Text

Response to Request for Additional Information, License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements
	ML19308A595
Person / Time
Site:	Salem, Hope Creek
Issue date:	11/04/2019
From:	Mannai D; Public Service Enterprise Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EPID L-2019-LLA-0145, LAR H19-05, LAR S19-05, LR 19-0099
	Download: ML19308A595 (24)
	v • d • e

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 PSEG Nudtnr IJ NO\/ 0 4 2019 10 CFR 50.90 L R19-0099 LAR H19-05 LAR S19-05 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Subject Response to Request for Additional Information, Re: License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

References:

1. PSEG letter to NRC, "License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements," dated July 8, 2019 (ADAMS Accession No. ML19189A316)

2. NRC email to PSEG, "Hope Creek, Salem 1 and 2 - Final RAI RE:

Emergency Plan Staffing Requirements (L-2019-LLA-0145)," dated October 3, 2019 (ADAMS Accession No. ML19280AOOO)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Hope Creek and Salem Generating Stations. The proposed amendment would revise certain Emergency Response Organization (ERO) positions for the facilities listed consistent with the minimum staff ERO guidance specified in the "Alternative Guidance for Licensee Emergency Response Organizations," finalized in a letter from the NRC to the Nuclear Energy Institute (NEI), June 12, 2018. In Reference 2, the Nuclear Regulatory Commission (NRC) provided PSEG with a request for additional information (RAI) required for the staff to complete its review. to this letter provides a restatement of the RAI questions followed by PSEG's responses. Enclosure 1 provides the existing Emergency Plan marked up pages. Enclosure 2 provides clean copies of the proposed changes. Enclosures 1 and 2 replace Enclosures 1 and 2 from Attachment 1 of Reference 1.

PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for

4 2019 LR-N19-0099 concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this letter.

In accordance with 10 CFR 50. 91, "Notice for public comment; State consultation," paragraph (b), PSEG is providing a copy of this response, with attachments, to the designated State of New Jersey Official.

Should you have any questions regarding this submittal, please contact Mr. Lee Marabella at 856-339-1208.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

' '{Date)

David J. Mannai Senior Director, Regulatory Operations & Nuclear Oversight Attachments:

1. Response to Request for Additional Information

Enclosures:

1. Emergency Plan Marked-Up Pages

2. Emergency Plan Clean Copy Pages cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Site Regulatory Compliance Commitment Tracking Coordinator

LR-N19-0099 Attachment 1 Response to Request for Additional Information

LR-N19-0099 By letter dated July 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19189A316), PSEG Nuclear LLC submitted proposed changes to the Radiological Emergency Preparedness Plan for Hope Creek Generating Station (Hope Creek) and Salem Generating Station (Salem) Unit Nos. 1 and 2 pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The staff has reviewed the licensee's submittal and determined that additional information is required to enable the staff to make an independent assessment regarding its technical review.

RAI-PSEG-1 Currently, for the major functional area of Radiological Accident Assessment and Support of Operation Accident Assessment, both Hope Creek and Salem possess a Chemistry Technician to perform Chemistry/Radio-Chemistry. PSEG has proposed to remove these two on-shift positions currently filled by a Chemistry Technician at each station from this major functional area.

Section 3.1, "Functional Analysis," of Attachment 1, "Evaluation of Proposed Changes" (page 3),

states, in part:

... the unaffected station Chemistry Technician "should" support the affected station Chemistry Technician and if needed, support Radiation Protection with onsite/offsite monitoring (driver) ... The proposed Emergency Plan revision will clarify this support duty for the unaffected station Radiation Protection Technicians. As a result of the above, there is no longer a need for the on-shift Chemistry Technician role in the Emergency Plan.

Section 3.1 further states, "A review of the on-shift staffing analysis under 10 CFR 50, Appendix E, Section IV.A.9 was performed to ensure that the Chemistry major task is not required per the Salem or Hope Creek procedures prior to augmentation." However, analysis is limited to the Chemistry Technician with no evaluation of the impact on the Radiation Protection (RP) major functional area by the addition of the driver function to the unaffected station's RP Technicians.

a) Please provide an analysis for the impact to the RP major functional area for this additional duty to the on-shift RP staffing. Assuming that the Shift RP Technician is performing dose assessment and the on-site (near site) survey team is dispatched to perform surveys, this analysis should describe the ability of the remaining on-shift RP Technician to perform in-plant surveys, access control, personnel monitoring, dosimetry, and RP coverage for repair and corrective actions, search and rescue, first aid, and firefighting during emergency response operations as identified in the Radiological Emergency Preparedness Plan.

b) Clarify whether an analysis was performed on the current on-shift staffing to identify any other potential drivers for the onsite/offsite monitoring team to minimize the impact to the RP major functional area (e.g., unaffected station's maintenance personnel).

PSEG Nuclear LLC (PSEG) Response a) PSEG has identified an alternative ERO position from the unaffected station to provide support as the driver for the affected station's onsite/offsite monitoring team. Therefore, 2

LR-N19-0099 the duties currently listed for the RP Technicians in the Emergency Plan (positions E.3 and E.4) will not be changed as part of this license amendment request.

PSEG proposes to assign the duty of supporting the affected station's RP with onsite/offsite monitoring (driver), if needed, to the OSC Radwaste Operator (position C.5.A) at the unaffected station. In the current Emergency Plan, the OSC Radwaste Operator at the unaffected station does not have any duty expectation to support the affected station as needed, as there is no Note 5 applied to position C5A in Table 3.2 of the Emergency Plan (PSEG Nuclear Correlation to Supplement 1 of N UREG-0737 Table 2 (NUREG-0654, Table B-1)). The role of driver for the affected station's onsite/offsite monitoring team does not require any specific training or skills and is within the capabilities of the OSC Radwaste Operator. Enclosures 1 and 2 to this Attachment contain the affected Emergency Plan marked-up and clean copy pages, respectively.

These Enclosures are a complete replacement for Enclosures 1 and 2 of Attachment 1 to the original submittal letter, dated July 8, 2019 (ADAMS Accession No. ML19189A316). To reflect the change described above, Section 2.1 from the original submittal is also revised as follows:

2.1 Proposed Changes Enclosures 1 and 2 provide marked-up and clean copy pages of Emergency Plan Section 3.

Brief descriptions of the proposed changes are provided below. The justifications for the Functional Area changes are discussed in Section 2.2.

Paragraph 2.7 of Section 3, Radiation Protection/Chemistry Organization- Modified reference to the Chemistry organization and Chemistry Technician.

Paragraph 9.3 of Section 3. Corrective Action and Support of Operations o Added duty description 4 under C.5.A. OSC Radwaste Operator - "The Radwaste Operator CC.5.A) at the unaffected station should support the affected station's RP with onsite/offsite monitoring (driver). if needed."

Paragraph 9.5 of Section 3, Radiation Protection Onsite o Deleted duty description 5 under E.6 Chemistry Technician (CT) -

"CT at the unaffected station should support the affected stations CT and if needed, support RP with onsite/offsite monitoring (driver)"

a Modified duty desoription 14 under E.3, Radiation Proteotion Teohnioians (RPT),

to add ... '\vith onsite/offsite monitoring (driver)"

o Modified duty desoription 14 under E.3/E.4, Shift Radiation Proteotion Teohnioians E4 (SRPT)/Onsite Radiation Proteotion Teohnioian E.a (ORPT),-to add ... "with onsite/offsite monitoring (driver)"

Table 3-2, PSEG Nuclear Correlation To Supplement 1 of NUREG-0737, Supplement 1, Table 2 (NUREG-0654, TABLE B-1) o Removed twe one on-shift positions filled by 2 Chemistry Technicians from the affected plant and replaced 1 Chemistry Technician CE6) with a Radwaste Operator CC5 A) from the unaffected station. from the Radiological Accident Assessment and Support of Operational Accident Assessment major functional area and thus reduced the total staffing number by 1-

Figure 3-1, On-Shift Staffing Emergency Response Organization- Removed 2 Chemistry Technician positions and associated reference in Note 1.

Figure 3-2, Station Response With External Interface- Removed 2 Chemistry Technician positions, one each at Hope Creek and Salem.

3

LR-N19-0099 b) As the duty of the driver is proposed to be assigned to the OSC Radwaste Operator at the unaffected station (if needed), there is no impact on the RP major functional area.

4

LR-N19-0099 Enclosure 1 Emergency Plan Marked-Up Pages

the Maintenance Department for normal assignments and supervision but receives on shift direction from the shift maintenance supervisor in coordination with the SM concerning priority repairs to support plant operations.

2.5 Technical The Technical Engineers with specialties in controls, electrical, mechanical, and core thermal engineering are assigned to the Technical Support Team. The PSEG Nuclear, LLC plant technical support provides primary system engineering support during normal operations.

2.6 Security Organization The on-duty Security Shift Manager and the Security Force are responsible for station security. Security personnel are assigned in accordance with the PSEG Nuclear Security Plan and report to the Manager Security Operations for normal assignments and directions, but receive on-shift direction from the Shift Manager, concerning special access control requirements or accountability.

2.7 Radiation Protection/Chemistry Organization The Salem and Hope Creek Generating Stations back-shift Radiation Pro tection/Chem istry Organization consists of one Shift Radiation Protection Technician (SRPT) and one Onshift Radiation Protection Technician (ORPT), who is directed by the SRPT, and one Chemistry Technician.

When Radiation Protection Supervision is not present, the SRPT, ORPT, and any Radiation Protection Technicians (RPTs), who may be on shift, report to the SM.

Radiation Protection personnel on the back-shift are normally responsible for con ducting routine and special surveys, operating counting room instrumentation, maintaining access control at the Control Points, writing Radiation Work Permits, and providing job coverage as required.

The Chemistry Technicians are the members of the Station Chemistry Department who are responsible for performing reactor coolant chemistry sampling and analysis.

This position reports to the Chemistry Department for normal assignments and supervision, but receives on-shift direction from the SM concerning sampling required to support station operations.

During an Emergency, Chemistry Supervisors and technicians report to the SM, until the TSC is activated. The Chemistry Supervisor(s) and technicians report to the Radiological Assessment Coordinator (RAC), upon activation of the TSC.

PSEG NUCLEAR LLC - EP 3.3 Rev.31

C.5.A OSC Radwaste Operator C.5.8 Nuclear Tech - Mechanical C.5.C This designator is no longer used C.5.D Controls Tech Electrical C.5.E Controls Tech - I&C These OSC Support Team Members report to their respective OSC Supervisors at the OSC. Assignments and responsibilities vary, but all disciplines provide general technical and specialist support as requested.

Members are frequently assigned to corrective actions and repair teams.

Duties:

1) Activate or monitor equipment.

.f} Assess damage, determine condition, or report status of plant/plant equipment.

e- Receive direction from the Maintenance Supervisor.

.1). The Radwaste Operator (C.5.A) at the unaffected station should support the affected station's RP with onsite/offsite monitoring (driver). if needed.

C.6 Fire Brigade The Fire brigade reports to the OSCC and provides fire protection support to the Station.

Duties:

1) Provide fire fighting and first aid support.

2) Conduct search and rescue operations.

3) Conduct survey, repair and corrective actions.

C.7 On-Shift Stock Handler The On-Shift Stock Handler reports to the OSCC to provide material control support to the OSC.

Duties:

1) Supply/obtain support materials as needed for OSC activities.

PSEG NUCLEAR LLC - EP 3.16 Rev. W 31

5) Coordinates sample results with the Core Thermal-Hydraulics Engineer and the Technical Support Team Leader.

6) Initiates sample log.

7) Augments Chemistry Staff when necessary.

8) Coordinates with Core Thermal-Hydraulics Engineer in the TSC.

E.6 Chemistry Technician (CT)

The CT will assist and advise the Chemistry Supervisor with respect to sampling activities from the Control Point.

Duties:

1) Directs and coordinates high activity samples, main steam sampling, and analysis of samples.

2) Disassembles, assembles, and operates the multi-channel analyzer.

3) Establishes backup laboratory facility (Hope Creek Count Room for Salem and Salem for Hope Creek).

4) Coordinates activation of high activity sampling systems and necessary ventilation systems in those areas if the TSC is not activated.

5) CT at the unaffected station should support the affected stations CT and if needed, support RP with onsite/offsite monitoring (driver).

9.6 F. PLANT SYSTEMS ASSESSMENT AND ENG INEER ING F.1 Technical Support Supervisor (TSS)

The TSS has overall responsibility for tracking and trending plant conditions, identifying plant condition EALs, and providing advice on PARs to the EDO, and when the EOF is activated, the SSM. The TSS is the lead evaluator and decision maker for the Severe Accident team.

Duties:

1) The TSS reports to the EDO.

2) The TSS evaluates the potential for an offsite radiological release based upon plant conditions in accordance with EALs. Prior to activation of the EOF, these evaluations are provided to the EDO for action. After activation of the EOF, these evaluations are provided to the SSM for action and the EDO for information.

PSEG NUCLEAR LLC - EP 3.25 Rev.31

TABLE 3-2 PSEG NUCLEAR CORRELATION TO SUPPLEMENT 1 OF NUREG-0737 TABLE 2 (NUREG-0654, TABLE B-1) (Note2)

(NUREG- On* Capabilities for Additions 90 min 0654, TABLE Shift Major Tasks Position Title or Expertise B-1) (Note 1)

Major Functional Area Plant Operations Shift Manager (SM) (SRO) 1 A4 and Assessment of Operational Aspects 1B2 Control Room Supervisor (CRS) (SRO)

Reactor/Plant Operator 2B3 (RO/PO)

Nuclear Equipment 2B5 Operator (NEO)

Emergency Direction and 1**A4 Control Shift Manager (SM)(SRO)

(Emergency Coordinator Notification/ Notify Licensee, Control Room 2B4 Communication State, Local and Communicator Federal personnel and maintain TSC&EOF 2 F8 &2 15 (TSC & EOF communication Communicators Communicators)

Radiological EOF- Manager Emergency Response 1A1 (Emergency Response Mgr)

Accident Manager (ERM)***

Assessment and Offsite Dose Support of Assessment Shift RP Tech 1 E4 (Note 3) 2E1 (RACs)

Operational (SRPT)/RP Supervisor-Accident Offsite Assessment Offsite Surveys Technician (RPT) (Note 9) 4D4 (Offsite Monitors/Drivers)

Onsite (out-of-plant) Technician (RPT) 1 E3 (Note 5) 1E2A (RPS Offsite)

I CSA £6-(Note 5)

In-plant Surveys Technician (RPT) 2 E3 (Note 5) 1E3 (Callout RPT)

Chem/Radio-chemistry Technician (CT) -!--B{} 1E5 (Chemistry Supv)

PSEG NUCLEAR LLC EP - 3.4 0 Rev. 31

TABLE 3-2 (cont.}

PSEG NUCLEAR CORRELATION TO SUPPLEMENT 1 OF NUREG-0737 TABLE 2 (NUREG-0654, TABLE B-1} (Note 2)

On* Capabilities for Major Functional Shift Additions 90 min Area Major Tasks Position Title or Expertise (Note 1)

Site Access Control Security, Fire Security Personnel All per Security Plan Local and State Support and Personnel Fighting, Accountability Communications, Personnel Accountability Total Staffing: 27 20 Notes:

For each unaffected nuclear unit in operation, maintain at least one Control Room Supervisor, one Reactor/Plant Operator and one Equipment Operator.

May be provided by Shift personnel assigned other functions. Staffing designated with double asterisk is not counted in "Total Staffing" values at end of table.

Overall directions of facility response to be assumed by EOF Emergency Response Manager when all facilities are fully manned & activated.

Note 1: Thirty (30) - minute responder positions in NUREG- 0737, Table 2, Supplement 1, are addressed in the "On-Shift" staffing column. There is not a 30 - minute callout process.

Note 2: This chart provides a table that correlates the emergency response organization to the position guidance of Table 2, NUREG-0737, Supplement 1. Staffing response times are as discussed in Section 9 of the Emergency Plan.

Note 3: Will be performed by the Shift Radiation Protection Technician (E4) until relieved by the Radiation Protection Supervisor - Offsite.

Note 4: Advisory function will be performed by Shift Technical Advisor (STA) until relieved by Core/Thermal Hydraulics Engineer.

Note 5: Additional personnel available from the unaffected station to support In-plant activities.

Note 6: At Hope Creek, the STA can also be assigned the duties of the Control Room Supervisor or Shift Manager in accordance with technical specification provisions.

Note 7: Individuals who are radiation worker qualified may fill this position.

Note 8: An onshift Nuclear Equipment Operator (Salem) or Rad Waste Operator (Hope Creek) may concurrently fill the Mechanical Maintenance/Rad Waste Operator position until relieved.

Note 9: Offsite surveys may be performed by onsite field monitoring personnel until the offsite field monitoring team members report to the EOF.

PSEG NUCLEAR LLC - EP 3.4 2

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LR-N19-0099 Enclosure 2 Emergency Plan Clean Copy Pages

the Maintenance Department for normal assignments and supervision but receives on shift direction from the shift maintenance supervisor in coordination with the SM concerning priority repairs to support plant operations.

2.5 Technical The Technical Engineers with specialties in controls, electrical, mechanical, and core thermal engineering are assigned to the Technical Support Team. The PSEG Nuclear, LLC plant technical support provides primary system engineering support during normal operations.

2.6 Security Organization The on-duty Security Shift Manager and the Security Force are responsible for station security. Security personnel are assigned in accordance with the PSEG Nuclear Security Plan and report to the Manager Security Operations for normal assignments and directions, but receive on-shift direction from the Shift Manager, concerning special access control requirements or accountability.

2.7 Radiation Protection/Chemistry Organization The Salem and Hope Creek Generating Stations back-shift Radiation Protection Organization consists of one Shift Radiation Protection Technician (SRPT) and one Onshift Radiation Protection Technician (ORPT), who is directed by the SRPT.

When Radiation Protection Supervision is not present, the SRPT, ORPT, and any Radiation Protection Technicians (RPTs), who may be on shift, report to the SM.

Radiation Protection personnel on the back-shift are normally responsible for conducting routine and special surveys, operating counting room instrumentation, maintaining access control at the Control Points, writing Radiation Work Permits, and providing job coverage as required.

The Chemistry Technicians are the members of the Station Chemistry Department who are responsible for performing reactor coolant chemistry sampling and analysis.

This position reports to the Chemistry Department for normal assignments and supervision, but receives on-shift direction from the SM concerning sampling required to support station operations.

During an Emergency, Chemistry Supervisors and technicians report to the SM, until the TSC is activated. The Chemistry Supervisor(s) and technicians report to the Radiological Assessment Coordinator (RAG), upon activation of the TSC.

PSEG NUCLEAR LLC - EP 3.3 Rev. 31

C.5.A OSC Radwaste Operator C.5.B Nuclear Tech - Mechanical C.5.C This designator is no longer used C.5.D Controls Tech Electrical C.5.E Controls Tech - I&C These OSC Support Team Members report to their respective OSC Supervisors at the OSC. Assignments and responsibilities vary, but all disciplines provide general technical and specialist support as requested.

Members are frequently assigned to corrective actions and repair teams.

Duties:

1) Activate or monitor equipment.

2) Assess damage, determine condition, or report status of plant/plant equipment.

3) Receive direction from the Maintenance Supervisor.

4) The Radwaste Operator (C.5.A) at the unaffected station should support the affected station's RP with onsite/offsite monitoring (driver), if needed.

C.6 Fire Brigade The Fire brigade reports to the OSCC and provides fire protection support to the Station.

Duties:

1) Provide fire fighting and first aid support.

2) Conduct search and rescue operations.

3) Conduct survey, repair and corrective actions.

C.7 On-Shift Stock Handler The On-Shift Stock Handler reports to the OSCC to provide material control support to the OSC.

Duties:

1) Supply/obtain support materials as needed for OSC activities.

PSEG NUCLEAR LLC - EP 3.16 Rev. 31

5) Coordinates sample results with the Core Thermal-Hydraulics Engineer and the Technical Support Team Leader.

6) Initiates sample log.

7) Augments Chemistry Staff when necessary.

8) Coordinates with Core Thermal-Hydraulics Engineer in the TSC.

E.6 Chemistry Technician (CT)

The CT will assist and advise the Chemistry Supervisor with respect to sampling activities from the Control Point.

Duties:

1) Directs and coordinates high activity samples, main steam sampling, and analysis of samples.

2) Disassembles, assembles, and operates the multi-channel analyzer.

3) Establishes backup laboratory facility (Hope Creek Count Room for Salem and Salem for Hope Creek).

4) Coordinates activation of high activity sampling systems and necessary ventilation systems in those areas if the TSC is not activated.

9.6 F. PLANT SYSTEMS ASSESSMENT AND ENG INEER ING F.1 Technical Support Supervisor (TSS)

The TSS has overall responsibility for tracking and trending plant conditions, identifying plant condition EALs, and providing advice on PARs to the EDO, and when the EOF is activated, the SSM. The TSS is the lead evaluator and decision maker for the Severe Accident team.

Duties:

1) The TSS reports to the EDO.

2) The TSS evaluates the potential for an offsite radiological release based upon plant conditions in accordance with EALs. Prior to activation of the EOF, these evaluations are provided to the EDO for action. After activation of the EOF, these evaluations are provided to the SSM for action and the EDO for information.

3) The TSS provides advice to the EDO on priorities for plant repair and corrective actions.

PSEG NUCLEAR LLC - EP 3.25 Rev. 31

TABLE 3-2 PSEG NUCLEAR CORRELATION TO SUPPLEMENT 1 OF NUREG-0737 TABLE 2 (NUREG-0654, TABLE B-1 ) (Note 2)

(NUREG- On* Capabilities for Additions 90 min 0654, TABLE Shift Major Tasks Position Title or Expertise B-1) (Note 1)

Major Functional Area Plant Operations Shift Manager (SM) (SRO) 1 A4 and Assessment of Operational Aspects 1B2 Control Room Supervisor (CRS) (SRO)

Reactor/Plant Operator 2B3 (RO/PO)

Nuclear Equipment 2B5 Operator (NEO)

Emergency Direction and 1**A4 Control Shift Manager (SM)(SRO)

(Emergency Coordinator Notification/ Notify Licensee, Control Room 2B4 Communication State, Local and Communicator Federal personnel and maintain TSC&EOF 2 F8 &2 15 (TSC & EOF communication Communicators Communicators)

Radiological EOF- Manager Emergency Response 1A1 (Emergency Response Mgr)

Accident Manager (ERM)***

Assessment and Offsite Dose Support of Assessment Shift RP Tech 1 E4 (Note 3) 2E1 (RACs)

Operational (SRPT)/RP Supervisor-Accident Offsite Assessment Offsite Surveys Technician (RPT) (Note 9) 4D4 (Offsite Monitors/Drivers)

Onsite (out-of-plant) Technician (RPT) 1 E3 (Note 5) 1E2A (RPS Offsite) 1 C5A (Note 5)

In-plant Surveys Technician (RPT) 2 E3 (Note 5) 1E3 (Callout RPT)

Chem/Radio-chemistry Technician (CT) 1E5 (Chemistry Supv)

PSEG NUCLEAR LLC - EP 3.4 0 Rev. 31

TABLE 3-2 (cont.)

PSEG NUCLEAR CORRELATION TO SUPPLEMENT 1 OF NUREG-0737 TABLE 2 (NUREG-0654, TABLE B-1) (Note 2)