.

2. Only applicable when Unit 2 is in MODE 5, MODE 6, or defueled.

C. AC vital bus 2-1, 2-11, 2-111, C.1 Restore AC vital bus to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or 2-IV inoperable. OPERABLE status.

(continued)

Watts Bar-Unit 1 3.8-41 Amendment 126, 129

Distribution Systems-Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more vital DC D.1 Restore DC electrical power 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power distribution distribution bus to buses inoperable. OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

NOTES-------------------

1. Only applicable during planned maintenance of a Unit 2 AC electrical power distribution subsystem.

2. Only applicable when Unit 2 is defueled.

E. One or more AC electrical E.1 Declare associated required Immediately power distribution feature( s) inoperable.

subsystems inoperable due to one or more Unit 2 AC shutdown boards inoperable.

F. One or more AC electrical F.1 Restore Unit 2 AC electrical 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months power distribution power distribution subsystems inoperable due subsystem( s) to OPERABLE to one or more Unit 2 AC status.

shutdown boards inoperable for reasons other than Condition E.

(continued)

Watts Bar-Unit 1 3.8-42 Amendment 126, 129

Distribution Systems-Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Required Action and G.1 Bein MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND G.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months H. Two trains with one or H.1 Enter LCO 3.0.3. Immediately more inoperable distribution subsystems that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days required AC, vital DC, and AC vital bus electrical power distribution subsystems.

Watts Bar-Unit 1 3.8-42a Amendment 129

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-391 WATTS BAR NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 32 License No. NPF-96

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

A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated November 26, 2018, as supplemented by letters dated May 13, 2019, and October 9, 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;

8. 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.

Enclosure 2

2. Accordingly, Facility Operating License No. NPF-96 is amended as indicated in the attachment to this license amendment, and paragraph 2.C.(2) is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 32 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and Technical Specifications Date of Issuance: November 2 6, 2 O1 9

ATTACHMENT TO AMENDMENT NO. 32 WATTS BAR NUCLEAR PLANT, UNIT 2 FACILITY OPERATING LICENSE NO. NPF-96 DOCKET NO. 50-391 Replace page 3 of Facility Operating License No. NPF-96 with the attached revised page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain vertical lines indicating the area of change.

Remove Pages Insert Pages 3.8-1 3.8-1 3.8-2 3.8-2 3.8-2a 3.8-2a 3.8-2b 3.8-2b 3.8-3 3.8-3 3.8-4 3.8-4 3.8-4a 3.8-4a 3.8-34 3.8-34 3.8-36 3.8-36 3.8-37 3.8-37 3.8-38 3.8-38 3.8-38a 3.8-38a

C. The 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 TVA is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 32 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) TVA shall implement permanent modifications to prevent overtopping of the embankments of the Fort Loudon Dam due to the Probable Maximum Flood by June 30, 2018.

(4) PAD4TCD may be used to establish core operating limits for Cycles 1 and 2 only. PAC4TCD may not be used to establish core operating limits for subsequent reload cycles.

(5) By December 31, 2019, the licensee shall report to the NRC that the actions to resolve the issues identified in Bulletin 2012-01, "Design Vulnerability in Electrical Power System," have been implemented.

(6) The licensee shall maintain in effect the provisions of the physical security plan, security personnel training and qualification plan, and safeguards contingency plan, and all amendments made pursuant to the authority of 10 CFR 50.90 and 50.54(p).

(7) TVA shall fully implement and maintain in effect all provisions of the Commission approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The TVA approved CSP was discussed in NUREG-0847, Supplement 28, as amended by changes approved in License Amendment No. 7.

(8) TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as described in NUREG-0847, Supplement 29, subject to the following provision:

Facility License No. NPF-96 Amendment No. 32

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Four diesel generators (DGs) capable of supplying the onsite Class 1E AC Electrical Power Distribution System.

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

ACTIONS

NOTES-----------------------------------------------------------

1. LCO 3.0.4.b is not applicable to DGs.

2. Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems -

Operating," when any Condition(s) is entered with no AC power source to any shutdown board resulting in a de-energized shutdown board.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite circuit A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable for reasons other required OPERABLE than Condition D. offsite circuit.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter (continued)

Watts Bar - Unit 2 3.8-1 Amendment 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no offsite discovery of no offsite power available power to one train inoperable when its concurrent with redundant required inoperability of feature(s) is inoperable. redundant required feature(s)

AND A.3 Restore required offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status. AND 13 days from discovery of failure to meet LCO B. One DG inoperable. B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months required offsite circuits.

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND 8.2 Evaluate availability of 6.9 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months kV FLEX DG.

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND (continued)

Watts Bar - Unit 2 3.8-2 Amendment 5, 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.3 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s) supported by discovery of Condition the inoperable DG B concurrent with inoperable when its inoperability of required redundant redundant required feature(s) is inoperable. features(s)

AND B.4.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DGs are not inoperable due to common cause failure.

OR B.4.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DGs.

AND 8.5 Restore DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from OPERABLE status. discovery of unavailability of the 6.9 kV FLEX DG AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of Condition B entry ~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months concurrent with unavailability of the 6.9 kV FLEX DG.

AND 10 days 13 days from discovery of failure to meet LCO (continued)

Watts Bar - Unit 2 3.8-2a Amendment 5, 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two DGs in Train A C.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. the required offsite circuits. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Two DGs in Train B thereafter inoperable.

AND C.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s) supported by discovery of the inoperable DGs Condition C inoperable when its concurrent with required redundant inoperability of feature(s) is inoperable redundant required feature(s)

AND C.3.1 Determine OPERABLE 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DGs are not inoperable due to common cause failure.

OR C.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DGs.

AND C.4 Restore DGs to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

AND 6 days from discovery of failure to meet LCO (continued)

Watts Bar - Unit 2 3.8-2b Amendment 5, 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

NOTES-----------------

1. Only applicable during planned maintenance of a Unit 1 AC electrical power distribution subsystem.

2. Only applicable when Unit 1 is defueled.

D. One required offsite circuit D.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable solely due to an required OPERABLE offsite power source to offsite circuit.

6.9 kV Shutdown Board 1A-A or 1B-B inoperable. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND D.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) supported by discovery of no offsite the inoperable DG(s) power to 6.9 kV inoperable when its Shutdown Board required redundant 1A-A or 1B-B feature(s) is inoperable concurrent with inoperability of redundant required feature(s)

AND D.3 Restore required offsite 7 days circuit to OPERABLE status.

(continued)

Watts Bar - Unit 2 3.8-3 Amendment 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two required offsite circuits E.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from inoperable. feature(s) inoperable discovery of when its redundant Condition E required feature(s) is concurrent with inoperable. inoperability of redundant required features AND E.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

F. One required offsite circuit F.1 Restore required offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months inoperable for reasons other circuit to OPERABLE than Condition D. status.

AND OR One or more DG(s) in Train F.2 Restore DG(s) to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A inoperable. OPERABLE status.

OR One or more DG(s) in Train B inoperable.

G. One or more DG(s) in G.1 Restore DG(s) in Train A 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Train A inoperable. to OPERABLE status.

AND OR One or more DG(s) in G.2 Restore DG(s) in Train B 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Train B inoperable. to OPERABLE status.

(continued)

Watts Bar - Unit 2 3.8-4 Amendment 5, 32

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A. B, C, AND D, E, F, or G not met.

H.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I. Two required offsite circuits 1.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more DG(s) in Train A inoperable.

OR One or more DG(s) in Train B inoperable.

J. One required offsite circuit J.1 Enter LCO 3.0.3. Immediately inoperable.

AND One or more DG(s) in Train A inoperable.

AND One or more DG(s) in Train B inoperable.

Watts Bar - Unit 2 3.8-4a Amendment 5, 32

Inverters - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and 7 days alignment to required AC vital bus.

Watts Bar - Unit 2 3.8-34 Amendment 32

Inverters - Shutdown 3.8.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, and 7 days alignments to required AC vital bus.

Watts Bar - Unit 2 3.8-36 Amendment 32

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Train A and Train B AC, four channels of vital DC, and four channels of AC vital bus electrical power distribution subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical A.1 Restore Unit 2 AC 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months power distribution electrical power subsystems inoperable due distribution subsystem to AND to one or more Unit 2 AC OPERABLE status.

shutdown boards 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from inoperable. discovery of failure to meet LCO B. One or more AC vital buses B.1 Restore AC vital bus(es) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in one channel inoperable to OPERABLE status.

for reasons other than AND Condition C ..

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

NOTES-------------------

1. Only applicable during planned maintenance of AC vital bus 1-1, 1-11, 1-111, or 1-IV.

2. Only applicable when Unit 1 is in MODE 5, MODE 6, or defueled.

C. AC vital bus 1-1, 1-11, 1-111, or C.1 Restore AC vital bus to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1-IV inoperable. OPERABLE status.

(continued)

Watts Bar - Unit 2 3.8-37 Amendment 29, 32

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One or more vital DC D.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power distribution power distribution bus to buses inoperable. OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

NOl"ES-----------------

1. Only applicable during planned maintenance of a Unit 1 AC electrical power distribution subsystem.

2. Only applicable when Unit 1 is defueled.

E. One or more AC electrical E.1 Declare associated Immediately power distribution required feature(s) subsystems inoperable due inoperable.

to one or more Unit 1 AC shutdown boards inoperable.

F. One or more AC electrical F.1 Restore Unit 1 AC 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months power distribution electrical power subsystems inoperable due distribution subsystem(s) to one or more Unit 1 AC to OPERABLE status.

shutdown boards inoperable for reasons other than Condition E.

(continued)

Watts Bar - Unit 2 3.8-38 Amendment 32

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND G.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months H. Two trains with one or more H.1 Enter LCO 3.0.3. Immediately inoperable distribution subsystems that result in a loss of safety function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to 7 days required AC, vital DC, and AC vital bus electrical power distribution subsystems.

Watts Bar - Unit 2 3.8-38a Amendment 32

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.129 AND 32 TO FACILITY OPERATING LICENSE NOS. NPF-90 AND NPF-96 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-390 AND 50-391

1.0 INTRODUCTION

By letter dated November 26, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18331A134), as supplemented by letters dated May 13, 2019 (Accession No. ML19134A233), and October 9, 2019 (ADAMS Accession No. ML19283G192),

Tennessee Valley Authority (TVA or the licensee) submitted a license amendment request (LAR) for Watts Bar Nuclear Plant (Watts Bar), Units 1 and 2. The proposed LAR would revise the Watts Bar, Unit 1 and Unit 2, Technical Specification (TS) 3.8.1, "AC [Alternating Current]

Sources - Operating"; TS 3.8.7, "Inverters - Operating"; TS 3.8.8, "Inverters - Shutdown"; and TS 3.8.9, "Distribution Systems - Operating," to support performance of the 6.9 kilovolt (kV) and 480 Volt (V) shutdown boards (SDBDs) maintenance.

The supplements dated May 23, 2019, and October 9, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on June 18, 2019 (84 FR 28348).

2.0 REGULATORY EVALUATION

2.1 Description of Electrical Power Distribution System 6.9 kV and 480 V Electrical Power Distribution System The Watts Bar electrical power distribution system AC sources consist of the offsite power sources (preferred power sources) and the onsite standby power sources. The onsite Class 1E AC electrical power distribution system is divided into two redundant and independent load groups/trains (i.e., A and 8) with two 6.9 kV SDBDs in each load group (i.e., 1A-A and 2A-A in load group A, and 18-8 and 28-8 in load group 8) and the associated 480 V SDBDs. Each 6.9 kV SDBD is connected to one of the preferred offsite power sources or to an onsite power source (a diesel generator (DG)) in case the preferred offsite power source is lost. Two DGs associated with one load group (e.g., 1A-A and 2A-A) can provide all safety-related functions to mitigate a loss-of-coolant accident in one unit and safely shut down the other unit.

Enclosure 3

Offsite power is supplied to the Watts Bar 161 kV transformer yard by two dedicated lines from the Watts Bar hydro plant switchyard. From the 161 kV transformer yard, two electrically and physically separated circuits provide AC power through stepdown common station service transformers C and D to the 6.9 kV Train A and Train B SDBDs, respectively.

The onsite standby power source DGs 1A-A, 1B-B, 2A-A, and 2B-B are separate and independent, and are dedicated to 6.9 kV SDBDs 1A-A, 1B-B, 2A-A, and 2B-B, respectively.

Each DG set consists of two diesel engines in tandem driving a common generator. A DG starts automatically on a safety injection (SI) signal (e.g., low pressurizer pressure, high containment pressure, or low steam line pressure signals), a 6.9 kV SDBD degraded voltage, or a loss-of-voltage signal. After a DG is started, it can automatically tie to its respective 6.9 kV SDBD after offsite power is tripped as a consequence of a 6.9 kV SDBD degraded voltage or loss-of-voltage signal, independent of or coincident with an SI signal.

The core cooling systems and containment systems (e.g., SI, auxiliary feedwater, residual heat removal, centrifugal charging, containment spray, and air return system) are unitized (i.e., not shared among the units). However, some safety-related systems (e.g., essential raw cooling water, component cooling water system, emergency gas treatment, auxiliary building gas treatment, control room emergency ventilation, and control room air conditioning) are shared by the two units. The AC sources for these shared loads are distributed across all four 6.9 kV SDBDs and associated downstream 480 V SDBDs in such a way that each Train A or Train B engineered safety features system can provide for the minimum safety functions necessary to shut down the plant and maintain it in a safe shutdown condition.

120 Volts Alternating Current (VAC) Vital Power System The 120 VAC vital power system is a Class 1E system that provides a reliable source of instrument and control power for reactor protection circuits and other critical instrumentation systems and components within the plant.

The system for each unit consists of four uninterruptible power supplies (UPS) with distribution boards and associated cabling, instrumentation, and protective devices. Each unit has four identical power channels (designated as Channels I, II, Ill, and IV), with the equipment of each channel being electrically and physically independent from the equipment of other channels so that a failure in one channel will not cause a failure in another channel. Each channel consists of a unit UPS, a spare UPS, and a distribution board that facilitates load grouping and provides circuit protection.

According to the Final Safety Analysis Report (FSAR), Chapter 8, the UPS units are sized and coordinated to maintain the required inverter output for the worst maximum or minimum operable input conditions. The normal AC input power is derived from one of 480 V shutdown distribution boards. The DC alternate input power source is derived directly from the DC distribution board. This input is biased against the normal rectified AC input by means of an

'auctioneered' diode circuit to permit use of the battery source only in the event the AC input voltage is lost.

2.2 Proposed TS Changes The operability requirements for the 6.9 kV and 480 V SDBDs are defined in Watts Bar, Units 1 and 2, TS LCO (Limiting Condition for Operation) 3.8.9 for Modes 1, 2, 3, and 4, and TS

LCO 3.8.10 for. Modes 5 and 6. LCO 3.8.9 requires four 6.9 kV SDBDs and eight 480 V SDBDs whenever a unit is in Mode 1, 2, 3, or 4. LCO 3.8.10 requires two 6.9 kV SDBDs (either 6.9 kV SDBDs 1A-A and 2A-A or 1B-B and 2B-B) and the four associated 480 V SDBDs to be operable whenever a unit is in Mode 5 or 6. Currently, if a 6.9 kV or 480 V SDBD is inoperable or deenergized while either unit is in Mode 1, 2, 3, or 4, LCO 3.8.9, Condition A, requires that the inoperable SDBD be restored to an operable status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or actions taken to place the unit in a mode to which the LCO does not apply.

In the LAR, the license stated that preventive maintenance (PM) to clean and inspect the 6.9 kV and 480 V SDBDs is required every 15 years to ensure the reliability of the standby AC power system. The PM activities associated with the switchgear include:

Insulation resistance testing (megger)

Inspection and micro-ohm resistance measurements

Inspecting, cleaning, and lubricating primary stabs

Cleaning rear compartments by vacuuming and wiping buses and insulators with alcohol and rags

Pulling rear panels of potential transformer cabinets, inspecting components, and lubricating bus connections, and

Performing additional work orders to address equipment issues (e.g., cell switch replacements, fuse block replacements) as allowed within the completion times The licensee stated that during PM, SDBDs are expected to be inoperable for a duration of 7 days, consisting of the following time estimates based on past performance of the maintenance, with additional time allowed for unforeseen circumstances.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for clearance placement and removal

Nine hours for ground placement and removal

42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months for inspections of compartments (21 compartments) o E-16 light resistor replacements o pull-out fuse block tension o relay and instrument o potential transformer drawer operation

34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months for circuit breaker interface inspections and adjustments

( 17 breakers) o primary/secondary disconnects o shutters o breaker position and interface measurements and adjustments

Eight hours for bus inspection and tests o as-found and as-left megger o DLRO [Digital Low Resistance Ohmmeter]

o torque checks The current TSs for an operating unit do not provide sufficient time to perform the 15-year PM on the 6.9 kV and 480 V SDBDs. The current TSs require a dual outage to perform this maintenance.

The licensee stated that an extension of the LCO action completion times to 7 days for the affected systems would permit performance of the PM while one unit is in Mode 1, 2, 3, or 4, and the other unit is defueled. The PM will normally be performed over several refueling outages with one set of 6.9 kV and 480 V SDBDs being cleaned and inspected during a

refueling outage. The main changes relate to TS 3.8.1, LCO Condition A, and TS 3.8.9, LCO Conditions A, F, and G. The changes would allow the licensee to perform PM on one set of 6.9 kV and 480 V SDBDs, with one unit in Mode 1, 2, 3, or 4, and while the other unit is defueled. The licensee also proposed minor changes to TS Surveillance Requirements (SRs) 3.8.7.1 and 3.8.8.1.

2.3 Regulatory Requirements The NRC staff ("the staff') applied the following NRC regulations for review of this LAR.

Title 10 of the Code of Federal Regulations (CFR) 50.36, "Technical specifications," establishes the requirements related to the content of the TSs. Pursuant to 10 CFR 50.36(c), TSs are required to include items in five specific categories related to station operation: ( 1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. The proposed changes in this LAR relate to the LCO and SR categories.

The regulations in 10 CFR 50.65(a)(4), "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," state:

Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance}, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

In FSAR Section 3.1.1, the licensee stated that Watts Bar was designed to meet the intent of "Proposed General Design Criteria for Nuclear Power Plant Construction Permits" published in July 1967. In FSAR Section 3.1.2, the licensee addressed the General Design Criteria (GDC) published as Appendix A to 10 CFR Part 50 in July 1971. Each criterion is followed by a discussion of the design features and procedures which meet the intent of the criteria.

The NRC staff identified the following GDC applicable for the review of this LAR.

Criterion 5, "Sharing of structures, systems, and components," states, "Structures, systems, and components important to safety shall not be shared between nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units."

Regarding compliance with Criterion 5, in Section 3.1.2 of the FSAR, the licensee stated:,

The structures important to safety that are shared are the Auxiliary Building, Control Building, Diesel Generator Building, and the intake pumping station.

Shared safety-related systems include the essential raw cooling water, component cooling water, fire protection, spent fuel cooling, fuel oil storage tanks, preferred and emergency electric power, chemical and volume control, radioactive waste, emergency gas treatment system, auxiliary control air system, and control and Auxiliary Building ventilation systems. The vital DC power

system is shared to the extent that a few loads (e.g., the vital inverters) in one nuclear unit are energized by the DC power channels assigned primarily to power loads of the other unit. In no case does the sharing inhibit the safe shutdown of one unit while the other unit is experiencing an accident. All shared systems are sized for all credible initial combinations of normal and accident states for the two units, with appropriate isolation to prevent an accident condition in one unit from carrying into the other.

Criterion 17, "Electric power systems," states, in part, that:

An onsite electric power system and an offsite electric power system shall be provided to permit the functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that ( 1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power sources, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Regarding compliance with Criterion 17, in Section 3.1.2 of the FSAR, the licensee stated:

The capacity and capability of either the onsite or offsite electric power system is sufficient to assure that (1) specified fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The offsite electrical power source consists of two physically independent circuits which are energized and available. The offsite sources are two independent 161-kV transmission lines terminating at the 161-kV switchyard, providing power to the plant, on demand, via the common station service transformers to the onsite Class 1E distribution system.

The onsite electrical power system serves both nuclear power units and certain common plant equipment. It consists of two independent diesel generator systems, each system containing two diesel generator units, two redundant Class 1E electric power distribution trains, and four redundant vital instrument and control power channels, each provided with an uninterruptible AC power supply and distribution panel. A plant Class 1E DC power system is provided with four redundant divisions, each consisting of a battery, battery charger, and distribution panel. Each redundant onsite power supply, train, and channel has the capability and capacity to supply the required safety loads assuming the failure of its redundant counterpart.

The NRC staff alsp applied the following regulatory guidance for review of the LAR.

Regulatory Guide (RG) 1.177, Revision 1, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," dated May 2011 (ADAMS Accession No. ML100910008). Although the LAR is not specifically based on probability risk evaluation, the NRC staff applied certain guidelines and principles such as defense-in-depth measures described in RG 1.177 to evaluate this LAR.

NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," Revision 4.0, Volume 1, dated April 2012 (ADAMS Accession No. ML12100A222). This NUREG contains the Improved Standard Technical Specifications (STS) for Westinghouse plants. The changes reflected in Revision 4 result from the experience gained from the various plant operations using the ISTS and extensive public technical meetings and discussions among the NRC staff and various nuclear power plant licensees and the Nuclear Steam Supply System Owners Groups.

The ISTS were developed based on the criteria in the Final Commission Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132), which was subsequently codified by changes to 10 CFR 50.36.

Generic Letter (GL) 80-30, "Clarification of the Term 'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by Technical Specifications." This GL provides for a temporary relaxation to a plant to depart from the single-failure design criterion when the plant is operating within a TS action requirement.

3.0 TECHNICAL EVALUATION

The licensee proposed TS changes for both Watts Bar, Units 1 and 2. The following changes are discussed with respect to Unit 1. The changes with respect to Unit 2 are similar, and the same evaluations apply to Unit 2 TS changes.

3.1 Changes to TS 3.8.1 The proposed changes to TS 3.8.1 and the evaluations are as follows:

Addition of Condition D, Applicable Notes, Required Action, and Completion Time

NOTl=S--------------------------------------------------------

1. Only applicable during planned maintenance of a Unit 2 AC electrical power distribution subsystem.

2. Only applicable when Unit 2 is defueled.

Condition D: One required offsite circuit inoperable solely due to an offsite power source to 6.9 kV Shutdown Board 2A-A or 2B-B inoperable.

Required Action and Completion Time:

D.1 Perform SR 3.8.1.1 for required OPERABLE offsite circuit.

Completion Time: 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter

D.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

Completion Time: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to 6.9 kV Shutdown Board 2A-A or 2B-B concurrent with inoperability of redundant required feature(s).

D.3 Restore required offsite circuit to OPERABLE status.

Completion Time: ?days Evaluation of Addition of Condition D, Required Action, and Completion Time The proposed Condition D is similar to TS 3.8.1, Condition A. However, Condition D will be applicable only when Watts Bar, Unit 2, is defueled, and the offsite circuit belongs to Unit 2 SDBDs. The completion time is 7 days instead of 3 days. In order to do maintenance on SDBD 2A-A or 2B-B (when Unit 2 is defueled), the licensee will have to lock out the corresponding emergency DG and also enter Condition B of TS 3.8.1, "One DG inoperable."

This condition will result in one of the Unit 2 SDBDs inoperable. Therefore, the licensee will also have to enter TS 3.8.9, new Condition F, "One or more AC electrical power distribution subsystems inoperable due to one or more Unit 2 AC shutdown boards inoperable for reasons other than Condition E." TS 3.8.9, new Condition F is described and evaluated separately below. The justifications for the "additional TS 3.8.1 Condition D" and "additional TS 3.8.9 Condition F" are the same and are discussed under TS 3.8.9, new Condition F.

Other TS 3.8.1 Changes.

Other proposed changes to TS 3.8.1 are due to the consequences of adding Condition D.

These changes (indicated in bold text) are discussed as follows:

a) Condition A will be revised as: One required offsite circuit inoperable for reasons other than Condition D. The staff finds this change to be editorial, and therefore, acceptable.

b) Current Condition D and associated required actions will be renumbered as E. The staff finds this change to be editorial, and therefore, acceptable.

c) Current Condition E and associated required actions will be renumbered as F. The staff finds this change to be editorial, and therefore, acceptable.

d) The NOTE associated with required actions of current Condition E: "Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating,"

when Condition E is entered with the no AC power source to any train," is proposed to be deleted from the current location and moved to location under generic notes of LCO 3.8.1 (generic notes that would be applicable, depending upon an operating scenario) as Note 2. Note 2 would read as: "Enter applicable Conditions and Required Actions of LCO 3.8.9, 'Distribution Systems - Operating,' when any Condition(s) is entered with the no AC power source to any shutdown board resulting in a de-energized shutdown board." The staff finds this revised wording and changed location of the note appropriate, and therefore, acceptable.

e) Current Conditions F, G, H, and I and associated required actions will be renumbered as G, H, I, and J respectively. The staff finds this change to be editorial, and therefore, acceptable.

3.2 TSs 3.8. 7 3.8.8, SR Changes Currently SRs 3.8. 7.1 and 3.8.8.1 state as follows: "Verify correct inverter voltage, frequency, and alignment to required AC vital bus and from associated vital battery board and 480 V shutdown board."

The licensee has proposed to revise SRs 3.8.7.1 and 3.8.8.1 as follows: "Verify correct inverter voltage, frequency, and alignment to required AC vital bus."

The licensee has proposed to remove from the SR details as to how the vital inverters are aligned to input sources. The licensee stated that the proposed change to remove the details that the vital inverter is aligned to its associated vital battery and 480 V SDBD is acceptable because the vital batteries provide the uninterruptible power source to the safety-related 120 V AC loads. During an emergency in which all 480 VAC power is lost to the UPS, the auctioneering circuit automatically switches to the battery board input. Removing the requirement for the vital inverters to align to their associated 480 V power supplies is consistent with the design basis of the plant. The licensee also stated that the changes are in accordance with NUREG-1431.

Evaluation of TSs 3.8. 7 and 3.8.8 SR Changes The main requirement of this SR is to verify that an inverter has correct output voltage and frequency and is correctly aligned to a vital 120 VAC bus. The normal and alternate alignment of input sources is described in the TS Bases and FSAR. The description of alignment of input sources to an inverter is not considered essential. The NRC staff finds the changes are consistent with NUREG-1431, and therefore, acceptable.

3.3. TS 3.8.9 Changes The licensee proposed the following changes to TS 3.8.9 to distinguish between the Units 1 and 2 electrical distribution systems. The proposed changes to TS 3.8.9 and the NRC staff evaluations are as follows.

Change to Condition A The changes are indicated in bold text.

Condition: A One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable.

Required Action and Completion Time:

A.1 Restore Unit 1 AC electrical power distribution subsystem to OPERABLE status. Completion Time: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO

Evaluation of Change to Condition A The proposed change to Condition A states that the condition is applicable for Unit 1 when the Unit 1 SDBDs are inoperable. Two separate Conditions F and G will be added when the inoperable subsystems belong to Unit 2. These are discussed separately below. Since there will be no change in the completion time for Condition A, this change is considered to be editorial for Unit 1, and therefore, acceptable.

Addition of Condition E, Applicable Notes, Required Action, and Completion Time

N()TES--------------------------------------------------

1. Only applicable during planned maintenance of a Unit 2 AC electrical power distribution subsystem.

2. Only applicable when Unit 2 is defueled.

Condition: E One or more AC electrical power distribution subsystems required inoperable due to one or more Unit 2 AC shutdown boards inoperable.

Required Action and Completion Time:

E.1 Declare associated required feature(s) inoperable.

Completion Time: Immediately Evaluation of Addition of Condition E, Required Action/Completion Time In Enclosure 1 of the LAR, the licensee provided Tables 3 and 4, which list major loads that will be impacted if a 6.9 kV Unit 2 SDBD 2A-A or 28-B is deenergized during maintenance. If any Unit 2 AC SDBD becomes deenergized/inoperable, the associated required downstream fed subsystems will be declared inoperable immediately and will be governed by their own TS LCOs. Based on the completion time listed in Tables 3 and 4, maximum completion time for the shared systems will be limited to 7 days. The completion time for Unit 2 SDBD 2A-A or 28-B will be limited to the minimum completion time of required downstream fed subsystems (maximum 7 days). Therefore, the following justifications are applicable for a completion time of maximum 7 days for new TS 3.8.9, Condition E, and for the new TS 3.8.1, Condition D, with completion time of 7 days, which will also be entered simultaneously.

1. Deenergization/inoperability of Unit 2 SDBD 2A-A or 28-B will only impact one train of shared systems. Therefore, the other train of shared systems will still be available to meet any accident during the applicable Completion Time. As stated in GL 80-30, temporarily departing from the single-failure design criterion when the plant is operating within a TS action requirement is acceptable.

2. In the letter dated May 13, 2019, the licensee described (in response to EEOB RAl-1) that a graded defense in depth will be maintained as follows:

With equipment or components out of service, TVA employs a graded approach to defense-in-depth (DID) and protected equipment strategies

based on the operating status of the affected unit and a unit in an outage.

Because the alternating current (AC) electrical distribution system is a system shared between Watts Bar, Units 1 and 2, the DID strategies address both the outage unit and the operating unit.

For the outage unit, TVA procedure NPG-SPP-09.11.3, "Shutdown Equipment Out of Service Management," provides guidance for using a Shutdown Equipment Out of Service (EOOS) software and site-specific EOOS models to assess risk of maintenance activities, as defined by 10 CFR 50.65(a)(4), "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." The Shutdown EOOS computer program takes the status (i.e., available, unavailal;>le, protected) of key plant equipment and produces an output of the relative level of safety/defense in depth of key shutdown areas (i.e., reactivity control, shutdown cooling, AC power (onsite, offsite), fuel pool cooling, inventory control, support equipment).

For the operating unit, TVA procedure NPG-SPP-09.11.1 is used to assess risk of maintenance activities as defined by 10 CFR 50.65(a)(4).

Quantitative risk information provided by the at-power EOOS model is considered as one input to a blended approach to risk management that includes deterministic information, operating experience, engineering judgment, and management standards. For those activities requiring risk management due to elevated risk levels, the following actions are considered to provide additional risk awareness and control, reduce activity duration, and reduce magnitude of risk increase.

Discussion of the activity with the operating shift and operator approval in advance of the planned evolution.

Pre-job briefing of maintenance personnel in advance of the evolution emphasizing the risk aspects of the evolution.

Presence of appropriate engineering or technical personnel for appropriate portions of the activity. Pre:..staging of parts and materials.

Crew walk down of the tag out boundary and activity prior to conducting maintenance.

Consider the use of appropriate Human Performance (HP) tools to reduce the potential for human performance problems.

Operations personnel walk down of the redundant and opposite trained/division designated equipment to ensure availability to mitigate challenges.

Conduct of training and mock ups to familiarize personnel with the activity.

Consider activity performance around the clock, or on back shifts.

Establish contingency plans to specifically restore from the out of service condition rapidly, if needed, to make equipment available.

Minimize other work in areas that could affect event initiators (for example reactor protection system areas, switchyard, diesel generator rooms, switchgear rooms) to decrease the frequency of initiating events that are mitigated by the safety function served by the out of service SSCs [structures, systems, and components].

Minimize work in areas that could affect other redundant systems such that there is enhanced likelihood of the availability of the safety functions at issue served by the SSCs in those areas.

Establishment of alternate success paths for performance of the safety functions of the out of service SSC.

3. In the letter dated May 13, 2019, the licensee also stated that compensatory measures required for extending the completion time for an inoperable DG beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months will also be applicable for planned maintenance on a 6.9 kV SDBD as described below.

When a 6.9 kV shutdown board is being de-energized for planned maintenance and the notes associated with TS 3.8.1, Condition D, are met, the breakers from the normal and alternate offsite circuits, as well as from the maintenance feeder are opened. Additionally, the emergency DG output breaker to the 6.9 kV shutdown board is opened to preclude the DG from loading onto the de-energized 6.9 kV shutdown board. Upon opening these breakers, the offsite circuit and DG are declared inoperable and TS 3.8.1, Conditions B and D are entered. It is important to note that the planned maintenance on the 6.9 kV and 480 V shutdown boards cannot be performed unless the boards are de-energized.

Therefore, any time that Condition Dis entered, Condition B will also be entered.

Per TS 3.8.1, Condition B, the Completion Time for the inoperable DG is limited to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months unless a 6.9 kV FLEX DG is available as an alternate power source. Because the shutdown board maintenance is anticipated to require more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to complete, a 6.9 kV FLEX DG will be required to be available as an alternate power source prior to performing the planned maintenance on the shutdown boards. In addition, per TS 3.8.1, Condition B, Bases, compliance with the contingency actions listed in Bases Table 3.8.1-2 is required whenever Condition Bis entered for a planned or unplanned outage that will extend beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The contingencies listed in TS Bases Table 3.8.1-2 and TVA procedure O-Tl-12.16, "Diesel Generator Outage TIS or SR Contingency Actions,"

include:

verifying that the offsite power system is stable

verifying that no adverse weather conditions are expected during the outage period

ensuring adequate ventilation for the 6.9 kV shutdown board rooms, elevation 772 transformer rooms, and 480 V shutdown board rooms

precluding the removal from service of the reactor trip breakers

precluding the removal from service of the turbine-driven auxiliary feedwater (AFW) pump

precluding the removal from service of the AFW level control valves

precluding the removal from service of the opposite train residual heat removal pump Based on the above justifications and defense-in-depth measures to comply with 10 CFR 50.65(a)(4) beyond 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the NRC staff finds that during performance of maintenance on a 6.9 kV SDBD and associated 480 V SDBDs, Unit 1 will be operated safely (while Unit 2 is defueled). The above measures also meet the intent of defense in depth described in RG 1.177.

Therefore, the NRC staff finds the completion time of maximum 7 days (equivalent to worst case completion time for downstream fed subsystems) for the new Condition E in TS 3.8.9 and the completion time of 7 days for the new Condition D in TS 3.8.1, which will be entered the same time as Condition E, reasonable and acceptable.

Addition of Condition F, Required Action/Completion Time Condition F: One or more AC electrical power distribution subsystems inoperable due to one or more Unit 2 AC shutdown boards inoperable for reasons other than Condition F.

Required Action and Completion Time:

F.1 Restore Unit 2 AC electrical power distribution subsystem(s) to OPERABLE status.

Completion Time: 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Evaluation of Addition of Condition F, Required Action. and Completion Time Condition F applies for a condition other than Condition E, and when the distribution boards belonging to Unit 2 (opposite unit) become inoperable, Unit 1 is in TS Mode 1, 2, 3, or 4, and Unit 2 is in TS Mode 5 or 6. This condition is somewhat similar to Condition F except that, in this case, a shorter completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will be allowed compared to the maximum 7 days completion time for Condition E.

Completion time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition F is reasonable since the inoperable distribution boards belong to the opposite unit that will be in Modes 5 and 6. Only a few loads belonging to Watts Bar, Unit 2, will be operable. One complete train of shared systems will remain available to meet any accident in the operating Unit 1 and the reduced load requirements of the shutdown Unit 2.

In the letter dated May 13, 2019, the licensee stated that for planned maintenance on the opposite unit AC electrical power distribution subsystem, the requirements for protected equipment described in its response to EEOB RAl-1 will be applied (as discussed above applicable to Condition E), including the restrictions on working on or near protected equipment.

Any planned entry into TS 3.8.9, Condition F, will be precluded if any redundant equipment is inoperable.

Considering that the licensee will be applying defense-in-depth protective measures similar to those described for TS 3.8.9, Condition E, the NRC staff finds the completion time of maximum 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the new TS 3.8.9, Condition F, reasonable and acceptable.

Other TS 3.8.9 Changes Other proposed changes to TS 3.8.9 are due to the consequences of addition of Conditions E and F. Current Conditions E and F and associated Required Actions will be renumbered as G and H, respectively. The NRC staff finds these changes to be editorial, and therefore, acceptable.

3.4 Risk Insights The NRC staff performed an independent assessment using the NRC's Watts Bar standardized plant analysis risk model to evaluate the risk contribution from internal events. The model represented Unit 1 online and Unit 2 offline, with a 6.9 kV SDBD belonging to Unit 2 not available for up to 7 days. The NRC standardized plant analysis risk model insights and results support the engineering conclusions associated with the proposed change and appropriateness of the licensee's proposed compensatory actions. The currently available risk insights and results did not challenge the engineering conclusions that the proposed change maintains defense in depth.

3.5 Technical Conclusion Based on the technical evaluation described in Sections 3.1, 3.2, and 3.3 above, the NRC staff finds the proposed changes to TSs 3.8.1, 3.8.7, 3.8.8, and 3.8.9 acceptable. The staff also concludes that the proposed TS changes are in accordance with 10 CFR 50.36(c) and do not impact the licensee's current compliance with GDC 5 and 17. Therefore, the staff finds the proposed TS changes in the LAR acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments on October 24, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change SRs. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on June 18, 2019 (84 FR 28348). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c )(9). Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: V. Goel C. Spore Date: November 26, 2019

J. Barstow

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2- ISSUANCE OF AMENDMENT NOS. 129 AND 32 REGARDING CHANGES TO TECHNICAL SPECIFICATIONS 3.8.1, 3.8.7, 3.8.8, AND 3.8.9 (EPID L-2018-LLA-0492)

DATED NOVEMBER 26, 2019 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrLALRonewicz Resource RidsNrrDorlLpl2-2 Resource RidsNrrPMWattsBar Resource RidsNrrDeEeob Resource RidsNrrDssScpb Resource RidsNrrDssStsb Resource RidsNrrDraApob Resource VGoel, NRR CSpore NRR LWheeler, NRR PSnyder, NRR ADAMS Access1on No.: ML19238A005 *b,v memo **b,y e-ma1*1 OFFICE DORL/LPL2/PM DORL/LPL2/LA DE/EEOB/BC(A)* DRA/DRA/APOB/BC** DSS/SCPB/BC**

w/comments NAME FSaba LRonewicz DWilliams AZoulis BWittick DATE 10/11/2019 10/11/2019 06/18/2019 10/24/2019 10/29/2019 OFFICE DSS/STSB/BC* OGC-NLO** DORL/LPL2/BC DORL/LPL2/PM W/comments w/comments E VCusumano KGamin UShoop KGreen (FSaba for)

DATE 11/01/2019 10/28/2019 11/26/2019 11/26/2019 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2018-LLA-0492, TSTF-500, TSTF-360 (Approved, Closed)
Initiation Request, Request Acceptance... Supplement Administration Questions 15 April 2019 Answers Results Approval Other: ML19338B776
MONTHYEAR2019-10-09 [Table View]

ML19238A005

Text

SUBJECT:

Dear Mr. Barstow:

Enclosures:

Attachment:

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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